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Roundtable on Sustainable Palm Oil Public Summary Report Report no.: 82450216034 Certification assessment against the RSPO Principles & Criteria Generic Standard 2013& RSPO Supply Chain Certification System year 2014 PT Gunung Tua Abadi Sumber Sawit Palm Oil Mill South Sumatera Indonesia Date of assessment: November 09 to 13, 2015 Report prepared by: Dian S Soeminta (RSPO Lead Auditor) Certification decision by: Abdul Qohar (Director of TUV Rheinland Indonesia) Certification Body: PT TUV Rheinland Indonesia Menara Karya, 10 th Floor Jl. H.R. Rasuna Said Block X-5 Kav.1-2 Jakarta 12950,Indonesia Tel: +62 21 57944579 Fax: +62 21 57944575 www.tuv.com/id

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Roundtable on Sustainable Palm Oil Public Summary Report

Report no.: 82450216034

Certification assessment against the

RSPO Principles & Criteria Generic Standard 2013&

RSPO Supply Chain Certification System year 2014

PT Gunung Tua Abadi Sumber Sawit Palm Oil Mill

South Sumatera Indonesia

Date of assessment:

November 09 to 13, 2015

Report prepared by: Dian S Soeminta

(RSPO Lead Auditor)

Certification decision by: Abdul Qohar

(Director of TUV Rheinland Indonesia)

Certification Body: PT TUV Rheinland Indonesia

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

Jakarta 12950,Indonesia Tel: +62 21 57944579 Fax: +62 21 57944575

www.tuv.com/id

TABLE OF CONTENTS

1.0 SCOPE OF CERTIFICATION ASSESSMENT 3

1.1 National Interpretation Used 3

1.2 Type of Assessment 3

1.3 Location and Maps 3

1.4 Description of Supply Base 5

1.5 Dates of Plantings and Replanting Cycles 6

1.6 Other Achievements and Certifications Held 6

1.7 Area of Plantation (Total, Planted and Mature) 6

1.8 Organisational Information / Contact Person 7

1.9 Description of Company History, Socioeconomy & Environment 7

1.10 Time Bound Plan for Other Management Units 8

1.11 Compliance to Rules for Partial Certification 9

1.12 Plan for certification of associated smallholders 10

1.13 Approximate Tonnages Certified 10

1.14 Recommendation for Certification 10

1.15 Date of Certificate Issued and Scope of Certificate 11

2.0 ASSESSMENT PROCESS 12

2.1 Certification Body 12

2.2 Qualifications of Lead Assessor and Assessment Team 12

2.3 Assessment Methodology 13

2.4 Stakeholder Consultation and Stakeholders Contacted 15

2.5 Date of Next Surveillance Visit 15

3.0 ASSESSMENT FINDINGS 16

3.1 Summary of Findings 16

3.2 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions 50

3.3 Noteworthy Positive Components 59

3.4 Issues Raised by Stakeholders and Findings Pertaining to Issues 60

3.5 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client 68

APPENDICES 69

Appendix 1: Details of Certificate 69

Appendix 2: Certification Audit Plan 71

Appendix 3: List of Abbreviations 76

Appendix 4: List of Stakeholders Interviewed and Contacted 76

Appendix 5: Observations and Opportunities for Improvement 77

RSPO Certification Assessment Report

- PT Gunung Tua Abadi – Sumber Sawit Palm Oil Mill –

South Sumatera indonesia

Page 3 of 78

QMF: RSPO-007a-13(Rev.0)

1.0 SCOPE OF CERTIFICATION ASSESSMENT

1.1 National Interpretation Used

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

1.2 Type of Assessment

The main certification assessment was carried out on 1 of mills (Sumber Sawit Estate) and 1 estate under PT Gunung Tua Abadi and 1 estate under PT Mutiara Bunda Jaya i.e. (Inti Permata Bunda 2 estate) furthermore noted only Inti Permata Bunda Dua estate owned by PT Sampoerna Agro Tbk. Sumber sawit estate devided into 2 sub estate called district namely Sumber sawit sub district and Balian sub district. The main assessment all estate and sub estate under PT Gunung Tua Abadi and One estate only under PT Mutiara Bunda Jaya i.e. Inti Permata Bunda Dua estate.

1.3 Location and Maps

Figure 1. Location PT Gunung Tua Abadi & Inti Permata Bunda Dua estate in South Sumatera Province Indo-

nesia.

RSPO Certification Assessment Report

- PT Gunung Tua Abadi – Sumber Sawit Palm Oil Mill –

South Sumatera indonesia

Page 4 of 78

QMF: RSPO-007a-13(Rev.0)

Figure 2. PT Gunung Tua Abadi, Sumber Sawit Mill an d Sumber Sawit estate.

Figure 3. Inti Permata Bunda Dua Estate

RSPO Certification Assessment Report

- PT Gunung Tua Abadi – Sumber Sawit Palm Oil Mill –

South Sumatera indonesia

Page 5 of 78

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Table 1: GPS locations for all estates and mills in cluded in certification assessment

1.4 Description of Supply Base Table 2: FFB Supply Information for Sumber Sawit P alm Oil Mill year 2015 and projection year 2016

FFB Contributors FFB supplied year 2015

FFB Suplied year 2016 (projec-

tion)

Tonnes % Tonnes %

Company owned estates :

Sumber Sawit 94,359 40.42 85,751 38.64

IPBD 26,700 11.43 25,336 11.41

Sub Total 121,059 51.85 111,087 48.05

Others Company’s estate

Hikmah 3 47,597 20.38 49,262 22.19

Hikmah 5 43,987 18.84 45,741 20.61

Belida 15,294 6.5 - -

Surya Adi 452 0.19 - -

Mesuji 1,192 0.51 - -

IPBS 699 0.29 - -

Sub Total 109,221 46.71 95,003 42.8

Smallholder/Outgrower Plasma Pagar Dewa 3,165 1.35 15,879 7.15

Total 233,445 100 221,969 100

Table 3: CPO and PK production from SUmber Sawit Pa lm Oil Mill in year 2015 and projection year 2016

Name of mill / es-tate

Location GPS locations Latitude Longitude

Sumber Sawit Mill Village of Balian, Subdistrict of Mesuji Raya

03˚ 48' 29,44" 105˚ 11' 57,03"

Sumber Sawit Estate Village of Balian, Subdistrict

of Mesuji Raya

03º48’25” 105º10’34”

IPBD 2 estate Village of Balian, Subdistrict

of Mesuji Raya 03°47'5.61" 105° 9'32.25"

FFB supplied in 2015

( Tonnes ) OER

CPO

(Tonnes) KER

PK

(Tonnes)

233.443 22.01 51,373 5.65 13,184 Projection FFB supplied in 2016

( Tonnes ) OER

CPO

(Tonnes) KER

PK

(Tonnes)

221.969 23.10 51,275 5.5 12,208

RSPO Certification Assessment Report

- PT Gunung Tua Abadi – Sumber Sawit Palm Oil Mill –

South Sumatera indonesia

Page 6 of 78

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1.5 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 table below. Table 4: Age and year of plantings of company estat e supplying to Sumber Sawit Mill

Age & Year of Plan t-ings

Oil palm planted area at each estate(ha)

Sumber Sawit estate IPBD 2 estate

2015-2011 4.42 -

2010-2006 541.55 434.79

2005-2001 906.05 778.11

2000-1996 1,642.2 -

1995-1991 1,098.69 -

1990-1986 -

TOTAL 4192.91 1,212.90

There is no replanting plan for next 5 years both in PT Gunung Tua Abadi and IPBD 2 estate. Replanting plan for Sumber sawit estate will be planned next 2020 as stated on the Company’s long term plan, while for IPBD estate all plantation still young.

1.6 Other Achievements and Certifications Held Table 5: Details of other certifications or awards held by PT Gunung Tua Abadi (PT Sumber Sawit estate ,

PT IPBD estate and PT Sumber Sawit mill.

Name of mill / es-tate

Certification Standard / Award achieved

Certification Body / Awar der

Date Achieved

Sumber Sawit mill ISPO TUV Nord 16 January 2014

Sumber Sawit Estate ISO 14001:2004 ISO 9001:2008 ISPO

TUV Nord TUV Nord TUV Nord

28 January 2014 28 January 2014 16 January 2014

IPBD Estate ISO 14001:2004 ISO 9001:2008 ISPO

TUV Nord TUV Nord TUV Nord

27 January 2014 27 January 2014 7December 2014

1.7 Area of Plantation (Total, Planted and Mature)

Table 6: Oil Palm Planted Area Summary, FFB Product ion and Average yield/ha for PT Gunung Tua Abadi and IPBD Estate

Estate Name Total area (ha)

Oil Palm Planted area (ha)

Mature (Production) area (ha)

Immature (Non-production) area (ha)

FFB Production*

(tonnes) Average

yield/ ha

Year 2014 2014 2015*

Sumber Sawit

5032 4188.43 4188.43 - 63,809,400 94,359 20.65

IPBD Estate 1527.92 1,212.72 1,212.90 - 24,159,600 26,700 19.91

RSPO Certification Assessment Report

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South Sumatera indonesia

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TOTAL 6,559.92 5,401.15 4,188.43

Note: production until year October 2015 budget for year 2015 is 65,612,302 kg; budget for year 2014 is 80,905,000

Table7: Land use data for PT Gunung Tua Abadi & IPB D Estate

Estate Name

Total area (ha)

Oil Palm Planted Area (ha)

HCV/

Poten-tial HCV areas* (ha)

Land used for other purposes (ha)

River/wet land mill Housing

Road con-struction Occupied

Sumber Sawit

3,696 3,089.8 304.18 9.40 24.80 16.4 161.56 89.86

1,336 1,098.63 105.75 - 0 3.00 55.29 73.33

IPBD Estate 1527.92 1,212.72 - 118.50 - 4.20 6.20 28.70

TOTAL 6,559.92 5,401.15 109.93* 127.9 24.80 19.4 223.05 191.89 Source: Areal statement 2015 HCV area include on company’s productive are

1.8 Organisational Information / Contact Person

Contacts details of the company are as follows:

1.9 Description of Company History, Socio-economy & Environment Sampoerna Agro is a diversified plantation company currently engaged in the production of Germinated Oil Palm Seed, Crude Palm Oil and Palm Kernel, and Slab Rubber .The oil palm plantation segment, which pro-duces the Fresh Fruit Bunch (FFB) from which Crude Palm Oil (CPO) and Palm Kernel (PK) is milled, two sub-sidiearies under Sampoerna Agro Tbk i.e. PT Gunung Tua Abadi which is have Sumber Sawit Palm Oil Mill and their Supply based i.e. Sumber Sawit estate and Inti Permata Bunda Dua Estate ( an estate part of PT Mutiara Bunda Jaya) with a total land holding of 6,559.92 ha, of which 5,401.15 ha has been planted. Sumber Sawit mill has a total milling capacity of 60 tonnes/hour.

Table 9: General Information on Estates under PT Gu nung Tua Abadi and Inti Permata Bunda 2 Estate

No. Description Estate Sumber sawit estate IPBD 2 estate

1. Government Administration office

Dabuk Makmur; Balian, Balian Makmur; Sungai Sodong Kecamatan Mesuji Raya kabupaten Ogan Komering Ilir

Village of Balian, Subdistrict of Mesuji Raya

Plantation Kabupaten Ogan Komering Ilir

Company Name: PT Gunung Tua Abadi & PT Mutiara Bund a Jaya (Inti Permata Bunda Dua Estate)

RSPO Membership no. 1-0031-07-000-00 under PT Sampoerna Agro

Address: Adress : Jl. Basuki Rahmat 788, Palembang 30127, South Sumatera

Village of Balian, Subdistrict of Mesuji Raya

Contact Person: Yusi Rosalina

Telephone: Tel : +62-711-813388

Email: Email:[email protected]

RSPO Certification Assessment Report

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South Sumatera indonesia

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No. Description Estate Sumber sawit estate IPBD 2 estate

Administration office 2. North IPBD estate Plasma KKPA Balian,

Balian Village East Pagar Desa village Pagar Dewa Village South KKPA Permata Bunda Corporation, Sumber Sawit estate West Balian Makmur Village Sungai Sodong

Village 3. Land Condition Undulating flat until Undulating 4. Soil type Aluvial and podsolik Aluvial and podsolik 5. Climate B B 6. Topography 3-15% 3-15%

1.10 Time Bound Plan for Other Management Units The time frame laid out below is considered to be both challenging and realistic. Table 10: Time Bound Plan of PT Sampoerna Agro Tbk.

Name of Holding Location Time bound plan for certification

Status

PT Aek Tarum 1. Mesuji Smallholder 2. Belida Smallholder

South Sumatera 2015 Processing certification

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

South Sumatera 2016 2016 2015 2019 2019

Planned

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

South Sumatera 2015 2015 2018

Processing certification Planned

PT Bina Sawit Makmur Surya Adi estate

South Sumatera 2016 Planned

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

South Sumatera 2016 2016 2019 2019 2019 2019 2019 2019

Planned

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

South Sumatera 2016 2016 2016 2016 2016 2019

Planned

PT Sungai Rangit Sungai Rangit Palm Oil Mill

Central Kalimantan 2016

Planned

RSPO Certification Assessment Report

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South Sumatera indonesia

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Name of Holding Location Time bound plan for certification

Status

Baboti Estate Rauk Naga Estate Sungai Sagu Estate Waringin Estate Sukamara Estate Telaga Bintang Estate Sungai Rangit Smallholder

2016 2016 2016 2016 2016 2016 2019

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

1.11 Compliance to Rules for Partial Certification

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

Partial Certification Requirements Audit Findings

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

PT GunugnTua Abadi (Sumber Sawit Palm Oil Mill, Sumber sawit estate and Balian Estate) and PT Mutiara Bunda Jaya (Inti Permata Bunda Dua Es-tate are subsidiary of PT Sampoerna Agro Tbk. Sampoerna Agro has been a member of RSPO since 10 January 2007 With membership no 1-0031-07-000-00.

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

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

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

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

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

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

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

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

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

1. Mega Terang estate with community from Sungai Menang Village for 600 ha located in Block 14, 15 and 16 Mega Terang Estate. Cur-renty on the legal processed. According to

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South Sumatera indonesia

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Partial Certification Requirements Audit Findings

management confirmation, the company still harvest that conflict area because the land compensation payment was clear.

2. PT Aek Tarum with Mataram Jaya dan Com-munity of Kemang Indah village. According to company explanation the case has been closed because unclear reason from the land claimer.

3. PT Mutiara Bunda Jaya with community of Sungai Menang and Rantau Durian I Village, has been closed since a year ago due to Small-holder scheme decree letter from head of Dis-trict has been issued.

Some action has been taken to solve the conflict.

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

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

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

There are two management units under Sampoer-na Agro have not complied with certain legal re-quirements, i.e. PT Sungai Rangit and PT Mutiara Bunda Jaya, there are issues regarding land title. The process for land title the company is taking ac-tion by inviting the National Land Agency (BPN) to remeasure the land and resolve the issue. The pro-cess is still ongoing.

1.12 Plan for certification of associated smallhold ers

As seen from data in Table 3, the mill receives more than 40 % supply of FFB from smallholders, of which 5 % of these are smallholders associated with the mill.

The mill has developed a plan for certification of associated smallholders as seen on Planning for Smallhorder PT GTA towards to RSPO P & C year 2015.

1.13 Approximate Tonnages Certified

The approximate tonnages certified, based production in year 2015 for company owned estates only are as fol-lows:

Crude Palm Oil (CPO) : 26,645 tonnes Palm Kernel (PK) : 6,839 tonnes While the projection for FFB production for year 2016 is 111,087 tonnes from companies’ owned estate. Crude Palm Oil (CPO) : 25,661.097 tonnes Palm Kernel (PK) : 6,109.785 tonnes

1.14 Recommendation for Certification Sumber Sawit Palm Oil Mill and its supply bases PT Gunung Tua Abadi and Inti Permata Dua estate has es-tablished and maintains an effective system to ensure compliance with the RSPO principles and criteria. The audit team has confirmed through the audit process that the company’s practices complies with, adequately maintains and implements the requirements of RSPO Principles and Criteria Generic Standard. PT TUV Rheinland Indonesia recommends that Sumber Sawit Palm Oil Mill and its supply bases PT Gunung Tua Abadi and Inti Permata Dua estate be approved as a producer of RSPO Certified Sustainable Palm Oil.

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1.15 Date of Certificate Issued and Scope of Certif icate

The scope of the certificate covers production of palm oil from PT Gunung Tua Abadi; Sumber Sawit palm Oil Mill and its supply base, which includes Sumber Sawit Estate and Inti Permata Bunda Dua estate. The date of certificate issued is April 25, 2016. Further details of the certificate are as per Appendix 1.

RSPO Certification Assessment Report

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2.0 ASSESSMENT PROCESS

2.1 Certification Body PT TUV Rheinland Indonesia is member of Group TÜV Rheinland Group, a global leader in independent test-ing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. PT TUV Rheinland Indonesia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Validations and Verifications. PT TUV Rheinland Indonesia’s office is located in Jakarta, Indonesia.In year 2014, PT TUV Rheinland Indonesia has been accredited by Accreditation Services International for RSPO certification and other related RSPO requirement with accreditation number RSPO-ACC-013.

2.2 Qualifications of Lead Assessor and Assessment Team

Name Position Qualifications / Experience

Dian S Soeminta Lead Auditor

Education: Bachelors Degree in Forestry - Bogor Agriculture Insti-tute. Indonesia, (1990 to 1995).

Trainings attended : ISO 9001:2000 lead assessor course 1996 - Neville Clark; ISO 14001 lead assessor course - PE International; OSHAS: 2007 training, Sustainable Forest Management (SFM) - Forest Stewardship Council (FSC) system training; Chain of Cus-tody training for FSC System. RSPO lead Auditor training year 2010 by Pro Forest and Wild Asia. SCCS training by David Ogg Consulting. ISPO Lead Auditor training Working experience: Professional forester since 1995 to 2000. Lead Auditor for Forest Stewardship Council (FSC), Sustainable Forest Certification (SFC) and Chain of Custody (COC) Certifica-tion. Lead auditor for Environmental Management System (EMS) and Quality Management System (QMS) audits. Conducted sus-tainable forest management certification audits on FSC and Indo-nesian Ecolabel Institute (Lembaga Ecolabel Indonesia - LEI) standards for 20 companies, 50 COC FSC/LEI audits, and EMS and QMS audits at more than hundred companies for TUV Rhein-land Indonesia. Instrumental in the preparation of TUV Rheinland Indonesia for Sustainable Forest Management Certification System and TUV Rheinland Malaysia for RSPO Certification. Member of Task Force for Indonesian National Interpretation (Guidance on scheme smallholder RSPO certification). Developed TUV Rhein-land RSPO acceditation process and report template.

M. Fundy Cholis Kurniawan

Auditor

Education : Bachelor of Agriculture (social and economic of agri-culture) – Bogor Agriculture University. Trainings attended : ISO 9001:2008 Lead Auditor training – TUV Rheinland Indonesia, Sustainable Forest Management training –Forest education and training center, ISPO training - Commission of ISPO. Working experience : Social research – Indonesian Centre for Agricultural (Social Economic and Policy Studies) since 2003-2007, Social Researcher – CSR Indonesia since 2007-2010, So-cial Economic Expert – Mott MacDonald Indonesia since 2010-2011, Personal consultant in research and development – Colors Media Group since 2011-2013, RSPO & ISPO auditor at TUV Rheinland Indonesia since 2013 -present.

Monang Lingga Auditor Education : Bachelor of Forestry, Gadjah Mada University. Training attended : ISPO Auditor, Quality Management System

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Name Position Qualifications / Experience

(QMS) Auditor/Lead Auditor (ISO 9001:2008) by IRCA, Environmen-tal Management Systems Auditor/Lead Auditor Conversion Training by IRCA (ISO 14001-2004), Lead Auditor RSPO Training, and HCVA Training Working experience : Field Assistant PT Sapta Karya Damai (2008-2013), Auditor in PT Sucofindo (2013-2015), and Auditor in PT TUV Rheinland Indonesia (2015-present).

Suriadi Auditor

Education : Diploma Applied Analitycal Chemistry. North Sumatra University, Medan and Bachelor of Chemical Engineering, Univer-sity of Jaya Baya, Jakarta. Trainings attended: ISO 9000:2000 Series Auditor / Lead Auditor Training - PE International (Jakarta), IEMA Advanced EMS Auditor (IEMA / EARA ISO 14001) Auditor / Lead Auditor Training Course - PE International (Jakarta), OHSAS 18001 Lead Auditor Training Course - PE International (Jakarta). ISPO lead auditor training. Na-tional Examination Board of Occupational Safety and Health (In-ternational General Certification (IGC) 1,2 and 3 TUV Nord (Du-bai). National Examination Board of Occupational Safety and Health (International Technical Certification (ITC) for Oil and Gas Industries. RRC (Dubai). Indonesian Engineer Association (PII) (Jakarta), Occupational Health and Safety Specialist for lifting equipments. Indonesia Man Power and Transmigration Depart-ment (Jakarta). Working experience: Experienced in Quality Control from 1992-2004. Coordinator for Safety Quality and EnvironmentManagement System since 2002 – present. Auditor for Environmental Manage-ment System since 2002 – present. Auditor for OHSAS 18001 since 2012 - present. Conducted over 10 Quality Management System audits Environmental Management System audits and OHSAS

2.3 Assessment Methodology The certification assessment was conducted between November 09 to 13, 2015 as per the assessment pro-gram below. The assessment was carried out in accordance with PT TUV Rheinland Indonesia’s RSPO audit procedure as well as the RSPO Certification Systems document. During assessment, the qualified TUV Rhein-land assessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without com-promising the integrity of the assessment in anyway. All 2 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 evidence was recorded for individual estates. Interviews were conducted at all estates and the mill. The company proposed the correction and corrective action for all identified non conformities raised to the cer-tification body 30 days after the closing meeting. Verification of closure of major non-conformances was con-ducted 2 months after the closing meeting of the main assessment and implementation of corrective actions for minor non-conformities will be verified during the next suriveillance audit. The certification assessment agenda is as explained below. Main Assessment Agenda. Date Location Agenda

09.11.2015 PT GTA Office Opening meeting

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Date Location Agenda

- Introduction and background of estate and mill - Audit team introduction and audit plan finalization - Document Checking

10.11.2015 PT GTA estate, and Of-

fice

Site Visit: - Interviews with Sprayers for Sumber Sawit Division - Interview and Pest & Diseases Team for Sumber

Sawit estate & smallholder scheme - Interview with contracted FFB loaders - Interviews with harvesters and loose fruit pickers - EFB Application area - Chemical store

Sumber sawit Estate office: Document Review Legal Requirements (OSH & Environment), OSH, Training, SOP’s of Legal requirements register & implementation ,Field operations (spraying, harvesting, manur-ing), fertilizer application records, chemical application records, chemical stock inventory ,Worker interviews , visit of PT GTA Estate Chemical stores,Workshops,HIRARC,OSH Committee & safety records, Accident records,Training & PPE issuance, Waste storage also Hazardous waste inventories & manifest. On-site visit: Sumber Sawit Estate harvesting on block 72 and Block 110.

