Agrochemicals are used in a way that does not endanger health or the

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 37of 77

4.6 Agrochemicals are used in a way that does not endanger health or the

environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented Company has established agrochemical handling procedures i.e. Agrochemical Handling SOP. There is a list of agrochemicals used by Company with brand, active substance, WHO classification, and distribution license details. Monthly use of pesticide has been recorded on toxicity monitoring report. Agrochemical use has been recorded on a logbook covering application area, amount of use per ha and application rotation. During field visit at block B- 15 of Afdeling A, Glyphosat and Metaprima was being applied. Dose was in accordance with the recommendation. Restricted pesticide such as paraquat remains in use but Company has a policy to stop ordering and reduce paraquat herbicide application as addressed in the Internal Memo 001TAPMIN-EST-HOII2013. The trend of paraquat use has declined from 2012 to 2013 up to August 2013. In March and April 2013 reports there is a use of Furadan carbofuran, which comes into category of 1A type for exterminating kumbangtanduk Oryctes rhinoceros. But now its use has been stopped and the method of handling kumbangtanduk pest is replaced with biological methods using feromonas. This is evidenced by the record of agrochemical inventory stock per 10 September 2013 in which carbofuran is not listed. Used pesticide container management has been regulated in Agrochemical Handling Procedure SHE SOP, Chapter VI Environment, VI.5 Agrochemical Handling, No. TAPSOP120-SHE0001. Containers are washed 3 times in a dedicated facility and sent to Hazardous Waste temporary collection site TPS for transfer to licensed third party. Sprayer training was conducted on 19 June 2013 by Estate Manager to spraying personnel. There is evidence of training in the form of attendee list, minutes and photos. Female sprayers undergo health and pregnancy checks on a monthly basis. The record of sprayer health examination in August 2013 shows healthy and unpregnant condition. The name of sprayer interviewed during field audit is Mrs. Mustakimah who had cholinesterase SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 38of 77 examination in January 2013. Nevertheless, the implementation of cholinesterase examination has not made a reference to laws where special health examination must be performed twice a year. Compliance status: Minor NCR No.10 4.7 An occupational health and safety plan is documented, effectively communicated and implemented Company has established PT. GBSM SHE Policy. The points are: 1 commitment to SHE by allocating budget, quality personnel, and other facilities, 2 prevent accident and work- related disease, 3 environmentally responsible, 4 comply with laws and regulations, 5 perform CSR, and 6 efficient energy use. The policy was signed on 2 January 2012 by President Director Mr. Tjandra Karya Hermanto. It is disseminated by displaying it in work areas, class dissemination for staff level and above, and dissemination to each worker through distribution of a brochure containing: SHE Policy and points of RSPO, ISPO, and PUP Estate Business Assessment. Related to safety target, Company has set forth as target a program to prevent occupational accident and work-related disease, by referring to Presidential Decision No. 221993 pertaining Disease Arising out of Work Relation. The target of accident prevention is: 1. Zero fatality, 2. FR 4.5, and 3. SR 4.5. Company has set Activity Plan 2013, prepared by SHE-Section Head, and approved by Mill and Estate Manager. KPI measurement, unit, target, weight , due date, PIC, and Schedule month have been incorporated. Company has had and established Occupational Safety and Health and Environment SHE SOP GSMSOP120-SHE0001. Approval sheet states that: the document is established based on TAP Group SHEMS Guideline No. TAPPedoman120-SHE, OHSAS 18001:2007, EMS ISO 14001:2004, and the Regulation of the Minister of Environment No. 51996, where the implementation covers all the operational activities of PT. GBSM. Prepared by: SHE TAP Team, SHE Dept. Head, Sustainability Div. Head, verified by: CMO and COO, and approved by Managing Director and CEO as per 22 March 2012. This SHE SOP applies in GBSM only, and is planned to be put into force throughout the company Group. The format is like a book, consisting of Table of Contents, List of Changes, Chapter 1, 2, to SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 39of 77 Chapter 7 Review, glossary of terms, and list of attachments. The report of workplace physical factor measurement carried out on 27 August includes the following factors: noise, lighting, vibration, ambient and emission air quality, and ISBB heat stress, but for estate ISBB heat stress physical factor has