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Roundtable on Sustainable Palm Oil Certification Audit Report no.: 824 502 16041 Certification Assessment against the RSPO Principles & Criteria Generic 2013 and RSPO Supply Chain Certification System Nov 2014 PT Perkebunan Nusantara III Rambutan Palm Oil Mill and Supply Based Jln. Sei Batang hari No. 2 Medan, 20122 North Sumatera, Indonesia Date of assessment : May 18 – 21, 2015 Re-assessment on October 25, 2016 Report prepared by : Mhd Fundy Cholis Kurniawan (RSPO Lead Auditor) Certification Decision by : Dian Soesanty Soeminta (General Manager of Sustainaibility Assurance) Certification Body : PT TUV Rheinland Indonesia. Menara Karya Building 10 th floor Jl. H.R. Rasuna Said Block X-5 Kav.1-2, Jakarta, Indonesia. 12950 Tel: +62 21 579 44 579 Fax: +62 21 579 44 579 www.tuv.com

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Page 1: Roundtable on Sustainable Palm Oil - TÜV Rheinland · 2020-05-31 · Roundtable on Sustainable Palm Oil Certification Audit Report no.: 824 502 16041 Certification Assessment against

Roundtable on Sustainable Palm Oil

Certification Audit Report no.: 824 502 16041

Certification Assessment against the

RSPO Principles & Criteria Generic 2013 and

RSPO Supply Chain Certification System Nov 2014

PT Perkebunan Nusantara III

Rambutan Palm Oil Mill and Supply Based

Jln. Sei Batang hari No. 2 Medan, 20122 North Sumatera, Indonesia

Date of assessment : May 18 – 21, 2015

Re-assessment on October 25, 2016

Report prepared by :

Mhd Fundy Cholis Kurniawan (RSPO Lead Auditor)

Certification Decision by : Dian Soesanty Soeminta

(General Manager of Sustainaibility Assurance)

Certification Body : PT TUV Rheinland Indonesia.

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

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

www.tuv.com

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TABLE OF CONTENTS

TABLE OF CONTENTS.................................. ........................................................................................................ 2

1.1 National Interpretation / Standard Used ............................................................................................................ 3

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

1.3 Certification Details ........................................................................................................................................... 3

1.4 Location and Maps ............................................................................................................................................ 3

Figure 1: Location of Rambutan Palm Oil Mill and 5 company-owned estates within its supply base .................... 5

Figure 2.a: Map of Gunung Monaco Estate ............................................................................................................ 6

Figure 2.b: Map of Sei Putih Estate ........................................................................................................................ 7

Figure 2.c : Map of Sarang Giting Estate ................................................................................................................ 8

Figure 2.d : Map of Silau Dunia Estate ................................................................................................................... 9

Figure 2.e : Map of Tanah Raja Estate ................................................................................................................. 10

1.5 Organisational Information / Contact Person .................................................................................................. 10

1.6 Description of Supply Base ............................................................................................................................. 10

1.7 Actual production volumes and project outputs. ............................................................................................. 11

Note: *) certified product will claimed based on production budget 2016 for IP product ....................................... 12

1.8 Dates of Plantings and Replanting Cycles ...................................................................................................... 12

1.9 Area of Plantation (Total, Planted and Mature) ............................................................................................... 12

1.10 Progress against Time Bound Plan ............................................................................................................... 13

1.11 Audit against the rules for Partial Certification .............................................................................................. 14

1.12 Progress of associated smallholders or outgrowers towards RSPO compliance ......................................... 14

1.13 Approximate Tonnages Certified ................................................................................................................... 14

The approximate tonnages certified, based on projection year 2016 for company owned estates only (refer to the table above as follows: .......................................................................................................................................... 14

1.14 Recommendation for RSPO Princilples and Criteria and Supply Chain Certification ................................... 15

2.0 ASSESSMENT PROCESS ............................................................................................................................. 16

2.1 Certification Body ............................................................................................................................................ 16

2.2 Qualifications of Lead Assessor and Assessment Team ................................................................................ 16

2.3 Assessment Methodology & Agenda .............................................................................................................. 17

3.0 ASSESSMENT FINDINGS ............................................................................................................................. 23

3.1 Summary of Findings pertaining to RSPO Principles & Criteria ...................................................................... 23

3.2 Identified Non-conformances against RSPO P&C Requirements, Corrective Actions Taken and Auditors Conclusions........................................................................................................................................................... 44

3.3 Description of Supply Chain Management System ......................................................................................... 48

3.5 Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions........................................................................................................................................................... 50

3.6 Noteworthy Positive Components ................................................................................................................... 50

3.7 Issues Raised during Stakeholder Consultation Meeting ............................................................................... 50

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INT ERNAL RESPONSIBILITY ..................... 58

4.1 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client ................................................ 58

APPENDICES ....................................................................................................................................................... 59

Appendix 1: Details of Certificate .......................................................................................................................... 59

Appendix 2: List of Abbreviations .......................................................................................................................... 61

Appendix 3: List of Stakeholders Interviewed and Contacted ............................................................................... 62

Appendix 4: Attendend list of stakeholder consultation meeting ........................................................................... 63

Appendix 5: Observations and Opportunities for Improvement ............................................................................ 66

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RSPO Certification Assessment PT Perkebunan Nusantara III – Rambutan Palm Oil Mil l

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1.1 National Interpretation / Standard Used The operations of the palm oil mill(s) and its supply base of FFB were assessed against RSPO Principle and Criteria Generic year 2013 and the RSPO Supply Chain Certification Systems (SCCS) document (November 2014).

1.2 Type of Assessment The certification assessment audit carried out on 1 (one) mill and 5 (five) company estates to this mill, which are Tanah Raja Estate, Gunung Monaco Estate, Silau Dunia Estate, Sarang Giting Estate and Sei Putih Estate owned by PT Perkebunan Nusantara III (PT PN III). The date of certification of this unit was May 18 – 21, 2015. During the certification audit, Rambutan palm oil mill was applied Identity Preserve (IP) supply chain model of Rambutan Palm Oil Mill. However until the timeline of closing NCR, Rambutan mill could not meet requirement for IP due to the nature of supply based on rambutan mill still receive non certified FFB from other sources, PT PN III Top Management issued Management decree, No.3.03/SKPTS/02/2015 dated on December 31, 2015, whereas this decree letter explaine and signed that Rambutan Palm Oil mill replaced the IP supply chain model into MB supply chain model. It was showed on production record process until May 2016 showed that Rambu-tan Palm Oil Mill still received non certified FFB from others estate and mixed the process with certified materi-al. Because NCR closing processing take long time by the auditee related government process, to the certification body carried out the re-assessment to update the auditee data, while the re-assessment carried out on October 2016 by two auditor from TUV Rheinland Indonesia.

1.3 Certification Details The details of RSPO certification of Rambutan Palm Oil Mill are as per the table below Table 1: RSPO Certification details of Rambutan Pal m Oil Mill

RSPO Membership No. 1-0030-06-000-00

RSPO Certificate No. 824 502 16041

Date of first RSPO certificate & validity September 01, 2016 to August 31, 2021

Date of certification audit May 18 to 21, 2015

Date of surveillance audit This is certification assessment

Certified FFB processed in 2015 125,777.740

CPO tonnages claimed 33,370.04 mt

PK tonnages claimed 7,003.67 mt

Mil Capacity 60 mt/hours

1.4 Location and Maps

Table 2: GPS locations for all estates and mills in cluded in annual certification assessment

Name of Mill / Estate

Location GPS locations

Latitude Longtitude

Rambutan Mill Paya Bagas village, Tebing Tinggi sub-district, Deli Serdang district, North Su-matra Province.

03°22’ 36” 99°09’56”

Tanah Raja Tanah Raja village, Teluk Mengkudu subdistrict, Serdang Bedagai district, North Sumatra Province.

03o 32’ 03’’ 99o 02’50”

Gunung Monaco Siberau village, Sipispis subdistrict, Serdang Bedagai district, North Suma- 03o13’31’’ 98o 59’ 60”

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tra Province.

Silau Dunia

Silau Badar – I village, Dolok Masihul subdistrict, Serdang Bedagai district; Si-lau Dunia village, Silau Kahaen subdis-trict, Simalungun district; Ujung Negeri Hulu village, Kotarih subdistrict, Deli Serdang district, North Sumatra Prov-ince.

03o17’00’’ 98o57’16,2”

Sarang Giting

Sarang Giting village, Dolok Masihul subdistrict, Deli Serdang district; Serba-jadi village, Serbajadi subdistrict, Se-dang Bedagai district, North Sumatra Province.

03o20’33’’ 98o 58’35”

Sei Putih Sungai Putih village, Galang subdistrict, Deli Serdang district, North Sumatra Province.

03o 24’ 35’’ LU 98o 52’ 58” BT

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Figure 1: Location of Rambutan Palm Oil Mill and 5 company-owned estates within its supply base

Assessment location split

into 3 districts : 1. Serdang Bedagai District 2. Deli Serdang District 3. Simalungun District

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Figure 2.a : Map of Gunung Monaco Estate

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Figure 2.b : Map of Sei Putih Estate

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Figure 2.c : Map of Sarang Giting Estate

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Figure 2.d : Map of Silau Dunia Estate

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Figure 2.e : Map of Tanah Raja Estate

1.5 Organisational Information / Contact Person Contacts details of the company are as followed:

Company Name: PT Perkebunan Nusantara III (Rambutan Palm Oil Mill)

Address: Jln. Sei Batang hari No. 2 Medan, North Sumatra Province – Indonesia

Contact Person: Tio Handoko, ST, MM

Telephone: +62 61-8452244/+62 81 264 575 552

Email: [email protected]/ [email protected]

1.6 Description of Supply Base Rambutan Palm Oil Mill (POM) is one of several palm oil mills owned by PT Perkebunan Nusantara 3, and is located in Paya Bagas village, Tebing Tinggi subdistrict, Deli Serdang District, North Sumatra Province. Cur-rently, Rambutan POM receives FFB supplies from 5 company-owned estates, and these are Tanah Raja Es-tate, Gunung Monaco Estate, Silau Dunia Estate, Sarang Giting Estate, Sei Putih Estate. Rambutan Palm Oil Mill also receives FFB supplies from other’s company estate under PT PN III such as Gunung Pamela estate, Gunung Para Estate and Rambutan estate. The FFB supplies received from company-owned estates and other’s company estate under PT PN III are as described below:

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Table 3: FFB Supply Information for Rambutan Palm O il Mill year 2015 and 2016 (Projection) 3.a FFB Supply Information from Rambutan Palm Oil M ill during certification assessment

FFB Contributors FFB Supplied 2015 FFB Supplied 2016*

Tonnes % Tonnes % Certified Source Mil l Supply Based Tanah Raja Estate 34,157.930 17.61 36,845.000 18.18 Sei Putih Estate 6,632.330 3.42 6,735.000 3.32 Sarang Giting Estate 10,167.120 5.24 9,630.000 4.75 Silau Dunia Estate 33,390.690 17.22 33,950.000 16.75 Gunung Monaco Estate 41,429.670 21.36 45,737.000 22.56 Sub Total 125,777.740 64.85 132,897.000 65.57 Others Certified Estate under PT PN III Rambutan Estate 36,545.440 18.84 37,944.200 18.72 Gunung Para Estate 9,288.890 4.79 7,501.200 3.70 Gunung Pamela Estate 22,326.200 11.51 23,810.630 11.74 Sub Total 68,160.530 35.14 69,756.030 34.42 Non Certified Source Independent outgrower - - - - Total 193,938.270 100 202,653.030 100

Note: *) Projection production for 2016 3.b FFB Supply Information from Rambutan Palm Oil M ill during re-assessment for data update

FFB Contributors FFB Supplied 2016* FFB Supplied 2016* Tonnes % Tonnes %

Certified Source Mill Supply Based Tanah Raja Estate 20,233.44 2.79 36,845.000 18.18 Sei Putih Estate 3,646.00 15.50 6,735.000 3.32 Sarang Giting Estate 6,352.56 4.87 9,630.000 4.75 Silau Dunia Estate 19,908.96 15.25 33,950.000 16.75 Gunung Monaco Estate 29,512.13 22.61 45,737.000 22.56 Sub Total 79,653.09 61.03 132,897.000 65.57 Others Certified Estate under PT PN III Rambutan Estate 26,458.09 20.27 37,944.200 18.72 Gunung Para Estate 4,695.06 15.10 7,501.200 3.70 Gunung Pamela Estate 19,703.76 3.60 23,810.630 11.74 Sub Total 50,856.91 38.97 69,756.030 34.42 Non Certified Source Independent outgrower - - - - Total 130,510.00 100 202,653.030 100

Note: *) FFB realization for 2016 until September

1.7 Actual production volumes and project outputs. This is certification assessment, the PT PN III did not sold any RSPO certified product (CPO and PK), as viewed from the table below.

Table 4: Total and projected CPO and PK production from Rambutan Palm Oil Mill

Remarks Amount

CPO (mt) PK (mt) Certified tonnage claimed *) 33,370.04 7,003.67 Total product tonnage sold claimed under RSPO e-Trace - - Certified tonnage sold claimed under Green palm - - Certified tonnage purchased - -

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Actual prouction in 2015 Actual OER and KER for 2015 25.47 5.47 Total production for 2015 49,396.07 10,608.42 Total Certified production for 2015 **) 32,035.59 6,880.04 Projection Production for 2016 OER and KER projection for 2016 25.11 5.27 Total FFB process projection for 2016 (mt) 202,653.030 Total FFB certified projection for 2016 (mt) 132,897.000 CPO certified projection production for 2016 (mt) 33,370.04 PK certified projection production for 2016 (mt) 7,033.67 CPO total (mt) 50,886.17 PK total (mt) 10,679.81

Note: *) Certified product will claimed based on production budget 2016 for IP product **) Total certified production from mill supply based only in 2015

1.8 Dates of Plantings and Replanting Cycles The company follows a replanting cycle of 25 years. Information on the dates of plantings are as per the ta-ble below.

Table 5: Age and year of plantings of company estat es supplying to Rambutan Palm Oil Mill Period

year 2015

Age & Year of

Plantings

Oil palm planted area at each estate(ha) Kebun Tanah Raja

Kebun Sei

Putih

Kebun Sarang Giting

Kebun Silau Dunia

Kebun Gunung Monako

2016-2012 48.65 - 41.20 - - 2011-2007 159.38 - 47.80 86.76 49.45 2006-2002 978.89 - - 457.15 756.72 2001-1997 - 286.10 382.25 1,008.27 1,148.30 1996-1992 912.20 20.00 - 80.05 21.15 1991-1987 - - - - - 1986-1992 - - - - - TOTAL 2,099.12 306.10 471.25 1,632.23 1,975.62

Table 6: Planned and actual oil palm replanting act ivities for company-owned estates supplying to

Rambutan Palm Oil Mill

Total planned replanting area for each estate

(ha)

Total planned

replanting area (ha)

Year Actual to-tal area

replanted (ha)*

2015 2016 2017 2018 2019

Tanah Raja 366.7 - 240 126.70 - - -

Sei Putih - - - - - - -

Sarang Giting - - - - - - -

Silau Dunia - - - - - - -

Gunung Monako - - - - - - -

1.9 Area of Plantation (Total, Planted and Mature)

Table 7: Oil Palm Planted Area Summary, FFB Product ion and Average yield/ha for PTPN III company

owned estates

Estate Name Total area

(ha)

Oil Palm Planted area

(ha)

Mature (Production)

area (ha)

Immature (Non-production)

area (ha)

FFB Production

Average yield/ ha

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(ton) (ton/ha)

Tanah Raja 3,360.07 2,099.12 2,050.47 48.65 34,157.93 16.66 Sei Putih 2,694.49 306.01 306.01 - 6,632.33 21.67 Sarang Giting 3,051.72 471.25 430.05 41.20 10,167.12 23.64 Silau Dunia 4,963.62 1,632.23 1,632.23 - 33,390.69 20.48 Gunung Monako 2,322.77 1.975,62 1.975,62 - 41,429.67 23.49 TOTAL 16,392.67 4,508.61 4,418.76 89.85 125,777.74 21.18

Table 8: Land use data for PT PN 3 Company’s owned estates

Estate Name Total area (ha)

Rubber Planted Area (ha)

Oil Palm Planted Area (ha)

HCV/ Potential HCV areas* (ha)

Land used for other purposes (ha)

Housing, Road, other infrastruc-

ture

Nursery Cleared Area

Other Land

Tanah Raja 3,360.07 1,115.17 2,099.12 30.39 122.35 - - 23.43 Sei Putih 2,694.49 2,307.53 306.01 22.49 238.17 - - 148.79 Sarang Gitting 3,051.72 2,274.08 471.25 10.56 233.07 - - 73.32 Silau Dunia 4,963.62 2,451.75 1,632.23 453.73 152.95 - - 726.69 Gunung Monako 2,322.77 - 1.975,62 189.11 145,15 - - 202.00 TOTAL 16,392.67 8,148.53 4,508.61 706.28 746.54 - - 1,174.23

Note: *) all of HCV area above part of planted area 1.10 Progress against Time Bound Plan

The company has revised their time bound plan for RSPO certification of other management units as per the schedule below. The plan was revised as the company was awaiting RSPO certification of Sei Mangke mill and its supply base and is applying experience gained from the first certification to prepare other manage-ment units for certification. Table 9: Time Bound Plan of the Other Management Un its

Holding Name Location Time bound plan for certification

Status

PKSMK Sei Mangke / Simalungun August 2010 Certified

PRBTN Tebing Tinggi May 2015 In-process

PSSIL Sei Silau / Asahan May 2015 In-process

PANAS Aek Nabara / Labuhan Batu May 2014 Certified

PSSUT Sisumut / Labuhan Batu May 2015 Certified

PSBAR Sei Baruhur/ Labuhan Batu November 2014 Certified

PPARO Aek Raso/ Labuhan Batu June 2014 Certified

PTORA Torgamba/ Labuhan Batu June 2015 In-process

PATOR Aek Torop/ Labuhan Batu June 2014 Certified

PSDAN Sei Daun/ Labuhan Batu June 2015 Certified

PSMTI Sei Meranti/ Labuhan Batu June 2015 In-process

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Hapesong Mill Tapanuli Selatan November 2016 Planned

1.11 Audit against the rules for Partial Certificat ion

Compliance of the PT PN III against the rules for partial certification according to RSPO certification system year 2013 Generic, clause 4.2.4 was assessed through document checks and interviews and the head office and through findings of concurrent ISO:9001 checks conducted at other management units of PTPN III. A summary of findings is as stated below.