Interviews: Head of Sumber Sawit Estate, agronomist personal and Manager estate, Spraying, Harvesting and Manuring workers.

11.11.2015 Dabuk Makmur Village. PT GTA Estate

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

Filed Checking - Land application at IPBD 2 - Checking HCV area - Boundary with - Riparian … - Water Reserve and water dam - Boundary stone no. 60 Blok 78B & 79B - Boundary stone No.9 blok 66 B. - Harvesting activities - Dabuk Makmur Village - Worker’s housing area

12.11.2015 IPBD estate

Embacang Village Site Visit: - EFB application - Sparyer activities - Housing area - Chemical warehouse - IPM implementation - Beneficial plant plantation - Harvesting activities - Riparian river… Document Review Legal Requirements (OSH & Environment), OSH, Training, SOP’s of Legal requirements register & implementation ,Field operations (spraying, harvesting, manur-ing), fertilizer application records, chemical application records, chemical stock inventory ,Worker interviews , visit of Sumber Sawit Estate Chemical stores,Workshops,HIRARC,OSH Com-mittee & safety records, Accident records,Training & PPE issu-

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Date Location Agenda

ance, Waste storage also Hazardous waste inventories & mani-fest, Land Application field. On-site visit: Inti Permata Bunda Dua Estate harvesting and chemist spraying on block 46B and Block 54 and 64 Interviews: Head of Inti Permata Bunda Dua Estate, agronomist personal and Manager estate, Spraying, Harvesting and Manur-ing workers

13.11.2015 Sumber Sawit Mill Mill site visit - Mill compound - Loading ramp - Security post - Lubricant store - Effluent treatment ponds - Interviews with mill workers from boiler and clarification stations Document Review: OHS, Environmental, Issues related to Legal compliance ,Occupational Safety & Health implementa-tion,Training , AMDAL, UPL/UKL, RKL/RPL Aspect Impact Anal-ysis,Verification of previous audit findings On-site visit: plant tour. Interviews: Head of Mill, staff operation, kerani(foreman) and Mill Worker ( operators)

2.4 Stakeholder Consultation and Stakeholders Conta cted The stakeholder consultation involved both external and internal stakeholders. External stakeholders were noti-fied to make comments on the certification assessment by placing an invitation to comment on the RSPO web-site. Stakeholders included those immediately linked with the operation of the company such employees, out-growers, the local government, NGO’s, trade and labour unions and local communities. Stakeholder consultation took place in the form of meetings and interviews. Meetings with stakeholders were held to seek their views on the performance of the company with respect to the sustainability practices outlined in the RSPO Principles & Criteria, and to comment on aspects where improvements could be made. Meetings with local communities were held at their respective premises within and near the company’s area. A stake-holder consultation meeting was also held on Dabek Makmur Head of Village office on [November 11, 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 discussion proceeded to obtain the stakeholders feedback on the company’s compliance to different aspects of the RSPO Principles & Criteria. Although several stakeholders were not familiar with RSPO but they agreed with its objective and expressed their willingness to collaborate in the promotion of sustainable palm oil in South Sumatera province. In all interviews and meeting, the assessment team did not restrict discussion of both the positive and negative aspects of operations conducted by PT Gunung Tua Abadi estates and mill. The stakeholder consultation meeting held with stakeholders during the audit was extensive and productive, with an attendance of more than 40 of attendees]. This was followed by site inspections, including visits to the local communities, interviews with land claimants and contractors, and inspections of worker amenities and in-frastructure. All stakeholder issues raised were recorded and forwarded to the management for their written re-ponse, and this is summarized in Section 3.4.The list of stakeholders that attended the stakeholder consultation meeting and stakeholders interviewed during the assessment is included as Appendix 4.

2.5 Date of Next Surveillance Visit The next surveillance visit is planned for November 2016

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3.0 ASSESSMENT FINDINGS

3.1 Summary of Findings: RSPO Principle and Criteria During the certification assessment, total 18 nonconformities were raised, 8 nonconformities were assigned against Major Compliance indicators while 10 nonconformities were assigned against Minor Compliance Indica-tors. The 17 observations or opportunities for improvement were identified. Further explanation of the non-conformities raised and corrective actions taken by the company are provided in Section 3.2. The observations & opportunities for improvement are listed in Appendix 5. The following is a summary of findings made for the criteria listed in the RSPO Principles & Criteria Generic Standard 2013.

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

Findings:

Management PT GTa has commintment to provide adequate information on (environmental, social and/or legal) issues relevant to RSPO Criteria to relevant stakeholders, it was stated on the IMS Procedure P-SAG-RO-CAS-08 rev.08. PT GTA has indicated releavant stakeholder that affected to operational planta-tion and also mills, such as Dinas perkebunan, BLHD, head of villages, head of sub district, community leaders, tributary leaders, NGO, Contractors, representative from workers, FFB suppliers, smallholder representative, etc. The list of stakeholder will be updated every 6 months.

All records of incoming request of information keep maintained by Corporate, Affair and Legal (CAL) de-partement and notified on Log Book of Stakeholder Communication (LB-SAG-RO-CAS-080001).

Unit head records incoming letter from external parties, CAL department distribute to relavant section in plantation or mill regarding the information requested or relevant issue. Sustainibility department is re-sponsible to handle issue related to product quality, environment, safety and health. CAL will response to requesting parties after get confirmation from respective section. The response for incoming request of information will be given 14 days after request come as stated on IMS prosedur P-SAG-RO-CAS-08 rev.08 dated November 01, 2015.

Until the final audit most of incoming letter related to request of donation, there is no letter regarding re-quest of information. Compliance status: Full Compliance

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

Findings: The IMS Porcedure P-SAG-RO-CAS-08 rev.2 dated November 1st, 2015 section 7.1.4 state informations and document that can publicly available include but not limited to: - Land titles/user rights Legal boundaries ,land use, classification, total area, grant title, permit validity , - Occupational health and safety plans risk assessment and mitigation ,emergency response plan, train-

ing, accident records - Plans and impact assessments relating to environmental and social impacts main social and environ-

mental impacts and mitigation measures, - identification on HCV areas, maps, management and monitoring HCV - identification of pollutants, management and reduction measures - nature of complaints, parties involved, status of case

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- SOP, consultative, neutral, inclusiveness, timeframe, Audit report - Human Rights Policy All information about all avaiable for public upon request. Compliance status: FullCompliance

Criterion 1.3.

Findings: Management PT Sampoerna Agro as holding company has determined a policy committing to a code of ethical conduct and integrity in all operations and transactions. The policy was signed by Sampoerna Agro Chief Executive Office on July 1st, 2015. Management commit to conduct all business in ethical and full integrity following the corporate vision mission and the culture of Sampoerna Way.

The policy include information about respect of fair conduct of business, prohibition of all forms of cor-ruption, bribery and fraudulent use of funds and resources and proper disclosure of information in ac-cordance with applicable regulations and accepted industry practices.The policy has been available on the Bahasa and was communicated to all workers on July 05, 2015 and clearly understood by staff from all level, including local business, contractor and suplier s. It was sight during the main audit, records of socialization of the policy dated September 21, 2015 to housing contractor (CV Bangun Boswa), Dabek Makmur villages, 21 participant from heavy equipemt contractors.

Records of communication and socialization were available such as list of participant, photograps and minutes of meeting.

Compliance status: Full compliance.

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

Findings: The company has effort to comply with all applicable local, national and ratified international laws and regulations. Company have copies of applicable legal requirements were kept by General Affairs de-partement. Some evidences to comply with legal requirements were signt during main audit such as: Sumber Sawit Estate and GTA Palm Oil Mill PT GTA (Estate and Mill) has record of list document of law and regulation as guidelines for the company related to the plantation, workers, environmental activity, with document named is evaluation of Legal re-quirement compliance. The document showed the article should be fulfilled and level of requirement. The company has record of legal requirements was compliance by the estate and mill, such as: 1. Plantation permits No.65/KEP/D.PERKE/2004, with area 5,302 Ha, located in Sungai Sodong, Balian

and Embacang village, Mesuji District, Ogan Komering Ilir Regency. Issued date on December 30, 2004.

2. Temporary Hazardous Storage No.660.1/15/KEP/B.LH/2012, with hazardous type are allowed to be stored such as oil, accu, second cotainer, oil filter, chemical container, fertilizer second sack, lamp, second cartridge, printer ribbons, waste/container contaminated by hazardous waste, and all of haz-ardous waste type from estate and mill activity, with 90 days for storage. Still valid during the 1st sur-veillance.

Environmental feasibility permit No. 540/166/KEP/K-PELH/2006, covered area for 5,302 Ha and Mill with capacity process was 60 tonnes FFB/hours. Issued on June 29, 2006. Inti Permata Bunda Dua Estate (IPBD Estate) IPBD estate has record of list law and regulation as guidelines for company related all activity in estate such as estate, workers, environmental and others. The document showed the article should be fulfilled and level of requirement. Another company effort to comply with applicable of legal requirements such as: 1. Hazardous waste temporary permit No. 681/KEP/B.LH/2015, valid for 3 years until September 10,

2016 with type of hazardous waste to be allowed all of hazardous waste result from all estate activity,

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South Sumatera indonesia

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with 180 days for storage. 2. Renewal of Land application based on Decree of Head of Regent of Ogan Komering Ilir No.

660.1/31/KEP/B.LH/2014, valid for 3 years since the issued on June 30, 2014, with field number for land application was 68, 69 and P1 located in PT Gunung Tua Abadi and field number 64 and 65 in PT Mutiara Bunda Jaya, with total area for land application about 300 Ha.

3. Plantation permit No.029/KEP/D.PERKE/2009, this permit covered for 12,500 Ha areas for palm oil plantation, located in Tanjung Sari I, Tanjung Sari II, Tanjung Sari III villages, Rantau Durian II, Lempuing Jaya District and Cinta Jaya village. IPBD estate located inside this permit.

Mill and estate has established the procedure document number P-SAG-RO-SUS-07 Rev01, date issued June 1st, 2012 about laws and others regulation compliance. The procedure explained that Head of Ad-ministration will responsible for maintain law and regulation document, and Sustainability department will distribute that document to all related department, conduct review in once year to ensure the compliance. Company also has appointed the person in charge will responsible to ensure, maintain, and conduct in-ternal audit for law and regulation compliance. Evidenced that the list of law and regulation was distribut-ed by the company to all related department was record by email dated on August 18, 2015, at 1:39 PM. The company has conduct the revision to procedure related Law and others regulation document number P-SAG-RO-SUS-07 Rev02 dated on October 30, 2015 (during the audit still in draft). This draft explained about mechanism for evaluation of law and regulation compliance in every once year. Procedure for eval-uation for result of evaluation compliance to law and regulation also available in document number P-SAG-RO-SUS-06 Rev01, date issued on August 1st, 2012, in page number 7, point 3 through the man-agement review. However it was also found activities in PT GTA both Sumber Sawit Mill, Sumber Sawit estate and IPBD estate against to some regulation and this has been raised as non conformity i.e. a. There is evidence that casual workers for Division IV with Employee Number (EN) 8413 ; Siti Nur

Employee No. 8361 and employee number 8406 for four consecutive months from March to June 2015 has been working for more than 21 days per month. This is contrary to the Decree no. 100 in 2004, as well as POM employees named Maryono .

b. Found some POM workers who have exceeded the limits set forth in the overtime as required by Manpower Regulation (Permenaker) No. 102 in 2004 and have not been reported to the relevant agencies among which ( in July 2015 )

c. Containt of first aid box in the POM office and for several locations in the estate office does not match that set out in Menpower Regulation (Permenaker) No. Per.15 / Men / VIII / 2008 on the con-tents of the box standard P3K.

d . From as many as 23 operators ( 9 lifting operator ; 9 Steam boiler operators ; 4 operators of elec-tricity ; 1 welder ) which have trained ( 4 operators of steam boiler , 2 lifting transport operators , 1 operator of electricity ) but for 17 remaining operators stil have not been trained ( related to P & C 4.8).

e . 2 medical personnels in the GTA have not trained yet in accordance with the work program of com-pliance regulations are made.

f . GTA's POM has not been able to show a permit stating if GTA’s POM capacity is 60 tones FFB's / hour.

g . First aid box is also not available in the FFB truck transporter. The company has a mechanism to identify all applicable legal requirements for all operational activities. i.e. P-SAG-RO-SUS-07 Rev 01, date issued 01 Juni 2012 Head of General Affairs department will update annualy the list of applicable regulation and Sustainibility department inform to all respective section for implementation and ensuring the compliances. There is a mechanism to ensure that legal regulation has been comply and implemented i.e. through internal audit process. It was conducted by dsustainibilty section every once a year. SOP P-SAG-RO-SUS-07 Rev 01, date issued 01 Juni 2012 has been include system for tracking any changes in the law including the person inchage to update the changes of regulation. Some documents showing legal ownership or lease, history of land tenure and the actual legal use of the land are available i.e.: - Land use right certificate (Hak Guna Usaha) No. 15 located on Balian Village, Mesuji Sub District,

Ogan Komering Ilir District.. Valid until 23/11/2039 for 306 Ha according to decree letter No. No.159/HGU/BPN/2004 dated November 11, 2004

- Land use right certificate (Hak Guna Usaha) No. 14 located on Balian Village and Embacang Vil-lage, Mesuji Sub District, Ogan Komering Ilir District.. Valid until 23/11/2039 for 1336 Ha, accord-ing to decree letter No. No.159/HGU/BPN/2004 dated November 11, 2004

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- Land use right HGU No.03 located in Sungai Sodong and Balian Village , valid until 30/04/2038 with area 3.390 Ha according to SK HGU No.27/HGU/BPN/2003 dated April 15, 2003.

- SK HGU No.159/HGU/BPN/2004 decree letter of Head of national Land Authority regarding land title located in Ogan Komering Ilir District, Mesuji Sub District South Sumatera District with area 1.642 Ha valid for 35 years

- SK HGU No.27/HGU/BPN/2003 decree letter of Head of national Land Authority regarding land title located in Ogan Komering Ilir District, Mesuji Sub District South Sumatera District with area 3,390 Ha valid for 35 years..

Compliance status: Non Compliance Non-conformance 2015-01 of 18 (Major non-conformi ty) PT GTA has not comply with some of relevant laws and regulations , for example : a. There is evidence that casual workers for Division IV with Employee Number (EN) 8413; Employee

No. 8361 and employee number 8406 as well as POM employees has been working for more than 21 days per month in more than 4 months,. This is against to the man power and transmigration decree letter no. 100 in 2004,

b. Found some mill workers have exceeded overtime limit as required by Manpower Regulation (Permenaker) No. 102 in 2004 and have not been reported to the relevant agencies.

c. Contain of first aid box in the POM office and for several locations in the estate office does not match that set out in Menpower Regulation (Permenaker) No. Per.15 / Men / VIII / 2008 on the con-tents of the box standard P3K.

d. From as many as 23 operators ( 9 lifting operator ; 9 Steam boiler operators ; 4 operators of elec-tricity ; 1 welder ) which have trained ( 4 operators of steam boiler , 2 lifting transport operators , 1 operator of electricity ) but for 17 remaining operators stil have not been trained .

e. 2 medical personnels in the GTA have not trained in accordance with the work program of compli-ance regulations are made.

f. The mill can not showed operation license for 60 tones FFB's / hour mill capacity g. First aid box is not available in the all FFB truck transporters.

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

Findings: PT Gunung Tua Abadi, Sumber Sawit Estate showed legal ownership i.e.: 1. Decree of Head Land Agency No.159/HGU/BPN/2004 dated November 11, 2004 about license of

land use rights covered area 1,642 Ha for Gunung Tua Abadi, valid for 35 years, located in Mesuji District. This decree followed by HGU certificate issued, i.e.: a. HGU certificate No.15; Desa/Kelurahan Ogan Kemering Ilir, valid until 23/11/2039 covered for

306 Ha based on Decree HGU No.159/HGU/BPN/2004 dated November 11, 2004. This certifi-cate was issued in Kayu Agung on November 24, 2004 by Head of Land Agency of Ogan Ko-mering Ilir Regency.

b. HGU certificate No.14; Desa/Kelurahan Ogan Kemering Ilir, valid until 23/11/2038 covered for 1,336 Ha based on Decree HGU No.159/HGU/BPN/2004 dated November 11, 2004. This cer-tificate was issued in Kayu Agung on November 24, 2004 by Head of Land Agency of Ogan Komering Ilir Regency.

2. Decree of Head Land Agency No.27/HGU/BPN/2003 dated April 15, 2003 about license of land use rights covered area 3,390 Ha for Gunung Tua Abadi, valid for 35 years, located in Mesuji Dis-trict. This decree followed by HGU certificate issued, i.e.:HGU certificate No.03; Desa/Kelurahan Ogan Kemering Ilir, valid until 30/04/2038 covered for 3,390 Ha based on Decree HGU No.27/HGU/BPN/2003 dated April 15, 2003. This certificate was issued in Kayu Agung on April 30, 2003 by Head of Land Agency of Ogan Komering Ilir Regency.

Some evidence of land compensation before land accuired e.g. 1. Record of land compensation of Desa Sungai Sodong, Mesuji district, was done in 1996. This book

showed the record of land compensation and agreement of compensation. 2. Record of land compensation of Balian village, Mesuji district, was done on July 21, 2003. This

compensation process between company and one villager in Balian village for area 16 Ha. Following the legal land ownership, the hectarage statement for 2015 and plan for revision in 2016. As

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presented below: Plantation Condition 2015 2016 Mature palm oil tree* 4,195.45 4,188.43 Immature palm oil tree - - Total planted 4,195.45 4,188.43 Mill 24.80 24.80 Infrastructure (road, emplacement, river/natural stream dan drainage)

245.65 245.65

Conservation area 405.51 409.93 Total cultivated area 4,871.41 4,868.81 Others** 160.59 163.19 Total area 5,032.00 5,032.00

Note: *) Mature: planted area revision, because area was 4.42 Ha in division I was excluded from planted area because this

area was low land, and converted to conservation area. **) Claimed by local community was increased because there is re-measurable and re-calculate was get the actual result. Based on field observation, in block number 001A was indicated about ± 2 Ha oil palm planted outside of HGU in Balian Estate. The management has not made clear action for that land. This is raised as non-conformity (NCR 2015-02 of 18 ). Legal boundary has clearly demarcated and visibly maintained, it was observed during field verification on block no. 79 division III (boundary number 49, 50 and 47) showed that the boundary condition was well maintained and accessable. Company has work instruction for maintenance and builds the boundary stone with document number WI-SAG-KBN-PML-0206 Rev0 issue date 02/03/2015. Procedure mentioned the boundary stone maintenance conduct in once year through the cleaning around the pillars and replace in any missing. Map of boundary pillars issued by national land autorithy was available on estate office site, it was stated the total boundary pillars was 87, consist of Sumber Sawit division 38 pillars and 49 pillars in Balian division. But, during the main audit the company can not showed record of boundary pillars maintenance in Balian division. This is raised as non-conformity (NCR 2015 03 of 18 ). IPBD Estate This estate has legal land use rights (HGU), based on records of: 1. Decree letter from Head of Land Agency of Ogan Komering Ilir Regency number 002/SK-

IL/OKI/1996 about location permit for palm oil plantation development as much 11,500 Ha, consist of 3,500 Ha for nucleus estate and 8,000 Ha for smallholder. Located at Mesuji District, Ogan Ko-mering Ilir Regency. Issued in Kayu Agung dated March 14, 1996.

2. Decree letter from Head of National Land Agency number 48/HGU/BPN/2003 about land use rights (HGU) for PT Mutiara Bunda Jaya as long as 35 years for 1,268.5 Ha in Mesuji District, Ogan Ko-mering Ilir Regency for palm oil plantation development. Issued in Jakarta dated September 10, 2003.

3. Decree letter from Head of Land Agency of South Sumatera Province number 02/HGU/BPN-26/2004 about the land use rights (HGU) for PT Muatiara Bunda Jaya as long as 35 years for 102 Ha in Mesuji District, Ogan Komering Ilir Regency for palm oil plantation development. Issued in Palembang dated October 19, 2004.

4. Land use rights (HGU) certificate number 04 Desa/Kelurahan: Balian, valid until 17/09/2038 for total area was 1,268.5 Ha based on Decree letter from Head of National Land Agency number 48/HGU/BPN/2003.

5. Land use rigts (HGU) certificate number 13 Desa/Kelurahan: Balian, valid until 23/11/2039 for total area was 102 Ha, based on Decree letter from Head of Land Agency of South Sumatera Province number 02/HGU/BPN-26/2004.

Total area under IBPD estate was 1,370.5 Ha. Record of hectarage statement are available on the estate, with consist of:

Plantation condition 2015 Mature palm oil tree 1,212.90 Immature palm oil tree - Total planted 1,212.90 Mill - Infrastructure (road, emplacement, river/natural 10.40

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South Sumatera indonesia

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stream dan drainage) Conservation area - Low land 118.50 Total unplanted area 157.70 Others* 28.70 Total area 1,370.50

Note: *) some area claimed by local community. Map of pillars boundary in estate also available. There are identified 55 boundary pillars with condition 18 boundary pillar available in the field, 1 boundary pillar missing, and 22 boundary pillars were cov-ered by soil. Based on field observation in division II, the boundary pillar no. 19 was exist in the field and vissible, but for boundary pillar number 30 was not availble. In year 2016, the company will install new boundary pillars for missing ones. There are some land disputes in PT Gunung Tua Abadi, both in Sumber sawit estate and Inti Permata Bunda Dua estate, i.e.: 1. Land dispute with Dabek Makmur villager. There is 75 ha land dedicated for conservation area as

recommended on HCV assement result, the area being claimed as Plasma by Dabek Makmur vil-lager. Some meeting and negotiation to find solution has been done, however until the audit time the agreement has not achieved and further meeting and negotiation are planned.

2. Land occupied in several HGU area, it was identified total 163.19 ha in PT GTA etates and more than 28 ha IPBD estate. All area has been planted by Rubber plantation. The company has not identified and has not planning to solve the cases.