not been measured. Company set a policy that each worker with permanent employment status KT is included as a participant in Jamsostek social security scheme. The given program is JHT, JKK, and JK. Company has jamsostek related policy as regulated in Jamsostek Policy document No. Doc. TAP-PRHRD-GN055-1112-0 issued 1 November 2011, which is approved by CEO of PT. Triputra Agro Persada, as parent company. Point D.1.1 states that Company will include the workers in Jamsostek Program on package A only, i.e. Work Accident Insurance JKK, Life Insurance JK, and Old Age Insurance JHT. On point D.1.5 it is stated that all workers will be included as participant in Jamsostek from the time they pass the probation period into Permanent worker KT or after working 3 three months for contract workers. Further, point D.1.6 says that workers under probation period and Casual Workers KL are not included in the jamsostek program; however, Company is still responsible in the case of accident at work or death. Company manages its own old age pension insurance JPH. There is evidence in the form of Worker Jamsostek Premium Payment slip for Estate and Mill in February 2013. By corporate both Mill and Estate structure has SHE function where its officials are assigned to Assistant level. It is this function that is responsible for the aspects of Occupational Safety and Health, Environment, including emergency response. In order to comply with laws and regulations, Company has established Safety Committee for Estate and Mill areas, and has obtained approval from the Department of Manpower Transmigration and Tourism of Seruyan Regency with the Decision Letter No. 56066KEP DisnakertransparI2012, dated 22 January 2013. T he Safety Committee’s Program is the same as SHE Department’s Program. Safety Committee monthly meeting was conducted from February 2012 to February 2013 and meeting minutes are recorded on MoM and provided with Problem Identification Corrective Action PICA and attendee list. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 40of 77 Health check is carried out on any fresh worker upon employment. Workers who have been working for years do not have periodic examination because there is no policy. But monthly examination is conducted by internal clinic doctor exclusively for spraying and fertilizing personnel that cover age, tension, pregnancy, and pulse aspects. Blood cholinesteration checks are planned to be conducted every six months. When audited, Company had carried out blood cholinesteration check for 50 workers: fertilizer applicator, sprayer, laboratory employee, and hazardous material handler on 22 January 2013 in collaboration with Prodia Laboratory. This mid 2013, however, the organization did not perform special examination according to the regulation of the Minister of Manpower No. 03MEN1986. Also with audiometry test for Mill workers in areas of high noise level, such as: sterilizer station, boiler, processing machine, and power plant genset, including Estate genset area. Company has a clinic with 1 hyperkes-certified doctor, 2 midwives, and 2 paramedics 1 of them is hyperkes-certified. Also, it is provided with 1 ambulance unit. But, this clinic is located 12 km from the Afdeling Alfa Central Office. A new and permanent clinic is planned to be built in Central Office area in July 2013. The permit for permanent clinic is currently in process. Hazard Identification and Risk Assessment Environmental Aspect Identification Environmental Impact Evaluation IBPR has been developed and established TAPFO120-SHE0001-12, rev. 0, for Estate and Mill. It has been signed by SHE Secretary and Estate and Mill Manager. IBPR covers all existing Estate and Mill activities. Related to work accident, Accident and Incident Report Investigation SOP has been established SHE SOP, Chapter IV.5. AccidentIncident Investigation and Improvement Recommendation form has been established GSMFO120-SHE0001-26, rev.0. Any incident or accident at work has been reported and investigated, improvement recommendation been defined, and its effectiveness monitored. Company has established SOP pertaining SHE GSMSOP120-SHE0001 and signed by Managing Director as per 2232012. Fire mitigation SOP is included in:  Sub III.8. “Wildfire Emergency Preparedness Response”, which is intended specifically for land and forest fire.  Sub III.8. “General Emergency Preparedness Response Team TKTD-General”, which SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 41of 77 covers: fire, pollution, riots, earthquake, floods and others. It is valid at mill and estate. The implementing agency is TKTD.  It has been distributed up to staff level both at estate and mill. Approximately 50 copies.  