Partial Certification Requirements Audit Findings

1.a The organisation is an RSPO member.

Yes, PTPN III is an RSPO member with ID No. 1-0030-06-000-00 (membership since December 14, 2006). RSPO Cer-tification system section 4.2.4. PTPN III has been provide result of the self-assessment for all units entering estate and mill at the time bound.

1.b A time-bound plan for achieving certification of all relevant entities;

PTPN III has a time-bound plan to achieve RSPO certification for all relevant entities. However, one of the company’s de-velopment areas (Muara Upu site) located at South Tapanuli is still not included by the time-bound plan. NPP assessment for this area was carried out by Certification Body (Sucofindo) in 2012 years.

1.c. i. There are no significant land con-flicts.

There are some land conflicts/ potential land conflicts ongo-ing in other PTPN III’s management units, such as Silau Dunia, and Si Sumut Estates. While the company has al-ready made a conflict resolution mechanism, these conflicts remain unresolved as the mechanism is still not agreed by the land claimants.

1.c. ii. No replacement of primary forest or any area containing HCV since November 2005.

PTPN III’s development of a new planting area (Muara Upu at South Tapanuli) had been raised before as a major non-compliance by TUV Rheinland audit team, which is now closed as the company has carried out applying NPP in ac-cordance with this clause and the progress under reviewing of Compensation Task Force. Based on communication with PT PN III. The company still waiting for Head of District deci-sion response, for land exchanged process since the land was included on peat moratorium area according to President of Republic Indonesia decree letter no. 6 year 2013.

1c. iii. No labour dispute that are not be-ing resolved through an agreed process.

No labour issues were found during this certification audit.

1c.iv. No evidence of non-compliance with law in any of the non-certified holdings.

Some of PTPN III’s other management units have not com-plied with certain legal requirements. For example, in Silau Dunia Estate under another PTPN III management unit, an issue has been found with the area stated under the Right of Cultivation certificate (HGU). However, the company is taking action by inviting National Land Agency (BPN) to re-measure the land and resolve the issue. The process is still ongoing. Some legal non compliance found, it has been reported on surveillance audit report for each PT PN 3 unit.

1.12 Progress of associated smallholders or outgrow ers towards RSPO compliance

There is no scheme and or associated smallholder in Rambutan Palm Oil Mill its supply based estate. The requirement is not applied for this certification management unit.

1.13 Approximate Tonnages Certified

The approximate tonnages certified, based on projection year 2016 for company owned estates only (refer to the table above as follows: Crude Palm Oil (CPO) : 33,370,43 tonnes Palm Kernel (PK) : 7,003.67 tonnes

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1.14 Recommendation for RSPO Princilples and Criter ia and Supply Chain Certification Rambutan Palm Oil Mill and supply based has established and maintains an effective system to ensure compliance with the RSPO Principles and Criteria. The audit team has confirmed through the audit process that company practices complies with adequately maintains and implements the requirements of RSPO prin-ciples and criteria Generic 2013 and Supply Chain Certification System requirements (dated November 2014).

TUV Rheinland Indoneisa recommends that Rambutan Palm Oil Mill to be approved to get certification of compliance RSPO Certified Sustainable Palm Oil.

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2.0 ASSESSMENT PROCESS 2.1 Certification Body

TUV Rheinland Indonesia is member of Group TÜV Rheinland Group, a global leader in independent testing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 360 locations in 62 countries on all five continents. TUV Rheinland Indonesia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Project Validations and Verifications. TUV Rheinland Indonesia’s office is located in Jakarta, Indonesia.

2.2 Qualifications of Lead Assessor and Assessment Team The assessment team members of this certification assessment audit that were part of the same assess-ment team for the certification audit are as per the table below:

Name Position Qualifications / Experience

Mhd Fundy C Kurniawan

Lead auditor

Education: Master Degree in Natural Reseource and Environmental Management, Bogor Agriculture University Trainings attended: Environmental Impact Assessment (EIA), Ecologi-cal Risk Assessment (ERA), Internal Quality Audit Training for Quality Management System, IRQA-QMS ISO 9001:2000, IRQA-EMS 14001, High Conservation Value (HCV), RSPO Lead Auditor Course, ISPO Audi-tor Course, SCCS Auditor and ISCC plantation audit. Working experience: Experienced in Environmental Impact Assessment (EIA Assessment), Environmental Health Safety Senior Officer (EHS-Officer) in Wilmar International Plantation, Internal Auditor for Wilmar In-ternational Plantation, Auditor for Rountable on Sustainable Palm Oil (RSPO), Indonesian Sustainable Palm Oil (ISPO), Certification for Tim-ber Legality Verification (SVLK) in PT TUV Rheinland Indonesia since June 2012 – present.

Warsito Auditor

Education: Bachelor of Forestry, Nusa Bangsa University, Trainings attended: Indonesian Forestry Certification Cooperation (IFCC) Training, ISPO Auditor, Somatic Embryo Cacao Seed Handling Training, Sustainable Production Forest Management Auditor Training – Indonesian Ecolabel Institute (PHPL-LEI), Community Forest Assistant Training. Work Experience: Legal, Social, and Environment Manager in Industrial Forest for Rubber in PT Istana Kawi Kencana, Forest Expert, Head of Forest Planning Department, Geology Staff, PHPL Auditor, Forest Plan-ning Expert, and Auditor ISPO.

Mochamad Anwar Auditor

Education : Bachelor of Agriculture, Bogor Agricultural Institute Trainings attended : Indonesian Sustainable Palm Oil (ISPO) Auditor Training, Sustainable Forest Management (Bogor, 2013). Working Experience : Trainer for community development and entrepre-neurship projects and motivator for micro business entrepreneurship program since 1999, experience as expert of micro business develop-ment (1995-2006), team leader of community development program (2006-2012), program manager of corporate social rensponsibility in PT Aneka Tambang (2012) and PT Timah (2013), ISPO Auditor since 2014, SFM Auditor since 2013, Agriculture Expert for ANDAL and AMDAL since 2008

Suriadi Auditor

Education : Applied Analitycal Chemistry North Sumatra University, Me-dan and Bachelor of Chemical Engineering, University of Jaya Baya, Ja-karta. Trainings attended: ISO 9000:2000 Series Auditor / Lead Auditor Train-ing - PE International (Jakarta), IEMA Advanced EMS Auditor (IEMA /

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EARA ISO 14001) Auditor / Lead Auditor Training Course - PE Interna-tional (Jakarta), OHSAS 18001 Lead Auditor Training Course - PE Inter-national (Jakarta). ISPO lead auditor training. National Examination Board of Occupational Safety and Health (International General Certifica-tion (IGC) 1,2 and 3 TUV Nord (Dubai). National Examination Board of Occupational Safety and Health (International Technical Certification (ITC) for Oil and Gas Industries. RRC (Dubai). Indonesian Engineer As-sociation (PII) (Jakarta), Occupational Health and Safety Specialist for lifting equipments. Indonesia Man Power and Transmigration Department (Jakarta). Working experience: Experienced in Quality Control from 1992-2004. Coordinator for Safety Quality and EnvironmentManagement System since 2002 – present. Auditor for Environmental Management System since 2002 – present. Auditor for OHSAS 18001 since 2012 - present. Conducted over 10 Quality Management System audits Environmental Management System audits and OHSAS audits since 2012. RSPO and ISPO auditor since year 2014.

While the auditor did re-assessment verification was: 1. Mhd Fundy C Kurniawan 2. Hendra Fachrurozy The summary of new auditor who joined in re-assessment audit, presented below:

Name Position Qualifications / Experience

Hendra Fachrurozy

Auditor

Education: Bachelors Degree in Forestry - Bo-gor Agriculture Institute. Indonesia, (1995 to 2000). Trainings attended: ISO 9001:2008 lead auditor course - Neville Clark (2011); ISO 14001:2004 lead auditor course – TUV Rheinland Indonesia (2011); SMK3 auditor course – Department of Manpower and Transmi-gration of The Republic of Indonesia (2009); Sustainable Forest Man-agement (SFM) - Forest Stewardship Council (FSC) system training; Chain of Custody training for FSC System; Sustainable Forest Manage-ment (SFM) – Forestry Education and Training Centre (2010); Timber Legality of Verification – Forestry Education and Training Centre (2010); RSPO Lead Auditor Course – Pro Forest & Wild Asia (2011); SCCS RSPO by David Ogg Consulting (September 2012). Working experience: Experienced as Junior Consultant at PT Surveyor Indonesia (2002 s/d 2010), assessor for SFM –mandatory (PHPL & PHTL), assessor for industry performance as-sessment (IPHHK)-mandatory, auditor for Tim-ber Legality of Verification and CoC, auditor for SMK3, auditor for QMS and EMS and auditor for ISPO, RSPO & SCCS at TUV Rheinland In-donesia.

2.3 Assessment Methodology & Agenda The certification audit assessment combined with supply chain certification assessment was conducted from May 18 – 21, 2015 as per the assessment program below. The assessment was carried out in accordance with TUV Rheinland Indonesia RSPO audit procedure as well as the RSPO Certification Systems document and RSPO Supply Chain Certification Systems document. During assessment, the qualified TUV Rheinland assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was pos-sible to carry out both field and document assessments of all estates and the mill within the time frame with-out compromising the integrity of the assessment in anyway. All 5 estates and 1 mill were visited and the assessment team carried out field and document assessments of compliance to all the RSPO principles and criteria. Common systems were identified and specific evi-dence was recorded for individual estates. Interviews were conducted at all estates and the mill.

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The company proposed the correction and corrective action for all identified non conformities raised to the certification body more than 60 days after the closing meeting. Document checks to verify closure of major non-conformances was conducted and implementation of corrective actions for minor non-conformities will be verified during the next surveillance audit. The certifications assessment agenda is as explained below. Re-assessment has been carried out on October 25, 2016, due to the auditee/palm oil mill and estate take long time to close some nonconformity related license. This is becuase auditee need correspondency with official government. As impact, production record of the Rambutan Palm Oil Mill should be update, and the update data has presented in table above.

Certification Assessment Agenda

Date/Time Activity Auditor Auditee

RSPO Principle and Criteria Generic 2013 and Supply

Chain Certification System Nov 2014

Monday, May 18, 2015

05:35 - …. Flight Jakarta – Medan MK,WA, MA,SA - GA 180 (05:35 – 08.00 WIB)

09.00 - …. Opening meeting on PT PN III Head Of-fice in Medan MK Management PT PN III

09.30 - ….. Travelling to Rambutan Palm Oil Mill WA, MA, SA

-

09.30 – 15.00

Legal document verification: - Land use rights - Mill legality document - Conversion license - Policy - Code of Ethical Conduct - HCV - SIA - Law and regulation compliance - Economic feasibility, budget, and

production projection - SCCS

MK PT PN III Managerial

Principle 1 Criteria 1.3 Principle 2 Criteria 2.1; 2.2; 2.3 Principle 3 Criteria 3.1; 3.2 Principle 5 Criteria 5.2 Principle 6 Criteria 6.1 SCCS Module E (Palm Oil Mill)

12.00 – 13.30 Break and pray MK - - 15.00 - ….. Traveling to Rambutan palm oil mill MK - -

Rambutan Mill 13.30 – 18.00

Document verification and plant tour: - Law and regulation compliance - Procedure’s implementation and eval-

uation - Water management plan - Water used per tonnes FFB - HCV

MA Rambutan Mill Management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.1; 4.4. Principle 5 Criteria 5.2

Rambutan Mill 13.30 – 18.00

Document verification and plant tour: - OSH implementation - Workers insurance - Training program and implementation - EIA document and implementation - Waste management - Efficiency energy used per ton product

SA Rambutan Mill Management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.7; 4.8 Principle 5 Criteria 5.1; 5.3; 5.4

Rambutan Mill 13.30 – 18.00

Document verification and plant tour: - Transparency - Law and regulation compliance - Compensation and conflict resolution - Sosial Impact Assessment - Stakeholder communication and con-

sultation - Wage/salary - Union workers - Workers discrimination and chield la-

bour - Gender committee - Sexual harassment - Third party work agreement - Contribution to local community

WA Rambutan Mill Management

Principle1 Criteria 1.1; 1.2 Principle2 Criteria 2.1; 2.3 Principle6 Criteria 6.1; 6.2; 6.5; 6.6; 6.7; 6.8; 6.9, 6.10, 6.11; 6.12; 6.13

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Date/Time Activity Auditor Auditee

RSPO Principle and Criteria Generic 2013 and Supply

Chain Certification System Nov 2014

- Forced labour - Human rights policy

Rambutan Mill 13.30 – 18.00

Verifikasi dokumen dan lapangan: - Emission, pollution and greenhouse

gases identification - Continou improvement - SCCS Module E

MK Rambutan Mill Management

Principle 5 Criteria 5.6 Principle 8 SCCS Module E

18.00 - ….. End of 1st day audit Tuesday, May 19, 2015

07.30 – 12.00 Stakeholder consultation meeting All

auditor All stakhodlers related and invited -

Tanah Raja Estate

13.30 – 17.30

Document verification: - Code of ethical conduct - Economic feasibility/budget - Replanting plan if any - Land use rights - Fertilizing program and implementation - Soil erosion - HCV - Emission, pollution and greenhouse

gases identification - New planting if any - Continue improvement

MK Estate management

Principle 1 Criteria 1.3 Principle 3 Criteria 3.1; 3.2 Principle 4 Criteria 4.2; 4.3 Principle 5 Criteria 5.2; 5.6 Principle 7 Criteria 7.2; 7.3; 7.8 Principle 8

Tanah Raja Estate

13.30 – 17.30

Document verification: - Law and regulation compliance - Procedure’s implementation and eval-

uation - Water management plan and imple-

mentation - Integrated pest management - Pesticed record used - New planting if any - Continue improvement

MA Estate management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.1; 4.4; 4.5; 4.6 Principle 7 Criteria 7.4 ; 7.7 Principle 8

Tanah Raja Estate

13.30 – 17.30

Document verification: - Law and regulation compliance - OSH implementation - EIA document and implementation - Zero burning activity - Waste management - Training program and implementation - Enegry used per tonnes FFB - Continue improvement

SA Estate management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.7; 4.8 Principle 5 Criteria 5.1; 5.3; 5.4 Principle 8

Tanah Raja Estate

13.30 – 17.30

Document verification: - Transparency - Law and regulation compliance - Compensation and conflict resolution - Workers welfare - Kesejahteraan pekerja - Workers insurance - Wage/salary - Workers issue (gender, sex, religion

and others) - Forced labour - Works agreement - Workers union - New planting if any - Continue improvement

WA Estate management

Principle 1 Criteria 1.1; 1.2 Principle 2 Criteria 2.1; 2.3 Principle 6 Criteria 6.1 s/d 6.13 Principle 7 Criteria 7.1; 7.5; 7.6; Principle 8

12.00 – 13.20 Break and pray 17.30 - ….. End of 2nd day audit Wednesday, May 20, 2015

Gunung Monaco /

Silau Dunia Estate

08.00 – 12.00

Document verification: - Code of ethical conduct - Economic feasibility/budget - Replanting plan if any - Land use rights

MK Estate management

Principle 1 Criteria 1.3 Principle 3 Criteria 3.1; 3.2 Principle 4

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Date/Time Activity Auditor Auditee

RSPO Principle and Criteria Generic 2013 and Supply

Chain Certification System Nov 2014

- Fertilizing program and implementation - Soil erosion - HCV - Emission, pollution and greenhouse

gases identification - New planting if any - Continue improvement

Criteria 4.2; 4.3 Principle 5 Criteria 5.2; 5.6 Principle 7 Criteria 7.2; 7.3; 7.8 Principle 8

Gunung Monaco /

Silau Dunia Estate

08.00 – 12.00

Document verification: - Law and regulation compliance - Procedure’s implementation and eval-

uation - Water management plan and imple-

mentation - Integrated pest management - Pesticed record used - New planting if any - Continue improvement

MA Estate management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.1; 4.4; 4.5; 4.6 Principle 7 Criteria 7.4 ; 7.7 Principle 8

