Oil palm growers and millers provide adequate information to other stakeholders on

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 24of 164 The management Mill and estate showed the commitment to the implementation of the principles and criteria of the RSPO NI-INA. The Surveillance audit has been carried out through field visit to head office, mill and estate. The Team has conducted a follow-up audit to verify the 14 major findings issued at the time of the certification audit. From the audit results, 11 eleven of the findings can be closed and 3 three can not be closed ie the criteria 4.7.2 ; 6.3.1 and 6.9.1. In accordance with the provisions of the RSPO certification system then the company is suspended per date May 9, 2017 Surveillance audit conducted on date July 16-20, 2017. From the verification of the above three findings, it can be concluded that the company has taken corrective action in a systematic and comprehensive so that the findings can be closed. Status suspension revoked dated July 20, 2017. Audit Team has published the nonconformities, comprising 3 minors and 1 observation. The company has made the corrective actions refere to nonconformities as graded to minors and observation issued. The implementation of corrective action will be seen in the next surveillance audit. There is commitment of management to make corrective action and for continuous improvement. The audit team found that PT Poliplant Sejahtera – Siriham Mill and its estates is complying against RSPO P C approved for Indonesia. Therefore, certification can proceed to PT. Poliplant Sejahtera – Siriham Mill Mill and supply bases. Signed by: Tuti Suryani Sirait C.2. Summary of the Findings by Criteria 1 COMMITMENT TO TRANSPARENCY

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 decision making.

1.1.1 Evidence should be provided that information is received in appropriate forms and

languages by relevant stakeholders. Information will include information on the RSPO mechanisms for stakeholder involvement, including information on their rights and responsibilities. Minor The company already has SOP COM PPG CA 02 SOP, rev. 00, dated September 29, 2016, which regulates effective communication, consolidation and participation systems with stakeholders. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 25of 164 In the procedure explains that the list of stakeholders is updated and verified periodically once a year. The latest stakeholder data is available. The latest stakeholder data is updated in July 2017. The stakeholders list included provincial, sub-district and village groups, partnership plasma, customary leaders, community leaders and religious leaders, NGOs, company names, and contactors suppliers. In the list there is information, name of agency, name of person in charge contact person, address, and phone number that can be accessed. The previous minor fnding has been issued as follows : 1. There was no mechanism for regular updating and verification of stakeholder data. 2. There was no stake holder list and related information obtained from them. 3. Company already determined the provision of information report related to the environment but has not identified spesifically the type of information that needs to be provided periodically to relevant institutions. In related SOP only mentions periodic reports related to environment. With the explanation above and related to criteria 1.1.2, the findings can be closed. Conclusion : Conform 1.1.2 Records of requests for information and responses shall be maintained. Major The Company has procedures in response to information or complain from its stakeholders COM PPG CA 01 SOP Procedure, rev. 01, dated 01 June 2017. In the procedure has been determined the period of communication response is within 14 working days. The Company has appointed the person in charge of receiving and responding to information or complain from stakeholders ie CA Team and its personnel is Head of Community Relation Decision Letter no. 044 SK AAI-HRD V 2017 dated May 02, 2017. The job description is available from the position of Head of Community relation in document no. JD EST HRD INK.15 dated 01 June 2017. Monitoring the status of the communication is done using the media Log Book Communications. In the Log Book Incoming letter has the information of stakeholder, response status. Each incoming and outgoing letter is scanned and stored in the company database. It is recommended that the company inform stakeholders regarding the status of follow-up and decision of each request for information. All this time the company only informed that the request for information and or letter has been received but did not convey when the decision was approved or execution of the request. The first sampling of the letter number 1401252017 pem dated April 25, 2017 from Harapan Baru Village Air Upas District. There is already a follow-up status in the form of approval of digging wells to be realized in August-September 2017 letter No. 87 PSA-Mgr SHME 2017 dated May 15, SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 26of 164 2017. The follow up of the company in accordance with the SOP of Donation Sponsorship CSR PPG CA 02 SOP, rev. 01, dated 01 June 2017. There is a documentation of its follow-up evaluation of the request as outlined in the Checklist for Proposal form and cost budget plan for the dug well CSR program located in Judik District, Dentot Hamlet, Harapan Baru Village dated May 26, 2017. The second sampling of the letter from Kop Bun Kudangan Manis dated May 02, 2017 which contains the demand for increased transportation prices for seed transport. The company has responded to the letter and in the log book it is stated that it has submitted a letter to the management leader dated May 27, 2017. Follow up audit for the major finding raise at the time of the certification was: The company has already noted for all information requests and answers from stakeholder. In the SOP and in its implementation, the company has not determined a timeframe for providing an answer to an information request. At the time of stakeholders meeting, it has been obtained an information that they were never given time certainty of any requests for assistance or an update for information which was submitted to the company. For example, the request for road improvement, bridges, and construction of waterways which has been informed by the representatives of SP3, SP 5, and SP 6. In this case, the smallholders did not get any written answer and also the time certainty of the request. Follow-up audit verification: The company has made systematic in recording of incoming and outgoing mail to ensure that every request for information has to be responded within 14 working days. The company has determined the hierarchy from the mill estate manager to the director level. If there are problems that can not be resolved, then interested parties are welcome to contact RSPO in section of Dispute Settlement Facility Advisory Group. The company has already conducted socialization related to the procedure and the time frame of giving the answer to the stakeholders. Corrective action is sufficient and the major finding can be closed Conclusion : Conform 1.2 Management documents are publicly available except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes

1.2.1 Publicly available documents shall include, but are not necessarily limited to:

Major SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 27of 164 Criteria 5.1, 6.1, 7.1 and 7.8; c summary of certification assessment report; The Company has the procedure SOP COM PPG CA 02 SOP, rev. 00, dated September 29, 2016 to regulate the type of information that is allowed to be accessed by the public, how to provide the information, and officer who received and answered letters. It has set the classification of available and accessible information points 4.5 such as CSR programs issued by the company. Availability of List of Documents to the public and authority approval document that was prepared by the Sustainability Manager and approved by the President Director. Conclusion : Conform 1.3 Grower and millers commit to ethical conduct in all business operation and transaction

1.3.1 There shall be a written policy committing to a code of ethical conduct and

integrity in all operations and transactions, which shall be documented and communicated to all levels of the workforce and operations. Minor The company has had a code of ethical conduct policy which was stipulated in a code of conduct book 3 rd edition 2012. The contents of this book has already included bussiness ethics, prevention of corruption and bribery. The ethical conduct can also be found in 7 Cargill’s guiding principle number 2. The company has already socialized 7 Cargill’s guiding principle in every morning muster periodically. Conclusion : Conform 2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS 2.1 There is compliance with all applicable local, national and ratified international laws and regulations.

2.1.1 Evidence of compliance with relevant legal requirements shall be available.

Major The Company has established procedures for the identification and evaluation of regulation with no. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 28of 164 The PPG MR 002 SOP. Procedure prevail since May 2015. The results of the identification and evaluation was written on the form PPG MR 002 F.01. The list of regulations covers legality, environment, occupational safety and health, employment, HCV and other relevant regulations. This regulation have been communicated and distributed to each level of operation. Some of regulation that obeyed by companies are : 1 Law No. RI. 322009 regarding the Protection and Management of the Environment 2 Government Regulation No. 272012 regarding Environmental Permit 3 Government regulation RI No. 1012014 on the Management of Hazardous Waste 4 Ministerial Decree No. 292003 on Guidelines for Permit for Utilization of Waste Water of Palm Oil Industry on Land in Oil Palm Plantations Conclusion : Conform 2.1.2 A documented system, which includes written information on legal requirements, shall be maintained. Minor The Company has established procedures for the identification and evaluation of regulation. The Company has identified and evaluated compliance of the applicable legislation and its change periodically. Personnel incharge to manage this requirement regulation is sustainability officer. The regulation which identified starting from the law, government regulations, presidential instructions, ministerial regulations until local regulations. This regulation have been communicated and distributed to each level of operation. Conclusion : Conform 2.1.3 A mechanism for ensuring compliance shall be implemented. Minor Internal audit for legal compliance conducted annually and documented. The company conducts regulatory review every 6 months. The latest review took place in July 2017. The company has already complied with about 378 regulations. Conclusion : Conform 2.1.4 A system for tracking any changes in the law shall be implemented. Minor The Company access the regulations from the internet, send letters to agency, information from training institutions and others. Personnel in charge to manage this requirement regulation is sustainability officer. The company conducts regulatory review every 6 months. The company has SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 29of 164 already complied with about 378 regulations. The last review was conducted on July 3, 2017. On July 3, 2017, the company has added one regulation, namely Permen LHK no 202017 regarding the standard gas buang kendaraan. At the time of certification audit, SOP of waste management no. PASPPGEHS 32SOP should be revised because the underlying regulation that has expired i.e. PP 181999, PP 851999 dan Kep.Bapedal 051995. The Company has made corrective action such as the regulation has been revised with the latest related regulation of PP 101 of 2014 on Hazardous material Waste Management. The corrective action has been addressed and the minor NC can be closed. Conclusion : Conform 2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights

2.2.1 Documents showing legal ownership or lease, history of land tenure and the actual

legal use of the land shall be available. Major Site Permit - The Company already has a location permit issued by the Governor of First Level Head of West Kalimantan Province No. 155 of 1990 about reserve and location permit, totaled 39,700 Ha for Palm Oil Plantation with PIR TRANS system on behalf of PT POLIPLANT SEJAHTERA in Manis Mata and Murau Subdistrict, Subdistrict of Second Level Region of Ketapang, West Kalimantan Province. - The Company has Extension Permit Site for the purposes of the Palm estates project with PIR- TRANS system on behalf of PT POLIPLANT SEJAHTERA No. 37931993, totaled 39,000Ha. IUP Estates Business Permit - The Company has Estates Business Registration License SPUP No. 198Menhutbun- VII2000 which states that the designation of area for Palm Oil Plantation with an area of 4004.5 ha and 1 unit PKS with 60 Tons capacity of FFB hour. This is raised as Major Non Conformity no. 01 appendix 2 and corrective action taken as written in the appendix 2 column 8 is considered adequate therefore this major NC finding can be closed Permanent Business License - The Company has a permanent business license issued by the Head of the Investment Coordinating Board No: 884TPERTANIANINDUSTRI2007 with capacity of 95,200 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 30of 164 tonyear. At the time of thestage II audit there was difference of capacity between installed capacity SPUP No. 198Menhutbun-VII2000 60 Tons of FFBhour with a Permanent Business License about 95,200 tonsyear and The Companyhad gave responses by presenting the Industrial business permit from Department Industry and Trade of Kab.Ketapang No. 353002Kop.UKM.Perindag-CKBLI.15144I2013 with capacity of 60 tonshour. Release of Forest Area Based on Padu Serasi Map and RTRWP of West Kalimantan Kalbar Regulation No. 11995 is an area of cultivation of food crops and plantations. The Company already has a Minister Decree No. 50 Kpts-II1996 about release of some forest areas located in Forest Group Sarang Membuluh and Silat River, Level II of District of Ketapang with number of 16,418 on behalf of PT POLIPLANT SEJAHTERA. In letter of release of forest area was decided to give HGU Land Use Permit for 35 years to PT POLIPLANT SEJAHTERA with area of 4004.5 Ha. Hak Guna Usaha HGU HGU Decree The Company has SK HGU issued by the National Land Agency No: 139HGUBPN97 about granting of HGU of land in Ketapang District, West Kalimantan Province,covering area of 4004.5 Ha. HGU Certificate The Company has HGU certificate No.6 located in the village of Sarang Membuluh and Silat River in Manis Mata Subdistrict, Ketapang, West Kalimantan Province NIB: 1407060000188. Stated in the certificate area of 4004.5 Ha with a validity period for 35 years untill February 19, 2034. Companies can show actual data of the used area in the statement area, ie: - Emplasment = 13,16 ha - Road = 107,42 ha - Waste pool = 4,84 ha - Palm oil mill: 7,79 ha - Parungan = 8,65 ha - Reservoir = 5,25 ha SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 31of 164 - Quari = 0,55 ha - Swamp = 62,31 ha - HCV MA = 270,01 ha - Planted = 3.524,44 ha - Total land used = 4.004,42 ha During Certification audit was founf major conformity as follows : There is a difference in capacity permit between capacity in SPUP Number 198Menhutbun-VII2000 60 Ton FFBHour with capacity in IUT which is 95.200 tonyear. The company has conducted corrective action as follows: The company has showed industrial permit which was issued in the year of 2013 with production capacity 60 tonhour. Follow-up audit verification: Based on the IUT which was issued by the Head of the Capital Investment Coordinating