SHE SOP dissemination is carried out through the issuance of Internal Memo No. MI- 001MDSUSTIX2012, from Sustainability Division, approved by CEO Mr. Arif Rachmat, and enforced throughout the Triputra Group. PT. Gawi-Estate TKTD has been established, signed by Estate Manager and General Manager. It consists of: Admin Head, Maintenance Head, and Pres AB Head. It comprises: Emergency Mitigation, Communication, Rescuer, Security, Paramedic, Investigation, and Repair Restore units. Their jobdesc has been established. Company has provided fire mitigation facilities and infrastructure both for Estate and Mill. It can be described as follows:  For Estate, Light Fire Extinguishers are provided and placed for the entire estate area, 1 unit each, including: GSBM1, Gasoline Warehouse, Diesel Fuel Warehouse, Office, workshop GSMB5, Genset Room GSBM6, and Clinic GSBM7. There are fire towers in 3 locations i.e. B-21, I-22, and D-51. There are portable fire extinguishers of 2 mobile tanks and 4 sets of portable pump with a capacity of 5000 liter each.  For Mill, Evacuation Route, Light Extinguisher Layout, Hose Rail Hydrant have been set forth. There are 35 light fire extinguishers, 7 points of hydrant pillar, and 5 points of hose rail in the field. There is a manual siren that can be heard from 500 meter radius. Muster point has been determined in front of mill at Mill office and at Estate office, and there are evacuation direction arrows in areas where workers are found.  There is Emergency Response Maintenance Program Fire that covers: Electric Pump, Diesel pump, and all hydrant facilities. Light fire extinguishers are inspected monthly and the evidence is recorded on Light fire extinguisher Checklist card. Likewise for hydrant, there is a card in each hydrant box on which routine inspection results are recorded. Light fire extinguishers are adequately pressurized, and have been labeled with refilling date. Hydrant hoses are still in good condition because of recent replenishment. Training that has been given to TKTD includes: 1 PPGD First Aid, on 27 Jan 2012 and SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 42of 77 14 Dec 2012, for members of TKTD Paramedic, by Clinic doctor. The First Aid officers have obtained safety license from the manpower department on 23052013 2. Fire Extinguishing on 25012012 and 12122012, with training materials of Light fire extinguisher Operation. The trainer is Fire Safety Expert Class A. 3 Introduction to Fire and APAR Use Training on 29062012 13 personnel. Company has conducted fire emergency simulation, both in Estate and Mill area. For Estate area it was carried out during the audit on 11 September 2013, while for Mill area it was on 31082013. Simulation has been provided with a scenario and evaluation of its effectiveness. Some conclusions from evaluation have been followed up either directly or incorporated into SHE Dept. program. It should be noted that Company do not have a TKTD officer according to the Decree of the Minister of Manpower No. 1861999 for Mill area as stipulated in Attachment 1 and 3. Company is currently has just 1 Fire Safety Expert. First Aid Kit has been available in mill and estate location. First aid kit in estate should be provided with pincers and book to record its use. The organization has appointed first aiders in mills in corresponding with Mill emergency response organizational structure, while in estates the foremen are appointed as first aider. Compliance status: Minor NCR No.12 Observation No.9, No.11, No.13, No.14 4.8 All staff, workers, smallholders and contractors are appropriately trained. Company established training program 2013 for mill and estate personnel based on training need analysis. Training need analysis takes into consideration job types and personnel position. There is training implementation evidence of attendee list, photos and training materials. Sample of training realized at mill location is: Grading Training on 27 February 2013 and QCC, QCP and SS Training on 28 April 2013. There are records of training realization in estates, for example, sprayer training was conducted on 19 June 2013 by Estate Manager, for spraying personnel. There is training evidence in the form of attendee list, minutes and photos. Estate II Foreman Training was carried out on 20 – 24 April 2013 by HRD Learning Department. Training for afdeling OL fertilizing personnel related to Safety and Health was given by Sustainability Division on 18 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 43of 77 April 2013 with 8 participants; there is evidence of records of activity. Company has Contractor Selection SOP Memo Internal No.: MI-011MDPROCVI2013 that incorporates company profile and reference requirements to ensure contractor competencies. Where a candidate contractor company is questionable, its competence and legality will be verified. Sample contractor whose competence has been assessed is PT MajuBersama Perkasa as LC Contractor. Compliance status: Compliance 5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

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