Gunung Monaco /

Silau Dunia Estate

08.00 – 12.00

Document verification: - Law and regulation compliance - OSH implementation - EIA document and implementation - Zero burning activity - Waste management - Training program and implementation - Enegry used per tonnes FFB - Continue improvement

SA Estate management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.7; 4.8 Principle 5 Criteria 5.1; 5.3; 5.4 Principle 8

Gunung Monaco /

Silau Dunia Estate

08.00 – 12.00

Document verification: - Transparency - Law and regulation compliance - Compensation and conflict resolution - Workers welfare - Kesejahteraan pekerja - Workers insurance - Wage/salary - Workers issue (gender, sex, religion

and others) - Forced labour - Works agreement - Workers union - New planting if any - Continue improvement

WA Estate management

Principle 1 Criteria 1.1; 1.2 Principle 2 Criteria 2.1; 2.3 Principle 6 Criteria 6.1 s/d 6.13 Principle 7 Criteria 7.1; 7.5; 7.6; Principle 8

12.00 – 13.30 Break and pray 13.30 – 17.30 Continue audit agenda 17.30 - ….. End of 3th day audit Thursday, May 21, 2015

Sarang Gitting / Sei Putih

Estate 08.00 – 12.00

Document verification: - Code of ethical conduct - Economic feasibility/budget - Replanting plan if any - Land use rights - Fertilizing program and implementation - Soil erosion - HCV - Emission, pollution and greenhouse

gases identification - New planting if any - Continue improvement

MK Estate management

Principle 1 Criteria 1.3 Principle 3 Criteria 3.1; 3.2 Principle 4 Criteria 4.2; 4.3 Principle 5 Criteria 5.2; 5.6 Principle 7 Criteria 7.2; 7.3; 7.8 Principle 8

Sarang Gitting / Sei Putih

Estate 08.00 – 12.00

Document verification: - Law and regulation compliance - Procedure’s implementation and eval-

uation - Water management plan and imple-

mentation - Integrated pest management - Pesticed record used - New planting if any

MA Estate management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.1; 4.4; 4.5; 4.6 Principle 7 Criteria 7.4 ; 7.7 Principle 8

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Date/Time Activity Auditor Auditee

RSPO Principle and Criteria Generic 2013 and Supply

Chain Certification System Nov 2014

- Continue improvement

Sarang Gitting / Sei Putih

Estate 08.00 – 12.00

Document verification: - Law and regulation compliance - OSH implementation - EIA document and implementation - Zero burning activity - Waste management - Training program and implementation - Enegry used per tonnes FFB - Continue improvement

SA Estate management

Principle 2 Criteria 2.1 Principle 4 Criteria 4.7; 4.8 Principle 5 Criteria 5.1; 5.3; 5.4 Principle 8

Sarang Gitting / Sei Putih

Estate 08.00 – 12.00

Document verification: - Transparency - Law and regulation compliance - Compensation and conflict resolution - Workers welfare - Kesejahteraan pekerja - Workers insurance - Wage/salary - Workers issue (gender, sex, religion

and others) - Forced labour - Works agreement - Workers union - New planting if any - Continue improvement

WA Estate management

Principle 1 Criteria 1.1; 1.2 Principle 2 Criteria 2.1; 2.3 Principle 6 Criteria 6.1 s/d 6.13 Principle 7 Criteria 7.1; 7.5; 7.6; Principle 8

12.00 – 13.30 Break and pray 13.30 – 17.30 Continue audit agenda 17.30 - ….. End of 4th day aiudit Friday, May 22, 2015

05.30 - …… Travelling from site to Kuala Namu Airport

MK, WA, MA, SA

09.00 - ….. Fligh from Kuala Namu - Jakarta MK, WA, MA, SA

GA 183 (09.00 – 11.25)

2.4 Stakeholder Consultation and Stakeholders Conta cted

The stakeholder consultation involved both external and internal stakeholders. External stakeholders were noti-fied to make comments on the certification assessment by placing an invitation to comment on the RSPO web-site. Stakeholders included those immediately linked with the operation of the company such employees, out-growers, the local government, NGO’s, trade and labour unions and local communities. Stakeholder consulta-tion took place in the form of meetings and interviews. Meetings with stakeholders were held to seek their views on the performance of the company with respect to the sustainability practices outlined in the RSPO Principles & Criteria, and to comment on aspects where improvements could be made. Meetings with local communities were held at their respective premises within and near the company’s area. A stakeholder consul-tation meeting was also held in Rambutan Palm Oil Mill meeting room on May 09, 2015. Letters inviting individual stakeholders to the stakeholder consultation meeting were prepared and sent to the individual stakeholders, while electronic mail and telephone calls were made to arrange the meetings. In all the interviews and meeting, the objectives of the RSPO and the purpose of the assessment was clarified at the outset followed by an evaluation of the relationship between the stakeholders and the company before discus-sion proceeded to obtain the stakeholders feedback on the company’s compliance to different aspects of the RSPO Principles & Criteria. Although several stakeholders were not familiar with RSPO but they agreed with its objective and expressed their willingness to collaborate in the promotion of sustainable palm oil in North Su-matera province. In all interviews and meeting, the assessment team did not restrict discussion of both the pos-itive and negative aspects of operations conducted by Aek Nabara Selatan Palm Oil mill and its supply estates. The stakeholder consultation meeting held with stakeholders during the audit was extensive and productive, with an attendance of 44 attendees. This was followed by site inspections, including visits to the local commu-nities, interviews with land claimants and contractors, and inspections of worker amenities and infrastructure. All stakeholder issues raised were recorded and forwarded to the management for their written responsed and this is summarised in Section 3.4.The list of stakeholders that attended the stakeholder consultation meeting and stakeholders interviewed during the assessment is included as Appendix 4.

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2.5 Date of Next Surveillance Visit The surveillance visit will planned for June 2017.

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3.0 ASSESSMENT FINDINGS 3.1 Summary of Findings pertaining to RSPO Principl es & Criteria

The following is a summary of findings made for the criteria listed in the RSPO Principles & Criteria Generic 2013 and RSPO Supply Chain Certification System November 2014. During the certification assessment, 10 non-conformities were assigned against Major Compliance indicators while 5 non conformities was assigned against a Minor Compliance Indicator. Further explanation of the non-conformities raised and corrective actions taken by the company are provided in Section 3.2 & 3.3. The ob-servations & opportunities for improvement are listed in Appendix 5.

Criterion 1.1: Oil palm growers and millers provide adequate information to other stakeholders on en-vironmental, social and legal issues relevant to RS PO Criteria, in appropriate languages & forms to al -low for effective participation in decision making.

Findings: The mill and plantation has provide adequate information to related stakeholders. The company regularly re-ports the plantations and mill operations to the relevant agencies dealing with environmental management, employment, the development of the plantation business, etc., namely: Report of environmental management and monitoring plan II period in 2014, report of the management of hazardous wastes and toxic quarter I peri-od 2015, wastewater management report quarter I period in 2015, report of PROPER first quarter period 2015, Plantation Business Progress Report on semester II 2014, Report of the committee occupational health and safety adviser first quarter period in 2015, report of Mandatory job Agency Company in 2014 was report-ed to the Manpower Agency, and Plantation Business Progress Report semester II 2014. All reports are time-ly reported to the relevant agencies by plantation or mill. Company documents the letter requests for information from outside parties and response, for example : - Letter of application for a permit for the election of village chief Teluk Mengkudu Liberia on 4 April 2014

and addressed tanggal 7 April 2014 concerning the approval of the use of the place . - Letter of application for a license for the provision of MTQ X of the Regional Secretariat Serdang Bedagai

dated March 7, 2014 and addressed dated March 11, 2014 regarding the approval of the use of the place .

Available incoming letter log book in 2014 and 2015 until May 2015, all incoming letter are listed into the log book. All of incoming letter are responded. Based on the results of the public consultation interview on May 19, 2015 obtained information that the proposals have not been followed up and no response by the compa-ny until now. This is as an observation to the company, to response the incoming letter immediately. Compliance status: Compliance with observation

Criterion 1.2: Management documents are publicly av ailable, except where this is prevented by com-mercial confidentiality or where disclosure of info rmation would result in negative environmental or social outcomes.

Findings: There is Directors Circular Letter No. 3.00 / SE / 01 / 2015 dated 8 April 2015 concerning data which can and can not be published. The data can be published as many as 28 types including: company profile, annual report, financial statements, certificates of land, land rights, environmental documents (EIA/RKL/RPL), occupational safety and health programs, policy management systems, reports employment, the document ef-fluent use permit, permit storage of hazardous materials and toxic waste, the production of the report, the program of sustaianability, human rights policy, social impact assessment documents, high conservation value, continuous improvement program documentation, reduction and pollution prevention plan , the process of conflict resolution / management complaints from the public consultation and the data certification assessment report, etc. Compliance status: Full Compliance

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Criterion 1.3: Growers and miller commit to ethical conduct in all business operations and transac-tions.

Findings: Mill and estate has carried out the code of ethical conduct brief to all level workers and third party (contractor) to ensure they workers and third party commit and understood about the code of ethical conduct in business operation in Rambutan Mill and supplied based, example:

• Estate Monaco carried out brief/socialization about code of ethical conduct to all level workers dated on 04 – 06 May, 2015 in Afdeling II hall meeting. This brief attendant by all level workers such as foreman, harvesters, sprayers, estate manager, asst manager, contractor/third party, and was at-tendant by 138 workers, evidenced by attendant list and photograph.

• Then, for Sarang Giting estate, also carried out the brief of ethical conduct to all level workers and contractor dated on May 11, 2015, evidenced by attendant list and photograph.

Compliance status: Full Compliance

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

Findings: The Company already has a list of applicable laws and regulations, including its archives in the aspects of en-vironment, labor and workplace safety. In connection with environmental aspects, Rambutan Mill has had Recommendation utilization of waste, in the form of the Decree of the Head of Environment Serdang Bedagai on Recommendation Waste Utilization in Soil PT PN 3 Rambutan palm oil mill No.660/421/LH/2010 which is valid until 19 November 2015 Permit tem-porary storage of hazardous waste (B3), in the form of the Decree of the Head of Environment Serdang Bedagai on B3 Waste Temporary Storage Permit Mill PTPN3, and Rambutan Estate No. 18.32 / 66/278/2013, with a validity period of 12 September 2013 s / d 12 September 2016. There is a digital document storage system (intranet) where the legal regulations in force already in the doc-ument that can be accessed by employees. There is a special officer in charge of this documentation are Field Clerk (Krani) and Document Control Clerk. There is system that record every change in the terms of either internal or based on government regulation mechanisms to ensure compliance with company regulations contained in Article 66 that the phases of sanc-tions, namely :

� written warning , � demotion, � termination of employment.

In the aforementioned article also stated that sanctions should be through negotiations LKS Bipartit. There is system that record every change in the terms of either internal or based on government regulations. The company provides a mechanism for evaluation of implementation and compliance to applicable legal re-quirements in a standard operation procedure i.e. PK-3.11-01, rev 0, dated 25 February 2014. There are also procedures which define the mechanism of evaluation of compliance to regulations related to the company's plantation, legislation related to the environment, legislation relating to labour, and regulations related to health and safety. The SOP states that the identification and evaluation is to be carried out 4 (four) times a year and conducted by the each section, and estate and will be compiled by Legal officer and supported by the Head of Operations / field and other departments within the company organisation. Most estate maintains and updates their list of all applicable legal requirements relating to environmental, occupational safety and health, the company plantations, and employment as well as records of internal compliance checks to legal requirements. The company maintains a list of all applicable legal requirements relating to environmental, occupational safe-ty and health, the company plantations, and employment as well as records of internal compliance checks to legal requirements as they are summarize in the FM-3.11-01/02. List of applicable legal, regulation and other requirements was recorded in the FM-3.11-01/01 and FM-3.11-01/03 The summary of law and regulation compliances for year 2014. As all the estate still have submitted to the head of Mill and Estates. Some evidence of compliance with relevant legal requirements as seen on latest legal requirements register i.e. "Report of legal and other requirement " for First Quarter of year 2015 in Rambutan Mill and Estates, Tanah Raja Estate, Gunung Monaco Estate and Sarang Giting Estate.

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Evidence of efforts made to comply with changes in the regulations was checked through the latest legal reg-ister updated on March 2015 & confirmed that latest applicable legal requirements as described above have been updated. The latest legal register is also sighted to be available at the respective mill and estate offices. Mill and estate has record of evidenced with law and regulation compliance, example:

- Decree environmental head agency number 660/421/LH/2010 about land application in Rambutan estate in division I, field number 300, 309, 310, 319, 320, 330, 340, 350 with total area about 232.35 Ha, valid for 5 years from the date issued on November 19, 2015, issued in Sei Rampah.

- Decree of Badan Pelayanan Perizinan Terpadu of North Sumatera number 610/21/BPPTSU/2/12.1/III/2014 about renewal of water surface license, when the water source was in Padang river, pump maximum capacity 30.56 litter/second. This license valid for 3 years from the dated issued.

- Chemical used in work location permit number 18.14/560/03/BKB/2014 about chemical used in work location. This permit complete with name of chemical type based on active ingredient.

- Ground water used permit number 119/08/XI/KP2TPM-SB/2014 dated on November 11, 2014, with water maximum intake about 15 m3/hours and water point maximum about 5 point water source.

But found in Silau Dunia estate incompatibility date EIA document between EIA approval with implementation discussion, were the EIA document approval in 2008, and the implementation discussion in 2009. Compliance status: Non Compliance NCR 2015 – 01 of 13 Found in Silau Dunia estate incompatibility date EIA document between EIA approval with implementation discussion, were the EIA document approval in 2008, and the implementation discussion in 2009.

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

Findings: All estate under Rambutan palm oil mill supplied based has a legal land use rights documentation, i.e.: 1. Tanah Raja estate

Decree of Land National Agency number 91/HGU/BPN/2009 about land use rights for PT PN 3 located in Serdang Bedagai district, North Sumatera province, total area 3,360.07 Ha, in Tanah Raja village, Sei Rampah district. This legal land use rights valid for 25 years from the issued dated on July 6, 2009, is-sued in Jakarta. Then, this decree consist of several legal land use rights certificate, i.e.:

• Legal land use rights certificate No.10, with total area about 3,319.63 Ha, valid until 20/12/2034. This certificate issued in Sei Rampah, on 21/12/2009.

• Legal land use rights certificate No.11, with total area about 12.95 Ha, valid until 20/12/2034. This certificate issued in Sei Rampah, on 21/12/2009.

• Legal land use rights certificate No.12, with total area about 27.49 Ha, valid until 20/12/2034. This certificate issued in Sei Rampah, on 21/12/2009.

Legal land use rights decree and certificate mentioned the land was gave to the PT PN 3 only for plan-tation development. Based on hectarage statement in 2015, legal land realization presented below:

� Rubber - Mature planted about 412.16 Ha - Immature planted about 491.20 Ha - Rubber replanting about 204.90 Ha - Total rubber planted about 1,109.26 Ha � Palm oil - Mature about 2,050.47 Ha - Immature about 48.65 Ha - Total palm oil planted about 2,099.12 Ha � Total rubber + palm oil planted was 3,208.38 Ha � Others land usage about 151.69 Ha � Total realization legal land used rights about 3,360.07 Ha

2. Monaco Estate Decree letter Head of National Land Agency number 188/HGU/BPN/2004 about renewal land use rights located in Serdang Bedagai district, total area about 2,322.775 Ha located at Sipispis subdistrict. This de-cree letter valid for 35 years, issued in Jakarta on December 31, 2004. Then, this decree consist of legal land use rights certificate, i.e.:

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• Legal land use rights certificate No. 160, with total area 2,322.775 Ha, valid until 31/12/2029, issued on 01/09/2005 in Lubuk Pakam. Based on information on this document, mentioned this license should use for palm oil plantation development. Then, based on hectarage state-ment in 2015, realization land use rights presented below: � Mature planted about 1,975.62 Ha � Other land usage about 347.15 Ha � Total land used realization about 2,322.77 Ha

3. Sei Putih Estate a. Decree letter Head of National Land Agency number 36-HGU-BPN-RI-2009 about land use rights on

behalf PT PN 3, located at Deli Serdan district, total area about 474.54 Ha, located at Serbajadi vil-lage, Galang subdistrict. This legal land use rights valid for 25 years, started from the dated issued on February 13, 2009 in Jakarta. This decree letter mentioned the legal land use rights should use for plantation development accordance to the governmental official approval. Then, this decree consist legal land use rights certificate, i.e.:

• Legal land use certificate No. 170, with total area 474.54 Ha, valid until 19/05/2034, issued in Lubuk Pakam dated on 20/05/2009 by Head of Land Agency Official.

b. Decree letter Head of National Land Agency number 11/HGU/BPN RI/2010 about legal land use rights for PT PN 3 located in Deli Serdang district, Sei Putih village, total area about 2,219.95 Ha, is-sued in Jakarta February 17, 2010. Until certification assessment process, the land use certificate still in process in official governmental land agency. This decree letter mentioned the legal land use rights should use for plantation development accordance to the governmental official approval.

4. Sarang Giting Estate a. Decree letter Head of National Land Agency number 37-HGU-BPN RI-2009 about land use rights on

behalf PT PN 3 total area 813.39 Ha located in Serbajadi village, valid for 25 years from dated issued on February 13, 2009 in Jakarta. This decree letter mentioned the legal land use rights should use for plantation development accordance to the governmental official approval. Then, this decree consist legal land use rights certificate, i.e.:

• Legal land use certificate No. 4, total area about 591.28 Ha, valid until 07/04/2034, issued on 08/09/2009 in Sei Rampah.