Board on behalf of Minister of Agriculture Minister of Industry Number: 884 T PERTANIAN INDUSTRI 2007 with factory capacity of 95.200 tonyear. The company has made improvements by obtaining IUI Number: 535002Kop.UKM.Perindag-CKBLI.151442013 which was issued by the Ketapang District Office of Industry Trade and has been stated that production capacity was 60 ton FFBhour. The permit has been in accordance with the capacity permit in SPUP Number: 198 Menhutbun-VII 2000. Corrective action is sufficient and the major finding can be closed Conclusion: conform 2.2.2 Legal boundaries shall be clearly demarcated and visibly maintained. Minor PT. Poliplant Sejahtera has a Map of HGU pole with a scale of 1: 60.000. In the Map there is information of the number of the pole, the location of the pole, and the point of coordinates of the pole. During the field visit, sampling to Pole HGU no. 20. Pole in a well maintained condition and can be seen clearly. The coordinates listed on the HGU pole map also match to the exact coordinates of 2 ° 1853.6 S and 110 ° 5139.3 E. There is a SOP for Inspection of B PN pole No: PAS PPG EHS 44 SOP. In the SOP it is written that the implementation of monitoring spoles carried out every 6 months. The last monitoring was conducted in June 2017. Conclusion : Conform 2.2.3 Where there are or have been disputes, additional proof of legal acquisition of title and evidence that fair compensation has been made to previous owners and occupants shall be available, and that these have been accepted with free, prior and informed consent FPIC. Minor Based on Log Book Communications Incoming Letter PT. Poliplant Sejahtera, in 2016 there was SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 32of 164 no record entry letter regarding land disputes. Conclusion : Conform 2.2.4 There shall be an absence of significant land conflict, unless requirements for acceptable conflict resolution processes see Criteria 6.3 and 6.4 are implemented and accepted by the parties involved. Major Based on Log Book Communications Incoming Letter PT. Poliplant Sejahtera, from 2016 to July 2017 there was no record entry letter regarding the dispute Conclusion : Conform 2.2.5 For any conflict or dispute over the land, the extent of the disputed area shall be mapped out in a participatory way with involvement of affected parties including neighbouring communities where applicable. Minor The Company has Land Acquisition SOP No. LCP PPG HUMAS 02 and in point 6.10 it states that for any land-related conflicts or disputes, there should be evidence of disputed land and should be mapped participatively by involving affected parties. Based on Log Book Communications Incoming Letter PT. Poliplant Sejahtera, from 2016 to July 2017 there was no record entry letter regarding the dispute Conclusion : Conform 2.2.6 To avoid escalation of conflict, there shall be no evidence that palm oil operations have instigated violence in maintaining peace and order in their current and planned operations. Major The Company has a Cargill Code of Ethics which one of its principles is to Treat Others with Dignity and Respect in which it is stated: 1. Will not tolerate any kind of harassment. 2. Will not tolerate the use of physical coercion intended to injure a persons body. 3. Will not tolerate actions or threats intended to intimidate or intimidate a person physically. The Company does not use military personnel for security within its working area. The company uses security personnel from security unit providers security guards, namely PT. Bazcorp Citra Indonesia which currently has a working contract up to January 31, 2018. Conclusion : Conform 2.3 Use of land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent.

