Aspects of plantation and mill management, including replanting, that have

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 48of 105 PPE use training. From the results of field interviews in the afdeling D of sprayers it was found that they had received training in spraying procedures. For workers in the mill, the training has been implemented, such as FFB grading methods on 14 and 15 February 2014, loading ramp and sterilizer on 27 March 2014. For the plasma the training has been implemented i.e. fertilization on 17 April empty fruit bunches application and FFB grading on 25 August 2014. Compliance status : Conform 5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

5.1 Aspects of plantation and mill management, including replanting, that have

environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate Environmental reports held by company are in the form of Environmental Evaluation Documents DELH. DELH is the document for those Oil Palm Plantations and Oil Palm Processing Mills that do not have an environmental document before the stipulation of Law No. 322009 on Environmental Protection and Management and yet already has a business license. DELH of PT. BBB has been approved by Muaro Jambi Regent through Decree of the Head of Environment Office Number 112010 on Environmental Evaluation Documents for Oil Palm Estate Core and Plasma and Oil Palm Processing Mill covering an area of ± 10,500 hectares in Sekernan District, Muaro Jambi Regency, by PT Brahma Binabakti dated 27 December 2010. The installed capacity of oil palm processing mill operation is 60 tons FFBhour. DELH and RKL-RPL were prepared by CV. Sangga Buana Lestari located in Jambi with the implementation in 2010. Environmental management reporting is carried out every 6 months as recorded in the RKLRPL report. For the RKLRPL report of Semester I 2014, environmental management carried out includes: - Liquid waste quality monitoring. The test results still comply with the quality standard requirements. - Hazardous waste management monitoring - Solid waste monitoring: records of the use of shells, fiber, and empty fruit bunches SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 49of 105 - Air quality monitoring: test results of genset emissions and ambient air - Noise monitoring: noise test results still meet the quality standard - Water quality monitoring: test results of river water quality still meets the quality standard - Monitoring of social, economic, and cultural conditions in the neighborhood around the company site: records of CSR realization Company needs to ensure the measurement of mobile source emission. This has been issued as an observation no. 5 Evidence of RKLRPL report document available is as follows: 1. Minutes of liquid waste report for quarter II 2014 to the Ministry of Environment of Muaro Jambi Regency, BLHD of Jambi Province, dated 17 July 2014. 2. Minutes of hazardous waste report for quarter II 2014 to the Ministry of Environment of Muaro Jambi Regency, BLHD of Jambi Province, dated 17 July 2014. 3. Minutes of RKLRPL report for Semester I 2014 to the Ministry of Environment of Muaro Jambi Regency, BLHD of Jambi Province, dated 17 July 2014, and the Ministry of Environment on 21 July 2014. Compliance status : Observation no. 5 5.2 The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations Company has High Conservation Value Assessment SOP with document number TAPSOP120- HCV001 dated 23 January 2013. Company has made the identification of the Existence of High Conservation Value Areas starting on 11-16 February 2013, chaired by Ahmad Faisal Siregar, S.Hut, MSi and has been reviewed by Peer Review Dr. Ir. Nyoto Santoso, M.Si who is a lecturer in the Faculty of Forestry of Bogor Agricultural Institute. Both the Team Chairman and Peer Review with respect to the identification of the Existence of High Conservation Value Areas have been approved by the RSPO. Based on the report of the identification of High Conservation Value there is only NKT 4.1 found in the company site i.e. the border of Suak Putat River and the border of Mendahara River tributary covering an area of 30.66 hectares. Company also has a map associated with areas with SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 50of 105 high conservation value at 1: 70,000 scales. From the results of report of the identification of high conservation value there are recommendations, such as company should conduct dissemination and establish a buffer zone by boundary management. Company has conducted the buffer zone management and monitoring. Company issued a Standing Instruction Number: 048SI-DIRVIII2014 dated 7 August 2014 regarding the implementation of remediationrehabilitation program to improve the value and function of HCV areas. The Instruction stated that should not be conducted chemist treatment for non-producing plants by installing yellow painted pegs of 1.5 meter high and for producing plants by giving a yellow circular sign of 20 meter wide and installing notice boards. Company has developed High Value Conservation Area management and monitoring plans of June 2013 - June 2018. Some of these plans have been realized such as the installation of sign boards in the protection area in the border of Suak Putat River and