• Legal land use certificate No. 3, total area about 112.18 Ha, valid until 07/04/2034, issued on 08/09/2009 in Sei Rampah.

• Legal land use certificate No. 2, total area about 109.93 Ha, valid until 07/04/2034, issued on 08/09/2009 in Sei Rampah.

b. Decree letter Head of National Land Agency number 188/HGU/BPN/2004 about land use rights lo-cated Serdang Bedagai district total area about 2,238.33 Ha, valid for 25 years, issued in Jakarta on December 16, 2004. On this decree letter mentioned the land use rights should use for plantation de-velopment for palm oil and rubber based on government official approval. Then, this decree consist legal land use rights certificate, i.e.:

• Legal land use certificate No. 163, total area about 2,238.33 Ha, valid until 31/12/2029, is-sued on 01/09/2005 in Lubuk Pakam.

5. Silau Dunia Estate a. Decree letter Head of National Land Agency number 90/HGU/BPN RI/2009 about land use rights on

behalf PT PN 3 total area about 1,658.07 Ha located at Silau Bandar I-II village, Serdang Bedagai district, valid for 25 years, issued in Jakarta on July 6, 2009. On this decree letter mentioned the land use rights should use for plantation development for palm oil and rubber based on government official approval. Then, this decree consist legal land use rights certificate, i.e.:

• Legal land use certificate No. 2, total area about 1.24 Ha, valid until 14/10/2034, issued on 15/10/2009 in Sei Rampah.

• Legal land use certificate No. 3, total area about 109.93 Ha, valid until 14/10/2034, issued on 15/10/2009 in Sei Rampah.

• Legal land use certificate No. 4, total area about 12.39 Ha, valid until 14/10/2034, issued on 15/10/2009 in Sei Rampah.

• Legal land use certificate No. 5, total area about 1,516.60 Ha, valid until 14/10/2034, issued on 15/10/2009 in Sei Rampah.

• Legal land use certificate No. 6, total area about 7.70 Ha, valid until 14/10/2034, issued on 15/10/2009 in Sei Rampah.

• Legal land use certificate No. 7, total area about 2.45 Ha, valid until 14/10/2034, issued on 15/10/2009 in Sei Rampah.

• Legal land use certificate No. 8, total area about 5.63 Ha, valid until 14/10/2034, issued on

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15/10/2009 in Sei Rampah. • Legal land use certificate No. 9, total area about 2.13 Ha, valid until 14/10/2034, issued on

15/10/2009 in Sei Rampah. b. Decree letter Head of Head of National Land Agency number 2/HGU/BPN/2005 about renewal land

use rights in Sedang Bedagai district with total area about 2,087.42 Ha, valid for 25 years from the date issued on January 13, 2005. On this decree letter mentioned the land use rights should use for plantation development for palm oil and rubber based on government official approval. Then, this de-cree consist legal land use rights certificate, i.e.:

• Legal land use rights certificate No. 161, total area about 2,087.42 Ha, valid until 31/12/2029, issued on 01/09/2005 in Lubuk Pakam.

c. Decree letter Head of National Land Agency number 92/HGU/BPN RI/2009 about renewal land use rights on behalf PT PN 3, with total area 1,218.13 Ha, located in Silau Dunia, Silau Paribuan and Bah Sarimah village, valid for 25 years from the date issued on July 6, 2009. On this decree letter men-tioned the land use rights should use for plantation development based on government offical ap-proval. Then, this decree consist legal land use rights certificate, i.e.:

• Legal land use rights certificate No. 8, total area about 1,218.13 Ha, valid until 22/10/2034, issued on October 23, 2009 in Pematang Siantar.

All estate such as Gunung Monaco and Sarang Giting carried out the boundary pillars maintenance in 2015. Based on record in 2015, boundary pillars both of two estate in good condition and accessible. On site verifi-cation showed the boundary pillars in good condition. Especially in Sarang Giting estate found 42 boundary pillar missed in place in 2014, then estate management follow up this condition through the send the letter to Head Office to made plan for boundary pillar replacement, letter number KSGGI/DSER-2/MO/517/2014 dated on October 30, 2014. During in certification assessment, the boundary pillars replacement still in process. In Gunung Monaco estate, found some area in dispute condition, with total area about 137.2 Ha, and compa-ny has carried out compensation process and during the certification assessment area about 1.62 Ha has been compensation already, evidenced with compensation record between company and community, exam-ple minutes of compesation process (Suguh Hati) in around the riparian river in division I, field number K, L about 1.62 Ha on Friday, April 4, 2014. Then the balance about 135.58 Ha still in compensation process, were the company carried out the identification of land occupied in division I, III and IV; invite the community occu-pied in April 23, 2015; but there is no person from community invited the invitation. Next, in Sarang Giting estate also found total area about 105.35 Ha land dispute, this land dispute already fin-ished compensated process evidenced by record of compensation (Suguh Hati) located in division I, field number J40, and between company and occupied already agree with compensation process. Company already has work instruction number IK-3.11-12 Rev00 about conflict resolution. On this document mentioned about conflict resolution process, were the process was involved the affected parties (community, company, head of community, local government) through the discussion process (musyawarah). Both of estate (Gunung Monaco and Sarang Giting) already showed the land conflict map scale 1:45,000. Compliance status: Full Compliance

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

Findings: There is Conflict Resolution SOP number: IK-3.11-12 regarding the handling of conflicts of arable acreage, laments the relationship between the company and stakeholders. There is a map showing the location occupied by the community with the scale of 1: 18,000. The total area occupied by the people of an area of 644.97 hectares. Claim boundary between company and community arable land is owned by the outermost plants. No horizontal conflict with community. There is document of socialization/unification contains the opinion of the conflict issues which held on 13 September 2011 at the Silau Dunia estate hall. Approach after the year 2011 up to now made directly to the people who work for the land. Before conducting the negotiation, the company made a visit to the growers to hold preliminary talks about opportunities replacement, if there was an agreement growers will be called to the office to negotiate the compensation price with management. There is an evidence of a copy of the agreement/negotiation process on the settlement of land disputes Silau Dunia estate from 2012 through 2014. The land area occupied by the public area of 666.33 ha and completed

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compensable plants for 10.68 ha in 2012 of 1 ha, in 2013 covering an area of 5.83 ha, 3.85 ha of land which has not been completed so that the payment processing area of 644.97 ha. Company store all files of the payment process to the public, provided all file compensation payment process plant . Data of land area and the resident that are still occupied by the public area of 644.97 ha and map the location of each Afdelling. Has formed a team of arable acreage settlement based on a letter from director number: KSDUN / SKPTS / 14/2015 dated May 20, 2015. In the process of payment of compensation plants are mostly done on an individual basis . Compliance status: Full Compliance

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

Findings: Mill and estate has document record of financial long term economic (budget plan) for 3 years from 2015 – 2018. All of budget plan was estimated the FFB production, FFB process, CPO and PK production, OER and KER production, price product, price for production in estate and mill, maintenance, harvesting, manuring, spraying, and others activity in estate and mill. Budget plan also contained about replanting plan. Only Tanah Raja Estate has replanting plan for 2016 – 2017, were in 2016 replanting process will plan about 240 Ha and 126.70 Ha for 2017. Then for the others es-tate they did not have any plan for replanting because the year of planting still far from replanting plan. Compliance status: Full Compliance

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

Findings: Mill and estate already complete the procedure and work instruction for their activity. The procedure and work instruction contained from land clearing activity, replanting process, fertilizing, spraying, manual maintenance, harvesting, integrated pest management, high conservation area, FFB transportation process, riparian buffer-zone protection, EFB mulching, land application process, waste water management, waste management, chemical waste handling management, incoming FFB receiving in weighbridge, loading ramp area, process in sterilizer, kernel station, engine room, nut plan, warehouse, storage tank, product quality standards, supply chain mechanism, monitoring and measuring of waste water quality and others until dispatch process. Procedure and Work Instruction has been well documented digitally but not all levels of employees can access the document. The mechanism for the implementation of the above procedure, attached with an assistant function performance that works to supervise the activities that in the mill and in the estate. There is an assistant of Processing (2nd Shift), Assistant Lab (1), Assistant maintenance, and provided some work instructions contained in the respective sections). Available records for mill activity: � Dailly production report � Production report of Rambutan Palm Oil Mill by origin supplier � Recording weighbridge: Proof weighbridge (fruit), fruit delivery letter, CPO weigh evidence, weigh

evidence (kernel), permit entry / exit, Surat pengangtar (goods / products) � Loading ramp: TB external grading (sorting) � Note of clarification stations (each shift) � Note of Pressing Station (every shift) � Note Activity Boiler � The use of solar Reports � Note stations Threshing � Note kernel Station � Note Activities Water Treatment � Note stations Sterilizer � Logsheet Feed back process (Lab) � Letters of test (report of analysis) - wastewater: BOD, COD, pH, fat oil, Lead, Copper and cadmium � Report of the application of wastewater to land application � Daily reports Process and Quality Control Plant Oil

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� Analysis of the quality of palm oil Monitoring records are made including the information of: � Analysis of CPO and PKO � Report the results of laboratory analysis � Calibration weighbridge done by outsiders. Rambutan Mill has recorded the origin of suppliers who supply FFB to the factory PT PN3, there are several suppliers listed are:

- Rambutan Estate about 20.02% - Tanah Raja Estate about 14.03% - Sarang Giting Estate about 3.67 % - Sungai Putih Estate about 2.40 % - Silau Dunia Estate about 11.61 % - Gunung Monaco Estate about 16.27 % - Gunung Pamela Estate about 15.22 % - Gunung Para Estate about 4.96 % - Bangun Estate about 11.82 % (Since April 2015 Bangun Estate sent to Sei Mangke Mill)

Compliance status: Full Compliance

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

Findings: Estate has record of soil fertility maintenance through the fertilizing record application. Estate has document of work instruction document number IK-3.01-03/16 Rev01. The procedure has mentioned about fertilizing ac-tivity should accordance to year of planting, fertilizer type and time for fertilizer application. Tanah Raja estate, has record of fertilizer activity. Based on fertilizer record activity in 2014, in December di-vision III, all fertilizer application was meet the dosage application accordance to foliar sampling. Fertilizer application depend of year of planting, example YoP 1994, planted area was about 126.70 Ha, stand per hec-tare palm oil about 14,346 trees, Dolomit plan application accordance dosage record about 32,179 tonne, and realization application was about 32,100 tonne. Also in Gunung Monaco estate, for fertilizer program implementation in Semester I, division II, example for NPK15.10.18.2+05TE, total hectare will fertilizer about 519.44 Ha, until April 2015 fertilizer application was about 242.21 Ha, with fertilizer application was about 84.620 kg. And the other hand, Sarang Giting estate also ha record of fertilizer application for 2014 and 2015 until April. Fertilizer application record showed the application was meet with the dosage, but found the realization appli-cation in 2014 for Urea fertilizer application did not meet with the total application recommendation because the Urea fertilizer still in purchased process. But found in Tanah Raja estate, fertilizer application not meet with fertilizer recommendation for immature palm oil. This is raised as nonconformity (NCR 2015 – 02 of 1 3). Estate has carried out the foliar sampling (leaf and soil analysis), with record evidenced, i.e.: 1. Tanah Raja estate; leaf analysis based foliar sampling certificate number 972/0.1/Sert/IX/2014 dated on

August 18, 2014 with parameters analyzed was N, P, K, Ca, Mg, B. The leaf sampling collected from divi-sion I, II, III, IV. Then the soil analysis certificate number 458/0.1/Sert/IV/2014 dated on February 25, 2015.

2. Gunung Monaco estate; leaf analysis based on foliar sampling certificate number 971/0.1/Sert/IX/2014 dated on August 18, 2014, and the soil analysis certificate number 461/0.1/Sert/IV/2014 dated on Febru-ary 25, 2014.

3. Sarang Giting estate; eaf analysis based on foliar sampling certificate number 016/A.D/Lab-TM/VII/2014 dated December 22, 2014, and the soil analysis certificate number 462/0.1/Sert/IV/2014 dated on Febru-ary 25, 2014.

All of foliar sampling carried out by Palm Oil Research Institute of Medan. Tanah Raja estate has record of EFB mulching, in 2015 already EFB mulching in division V about 24,000 kg. Then in Sarang Giting estate also has record of EFB mulching in division V, for February in 2015 EFB mulch-ing was about 122.410kg, January 2015 about 1.043,870 kg, March 2015 about 68.760kg, so total EFB mulching in the end of March 2015 was 1,235,040kg. Compliance status: Non Compliance

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NCR 2015 – 02 of 13 Found the fertilizer records in Tanah Raja estate, the fertilizer application not meet with the fertilizer recom-mendation.

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

Findings: Based on HCV assessment identification document, there is no fragile soil in Tanah Raja, Sarang Giting and Gunung Monaco estate. Because the fragile soil not available in three estate above, so there is no manage-ment for fragile soil strategy. For road maintenance, Tanah Raja estate has record for road maintenance, example in division III, production road maintenance about 24,000 meter, and already maintained on March 31, 2015 about 24,000 meter. Then for control road about 17,000 meter also already maintained all by estate in the same date. While in Sarang Giting estate already map of road maintenance for all division, example in division V based on realization map of road maintenance in January 2015, with total road about 43,554 meter for production road and main road. Based on soil map, HCV document and EIA document, there is no peat land in the all estate as a Rambutan oil mill supplied base. Compliance status: Full Compliance

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

Findings: Rambutan Mill water supply needs met from Sungai Padang, which accommodated through dam reservoir - clarifier tanks with a capacity of 90 tons, sedimentary basin with a capacity of 200 tons and there 2 units tower tank with a capacity of 90 tons each. Used to purify water and soda as ammonium sulphate. Fulfillment of domestic water for the employee housing is not from the supply from the mill, but they pursue their own by using a jet pump groundwater. Documents realization water use has been provided, for example, water consumption data was available in April 2015 are :

No Use Volume (m3) Presentase

(%) 1 Housing 152 0,49 2 Social facilities 377 1,21 3 Poliklinik 62 0,2 4 Engine room 109 0,35 5 Boiler 12.440 39,87 6 Workshop 109 0,35 7 Laboratorium 1.088 3,49 8 Office 306 0,98 9 Mill 12.977 41,40 10 Electricity 3.640 11,67 Jumlah 31.200 100,00

Water conservation efforts that have been made by PTPN3 is by planting in the estate area with plants conservation in 2014 as many as 1,290 trees, as follows: durian 366, mahogany, 585, mangosteen 56, lansium domesticum 21, nephelium lappacium 66, coconut 100, breadfruit 50, Antocephalus cadamba 18, soursop 16, and mango 12. Periodic reports on the use of water may have been carried out by the company in the form of an annual report book. Water conservation has been carried out by Rambutan Mill:

� Recovery of water that has been used (recycling) as much as 80-90%

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� Recovery of entire turbine cooling water 30 tons per day � Protection for the area of water resources is carried out by planting trees rambutan trees, mahogany,

durian, kweni with a total crop of about 500 trees. PT PN 3 is currently implementing land application of wastewater in ponds to manage WWTP by subjecting it to the location of the estate to be used as fertilizer. No more dumping waste water into the river. Land application to division 1 field number 309.306. Land permit application or utilization of industrial waste water from palm oil of PT PN 3, by Environment Agency, Serdang Bedagai No. 660/421 / LH / 2010 19 November 2010 , validity period of 5 years to the date of October 19, 2015 on the Recommendation of the utilization of waste water in the land to PT PN 3 Rambutan Estate. Utilization of waste water monitoring reports reported to the Environment Agency Serdang Bedagai District every month to parameter: daily discharge, pH, BOD, COD, oils / fats. Pb, Cu, Cd, Zn. Report every 6 months covers groundwater monitoring wells: BOD, DO, PH ,, NO3, N, NH3-N, Cd, Cu, Pb, Zn, Cl and SO4. And 1 year to monitor the quality of the soil on the land application (waterpoint, inter-waterpoint and land control) There are seven pools at the mill for effluent waste: pond cooling pools (one pool), anaerobic pool (3 pools), aerobic Pool 2, Pool maturity (1 pool) colecting pond (1 pool). Channeled to pool land application of anaerobic pond. The measurement results wastewater on Waste Outlet in April 2015 by the Environmental Quality Laboratory testing in Bandung. Water consumption per ton FFB recorded and monitored in the report of water usage per month. In April 2015 the figure water usage at the plant as follows:

No Water Usage Amount Normal 1 FFB 1,50 m3/ton TBS 1,50 – 2,0 2 CPO 5,86 m3/ton CPO

Compliance status: Full Compliance

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

Findings: Gunung Monaco estate has record of IPM management plan and implementation for 2014 and 2015 until April. This estate carried out the EWS (early warning system) to ensure the level attack, while the medium to up level attack will handling with combination between biological and pesticide accordance to the dosage rec-ommendation. Based on EWS record in 2014, there is no any level attack medium – high level in division I example, only lowest level attack from caterpillar and bagworm. This condition already managed by estate through the Turnera subulata and Antigonon leptopus, were in 2015 already planted about 406 trees Turnera subulata. Also in 2015 until April there is no indication medium – high level attack for all division. Then, in Sarang Giting, pest and diseases handling program for 2014 and 2015 available in place with imple-mentation record. Example census for bagworm and caterpillar in April 2015 in division V, for YoP 2000 with total area 381.25 Ha, field number W21 (14.80Ha); X20 (15.76Ha) and based on census records there is no attack in this field. Estate also record of beneficial plant example Turnera subulata and Antigonon leptopus. Map of beneficial plant realization also available, example in division V, until January 2015 there are 175 trees beneficial plant already planted for Turnera subulata and 172 trees for Antigonon leptopus. In Tanah Raja estate found the Genoderma attack about 23% or 470Ha, but there is no evidenced this condi-tion was handled by estate. This is raised as nonconformity (NCR 2015 – 03 of 1 3). Person in charge for IPM implementation both of two estate (Gunung Monaco and Sarang Giting) already provide training based on training record dated on May 4 – 5, 2015 in division II and III, evidenced by at-tendant list and was attended by 11 person from division II and 13 person for division III. Then for Sarang Git-ing training also already carried out on September 10, 2014, attended by 7 person. Training evidenced record complete by training material and photograph. Compliance status: Non Compliance NCR 2015 – 03 of 13 There is no records handling of Genoderma attack in Tanah Raja estate.

