POTENTIAL BREACHES OF THE DESIGNATED “NO GO” AREAS OF 2013 VERIFICATION STEPS TAKEN BY THE FCP IMPLEMENTATION TEAM

3 extent of this area is 14,600 Ha, of which 6,623 Ha had been developed between 1 st February 2013 and 31 st July 2013. Pre-assessments to identify HCSHCVpeatland areas were conducted for all three companies between 29 January and 8 February 2013. The methodology used for the pre-assessment is described in Appendix1.

3. POTENTIAL BREACHES OF THE DESIGNATED “NO GO” AREAS OF 2013

RKT COMPARTMENTS IN BAP, SBA AND BMH Based on the updated Planting Realization Map of the three HTI companies that were obtained by the FCP Implementation Team on 15 July 2013, land preparation and planting activities had occurred inside the designated “ No Go ” areas. Of the total 489 compartments located inside the “ No Go ” , 23 were affected. The profile of these 23 compartments can be seen in Appendix 2. With this finding, the FCP JSC immediately instructed the FCP Implementation Team to conduct a document review and field verification on the alleged cutting of potential HCVHCSpeatland areas within compartments designated as “ No Go ” .

4. VERIFICATION STEPS TAKEN BY THE FCP IMPLEMENTATION TEAM

The following steps were taken in relation to the potential forest moratorium breaches within the “ No Go ” areas in the 23 compartments in BAP, SBA, and BMH: a. A preliminary evaluation was conducted in APP ’ s Office in Jakarta on relevant documents, data, and maps against the original recommendations of the HCSHCVpeatland pre-assessment. b. APPTFT formed a Field Verification Team FVT that was sent to BAP, SBA, and BMH where the breaches occurred see Appendix 5. 4 c. The FVT conducted a field visit from the 23 rd to 27 th July 2013 using the following steps: Ø Reviewed relevant documents in the Region of Palembang and in the 4 Districts Simpang Tiga District, Kuala Lumpur District, Sungai Ketupak District, and Simpang Heran District. Ø Interviewed relevant parties in the Region of Palembang and in the 4 Districts. Ø Conducted field observations in the 23 compartments where the potential forest moratorium breaches within the “ No Go ” areas had occurred. Ø Conducted a two-stage data reconciliation process with all the relevant resource persons in the APP Office in Jakarta that commenced on the 1 st August 2013 and which was completed on the 22 nd August. The findings were reported to the FCP JSC. 5. CONCLUSION OF THE FIELD VERIFICATION TEAM Based on the result of the verification process and accompanying field data the FVT concluded: 1. Within BAP, SBA and BMH RKT, potential forest moratorium breaches occurred after 1 February 2013 in RKT compartments 2013 inside the designated “ No Go ” areas. The total area developed was 431.1 Ha and took place in 23 compartments Appendix2. 2. A first stage of data reconciliation alignment of field verification data and APP operational data Appendix 3 concluded that: a. With respect to HCV, these 23 compartments were cross checked in relation to potential HCV areas identified during the pre-assessments HCSHCVpeatland in February 2013 – there was no overlap. Therefore, none of the 23 compartments above were assessed to contain HCV and all further verification would focus on identifying potential HCS. 5 b. With respect to HCS, the verification analysis output revealed that of the 431.1 Ha, a maximum area of 72 Ha could provisionally be considered as HCS and therefore in breach of the forest moratorium. This estimate would be further analysed in a second stage of verification to establish a more accurate figure. 3. Following stage 1, whereby field verification data and APP Operational data field and head office were reconciled, a second stage comparative spatial analysis was implemented Appendix 4 to both double check the output of the first stage and to strengthen the overall result through the inclusion of plot data generated in the full HCS assessment implemented in JuneJuly 2013. Based on the analysis of spatial mapping data and field data, it can be concluded that the total HCS area cleared after 1 February 2013 is 69.45 Ha. This is an unacceptable breach of APP ’ s natural forest clearance moratorium and its FCP. 4. This 69.45 Ha of HCS was cleared despite the FCP Implementation Team “ RKT 2013 Recommendation Map ” and Moratorium Protocol being distributed to all regional and district managers. Land preparation activities took place within the compartments designated as “ No Go ” areas because of a lack of understanding by the district managers of the pre-assessment objectives and the ongoing HCVHCS assessment work being carried out in the “ No Go ” areas. Further, there wasn ’ t a clear and comprehensive protocol and sign off process in place between the regional and district managers related to “ No Go ” and “ Go ” areas. 5. If the pulpwood suppliers ’ operational teams had been provided a robust checklist of actions and documents requiring formal sign-off and on-going monitoring and supervision, this incident would have been avoided. 6. None of the wood cleared from the 69.45 Ha of HCS was sent to APP ’ s mills.

6. ACTIONS BEING TAKEN TO STRENGTHEN APP ’S MORATORIUM AND