in the border of Mendahara tributary in August 2013 and in November 2013 in the portal of Afdeling B and Afdeling A of PT. Brahma BinaBakti The socialization plan of river border conservation SOP has been conducted for field staff and employees. For field staff it was conducted on 15 February 2013 and for the employees of afdeling it was performed on 15 November 2013 and on 30 August 2014. Company also conducted stakeholder consultations and socialization of High Conservation Value to Suko Awin Jaya Village community on 26 August 2014, Putat Suak Village community on 4 September 2014, Tanjung Lanjut Village community on 5 September 2014, Bukit Baling Village community on 5 September 2014. Evidence of socialization is attendance list and photos on the activities. During a visit to the border of Putat Suak River in the afdeling A Block 5, the evidence of palm tree marking was found in one part of the river in accordance with the standard operating procedure. The other part next to it there is no mark found on palm tree because the plant belongs to the plasma area. It is suggested that high conservation value map to be completed with marking explanation about core area and plasma area. It is also suggested to conduct dissemination to the plasma regarding the marking of palm trees around the border of Suak Putat River. Company has a list of fauna in August 2014,such as: No Local Name Scientific Name IUCN CITES PP Mammals SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 51of 105 1. Squirrel Callosciurus sp LC TD 2. Wild boar Sus scrofa LC TD Aves 1. Merbah cerukcuk Pycnonotus goiavier LC TD 2. Cinenen belukar Orthotomus atrogularis LC TD 3. Pekaka Emas Pelargopsis capensis LC TD 4. Dederuk Jawa Streptopelia bitorquata LC TD 5. Gereja erasia bird Passer montanus LC TD 6. Wiwik kelabu Cacomantis merulinus LC TD 7. Jungle crow Corvus enca LC TD 8. Perenjak Jawa Prinia familiaris LC TD 9. Cucak kutilang Pycnonotus aurigaster LC TD Herpetofauna 1. Lizard Eutropis multifasciata LC TD Company has listed the flora and fauna on August 2014, such as : No Local Name Scientific Name IUCN CITES PP 1. Durian Durio carinatus - TD 2. Jackfruit Artocarpus integra - TD 3. Areca Areca macrocalyx - TD 4. Rambutan Nephelium mutabile - TD 5. Rubber Hevea brasiliensis - TD SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 52of 105 From the report of HCV assessor, there is no rare, threatened or endangered species within the concession area. The area is closed to local community, local plantation and far from national park. Company has a HCV Department responsible for overseeing the HCV plans and activities. This is evidenced by the presence of certificates of Identification and Management of High Conservation Value training from Bioref of Bogor Agricultural Institute on 5-6 May 2014 under the name of Samsul Rijal, S.Hut and Risto Laksono, S.Hut. Compliance status : Observation no. 2 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner Company has made the identification of the sources of waste as recorded in the report of the Identification of Sources of Waste, Pollution, and Contamination in the Estate and the Mill of PT. BBB. Sources of waste from activities in the estate include domestic waste, hazardous waste used pesticide package, used lamps mercury, and medical waste. Sources of waste from activities in the mill include solid waste empty fruit bunches, fiber, shells, POME liquid waste, and hazardous waste used rags, used filters, used accu, and used oil. Waste re use has been implemented by company i.e. the utilization of fiber shell for boiler fuels, and utilization of empty fruit bunch for organic fertilizer Company has a procedure of Waste Management and Land Application NO. POM-SOP12, dated 1 June 2013. The procedure already covers management at WWTP and Land Applications. Procedures for controlling air pollution and waste water are already contained in the Environmental Management Program No. POM-SOP21, dated 1 June 2012. This procedure already covers measurement, the parameters used, and reporting obligations. Waste generated by the mill is not discharged into a water body but utilized as Land Applications. Company has a permit of utilization of liquid waste as land application with Decree of the Regent of Muaro Jambi Number 2992011 concerning Permit of Utilization of Mill Waste Water on the land of PT Brahma Binabakti oil palm plantation dated 12 July 2011 with 5 years validity period and 300 ha application area. There is a measurement of the quality standard of Land Application in the land area which is conducted once a month by the environmental laboratory of the Regional Environmental Agency of the Jambi Provincial Government. The results of measurement is meet with the Environmental Quality Standard of BOD of 5000 and pH of 6 – 9 refers to Decree of the State Minister of Environment 2829 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 53of 105 2003 for monthly measurements. The records of liquid waste quality management are in the form of Report of the Result of Test which is carried out once a month. The tests are conducted in the testing laboratory by the BLHD of Jambi Province. The test parameters refer to Decree of the Minster of Environment 2829 of 2003 as follows: BOD, COD, pH, oil and grease, Pb, Cu, Cd and Zn. Waste water sampling is conducted in pond 3 facultative pond 1. The test was lastly conducted in June 2014 and the results meet the quality standard for land application waste. The calculation of liquid waste volume rate has been made based on the mass balance and records are taken for the volume of waste discharged to the estate every day. For land application, there are monitoring activities in the estate E.5.1 at well 1, in the estate E.5.5 at well 2, in the estate E.6.3 at well 3, in the estate E.5.2 resident at well 1 and in the estate E.5.4 resident at well 2. There are the results of measurement in monitoring well and control well which refer to Regulation of Governor No. 202007. The results of measurement have not exceeded the BML of pH 6 – 9, ammonia 0.5, cadmium 0.005, nitrate, 10, cuprum 1, lead 0.05, and Zinc 16. Measurements are conducted once every 3 months. Company reports to BLHD of Jambi Provincial Government every three months as stated in the liquid waste quarterly report. BLHD is currently renovating its laboratory so that data of sample test of June to August 2014 has not yet be able to be produced. Testing of boiler air emissions is conducted in the semester I 2014. For boiler 1 and 2 PT. BBB still meets the quality standard based on Regulation of the Minister of Environment No. 72007. The tests were conducted by the Environmental Lab. of BLHD of Jambi Province. Air emission monitoring of generator 2 Semester I 2014 still meets the quality standard based on Per Men LH 21 2008. Noise monitoring of semester I of 2014 still meets the quality standard based on Per Men LH 48 1996. Ambient air monitoring in the mill area and employee housing of Semester I 2014 still meets the quality standard based on PP RI 41 1999. The company has the SOP SOP-POM21, 1 June 2012 for Environmental Management Program. In the procedures hazardous waste generated is already identified. Company has established K3L procedures in Chapter VI Environment, Subchapter VI Hazardous Waste Handling. The procedure already establishes the method of hazardous waste storage, placement of label and symbol, storage SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 54of 105 area and reporting. Hazardous wastes identified in the mill are used oil, used accu, and used filters, contaminated jerricans and other contaminated materials. Hazardous waste identified in the estate is used pesticide package, used lamps mercury, and medical waste. Hazardous wastes generated are stored in the licensed hazardous waste temporary storage TPS LB3. Medical wastes in the location of the clinic are already placed in a special bin and their destruction is carried out in collaboration with the local hospital of RSUD Abdul Manaf. Delivery of medical waste was lastly performed on 2 July 2014, minutes of medical waste delivery is already available. The RSUD Abdul Manaf has submitted incinerator permit recommendation and currently in the stage of arrangement by BLH of Jambi Municipality, with a recommendation application letter number 445025RSUD-HAMVIII2014, dated 30 August 2014. Company needs to ensure that the incinerator of RSUD Abdul Manaf already has a license from the Ministry of Environment. This has been issue as an observation no. 6 Company has waste balance documents in hard copy and also writen on waste balance board inside the TPS LB3. Company already has a Hazardous Waste Temporary Storage Permit of Decree of the Regent of Muaro Jambi Number 3312010 concerning Hazardous Waste Temporary Storage to PT Brahma Binabakti dated 11 August 2010. The license is valid for 5 years. The company has the license to store the hazardous waste at maximum for 90 days The company is contracted PT Primanru Jaya to transport and collect hazardous waste. PT Primanru already has license from the State Minister of Environment No. 2342011 on Hazardous Waste Collection Permit. The license covers as listed the transportation and collection of used oilused lube oil, slop oil, sluge oil, used solvent, sludge of paint residue, sludge containing metals aluminum, tin, and iron, contaminated scraps, zinc dross, hazardous waste contaminated gloves, hazardous waste contaminated masks, filter bag, hazardous waste contaminated packages, and used accu from Sumatera, the Riau Islands, Java, Kalimantan, Sulawesi, Papua, Bali, NTB, and NTT. The TPS LB3 is in compliance with the standard requirements in terms of the building and already has hazardous waste signs in accordance with regulatory requirements. PT Primanru also has a Supervisory card from the Ministry of Transportation the Directorate General of Land Transportation concerning Supervisory Card of Special Cargo Transportation operating permit to transport dangerous goods, number: SK.2840A.J. 309DJPD2013360030296BB-0010. PT Prinmaru has had a partnership with waste utilization company, such as, PT Holcim Indonesia Tbk. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 55of 105 PT PPLI, Bumi Benteng Lestari, Non Ferindo Utama, and Andhika Makmur Persada, which already have a waste utilization permit from the Ministry of Environment. Company performs quarterly reporting of LB3 TPS covering waste balance Hazardous and Toxic Material Balance Sheets. It has a monthly hazardous waste balance sheet. There are hazardous waste manifest and hazardous waste document. There are minutes of hazardous waste handover from PT Brahma Binabhakti to PT Prinmaru. Company has provided a dike to contain spill in the area of diesel fuel storage tanks with capacity in excess of 110. Company already uses fiber as boiler fuel to generate electrical energy instead of using a diesel-fueled generator. Genset is used as prime movers of palm oil mill until the boiler is ready to provide steam to the turbine to produce electrical energy. Company conducts environmental measurements of air, except for the measurement of emission of mobile sources, such as from dump trucks, operational vehicles, fruit trucks, loaders, and so on.his has been raised as an observation no. 5 at criteria 5.1 above. Company has a TPA Garbage Final Dump Site which is already sorting garbage into organic and non organic ones. Company has implemented it adequately. Non-organic garbage is packed in sacks. There is cooperation with a public institution IPB3 that carries non organic waste plastic, glass bottles, and the like. Organic waste containing paper, grass, foliage, once full is dumped. Company has provided organic and non organic waste bins. Garbage bins provided in residential area block H is blue in color with organic and non organic labels but its implementation is still not yet consistent because the garbage is mixed of plastic, leftovers or leaves. This has been raised as an observation no. 6 Compliance status : Observation no. 6 5.4 Efficiency of energy use and use of renewable energy is maximized Company already uses fiber as boiler fuels to generate electrical energy instead of using a diesel- fueled generator. Genset is used as prime movers of palm oil mill until the boiler is ready to provide steam to the turbine to produce electrical energy. Company also uses smooth kernel shell mixed with fiber as boiler fuels. Company sells rough kernel shell to outside partiesthird parties. Fiber and shell application has been recorded in the form of shell and fiber consumption report. Data of kkalton CPO for 2013 is 25.756.325,46 kkalton CPO. Records of monitoring of fossil fuels use are in the form of SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 56of 105 fossil fuel consumption report. Compliance status : Conform 5.5 Use of Fire for Waste Disposal and for preparing land for replanting is avoided except in specific situation, as identified in the ASEAN guidelines or other regional best practice Company has set up zero burning policy for the opening of land as recorded in the Land Opening procedure and the Internal Memos Memo No.: MI-003MDSUSTXI2012, dated 12 November 2012. The organizational structure of Emergency Response and Preparedness Team TKTD of both the estate and the mill has been established, which was signed by the Estate Manager and the Senior Mill Manager. The structure of TKTD consists of: General Chairman of TKTD directly seated by the Unit Manager, Secretary, Chairmen of TKTD who are Adm Division, Workshop Division, and FieldMill Division. Each respectivelly consists of: Emergency Mitigation Task Force, Communication, Rescue, Security, Paramedic, Investigation, and Remediation and Rehabilitation. Company has defined their respective job description. The training already given to TKTD, such as: Estate Unit: 1 first aid, dated 162013 for Members of TKTD paramedics and some afdeling representative staff, delivered by company doctor. 2. Training in the use of light extinguishers APAR, dated 25092013 followed by fire handling simulation in Afd. B. Company already provides facilities and infrastructure for fire mitigation for both the Estate and the Mill. This can be illustrated as follows: For the Estate, company provides APAR light fire extinguishers which are placed throughout the estate, each 1 unit of APAR at warehouse, workshop, central office and afdeling office. The estate already has warning signs “Beware of Fire” as a warning of a fire in the forest. The company and group have a monitoring system of oil palm plantation land hot spot which is updated daily. Hot spot sources are from NASA satellite early warning system, https:earthdata.nasa.govdatanear-real- time-datafirms. There are hardcopy monitoring sheet of fire point distribution in oil palm concession area. Group data hotspot is available per 9 September 2014 14.18 WIB There is company system to respond to dry month conditions in order to be alert of things that may SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 57of 105 lead to disadvantages for the company, for instance land fire. Company already performs routine inspection of emergency response equipment. In the estate there is Portable Fire Extinguisher Inspection Report which is also conducted on a monthly basis.The evidence is recorded on a Portable Fire Extinguisher Checklist card. Each hydrant box is provided with a card to record routine inspection results. All portable fire extinguishers have adequate pressure. Company performs fire monitoring and prevention efforts. The efforts such as make firebreaks on the perimeter of the estate bordering the community land, install fire-prone warning signs, install fire watchtower, conduct fire prevention