From the overlay result of the concession map and the company's workmap were indicated the exist-ence of land occupation in the PT GTA concession area of 163.19 Ha and IPBD estate of more than 28 hectares, but no information regarding details of farmers who occupied the land, furthermore no evi-dence has been made related participatory mapping involving smallholders and other relevant stake-holders. This is raised as non conformity. There is no significant land condlict, even some land problem occurs in PT GTA and PT IPBD. Com-munication and relationship still good between company and villagers surrounding companies ar-ea.This is agreed by communities in Dabek Makmur and Embacang villager during interviewed. For that land problem, the company has no conduct participatory mapping with affected parties (includ-ing neighbouring communities where applicable, participatory mapping is planned on the next June year 2013 as explained by the community relationship officer. The Company has not had documented evidence of the negotiation process with the peasants land in the PT GTA concession. Furthermore there is not plan agreed by both parties for existing land problems settlement. This is raised as non conformity NCR No. 2015-05 of 18 . From the overlay result of the concession map and the company's workmap were indicated the existence of land occupation in the PT GTA concession area of 163.19 Ha and IPBD estate of more than 28 hectares, but no information regarding details of farmers who occu-pied the land, furthermore no evidence has been made related participatory mapping involving small-holders and other relevant stakeholders. This is raises as non conformity 2015-04 of 18. According to information from police office during stakeholder consultation, the problem of FFB theft in PT GTA and PT IPBD very high, to protect the security of company’s asset, management make coopration with local polices officer and militer. Compliance status: Non Compliance Non-conformance 2015-02 of 18 (Major non-conformity ) The management has not made clear action for block number 001A that was indicated about ± 2 Ha oil palm planted outside of HGU in Balian Estate. Non-conformance 2015 03 of 18 (Minor non-conformit y): During the main audit the company can not showed record of boundary pillars maintenance in Balian division Sumber Sawit estate. Non-conformance 2015-04 of 18 (Major non-conformit y): From the overlay result of the concession map and the company's workmap were indicated the exist-

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ence of land occupation in the PT GTA concession area of 163.19 Ha and IPBD estate of more than 28 hectares, but no information regarding details of farmers who occupied the land, furthermore no evi-dence has been made related participatory mapping involving smallholders and other relevant stake-holders. Non-conformance 2015-05 of 18 ( Minor non-conformit y): The Company has not had documented evidence of the negotiation process with the peasants land in the PT GTA concession. Furthermore there is not plan agreed by both parties for existing land prob-lems settlement.

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

Findings: Information from social impact assesment, there are four villages which has direct interaction with PT Gunung Tua Abadi and PT IPBD, i.e. Sungai Sodong River Village, Village Embacang, Balian village Village Dabek prosperous and affluent.The community in fourth villages are no longer exploit the natu-ral resources exist in PT GTA working area. Most of basic needs are met from the outside company’s, they purchase, aquaculture and others.Natural ecosystems around the area of PT GTA which is cur-rently used only for farming plasma or fishing waters around PT GTA. Society is no longer directly ex-ploit the natural ecosystem in the area of PT GTA, besides there is no more forest left, this time also the public interest is more to farming activities and work as an employee of the company.

PT GTA paid land compensation before land cleared,it was proved by records of land compensation pay-ment e.g. for Sungai Sodong Village, District Mesuji, conducted in 1996, the information contains docu-ments land release agreement.

There are log books recorded Balian village land compensation porcess, District Mesuji, the land com-pensation was done on July 21, 2003, land acquired done for a villager for total area 16 ha. Compliance status: Full Compliance

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

Findings: PT Gunung Tua Abadi and IPBD estate has A business plan (minimum three years) established since yaer 2014 to 2019. All information about land area statement (planting years, non-planted areas, i.e. HCV, conservation areas, fragile soils, enclaves) has been included on the business plan document, The estate 5 year business plan also explained on the document, which covers activities such planning for manuring activities according to fertilizing recommendation, maintenance of mature and immature plantation; control of pests and diseases, harvesting, replanting programs including of sustainable agri-culture practice planning. For mill operation, planning also has been determined on the management plan, from the incoming FFB plan until production dispatch for year 2014 to 2019, includeing explanation about the CPO and PK production including its extraction rate and Financial indicators – profitability forecast (income vs cost). The company also has planning for smallholder operation. However there are some old data on the document which are not reflecting the company's 5 year management plan, such as the replanting schedule. It was stated on company’s business plan year 2014; there will be replanting program for next 2014 for 4195 has area on Balian estate for the planted year 1994 area. Compliance status: Full Compliance

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

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Findings: PT GTA(PT GTA) has Standard Operating Procedures (SOPs) as below: - PT GTA SOP for Estate Operations 1st Edition dated October 2013, covers handling and use of Ma-

layan knife (sickle), wheel barrow transport, transport of labour, cutting of FFB or fronds, harvesting, FFB collection, FFB loading, transport, spraying of pesticides and herbicides, chemical mixing, ferti-lizer application, POME application, digging of pits, lining and construction of terraces, road mainte-nance, etc.

- PT GTA SOP for Processing 2nd revision dated September 2014, including SOPs for all mill sta-tions, including weighbridge, mill stopping and starting, boiler and steam generation, removal of boil-er ash, sterilization, threshing, clarification, sludge oil recovery, nut conditioning, kernel recovery, etc.

- PT GTA Oil Mill Standard & Safe Work Procedures (Maintenance Activities) 2nd revision dated Sep-tember 2013 including safe procedures for maintenance at all mill stations.

PT GTA carries out monthly SOP and PPE compliance checks as seen from SOP and PPE compli-ance monitoring records. The checks are done by the auditor by observing work carried out individual contracted and permanent workers, and the date, time, location, name of worker, gender, type of work, status of PPE and SOP compliance and remarks are noted. Records of SOP and PPE compliance checks done since year 2013 are available, and audits are done by shift supervisors of the mill, and di-vision assistants or supervisors at the estate but harvesting practices are not consistently applied in accordance with procedures that still met the harvesting officer in the crop harvesting process improp-erly found, such as by lowering the seat midrib it was rised as an observation. Smallholders are trained on the Standard Operating Procedures of PT GTA estate and confirmed through training records and interviews with the smallholders, who informed that the company's man-agement does regular monitoring of the farmers activities to ensure the smallholder's fields are well maintained and carrying out field maintenance activities according to the company's program. Where the company finds smallholders are not conducting field maintenance accordingly, the company will engage contracted workers to carry out the work and deduct the fees for maintenance activities from the smallholders. Compliance status: Full Compliance

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

Findings: The company has a procedure for fertilization with document number PT-SAG-KBN-PML-21 Rev 01 dated March 16, 2012. In the palm fertilization procedures contained work instructions with the docu-ment No. WI-SAG-KBN-PML-2012 Rev. 0 dated March 16, 2012 about application of an organic ferti-lizer. The work instructions regulating the procedures for conducting fertilization, when the fertilizer should be applied, how to apply, fertilizer labor, and dose of fertilizer. The Company also has a work instructions with document number WISAG-PML-KBN-2013 Rev. 0 dat-ed March 16, 2012 about the application of organic fertilizers. The work instructions explain the EFB applications must be one layer with the doses 40 tons / ha. The company has the records of fertilizer application both organic and an organic fertilizer until October 2015. Records showed that the realization of fertilization activities conducted based on recommended fertilization work program and doses. Following the realization of fertilization in 2014 and 2015 with the following details: Sumber Sawit Estate Year 2014

No Type of fertilizer Realization (kg) FFB Produced (ton)

Use of fertiliz-ers (kg/ton FFB)

1 Urea 961,182 64,105.680 14.99

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South Sumatera indonesia

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2 RP 1,086,181 64,105.680 16.94

3 MOP 1,513,426 64,105.680 23.60

4 Dolomite 152,294 64,105.680 2.37

5 Borate 25,193 64,105.680 0.39 Year 2015 (until October 2015)

No Type of fertilizer Realization (kg) FFB Produced (ton)

Use of fertiliz-ers (kg/ton FFB)

1 Urea 601,007 79,476.830 14.99

2 RP 875,493 79,476.830 16.94

3 MOP 1,363,420 79,476.830 23.60

4 Dolomite 201,160 79,476.830 2.37 IPBD Estate Year 2014

No Type of fertilizer Realization (kg) FFB Produced (ton)

Use of fertiliz-ers (kg/ton FFB)

1 Urea 359,935 24,159.600 14.89

2 RP 343,942 24,159.600 14.23

3 MOP 411,578 24,159.600 17.03

4 Dolomite 136,613 24,159.600 5.65

5 Borate 6,401 24,159.600 0.26 Year 2015 (until October 2015)

No Type of fertilizer Realization (kg) FFB Produced (ton)

Use of fertiliz-ers (kg/ton FFB)

1 Urea 181,657 21,226.160 8.55

2 RP 285,136 21,226.160 13.43

3 MOP 378,172 21,226.160 17.81

4 Dolomite 170,921 21,226.160 8.05

5 Borate 9,958 21,226.160 0.46 The company has procedures leaf and soil analysis with document No. P-SAG-RST-ASE-01 Rev 0 01 September 2009 about palm oil fertilizer recommendations which regulates the implementation for the analysis of leaves and soil were used as fertilizer recommendation. Leaf analysis conducted once eve-ry 1 year, and soil analysis conducted every 5 years (mentioned in the definition). The company has records of results the analysis of leaves that have been conducted in 2014 by the Research and Development PT Sampoerna Agro, to get the fertilizer recommendations in 2015. Re-sults of the leaf analysis have described the nutrient content that is contained namely N, P, K, Ca, Mg, B, etc. Soil analysis was conducted in 2011 by the Research and Development and conducted every 1 time in 5 years. Leaf and soil analysis results are used as a source of fertilizer recommendation and fertilization program. Based on field visits, the company should conduct the fertilizer application in accordance with the ferti-lizer recommendations that have been issued. Based on field visits in Block 110 Division 2, conducted fertilization of Borate where the fertilizer recommendations were issued this type of fertilizer should be applied in May 2015.

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South Sumatera indonesia

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The company has records of the use EFB to maintain soil fertility. For IPBD Estate is not conducted empty bunch application but conducted liquid waste application. Sumber Sawit Estate

• Division 1, Block 113 with an area of 98.60 hectares, until October 2015 has been realized an area 5.40 hectares or as much as 216 tons

• Division 2, Block 94 with an area of 53.10 hectares, until October 2015 has been realized an area 52.40 hectares or as much as 2,096 tons, block 95 with an area of 97.60 hectares until October 2015 has been realized an area 79.00 hectares or as much as 3,080 tons

• Division 3, Block 80, 81, 87, 88, 70A, 70D, 70, 71D, 80, until October 2015 has been realized an area 330.80 hectares or as much as 13,320 tons

• Division 4, Block 82, 96, 68, 69, 82 until October 2015 has been realized an area 302.60 hec-tares or as much as 11,984 tons

• Division 6, Block 004, 005, 009, 010 until October 2015 has been realized an area 97.60 hec-tares or as much as 3,694 tons

IPBD Estate Recording realization of application Land application until October 2015, among others:

No Blok Realization of appli-cation (m3)

1 64A 6,875,629

2 64C 21,102,410

3 64D 30,036,948

4 65A 29,134,693

5 65B 21,376,107

6 65C 26,689,789

7 65D 25,313,211

Total 160,528,787

Compliance status: Full Compliance

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

Findings: Sumber Sawit Estate The company has the type of soil maps with a scale of 1: 35,000 with the following details:

• Plinthic kandiudults with an area of 1,402.8 hectares (sedimentary rock, clay gravel and loam rock)

• Lithic hapludults with an area of 1,221.5 hectares (sedimentary rock, clay gravel and loam rock)

• Typic dystrudepts with an area of 125.5 hectares (alluvium, sedimentary rock) • Typic kandiudults with an area of 235.4 hectares (sedimentary rock, clay gravel, sandstone

and loam rock) • Typic haplohemists with an area of 10.5 hectares (sediment of organic materials) • Typic haplofibrists with an area of 354.7 hectares (sediment of organic materials)

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South Sumatera indonesia

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IPBD Estate The company has the type of soil maps with a scale 1:20,000 with the following details:

• Typic Dystrudepts with an area of 577.2 hectares (sedimentary rock, clay gravel and sand-stone)

• Typic Hapludox with an area of 429.4 hectares (sedimentary rock, clay gravel and sandstone) • Typic dystrudepts with an area of 126.7 hectares (sedimentary rock, clay gravel and loam

rock) • Plinthic kanhapludults with an area of 131.9 hectares (loam rock) • Typic haplofibrists with an area of 23 hectares (sement of organic materials)

Base on field visit and topographic map, Sumber Sawit and IPBD estate is flat topography to gentle slope, and there is no the steep slopes. Thereby, the company has no policy related to management in areas with steep slopes. The company has the road maintenance budget in 2015. For Sumber Sawit Estate, road maintenance plan in 2015 namely manual road maintenance along 209,773 meter, road grading along 41,995 meter and road compact along 41,995 meters. As long as 2015, the company has been doing road mainte-nance until October 2015 namely 143,650 meters. For IPBD Estate, road maintenance plan in 2015 namely manual road maintenance along 60,645 meter, road grading along 60,645 meter and road compact along 60,645 meters. As long as 2015, the company has been doing road maintenance until October 2015 namely 55,000 meters. The company has technical agronomy instructions land clearing on peat area was published on April 4, 2011 Rev 0, which has been approved by COO-CPO (Chief Operation Officer- CPO) and CEO. In the technical instructions regulated about making drainage, subsidence measurements, measurement of water level in the peat, the process of land clearing on peat lands, planting on peat land, water gates, etc. In the Sumber Sawit Estate, there is block planted of palm oil on peat that is on blocks 67, 68, 83, 84, 85, 86 with the varies depths of 0-1 m; 1-2 m; 2-3 m; 3-4 m, 4-5 m and more than 5 m and in the IPBD Estate there is on the block 66 with the varies depths of 0.5-1 m; and more than 3 m. In the procedure regulated on the thickness of the peat, the nature of maturity, peat subsidence, type and nature peat, the drainage channel (drain), canal maintenance, water management. In the proce-dure is also explained that the water level is maintained at 50 cm - 70 cm. The company conducted monitoring by measuring the decrease in the peat regularly 1 month. For Sumber Sawit Estate, the company has conducted subsidence measurement from September 2015 because the beginning installation of measuring devices peat subsidence conducted in September 2015. Based on data of the peat subsidence measurement can be known the level of subsidence de-crease namely:

NO Depth (cm) Block subsidence (cm)

This month

Until this month

P01 560 85C 8 15

P02 560 86C 8 11

P03 460 85B 4 8

P04 350 86A 2 8

P05 60 83D 4 7

P06

P07 650 84B 3 6

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South Sumatera indonesia

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P08 360 83A 8 14

P09

P10 560 86B 2 4

For IPBD Estate, the company has conducted subsidence measurement from October 2015 because the beginning installation of measuring devices peat subsidence conducted in September 2015. Based on data of the peat subsidence measurement can be known the level of subsidence decrease namely:

NO Depth (cm) Block Subsidence (cm)

This month

Until this month

P01 560 85C 1.0 1.0

P02 560 86C 0.5 0.5

P03 460 85B 0.7 0.7

The company takes action to minimize with conducted monitoring the decrease of peat and water management by making a water gate and canal. Sumber Sawit Estate and IPBD Estate has conducted water management programs including maintaining the water level of 50-70 cm below the soil surface. Based on field visits in the water level in Block 85D Sumber Sawit Estates, the water level is at the lev-el of 70 cm. IPBD Estate has piezometers but not yet conducted measurement because newly in-stalled. Based on visits to the field in Block 66B has been installed piezometers and subsidence of the peat while the water level has not been replaced after cleaning the drains. Companies should conduct a study on the installation of stake of peat subsidence where subsidence the stake installed sustained by the ballast of cement and performed reinstallation the loss of water level because the drains wash-ing for monitoring high water level. The company does not have plans replanting in the area of peat because for plants in peat land is still productive planting year 2007. The company does not have a marginal soils (sand, organic matter is low, and sulfuric acid) so it does not have a management plan on marginal land. Compliance status: Full Compliance

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

Findings: Sumber Sawit Estate dan GTA Mill GTA mill has program for water source management, with program activity such as:

- Water supply for domestic activity carryout twice in one day - Water recycle from cooler in to water treatment plan - Water recycle from sterilizer condensates to water dilution - Reforestation around the water springs - Conduct the water analyzed periodically

Record of implementation the water source management are available, such as record of reforestation conducted in around of water springs, housing, river bank as much 579 tree consist of fruit tree, mahoga-ny, and others forest tree in 2014. While in 2015, the reforestation program conducted yet because dry season reason. In the other hand, company also conduct the water analyzed for surface water analysis, based on record:

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- Result certificate number 660/765/SPPC-ALC/V/2015 dated on May 28, 2015. The result showed the water surface quality is good and meet with the regulation based on Local Regulation number 16/2006.

Hydrology map also available with scale 1:60,000. Map informed the natural stream location, also low land and river bank. Especially for low land, company was protected this area through the conservation areas. And based on field visit, there is no natural stream cross the estate, because estate area directly adjacent with Dabuk river located in outside of land use rights (HGU). In the procedure number P-SAG-KBN-NKT-02 Rev0 dated on July 01, 2012, in pages number 9 was set the river bank and water springs protection with chemical activity no allowed in river bank, around of springs water, reservoir, and for opened area carryout by vegetation enrichment. Record waste water analysis every months also available, several example such as:

- Result record certificate number 660/832/SHU-LAB/V/2015 dated on May 20, 2015 accordance to Ministry Regulation number 28 and 29/2003 with parameter was analyzed pH, BOD, COD, oil and grease, Pb, Cu, Cd, Zn. The result showed the waste water meet with the requirement.

- Result record certificate number 660/832/SHU-LAB/V/2015 dated on June 10, 2015 accordance to Ministry Regulation number 28 and 29/2003 with parameter was analyzed pH, BOD, COD, oil and grease, Pb, Cu, Cd, Zn. The result showed the waste water meet with the requirement.

GTA mill has record for water usage per ton FFB from 2014 and 2015, i.e.: - For 2014, average water usage from January – December was 2.09 m3/ton FFB - For 2015, average water usage from January – October was 1.01 m3/ton FFB

IPBD Estate Base on hydrology map and field visit, there is no natural stream cross the IPBD estate area, so there is no water resource used by estate. Water resource used by estate came from outside (buy). Dabuk river is located in outside the IPBD land use rights (HGU). Some location is IPBD estate used the borehole based on Decree number 540/33.A/KEP/DPE/2013 about the renewal the borehole permit, this permit valid for 3 years since the issued in June 24, 2013m with maximum water take was 1.66 litter/second or 100 lit-ter/minutes every borehole. The company carries out the treatment of wastewater at the WWTP. The company has 5 ponds WWTP is cooling pond, anaerobic primary and secondary anaerobic. The mill has been measuring the quality of liquid waste every month. Based on test results, quality of liquid waste will be streamed to land application is still accordance with the quality standards regulated in the Decree of the Environ-ment Minister No. 28/2003 and Decree of the Environment Minister No. 29/2003. The company has a license extension utilization of industrial waste water on land in palm oil plantation of PT. Gunung Tua Abadi based on Decree of the Regent of Ogan Komering Ilir with numbers: 660.1/31/ KEP/B.LH/2014 dated June 30, 2014. This decision is valid for 3 years since its enactment. Block applications that are included in the permit are blocks 68 and 69 (PT.GTA) and blocks 64 and 65 (PT. MBJ). The company has procedure IMS Water Treatment with the document number PT-SAG-PKS-PRS-10 revision 0 the effective date of 1 September 2009.

The mill has a recapitulation recording of water use per ton of FFB for 2014 and October 2015 the cur-rent year with the following details:

Year 2014

Month FFB process (ton) Use of water (m3)

Use of water/ton FFB

January 9,083 12,322 1.35

February 8,280 11,904 1.43 March 10,494 19,010 1.81

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April 14,797 23,458 1.58 May 20,367 22,675 1.11 June 19,142 26,329 1.37 July 14,927 25,741 1.72

August 26,049 40,145 1.54

September 15,234 27,101 1.77

October 14,288 18,289 1.28 November 10,144 11,260 1.11 December 8,254 9,162 1.11 Total 171,059 247,396 1.44

Year 2015 Month FFB process

(ton) Use of water (m3) Use of water/ton

FFB January 9,272 14,489 1.56 February 9,688 16,309 1.68 March 14,971 17,296 1.15 April 16,400 22,886 1.39 May 19,289 27,055 1.40 June 23,529 29,336 1.24 July 20,001 20,881 1.04 Agust 24,953 16,977 0.68 September 24,288 16,875 0.69 October 28,773 19,495 0.67 Total 191,164 201,599 1.05

Compliance status: Full Compliance

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

Findings: The Company has an IPM plan as stated in the monthly work program. IPM plan is made for each of pest identified. The IPM plan include: Monitoring and census of potential pests The company uses with biological pest control (planting Turnera surbulata) and use of chemicals (per-formed if conditions of attacks have been above threshold) and also with the owl. IPBD Estate has a nest as many as 14 pieces. The Company has integrated pest management procedures, among others: 1. Pest monitoring procedures with the document number PT-SAG-KBN-PML-15 revision 1 dated

March 16, 2012. This procedure is followed by work instructions include: • Work Instructions marking of census lines with the document number WISAG-KBN-PML-1501

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

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

SAG-KBN-PML-1503 revision 01 dated March 16, 2012 • Work Instruction Census of Rats Pest in Mature ≥ 4with the document number WI-SAG-KBN-

PML-1504 revision 01 dated March 16, 2012 • Working Instruction Census of Tirathaba pest with the document number WI-SAG-KBN-PML-

1505 revision 01 dated March 16, 2012 2. Leaf pest control procedures with the document number PT-SAG-KBN-PML-16 revision 1 dated

March 16, 2012. This procedure is followed by work instructions include:

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South Sumatera indonesia

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

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

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

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

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

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

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

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

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

Sumber Sawit Estate has a record of pest census starting in January to October 2015. Based on the results of the census records of pests that have been conducted, in April 2015 there is a rat attack rate above 25% and should be controlled by using Ratgone. IPBD estate has a pest census records starting in January to October 2015. Based on the results of the census records of pests that have been con-ducted, in February 2015 there is a fire caterpillar attack rate above 5 piece / midrib and should be con-trolled by using Thuriside. Sumber Sawit Estate has conducted training on pest officers involved in integrated pest management. Training provided, among other handling of pest, pest monitoring and census, the introduction of other types of pests. Training the last holdout was conducted in February 2015. The company has not pro-vided training to the pest foreman on behalf of Heri Susanto who served as pest foreman from April 2015. Auditor raise as Non conformity (NCR No.2015- 06 of 18). IPBD Estate has conducted training on pest officers involved in integrated pest management. Training provided, among other handling of pest, pest monitoring and census, the introduction of other types of pests. Training the last holdout was conducted in February 2015. The company has provided pest training to the pest foreman on behalf Efriansyah. Compliance status: Non Compliance Non-conformance 2015-06 of 18 (Minor non-conformi ty): The Company has not provide the training to the pest foreman on behalf Heri Susanto who served as pest foreman starting from April 2015 (Sumber Sawit Estate)

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

Findings: The company's list of chemicals as seen from the company's agrochemical consumption summary in-clude the following: - Chermosate 360 SL (a.i. glyphosate 360g/l) - non-selective broad spectrum herbicide for weeds and

grasses - Garlon 4 (a.i. trichlophyr 480g/l) - herbicide for control of broad leaved weeds and grasses - Evisect S 50WP (a.i. thiocyclam oxalate 500g/kg) - insecticide for control of leaf miners - Pawa 2.5EC (a.i. lambda cyhalothrin 25g/l) - insecticide for control of insect pests All chemicals are registered under the EPA revised register of pesticides dated 30 June 2013. There are no chemicals used which are categorized as World Health Organisation type 1A or 1B, and there is no paraquat being used, as confirmed from chemical usage records and checks of the chemical store. For weed management, the company applies a mixture of glyphosate (Chermosate, Ceresate or

