Religion Ethnic groups Origin

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 45 of 82 age of 17 years. At the time of the visit to the work areas, the auditors did not find children in the estate or other areas. Compliance status: Full Compliance 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited The Company has and already set the Nondiscriminatory Policy, which is part of the Company’s policies. The policy was signed by the President Director on 4 January 2008. The policy states that Tunas Baru Lampung Group is committed, prohibits discrimination and conduct that can lead to discrimination. The policy is shown in the form of equal opportunity for all employees and workers as stated in Article 10 of CLA concerning Employee Recruitment, where the requirements do not mention gender, ethnicity, or religion. Evidence of implementation is seen in the data of manpower composition which consists of a diversity of ethnic, religion, worker place of origin, and workers gender of male and female. It can be seen from the Company Report in October 2011. The following tables also show the number or percentage of workforce viewed from various aspects that show non-discrimination. Number of Workers based on Gender Business unit Employee Male Female Total PKS1 TBL 295 91.6 27 8,4 322 100 TBL estate 117 84,2 22 15,8 139 100 BSA estate NA NA NA Number of Workers by Religion, Ethnic Group, and Origin Aspect Business Unit PKS1 TBL TBL estate BSA estate

A. Religion

Moslem 310 96,3 119 85,6 NA Christian 8 2,4 14 10,1 NA HinduBudahothers 4 1,3 6 4,3 NA

B. Ethnic groups

Jawa 221 101 72,7 NA SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 46 of 82 68,6 Sunda 34 10,6 7 5,0 NA Batak 6 1,9 6 4,3 NA Others 61 18,9 25 18,0 NA

C. Origin

Local around village 292 90,7 25 18,0 NA Non-Local outside the surrounding villages 30 9,3 114 82,0 NA The above number is a combination of Permanent workers KT and Casual worker HL. The number of KT employees for PKS1 is 225 people 69.9, and HL employees is 97 people 30.1. As for the TBL Estate, the number of HT is 139 people 100. They all are KT, while the contractorousourcing there are 2 groups of about 120 people. They are outside the TBL Estate workers listed in Table above. Compliance status: Full Compliance 6.9 A policy to prevent sexual harassment and other forms of violence against women and to protect the reproductive rights is developed and applied The Company has written policies related to the prevention of sexual harassment and violence, which is part of the Company’s policies, i.e. the Sexual Harassment Policy section. It states that: sexual disorder is the destruction of work climate and not tolerated by the TBL Group communities. When audited, all locations of the Company has not proved to disseminate sexual harassment prevention policy. When interviewed, the workers in the harvesting and spraying areas felt that they never get a socialization for the last 3 years. This is established as a nonconformity see NCR. No. 44. With respect to reproductive rights, the Company has set policies in Article 25, paragraph 5 of the CBA on maternity leave, and Article 26 on pregnancy leave and menstruation. The implementation of reproductive rights policy is seen from the following evidence: - The granting of a break in the form of a Certificate of Ill Health from PT. TBL Clinic with a diagnosis of CH menstruation leave. Maternity leave is in the form of a Certificate from maternity hospital and submitted to the HRD. Record evidence for both is available. - The company provides instant foods, such as milk and eggs as food supplement for working SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 47 of 82 women who work as pesticide sprayers. - The company do not employ a pregnant woman at pesticide spraying work. - Female workers understand the reproductive rights policy as interviews with Ibu Soesi, at the PKS1 Office When audited, all companies did not have specific complaint mechanisms related to sexual harassment andor violations of womens rights. This is established as a nonconformity finding. Compliance status: Minor, see NCR no. 06 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses. FFB is supplied by the estates owned by the company and also from outsiders. Suppliers ofrom outsiders are paid in a timely manner and in tranparant way. Interviews with suppliers of services confirmed that they are fairly treated and paid promptly . Compliance status: Full Compliance 6.11 Growers and millers contribute to local sustainable development wherever appropriate Palm Oil estate and mill contribute to local development through the payment of taxes to the local government. The following is a company contribution in taxes: Business Unit 2010 in Rp 2011 in Rp PBB PPh Pasal 23 PPh Pasal 21 PBB PPh Pasal 23 PPh Pasal 21 PKS1 TBL 946.176 701.286.993 3.160.250 946.176 193.593.501 28.188.250 TBL estate 781.191.554 42.103.260 861.744.010 39.675.920 BSA estate 137.068.190 2.939.750 492.900 151.404.740 8.663.513 430.510 Total 919.205.920 704.226.743 45.756.410 1.014.094.926 202.257.014 68.294.680 Description: The PKS1 and TBL Estate land and building taxes are combined, but the payment is made 2 times according to the table above. Likewise the PPh-23 taxes are combined, but the payment is made once. Compliance status: Full compliance SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 48 of 82 7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS

7.1 A comprehensive and participatory independent social and environmental

impact assessment is undertaken prior to establing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management, and operations Not Applicable 8 COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY

8.1 Growers and millers regularly monitor and review their activities and develop

and implement action plans that allow demonstrable continuous improvement in key operations Availability of monitoring action plans taking into consideration environmental and social impact assessment and routine evaluation of estate and mill activity. This should include, at a minimum, but are not limited to:  Reduction of the use of certain chemicals Criteria 4.6  Environmental impacts Criteria 5.1  Reduction of waste Criteria 5.3  Pollution and emissions Criteria 5.6  Social Impact Criteria 6.1 The new action plan allows for a reduction in the use of certain chemicals. The programs for environmental impact, waste reduction, pollution and emissions, social impact of the factory and estate activities are not available yet, but improvement has been made such as: Solid waste generated by PT. Tunas Baru Lampung is exploited further so as not to have a negative impact on the environment such as waste fiber and shells used as fuel for boilers, dust solid waste from the combustion of the boiler being mixed with sludge from the WWTP for organic fertilizers, waste bunches application at palm oil trees as fertilizer, where waste bunches are previously burned in the furnace, WWTP liquid waste used for watering the palm oil trees or land application, improved exhaust gas emissions particularly dust particles from Boiler with the addition of Schuber. Document has been created and verified in the field 1. List of identification, management plans and waste handling methods of hazardous and non-hazardous waste for PT. TBL palm oil estate and mills SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 49 of 82 2. Pollution and emission reduction efforts and plans There has been a realization of the PT. TBL action plan of TBS Harvest Fertilizer Conservation P D Maintenance. Compliance status: Full Compliance SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 50 of 82

C. 3. Non Conformity Registers