training, and perform a simulation of facing fire condition, in both the Mill and the Estate. Maintain emergency response equipment such as: portable fire extinguisher, hydrant, diesel pump, water tank truck and portable pump. Garbage and domestic waste management is already done without burning. However, in a residential area in block H, for instance, warning sign board regarding prohibition of garbage burning was not provided. It has been raised as an observation no. 7 Mitigation of land fires is regulated in procedure TAPSOP120-SHE0001 chapter III. 8. Company conducted estate land fire handling simulation on 5 September 2014 on the site of Afdeling BBlok B11 with scenario of accidentally disposal of a cigarette butt in the site which results in fire point. Documentation related to the simulation is photos, emergency response team TKTD personnel, equipment and evaluation. Company has submitted a report on the results of monitoring and prevention of land fire to the local government. Land fire monitoring is carried out through land patrols and land patrol route has been set and the results of fire patrolmonitoring have been recorded. The inspection of fire extinguishers in the estate has been done on a monthly basis. There are 2 units of fire extinguishers, hoes, shovels, pumps, harvester poles, and robin pumps. Compliance status : Observation no 7 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented, and monitored. Company has established Greenhouse Gas Emission Reduction procedures No. TAPSOP120- HCV004 which contains the identification and reduction of greenhouse gases. Identification of sources of greenhouse gas emissions was conducted on 2-4 April 2014 by HCV Department. In the report potential sources have been identified i.e. FFB transportation from the SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 58of 105 estate to the mill diesel fuel, fertilizer application, pesticide application, diesel fuel use for genset and POMEWWTP. CO 2 emissions in 2013 are calculated to be 1.534,73 Kg of CO per Hayear. CO2 emissions of 2014 are calculated later in 2015 period, because the calculation starts from January – December 2014. Company has a hard copy document of the identification and inventory of sources of greenhouse gas emission in PT Brahma Binabakti. The calculation is using a formulation sourced from ISCC 205 GHG Emission Calculation Methodolgy and GHG Audit. The results are fluctuative because the calculation is just for the past two years. There is an inventory of greenhouse gas emission mitigation effort in PT Brahma Binabakti Monitoring of the management of emission sources such as generator and boiler is done every 6 months. The results of air emission test of genset still meet the quality standard based on Per Men LH 212008 and the results of air emission test of boiler still meet the quality standard based on Per Men LH 72007. The results of ambient air test in residential and office areas still meet the quality standard of PP RI 411999. Liquid waste generated from FFB processing in the mill is directed to the WWTP and then used as a land application. The volume of liquid waste generated is recorded on a daily basis and tested internally on a daily basis and externally on a monthly basis. The record of greenhouse gas emission reduction effort is in the form of shell and fiber consumption report, empty bunches use report, engine maintenance record and water use record. Record of source emission trends such as diesel fuel use, fertilizer use, and pesticide use shows a falling trend. Diesel fuel use efficiency by using shell and fiber as fuel on boiler in August 2014 is not yet calculated. It is suggested to make a calculation of the efficiency of the greenhouse gas substitutes for comparison, such as the efficient of diesel fuel use for genset after use of fiber for boiler fuel to generate the electricity. This has been raised as an observation no. 8. Rough shell is sold to consumersthird parties. Reduction in the use of pesticide with the presence of beneficial plants turnera antigonon leptopus, SP. and owls for pest control. Reduction in the use of chemical fertilizers is carried out by using land aplication, empty bunches, and solid waste from mill processes. The application of empty fruit bunches shows the amount of tonnage applied to the core and plasma SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 59of 105 land that is written in the empty fruit bunches application performance. There is efficiency of using internal fuel against diesel fuel Company needs to make a conversion program from genset that uses diesel fuel to power generators without genset with emissions. This has been raised as an observation no 8 Reduction of mobile source emissions through vehicle maintenance and also can be found in KIR vehicle fitness test document, where the measurement of emission is one of the requirements for the extension of KIR of cargo trucks. For passenger vehicles, company has not made any exhaust gas emission measurement.This has been raised as an observation no 5 at criteria 5.1 Compliance status : Observation no. 8 6. RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS

6.1 Aspects of estate and mill management that have social impacts are identified in a