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Glyphader) and tricopher (Garlon 4 or Corta). The main chemicals applied are Chermosate and Garlon 4 at a rate of 150ml of Chermosate (a.i. 360 g of glyphosate) and 25ml of Garlon 4 in one 15 litre knap-sack. This is within the recommended dosage stated on the chemical container labels. PT GTA has a documented justification of other chemicals used for pest management in their Integrated Pest Man-agement Plan, revised October 2013. Records of pesticide use (including active ingredients used, area treated, amount applied per ha and number of applications) are maintained at estate division offices. Records of training for over 200 chemical sprayers and fertilizer applicators done on 11 April 2014 was sighted, and it was confirmed that several sprayers interviewed in the field had participated in the train-ing. Training topics included usage of appropriate PPE and safety precautions, methods of application, riparian & buffer zones, handling of spillages, and basic first aid measures. Sprayers are provided with appropriate PPE, i.e. masks, goggles, aprons, rubber gloves and boots. However, the following was observed at the chemical and sprayer’s PPE store at Ahinkrom division: 1) There was a PPE washroom, but no place for storage of washed aprons and PPE, and it was in-

formed that workers brought their PPE back home after washing due to this. 2) The water from the sprayer’s PPE washing area was discharged directly to the soil surface outside

the washing area, which flowed in the direction of a crèche. 3) The knapsacks used by sprayers were being stored on top of empty containers instead of a proper

safe place away from contaminated containers. The company took immediate action during the audit to rectify these by installing hangers for workers to put up their aprons and PPE before going home, connecting the pipe for outflow of water from the washing area into the discharge pipe for fertilizer bag washing area, which discharges to the field, and moving the sprayer’s knapsacks into separate room. As immediate corrective action was taken, this was noted as an observation. Chemicals are stored at a secure store, with retention bunds to contain spillage, spill kit and signage indicating toxic materials in the store. However, it was noted that smell of chemicals was strong in the chemical store at Ahinkrom estate and the store operator did not wear or provide visitors with a mask when entering the store. In addition, the chemicals are being stored together with paint, which are easi-ly flammable materials. This was noted as an observation The company does not carry out aerial application of pesticides. Chemical containers are collected and disposed of by a licensed contractor, i.e. ZOIL Services Ltd, as explained under CR 5.3. It was confirmed from interviews with male pesticide sprayers that their medical surveillance is done annually. All pesticides are applied by male workers and the chemical store is managed by a male worker as well, so there is no work with pesticides for pregnant and breast-feeding women. Scheme smallholders are trained on agrochemical use, including precautions to be taken. However, risk of chemical contamination to smallholders is minimal as all agrochemical application is done by workers engaged by the company Safe handling practices and health monitoring program for both male and female employees were ob-served and verified thru interviews. Suspected pregnant female employees as verified by the appointed occupational doctor and as communicated by the female employees themselves were removed from the workplaces handling the agrochemicals and re-assigned to non-agrochemicals use work areas. Pe-riodic medical checks were not conducted during year 2015 as medical examination for blood cholines-terase contamination still not perform yet for chemical sprayer and the worker who handling the chemi-cal in IPBD Estate during 2015 and it was raised as major non conformity NCR No. 2015-GTA- 7 of 15 . These agrochemicals were applied accordingly to the programmes developed. In addition on-site ob-servations reveal that these agrochemicals were not being applied near to the water bank / river chan-nel areas. Safe handling practices and health monitoring program for both male and female employees were ob-served and verified thru interviews. Suspected pregnant female employees as verified by the appointed occupational doctor and as communicated by the female employees themselves were removed from the workplaces handling the agrochemicals and re-assigned to non-agrochemicals use work areas. Pe-riodic medical checks were conducted by the appointed occupational health doctor with results report-ed and followed-up if there is suspected cases of deteriorating health from the use of agrochemical. Based on the sampled medical records there were no cases of health deteriorated from the use of ag-rochemicals. These agrochemicals were applied accordingly to the programmes developed. In addition

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on-site observations reveal that these agrochemicals were not being applied near to the water bank / river channel areas. Safe handling practices and health monitoring program for both male and female employees were ob-served and verified thru interviews. Suspected pregnant female employees as verified by the appointed occupational doctor and as communicated by the female employees themselves were removed from the workplaces handling the agrochemicals and re-assigned to non-agrochemicals use work areas. Pe-riodic medical checks were conducted by the appointed occupational health doctor with results report-ed and followed-up if there is suspected cases of deteriorating health from the use of agrochemical. Based on the sampled medical records there were no cases of health deteriorated from the use of ag-rochemicals. These agrochemicals were applied accordingly to the programmes developed. In addition on-site observations reveal that these agrochemicals were not being applied near to the water bank / river channel areas. Safe handling practices and health monitoring program for both male and female employees were ob-served and verified thru interviews. Suspected pregnant female employees as verified by the appointed occupational doctor and as communicated by the female employees themselves were removed from the workplaces handling the agrochemicals and re-assigned to non-agrochemicals use work areas. Pe-riodic medical checks were conducted by the appointed occupational health doctor with results report-ed and followed-up if there is suspected cases of deteriorating health from the use of agrochemical. Based on the sampled medical records there were no cases of health deteriorated from the use of ag-rochemicals. These agrochemicals were applied accordingly to the programmes developed. In addition on-site observations reveal that these agrochemicals were not being applied near to the water bank / river channel areas. Compliance status: Non Compliance Non-conformance 2015-07 of 18 (Major non-conformity ): IPBD estate still not perform Medical examination for blood cholinesterase parameter for chemical sprayer employees or who handling chemicals .

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

Findings: PT GTA Estate have documented occupational safety and health (OSH) policy. Example for this fact is PT GTA Estate an Palm Oil Mill Policy covers HSE matters dated 01 July 2015 which is signed by the Sampoerna Agro Group Chief Executive Officer . The policy includes documented objectives and tar-gets, i.e. comply with the company’s OSH procedures, committed to wearing of Personal Protective Equipment (PPE) at work sites, and manage potential work risks at the site. PT GTA Mill has identified and documented Occupational Health and Safety (OHS) risks for all mill ac-tivities as this was documented under its 5 August 2015 environmental aspects and impacts register. Designated PPE storage in PT GTA Mill Laboratory was located properly as the lab’s crew can be easy to find the available PPE that must be worn during their activities in there, also Shower/Eye wash sta-tion was easy to used when the emergency situation occurs and some safety warning signs were found during in the several place which need an attanetion related to the hazards available in plant tour activities and during the time it was found operator has no license for backhoe loaders and backhoe loaders dust seal on arm are leaked, rearview no glass, tail lamp broken and fire exthinguiser is not available in the backhoe loader and it was rised as NCR No. 2015-09 of 18 (Major Non-Compliance) and also rise an observation for Storage of gas cylinders should be placed in a safe and chained to keep from falling . Also in PT GTA Mill was have a consistent implementation in the work permit system implementation such as was found as the welding process work in the mill also PT PT GTA Estate has Hazard Identi-fication, Risk Assessment and Risk Control document for 2015, dated 6 January 2015 for all estate ac-tivities including spraying, manuring, harvesting, workshop activities, generator, truck transportation, chemical and material storage, and waste handling but it was rised as NCR No. No. 2015-09 of 18 (Major Non-Compliance) as Risk assessment for the identification and evaluation of safety health and environment impacts-aspects and their potential dangers are not covering all of the activities include the available dangers and risks that exist in the SS and IPBD estates.

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Chemical storekeeper in PT GTA Estate is provided with helmets, boots and goggles and look much aware to the visitor that need to wear the PPE while entering his area as it was already arranged in procedure No. PRO-GEN-016 Rev0 2009 related to Personal Protective Equipment. Contract field-maintenance workers are also required to wear boots and provide by company. Female spray-ing/manual maintenance workers interviewed in PT GTA are provided with Personal Protective Equip-ment (PPE) by the company, including masks, gloves, and plastic aprons. The sprayers are provided with appropriate cloth gloves for spraying activity. While they wash their PPE at washing facilities at the division office and they store their PPE in the estate store. As sighted from PT GTA Estate documents, Head of Social, Manpower and Cooperation Office of Og-an Komering District by virtue of Decree No KEP/DTKT-PK/P2K3/2015/661 dated 4 November 2015 have approved the organisational team of Estate OSH structure. As for PT GTA Mill, the Head of So-cial and for PT GTA Estate : Manpower and Cooperation Office of Ogan Komering District through De-cree No KEP.105/DTKT-PK/P2K3/2015 dated 29 August 2015 have approved its organisational struc-ture team of OSH, Regular reporting system to the related responsible locar government also were sighted as they were observed report qurterly which consist of the OHS team activities such as safety patrol, inspection, regular meeting and emergency drill, summary of accident report using Frequecy Rate and Severity Rate calculation record activities were reported but companies should include pro-cedures to investigate the accident in order to accident or a similar incident does not reoccurrence in the future and it was rised as an observation. The company has an emergency response procedure documented under Standard Operating Proce-dure No. P-SAG-RO-SUS-013 Rev 05 dated 15 April 2015, including identification of potential emer-gency situations (fire, accidents, flood, explosion, and chemical leakage) and a flowchart for Handling Fire Emergencies. PT GTA Mill has records of emergency response training and simulation on 18 De-cember 2014 for over 40 workers, as well as land burning simulation on 22 May 2015 for 35 estate di-vision 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 accident & emergency response procedure. Records of other OSH training, i.e. for first aid and man-agement of hazardous waste, are available as described under CR4.8. Fire emergency training for PT GTA Estate was conducted on 15 January 2015 for 46 staffs. Training on emergency response proce-dure for fire was conducted in June 2015 for 31 workers at PT GTA Estate. Emergency response train-ing should be done for other emergency conditions as for the handling of chemical spills , riots , earth-quakes and others and it was rised as an observation. During site visits, field executor (supervisor) in PT GTA Estates were found having brought first aid kits to the field, and those are located at other locations such as estate office, workshops, chemical store-house, etc. It was observed that the first aid kit at Division 1 of PT GTA office a complete pack of first aid kit. However for harvester and manurer foreman also have a first aid kit. Estates and Mill provide National Employee Social Security (Jamsostek) to permanent employees, as sighted from sampled payslips of 3 harvesters of PT GTA Estate, as verified with interview. According to the company’s Work Instruction for Jamsostek Participants and Fees, the amount paid by the com-pany for Jamsostek contribution is 3 % of the employees' basic salary, while another 2% payment is made through regular deduction of their basic salary. It has been verified paid correctly. As for contract workers, PT GTA Estate deducts the amount required for their insurance against payment to the re-spective contractors, and pays this insurance amount directly to the relevant authority to ensure that all contract workers are covered with insurance. During site visit the medical facilitiy in the estate it was found that Sphygmomanometer (tensimeter), for Sumber Sawit Estate polyclinic was damaged which cannot be used when needed it was rised as ma-jor non conformity NCR No. 2015-08 of 18 (Major Non-Compliance) . Compliance status: Non Compliance Non-conformance 2015-08 of 18 (Major non-conformity ): a. Sphygmomanometer in the puskesbun of Sumber Sawit Estate was damaged which is can not be

used when needed . b. Audiometri test for engine room operator has not done yet from 2013 until 2015 . Non-conformance 2015-09 of 18 (Major non-conformity ): a. Risk assessment for the identification and evaluation of environmental impacts aspects and their

OHS potential dangers not include all of the activities and the resks and dangers which are exist in the SS Estate , IPBD and SS POM.

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b. It was found the backhoe loader operator has no license and backhoe loaders are leaked for the dust seal his arm , rearview no glass , lamp of tail lamp were broken also do not have a fire ex-thinguiser.

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

Findings: The company (mill and estate) has record training program for 2015. Training program was informed the kind of training, who will be trained by the company and others. Record of training implementation was available such as:

- HCV record training carryout at September 8, 2015, attendant by 2 persons as a conservation foreman appointed by company.

- Training record for crane operator carryout at March 17 – 24, 2015, attendant by 2 persons, organized by Man Power Agency of OKI Regency.

- IPM training - Sterilizer operator training - Sprayers calibration training and sprayers operator - Security training - Safety driving - And others

Training program developed by the training analysis based on procedure number P-SAG-RO-HRS-02 Rev0 date issue on September 1, 2009, in section number 7.2 mentioned “Regional Head Human Re-source developed the training plan based on training needed in work achievement used training plan form (FM-SG-RO-HRS-02001) in the end of the year. Based on this, during the main assessment, train-ing program for 2016 can no showed yet. For IPBD estate, training record for 2015 was available, such as training for pesticide operator at-tendant by 8 persons and IPM training attendant by 3 persons, security training attendant by 2 persons, and others. Company has smallholders namely Makmur Bersama with area was 454.7 Ha, located in Dabuk Makmur village, Mesuji Raya District, with:

- Year planting 2012 was 80.80 Ha - Year planting 2012 was 4.50 Ha - Year planting 2014 was 315.60 Ha

Compliance status: Full Compliance

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

Findings: The mill has their Environmental Management Documents or (ANDAL) which revised for their previous approved document No.540/166/KEP/K-PELH/2006 on 08 May 2006 and approved by the Head of Og-an Komering District for plant's production capacity of 60 tons / hour. This document includes details of the mill's activities pertaining to oil palm processing and production also analysis results for air quality, NOx, SOx, particulate, carbon monoxide, land water quality, biological components and so on. Estates have their UKL and UPL document which was last revised on 21 April 2011 includes details on the es-tate activities, usage of natural resources, climate, air and water quality, geography and other environ-mental aspects, social aspects, potential environmental impacts and monitoring. The mill and all estates have also conducted their Identification of Environmental and Occupational Safety Aspects and Impacts dated 13 January 2015 for the mill, 16 January 2015 for PT GTA estate. The document covers environmental and safety aspects and impacts for estate work activities (eg. manual treatment, mechanical treatment, harvesting and tree maintenance), office activities, housing, management of hazardous wastes and domestic wastes, usage of natural resources, warehouse oper-ations, transport and so on. The mill and all estates prepare a report every 6 months based on their UKL and UPL documents as

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required by legal requirements includes reports on air quality, emissions from electrical generator, groundwater and soil quality, and noise. In PT GTA Estate, such report includes result of analysis of the same parameters, as well as of odour levels, and amount of hazardous waste produced. This is re-ported 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. The last report was prepared on December 2014 and includes monitoring and analysis results for ambient air and noise, water quality, and evaluation of results as they were sighted on report number 860/MT.I/08.06.70.169 for air ambient test result in PT GTA estate, 860/MT.I/08.06.70.172 dated 6 Au-gust 2015 for Clean Water test result from ground water sample point, No. 860/MT.I/08.06.70.171 for Plankton Benthos test result from surface water sample which conducted by Unit of Technical Imple-mentation for Materials Testing Laboratory. Sumatera Selatan Province Government. The analysis re-sults for mill air and water quality show no exceedance of environmental parameters to legal standards. From the reports, it was found that all environmental quality parameters measured were within the legal standards. The report has already been distributed to the related government department which con-cern to this UKL and UPL (Environment Management Efforts) as required by law and regulation. Compliance status: Full Compliance

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

Findings: PT Sumber Sawit

The company has conducted the HCV identification inside the land used rights (HGU) on August 2011. Based on HCV identification assessment, HCV area was identified is about 405.51 Ha (13% from total land) and plus 4.42 Ha in field number 119 division I (low land), so HCV total area was 409.93 Ha, consist of:

- Reservoir was 7.44 Ha located in field number 71, 72 - Low land reservoir Balian was 105.75 Ha located in field number 11, 12, 13, 14, 15, 19 - Low land reservoir Sumber sawit was 102.19 Ha located in field number 95, 96, 100, 101, 102,

107, 108, 109 - Peat swamp in Sumber sawit was 144.61 Ha located in field number 97, 99, 109, 110, 112 - Peat swamp in Sumber sawit was 45.52 Ha located in field number 98,99.

The type of HCV was 1.1; 1.2; 1.3; 2.3 and 4.1. HCV identification was carryout by internal assessor company, when the internal assessors was trained by Tropenbos International Indonesia. Sumber sawit estate has HCV brief to all of related stakeholder such as local community, all of workers level evidenced by attendant list on August 14, 2015 attendant by 34 persons. Material was brief about protection of flora and fauna also HCV conservation. HCV identification was covered information about flora dan fauna identification inside the land use rights (HGU), with consist of:

- 9 mammal with two categorized include in RTE species (Manis javanica and Felis ben-galensis)

- 26 aves - 5 pisces - 4 repltile

Based on HCV assessment also, there is no identified corridor fauna, because company location bor-dered with small holder, local community villagers. And HCV was build based on HCV toolkit. Map of HCV also available with scale 1:50,000. Potentially RTE species inside the HCV area of Sumber sawit estate was Manis javanica and Felis bengalensis. HCV management and monitoring plan was covered the RTE species monitoring such as biodiversity condition monitoring and RTE species abundance, demarcation and marking the HCV ar-

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ea, rehabilitation and enrichment species, brief to local community and workers level, and others. HCV signboard about prohibited the illegal fishing, hunting, catching, river bank protection and others also installed in HCV location area, road, housing and office.

The company has set the procedure (still in draft during the audit) with document number P-SAG-KBN-NKT-02 Rev02 dated on December 1, 2015 about HCV management and monitoring. Procedure has es-tablished rule of HCV management from maintaining, demarcation, HCV boundary, observation, protec-tion, (patrol periodically, alien species controlling, enrichment, river bank water springs protection and communication through brief activity to all stakeholders).

Record of HCV management and monitoring implementation are available from 2012 until 2016. Example based on monitoring record October 25, HCV monitoring officer has conducted the fauna monitoring in-side the working area such as estate field, riparian buffer zone and others.

There are identified HCV area 75 Ha in Balian estate was claimed by the local community as they owned. Based on field observation, some area was planted by rubber, with no identification how much the HCV area was planted by local community. Based on legal land tittle, HCV area is part of land use rights of company. The company has effort to resolve this problem, example based on decree letter of conserva-tion area designation from Environmental Agency of OKI Regency number 660.1/60/REK/B.LH/2015 dat-ed on June 5, 2015. The letter was mentioned HCV area 75 Ha (field number 11, 12, 13, 14, 15 and 19) was conservation area under the company and should protection by the company. Company also will conduct the meeting between local community and company with Environmental agency as a mediator. This mediation will conduct on November 14, 2015. And during the audit, there is no agreement with local community. So this is was raised as nonconformities (NCR 2015 – 10 of 18 ).

During the audit, HCV area ±20 Ha was fire as effect of dry season more than 8 months. To follow up this condition and to prevent for future, the company was develop action plan to reforestation and enrichment immediately all HCV area damaged in 2016 with vegetation forest and will planted in field number 100 and 119.

Figure: 4. HCV area in PT GTA, Sumber Sawit estate & IPBD estate

Especially for IPBD estate, based on HCV identification assessment, there is no HCV area was identified in IPBD estate. But, IPBD estate still gave the brief about the HCV to the all of workers level carry out on June 10, 2015 and October 10, 2015 was attendant by 34 persons from harvesters, sprayers, foreman, and others.

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Compliance status: Non Compliance Non-conformance 2015-10 of 18 (Minor non-conformit y): There are areas defined as HCV 1.4 and 4 area of 75 Ha in Balian Estate concession and the area is also claimed as the area belongs to the public, until now there has been no agreement, negotiation or plan to reach an agreement made by PT GTA.

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

Findings: The mill and estate have identified all potential sources of wastes and pollution in their Environmental and Safety Aspects and Impacts Identification document FRM-GEN-071 prepared in updated year 2015. All estates have a Standard Operating Procedure available for management of domestic wastes generated from housing & offices, plastic wastes as well as for hazardous wastes PT GTA estate and the mill have their own licenses for hazardous waste collection No.061/Kpts/BPMP2T-PZN/IX/2014/1077 valid to next 5 years and which are confirmed to be valid at explained under CR2.1 above, while PT GTA estate sends their hazardous wastes for collection to PT GTA estate temporary waste storage. PT GTA estate maintains records of amount of hazardous wastes received from PT GTA estates, as seen from sample receipt records for 7 July 2014 and 29 April 2014. PT GTA estate maintains records of incoming hazardous wastes in Control Form for Incom-ing and Outgoing Hazardous Wastes and Inventories of Hazardous Wastes. Hazardous wastes are collected by Licensed contractors PT Dame Alam Sejahtera, where most recent collection was on 30 June 2015 and prior to that was 18 January 2015, collect hazardous wastes. It was found that the inventories for all hazardous wastes at PT GTA estate have been updated from January to June 2015 up until time of collection by the contractor. For example, last inventory update for oil filters was 174 pieces on 30 June 2015. Inventory records at the mill hazardous waste stores were found to be consistent with the hazardous waste collection summary note prepared by the mill and final collection amount stated in the manifests but sump pit for TPS B3 SS gardens should not be linked with stop valves that can be opened to drain the water to the water course and it was rised as an obervation. The mill conducts sampling of effluent BOD5 (outlet pond no.6 and 7) with tests conducted externally (Unit of Technical Implementation for Materials Testing Laboratory. Sumatera Selatan Province Gov-ernment). Sample results show (period of April 2014 to June 2015) that effluent BOD5 for land applica-tion is below 5,000 pm as required in the mill’s land application permit No.660.1/31/KEP/BLH/2014 dated 30 June 2014 which valid for 5 years as Land Application Block tagging applications were con-form with the license which already held by the company. Compliance status: Full Compliance

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

Findings: GTA has records of fossil fuel used per ton FFB. Based on record energy used 2014, total of fossil fuel used for FFB transportation was 25,785.00 liter. The company has calculated of emission result from fos-sil fuel used, when the emission total was 80,964.90 kgCO2e or 2.3833 kgCO2e/ton FFB. Record of energy used from 2015 until October 2015 was:

Remarks Total used TBS process (mt) 191,194 CPO poduction (mt) 42,727 Kernel production (mt) 10,702 Total water used (m3) 193,928 Water used per ton FFB (m3) 1,01

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Shell used for boiler 9,695.84 Shell used per ton FFB 0,23 Total fiber used 22,487.27 Fiber used per ton TBS 0,53 Diesel used 142,169 Diesel per ton FFB 0,33

IPBD estate has records of fossil fuel used per ton FFB transport to go to GTA mill, i.e.: 1. For 2014 total fossil fuel used in once year was 12,342 litter and 0.51 litter per ton FFB 2. For 2015 until October, total fossil fuel used was 9,874 liter and 0.44 litter per ton FFB Compliance status: Full Compliance

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

Findings: GTA (mill and estate) has policy for environmental protection, with prohibition of zero burning for all ac-tivity in the estate. In the procedure number P-SAG-KBN-PML-01- Rev01 dated on March 16, 2012. Procedure has men-tioned land clearing activity without zero burning activity. There are recorded of land clearing with zero burning activity based on field observation in estate. But, found some burning activity in housing area i.e. rubbish burned. The company has brief the waste domestic management i.e. separate the organic waste and an-organic waste carry out on Monday 19, October 2015 attendant by 36 persons, but this brief still not effective because still found that condition. Compliance status: Full Compliance

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

Findings: The company (estate and mill) has identified activities that produce greenhouse gas emissions, among others:

• Production of fresh fruit bunches • Application of fertilizer • Application of pesticide and herbicide • The use of electricity • The use of fossil fuels • Transportation CPO • Liquid waste • The use of chemical

The company has the data source of greenhouse gas emissions as stated in the report the calculation of greenhouse gas emissions that refer to document ISCC 205 GHG Emissions and GHG calculation meth-odology Audit. The Company has a plan to reduce GHG emissions include:

• Construction of methane capture • Research dried solid decanter • Setting a power outage • Substitution diesel fuel with biodiesel • The addition of carbon absorption by planting trees in conservation areas • Substitution fertilizer with the empty fruit bunch

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• Substitution fertilizer with POME organic content • Substitution fertilizer with dried solid decanter

The program contained in the time to conduct the reduction of GHG emissions. The program that currently taking place is setting a power outage, use of empty fruit bunches, use of biodiesel and methane capture feasibility study conducted by ProSympac in 2013. The company has records of testing POME every month. Based on test results, quality of the effluent does not exceed environmental quality standards have been set.