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

Findings: Based on document verification in place, proved that the company particularly the treatment plant has provided recommendation use of pesticides used in the field. There is no found paraquat dichloride used by estate. The use of pesticides is reported in foremen daily reports to explain the use and dosage pestisides and carried out in the estate by the foremen. Dosage use of pesticides refers to Norma Herbicides 2015 established by the company that set the dosage/liter/ha/rotation. The company has made efforts and rare-step reduce the use of chemicals in pest management, such as:

� Planting flowers Tunera subulata � Training IPM (integrated pest management): 6 people are certified and certificates � Spraying depends attack in 2015 there has been no attack.

Efforts to reduce pesticide done by reducing the rotation of the sixth rotation to rotation only 3-4, then the use of biological enemies of pests of plants (plant Tunera subulata), the use of empty fruit bunches to reduce weeds. Based on the search documents note that the Silau Dunia estate , Tanah Raja estate, and the Sungai Putih Estate using pesticides to the type of active ingredients as follows: Methyl mestsufuron, Isoprophyl amina glyfosat, deltametrin and others. The use of the active ingredient in compliance with applicable regulations. Based on the explanation of the maintenance worker labour that the plant has the same dosage with the provisions, because of the mixing of pesticides is done in the warehouse of pesticides by certified personnel. The workers apply only on the field in accordance guidance of foreman and assistant. Based on document tracking and verification in the field, the company has a proven that :

� Officer of IPM (integrated pest management) as many as 23 (permanent employees), and which has a certificate of six people (26%)

� Officer herbicide spraying (maintenance): 96 people and 34 people have been checked health. � All have been trained by Assistant Afdeling, with available evidence photos, meeting minutes, and

attendance. The warehouse storage and mixing of pesticides have been equipped with symbols precautions for chemist materials, as well as safety elements such as water faucets affordable, sandbox, and others. Management permit and temporary storage of waste B3 has been owned by the company, namely:

� Letter of Endorsement, Control Hazardous Chemical Substances in the Workplace No. 18.14/560/01/ BKB / 2013 issued by the Department of Social Labour and Cooperatives of Serdang Bedagai in November, 2013.

� Decree of the Head Office of Environmental Serdang Bedagai No: 18.32/660/206/2013 on the Permit for Temporary Storage of waste Chemicals Toxic and Hazardous PTPN 3 Tanah Raja Estate

Waste Pesticides former channeled to institutions hazardous waste transporter Licensed in this case is PT. Primanru Jaya, Tangerang. Chemical storage warehouse in compliance with the rules of best practice as provided symbols B3, provided with good air ventilation, there are spill kits (sand and container discharge), emergency facilities such as eyewash (faucet / shower) near chemicals. There are special SOP Pesticide application methods that minimize the risks and impacts of pesticide use. There laundering spraying equipment, etc. There are special washing facilities work tool application of chemicals and spraying clothes officers. Laundering tools work done on a special bathroom. Based on data retrieval and verification in the field, the company had made efforts to improve the ability of farmers in the management of activities in the oil palm plantation. The activity in the form of regular training to workers/ labour harvest and treatments are mostly farmers. The company has a mechanism related to waste management in the form of working instruction (IK-7.07-05 /

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01). Based on field-proven verification that the workers to understand the management of both solid and liquid waste, and understand common uses of the personal protective equipment to preserve safety. The Procedures for handling such waste was also put up on the information board in the warehouse waste. Based on field verification that it has done a special health examination (medical surveillance) for operators of pesticide spraying and fertilization. Cholenestrase examination conducted once every year, and if there worker/labour indicated it is recommended to be transferred to other jobs that are not at risk of exposure to chemicals. Based on the field verification, proved that the company does not employ his enlistment and lactating women. Pregnancy tests routinely performed three months with test pack/ pregnant test conducted at the company clinic. Compliance status: Full Compliance

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

Findings: All estates have documented occupational safety and health (OSH) policy. Example for this fact is Tanah Ra-ja Estate OSH policy dated 2 March 2015; and Gunung Monaco Estate’s OSH policy dated 2 March 2015. The OSH policy includes documented objectives and targets, i.e. comply with the company’s OSH proce-dures, committed to wearing of Personal Protective Equipment (PPE) at work sites, and manage potential work risks at the site. As sighted from Rambutan Mill documents, the Mill OSH team organisational structure has been approved by the Head of Social, Manpower and Cooperation Office of Serdang Bedagai District by virtue of Decree No. 18.14/566/773/P2K3/2015 dated 29 April 2015. As for Tanah Raja Estate, its OSH team organisational structure has been approved by the Head of Social, Manpower and Cooperation Office of Ser-dang Bedagai District through Decree No. 18.14/560/60/P2K3/2015 dated 12 January 2015. All estates provides National Employee Social Security (Jamsostek) to permanent employees, as sighted from sampled payslips of 3 harvesters of Gunung Monaco Estate, as verified with interview. According to the company’s Work Instruction for Jamsostek Participants and Fees, the amount paid by the company for Jam-sostek contribution is 4.2.4% of the employees' basic salary, while another 2% payment is made through reg-ular deduction of their basic salary. This has been verified to be paid correctly. As for contract workers, Sa-rang Giting Estate deducts the amount required for their insurance against payment to the respective contrac-tors, and pays this insurance amount directly to the relevant authority to ensure that all contract workers are covered with insurance. The estates have records of annual medical check-up provided by Ministry of Manpower and Transmigration on rotational basis for permanent workers performing high-risk works, e.g. chemical storehouse operators, sprayers, weeding, generator operators, and harvesters. The last medical check-up report for Tanah Raja Es-tate is dated 4 May 2015, while for Sarang Giting Estate dated 7 April 2015. Both are available and records have been prepared on recent check-up completely performed. Medical check-up reports include audiometric tests, spyrometry test, blood cholinesterase levels and vision (in Gunung Monaco Estate, some workers also underwent urine and faeces check). Workers at Gunung Monaco were identified having high blood cholines-terase levels and the hospital produced recommendation letters for two workers found with high cholinester-ase levels, stating that these workers should not do insecticide spraying work for at least one month and there were an objective evidence has been obtained indicating that the company has followed up the hospital rec-ommendation to temporarily transfer these workers to carry out other works. All of permanent workers inter-viewed stated that they have undergone medical checks, and based on review of Tanah Raja Estate’s medi-cal examination records, such medical check-up records were available for three interviewed harvesters. Tanah Raja Estate has identified and documented Occupational Health and Safety (OHS) risks for all estate activities, although this was documented under its 2015 environmental aspects and impacts register. Rambu-tan Mill, Gunung Monaco Estate and Sarang Giting Estate has Hazard Identification, Risk Assessment and Risk Control document for 2015, dated 26 January 2015 for all estate activities including spraying, manuring, harvesting, workshop activities, generator, truck transportation, chemical and material storage, and waste handling. The company has an emergency response procedure documented under Work Instruction No. IK-3.12-01/10, including identification of potential emergency situations (fire, accidents, flood, explosion, and chemical leak-age) and a flowchart for Handling Fire Emergencies. Rambutan Mill has records of emergency response train-ing and simulation on 22 May 2015 for over 50 workers, as well as land burning simulation on 22 May 2015 for 35 estate division staffs. It was confirmed through interviews with three harvesters that they had attended the emergency response training. Notes of the training results are maintained, including the steps of the acci-

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dent & emergency response procedure. Records of other OSH training, i.e. for first aid and management of hazardous waste, are available as described under CR4.8. Fire emergency training for Sarang Giting Estate was conducted on 4 February 2015 for 46 staffs. Training on emergency response procedure for fire was conducted in March 2015 for 31 workers at Gunung Monaco Estate. During site visits, field executor (supervisor) in Tanah Raja, Gunung Monaco and Sarang Giting Estates were found having brought first aid kits to the field, and those are located at other locations such as estate office, workshops, chemical storehouse, etc. It was observed that the first aid kit at Division 1 of Tanah Raja Estate office a complete pack of first aid kit. However, at Gunung Monaco Division 3, harvester and manurer fore-man also have a first aid kit. Evidence of OHS (e.g. PPE provided to workers) has been found in the Rambutan Mill. However, there are aspects must be improved. Chemical storekeeper in Gunung Monaco Estate is provided with helmets, boots and goggles but look not much aware to the visitor that need to wear the PPE while entering his area. Con-tract field-maintenance workers are required to wear boots and provide by company. Female contract spray-ing/manual maintenance workers interviewed in Gunung Monaco Estate are provided with Personal Protec-tive Equipment (PPE) by the company, including masks, gloves, and plastic aprons. The sprayers are provid-ed with appropriate cloth gloves for spraying activity. While they wash their PPE at washing facilities at the di-vision office and they store their PPE in the estate store. At Tanah Raja Estate, contract spraying workers are provided with rubber gloves, goggles; masks and plastic aprons by their contractor but the plastic aprons only partially cover their clothes. PPE washing and storage facilities are provided for the sprayers. The contracted spraying workers in Tanah Raja and Gunung Monaco Estates were aware that they can get medication or treatment for minor illnesses from the estate clinic as they are allowed by the estate management and this medication is to be paid for by the contractor. As a matter of fact, they currently recorded in estate clinic rec-ord for medication. Based on interviews with harvesters at Gunung Monaco Estate, there was a worker whose part of his leg was injured cut by slippery accident while the harvesting activities The estate’s report of this accident occurring on 7 March 2015 is available and the company has documented preventive actions and followed up by request-ing their Human Resources Department (HRD) to apply for insurance payment for the worker as required by their Working Procedure of Handling and reporting of OHS accident No PK-3.12-11 Rev 0 Year 2014. Compliance status: Full Compliance

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

Findings: As sighted in the memorandum of Human Resources and General director No.KRBTN/MO/27/2015 related on the job-training program for estate employees in Rambutan Estate. The training program consist of Chemical handling training, Integrated pest management and early warning system, Electrical overhead power line har-vesting activities and HCV training were well filed including their signed attendance list, training materials and completed with the training evaluation. Rambutan Mill has also documented 2015 training plan, including training plan for OSH hazard and risk identification, workplace safety inspections, first aid training, hazardous waste management, and emergency response training. The estate and Mill have documented worker identifi-cation that requires training. For example in January to June 2015, Tanah Raja Estate has also identified the training need for PTPN3 system management (SMPN3) training for 5 employees, Harvesting training for har-vester total 60 harvester and maintained training participant record. Gunung Monaco, Tanah Raja and Sarang Giting Estate and Rambutan Mill and estate training programme in 2015 has also been observed, including harvesting, fire emergency and pest management trainings. The company’s estates maintain records of trainings delivered by contractors to their workers. For example, in Sarang Giting Estate harvesting training was delivered for Syaifudin as Mill Staff on January 2015. Signed at-tendance 16 participants list for ISPO self assessment training including the training evaluation, Report of SMPN3 training result batch II in Sei Karang Training centre for employee named Darman Simanungkalit in-cluding the post training evaluation result for him was well documented in the mill office was sighted. The es-tate also carries out evaluation of workers understanding on the trainings provided. Gunung Monaco Estate holds records of competency certificates for employee such as General OHS special-ist certificate for Jimmy Ardhianta Tarigan and M Suryadi Karsono, OHS electric operator for Erwanyah Rizal, Nasic Welder Operator for Mindo Pane, First Aider certificate for Irsan Barus and several available contrac-tors, i.e. contractors for Sprayers and road maintenance. Selection of contractors providing spraying workers is done by PTPN III head office. Certificates of competency from North Sumatera Chamber of Commerce & Industry for two contractors providing spraying workers to Tanah Raja and Sarang Giting Estate have been sighted and referred to as evidence that selected contractors are eligible for executing this work. Compliance status: Full Compliance

Criterion 5.1: Aspects of plantation and mill manag ement, including replanting, that have environmen-tal impacts are identified, and plans to mitigate t he negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.

Findings: All estates have Environmental Impact Assessment (AMDAL) documents. For example those sighted in Ram-butan Mill (No.660/59.C/KAN/AMDAL/2009) and Rambutan Estate (No.660/59.A/KAN/AMDAL/2009), Tanah Raja (No.660/59.B/KAN/AMDAL/2009), Gunung Monaco (No.660/59.D/KAN/AMDAL/2009) and Sarang Giting Estates (No.661/21/KAN/AMDAL/2009). Their revised versions of Environmental Management/Monitoring Plan (RPL/RKL) prepared by the Research Institute of North Sumatera University (USU) have been approved by the Environmental Department Head. The original AMDAL documents of both estates are Environmental Evaluation Assessment (EEA) and original RPL/RKL documents prepared in 2008. The RPL/RKL documents have been revised in 2009 for all estates due to changes in plantation operation, e.g. change in the estates’ HGU concession resulted in changes in estate capacity and design. All estates have prepared RPL/RKL implementation report once semi-annually to comply with legal require-ments. For example, Sarang Giting report in 22 December 2015 includes reports on air quality, emissions from generator, groundwater and soil quality, and noise. In Tanah Raja and Gunung Monaco Estate, such re-port includes result of analysis of the same parameters, as well as of odour levels, and amount of hazardous waste produced. This is reported semi-annually, while some parameters to be reported annually have been sighted in the estate’s December 2014 report, e.g. analysis of employment opportunities, local community perception and CSR activities. The analysis results indicate no excess towards legally permitted standards in both estates. While in Silau Dunia and Sungai Putih estate found non-compliance between implementation management plan with environmental management matrix document, were the type of plan was planted not met with plant recommendation in environmental management document matrix. This is raised as nonconformity (NCR 2015 – 04 of 13) .

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Compliance status: Non Compliance NCR 2015 – 04 of 13 Found non-compliance between implementation management plan with environmental management matrix document, were the type of plan was planted not met with plant recommendation in environmental manage-ment document matrix.

Criterion 5.2: The status of rare, threatened or en dangered species (ERTs) and high conservation val-ue habitats, if any, that exist in the plantation o r that could be affected by plantation or mill mana ge-ment, shall be identified and their conservation ta ken into account in management plans and opera-tions.

Findings: Mill and estate has carried out the HCV identification assessment in all estate. Example in Tanah Raja estate, HCV identification assessment assessed by Biodiversity and Biotechnology Research Centre of Bogor Agri-cultural University in 2013. From the HCV assessment identification, found the 30.39 Ha HCV area, consist of riparian bufferzone of Buluh river and Canal, slope area, and cultural site grave, with HCV type was 1.3, 1.4, 4.1, 4.2 and 6. While in Gunung Manoco estate the HCV area was about 189.11 Ha consist of riparian bufferzone of Bah Bo-lon river, Bah Bulian river, Bah Sumbu river, water springs, cultural site grave and slope area. The HCV type on this estate categorized as HCV 1.1, 1.3, 1.4, 2.3, 4.1 and 6. This HCV identification assessment carried out in 2011. Then in Sarang Giting estate the HCV assessment identification carried out in 2011, with HCV identification area was about 36.36 Ha, consist of riparian bufferzone of Belutu river, Ular river and slope area >40%. Based on HCV identification assessment in Tanah Raja estate, there is no found any RTE species, while species available in Tanah Raja estate was Pronailurus bengalensis, Elanus caerulus, Spizaetus cirrhatus, Naja sumatrana. This species categorized protection by National regulation number 7/1999, CITES APP Iiand IUCN LR and LC. In Gunung Monaco estate found RTE species based on HCV identification assessment, i.e.: Lutra sumatrana, and Manis javanica. This species categorized as IUCN EN and CITES APP II. Also found Trerron capellei and Macaca nemestrina categorizes as IUCN VU and CITES APP II. Next in Sarang Giting estate, based on HCV identification assessment, there is no found RTE species. While species has been identified in this estate was Pronailurus bengalensis, Spizateus cirrhatus, Varanus salvator and Naja sumtrana. Those species categorized protected by National regulation number 7/1999, CITES APP II and IUCN LR and IUCN LC. Especially in Gunung Monaco estate, this estate has carried out the RTE species monitoring, example in divi-sion I dated on 08/07/2014, based on monitoring result found the Manis javannica species in field number Q2 and Q3, but the estate did not carried out the appearance intensity of the RTE species. Based on HCV man-agement plan in Gunung Monaco estate, there is no found record for maintain and enhance the RTE species, because until the certification assessment process, estate only carried out the monitoring without any follow up from the monitoring result. This is raised as Nonconformity (NCR 2015 – 05 of 1 3). Tanah Raja and Sarang Giting estate has record of programme to regularly to educate the all workers level for protect the RTE species, through the brief/socialization carried out in June 28, 2013. This brief explained about protection of RTE species and non RTE species about prohibition of hunting, shooting, catching, poi-soning all of species in all estate, also prohibition about illegal logging in HCV area. This agreement signed together between company with community and local government. Also in Sarang Giting estate, found memo intern to the Asst division I until V dated on March 7, 2015 number Int/43A/2015 about prohibited species to collect, hunting, catching and others activity will damage and disruption the species. The Tanah Raja estate has carried out the HCV brief/socialization dated on January 19, 2015 attended by 16 person from level workers (manager, manager asst, clerk, foreman and others). Then in Gunung Monaco es-tate also has carried out the HCV brief/socialization on May 4 – 5, 2015 in all division attended by all level workers from manager level, until harvester, sprayers and others. Then, in Rambutan palm oil mill and Sungai Putih estate there is no found any evidenced related RTE spe-cies protection from activity of hunting, catching, collect and others will damage/disturb the RTE species. This raised a nonconformity (NCR 2015 06 of 13) . Compliance status: Non Compliance

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NCR 2015 – 05 of 13 There is no found record for maintain and enhance the RTE species, because until the certification assess-ment process, estate only carried out the monitoring without any follow up from the monitoring result. NCR 2015 – 06 of 13 There is no found any evidenced related RTE species protection from activity of hunting, catching, collect and others will damage/disturb the RTE species.

