Oil palm growers and millers provide adequate information to other stakeholders

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 22of 105 and environmental area. The audit team found that PT Brahma Binabakti – Brahma Binabakti Mill and its estate is complying against RSPO P C approved for Indonesia. Therefore the recommendation of the Lead Auditor that Certificatre of RSPO is awarded to PT Brahma Binabakti – Brahma Binabakti Mill and its estate. Signed : Tuti Suryani Sirait Date : 22 Januari 2015 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. Company already has Receiving and Handling of Information Request SOP No. 106181TAPPRO- CSR-HOVI13, issue since 3 June 2013. It is mentioned in Point 4.2.2 the responsible person in charge to handle the information is Assistant CSR at estate , while the Mill is Adminstration officer. In the SOP it is specified that if requestors comes directly to the site, they have to fill in a guest book provided by the security officer, who is also the first to receive guests and then will take the guest to the Assistant CSRKTU. Company already has a list of stakeholders consisting of: plasma community, the management of KUD Akso Dano cooperative, chiefs of surrounding villages and their team, district head, district head‟s secretary, chief of BPD, chief of customary institution, youth organization, subvillage chiefs, neighborhood chiefs, and government leaders at provincial level, government leaders at regency level, police, trade unions, supplierspartners, and customers. Estate : A sampling to an incoming letter to the Estate from the Police no. B034TV2014SatBri dated 18 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 23of 105 April, 2014. The letter was received by the company on 25 April 2014 requesting to borrow TV for safeguarding the election. Company has responded to the letter on 28 April 2014 by not granting the request. SOP has not made a category of types of letter that need and do not need a reply. In the implementation there are types of letter such as invitation letter, notification letter, circulars from governmentnon-government agencies that need no reply. This has been raised as a Major non- conformity no. 19 At Mill, sampling of an incoming letter from Internal Futsal Management, dated 08 January 2014 and replied by the company through a letter number 02BBB-PKSSKR12014 regarding requests for Futsal Field Lighting assistance. The incoming letter was found not to be archived in the incoming letter file. The outgoing letter has been given to relevant stakeholder but not date is available indicating when the letter is delivered. In this case, the company cannot prove that the compliance with the provisions of the SOP where the company will reply an incoming letter within a maximum of 10 working days. This has been raised as a Major non-conformity no. 19. The company has revised the related procedure 106181TAPPRO –CSR–HOVI13 Revision: 01 and delivered traininginformation dissemination of the procedure to relevant parties. Compliance status : Confom 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 The Company has determined in SOP for Information Request Acceptance and Handling 106181TAPPRO-CSR-HOVI13 that there are 7 items of information that can be accessed, including: 1. company social activities, 2. HCV management, SIA, and AMDAL, 3. K3 and environment, 4. Commercial data can only be delivered orally, as directed by Regional CEO, 5. Invoices and support data from contractors, suppliers, purchases of FFB, 6. Employment and request for internships or comparative studies, and 7 Others which has not yet specied as above. Types of information that can be provided by company have been listed in the SOP 106181TAPPRO-CSR-HOVI13. Company has categorized information that may be provided along with their related PIC. All information is subject to approval of the MillEstate manager, Senior EMSMM. Confidential information in addition to the categories mentioned in the SOP can be granted by the SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 24of 105 Regional CEO. Each information request is recorded in the form 106183 2013TAPPRO-CSR- HOVI13 and the response in the receipt form no. 106181TAPPRO-CSR-HOVI13 A Sampling of a letter from the Minister of Forestry No. 942094Dishutbun2014 dated 23 January and received on 16 May, 2013. The letter contained a request for a list of permitslegality related to the company‟s land ownership and company responded on 04 June 2014. This has complied with the provisions