The company has a system to monitor emissions of pollutants including greenhouse gases from farm or factory by conduct the calculation of greenhouse gas emissions. The company has the calculation of greenhouse gas emissions by using RSPO GHG Toolkit version 2.1.1, but not yet reported the results of calculation of GHG to RSPO. Auditor raise as Non conformity (NCR No.2015- 11 of 18).

Compliance status: Non Compliance Non-conformance 2015 -11 of 18 (Minor non-conformit y): The Company has not yet reported the results of GHG calculation 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 positive ones are made, implemented and monitored, to demonstrate continuous improvement. Findings: PT GTA and PT IPBD has social impact assessment (SIA), the assessment was conducted in year 2012. The process to conducted social impact assessmement can be seen through photograph, at-tendance list in several villages such as Dabek Makmur, Embacang etc. However the document SIA made has not explained comprehensively the impacts associated with the company actual condition ei-ther to the negative impacts as well as to the positive impact. This is raised as non confomrity. Some evidence that the assessment has been done with the participation of affected parties such as: Photo FGD activities in Dabuk Makmur village on September 14th, 2012 at 9:30 am was attended by 16 participants. - Photo FGD activities in Balian Makmur village on September 14, 2012 at 14.00 pm was attended by

16 participants. - Photo FGD activities in Embacang village on 14 Setember 2012 was attended by 18 participants. - Photo FGD activities in Balian village on 14 Setember 2012 was attended by 16 participants. The affected parties from operational PT IPBD are: Margo Bakti Village; Makarti Mulya Village; Dabuk Makmur Village; Mulya Jaya village; Sumber Baru village; and Balian village; The company has social management plan stated, the information on the plan has not rele-vant with information stated on social impact assessment document. There is no specific plan for avoidance or mitigation of negative impacts and promotion of the positive ones, and monitoring of impacts identified, has not developed in consultation with the affected parties, documented and timetabled, including responsibilities for implementation. This is raised as non conformity. Furthermore review of the management plan and social impact periodic monitoring of 2 years yet, since a social impact assessment document has not been made by PT GTA. The impacts of smallholder schemes (where the plantation includes such a scheme) has not included on the existing social impact assessment. This is raises as non conformity. Compliance status: Non Compliance Non-conformance 2015-12 of 18 (Major non-conformity ): The SIA document made has not explained comprehensively the impacts associated with the company actual condition either to the negative impacts as well as to the positive impact. Non-conformance 2015-13 of 18 (Major non-conformity ): a. The management and monitoring of social impacts document both negative impacts and positive

impacts are not yet available. The document is available for social management plan only.

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b. There is a social management plan document has been made by the company, but the manage-ment plan has not been fully associated with the identified social impacts both for the available es-tates and for POM.

Non-conformance 2015-14 of 18 (Minor non-conformity ): No evidence has been carried out related a review of the management plan and social impact periodic monitoring of 2 years yet , since a social impact assessment document has been made by PT GTA. Non-conformance 2015-15 of 18 (Minor non-conformity ): The social impact of the plasma presence in the PT GTA has not been identified yet.

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

Findings: The company has Consultation and communication procedures, it is documented on P-SAG-RO-CAS-

08. There is a management official letter regardsing assignment of responsible person for sosial issues, it was ststed onletter no. 138/HRS/SKJ/P/VI/2015 for Plantation Support Coor-dinator. The specific job desription for plantation support coordinator as stakeholder commu-nication has no explained, this is company opportunity for improvement. , A list of stakeholders is well maintained, the list contain, representative from smallholders, head of village, FFB Suppliers, local institution, NGO, Sub Contractors, FFB suppliers, hous-ing contrarctor, community leaders from affected parties. Stakeholder consultaion to inform Company’s procedure of communication was done on August 14, 2015. 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 parties. Findings: The open system regarding dispute resolution is available integrated with the communication and com-plaint procedure on P-SAG-RO-CAS-08, the company also establihed policy to protect anonymity of complainants and whistle-blowers. There is no incoming complaint until the audit time. Compliance status: Compliance with observation Criterion 6.4: Any negotiations concerning compensa tion for loss of legal or customary rights are dealt with through a documented system that ena bles indigenous peoples, local communi-ties and other stakeholders to express their views through their own representative institutions. Findings: A procedure for identifying legal, customary or user rights, and a procedure for identifying people enti-tled to compensation have been in place, it is determined on IMS Procedure P-SAG-RO-CAS-03 rev2 dated December 2, 2013. However there is no evidence that procedure are jointly developed, agreed and accepted by local communities. The company explained that the drfat was made by company and was communicated to stakeholder’s especailly local community by August 14, 2015. The procedure include for calculating and distributing compensation (monetary or otherwise) The pro-cedure is new has not clear information about conisderation of gender differences in the power to claim rights, ownership and access to land; differences of transmigrants and long-established commu-nities; and differences in ethnic groups’ proof of legal versus communal ownership of land. This is company opportunity to improve the procedure. Compliance status: Compliance with observation.

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

Findings: There are 5 types of workers, i.e.: Staff; Monthly employee; casual workers and contracted employees. Pay and conditions for each employee has been explained on the working agreement. There is a de-cree letter from Governor of South Sumatra No. 217 / KPTS / Manpower / 2015 on Minimum Wage South Sumatra provincial for agriculture sectoral the minimum wage is, Rp, 2,100,000, - followed by the Memorandum No. 026 / MD / III / 2015 related to the Basic Daily Wages Release 2015 and No. 027 / MD / IVI / 2015 monthly basic wage of employees and casual workers; No. 028 / MD / IV / 2015 adjusted monthly basic wage of employees and casual workers in 2015 dated January 26, 2015 minimum wages Rp 84,000 equal with Rp.2,100,000 per month. It was sight during the audit the implementation of payment for several casual workers has been fulfill the minimum wages, such as employee no. PS0590; PS0665; PS0663 and PS0441. However during the audit it was found employement condi-tion for casual workers were not consistent with the regulation, there are casual worker has been working more than 3 maonths with 21 days working days per month but the worker has not promoted become permanent workers as required by Kepmenaker no. 100 year 2004; and some workers in SS mill working with overtime more than required time, this is also in-consistent with Kepmenaker no. 102 year 2004. This is raised as non conformity under CR. 2.1 above. There is working agrement between company and workers union, the agrement has inlcude employment detailing payments and conditions of employment (e.g. working hours, deduc-tions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc.). The new agrement has been establishe valid since October 24, 2015 and asking for apporval from local manpower office Ogan Komering Ilir. Working agrement avail-able in Bahasa Indonesia, the languages understood by the workers. Company provide adequate housing for all workers including their family, there are type of house 21 unit of G6, G4 and G2 for casual workers, free electrical with quota 450 watt per month; clean water from boreholes; mosque, childcare, secuirty pos, school and bus shuttle schoolchildren until the nearby village that has junior secondary school. Both estates and mill have make demonstrable efforts to monitor and improve workers’ access to ade-quate, sufficient and affordable food especially for workers family, There are shops selling basic goods for daily needs in housing area with adequate prices, small weekly market. Rice given free of charge by the company with the amount of 15 kg for workers, 9 kg for the wives, 7 kg for a kid. The worker will get 38 kg rice for one family (1 wife and 3 children). Health facilities provided free of charge, the company provides medical clinic in estate area, and if the clinic can not handl, it will be referred to a big hospital and all cost will be paid by the company. Compliance status: Non Compliance See NCR under CR 2.1 above. 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 collec-tive bargaining are restricted under law, the emplo yer facilitates parallel means of independent and free association and bargaining for all such pe rsonnel. Findings: There is a published statement in local languages recognising freedom of association shall be availa-ble. It is stated on Sampoerna Agro Policy issued on July 21, 2015 section 4. The policy has been publish in all public area, such as meeting room, loading ramp, sport hall and housing area. A workers union has been established, it is called “Serikat Pekerja Sampoerna Agro (SPSA)”. There is an agreement between company and workers union. The new agrement has been established and val-id since October 24, 2015 and asking for apporval from local manpower office Ogan Komering Ilir. It was sight letter of registration No. 010/GTA/HRS/XI/2015 and No. 009/MBJ/HRS/XI/2015 dated No-vember 9, 2015.

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There are no evidence that workers union has periodc/regular meeting and no minutes meeting made by workers union or workers' representatives. This is raised as non conformity. Compliance status: Non Compliance Non-conformance 2015-16 of 18 (Minor non-conformit y): Not found for the minutes of meetings conducted by workers union or workers' representatives. ( Workers Union of SS estate ) Criterion 6.7: Children are not employed or exploit ed. Work by children is acceptable on family farms, under adult supervision, and when not interf ering with education programmes. Children are not exposed to hazardous working conditions. Findings: Company has commitment that children are not employed or expoited, it is tstated on Sampoerna Agro Policy dated Julay 21, 2015 section 5. The minimum age to be employed is 18 years. It was sight from the list of workers both casual and permanent workers including subcontractor work-ers, there is no workers under 18 years both in the estate and the mill. It was also confirmed by the workers during visited on the field. Compliance status: Full Compliance.

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

Findings: There is a company policy on non-discrimination and equal opportunities, it is stated on Sampoerna Agro Policy siisued on July21, 2015 section 4. The commitment about equal op-portunity was stated also in new working agreement. The policy was communicated to all workers especially during morning briefing. There is evidence about morning briefing on July 8, 2015 and Ocotober 24, 2015. All policy will be distributed to all staff, casual worker and permanent staff. There is no discrimination to the workers in company’s estate and mill as confirmed by the workers during field checking. There is complaint from local community in Dabek Makmur regarding job vacancy for their children in villges. The villages feel that com-pany has not provide job opportunities to local people instead of people from Java or any other people come from other regions. However it was checked casual workers and some of supervisor in the estate and mill already work with the company for longtime. The company demonstrated that recruitment selection, hiring and promotion are based on skills, capabilities, qualities, and medical fitness necessary for the jobs available. There is standard operation procedure for recruitment process i.e. IMS No. P-SAG-ADM-KTU-04 Rev.01 dated September 01, 2014. There is alos Standard Operation procedure for employee promotions. (PPK) P-SAG-RO-HRS-03. Compliance status: Full Compliance

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

Findings: The company established a policy to prevent sexual and all other forms of harassment and vio-lence was implemented and communicated to all levels of the workforce, as stated on Sam-poerna Agro corporate policy was communicated to all workers including workers from sub-contractor. Such evidence of socialization about corporate policy is list of participant on July 08, 2015. There is a policy to protect the reproductive rights of all, especially of women, the policy

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Has been documented, implemented and communicated clearly to all levels of the workforce. During morning briefing, and other informal seassion. The implementation can be seen i.e.:

- The company provide.maternity leaves 1.5month before and 1.5 month after deliver. - The company provide additional 15 minute to the workers especially for woman workers to

give breastfeeding to their kid. Protection of reproduction also found on new working agrment document period 2015 to 2017 article 21 regarding Materrnity, periodic leave and sick leave. Compliance status: Full compliace

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

Findings: The company follows FFB pricing mechanism as define by local government. There is a team to for-mulate FFB price in Ogan Komering Ilir Region it is called FFB pricing team, the team consist of multi-stakeholders participant i.e. government represented by lpcal ministry of Agriculture, growers repre-sentative, smallholder representative, growers and mill association etc. Every two week the team make a meeting to updateFFB price following current CPO price in the world market. The proce decided from the meeting valid for the next 2 weeks, e.g. FFB proce for October 2015. - The 1st period meeting was held on October 08, 2015, the meeting result was FFB proce for 1 to 15

October period i.e. CPO price Rp 6,002/kg and FFB price was 3990.33/kg . The price will consider the OER/KER for each planted year of oil plam plantation, it was make the range of FFB price lower become RP 1105.14/kg for planted year until year 3rd to Rp 1274.82/kg FFB for planted year be-tween 10-20 years,

- For the 2nd period meeting was held on October 19, 2015, the meeting result was FFB price for 16 to 31 October period i.e. CPO price Rp 6,335.84 /kg and FFB price was 3990.33/kg . The price will consider the OER/KER for each planted year of oil plam plantation, it was make the range of FFB price lower become RP 1105.14/kg for planted year until year 3rd to Rp 1274.82/kg FFB for planted year between 10-20 years,with consideration to the OER and KER result, the price become Rp 1182/kg FFB to 1340.18/kg FFB.

However nNo specific information regarding previous FFB Prices and FFB current prices have not seen available to the public specificly conducted by the miller. This is raised as non conformity. fur-thermore the company has no evidences of FFB price which set by FFB pricing team was communi-cated to the farmers who supply FFB's to the POM of SS estate

The company has cooperation with some local business contractors such as housing developer, FFB/CPO transporter and others activities. There is a contractual agreement between company and their FFB supplier and other local business such as contract no. no. 180/GTA/SPK/VIII/2013 between company and PT Steady Putra. Contract between PT MBJ and CV Bangun Bersama No. 294/MBJ/SPK/IX/2015 dated September 01, 2015. It was confirmed by the supplier during stakeholder consultation both parties were signed and understand the contractual agreement they have entered into. The contracts were legal and fair according to Indonesia governemnt regulation and both parties keep the copy of contract.

The payment condition and mechanism were agreed and stated in the contract, i.e. 14 days after compa-ny receive invoice or after the jobs finished. It was confirmed by management of CV Bangun Bersama both mill and estate has good commitment and pays their responsibilities in a timely manner.

Compliance status: Non Compliance Non-conformance 2015-17 of 18 ( Minor non-conformit y): Previous FFB Prices and FFB current prices have not seen available to the public. Non-conformance 2015-18 of 18 (Major non-conformit y): There is no evidences of FFB price which set by FFB pricing team was communicated to the farmers who supply FFB's to the POM of SS estate

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

Findings: There is Sampoerna Agro Corporate Social Responsibility program, as a kind of company’s contribu-tion to local development. The programs were made based on the input and consultaion with local communities. Such as from incoming proposal, and company visit to the villagers. There is overview activities of company’s CSR for 2 sub district i.e. “Kecamatan Mesuji (Sungai Sodong; Pagar Dewa; Mekar Wangi village) and “Kecamatan Mesuji Raya ( Balian Makmur; Dabuk Makmur, Balian and Mataram Jaya). There is CSR fund for year 2015 i.e. Rp 324,900,000, the fund were distributed to all agreed villaged as metions above. It was confirmerd by villagers from Dabuk Makmur and Balian the company has good contribution to local development such as provide clean water facility; education for catfish cultivation in Dabuk Makmur village. Even not all community need were fulfil as requested by community from Dabuk Makmur ragerding bridge construction in Dabek Itam river. The company can demonstrated and was confirmed by head of Embacang village i.e. contribution for road maintenance program in village road and donation for every moments held by villager. The company has scheme smallholder supply FFB to Sumber sawit mill. All activities in smallholders’ area were done by the company’s. The smallholder is not directly managed their lain. However to im-prove communities skill regarding plantation activite, Some activities such as training for best practice and IPM have been provided. This is confirmed by villagers in Dabuk Makmur village. There is list of participant for smallholder training in year 2014 and 2015 available in document controller office and also smallholder scheme manager. Compliance status: Full Compliance.

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

Findings: There is Sampoerna Argo corporate policy issued on July 2015, it was stated that company in all aspect protect all workers from forced activities and trafficked labour shall not used. The policy was com-municated to all workers level on August, 2015. The workers from boiler section that was intervieweed during onsite audit confimerd that they are working without forced and no trafficked. Even the overtime more that requirement from government regulation but this I s not direction from management. No migrant workers employeed. The reqiorement is no applicable. Compliance Status:Full Compliance

Criterion 6.13: Growers and millers respect human r ights.

Findings: There is a company’s policy on human rights as stated on Sampoerna Agro Policy section 4 dated Jlu 2012. It was communicated to employe on July 8, 2015. The supervisor and responsible manager have responsibility to communicate to all employe and workers. Until the audit time there is no any outsanding issue on human right in pT Sampoerna Agro and other subsidiaries. Compliance Status:Full Compliance Criterion 7.1: A comprehensive and participatory in dependent social and environmental impact assessment is undertaken prior to establishi ng new plantings or operations, or expand-ing existing ones, and the results incorporated int o planning, management and operations. Findings: As explained on the Cr. 6.1 above PT GTA and PT IPBD has social impact assessment (SIA), the as-

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South Sumatera indonesia

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sessment was conducted in year 2012. The process to conducted social impact assessmement can be seen through photograph, attendance list in several villages such as Dabek Makmur, Embacang etc. However the document SIA made has not explained comprehensively the impacts associated with the company actual condition either to the negative impacts as well as to the positive impact. This is raised as non confomrity in Cr.6.1 above. Compliance status: Non Compliance See NCR on CR.6.1. above.

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

Findings: Sumber Sawit Estate The company has the type of soil maps with a scale of 1: 35,000 with the following details:

• Plinthic kandiudults with an area of 1,402.8 hectares (sedimentary rock, clay gravel and loam rock)

• Lithic hapludults with an area of 1,221.5 hectares (sedimentary rock, clay gravel and loam rock)

• Typic dystrudepts with an area of 125.5 hectares (alluvium, sedimentary rock) • Typic kandiudults with an area of 235.4 hectares (sedimentary rock, clay gravel, sandstone

and loam rock) • Typic haplohemists with an area of 10.5 hectares (sediment of organic materials) • Typic haplofibrists with an area of 354.7 hectares (sediment of organic materials)

IPBD Estate The company has the type of soil maps with a scale 1:20,000 with the following details:

• Typic Dystrudepts with an area of 577.2 hectares (sedimentary rock, clay gravel and sand-stone)

• Typic Hapludox with an area of 429.4 hectares (sedimentary rock, clay gravel and sandstone) • Typic dystrudepts with an area of 126.7 hectares (sedimentary rock, clay gravel and loam

rock) • Plinthic kanhapludults with an area of 131.9 hectares (loam rock) • Typic haplofibrists with an area of 23 hectares (sediment of organic materials)

Based on field visits, planted area has well adequate water drain. The construction of drain refers to topo-graphic maps owned by the company so that can be known water flow direction. The company also uses topographical information and best practices to build roads and infrastructure in the garden. Compliance status: Full Compliance

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

Findings: It was sight on company’s hectare statement, there are 682.22 ha planted area after November 2005, before HCV assessment conducted in PT Gunung Tua Abadi i.e. year 2005 is 136.25 ha; year 2006 is 157.55 ha; year 2007 is 313.80 ha; year 2008 is 70.20 and after HCV assessment conducted in year 2011 there is 4.4.2 ha. While for Inti Permata Bunda Dua estate total oil palm planted after year 2005 is 770.02 ha consist of planted on year 2006 is 333.93 ha and year 2008 is 66.89 ha. There is no indi-cated company replaced primary forest and any area require to maintain or enchace one or more high conservation values, in all plantation area above year 2005 base on observation on the field and doc-ument checked. Acoording to information stated on HCV assessment result in year 2011, company condition in year 2001 was dominated by thicket swamp, bush, agriculture local community and small part oil palm eco-system. The land covered stated on satelite imaginary TM year 2001, PT Gunung Tua Abadi area was

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not connected with other forested ecosystem area. Small part categorized as peat land however the company has deliniating that area and excluded from company’s productive area as well as riparian Dabuk Itam river. No oil palm planted was sight during field audit on that area The company has con-duct land use change analisys for all opened area after year 2005, the information stated on the analy-sis result that using satelite imaginary 7 band 543 dated 09/08/2005 is categories as open land with coeficient 0. The condition of land covered for PT Inti Permata Bunda Dua estate according to land use change analisys conducted by external consultant from Bogor Agriculture Univesity as explained on the table below:

Source: land use changes analisys document IPBD estate year 2015. Using satelite imaginary 7 Band 543 aquisition 03/06/2004; 09/08/2005; 16/05/2006 and 02/10/2007. Notes ; 1 is swamp; 2 is thicket swamp; 3 is bush;4 is oil palm; 5 is open area. According HCV assessment for PT Mutiara Bunda Jaya It is an overlaid map between IPBD land use right HGU area and Forested area map issued by ministry of Forestry according to decree letter no. 866/Menhut-II/2014. IPBD are not side a side with protected forest of production forest. In year 2015 company submit their disclosed liability to RSPO and was confirmed by RSPO compensa-tion executive that PT Sampoerna Agro has disclosed zero liability for their units, including PT Gunung Tua Abadi and Inti Permata Bunda Dua estate. Compliance status: Full Compliance.

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

Findings: The PT Gunung Tua Abadi (Sumber Sawit Estate and Balian Estate) has the type of soil maps with a scale of 1: 35,000 with the following details:

• Plinthic kandiudults with an area of 1,402.8 hectares (sedimentary rock, clay gravel and loam rock)

• Lithic hapludults with an area of 1,221.5 hectares (sedimentary rock, clay gravel and loam rock) • Typic dystrudepts with an area of 125.5 hectares (alluvium, sedimentary rock) • Typic kandiudults with an area of 235.4 hectares (sedimentary rock, clay gravel, sandstone and

loam rock) • Typic haplohemists with an area of 10.5 hectares (sediment of organic materials) • Typic haplofibrists with an area of 354.7 hectares (sediment of organic materials)

IPBD Estate has the type of soil maps with a scale 1:20,000 with the following details:

• Typic Dystrudepts with an area of 577.2 hectares (sedimentary rock, clay gravel and sandstone) • Typic Hapludox with an area of 429.4 hectares (sedimentary rock, clay gravel and sandstone) • Typic dystrudepts with an area of 126.7 hectares (sedimentary rock, clay gravel and loam rock) • Plinthic kanhapludults with an area of 131.9 hectares (loam rock) • Typic haplofibrists with an area of 23 hectares (sediment of organic materials)

Based on the results of a soil survey have been conducted there is information about the type of peat, peat depth, peat management recommendations. The company uses the map to identify areas that are not suitable for planting. The maps are also used in the social and environmental impact assessment

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Compliance status: Full Compliance Criterion 7.5: No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a document ed system that enables indigenous peo-ples, local communities and other stakeholders to e xpress their views through their own repre-sentative institutions. Findings: It is observed during main audit, there is no new planting established on the local people’s land in Sumber Sawit estate, Balian and IPBD estate. It was confimed during interview proces in Dabek Makmur and Embacang village. Compliance status: Full compliance.

