Use of fire for waste disposal and for preparing land for replanting is avoided except

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 73of 164 Evidence of energy efficiency monitoring results compared to previous year data is not yet available. As specified in the objective document and environmental program PPG MR 001 SOP- Identification Evaluation of Environmental Occupational Aspects for the period of 2016-2017. Monitoring results in the Resource Efficiency Report for the period June 2016 - June 2017 with the following usage: - Fossil fuels diesel = 247834 liters 210440 tonnes TBS = 1.18 liters ton FFB - Renewable fuels shell and fiber = 37439 ton 210440 tonnes TBS = 0.18 ton ton TBS - Electricity coming from generator and turbine = 1776846 kWh 210440 ton TBS = 8.44 kWh ton TBS Energy efficiency has been established in all operations in the company especially in the mill. But the company has not conducted any studies related to the use of biogas from POME. Conclusion : Minor Nonconformity NCR No.2

5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except

in specific situations, as identified in the ASEAN guidelines or other regional best practice. 5.5.1 There shall be no land preparation by burning, other than in specific situations as identified in the ‘Guidelines for the Implementation of the ASEAN Policy on Zero Burning’

2003, or comparable guidelines in other regions. Major

The Company has a Zero Burning Policies that contain as follows: 1. Prohibition from using fire for land clearing, new planting or replanting 2. Prohibition use of unauthorized fires in all areas and corporate environments. All waste, household office waste, medical waste and the like will be managed and destroyed according to the rules and requirements In addition, the company has SOP Land Clearing No. PPG GMO ASD 11 SOP. The SOP aims to ensure that land clearing is done not by burning. The policies and SOPs are well executed, one of which can be seen from the management of household waste from the employee housing. Because the waste should not be burned then the garbage that has been collected separated between the organic and inorganic to be inserted into the garbage pit that has been determined and dumped by the ground if it is full. The company made the Fire Free Village program for the villages around the plantation PT. Poliplant Sejahtera. The forms of activities are as follows: 1. Training of forest and land fire prevention by working together with forestry service. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 74of 164 2. Development of Community Care Group Command Post in 28 Villages 3. Procurement of Damkar equipment aid. Conclusion : Conform 5.5.2 Where fire has been used for preparing land for replanting, there shall be evidence of prior approval of the controlled burning as specified in ‘Guidelines for the Implementation of the ASEAN Policy on Zero Burning’ 2003, or comparable guidelines in other regions. Minor Based on management plan, PT Poliplant Sejahtera will do replanting in 2020, so that in the year 2017 there is no replanting activities Conclusion : Confor 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented, and monitored.

5.6.1 An assessment of all polluting activities shall be conducted, including gaseous

emissions, particulatesoot emissions and effluent see Criterion 4.4 Major SOP of GHG inventory and mitigation or GHG calculation PAS PPG EHS 40 SOP rev. 1 dated September 1, 2016 that has inventoried GHG emission sources and the impact of GHG-producing activities has been available, namely: - Operational of Estate utilization of the estate, the use of pesticides and diesel for the operation of the estate - Operational of mill use of solar for energy generation, liquid waste POME, - Transportation of products transporting FFB from plantation to mill and transporting CPO from mill to bulking station Conclusion : Conform

5.6.2 An assessment of all polluting activities shall be conducted, including gaseous

emissions, particulatesoot emissions and effluent see Criterion 4.4. Major The GHG inventory and mitigation documents for estate and mill rev. 1 per July 2017 with the result of pollutant sources available as follows: Estate : - Land clearing land contain organic material 60, use of diesel, conservation area, land fires and agrochemical use - Seedlings use of diesel, land fires, agrochemical use SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 75of 164 - Planting use of diesel, land fires, conservation areas and the use of agrochemicals and fertilizers - Producing Plants and Non-Produce Plants use of diesel, land fires and use of agrochemicals and fertilizers - Application of palm solid waste use of diesel and land fires - Use of diesel engines use of diesel and land fires - Land application use of LA and land fires POM: - Operational POM use of diesel, POME, shell utilization, fiber and EFB and fire at mill - Land application POME and fire at mill The GHG inventory and mitigation documents have established plans to reduce GHG emissions and pollutants such as: - Create a piezometer to monitor groundwater level - Implement water management - Do maintenance, preuse inspection unit of vehicle and heavy equipment - Identify HCV areas - Set zero burning policy - Conduct forest and land fire control training - Apply appropriate doses of pesticides - No chemical applications in the buffer zone - Manage pesticide waste - Conduct land opening according to the procedure - Conduct fertilizer dosage calibration - Monitor vehicle emissions - Monitor the use of LA - Reforestation around the mill area - Maximize the operation of steam turbines - Monitor the generator of emissions, vehicles and heavy equipment SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 76of 164 - Perform regular maintenance of the machine The GHG inventory and mitigation documents have covered objectives, targets, implementation schedules, implementers and supervisors of mitigation action activities. Mitigation plans have been implemented and evaluated regularly in management review meetings. SOP Effluent Treatment Plant LAB PSA SHMM 06 SOP rev. 0 dated September 1, which has regulated WWTP design parameters, identification of waste disposal sources, waste pool design, waste pool capacity, waste pool function, waste treatment operations, operational procedures, sampling and analysis activities, waste recycle program and reporting method has been available. Siriham Mill waste pool consists of several ponds as follows: - 2 cooling pond - 4 anaerobic ponds - 3 sedimentation pond - 1 emergency pond - 1 CaCo 3 pond Conclusion : Conform

5.6.3 A monitoring system shall be in place, with regular reporting on progress for these

significant pollutants and emissions from estate and mill operations, using appropriate tools. Minor The organization has established matrix of monitoring and environmental measurement in the PPG MR 007 F.01 rev form. 3 as of June 2017. The matrix has established related monitoring and measurement parameters, regulatory reference, measurement location, monitoring measurement coordinates, monitoring frequency, execution time, proof of compliance, testing laboratory and responsible personnel. Environmental aspect or parameters monitored include quality of liquid waste for land application, liquid waste oil trap, drinking water RO, domestic water, groundwater, soil physics and chemistry, ambient of air, generator and boiler emissions, Surface river water, biota water, clean water, noise and emissions of vehicle exhaust. During certification audit, it was raised minor finding as follows : Organization has calculated greenhouse gas using RSPO calculator. But, It still had error when inputing data i.e. FFB receipt data about 68.142.540 mt, using of urea about 220.293 mt During surveillance audit, the company has conducted corrective action as follows : The Company has performed GHG calculation for 2016 using RSPO GHG Calculator with the following results: SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 77of 164 Estate: - Land conversion = 75152.37 tCO 2 e - Crop sequestration = -35522.63 tCO 2 e - N 2 O emissions = 3373.39 tCO 2 e - Fuel consumption = 307.82 tCO 2 e - Sequestration in conservation area = -0.18 tCO 2 e Mill: - POME = 8530.13 tCO 2 e - Fuel consumtion = 641.13 tCO 2 e - Export of excess electricity = -1.75 tCO 2 e - Sale of Mill = -2515.37 tCO 2 e Therefore, the finding can be closed. Conclusion: Conform 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