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

Findings: All estates and mills have identified all sources of wastes from estate and mill activities including spraying, manuring, storehouse, pest management, etc. in their 2014 Environmental Aspects and Impacts Identification. In several locations such as Division 4 office of Tanah Raja, evidence has been sighted of separation be-tween organic and non-organic wastes. Gunung Monaco Estate has record dated 20 July 2013 on waste transfer to a contractor (PT Primanru Jaya) including used fertiliser bags, used rubber tapping cups, metal, chemical containers, vehicle spare parts, used battery and used polybags. Tanah Raja Estate also has similar records on solid waste collection by a contractor, namely PT Primanru Jaya. For 2015 has been issued a new assignment for the contractor of waste collector and transporter as it was sighted on Director Memorandum Letter No. 3.03/X/38/2015 on 11 March 2015 and Technology Department Head letter No. 3.03/MO/211/2015 for PT.Putra Tunas Sejati which has no evidence their scope of capability were cover for available mill and estate waste produced by their own activities such as used battery, used printer cartridge, chemical container etc. PT. Putra Tunas Sejati has authorise only for used oil and used mixed oil only which not cover other available waste in the mill and estate. This was raised as nonconformity (NCR 2015 – 07 of 13). Rambutan Mill has planned and implemented waste management as noted from Working Instruction such as Working Instruction for Monitoring and Use of Solid Waste (IK-3.12.01/14 rev.0 dated 25 February 2014), Working Instruction for Handling and Use of Hazardous Waste (IK-3.12.01/08 rev.0 dated 25 February 2014) and Working Instruction for Mill Liquid Waste Management (IK-3.03-14/01 rev.0 dated 25 February 2014). The mill has implemented waste management such as use of POME (liquid waste) for Land Application (LA) areas, EFB (solid waste) as organic fertiliser, other solid wastes (non-EFB) and hazardous waste submitted to licenced third party. There is evidence of appropriate domestic waste management as seen from housing located in Division 2 of Tanah Raja Estate whose domestic waste is disposed of through closed waste container in front of the hous-es. They were also observe on housing of Gunung Monaco and Sarang Giting Estates, waste is disposed of to a proper segregated and closed waste containers. Rambutan Mill has appropriately licenced to temporarily store hazardous waste (Head of Serdang Badagai District Decree No.18.32/660/278/2013 and valid to 12 Sept 2016), where several types of hazardous waste (such as used oil and used batteries) were collected by licenced third party (PT Primanru Jaya NPWP 1.806.426.1-034 that holding licence from Ministry of Environment KEP MEN LH No 234 Tahun 2011). Sarang Giting estate holds a valid licence to temporarily store hazardous waste. This licence is dated 17 Oc-tober 2014, valid for 3 years and allows storing hazardous waste for maximum 180 days. Hazardous waste at the storage facility includes used oil, vehicle spare parts, used printer cartridges, and used light bulbs, while inventory of all types of chemicals is maintained as it was sighted on the log book for total 1,032.20 KGs of waste was recorded in their temporarily store. Tanah Raja Estate has a temporary storage facility for hazardous waste, including used oil, filter, used bat-tery, printer cartridge, etc. Estate staff maintains inventory of these types of waste and the records are availa-ble at the estate. Gunung Monaco Estate also maintains records of monthly solid waste, as sighted from Jan-uary 2014 record which includes amount of stored waste such as used fertiliser bags, papers, spare parts, used chemical containers, used spraying equipment, used polybags, etc. During field visit in mill housing area, found the domestic waste burned by workers in housing. This is non compliance with company regulation about zero burning activity and company procedure. This is raised as nonconformity (NCR 2015 – 08 of 13) . Compliance status: Non Compliance NCR 2015 – 07 of 13

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It was found that assigned waste collector and transporter was not have an authorised for waste produced in Rambutan Mill, Tanah Raja, Gunung Monaco, Sarang Giting, Silau Dunia and Sei Putih Estate. NCR 2015 – 08 of 13 Found burning activity in mill housing, were the garbage from housing burned by community in mill housing.

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

Findings: An established program to reducing fossil fuel use and renewable energy has well implemented and evaluat-ed as were found during the audit such as in Rambutan Mill uses oil palm shell and fibre as a source of re-newable energy to fuel its boiler. The mill maintains records of calculations of renewable energy produced from shell and fibre. Monitoring report mentions that total energy used from shell and fibre in 2014 and achieving 85.17% saving value. Since 2013 Rambutan Mill has been implemented a system which using the Palm shell burning to producing electrical power, for the maximum electrical energy produce 2.5 MW electri-cal energy to using the mill electricity and sell to State Electricity Company (PLN). It was sighted on the elec-trical selling record to PLN on until 18 Mei 2015 as the total amount is Rp. 392.225.503,- and the total kWh electrical power is 536.721.06 All estates maintain reports of monthly diesel use. Sarang Giting estate also maintains records of fossil fuel use for analysis. From the records, average fossil fuel use in 2014 is 49.427 litres. The fossil fuel used here is diesel which is used for starting up the generator set while electricity from PLN were blackout. The estate maintains calculation of estimated cost of the fossil fuel purchase and estimated price of the renewable ener-gy consumed. The mill’s data also shows that the renewable energy use is estimated to constitute approxi-mately 74.73% of the estate’s total energy use, being part of efforts to maximise use of renewable energy as opposed to the fossil one. Compliance status: Full Compliance

Criterion 5.5: Use of fire for preparing land or re planting is avoided, except in specific situations as identified in the ASEAN guidelines or other regiona l best practice.

Findings: Based on field assessment and document veriifcation in Rambuatan POM supply based, there is no opened burning already done by company. All estate under Rambutan POM no longer carried out land clearing activi-ty. During the assessment only replanting will cary out by company in the middle of year 2016 by manual land clearing, accordance to company regulation “no use fire for land preparing and re-planting activity. Compliance status: Full Compliance

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

Findings: Rambutan Palm Oill Mill and Estate has identified the pollution, emissions and greenhouse gases source from all activity through the document of environmental impact assessment for 2015, were source in palm oil miss consist of emission from boiler, engine room, waste water pond, fossil fuel from activity FFB transporta-tion and product transportation, the source in estate came from fuel fossil used from spraying, fertilizing, FFB transport. From all identification source above, mill and estate has identified the significant pollutants then made plans to reduce and mitigate the pollution, emissions and greenhouse gases, through the:

- Tools maintenance - Emissions measurement, ambient measurement - Waste water measurement - Record of fossil fuel used - Record of chemical and fertilizer used - Enrichment in riparian bufferzone - Composting record used

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- Program evaluation All estate and mill has record of management plan implementation to reduce and mitigate, such as records of fertilizer used in once year 2014, record of chemical used, fossil fuel used, waste treatment for land applica-tion used, and others. Then, Rambutan palm oil mill and all estate has calculated the greenhouse gases, but the calculated still not approved by RSPO or using appropriate tools. This is raised Nonconformity (NCR 2015 – 08 of 13) . Compliance status: Non Compliance NCR 2015 – 09 of 13 Rambutan palm oil mill and all estate has calculated the greenhouse gases calculation, but the tools used to GHG calculate did not meet with RSPO tools or appropriate tool and reported to RSPO. Criterion 6.1: Aspects of plantation and mill manag ement including replanting that have social impacts are identified in a participatory way, and plans to mitigate the negative impacts and promote the posi -tive ones are made, implemented and monitored, to d emonstrate continuous improvement. Findings: There is social impact assessment documents/SIA of Rambutan palm oil mill compiled by the Research Institute of the University of North Sumatra in November 2012. The results of the SIA study were obtained 6 positive impact for employees and villages around the plant as well as 2 negative impacts . In the process of drafting the document SIA has involved communities around the plantation by interview, Participatori Rural Appraisal ( PRA ), focus group discussions as well as the distribution of questionnaires. There is evidence of a meeting with stakeholders , namely meetings with villagers Lalang, Tanjung Rambutan Maruak Downstream the District , the District Subdistrict Paya Bagas Bukit Tinggi dated August 3, 2012 which was attended by the village government , community leaders , youth leaders and citizens are equipped with the attendance list as many as 50 person. There is evaluation of social impact assessment plan in 2012 to 2015 and the report made every year (in 2012, 2013, and 2014 ), in the report containing the location of the village, priority issues, alternative solutions , and implementation in the field, the information of farmer / smallholdings is not available. Compliance status: Full Compliance

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

Findings: There is procedure of communication, participation and consultation number: PK - 3.12-10 which became effective on 23 October 2014. The procedure governing the company's internal communications mechanisms, external communication and communication participation and consultation include relevant form. The company has appointed the person in charge for communication and consultation with the community either in the field or factory. There are a list of stakeholders for plantations and mill and meetings were held with stakeholders with village chiefs, community leaders, partners, and local government. Yet all documented meetings with stakeholders, so that the company has an opportunity to complete the recording of every meeting with stakeholders, this is an a observation to the company for improvement. Compliance status: Compliance with observation

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

Findings: The Company has a mechanism to receive and classify information required from and for stakeholders to know and understand the policy, situation, development of the company and anticipate negative issues. The company has Working Procedures Publication No. PK.3.00-06 Rev. 01 dated 15-09-2014 (one of them using online sms 9600). Its also explained company would to ensure the compalinants and whistleblower. The company has an open system for communication and consultation with local community as represented

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by Work Instruction No. IK-3.09-03/0 (6th revision) dated 15 February 2010. This SOP development process was initiated by the company, but it remains non-published to stakeholders. PT PN III corporate also has call centre 9600 as an open system to receive complaints and grievances from its stakeholders, which is openly announced in the front of estate or mill offices. The call centre is centralised in Medan head office and checked daily by corporate public relationship. Any incoming complaint or request of information from stake-holders through call centre will be forwarded to relevant sections for follow-up. During certification assess-ment audit this call centre was still newly established; no incoming request of information received yet. This makes it difficult to ensure effectiveness of the mechanism. There currently have been no incoming com-plaints regarding the company’s operation. Compliance status: Full Compliance Criterion 6.4: Any negotiations concerning compensa tion for loss of legal, customary or user rights are dealt with through a documented system that ena bles indigenous peoples, local communities and other stakeholders to express their views through t heir own representative institutions. Findings: The company has a mechanism to identify and calculate the compensation, Working Procedure Conflict Res-olution No. PK.3-11.11.12 Rev. 0 dated 02/25/2015. Any risk / conflict can be resolved properly and avoid minimize losses. In the procedure described above re-garding the calculation of the parties who are entitled to receive compensation All estates have established mechanism for identification, calculation and compensation of loss of legal or traditional rights of land, which is acceptable to all parties. However, the company has initiated establishing procedure for land release through Work Instruction No. IK-3.09-03/01 (4th revision), issued on 15 February 2010. During certification assessment, there have been no cases of dispute with any parties that require compensa-tion from each estate manager. Compliance status: Full Compliance

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

Findings: There is Decree of the Governor of North Sumatra Province number : 188.44 / 972 / KPTS / 2014 dated 7 November 2014 on Minimum Wage Fixing North Sumatra Province in 2015, which amounted to IDR 1,625,000. Follow-up of the Decree of the Governor is the Decree of the Board of Directors numbers 3:08 /SKPTS/R/08/2015 dated January 12, 2015 on Employee Salary Increase PT PN 3 2015 adjusted to the provincial minimum wage plus compensation for rent, water, electricity and transport. Based on field and doc-ument check was not found on the payroll of employees who are paid below the minimum wage in 2015. Available Collective Labour Agreement (CLA) year period from 2014 to 2014 that governs the relationship between the company and employees. Agreements presented in Indonesian so it can be understood by all employees , in the agreement are discussed on the rights and obligations of each party. The company has been providing infrastructure such as housing, sports facilities, educational facilities, health, religious facilities by a considerable amount. Compliance status: Full Compliance Criterion 6.6: The employer respects the right of a ll personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargainin g are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel. Findings: Available Collective Labour Agreement (CLA) which regulates the freedom of association / association. In Chapter III of the General section of Article 5 concerning the recognition of an organization described in paragraph 1 " Directors of the company admitted that the plantation workers' union is an organization that is legally available in the company. Have formed unions and bipartite institutions either in the estate or in the

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mill, and has been formed. Company documents all records meeting between members of the union or the company . Compliance status: Full Compliance

Criterion 6.7: Children are not employed or exploit ed.

Findings: There are documents that the minimum age requirements have been met by workers contained in Article 11 point b of work agreement (PKB document) " manpower requirements to be received at least 18 years of age ". based on workers data of employee April 2015 not found employees under the age of 18 years. Then dur-ing the field assessment in harvesting and spraying activity in the estate, and in mill, there is no found any workers under 18 years old. Compliance status: Full Compliance

Criterion 6.8: Any form of discrimination based on race, caste, national origin, religion, disability, gen-der, sexual orientation, union membership, politica l affiliation, or age, is prohibited.

Findings: There is document of recruitment procedures and hiring number: PK - 3.08-01. In this procedure is explained that the process of recruitment through a process that has been set by the company regardless of gender and regional origin . There is document of governing recruitment, appointment levels, promotion, demotion and transfer of work contained in the Cooperation Agreement (CLA) year period from 2014 to 2015 in article 11, 13, 14, 15 and 16. There are examples of recruitment in 2012 with the following sequence : - Announcement of the needs of employees for harvesting on 4 February 2012 is equipped with the

requirements . - File a job application on behalf Ramli , the results of medical tests, and the announcement of the result

of selection which states graduation . Employee assessment process prior to the proposed increase in class example : the name of Edi P Butar - Butar foreman positions I Afdelling group IIB / 5 based on management's assessment has value by 9 and has been out SK Directors numbers : 3:08 / SKPTS / SR / 19/2015 regarding increase level into groups IIC/0. Compliance status: Full Compliance

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

Findings: There are policies on prevention and sexual violence set forth in the Code of Conduct Edition III of Chapter IV of the work ethic point C which states "no sexual misconduct such as sexual harassment, defamation above and subordinates as well as their families". Follow-up of these policies is the release of a circular from Direc-tor number : 3:08/SE/164/2009 dated July 6, 2009 regarding the socialization of the sexual harassment policy. There are policies regarding the protection of reproductive rights of all workers, particularly women contained in the Collective Labour Agreement (CLA) Article 26, paragraph 1, which states " the female employee is entitled to maternity leave for 1 ½ months prior to giving birth and 1 ½ months after childbirth " and Article 27 article 1 which states " that the female employees in the menstrual period pain, not obliged to work on the first day and the second at the time of menstruation". Available evidence that menstrual employees are absent from work, for example : Ms. Toman Napitupulu permit menstruation leave two days on 18-19 April 2015. Silau Dunia estate gender committee already exist on March 5, 2015 is equipped with personnel scattered throughout Afdelling I until VII, so in case of sexual abuse of women can be quickly reported to the representatives of each of the estates. In the event the material flow socialization also described the sexual harassment complaint procedures. Not all estates and mill have gender committee and a complaints mechanism which ensures the anonymity of the complainant. So this is an a observation. It will be seen fur-ther on surveillance audit.

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Compliance status: Compliance with observation

Criterion 6.10: Growers and mills deal fairly and t ransparently with smallholders and other local busi -nesses.

Findings: PT PN III in group already has mechanism for fairly and transparently pricing with outgrowers/smallholders. But, especially for Rambutan palm oil mill, this mill didn’t bought any FFB from outgrowers or thirdparty or smallholder. This mill was set by management only receive FFB from owned estate under PT PN III. So, there is no any mechanism already established by this mill related transparently pricing with smallhold-ers/outgrowers. Compliance status: Full Compliance

Criterion 6.11: Growers and millers contribute to l ocal sustainable development wherever appropriate.