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

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

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

Findings: GTA (mill and estate) has policy for environmental protection, with prohibition of zero burning for all ac-tivity in the estate. In the procedure number P-SAG-KBN-PML-01- Rev01 dated on March 16, 2012. Procedure has men-tioned land clearing activity without zero burning activity. There are recorded of land clearing with zero burning activity based on field observation in estate. Compliance status: Full Compliance

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

Findings: There is planted area after year 2010, however the area had been cleared before year 2010 inside the former legal land. There is no new develompent area after year 2010. This requirement is not applica-ble both for GTA estate and IPBD estate. Compliance status: Not applicable.

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

Findings: The estate and mill have a monitoring action plan and implementation report based on their Environ-mental Management and Monitoring plan (UPL/UKL), and regular evaluations of plantation and mill op-erations. As PT GTA estate and the mill prepares a report of their implementation of the UPL/UKL once every 6 months as required by the environmental department, which covers aspects required to be monitored in the UPL/UKL. For the estate, this includes ambient air quality, groundwater quality, waste collection, water biota sampling and analysis, road damage, social economic aspects such as hiring of

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workers and FFB and EFB transport (which can impact water and air quality), as well as impacts to community health due to fertilizer application, and FFB and EFB transport. While for the mill, the im-plementation report includes results ambient air quality, boiler emission quality, palm oil mill effluent quality, soil quality of land application area, noise levels, and scheduled waste production records. In addition, PT GTA estate has a documented Environmental Improvement Plan for year 2015, which covers activities to reduce domestic waste separation, and HCV management and monitoring. The program is updated monthly to indicate status of activities carried out and the estate also has a form for monitoring of achievement of objectives and targets. The estates has program to reduce pesticide us-age and other restricted agrochemical materials. The mill also has an additional documented list of Environmental Objectives and Targets for year 2015, including progress of implementation. The list includes activities for improving environment manage-ment by reducing usage of fossil fuels to 0.79%/tonnes FFB, maintain water usage at 0.184 m3/tonnes FFB, and prevention of pollution resulting from spillage of mill effluent to the field through regular pond cleaning distribution for land application, installation of underflow pipes from pond 6 to pond 7 and reg-ular housekeeping. The mill must continue to ensure these activities are implemented as it was ob-served in the field that the effluent ponds were near overflowing levels after only one day of rain Compliance status: Full Compliance

RSPO Supply Chain: Sumber Sawit Palm Oil Mill (SS POM) is located in South Sumatera - Indonesia. Sumber Sawit Mill was es-tablished with a processing capacity of 60 tonnes FFB/hours (revision of permanent bussiness permit (IUT) and plantation business permit (IUP) in process). The location of Sumber Sawit palam oil mill. inside Sumber sawit Balian estate. The company implements SCC-RSPO with “Mass Balance (MB)” model according to the nature of mill FBB supply condition. The following is a description of the company’s supply chain management system according to the RSPO SCCS requirements (it was assessed/audited against Module E), including status of compliance of the company and their outsourced third parties to RSPO SCCS requirements. Results of audit/assessment as describe on the explaination bellows:

E.1.1 Definition Findings: PT Gunung Tua Abadi; Sumber Sawit Palm Oil Mill is one of mill under Sampoerna Group. Located in Balian village, Mesuji Raya district, OKI Regency, South Sumatera. GTA palm oil mill will implemented the RSPO SCCS MB. This model will be allowed the mill mix the certified and uncertified FFB, CPK and PK with control by mass balance record and will evaluate in every three months. GTA Palm Oil mill has record of incoming FFB supplyed to the mill. Based on year of 2014 data and 2015 until July, FFB incoming into the mill is came from owned estate and others estate in sister company, and there is no FFB from out growers/third party. During the main assessment, for 2014 total incoming FFB from owned estate under (scope certification) (Sumber sawit estate) was 62,529 mt and IPBD estate was 24,159.20 mt. Then, for 2015 until October 2015, incoming FFB from owned estate was 79,476.83 mt from Sumber sawit estate and 22,653.03 mt from IPBD estate. While the uncertified FFB, for 2014 was 160,667.68 mt and for 2015 until October was 76,408.65 mt (came from others estate under sister company and smallholder). List of supplier will explained in criteria E4.1 below. But, there is also FFB certified incoming from Belida estate was 24,283.38 mt and Mesuji estate was 640.090 mt, certified under TUV Nord Indonesia with certificate number was TNI-RSPO 009.2010 for Belidan and TNI-RSPO 009.2010 for Mesuji estate. Compliance status: Full compliance E.2 Explanation

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Findings: Estimated of tonnage CPO and PK products has been recorded in to the public summary of the P&C certifi-cation report. GTA Palm Oil Mill no registered yet in RSPO IT Platform (e-Trace), because this main assessment then the mill will registered in to e-Trace after mill has RSPO certificate and will verify in first surveillance audit. Compliance status: Not applicable for this time E.3 Documented procedures Findings: GTA palm oil mill has established the procedure for RSPO SCCS MB implementation, such as: 1. P-SAG-PKS-PRS-01 Rev01 dated on August 1, 2012 about recording and weighing and FFB

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

FFB, CPO and PK loading. 3. P-SAG-PKS-PRS-14 Rev0 dated on October 1, 2012 about traceability and mass balance. This

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

During the main audit, GTA mill has carry out the RSPO SCCS MB training for all person will responsible for RSPO SCCS implementation evidenced by training attendantlist on 02/11/2015 and was attendant by 4 person i.e. sustainability assisstant, QC assisstant, Process assisstant and Maintenance assisstant. Compliance status: Full Compliance E.4 Purchasing and good in Findings: GTA mill has record the incoming FFB from all supplayers. Because during the audit GTA mill still no certification yet, and GTA mill still in prepare the RSPO SCCS system, so that GTA mill not separated the certified and uncertified FFB. GTA mill only record all of incoming FFB, example for 2014 and 2015 October, i.e.: A. Year 2014 (Under certification scope):

1. Sumber Sawit is about 62,529 mt 2. Inti Permata Bunda Dua (IPBD) is about 24,159.200 mt a. Others estate under sister company: 1. Telaga Hikmah 3 (TH 3) is about 30,224.140 mt 2. Telaga Hikmah 3 small holder is about 74,740 mt 3. Pagar Dewa Small holder is abut 2,001.270 mt 4. Belida is about 24,283.380 mt (RSPO Certified TNI-RSPO 009.2010 TUV Nord Indonesia) 5. Mesuji is about 640,090 mt (RSPO Certified TNI-RSPO 009.2010 TUV Nord Indonesia) 6. Inti Permata Bunda Satu is about 917,100 7. Balian is about 1,569.890 mt 8. Surya Adi is about 17,130 mt 9. Hikmah Lima is about 23,528.810 mt 10. Hikmah Dua is about 566,150 mt 11. Hikmah Satu is about 875,580 mt 12. Tanjung Sari is about 83,780 mt

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B. Year 2015 until October 2015 (Under certification scope): 1. Sumber sawit is about 79,476.830 mt 2. Inti Permata Bunda Dua is about 22,653.030 mt a. Others estate under sister company: 1. Telaga Hikmah 3 is about 38,046.380 mt 2. Pagar Dewa small holder is abut 2,302.350 mt 3. Belida is about 12,589.740 mt (RSPO Certified TNI-RSPO 009.2010 TUV Nord Indonesia) 4. Mesuji is about 1,192.670 mt (RSPO Certified TNI-RSPO 009.2010 TUV Nord Indonesia) 5. IPBS is about 697,820 mt 6. Surya Adi is about 451,950 mt 7. Hikmah Lima is about 34,910.150 mt

GTA mill has procedure and mechanism to inform the over production into the CB by document number P-SAG-PKS-PRS-14 Rev01 date issue October 1, 2015, mentioned “if over production projected, the marketing unit will inform to the CB related that over production”, Compliance status: Full compliance E.5 Record keeping Findings: GTA mill has record of mass balance template, with mass balance template was consist of certified and uncertified FFB incoming information, FFB production, CPO and PK production, OER and KER, delivery information, and stock condition in every three months. GTA mill also has established the procedure about three months evaluation, when the mill will carry out sell activity when the stock was positive, in document number P-SAG-PKS-PRS-14 Rev01 dated on October 1, 2015. This main certification, so there is no sales activity related certified and uncertified product carry out by company, and will verifiy in next surveillance. Compliance status: Full compliance.

3.2 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions A total of 18 nonconformances were identified during the main certification assessment. These consisted of 8 major non-conformities and 10 minor non-conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 60 days of completion of the as-sessment excep major non conformity no. 2015-04 of 18 still not fulfilled,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, 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:

Criterion 2.1. (Major indicator 1): Evidence of compliance with relevant legal requ irements shall be available.

Non-conformance 2015-01 of 18 (Major non-conformi ty): PT GTA has not comply with some of relevant laws and regulations , for example : a. There is evidence that casual workers for Division IV with Employee Number(EN) 8413 ; Siti Nur

Employee No. 8361 and employee number 8406 for four consecutive months from March to June 2015 has been working for more than 21 days per month. This is contrary to the Decree no. 100 in 2004 , as well as POM employees named Maryono .

b . Found some POM workers who have exceeded the limits set forth in the overtime as required by

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Manpower Regulation (Permenaker) No. 102 in 2004 and have not been reported to the relevant agencies among which ( in July 2015 ) : - Syarif Hidayat overtime 174.50 Hours - Tomi Jevisa overtime 246 Hours - Harwinsyah overtime 196 Hours - Kuning overtime 251 Hours - Dedi overtime 229 Hours.

c . The contain of first aid box in the POM office and for several locations in the estate office does not match that set out in Menpower Regulation (Permenaker) No. Per.15 / Men / VIII / 2008 on the con-tents of the box standard P3K.

d . From 23 operators ( 9 lifting operator ; 9 Steam boiler operators ; 4 operators of electricity ; 1 weld-er ) which have trained ( 4 operators of steam boiler , 2 lifting transport operators , 1 operator of electricity ) but for 17 remaining operators stil have not been trained . (related to P & C 4.8).

e . 2 available Medical personnel in the GTA has not Hyperkes trained yet in accordance with the work program of compliance regulations are made.

f . GTA's POM has not been able to show a permit stating if GTA’s POM capacity is 60 tones FFB's / hour.

g . First aid box is also not available in the FFB truck transporter. Correction: a. Promoting employee named Suminem (EN 8413) , Siti Nur Saniah (EN 8361) , Jumiati (EN 8406) ,

and the POM workers named Maryono proposed appointment as daily permanent employees to HR section.

b. At the time of peak fruit crop conditions the work of FFB process made into 2 shifts. At the time of low crop FFB made the process work so 1 shift.

c. To provide first aid box completely according to regulation Permenaker No. 15/Men/VII/2008. d. To sending the training proposal to HRS for welder, electric operator, boiler operator, forklift op-

erator . e. To propose Hyperkes training (Company Hygiene and Health) to HRS for medical personnel who

are in PT.GTA in 2016. f. To revise the Plantation Business Permit (IUP), which is now integrated with the Factory IUP in ac-

cordance with the Goverment Regulation Permentan No. 98 in 2013? g. To requires of each FFB truck to be equipped first aid box.

Corrective Action: a. Performs every casual worker attendance recaps are eligible to become daily permanent employee

and proposes to HR Section . - Creating a memorandum letter to casual workers. - Make an assessment plan for the proposed appointment of casual employees in January and July - Making a contract for workers who exceed the casual worker time limit work according to the

terms of appointment daily permanent employee. b. Under the certain conditions (peak crop) managers will propose additional overtime hours to the

leaders for approval refers to the memorandum issued by HRS. Extension of overtime hours is an agreement between the company and employees.

c. To make checklist for first aid content monitoring. d. Worker that has not trained will be provide internal training by mill head. e. If there are new medical personnel onboard then will be creating Hyperkes training program by

HRS. f. To monitor the list of content related to the available law and regulation requirement. g. To monitor the availability of first aid box content based on checklist of first aid box monitoring each

month. Date of Closure : December 14, 2015 Auditor Conclusions: Closed Verification result: a. Memorandum No. 0357 / HRS / XI / 2015 dated November 19, 2015 concerning the appointment of

Maryono as casual worker become daily permanent worker basis (for a 6 months contract periods).

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b. Memorandum No. 003/Eng-Ho/XI/2015 dated 17 November 2015 concerning employee’s working day for casual workers according to Manpower decree (Kepmenaker) No. 100 Year 2004.

c. Image contents of first aid box and their card of inspection checklist December 2nd 2015 the num-ber of items in accordance with Ministerial Regulation No. 12 15 / Men / VIII / 2008.

d. PT GTA send evidence training application letter for electrical and generator operators No. 01 104 / IPBD / XII / 2015 dated December 2, 2015. Letter requesting training to obtain a certificate / SIO for boiler operators, machine room operator and welder, memo No. 0523 / pks.ss / XII / 2015 dated December 22, 2015.

e. Memorandum No. 090/SS/XI/2015 dated 14 November 2015 concerning Hyperkes paramedic training .Letter No. 090 / SA / HRS / XII / 2015 to the head of the Association of South Sumatra Province Hiperkes of requests for training medical personnel Hyperkes for 6 PT SA. For registra-tion form Hiperkes training on behalf Apriani December 3rd 2015. Replies from Asociation Hyper-kes and OHS Indonesia South Sumatra branch No. 17 / XI / AHKKI-SS / 2015 dated December 4, 2015, related to confirmation for Hyperkes and safety for paramedics training to be implemented on December 14 to 22 2015 in Wisma Sodikin dh. Wisma Olga jl. Sumatra 1 No. Bukit Besar Pa-lembang.

f. There is a decree Head of Licensing and investment Ogan district No.003 / OSS + BPPM / IUP / XII / 2015 on IUP PT GTA for the unit capacity of 60 tones / hour, dated December 4, 2015.

g. Checklist first aid box IPB estate; Evidence handover first aid box to the vehicle driver SS estate, evidence handover P3K box truck driver of FFB transporter and submitted a list of eight FFB trans-porter drivers.

Criterion 2.2. (Major indicator 1): Documents showing legal owners hip or lease, history of land tenure and the actual legal use of the land shall b e available.

Non-conformance 2015-02 of 18 (Major non-conformity ): Based on the overlay maps against Concession area work maps of the Balian Estate concession and the results of field observations in Block 001A Far East there are indications of planting outside of con-cession made for 2 hectares . Correction: To overlay HGU map with actual unit operation plantation map. Corrective Action: There are 2 options : 1. to popose additional 2 Ha land become included on the existing HGU certificate. 2.To exclude planted block 001A total 2 haf from existing HGU certificate area. Date of Closure : December 14, 2015 Auditor Conclusions: Closed Verification result: PT GTA provide a overlay map between the concession area and issued a statement that two hec-tares of land from the scope of certification, there memorandum No. 0944 / SS / XII / 2015 on the ap-plication for the reduction of land use rights management of 2 hectares in PT GTA in 4 December 2015. There is evidence checks 2 Ha of land from the CA to the location of the excess 2 Ha. And en-sure that the land is outside from concession. Criterion 2.2. (Minor indicator 2): Legal boundaries shall be clearly demarcated a nd visibly maintained.

Non-conformance 2015 03 of 18 (Minor non-conformit y): There has been no recording of the identification results for maintenance of Balian estate concession boundary markers as it is still not known the exact number of current concession boundry markers (SS Estate) .

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Correction: To make list of boundary stone maintenance program to be included on plantation maintenance pro-gram. Corrective Action: To identify and conduct boundary stones maintenance program and regular monitoring the implementa-tion of boundary stone maintenance program. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to be verified at next audit. Criterion 2.3. (Major indicator 1): Maps of an appropriate scale s howing the extent of recognised legal, customary or user rights (Criteria 2.2, 7.5 and 7.6) shall be developed through participa-tory mapping involving affected parties (including neighbouring communities where applicable, and relevant authorities). Non-conformance 2015-04 of 18 (Major non-conformit y): From the overlay result of the concession map and the company's workmap were indicated the exist-ence of land occupation in the PT GTA concession area of 163.19 Ha and IPBD estate of more than 28 hectares, but no information regarding details of farmers who occupied the land, furthermore no evi-dence has been made related participatory mapping involving smallholders and other relevant stake-holders. Correction: To identify and mapping of farmers and conduct participatory mapping (work program) to the farmers who cultivating in PT. GTA with total area of 163.19 Ha and IPBD area of 28 Ha. Corrective Action: Regular reviewing and monitoring of the company concession area in accordance with the concession deserved. Date of Closure : December 14, 2015 Auditor Conclusions : Closed with observation Verification Result: The company provide document planning for land occupation handling, it has been explained that the communication with land occupier will be conducted on June 2016. However there is no evidence of socialization planning to relevant parties with the land occupied. There are map of land occupied in the PT GTA concession area of 163.19 Ha and IPBD estate. However ther is no evidence those maps agreed by land occupier. There is a statement from Director of PT Gunung Tua Abadi regarding detal of land occupied condition and list of villager that occupie the land on PT Gunung Tua Abadi, i.e. In HGU No. 3 Sumer sawit es-tate total land occupied is 66 Ha ; HGU No. 15 Sumber Sawit estate total land ocupied is 52.19 ha; HGU no. 14 Balian estate total land occupied is 45 ha. The auditor realize that land occupation problem is the case that can not solve immediately, therefore the auditor decide to accept program planning provided and the progress to be monitore regularly at least every audit. Criterion 2.3. (Minor indicator 2): Copies of negotiated agreements detailing the pr ocess of free, prior and informed consent (FPIC) (Criteria 2.2, 7. 5 and 7.6) shall be available and shall include: a) Evidence that a plan has been developed through consultation and discussion with all affect-ed groups in the communities, and that information has been provided to all affected groups, including information on the steps that shall be ta ken to involve them in decision making; b) Evidence that the company has respected communi ties’ decisions to give or withhold their consent to the operation at the time that this deci sion was taken;

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c) Evidence that the legal, economic, environmental and social implications for permitting oper-ations on their land have been understood and accep ted by affected communities, including the implications for the legal status of their land at the expiry of the company’s title, concession or lease on the land. Non-conformance 2015-05 of 18 ( Minor non-conformit y): The Company has not had documented evidence of the negotiation process with the peasants land in the PT GTA concession. Furthermore plan agreed by both parties to the settlement of existing land problems still not available yet. Correction: Identifying through work map overlayed with concession map. Further mapping of farmers and partici-patory mapping (work program) to the farmers land occupation in PT. GTA with total area of 163.19 Ha and IPBD area of 28 Ha. Corrective Action: To reviewing the working program arranged once in every year. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 4.5. (Minor indicator 2): Training of those involved in IPM implementation shall be demonstrated.

Non-conformance 2015-06 of 18 (Minor non-conformi ty): The Company has not provide the training to the pest foreman on behalf Heri Susanto who served as pest foreman starting from April 2015 (Sumber Sawit Estate) Correction: To propose the integrated pest management to HRS for Heri Susanto in 2016. Corrective Action: Logging the worker who required attending the training. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit. Criterion 4.6. (Major indicator 11): Specific annual medical surveillance for pestici de operators, and documented action to treat related health condi tions, shall be demonstrated.

Non-conformance 2015-07 of 18 (Major non-conformity ): IPBD estate still not performs blood cholinesterase checks for chemical sprayer employees or who handling chemicals. Correction: To conduct the blood cholinesterase examination for IPBD employees on 25 November 2015. Corrective Action: To conduct the blood cholinesterase for each year. Date of Closure : December 14, 2015

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Auditor Conclusions: Closed. Verification Result: PT GTA has submitted evidence on the cholinetrase Spirometry tests conducted by UPTD Hiperkes and the Department of Labor Occupational Safety province of South Sumatra on 27 November 2015 to 35 workers (spirometer) and 16 workers (Cholinetrase) IPBDestate. The results from examination on November 27, 2015 cholinesterase of all workers are still within normal limits. Criterion 4.7 (Major indicator 1): A health and safety policy sh all be in place. A health and safety plan covering all activities shall be documented an d implemented, and its effectiveness moni-tored. Non-conformance 2015-08 of 18 (Major non-conformity ): a. Sphygmomanometer in the puskesbun of Sumber Sawit Estate was damaged which is can not be

used when needed. b. Audiometri test for engine room operator has not done yet from 2013 until 2015 . Correction: a.To provide a new Sphygmomanometer for puskesbun Sumber Sawit Estate. b.To performs an audiometric examination fo the engine room Operator (Harwinsyah) at the date of 25 November 2015. Corrective Action: a. Puskesbun have to reporting all the damage tool or equipment their area responsibility when they

are broken. b. To ensure that all worker has been conducted audiometric examination annually. Date of Closure : December 14, 2015 Auditor Conclusions: Closed Verification Result: PT GTA provide a report of engine room operator examination results of audiometric tests on 27 No-vember 2015 in Hall UPTD Hyperkes with the results classified Lightweight disorders. Necessary fol-low-up is what will be done to the employee to prevent exposure or further disruption. Criterion 4.7 (Major indicator 2): All operations where health and safety is an iss ue shall be risk assessed, and procedures and actions shall be docum ented and implemented to address the identified issues. All precautions attached to prod ucts shall be properly observed and applied to the workers. Non-conformance 2015-09 of 18 (Major non-conformity ): c. Risk assessment for the identification and evaluation of environmental impacts aspects and their

OHS potential dangers not include all of the activities and the resks and dangers which are exist in the SS Estate, IPBD and SS POM.

d. It was found the backhoe loader operator has no license and backhoe loaders are leaked for the dust seal his arm , rearview no glass , lamp of tail lamp were broken also do not have a fire ex-thinguiser.