2.3.1 Maps of an appropriate scale showing the extent of recognised legal, customary or

user rights Criteria 2.2, 7.5 and 7.6 shall be developed throughparticipatory mapping involving affected parties including neighbouringcommunities where Major SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 33of 164 applicable, and relevant authorities. The company has SOP on FPIC namely SOP of Land Acquisition no. LCP PPG HUMAS 02. Within the SOP in POIN 2 Land Acquisition Procedure it is stated that after the company has obtained location permit from an authorized party, the public relations department together with the village and sub-district apparatus perform FPIC activities to the local community. The SOP also comes with forms that ensure the existence of transparent, legal, and fair agreements for any land acquisition and redemption process. PT. Poliplant Sejahtera plans to plant a new area of 785 ha. Planting is a form of cooperation partnership development and management of oil palm with Kudangan Manis Plantation Service Cooperative KPJKM. Land obtained from KPJKM members who submit to the Cooperative on condition that it can be proven status of land ownership showing Land Statement and Letter of Physical Land Tenure Statement. There is no compulsion to the community to become a candidate for independent partnership. During Certification audit was found major conformity as follows : 1. There is a map of estate which contained the draws of lands that was not controlled by the organization as illustrated in the HCV map in October 12 th 2015. SIA report was conducted by the Daemeter Consulting in the November 6 th of 2015, but for the notes the scale of map was too small which was less than 1: 10,000. 2. The company does not have SOP of FPIC. In land acquisition procedure LPC PPG HUMAS 02 SOP, there is no subject and term about FPIC. Follow-up audit verification: 1. In the HCV Full Assessment Report dated in October 12 th of 2015, the map which was shown using the scale of 1,5 : 25.000 or ± 1 : 17.000 and the SIA report dated in November 6 th of 2015 was used the map scale of ± 1 : 400.000. The company has made an improvements by making the Map Allocation of Estate Areal, Smallholders and HCV of PT. Poliplant Sejahtera with scale of 1: 10.000. 2. The company has already conducted socialization to the employees which was responsible for the land acquisition process in accordance with the procedure of LCP-PPC-HUMAS-020SOP Rev.01 which was issued in January 13 th of 2016. In this procedure has already been equipped with forms which ensured the survey was conducted transparently, legal, and fair for every process of land acquisition and compensation. Corrective action is sufficient and the major finding can be closed. During Certification audit was found major conformity as follows : The company does not have SOP of FPIC. In land acquisition procedure LPC PPG HUMAS 02 SOP, there is no subject and term about FPIC. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 34of 164 Follow-up audit verification: The company has already conducted socialization to the employees which was responsible for the land acquisition process in accordance with the procedure of LCP-PPC-HUMAS-020SOP Rev.01 which was issued in January 13th of 2016. In this procedure has already been equipped with forms which ensured the survey was conducted transparently, legal, and fair for every process of land acquisition and compensation. Corrective action is sufficient and the major finding can be closed. Conclusion : Conform 2.3.2 Copies of negotiated agreements detailing the process 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 affected groups in the communities, and that information has been provided to all affected groups, including information on the steps that shall be taken to involve them in decision making; b Evidence that the Company has respected communities’ decisions to give or withhold their consent to the operation at the time that this decision was taken; c Evidence that the legal, economic, environmental and social implications for permitting operations on their land have been understood and accepted 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. Minor The Company and KPJKM have copies of the Memorandum of Understanding on Partnership for Development and Management of Oil Palm Plantation in Mandiri Kemitraan Village in Harapan Baru Village Air Upas Subdistrict, Ketapang District, West Kalimantan, Number: 001 MoU KM PSA V 2016. The memorandum of understanding includes the following pound points: 1. Land requirements that can be developed. 2. Requirements to participate as independent candidates. 3. Submission of land certification process 4. Funding 5. Pattern of implementation 6. Dispute resolution Conclusion : Conform 2.3.3 All relevant information shall be available in appropriate forms and languages, including assessments of impacts, proposed benefit sharing, and legal arrangements. Minor SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 35of 164 Based on the results of interviews with the Chairman of the Cooperative Fany Kristiawan it can be seen that all related documents are available in Indonesian language that can be understood by all member. Conclusion : Conform 2.3.4 Evidence shall be available to show that communities are representedthrough institutions or representatives of their own choosing, including legal counsel. Major Fany Kristiawan as the Chairman of Kudangan Manis Cooperative acts as the representative of the community in the negotiation process Conclusion : Conform 3 COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY 3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability

3.1.1 A business or management plan minimum three years shall be documented that

includes, where appropriate, a business case for scheme smallholders. Major The Company has had long periode plan 20152016 untill 2021. In the plan has been consisted of Replanting plan of core and plasma, yield, CPO volume and PK, OER, scheme smallholder. The Company has had plan for 3 years. Start from 2016-2018 to do mechanism of harvest activities and fertilization. In the plan, contained of total worker and application area. The Company has not have long periode plan regarding to : Forecast pricest, cost of production, financial indicators, and projected expansion. The Company has been had replanting plan in 2018- 2021. On previous Planting year’s data was 3794.6 Ha for core and 7746 for Plasma. Replanting plan still in the same vest area and has not contained area deficiency that can be planted because it is appropriate with HCV category. The Company has had system regarding to technology maintanance and information about repairing process activity that is communicate on management meeting observation. The Company did not have peat land in area that divised. During Certification audit was founf major conformity as follows The company has already had replanting plan for the year of 2018-2021. Data of the previous year of planting data was 3.794,6 Ha for estate and smallholders was 7.746 Ha. In the case for replanting plans still remain within the same areal and has not contained reductions in non-planting areas due SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 36of 164 to the HCV category. The company has conducted corrective action as follows: The company has already revised the replanting plan. Follow-up audit verification: The company has changed the long-term plan for period of 2018-2021 where there is a reduction of planting area from 3794,6 Ha become 3524,44 Ha reduction is about 270,01 Ha for HCV area. The reduction of area came from the edge of the river area which was not being planted 100 meters left and right of river and source of springs with a diameter of 200 m. Corrective action is sufficient and the major finding can be closed. The Company has had replanting plan by putting reduction of previous HCV that planted is 3794.6 Ha become 3524.44 Ha Reduction is about 270.01 Ha for HCV area. PT. PSA is committed to economic and financial sustainability with an annual plan as outlined in the five-year long term plan financial projections, the annual management plan, and annual budget plan for 2016-2019. The five-year long term plan financial projections consisted of replanting plan, scheme smallholder, yield, CPO volume and PK, OER. While annual budget plan consisted of total worker and application area for harvesting and fertilization mechanism. The annual management plan included the following : 1. Land area statement planting years, non-planted areas, HCV, conservation areas, fragile soils with updated location maps. 2. Plan for management of scheme smallholders 3. Quality of planting materials 4. Crop projection = FFB yield trends 5. Mill extration rates = Oil Extraction Rate OER trends 6. Cost of Production = cost per tonne of Crude Palm Oil CPO trends 7. Forecast prices 8. Financial indicators – profitability forecast income vs outcome 9. Projected expansion area, mill capacity, infrastructure, social amenities SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 37of 164 These plans are updated annually with a compari son for each year’s performance. As information, PT. PSA does not has peat area at Siriham Estate. There is ASD Agronomy Service Departement section to ensure implementation new information and techniques by conducting field agriculture appraisal. The information is updated through management meeting with related person in charge. There is SOP PPGGMOASD48SOP; prosedur for scoring field audit for productive plant for estate as a guideline for monitoring and updating information to improve practices. The ouput from field audit visitation is recommendation report from ASD which will be used as planter’s report or block history nutrient. Top management has to approve the recommendation report and distributed to estate manager. When necessary the relevant new information in the management plan shall be communicated to the relevant workers and scheme smallholders. Conclusion : Conform 3.1.2 An annual replanting programme projected for a minimum of five years but longer where necessary to reflect the management of fragile soils, see Criterion 4.3, with yearly review, shall be available. Minor Annual Review consisted of production such as TM area, FFB, Yield, Fertilization, harvest, Transport, Field infirect. There were eveluation towards deviation between budget and realization. Fertilize realization was a bit more than that of the budget. Based on eveluation, it said that realization more little because of delay of fertilization arrival so that it was not appropriate with fertilization schedule. Result of evaluation should be consisted of remedial action for prevent the problem in the further time. The annual review consisted of production such as productive plant area, FFB, yield, fertilization, harvesting, transport of FFB. There are evaluation towards deviation between budget and realization. As information, the annual replanting programme, its yearly progress and review has been documented. Conclusion : Conform 4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS 4.1 Operating procedures are appropriately documented and consistently implemented and monitored