Findings: In conducting its business enterprise involving local contractors that can assist / add income communities around the garden , for example :

- Mill: there are local transactions in 2014 local purchases in the form of purchases of office stationery, photo copy, food, etc. IDR 201.829.914 and 2015 until April IDR 69,420,045.

- Silau Dunia Estate: local transactions in 2014 in the form of transport of fruit IDR 2.723.643.900 , slender pieces Rp. 654 425 400, the transport of empty fruit bunches IDR 91.276.500, plant maintenance IDR 1.640.176.900 and local purchases in 2014 amounted to IDR 782.224.800.

Compliance status: Full Compliance

Criterion 6.12: No Form of forced or trafficked lab our are used.

Findings: The stages of hiring acceptance in accordance with the regulations of the company, was not found employment illegally trafficked or forced labor in any form. There are a list of company employees either fixed or not fixed (daily ), which includes the name, date of birth, origin, began to join in the company, position, etc. There is no contract substitution, all the work done by the contractor is poured in the form of employment contract and direct done by contractors. Not found migrant workers so as not to find mechanisms that regulate migrant labor particularly. Compliance status: Full Compliance

Criterion 6.13: Growers and millers respect human r ights

Findings: The company policy to respect human rights is not yet available, so that there is no evidence of documentation socialization to all workers. So this is raised as nonconformity (NCR 2015 – 10 o f 10). Compliance status: Non Compliance NCR 2015 – 10 of 10 There is no evidenced human rights policy available in place and communicate to all level workers.

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Criterion 7.1: A comprehensive and participatory in dependent social and environmental impact as-sessment is undertaken prior to establishing new pl antings or operations, or expanding existing ones, and the results incorporated into planning, managem ent and operat ions. Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Because information from SEIA document already available in place. The SEAI document assessment report already covered aspect impact (negative and positive) from palm oil development in Rambutan POM and supply based. The SEIA document already covered about replanting activity. Compliance status: Not Applicable

Criterion 7.2: Soil surveys and topographic informa tion are used for site planning in the establishmen t of new plantings, and the results are incorporated into plans and operations.

Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Because the soil type and topographic information already available in EIA and HCV document and al-so explained in related principle and criteria above. Compliance status: Not Applicable

Criterion 7.3: New plantings since November 2005, h ave not replaced primary forest or any area re-quired to maintain or enhance one or more High Cons ervation Values.

Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Year of planting since November 2005 in Rambutan POM supply based not from new planting but came from replanting. Compliance status: Not Applicable

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

Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Based on HCV and EIA document there is no marginal and/or fragile soil in Rambutan POM spplied based. Some area has 40% slope, but when carried out field assessment to the location, there is no slope condition in the area. Compliance status: Not Applicable Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and i n-formed consent, dealt with through a documented sys tem that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institu-tions. Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Because there is no new planting in Rambutan POM supply based, and only replanting activity, and based on field assessment and public consultation with stakeholders, there is no information and/or issue stated by community. Compliance status: Not Applicable

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Criterion 7.6: Local people are compensated for any agreed land acquisitions and relinquishment of rights, subject to their free, prior and informed c onsent and negotiated agreement

Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Accordance to criteria above, there is no information and issue stated by local community and based on field assessment there is no compensation process carry out by company. Compliance status: Not Applicable

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

Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. Based on field assessment replanting activity already done by company used manual land clearing. Compliance status: Not Applicable

Criterion 7.8: New plantation developments are desi gned to minimise net greenhouse gas emissions.

Findings: There is no new planting activity since November 2005 in all estate, so this criteria not applicable and did not verify. But the company has a work program to minimize and reduce the greenhouse gases emission from mill and estate activity. Compliance status: Not Applicable

Criterion 8.1: Growers and millers regularly monito r and review their activities and develop and im-plement action plans that allow demonstrable contin uous improvement in key operations.

3.2 Identified Non-conformances against RSPO P&C Re quirements, Corrective Actions Taken and Audi-tors Conclusions

During this certification assessment, a total of 10 nonconformances against the RSPO Principles & Criteria Generic year 2013 were identified. These consisted of 5 major non-conformities and 5 minor non-conformities. While for RSPO SCCS found 3 major nonconformaces against to the RSPO SCCS Require-ment System November 2014. For the major non-conformances, the company has taken the necessary corrective action to close most of these non-conformances, and this was verified by the audit team through checks of documents submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and the closure of these minor non-conformities will be assessed during the next surveillance audit. A summary of all identified non-conformances, corrective actions taken and auditor conclusions is as below:

Criteria 2.1.1 (Major) Evidence of compliance with relevant legal requirements shall be available

NCR 2015 – 01 of 10 (Major) Found Silau Dunia estate noncompliance between approval and discussion implement of EIA document, were EIA document was approved in 2008 and discussion implementation carried out in 2009.

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Correction : Revised the date of EIA document approval of Silau Dunia estate to 2009 based on point number 1 in approval letter mentioned that the EIA discussion carried out in 2009 and EIA Assessor Comission of Serdang Bedagai district accordance to the letter number 660/02/KP-AMDAL/2009 dated on Apeil 24, 2009. Corrective Action taken : Documented all related approval of EIA document Silau Dunian estate. Auditor Conclusions : Closed Verification result: The company has submitted the letter of EIA document approval. While in approval letter mentioned that the EIA document discussion implementation carried out on April 21, 2009. this difference happen be-cause typing eror while writing. Date of closure: July 30, 2015 Criteria 4.2.1 (Minor) There shall be evidence that goo agriculture practices, as containced in Standard Operating Procedure (SOPs) are followed to manage soil fertility to a level that ensures optimal and sustained yield, where possible.

NCR 2015 – 02 of 10 (Minor) Found in Tanah Raja estate the fertilizing activity for immature palm oil not met with fertilizer recom-mendation while based on recommendation the immature palm oil should applicate Dolimite and NPK fetilzer, but realization only NPK applicated by estate.

Correction : Complete the fertilizer implementation for immature palm oil accordance to fertilzer recommendation. Corrective Action taken : Documented all of fertilizer recommendation for immature and mature plantation. Auditor Conclusions : Evidence of correction/correc tive action will be verified during next audit

Criteria 4.5.1 (Major) Implementation of Integrated Pest Management (IPM) plans shall be moni-tored.

NCR 2015 – 03 of 10 (Major) Found in Tanah Raja Estate Ganoderma attacked about 23% or 470 Ha, but there is no any record found to handling the attack. Correction : Carried out the hoarding all palm tree attacked by Ganoderma as a metioned in work instruction number IK.No.3.01-03/12. Corrective Action taken : Carried out handling management to all palm oil tree attacked by Ganoderma as a mentioned in recom-mendation continuously. Auditor Conclusions : Closed Verification result: Estate has submitted the evidence of Ganoderma handling attacked for all plam oil tree through the pho-tograph of palm tree hoarding. Date of closure: July 30, 2015

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Criteria 5.1.2 (Minor) Where the identifiations of impacts requires changes in current practices, in order to mitigate negative effects, a timetable for change shall be developed and implemented within a comprehensive management plan. The managem ent plan shall identify the responsible person/persons.

NCR 2015 – 04 of 10 (Minor) Found in Silau Dunai and Sei Putih Estate some noncompliance between environmental management plan with implementation, where enrichment vegetation has been planted was different with environ-mental management plan recommendation. Correction : Propossed to the plant department of PT PN III, to ensure the seedlings procurement should reffer to environmental managament plan recommendation. Corrective Action taken : Carry out the environmental management implemtation through the enrichment reffer to environmental management plan recommendation. Auditor Conclusions: Evidence of correction/correct ive action will be verified during next audit. Criteria 5.2.2 (Major) Where rare, threatened or en dangered (RTE) species, or HCVs, are present or area affected by plantation and mill operations, appropriate measures that are expected to maintain and/or enhance them shall be implementend through a management plan.

NCR 2014 – 05 of 10 (Major ) Based on HCV assessment identification in Gunung Monaco estate found RTE species, but there is no found any record showed that estate maintain and enhance the RTE species. Correction : Develop action plan related protect with purpose to maintain and enhance the RTE species. Corrective Action taken : Carry out RTE species monitoring also follow up the HCV management plan especially for RTE species to maintain and enhance that species. Auditor Conclusions : Closed Verification result: Estate has provide the RTE species action plan for 2016 in Gunung Monaco estate, while the activity consist of: communicate the RTE species to the all workers and community about prohibited the activity will disturbing the RTE species; signboard installment to protect the HCV area and RTE species, protect the river bufferzone, and monitoring habitat and species periodically. Date of closure: July 30, 2015 Criteria 5.2.3 (Minor) There shall be a programme t o regularly educate the workforce about the status of these RTE species, and appropriate discip linary measures shall be instigated in ac-cordance with company rules and national law if any individual working for the company is found to capture, harm, collect or kill these species.

NCR 2015 – 06 of 10 (Minor) There is no comprehensive activity related RTE species protection in Rambutan mill and Sei Putih es-tate thorugh the appropriate disciplinary measures accordance to the company regulation and national regulation if found the workers capture, collect, kill, hunting and others the RTE species. Correction : Develop action plan related the RTE species protecttion if any. Corrective Action taken :

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Carry out the comprehensive related RTE species protection accordance to the company and national regulation and law, through the collect, capture, hunting prohibition of RTE species, and if any workers violate the company and national regulation and law will penalty by company. The estate has submitted the intern memo number KSPTH/Int/VII/95A/2015 dated on July 25, 2015 about announcement of RTE species protection for all level workers to prohibition of collect, hunting, kill, or catching the RTE species will penalty by company accordance to the company and national law and regulatin. Auditor Conclusions: Evidence of correction/correct ive action will be verified during next audit.

Criteria 5.3.2 (Major) All chemicals and their cont ainers shall be disposed of responsibly.

NCR 2015 – 07 of 10 (Major) It was found that assigned waste collector and transporter was not have an authorised for waste pro-duced in Rambutan Mill, Tanah Raja, Gunung Monaco, Sarang Giting, Silau Dunia and Sei Putih Estate. Correction : Complete the collect and transport hazardous waste permit/license from Rambutan palm oil mill, Gunung Monaco estate, Sarang Gitting estate, Silau Dunia estate, Tanah Raja estate and Sei Putih es-tate. Corrective Action taken : Ensure the third party (contractor) for hazardous collection and transportation has a complete license for hazardous handling. Auditor Conclusions : Closed Verification result: The company has ensure the hazardous contractor license, i.e.:

- License for hazardous utilization for PT Tenang Jaya Sejahtera accordance to the Decree of Environmental Ministry number 30/2012. This license valid for 5 years from date of issued on February 7, 2012.

- License for hazardous utilization for PT Triguna Pratama Abadi accordance to the Decree of Environmental Ministry number 238/2010. This license valid for 5 years from date of issued on September 27, 2010 (was not valid).

- License for hazardous collection for PT Putra Tunas Sejati, accordance to the Decree of Envi-ronmental Ministry number 324/2010. This license valid for 5 years from date of issued on De-cember 28, 2010 (was not valid).

- Work agreement about hazardous handling between PT Putra Tunas Sejati with PT Tenang Ja-ya Sejahtera number No.05/MS-TJS/VII/2015 dated on 13/07/2015.

- Work agreement about hazardous handling between PT Triguna Pratama Abadi with PT Putra Tunas Sejati number No.119/TPA-MOU/III/2015 dated on March 09/2015.

- Hazardous transportation recommendation decree of Environmental Ministry number B-3859/Dep.IV/LH/PDAL/04/2014 for PT Tenang Jaya Sejahtera. This license valid for 5 years from date of issuedon April 15, 2014.

NCR 2015 – 08 of 10 (Major) Found in Rambutan palm oil mill housing burned garbage activity. Correction : Provide the policy about waste/garbage handling in workers housing. Corrective Action taken : Provide the rubbish hole in back yard of workers housing to control the domestic waste and signboard installment of burned prohibition and ensure the organic and organic waste should separate. Auditor Conclusions : Closed Verification:

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The company has issued the intern memo number PRBTN/Int/084/2015 dated on Februari 03/2015 about domestic waste handling for organic and anorganic domestic waste accordance to the Governe-ment regulation number 81/2012 about domestic waste handling without burning activity. Date of closure: July 30, 2015 Criteria 5.6.3 (Minor) A monitoring system shall be in place, with regular reporting on progress for these significant pollutants and emissions from estate and mill operations, using appropriate tools. NCR 2015 – 09 of 10 (Minor) Rambutan palm oil mill and all supplie based estate has calculated the GHG emission, but the GHG cal-culation still not complie with appropriate tools and reported to the RSPO. Correction : Carried out the GHG emission calculation with new version and develop the mitigation management plan to reduce all the emission resulted by mill and estate activity. Corrective Action: Ensure the GHG calculation carry out every year and develop the management plan to reduce the emis-sion and pollution. Auditor Conclusions: Evidence of correction/correct ive action will be verified during next audit.

Criteria 6.13 (Major) Growers and millers respect h uman rights.

NCR 2015 – 10 of 10 (Major) There is no evidence that human rights policy available in place and has been communicate to all level workers. Correction : Revised the sustainable palm oil policy with include the PT PN III commitment to human rights respect. Corrective Action taken : Periodically review for PT PN III policy to ensure the policy was compliance with law and regulation. Auditor Conclusions : Closed Verification: The company has revised the company policy related commitment PT PN III and added the human rights respect in to company policy. This policy revised in September 2015. Date of Closure: July 30, 2015

3.3 Description of Supply Chain Management System

E.1 Definition

Findings: Accordanced to the explanation in the report section 1.2 Type of Assessment, to re-active again the e-Trace of Rambutan mill has been suspended, Rambutan Palm Oil Mill will implemented the RSPO SCCS Modul E, whereas this modul was Mass Balance. This system will allow the palm oil mill to re-ceive certified and uncertified FFB in one time and/or produce the certified and uncertified product in

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the same time, the keep in CPO storage tank together, but shall be control by mass balance system, to ensure the certified raw material until certified product still treace and recorded, and only certified prod-uct can be claime certified by palm oil. Based on informastion record for 2015, Rambutan Palm Oil mill received FFB from owned estate uncer certification scope (Tanah Raja, Sei Putih, Sarang Giting, Silau Dunia and Gunung Monaco estate), and also others estate under PT PN III (Rambutan, Gunung Para and Gunung Pamela estate) and third party. In 2015, Rambutan mill received FFB from all estate under scope audit about 125,777.74 mt, from others estate under PT PN III (Rambutan, Gunung Para and Gunung Pamela) about 68,160.53 mt. While certified CPO produced about 32,035.59mt and PK certified produced about 10,608.42 mt. Then, until May 2016, raw material received from Rambutan palm oil mill supply based about 6,356.26 mt with certified production of CPO about 1,515.50 mt and PK about 313.80 mt. While from others estate under PT PN III about 5,886.24 mt FFB, and produced about 1,387.98 mt CPO and 294.91 mt PK uncertified. Until during the certification assessment, Rambutan estate didn’t claimed any certified product Compliance status : Full Compliance

E.2 Explanation

Findings: Rambutan Palm Oil Mill has record of estimated certifed products production (CPO and PK) that could potentially be produced from owned estate under Rambutan supply base, i.e.: Tanah Raja estate, Silau Dunia estate, Gunung Monaco estate, Sarang Giting estate, and Sei Putih estate. The estimated certi-fied production will presented on the public summary in table 4. Rambutan Palm Oil Mill during the certification assessment, did not registered yet in RSPO IT Plat-form/e-Trace, and also during the certification assessment, the mill still prepared and developed the system to preventiv action when the IP system will run in the mill. Compliance status : Full Compliance

E.3 Documented Procedures

Findings: Rambutan Palm Oill Mill has established the procedures to implementation SCCS-MB, where the pro-cedures such as:

- IK-3.03-03/02 Rev00 about weighbridge activity - IK-3.03-03/11 Rev00 about FFB grading in loading ramp - PK-3.03-11 Rev01 about supply chain mechanism system - IK-3.03-02/02 Rev00 about production storage - PK-3.03-08 Rev01 delivery product in to Belawan installation, PT SAN, PT IKN, PKSMK and

others buyer - IK-3.03-12/01 Rev01 about FFB receiveing process in palm oil mill - PK-3.07-42 Rev00 about sales certified RSPO SCCS product mechanism - PK-3.07-43 Rev00 about certified RSPO SCCS kernel sale

Rambutan mill has established the person will be incharge to the RSPO SCCS implementation based on decree of Rambutan Mill Manager number PRBTN/SKPTS/05/2015 about established the person incharge i.e.: mill manager, asst mill manager, asst process, technique asst, human resource asst. per-son incharge has get the RSPO SCCS training on March 15, 2014 evidenced by attendant list and pho-tograph of training. Rambutan palm oil mill has mechanism/procedure for receiving and processing certified and uncertified FFB’s in the mill, in document number PK-3.03-11 Rev01 about supply chain system mechanism. On this procedure explained, every certified FFB received in mill through the wighbridge, the person in-charge in the weigbirde should ensure the FFB transport slip (PB25) complete by RSPO SCCS infor-mation and stamp. Compliance status : Full Compliance

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E.4 Purchasing and goods in

Findings: Rambutan palm oil mill has record of FFB incoming and FFB process in 2014 and 2015. Based on pro-duction record, Rambutan mill has separetly in mass balance record between FFB owned estate and outgrowers. Because Rambutan mill will implement RSPO SCCS MB, so the mill not necessary se-paretly in mill process between certified and uncertified raw material and product, but mill shall control in mass balance record. Only FFB come from 5 estate under Rambuatan supply base estate will claim as a certified FFB source under Rambutan mill audit scope. And for this, Rambutan mill has verify and identify also record the FFB produced and incoming Rambutan palm oil mill has mechanism to infor the CB if any over production projected through the email. But during the certification assessment, Rambutan mill not produced yet the certified product claimed as MB. Compliance status : Full Compliance

E.5 Record keeping

Findings: Rambutan palm oil mill has no record related of RSPO SCCS MB FFB’s receiving, and production certi-fied and certified product delivery also three montly basis. Because during the certification assessment mill still developed the system and Rambutan mill has record for this. Mill has identified and separtely in production record between FFB’s incoming from owned estate and outsource through the mass balance record production. This mass balance record showed information about date of incoming FFB, FFB origin, production process, product (CPO and PK), delivery to the storage tank and dispatch process from certifed and uncertified raw material until product. Mass balance record also showed the three monthly basis format, if RSPO SCCS MB will run in the future. Then, procedure also mentioned mill can be deliver product if mass balance stock is positive. Rambutan mill no have any outsources activities related their production activity. Compliance status: Full Compliance

3.5 Identified Non-conformances against RSPO SCCS R equirements, Corrective Actions Taken and Audi-tors Conclusions

Accordanced to the explaination in the report in Section 1.2 Type of Assessment, this report will replace about RSPO SCCS MB IP before, into RSPO SCCS MB will implement in Rambutan mill. The NCR relating IP model no more relevant. To ensure the real implementation of RSPO SCCS MB will check in next surveil-lance.