Correction: a. Incorporating all risk analysis in accordance with safety procedures that have been made. b. Helper is prohibit to operate the loader through the official memorandum and replace bechoe load-

er which do not meet the standards to bachoe loader which has operational standards. Corrective Action: a. To reviewing each year on risk analysis that has been made and adjusted to the procedures that

had been developed. b. To logging the available workers who are required to have license and propose to do training and

to replace / complement the work standard in the operating heavy equipment. Date of Closure : December 14, 2015

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Auditor Conclusions: Closed. Verification Result: a. PT GTA provide revised risk assessment document that has been included all activities including

its potentiatl hazardouse such as biohazard that may occure from filed activities. The risk assess-ment has been recorded on Risk Assessment to identified and evaluation environmental aspect and impact and hazard potencial document“.

b. Backhoe loader returns memorandum No. 59 along with his crew (letter no. 0527 / PKS.SS / XI / 2015) dated 3 December 2015. Irwanto certificates on behalf of the Department of Labor and Transmigration of Ogan district. News handover becholoader of SS POM to the central workshop on December 5, 2015. "

Criterion 5.2 ( Minor indicator 5): Where HCV set-asides with existing rights of loc al communi-ties have been identified, there shall be evidence of a negotiated agreement that optimally safe-guards both the HCVs and these rights. Non-conformance 2015-10 of 18 (Minor non-conformit y): There are areas defined as HCV 1.4 and 4 area of 75 Ha in Balian Estate concession and the area is also claimed as the area belongs to the public, until now there has been no agreement , negotiation or plan to reach an agreement made by PT GTA . Correction: Meetings were held to resolve the problem of HCV area covering 75 Ha are included in the core of concession Sawit Balian Estate PT. GTA on November 14, 2015, moderated by the Environmental Board Office OKI District and The Mesuji Raya Head of Sector Police. Corrective Action: Minutes of Agreement for Dabuk Makmur Cooperative Together with PT. GTA concerning to receiving area of 75 Hectares as the area of the company concession. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit. Criterion 5.6 (Minor indicator 3): A monitoring system shall be in place, with regu lar reporting on progress for these significant pollutants and em issions from estate and mill operations, us-ing appropriate tools. Non-conformance 2015 -11 of 18 (Minor non-conformit y): The Company has not yet reported the results of GHG calculation to RSPO Correction: Report the GHG calculation result to RSPO not later on 28 November 2015. Corrective Action: To including all available GHG data source as required by RSPO GHG version into procedure P-SAG-SUS-15 GHG inventory. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit.

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Criterion 6.1. (Major indicator 1): A social impact assessment (SIA) including recor ds of meet-ings shall be documented.

Non-conformance 2015-12 of 18 (Major non-conformity ): The SIA document made has not explained comprehensively the impacts associated with the company actual condition either to the negative impacts as well as to the positive impact. Correction: Create a matrix of issues related to the negative and positive impacts that arise in the actual condition of the company.

Corrective Action: Reviewing the matrix issues for positive and negative impacts in every year Date of Closure : Decem-ber 14, 2015. Date of closure : December 14, 2015 Auditor Conclusions: Closed. Verification Result: PT GTA submit a revised document for all SIA activities in PT GTA and PT IPBD, the information ex-plained on the document has been included description of impact positive and negative according to company activities. Criterion 6.1 (Major indicator 3): Plans for avoidance or mitigation of negative im pacts and pro-motion of the positive ones, and monitoring of impa cts identified, shall be developed in consul-tation with the affected parties, documented and ti metabled, including responsibilities for im-plementation. Non-conformance 2015-13 of 18 (Major non-conformity ): c. The management and monitoring of social impacts document both negative impacts and positive

impacts are not yet available . The document is available for social management plan only . d. There is a social management plan document has been made by the company , but the manage-

ment plan has not been fully associated with the identified social impacts both for the available es-tates and for POM .

Correction: a. Create a matrix of issues related to the negative and positive impacts that arise in the actual condi-

tion of the company Adjust social management plan to the documents that have been arranged in SIA accordingly.

Corrective Action: a. Reviewing the matrix issues for positive and negative impacts in every year. b. Conduct a review of social governance once in every 1 year in accordance with the SIA documents

that have been prepared. Date of Closure : December 14, 2015 Auditor Conclusions: Closed with observation. Verification Result: PT GTA provide matrix social impact management plan document that the management plan has not been fully associated with the identified social impacts both for the available estates and for POM . The matrix has inform identified impact, impact management, output form impact management activities, person incharge, impact management target, timetable and evidence of activities. It was found that the management plan was not made through consulaion method with affected parties, there is no docu-ment evidence showed the involment of stakeholder for development the management impact. Criterion 6.1. (Minor indicator 4): The plans shall be reviewed as a minimum once ev ery two years and updated as necessary, in those cases wher e the review has concluded that changes should be made to current practices. There shall be evidence that the review includes the partic-ipation of affected parties

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Non-conformance 2015-14 of 18 (Minor non-conformity ): No evidence has been carried out related a review of the management plan and social impact periodic monitoring of 2 years yet , since a social impact assessment document has been made by PT GTA. Correction: Will conduct a review of the social impact management plan and monitoring. Corrective Action: Will conduct a review of the social impact management plan and periodic monitoring each 2 years. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit. Criterion 6.1. (Minor indicator 5): Particular attention shall be paid to the impact s of smallholder schemes (where the plantation includes such a schem e).

Non-conformance 2015-15 of 18 (Minor non-conformity ): The social impact of the plasma presence in the PT GTA has not been identified yet. Correction: Re review Independently the relevant social impact of the scheme smallholder presence in the PT GTA that has not been described in the PT GTA SIA report. Corrective Action: The results of an independent review of relevant social impact of the scheme smallholder presence in the PT GTA will become part of the PT GTA SIA report. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit.

Criterion 6.6. ( Minor indicator 2): Minutes of meetings with main trade unions or wo rkers rep-resentatives shall be documented.

Non-conformance 2015-16 of 18 (Minor non-conformit y): The minutes of meetings conducted by workers union or workers' representatives was not found . ( Workers Union of SS estate ) Correction: To communicate to the relevant conducted worker union meetings and collect the records (invitation, attendance list, the minutes, the photo) also documented in the working unit. Corrective Action: To ensure all the worker union meeting are well documented in the available working unit. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit. Criterion 6.10 (Minor indicator 1): Current and past prices paid for Fresh Fruit Bun ches (FFB) shall be publicly available.

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Non-conformance 2015-17 of 18 ( Minor non-conformit y): Previous FFB Prices and FFB current prices have not seen available to the public. Correction: Installing in addition FFB price information boards in the gate of SS POM Corrective Action: Updating the FFB price information board regularly. Date of Closure : September 14, 2016 Auditor Conclusions: Evidence of immediate action t aken was accepted. Effectiveness of im-plementation to verified at next audit. Criterion 6.10 (Major indicator 2): Evidence shall be available that growers/millers have ex-plained FFB pricing, and pricing mechanisms for FFB and inputs/services shall be documented (where these are under the control of the mill or p lantation Non-conformance 2015-18 of 18 (Major non-conformit y): There is no evidences of FFB price which set by FFB pricing team was communicated to the farmers who supply FFB's to the POM of SS estate. Correction: All evidence related FFB price information and will be communicated to the public at the POM and keep maintain the document properly Corrective Action: Involved parties will inform the FFB price to the entire smallholder scheme and the information will be provided for public,all relevant documentations will be maintained in palm oil mill. Date of Closure : December 14, 2015 Auditor Conclusions: Closed Verification Result: PT GTA already provides a FFB price at the mill gate. This is FFB price result of Ogan FFB pricing team meetings for each 3 months and there is a meeting invitation for FFB pricing. Documents meeting invitation FFB pricing for the period December 09, 2015

3.3 Noteworthy Positive Components

1. Good commitment from PT SA management to impement RSPO requirements.

2. Good cooperation during audit time.

3. Company has fulfilled government regulation regarding minimum wages.

4. Palm Oil mill Office very clean, there is green line for walking and information about re-striction area very clear to prevent unintended person entering the high risk area.

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5. Complete PPE in palm oil mill especially for high noise area above 85dB.

6. Zero findings for RSPO SCCS on Sumber sawit palm oil mill.

3.4 Issues Raised by Stakeholders and Findings Pert aining to Issues A) Issues Raised during Stakeholder Consultation Me eting

No. Issues Raised Management Response Audit Verification

1

CV Bangun Bersama has cooperation with PT GTA since 2002, the payment is still good, the tender will be made open, and there is no element of corruption in the job tender. PT GTA has good relationship with the surrounding community, donation pro-vided has also been quite a lot. CV Bangun Bersama always provide good service for the purposes of the ex-isting infrastructure in the company even though it was not the responsibility of the job

Positive response

Supplier and company explaination can be ac-cepted.

2

Every year the company recruited work-ers from outside the region, never gave a chance for local people, whereas 30% of the village are high school graduates, there are 15 people who graduated S1 and D3.

- As a kind of appreciation to the community surround-ing, the company can be proven by the position of labor and letter of appoint-ment where 11 people from the Dabuk Makmur village and 90% of employees KHT harvesters in Division V and VI from the village Dabuk Makmur - 25 from total of 94 Mill workers are from Dabuk Makmur.

Some local wokers come from Dabuk Makmur as observed from list of work-ers,however the case Will be verified again for the next audit.

3

The work opportunities only for casual workers. Job opportunities for staff level are never opened for the community sur-rounding company’s area.

- As a kind of appreciation to the community surround-ing, the company can be proven by the position of labor and letter of appoint-ment where 11 people from the Dabuk Makmur village and 90% of employees KHT harvesters in Division V and VI from the village Dabuk Makmur

Company has no mechanism to com-municate job vacancy to the villager sur-ronding company’s area. This is raised as potential for improve-ment.

4 People from Balian Makmur followed job selectian, but not pass the pre test selec-tion.

Companies hire employees based on required qualifi-cations and continue to pri-oritize local communities

Company has no mechanism to com-municate job vacancy to the villager sur-ronding company’s area. This is raised as

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potential for improve-ment.

5

. Until now, the villagers have not received CSR donation. CSR socialization been done in 2013, had submitted proposals but had no response since 2013.

In the Year 2013 program CSR has not entered into Balian Makmur village, and would be built in 2015. This is evidenced by the rehabil-itation GPdI church in the village of Balian Makmur SP 5 March 2015.

Company explaination can be accepted.

6

It is said that the company had to set aside 2.5 % of their profits to CSR fund but until to date no realization has been done. The Company is not transparent in issuing a CSR fund

- With respect to the Compa-ny Law No. 40 of 2007 and the rules issued by the PP 47 Year 2012 on corporate social responsibility to observe the principle of allocation of funds CSR compliance and fairness does not mention the compa-ny had to set aside 2.5 % of its profits. - Every year the company re-ported a CSR budget program realization at the started from 2014 and 2015 budget pro-gram plans to OKI Regional Government through the Planning Agency.

Company explaination can be accepted

7 Once there was a proposal for cattle aid program but not yet implemented.

The Company has not re-ceived proposals related to cattle aid program

Will be verified again for the next audit.

8 Do RSPO forbid workers to caring birds and plants at home.

The Company does not pro-hibit workers caring birds and plants , except for birds and plants protected by the Gov-ernment Regulation No. 7 of 1990

Company explaination can be accepted

9

CSR funds should also be granted for the purchase of an ambulance, because the lo-cation is quite far between Polibun (Estate’s clinic facility) to the nearest hospital.

Company to prioritize the pur-chase of an ambulance for the needs of the company's em-ployees, but if society requires the use of an ambulance, they will be assisted by the com-pany. - Public Health Center (Pusk-esdes) own Ambulance from the Government.

Company explaination can be accepted

10

Companies should submit a report UKK (The Efforts of Occupational Health) every month; It was delivering routinely when starts, but now no longer exists.

The company has already re-ported UKK (The Efforts of Occupational Health) by the company doctor at the health office every month to OKI Dis-trict but not to sub district.

Company explaination can be accepted

11

The CSR funds Transparency to be made a proposal of CSR program that fits the needs of society.

The company reported a CSR budget program realization in Every year since 2014 and 2015 in a budget program plans to OKI Regional Gov-ernment through the Planning Agency.

Company explaination can be accepted

12 The village is currently building a new Proposals have been received Company explaination

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mosque, to which the proposal is submitted for funding?

and followed up. Its realization is already provided in the form of building material

can be accepted

13

Request the construction of the bridge ( riv-er Dabuk white ) that connects the village with Desa Makmur Dabuk Balian Damage to the existing bridge already claimed many victims.

At first the company has to build the bridge that can only be passed by a motor-cycle. Related to the peti-tion of bridge construction drivable four-wheel vehi-cles such as public de-mand, the company has provided assistance worth Rp . 100,000,000. Howev-er, the fund was rejected by people, for people wanting to build the bridge where community liaison Balian village with the Company plantations, which is not connecting between the Dabuk Makmur village and Balian village. If the bridge is built, there will be a lot of theft of palm fruit company.

Company explaination can be accepted

14

Companies were give 100 bags of cement and 4 truck of sand , totaling together a number of 8 million , but it was insufficient

The proposal of mosque con-struction and building com-mittee has been received and followed up by the company in the form of building materials aids that have been accepted by the committee

Company explaination can be accepted

15 The company should also to build biogas plan to power home communities around the plantation

The company will assess and coordinate with the Depart-ment of Mines and Energy

Company explaination can be accepted

16

There is no perceived negative things.PT GTA has been good, Mr. camat (Head of Sub District) who understand and know the problems that exist in the Dabuk Makmur village.

Positive response Company explaination can be accepted

17

Public consultation should be done also in the district in order to head of Regent can hear and provide input as well.

Public consultation is an im-plementation of the RSPO P & C which is aims to foster the aspirations of communities around the company. In the public consultation has also been invited from various De-partment of OKI regent for ex-ample the Department of Co-operatives , Department Bapedda , Plantation Office etc

Company explaination can be accepted

18 The licenses owned by PT GTA would have been complete because the existing con-cession , but keep re checking back

SKPD (Local Government Unit) has a mailing list of busi-ness licenses in the OKI dis-trict.

To be verified for the next audit.

19

There is already a CSR forum in Oki District comprised of various stakeholders including NGOs , whether PT GTA has been included in the forum

Sampoerna Agro and its sub-sidiaries, including PT. Gunung Tua Abadi is already incorporated in the CSR forum OKI regent. .

Company explaination can be accepted

20 How the problems that exist in the Em-bacang village, whether it has been solved ,

Embacang village is a local vil-lage of PT. Telaga Hikmah,

Company explaination can be accepted

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how the smallholder has finished and also whether CSR was already clear

not the local village of PT. GTA

21 Today many strikes occur trend for out-sourcing issues .

PT Gunung Tua Abadi was not implementing outsourc-ing employement system

Company explaination can be accepted

22

In GTA still finding the worker who work-ing as part-timer. Please be checked for daily casual worker has already promot-ed to be permanent worker?

The promotion program has been submitted to the management periodically

This is raised as po-tential for improve-ment. Some casual worker has been working for long time periode and has not promoted into perma-nent workers,

23 A continually works such as harvesting shall not be outsourced

PT Gunung Tua Abadi was not implementing outsourc-ing employement system

Company explaination can be accepted

24 Wages in the PT GTA is good , there is only a problem certain period of work engage-ment (PKWT) case.

Positive Response Company explaination can be accepted

25 Collective agreements (PKB) must be ap-proved by District Manpower and Transmi-gration Agencies (Disnakertrans)

Already registered on the November 2015 to the Pro-vincial Manpower Office

Company explaination can be accepted. Col-lective agrement has been renewed and registered.

26

Smallholder for some villages such as Dabuk Makmur, Balian Jaya, already avail-able reporting and compliance related to Regulation No. 27 is smooth. Monitoring has been reported related to the perfor-mance of the estates.

Positive response Company explaination can be accepted

27

There are areas of HCV in the plantation area, the government administration would ask for a report HCV be main-tained eventhough the BPN say it as wastelands.

The company has received the Circular of Ministry of Agrarian Affairs and Spatial Planning / Head of BPN No. 10 / SE / VII / 2015 on Issuance of Permits On High Conservation Value Forest Area through the Head of BPN Regional Of-fice of South Sumatra No. 2655 / 9-16 / VIII / 2015 dated August 4, 2015. However, some PT men-tioned, are included in Group Sampoerna Agro Tbk PT Selatan Jaya Per-mai. The future will be re-ported to the management report NKT all subsidiary Sampoerna Agro to Local Government.

To be verified for the next audit.

28 PT GTA has not submitted a report to the local government activities related to HCV management

The company has received the Circular of Ministry of Agrarian Affairs and Spatial Planning / Head of BPN No. 10 / SE / VII / 2015 on Issu-ance of Permits On High Conservation Value Forest Area through the Head of BPN Regional Of-fice Se-southern Sumatra

To be verified for the next audit.

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No. 2655 / 9-16 / VIII / 2015 dated Au-gust 4, 2015. However, some PT men-tioned, are included in Group Sampoerna Agro Tbk PT. South Jaya Per-mai. The future will be re-ported to the management report NKT all subsidiary Sampoerna Agro to Local Government

29

Must be checked how the fire fighting fa-cilities owned in connection with the fires that are currently assigned to a national disaster

The company has equipped a fire extinguisher in accordance Ditjenbun regulations in 2010 on Guidelines for Land Fire Control and Plantation

To be verified for the next audit.

30

In legal regulation categorized as a pro-tected area. Management of HCV should be reported as a basis for consideration of the change of Spatial plan (RTWP).

The company has not got the legislation in question if there besides Submission Circular Letter Agricultural and Spatial Planning Minis-ter / Head of BPN No. 10 / SE / VII / 2015 on Issuance of Permits On High Con-servation Value Forest Ar-ea through the Head of BPN Regional Office of South Sumatra No. 2655 / 9-16 / VIII / 2015 dated Au-gust 4, 2015

To be verified for the next audit

31

Please note facilities of fire prevention and control of land, with respect to the presence of peat in the area of PT GTA who had been burned and was under pressure from surrounding communities.

The company has equipped a fire extinguisher in ac-cordance Ditjenbun regula-tions in 2010 on Guidelines for Land Fire Control and the plantation

Company explaination is accepted. To be verified for the next audit

32 How was the handling of plasma fire in the village Pagar Dewa?

Plasma Pagar Dewa single management because it is adapted to the existing pro-cedures in the company.

To be verified for the next audit

33 How much the total Equipment needed to respond in the event of such this planta-tion area?

The company has equipped a fire extinguisher in accordance Ditjenbun regulations in 2010 on Guidelines for Land Fire Control and Gardens

Company explaination is accepted. To be verified for the next audit.

34

Use CSR funds for Land Clearing activi-ties undertaken by the community so that people no longer involve clearing land by burning.

CSR funds are used for community empowerment programs of mutual inter-est. The company sees the Land Clearing is not part of the community empower-ment program

Company explaination is accepted. To be verified for the next audit. Company ex-plaination is accepted. To be verified for the next audit.

35 Industrial environment licenses of PT GTA is complete including the EIA and waste management license

Positive response Positive response no needs to be verified.

36 The company should also to build biogas plan to power home communities around the plantation

The company will assess and coordinate with the Depart-ment of Mines and Energy

Company explaination is accepted

37 Are already established a special area for protected animals

There is already reserved of HCV area

Company explaination is accepted

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38

Must be checked the extent to which li-censes owned by PT GTA, such as SIUP, TDP, SITU how renewal doku-men IMB considering the company is already doing developm-ment facility.

The Company has met with the appropriate licensing laws and regulations.

Company explaination is accepted

39

LKPM report should be done by the company each month, whether the PT GTA already meets the rules-but terse. LKPM used to see how much investment already given PT GTA.

Already done for each 6 months

Company explaination is accepted

40 - LKPM Submission used to see whether the activities currently carried out is the same as its investment license.

Providing information state-ment

Company explaination is accepted.

41

EIA documents be made for are-as that get permission before 2007 in which the license carried by Government Eviron-mental Body (BLH) whereas after 2007 already uses carried out by the local land office

Providing information state-ment

Company explaination is accepted

42 EIA does not need to be amended if there is no change of capacity or ma-chine so far.

Providing information state-ment

Company explaination is accepted

43

In Telaga Hikmah harvest dismissed as sour grapes and the harvest is always the person has met the applicable rules.

It has been resolved through the mechanism in the OKI district of Manpow-er agency.

Company explaination is accepted

44 There are two organizations working in Sampoerna Agro.

The company gives freedom of association or union work-ers to employees

Company explaination is accepted

45

Land occupation must be completed by the company and the community, in the concession stated that the other prob-lems that exist in the land rights granted BPN should be discussed together.

Providing information state-ment

Company explaination is accepted

46 There should be no rights over the rights. Providing information state-ment

No need to be veified

47 In OKI regency is no unified team to re-solve land disputes.

Providing information state-ment

No need to be veri-fied.

48 No one has reported that PT GTA has the problem of land disputes with the rel-evant parties.

Providing information state-ment

There are some dis-pute, has been ex-plained on the rele-vant criteria above.

49 How plasma in Embacang and Pagarde-wa, should be clarified?

Smallholders in the Em-bacang and Pagardewa vil-lage already constructed and has converted

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

50

In accordance with Agriculture Ministry Regulation (Permentan) no. (8 in 2012, when The plantation license issued be-fore the year 2007, the company has no obligation to form the scheme smallhold-er, on the regulation required from peo-ple who give the land as scheme small-holder.

Providing information state-ment

No need to be veri-fied.

51 Permits issued in the period 2007 to 2012 shall form the scheme smallholder

Providing information state-ment

No need to be veri-fied.

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of 20% of the land that could be re-leased.

52 The division of scheme smallholder extents for each village depends on how wide the area of the village that made the plantation.

Providing information state-ment

No need to be veri-fied.

53

The positive impact because it can help the community because of the existence of the company so that people can work in the company.

Positive response No need to be veri-fied.

54 Smallholder reserve lands to be returned to the public / made as smallholder.

Land reserves for the smallholder may not over-lap with PT GTA Conces-sion. Currently the compa-ny only manages the con-cession area only.

Company explaination is accepted.

55

We asking the company to built the bridge wich connecting the Dabuk Makmur Village to the company but still no realization yet.

At first the company has to build the bridge that can only be passed by a motorcycle. Related to the petition of bridge construction drivable four-wheel vehicles such as public demand, the company has provided assistance worth Rp . 100,000,000. However, the fund was rejected by peo-ple, for people wanting to build the bridge where com-munity liaison Balian village with the Company plantations, which is not connecting be-tween the Dabuk Makmur vil-lage and Balian village. If the bridge is built, there will be a lot of theft of palm fruit com-pany.

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

56

The community were hope the returned to them for the land which were used for a conservation land by the company.

Land reserves for the small-holder may not overlap with PT GTA Concession. Current-ly the company only manages the concession area only. The area for which the public to be restored is the concession ar-ea of the Company which is used as a conservation area, not a backup area for small-hoders of Dabuk Makmur vil-lage. Filing aid in CSR program can be initiated by the health cen-ter to the Company in accord-ance with the procedure or through existing mechanisms.

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

57

Public Health Center (Puskesmas) still not utilize CSR program therefore asked for help in proposals related to improvement public health service improvement

In every year the company re-ported a CSR budget program realization at the start of the 2014 and 2015 budget pro-gram plans to OKI Regional Government through the Planning Agency. Filing can be done in accordance with the applicable procedures.