4.1.1 Standard Operating Procedures SOPs for estates and mills shall be

documented. Major SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 38of 164 The company has already had a well-documented SOP for Mill and Estate and which its copies are available on site at Mill and Estate included the Work Instruction. As information the companys SOP for Mill has already been included several key processes on Mill such as Loading Ramp, Sterilizer, Thresher, Press, Clarification, Kernel, Boiler, and Engine Room. In addition, work instructions has been provided by the company included Lory Filling, Lorry Displacement, Lorry Preparation, Sterilization, Pouring Lorry, Thresher, Rail Track, Baunch Cruiser, Bunch Press, Static Crane, Digester, Press, Sedimentation, Vibrating Screen, Decanter Sentrifuse , Vacuum Dyer, Purifier, Separation of Nut and Fiber, Ripple Mill, Wet System Separation, Kernel Drying, Boiler Operation, Emergency Measures, Diesel Genset, Turbine, and Main Panel. The SOP Mill which has been provided by the company as follows: • Loading Ramp PRS PSA SHMM 01 SOP • Sterilizer PRS PSA SHMM 02 SOP • Thresher PRS PSA SHMM 03 SOP • Press PRS PSA SHMM 04 SOP • Clarification PRS PSA SHMM 05 SOP • Kernel PRS PSA SHMM 06 SOP • Boiler PRS PSA SHMM 07 SOP • Engine Room PRS PSA SHMM 08 SOP The companys SOP for Estate has already been included several key processes such as land clearing, manual fertilization, fertilizer spreader, harvesting, FFB Transportation, Census ESW, establishment of single and contour terrace, integrated pest management. The SOP Estate which has been provided by the company as follows :  Land Clearing PPG GMO ASD 11 SOP  Manual Fertilization PPG GMO ASD 45 SOP  Fertilizer Spreader PPG GMO ASD 46 SOP  Harvesting PPG GMO ASD 60 SOP  FFB Transportation PPG GMO ASD 63 SOP  Census of ESW PPG GMO ASD 04 SOP  Establishment of Single and Contour Terrace PPG GMO ASD 25 SOP  Integrated Pest Management PPG GMO ASD 03 SOP SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 39of 164 Conclusion : Conform 4.1.2 A mechanism to check consistent implementation of procedures shall be in place. Minor There is master list for SOP which includes SOP for Estate and Mill. The changing or revisions to SOP are conducted when necessary, and each of SOP will be reviewed every 3 years. Every each of SOP has been attached with revision form in order to track any changes in SOP. The revision form of SOP contained such information as the revision order, date, and history of revision. In order to ensure the implementation of SOP in Estate, the company has conducted a field audit twice in one year. The field audit was conducted with the team composition of 4-person which consist of ASD Agronomic Service Departement team consisting of ASD Manager, ASD Assistant, and Field Auditor. In the meantime, the daily reports are used for each process in Mill Sterilizer, Thresher, Press Station, Clarification, Boiler, and Nut Kernel Separation to ensure SOP implementation. The daily reports are monitored by process assistants, assistant heads, and mill managers. In addition, every day the percentage of OER and KER has been monitored by taking and analysing samples from the quality assurance and quality control section. In order to ensure SOP implementation for all of employees, the company has conducted socialization and training for SOP both in Estate and Mill. Conclusion : Conform 4.1.3 Records of monitoring and any actions taken shall be maintained and available, as appropriate. Minor The company has recorder all of the operational monitoring both at estate and mill. For example the company has a daily logsheet for harvesting, manuring, spraying activities at estate and at mill such as pressure station, strelizer station, temperature of digester. The company also kept the maintenance record. Conclusion : Conform 4.1.4 The mill shall record the origins of all third-party sourced Fresh Fruit Bunches FFB. Major The SOP are available for FFB sortation No. LAB PSA SHMM 13 SOP at Siriham Mill which is being used as reference in FFB acceptance. At the time of audit at Siriham Mill, there is no activity of receiving FFB from outgrower or third party. Conclusion : Conform SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 40of 164

4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level