3.6 Noteworthy Positive Components

-

3.7 Issues Raised during Stakeholder Consultation M eeting

Below is a summary of issues raised by stakeholders interviewed during stakeholder consultation meeting.

No. Issues Raised Stakeholder Management Response Audit Verification

1.

1. Rambutan palm oil mill located very closed to national roads, it will be brought environ-ment pollution and emission. May be

Cempedak Lobang Head subdistrict

Rambutan palm oil mill developend since 1983. Where the Rambutan palm oil mill developend, the location still far from the community, national roads and other public facilities, but when the region developed, rural developend

Rambutan palm oil mill carried out the environmental management and monitoring measurement periodically and

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the mill location more better if locat-ed far from the na-tional roads.

2. Due to the impact

of FFB transporta-tion, Tanah Raja road villages was not good condition.

3. CSR application already submitted for many times to PT PN III manage-ment, but there is no follow up because the estate manager more frecuently change, and the new estate manager asked for new proposal, but always with now fol-low up action until the end of duty, so the PT PN III couldn’t showed the commitment.

4. There is charity aid

from PT PN III al-ready implemented, such as the charity aid for Mosque and School but please more increased.

5. There is road between PT PN III boundary with the another company, width 8 meters and lenght 13 km, the road under PT PN III (Tanah Raja estate), we ask for be paved by

Sei Buluh Head subdistrict Cempedak Lobang Head subdistrict Sei Buluh Head subdistrict Cempedak Lobang Head subdistrict

into the urban, the mill was located closed to the public facilities. But, for the pollution and emission prevention mitigation, the mill carry out the emission, polllution measurement periodically accordance to the EIA matrix for management and monitoring as a requirement in law and regulation. Roads broken condition in Tanah Raja was not becuase FFB transportation, becuase FFB transport from the Tanah Raja estate using the other way (estate road). PT PN III will acomodate the road maintenance of Tanah Raja village in next CSR program and will submit again to the head office. Every CSR proposal submitted to the Tanah Raja estate already respon and forwarded to the district office. And in the district office the related department will follow up the CSR. From Tanah Raja Estate to the Cempedak Lobang village, CSR already implemented with the data presented below: a. In 2011, CSR for public facilities

for mosque. b. In 2013, for Dusun I – II

Cempedak Lobang village, already implemented the CSR through the charity aid for facilities building such as mosque, and others.

c. The Tanah Raja estate will more effort to the CSR commitment in all village around in Tanah Raja Estate.

- It is true that the road part of land use rights (HGU) PTPN III Tanah Raja Mill until now the road still in good condition and the community used this roads, and the Tanah Ra-ja Estate never cross the road since estate build big canal to reduce the thief.

reported to Environmental Agency in every 6 month. Based on field verification, FFB transport from Tanah Raja estate, not used village roads but through the estate roads. Based on document and field verification, the company was distributed and implemented the CSR program, but the CSR program and budget still need the corporate because related the financial condition, so the estate or mill only received the budget from HQ to implemented according the CSR program. - Based on audit verification, Tanah Raja estate not used that road, because estate used they owned road inside concession area.

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asphalt using state budget, but reject-ed. Because the ownership status, could the community using the road for activity, because the village position in the middle of estate

6. Is the law from supreme court not implemented, because based on the regultion, the thef with under 2,5 million should not been arrest, but when the community thef under 2,5 million, they will be arrested.

Cempedak Lobang Head subdistrict

Each arrest for thef of FFB produc-tion in PT PN III, already law and regulations, Tanah Raja Mill calculate the value of FFB loses has been stolen, from immature until mature, include security personal costs when cheked crime scene, so the value of losses more than 2,5 Million.

-

2.

1. PT PN III already implemented the OSH management system for 10 years with good achieve-ment.

2. Always get achievement for “Zero Accident”.

3. For law and regula-tion compliance the PTPN III was complie especially related workers regulation and law.

4. PT PN III using the outsourcing for sev-eral activity in es-tate.

Head of Workers Union

1. PT PN III has implemented SM-PN3 such as: ISO 9000, ISO 14.000, OSH, RSPO, ISPO and others, and periodically checking through the surveillance audit by independent auditor.

2. In 2014 Tanah Raja estate has Zero Accident Certificate from Serdang Bedagai district and Ministry of Labour.

3. PT PN III and Tanah Raja estate always up to date law and regulations and evaluated com-pliance consistenly.

4. As a company commit to complie with law and regulations, PT PN III used the outsource and third party.

-

3.

1. Do not let us making the portal because the village road was broken by the company activities.

2. The recruitment process please in-form and made transparent to all community.

3. Please increased the soft loan to all community in the village.

1. In 2014 during Ir Alben Simatupang as a Manager, Tanah Raja estate already implemented road maintenance about 1.5 km and consistenly until now so there is no reason for community to make a portal on the road.

2. The last recruitment of Tanah Raja estate was in 2012 and has been inform to the Village, through the billboard. The em-ployee was recruited in 2012 ma-jority came from village around of Tanah Raja estate.

-

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3. Soft loan for community has been implemented through the founding program every quartare.

4

1. Our village very closed with division I Sarang Giting estate and we already got CSR for Public facilities such as mosque, school and others.

2. The recuitment process preferred for the local community from our village, because there are still many unemployed.

5

1. Village Road near to Gunung Monaco estate has been broken, please note.

2. Workers Union should awere to thee employee are not used PPE during in work location, such as harvesters and oth-ers.

3. Palm Oil Mill activity produced waste. So that, the mill should be provide alot of positive impact to community and en-vironment. So the mill contributions will balance with the waste produced.

4. To the outgrowers third party should complete with the FFB nets during the FFB transport process to reduce the accident.

5. Workers Union should be more ef-fort during works.

6. Please note to Sipispis Head Subdistrict, give at-tention to the bro-ken road as impact estate acitivity.

1. Rambutan palm oil mill located in

between Serdang Bedagai border with Tebing Tinggi, so many the positive impact to economic and social, such as:

- Job vacancy for around the local community

- CSR for local community through the charity, schoolarship, training, soft loan and others.

2. Already made MoU to outgrowers transport to provide nets during the FFB and EFB transport process.

3. The workers union will responsed the workers aspiration and submitt to management

6

1. Roads in Sipispis subdistrict was bro-ken.

2. The proposal for

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road maintenance submitted more than once, but there is no response from management, lo-cated in Simalas vil-lage.

7

1. Good relationship between company and community.

2. To PT PN III to give more attention to all head of village es-pecially for village near of company.

8

Many thanks to PT PN III was invite us to fol-low the stake-holder consulta-tion. So many charity has real-ized by PT PN III to all community member and with the palm plantation pre-sent, many posi-tive impact was gave to commu-nity.

9

1. Gunung Monaco vil-lage has submitted proposal to PT PN III for grave rehabili-tation, this proposal almost 3 – 4 year has submitted but there is no re-sponse form com-pany.

2. We hope the CSR will realize every year for Gunung Monaco village.

10

Community rela-tion between PT PN III as long as was good espe-cially with Silau Dunia Estate. We hope estate more effort to accept the local people to get job on the estate, and more CSR in education for local community, also incentive for head of community in every year.

Bandar Nagori Ujung Village

a. Every employee reqruitment, the estate/management informed to the village through the announcement letter, and if any local community passed the test, the company will higher that local community.

b. Management has concerned the education schoolarship from elementary until senior highschool every year.

c. Please submitted the budget plan for 2016, to realized the incentive for community head.

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11

1. Please concern to PT PN III manage-ment for rehabilita-tion of roads, com-munity housing, drainage for waste water and public fa-cilities.

2. Provide soft loan for community.

3. Provide seedlings and cattle for com-munity to increase the economic level

12

1. Maintain good rela-tionship with com-munity.

2. Maintain the envi-ronmental condition and protect form wastewater pollu-tion.

3. Please provide fog-ging to reduce the dengue in commu-nity.

13

Were communi-ty will complaint if PT PN III con-taminate the en-vironmental, be-cause one of re-quirement certi-fication is envi-ronmental condi-tion.

Rambutan Palm Oil mill has invited multistakeholder (community, official government, head of community, and others related) to brief and communicated the conflict prcess flowchart if any. And commit to maintain the environmental condition, this was evidenced by get the certificate of ISO 14001, PROPER from Ministry of Environmental of Indonesia, Green Industry level 5 from Ministry of Industry of Indonesia.

14

1. Recruitment pro-cess in 2014 fpr Do-lok Masihul subdis-trict, Pertambatan village especially not accepted by LPP for registered to PT PN III em-ployee in Silau Dunia estate, please for note.

2. Please provide in-centive to all head of village.

Pertambatan vil-lage

a. Because the Pertambatan village most close with Sarang Giting estate, so the recruitment vacancy process will in that estate, also zoning location for recruitment process determined by corporate.

b. Please to submit budget 2016 to Corporate level because this need corporate approval.

15

1. Community in around of Sarang Giting estate, was helped by PT PN III presence, because the community many receive the CSR program such as basic needed, public facilities, scholarship and

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others. 2. Community hope,

when the company open vancany please the local community to be priority.

16

1. The PT PN III pres-ence in the com-munity was good, because the com-munity many re-ceived the CSR program.

2. Please provide in-centive to head vil-lage.

Silau Dunia estate

The company will maintain the good relationship with all community. Please submit the budget 2016 to corporate level, because this need corporate approval.

17

1. Community hope, if their proposal still in process, the estate manager, please do not replace.

2. Please provide in-centive to head vil-lage.

3. Community rela-tionship with com-pany was good, es-pecially in religion and education rela-tionship.

18

1. Until this time the company especially in religion activity was good.

2. Repair public facili-ties especially in re-ligion such as reli-gion school more better for the next future.

3. Please provide the religion teachers for school.

19

Please, the communication between com-pany with local community should increase especially in subdistrict level.

Rambutan palm oil mill will maintai the communication to all related stakeholders and will keep in good relationship with local community.

20

1. Coordination be-tween company and local government please to be main-tain.

2. Recruitment pro-cess, the local community please to be priority.

21 1. Air pollution dis-

turbed the commu-nity.

1. For air pollution handling,

Rambutan palm oil mill has carried out the emision and air

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2. Rambutan palm oil mill has pay atten-tion through the CSR program to in-crease the commu-nity social level.

pollution measurement and the result showed the air pollution was in under standard as required in national regulation law.

2. The CSR program and realization are PT PN III commitment to increase and maintain good relationship to all community.

22

1. Please, that the company provide the office stationery per monthly to in-crease the service process for all community.

2. Please note, the coordination level between company and subdistrict gov-ernment.

3. Increase the good relationship be-tween local gov-ernment.

23

1. Please, if any reqruitment process in PT PN III, the lo-cal community to be a priority.

2. Please the CSR program to be dis-tributed the all vil-lage.

3. Please provide the softloan for com-munity.

4. Please provide in-centive to head vil-lage.

1. The reqruitment process was covered all local community, although not local community accepted by company becuase qualification reason.

2. The CSR program was distributed to all village, the the budget adjust with company financial condition.

3. The company provided the softloan, but not all softloan program fulfill by company, because the financial condition.

4. The incentive program to all head of village still not implemented by company. This need corporated level approval.

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4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INT ERNAL RESPONSIBILITY

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

It is acknowledged that the assessment visit was carried out as described in this report and we accept the assessment findings and report content.

Signed on behalf of PT Perkebunan Nusan-tara III …………………………………………. Tio Handoko, Head of Management System Date : June 10, 2016

Signed on behalf of TUV Rheinland Indonesia ………………………… Mhd Fundy Cholis Kurniawan Lead Auditor Date : June 10, 2016

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APPENDICES

Appendix 1: Details of Certificate

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Appendix 2: List of Abbreviations

AMDAL Analisis Dampak Lingkungan & Sosial (Social & Environmental Impacts Assessment)

BPN Land used Agendy (Badan Pertanahan nasional) CHRA Chemical Health Risk Assessment CPO Crude Palm Oil CSPO Certified Sustainable Palm Oil EIA Environmental Impact Assessment ERTs Endangered, Rare & Threatened species ESH Environmental Safety & Health FFB Fresh Fruit Bunches EFB Empty Fruit Bunches GHG Green Houses Gases HCV High Conservation Value HGU Hak Guna Usaha (Land Use Rights) HIRARC Hazard Identification, Risk Assessment and Risk Control HPL Land Manage Right (Hak Pengelolaan Lahan) IPM Integrated Pest Management IK Instruksi Kerja (Work Instruction) KTARA Kebun Tanah Raja (Tanah Raja Estate) KSPTH Kebun Sei Putih (Sei Putih Estate) KSGGI Kebun Sarang Giting (Sarang Giting Estate) KSDUN Kebun Silau Dunia (Silau Dunia Estate) KGMNO Kebun Gunung Monaco (Gunung Monaco Estate) LTA Lost Time Accident MSDS Material Safety Data Sheets MB Mass Balance NGO Non-Government Organization NIB Building Identification Number (Nomor Indentifikasi Bangunan) OSH Occupational Safety & Health PKO Palm Kernel Oil POME Palm Oil Mill Effluent PPE Personal Protective Equipment PPKS Pusat Penelitian Kepala Sawit (Oil Palm Research Center) PRBTN Pabrik Kelapa Sawit Rambutan (Rambutan Palm Oil Mill) PTPNIII PT Perkebunan Nusantara III RKL Rencana Pengelolaan Lingkungan (Environmental Management Plan) RPL Rencana Pemantauan Lingkungan (Environmental Monitoring Plan) SIA Social Impact Assessment SMK3 System Manajamen Kesehatan dan Keselamatan Kerja

(Occupational Safety & Health Management System) SOP Standard Operating Procedure SPBUN Serikat Pekerja Perkebunan (Estate Workers Union) UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pengelolaan Lingkungan (Environmental Management Efforts)

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Appendix 3: List of Stakeholders Interviewed and Co ntacted

No. Name of Stakeholder

Institution - Address Remark

Stakeholders Interviewed On-Site 1. Elvin Ginting Supervisor Head Office 2. Khairul Anwar Land tittle staff Head Office 3. Sahat Simanjuntak Head Office document controller Head Office 4. - Safety Health officer Mill and estate 5. - Sprayers worker

6. - Harvesters worker KTARA, KSDUN and KGMNO

7. - IPM staff KSDUN, KSPTH and KSGGI

8. Rina Paramedic Mill 9. Rianto Chairman of Mill Workers Union Mill 10. Edi Ginting Public relation KSDUN 11. Purnawati House holder Pondok Bengkok KSDUN 12. Abdul Sani Silalahi Land claimers (Penggarap) KSDUN 13. Misro Aliandi Land claimers (Penggarap) KSPTH 14. Erianto Head of Village (Kadus) KSPTH 15. - Operator boiler Mill 16. - Operator engine room Mill

17. - Estate manager KTARA, KSDUN, KGMNO, KSGGI and KSPTH

18. - Document controller KTARA, KSDUN, KGMNO, KSGGI and KSPTH

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Appendix 4: Attendend list of stakeholder consultat ion meeting

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Appendix 5: Observations and Opportunities for Improvement

No. Observations / Opportunities for Improvement Crit eria

1 Need to be informed to all community related revised the short message sending cen-tre (SMS Centre) number.

1.1.1

2 Need to socialized/brief all procedure/work instruction in Rambutan oil mill and all es-tate, because the procedure not all workers can be accessed.

4.1.2

3 Need to signboard installment more to reminder about fire burning, maintaian and pro-tected the HCV area to all estate and mill.

5.5.1

4 Need to carry out the housekeeping in warehouse. -

5 The company has carried out the stakeholder meeting consultation, but the documen-tation did not showed, because the person incharge forget keep store the document.

6.2.3

6 Not all estate has gender committee and mechanism for complain and protect the ano-nymity respects complaints

6.9.3