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

58 The Company has not build a bridge be-tween PT Sampoerna Agro with our village

At first the company has to build the bridge that can only

Company explaination is accepted, will be

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which is a citizen’s pioneering work in the company itself.

be passed by a motorcycle. Related to the petition of bridge construction drivable four-wheel vehicles such as public demand, the company has provided assistance worth Rp . 100,000,000. However, the fund was rejected by peo-ple, for people wanting to build the bridge where com-munity liaison Balian village with the Company plantations, which is not connecting be-tween the Dabuk Makmur vil-lage and Balian village. If the bridge is built, there will be a lot of theft of palm fruit com-pany.

verified on the next audit.

59 Please help CSR funds which should be the right of rural communities.

In every year the company re-ported a CSR budget program realization at the start of the 2014 and 2015 budget pro-gram plans to OKI Regional Government through the Planning Agency. Filing can be done in accordance with the applicable procedures.

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

60

Hopefully in the future the company could help our village and can realize the CSR to the village

In every year the company re-ported a CSR budget program realization at the start of the 2014 and 2015 budget pro-gram plans to OKI Regional Government through the Planning Agency. Filing can be done in accordance with the applicable procedures.

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

61

• The company was expected to be always pay attention to road repairs or mainte-nance. • Can help in the field of education both in its facilities as well as others • If there is a proposal submitted by the community to be immediately addressed.

Filing an aid for CSR program can be initiated by the health center to the Company in ac-cordance with the procedure or through existing mecha-nisms.

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

62 We expect the company to be more aware to the public environment

The Company strives to main-tain an environment in ac-cordance with applicable regulations

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

63 Use the local people as company worker in order to improve the local people life status.

- The Company hire employ-ees based on qualifications required and continue to prior-itize local communities - As an appreciation to the community around the com-pany can be evidenced by the position of labor and Appoint-ment decree of employees where 11 people from the Dabuk Makmur village were as supervisor and 90 % of Daily Permanent Worker

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

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(KHT) as harvesters in Divi-sion V and VI from the Dabuk Makmur village - 25 people out of a total 94 of employee in POM were people from the Dabuk Makmur village

64 The people around company who have re-ceived education can work in the company.

- The Company hire employ-ees based on qualifications required and continue to prior-itize local communities - As an appreciation to the community around the com-pany can be evidenced by the position of labor and Appoint-ment decree of employees where 11 people from the Dabuk Makmur village were as supervisor and 90 % of Daily Permanent Worker (KHT) as harvesters in Divi-sion V and VI from the Dabuk Makmur village - 25 people out of a total 94 of employee in POM were peo-ple from the Dabuk Makmur village.

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

65

Puskesdes(Public Health Center) ask for an ambulance because the distance between the Dabuk Makmur village to the hospital was so far away , so that can be used for the benefit of citizens in Dabuk Makmur

- Company to prioritize the purchase of an ambulance for the needs of the company's employees, but if society re-quires the use of an ambu-lance, they will be assisted by the company. - Public Health Center (Pusk-esdes) own Ambulance from the Government.

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

66

As an employee wants similarity of tasks and procedures in the appointment of staff promoted from within at least 75 %

The Company has provided the opportunity for employees to participate in the staff se-lection.

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

3.5 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client It is acknowledged that the assessment visit was carried out as described in this report and we accept the as-sessment findings and report content.

Signed on behalf of PT Gunung Tua Abadi

Yusi Rosalina Management Representaive Position Date: March 15, 2016

Signed on behalf of PT TUV Rheinland Indonesia Dian S Soeminta Lead Auditor Date: February 10, 2016

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APPENDICES

Appendix 1: Details of Certificate

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Appendix 2: Certification Audit Plan

dated Activities Auditor Auditee Keterangan

Monday, November 09, 2015

06.00-07.00 Tarveling Jakarta to Palembang

All tim -

07.00-12.00 Traveling Palembang – GTA estate

14.00-14.30 • Opening meeting

• Introduction about team audit • Introduction / presentation of

company background and source of FFB by respective managers

Tim auditor Perwakilan mana-jemen dan tim auditor

14.30-18.00 Checking document about :

RSPO

- Compliance with laws and regula-tions

- Legal land - Management plan & replanting

plan (if any). - FFB production and supply - Conservation and Biodversity - GHG calculation

MK

Rsepective manager RSPO

Principle 2 (Indicator 2.1.1 to 2.1.4 and 2.2.1 to 2.2.2) Principle 3 (Indicator 3.1.1 to 3.1.2) Principle 4 (indicator 4.4.1 to 4.4.2; 4.8.1 to 4.8.2) Principle 5 (Indicator 5.2.1 to 5.2.6; 5.4.1 to 5.4.2; 5.5.1) Principle 7 (Indicator 7.3.1 to 7.3.2; 7.4.1; 7.7.1 to 7.7.3)

Principle 8

14.30-18.00 Checking document relate :

RSPO - Partial certification, timebound

plan and NPP (if any) - Transparancy & Ethical con-

duct

- Compliance with laws and regulations

- Land conflict & use of the land

- Worker & Social Issues - Continual improvement

DSS

Respective manager RSPO

Principle 1 (Indicator 1.1.1; 1.2.1) Principle 2 (Indicator 2.2.3 and 2.3.1 to 2.3.2) Principle 6 (Indicator 6.1.1 to 6.1.2; 6.2.1 to 6.2.3; 6.3.1; 6.4.1 to 6.4.3; 6.5.1 to 6.5.3; 6.6.1 to 6.6.2; 6.7.1; 6.8.1 to 6.8.2; 6.9.1 to 6.9.2; 6.10.1 to 6.10.4; 6.11.1) Principle 7 (Indicator 7.1.1 to 7.1.3; 7.5.1; 7.6.1 to 7.6.6)

Principle 8

NPP RSPO certification systrem 4.2.4

14.30-18.00 Checking documents, relate : • Operating procedure &

agrochemical

• OSH • Waste

• Training • Continuous Improvement

SA Respectve manager Principle 4 (Indicator 4.1.1 to 4.1.3; 4.6.1 to 4.6.10; 4.7.1 to 4.7.6) Principle 5 (Indicator 5.1.1 to 5.1.3; 5.3.1 to 5.3.2) Principle 7 (Indicator 7.1.1 to 7.1.3) Principle 8

14.30-18.00 Checking document relate :

RSPO

• Compliance with laws and regula-tions

• Best Agriculture practice

• Environment issue

• Pollution and Emission • Zero Burning

• Emision and pollution

NMA Rsepective manager RSPO Principle 2 Criteria : 2,1 Principle 4 (Indicator 4.2.1 to 4.2.3; 4.3.1 to 4.3.4; 4.5.1 to 4.5.3; ) Principle 5 (Indicator 5.6.1 to 5.6.3) Principle 7 (Indicator 7.2.1 to 7.2.2; 7.4.2 to 7.4.3 ) Principle 8

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dated Activities Auditor Auditee Keterangan

• Continual Improvement

Tuesday, November 10, 2015 ; Sumber Sawit estate

08.00 - 12.00 Sumber Sawit Estate

Verification to field, relate :

• Compliance with laws and regula-tions

• Legal land

• Management plan & replanting plan (if any)

• Maintain the quality and availability of surface and ground water

• Training

• HCV • Efficiency of energy

• Use of fire • New Planting (if any)

• Continuous Improvement

MK Estate Representative Principle 2 (Indicator 2.1.1 to 2.1.4 and 2.2.1 to 2.2.2) Principle 3 (Indicator 3.1.1 to 3.1.2) Principle 4 (indicator 4.4.1 to 4.4.2; 4.8.1 to 4.8.2) Principle 5 (Indicator 5.2.1 to 5.2.6; 5.4.1 to 5.4.2; 5.5.1) Principle 7 (Indicator 7.3.1 to 7.3.2; 7.4.1; 7.7.1 to 7.7.3) Principle 8

08.00 - 12.00 Sumber Sawit Estate

Verification to field, relate : • Best practices

• Pollution and emissions • New Planting (if any)

• Continuous Improvement

NML Estate Representative Principle 4 (Indicator 4.2.1 to 4.2.3; 4.3.1 to 4.3.4; 4.5.1 to 4.5.3; ) Principle 5 (Indicator 5.6.1 to 5.6.3) Principle 7 (Indicator 7.2.1 to 7.2.2; 7.4.2 to 7.4.3 ) Principle 8

08.00 - 12.00 Sumber Sawit Estate

Verification to field, relate : • Operating procedure &

agrochemical • OSH

• Environmental • Waste

• New Planting (if any) • Continuous Improvement

SA Estate Representative Principle 4 (Indicator 4.1.1 to 4.1.3; 4.6.1 to 4.6.10; 4.7.1 to 4.7.6) Principle 5 (Indicator 5.1.1 to 5.1.3; 5.3.1 to 5.3.2) Principle 7 (Indicator 7.1.1 to 7.1.3) Principle 8

08.00 - 12.00 Sumber Sawit Estate

Verification to field, relate : • Transparancy • Land conflict & use of the land • Worker & Social • New Planting (if any) • Continuous Improvement

DSS Estate Representative Principle 1 (Indicator 1.1.1; 1.2.1) Principle 2 (Indicator 2.2.3 and 2.3.1 to 2.3.2) Principle 6 (Indicator 6.1.1 to 6.1.2; 6.2.1 to 6.2.3; 6.3.1; 6.4.1 to 6.4.3; 6.5.1 to 6.5.3; 6.6.1 to 6.6.2; 6.7.1; 6.8.1 to 6.8.2; 6.9.1 to 6.9.2; 6.10.1 to 6.10.4; 6.11.1) Principle 7 (Indicator 7.1.1 to 7.1.3; 7.5.1; 7.6.1 to 7.6.6) Principle 8

12.30 - 13.30 Break and Lunch

13.30 – 17.00

Continue previous schedule All Auditor

Wednesday, 11 November 2015; Mesuji Sub District O ffice

09.00-12.00 Stakeholder Consultation

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dated Activities Auditor Auditee Keterangan

12.00-13.00 Break & Lunch

14.30-18.00 Inti Permata Bunda Dua

estate

Checking document relate :

RSPO - Partial certification, timebound

plan and NPP (if any) - Transparancy & Ethical con-

duct

- Compliance with laws and regulations

- Land conflict & use of the land

- Worker & Social Issues - Continual improvement

DSS

Respective manager RSPO

Principle 1 (Indicator 1.1.1; 1.2.1) Principle 2 (Indicator 2.2.3 and 2.3.1 to 2.3.2) Principle 6 (Indicator 6.1.1 to 6.1.2; 6.2.1 to 6.2.3; 6.3.1; 6.4.1 to 6.4.3; 6.5.1 to 6.5.3; 6.6.1 to 6.6.2; 6.7.1; 6.8.1 to 6.8.2; 6.9.1 to 6.9.2; 6.10.1 to 6.10.4; 6.11.1) Principle 7 (Indicator 7.1.1 to 7.1.3; 7.5.1; 7.6.1 to 7.6.6)

Principle 8

NPP RSPO certification systrem 4.2.4

14.30-18.00 Inti Permata Bunda Dua

estate

Checking documents, relate : • Operating procedure &

agrochemical

• OSH • Waste

• Training • Continuous Improvement

SA Respectve manager Principle 4 (Indicator 4.1.1 to 4.1.3; 4.6.1 to 4.6.10; 4.7.1 to 4.7.6) Principle 5 (Indicator 5.1.1 to 5.1.3; 5.3.1 to 5.3.2) Principle 7 (Indicator 7.1.1 to 7.1.3) Principle 8

14.30-18.00 Inti Permata Bunda Dua

estate

Checking document relate :

RSPO

• Compliance with laws and regula-tions

• Best Agriculture practice

• Environment issue

• Pollution and Emission • Zero Burning

• Emision and pollution

• Continual Improvement

NMA Rsepective manager RSPO Principle 2 Criteria : 2,1 Principle 4 (Indicator 4.2.1 to 4.2.3; 4.3.1 to 4.3.4; 4.5.1 to 4.5.3; ) Principle 5 (Indicator 5.6.1 to 5.6.3) Principle 7 (Indicator 7.2.1 to 7.2.2; 7.4.2 to 7.4.3 ) Principle 8

Thursday, 12 November 2015 ; Inti Permata Bunda Dua Estate -

08.00 - 12.30

Verification to field, relate :

• Compliance with laws and regula-tions

Legal land • Management plan & replanting

plan (if any)

• Maintain the quality and availability of surface and ground water

• Training • HCV

• Efficiency of energy

• Use of fire • New Planting (if any)

• Continuous Improvement

MK Estate Representative Principle 2 (Indicator 2.1.1 to 2.1.4 and 2.2.1 to 2.2.2) Principle 3 (Indicator 3.1.1 to 3.1.2) Principle 4 (indicator 4.4.1 to 4.4.2; 4.8.1 to 4.8.2) Principle 5 (Indicator 5.2.1 to 5.2.6; 5.4.1 to 5.4.2; 5.5.1) Principle 7 (Indicator 7.3.1 to 7.3.2; 7.4.1; 7.7.1 to 7.7.3) Principle 8

10.30 - 12.30 Verification to field, relate : NML Estate Representative

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South Sumatera indonesia

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dated Activities Auditor Auditee Keterangan

• Best practices • Pollution and emissions

• New Planting (if any) • Continuous Improvement

Principle 4 (Indicator 4.2.1 to 4.2.3; 4.3.1 to 4.3.4; 4.5.1 to 4.5.3; ) Principle 5 (Indicator 5.6.1 to 5.6.3) Principle 7 (Indicator 7.2.1 to 7.2.2; 7.4.2 to 7.4.3 ) Principle 8

10.30 - 12.30

Verification to field, relate : • Operating procedure &

agrochemical

• OSH • Environmental

• Waste • New Planting (if any)

• Continuous Improvement

SA Estate Representative Principle 4 (Indicator 4.1.1 to 4.1.3; 4.6.1 to 4.6.10; 4.7.1 to 4.7.6) Principle 5 (Indicator 5.1.1 to 5.1.3; 5.3.1 to 5.3.2) Principle 7 (Indicator 7.1.1 to 7.1.3) Principle 8

10.30 - 12.30

Verification to field, relate : • Transparancy • Land conflict & use of the land • Worker & Social • New Planting (if any) • Continuous Improvement

DSS Estate Representative Principle 1 (Indicator 1.1.1; 1.2.1) Principle 2 (Indicator 2.2.3 and 2.3.1 to 2.3.2) Principle 6 (Indicator 6.1.1 to 6.1.2; 6.2.1 to 6.2.3; 6.3.1; 6.4.1 to 6.4.3; 6.5.1 to 6.5.3; 6.6.1 to 6.6.2; 6.7.1; 6.8.1 to 6.8.2; 6.9.1 to 6.9.2; 6.10.1 to 6.10.4; 6.11.1) Principle 7 (Indicator 7.1.1 to 7.1.3; 7.5.1; 7.6.1 to 7.6.6) Principle 8

12.30 - 13.30 Break and Lunch

13.30 – 17.00

Continue previous schedule All Auditor

FUNDY will back to Palembang earlier

Friday, November 13, 2015; Sumber Sawit palm Oil M ill 08.00-14.00 Mill

Verification document & field, relate : • Effluent

• Pollution and emissions • Continuous Improvement

NML Mill Representative Principle 4 (Indicator 4.4.3) Principle 5 (Indicator 5.6.1 to 5.6.3) Principle 8

08.00 - 14.00 Mill

Verification document & field, relate : • Operating procedure

• OSH • Environmental

• Waste • Continuous Improvement

SA Mill Representative Principle 4 (Indicator 4.1.1 to 4.1.3; and 4.7.1 to 4.7.6) Principle 5 (Indicator 5.1.1 to 5.1.3 and 5.3.1 to 5.3.2) Principle 8

08.00-14.00 Mill

Verification document & field, relate : • Transparancy • Worker & Social • Continuous Improvement

DSS Mill Representative Principle 1 (Indicator 1.1.1; 1.2.1) Principle 6 (Indicator 6.1.1 to 6.1.2; 6.2.1 to 6.2.3; 6.3.1; 6.5.1 to 6.5.3; 6.6.1 to 6.6.2; 6.7.1; 6.8.1 to 6.8.2; 6.9.1 to 6.9.2; 6.10.1 to 6.10.4; 6.11.1) Principle 8

14.00-15.00 Preparation for closing meeting

16.00-17.00 Closing meeting

17.30 End od Certification audit

18.00-22.00 Traveling to Palembang

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South Sumatera indonesia

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dated Activities Auditor Auditee Keterangan

November 14, 2015

09.30 Flight to Jakarta

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South Sumatera indonesia

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Appendix 3: List of Abbreviations AMDAL Analisis Dampak Lingkungan & Sosial

(Social & Environmental Impacts Assessment) CPO Crude Palm Oil EIA Environmental Impact Assessment ERTs Endangered, Rare & Threatened species ESH Environmental Safety & Health FFB Fresh Fruit Bunches EFB Empty Fruit Bunches GTA Gunung Tua Abadi HCV High Conservation Value IPM Integrated Pest Management IPBD Inti Permata Bunda Dua LTA Lost Time Accident MSDS Material Safety Data Sheets NGO Non-Government Organization OSH Occupational Safety & Health PKO Palm Kernel Oil POME Palm Oil Mill Effluent PPE Personal Protective Equipment RKL Rencana Pengelolaan Lingkungan (Environmental Management Plan) RPL Rencana Pemantauan Lingkungan (Environmental Monitoring Plan) SIA Social Impact Assessment SOP Standard Operating Procedure UKL Upaya Pengelolaan Lingkungan (Environmental Management Efforts) UPL Upaya Pengelolaan Lingkungan (Environmental Management Efforts)

Appendix 4: List of Stakeholders Interviewed and Co ntacted (attached on the report)

No. Name of Stakeholder

Institution / Position Remarks

Stakeholders Interviewed during Public Consultation Meeting 1. Edi Purwanto Head of Villager Balian 2. Winarto KUD UPTD 3. M. Sudiarto Spd KUD UPTD 4. Muslim Man power and transmigration officer 5. Mahmud nate Head of Village Pagar Desa 6. Rusmita Dabek Makmur Villager 7. Jalaludi Ahmad Disnaker Ogan Komering Ilir 8. Ahmad Fuad BPPM 9. Ragian fahmi Forestry Officer 10. Husen Nawawi Environment Body Officer 11. Hilwen BPN Officer 12. A.Rosidan Dinas Perkebunan (Plantation

Officer)

13. Jerry Hama Bappeda Ogan Komering Ilir 14. Gede Land Use Right Autority 15. Dedi Asmadi Dabek Makmur Villager 16. Ibnu Hajar Workers Union Representative 17. H. Rozali Dabek Makmur villager 18. Taufik Dabek Makmur Villager 19. Abu Hasan Dabek Makmur Head of Village 20. Winarno Dabek Makmur villager 21. Wedianto Police Officer Ogan Komering Ilir

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South Sumatera indonesia

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22. Sulistiyanto IPBD 23. Herson Situmorang Sumber Sawit estate 24. Nico Sihombing Sumber Sawit Mill 25. Mika Asri Salim Conservation Staff 26. Zoirokis Sustainibility 27. Amrinsyara Mill Sumber Sawit 28. Dwi Asmono R&D Director 29. Yusi Rosalina Sustainibility 30. M. Lukman Sustainibility 31. Mulyadi Estate Assistant 32. Suyatman Sumber sawit estate asistant 33. Hasutungan S Sumber Sawit Estate 34. Ali Amin Estate asistant 35. Sahirman Estate Assistant 36. Jenny Verawati S Estate Asistant 37. Ismail Mill Asistant 38. M. Palar Adminsitration Estate 39. Ricky Erwanto GTA Worker 40. Irwansyah GTA Worker 41. Achmad Amanurah

Salman Sustainibility

42. Anita Widiawati Sustainibility 43. Yulia Puspitaningrum IPBD Worker 44. Juan Maraga IPBD Worker 45. Etc.

Appendix 5: Observations and Opportunities for Impr ovement

No. Observations / Opportunities for Improvement Criteria 1 Company has not established mechanism to respond request of information ver-

bally, e.g. information about job vacancy from Balian, Dabek Mamur and Em-bacang village, and request of bridge reconstruction in Dabek Makmur village.

1.1.2

2 The Company immediately conducts an inventory of boundary stones where the pillar are still there and are buried to know the exact figure, to consider program to repairs, maintenance. Because based on checklist of HGU maintenance August-September, 2015 stated that the pillar no. No. 19 was buried, but it was verified the pillars still there, it is look like the data presented in the form pillar maintanence is not valid).

2.2.2

3 Some procedures has not finalized still in draft, I,e,

a. P-SAG-RO-SUS-07 Rev 02 dated Ocotber 30, 2015

b. WI-SAG-KBN-PML-0206 Rev 0 dated March 02, 2015

c. P-SAG-KBN-NKT-02 Rev 02 dated December 01, 2015

d. P-SAG-RO-CAS-08 dated November 01, 2015

e. P-SAG-PKS-PRS-14 Rev 01 tanggal 1 Oktober 2015

4.1.1

4 Company should apply fertilizer program as recommended, either dosage or time schedule. It was found program for Borat application in block 110 Divisi 2, was not consistent with the required time i.e. May 2015.

4.2.3

5 a. Company should evaluate subsiden point to be more acrurate bot in Sumber sawit and IPBD estate.

b. IPBD estate should reinstall water level measurement that was lost due to washing trench

c. Company should install proper trench at subsiden monitoring point to ensure

4.3.4

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South Sumatera indonesia

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that subsiden can be monitor naturally.

6 Energency and preparedness training should be conducted for other conditions such as chemical material spillage, riot, eartquick, etc.

4.7.5

7 Company should include procedure to accident investigation to prevent re-occurrence.

4.7.5

8 Harvesting procedure were not implemented consistenly e.g. for pruning ac-tiveities.

4.1.2

9 Gas cylinder should be placed securely and chained to keep from falling. 4.7.2 10 Sump pit for hazardouse temporary storage in Sumber sawit estate should

not be connected with a ball valve that can be opened to drain the water. 5.3.3

11 TBS truck is not equipped with a safety net, safety triangle 4.7.3 12 Some driver for FFB transporter without driving license.. 2.1.1

13 The Company has GHG calculation procedures but have not using GHG cacula-

tion version RSPO into existing procedures.

4.1.1

14 There should be a special mechanism to ensure that workers and people who are entering high risk area are using proper PPE.

4.7.1

15 The implementation of employee recruitment procedure No. P_SAG-ADM-KTU-04 i.e. employee induction for casual workers (FM-SAG-ADM-KTU-04002) has to be fulfill, especially to promote the workers from casual worker into permanent.

6.5.2

16 Procedure IMS PT-SAG-RO-CAS-08 on Communication, participation and consulta-tion have not been covered mechanism to address grievances of the local communi-ty, there are complaints from villagers Dapuk Makmur, such as: - Job vacancy in the mill for villager from Dabuk Makmur - On hold CSR program - Plasma land is not compliance with head of Ogan Komering Ilir decree letter No.

316/KEP/D.Perke/2008. - Bridge construction for Dabuk Makmur village

6.3.2

17 Progress of lands occupation in all company’s HGU area (repated to NCR No.20150 04 of 18) will be monitored regularly.

2.2.3