of the SOP where the company will reply an incoming letter within a maximum of 10 working days. Company has already conducted updating of the applicable regulations. At preliminary audit, it was found obsolete regulations in the list of regulations and it has been corrected accordingly. Compliance status : Conform 2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS 2.1 There is compliance with all applicable local, national and ratified international laws and regulations. Company has an Internal Memo on the Implementation and Fulfillment of Applicable Laws and Regulations with the document number MI-005MDSUSTXII2012 dated 11 December 2012, which is signed by the Sustainability Division Head, CPO Division Head, Chief External Relation, Managing Director and Chief Executive Officer. Company has also implemented any current laws and regulations company‟s update as per 3 March 2014 in the estate as well as in the mill in each of its departments, which is performed by Corporate Legal department. Company has a list of applicable legislation that corresponds to or is consistent with the company activities as provided in MI-005MDSUSTXII2012 dated 13 January, 2014. Company has also conducted analysis of applicable regulations periodically that correspond to activities taking place in the estate as well as in the mill. Company has appointed the Corporate Legal as a division in charge of updating the applicable regulations. Equipment Certification Company has obtained certification of its production equipment in accordance with the applicable legislation, such as: 1. 2 units of boiler, certification No.08566KV2006, 20 tons of steam per hour capacity with permitted operating pressure of 21 kgcm2, inspection test in January 2014 and No.05BOO58, SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 25of 105 20 tons of steam per hour capacity with operating pressure of 20 kgcm2, inspection test in July 2014 2. Steam Boiler a. Certification No 52566BU2012, tested and inspected in August 2012 b. Certification No 54566BU2012, May 2013 c. Certification No 51566BU2012, July 2012 d. Certification No 09566BU2006, Aprill 2013 e. Certification No 05B.0059A BPV, September 2013 3. Tractor, Certification No 05566PAA-TXI2012, November 2012 4. HIAB Static crane, Certification No 05566PAA-SCXI2012, November 2012 5. Skid loader, Certification No 03566PAASLXI2012, November 2012 6. Backhoe loader, Certification No 06566PAA-BLXII2012, December 2012 7. Pressure Vessel a. Certification No 02566BT-CXI2011, November 2012 b. Certification No 02566BT-CXI2011, November 2012 8. Gantry crane 01PAAGTCIX2013, inspection and test in August 2014 - Certification No 01PAAGTCI2012, inspection and test in August 2014 - Certification No 08566PAA-GTCIX2013, inspection and test in August 2014 9. Lightning arrester, inspected and tested in 21 August 2014 10. Steam Turbine a. Based on the approval of the Head of Social, Manpower and Transmigration Services of Muara Jambi Regency No. 10566PTP-TUIX2013 concerning Transfer and Correction of Turbine Use Approval, which has been inspected and tested on 01 September 2014. b. Steam Turbine Use Approval No. 27566tu2012, which has been inspected and tested on 2 January 2014 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 26of 105 11. 2 Gensets have had periodic inspection and test on 21 August 2014 12. Electricity has obtained approval No. 01566IL2011 13. Pressurized Vessels of 16 kgcm2 and 8 kgcm2 have been inspected and tested in November 2012 14. Lorry 56626PAA-PTVIII2014 dated 29 August 2014 15. Conveyor 14566PAA-PTVIII2014 and other elevators in August 2014 Licenses Company has obtained a license for the following specialized operators as regulated in laws and regulations: back hoe operators valid until 2017, 3 classes 3 OTC operators valid until 2017, tractor operators valid until 2017, skid loader operators valid until 2017 and farm tractor operators valid until 2017, and 2 class 1 boiler operators valid until September 2014. Company does not have safety experts for fire class A 1, class B 1, class C 5 and class D 12. This becomes an observation in the audit. Currently, the organization has a fire squad officer class C. The organization should submit evidence of registration with PJK3 related to license fulfillment of the rest. This non compliance has been issued as an observation no 14 at criteria 4.7.2. The designated first aid officer has not obtained a license from the local authorized agency as specified in the Regulation of the Minister of Manpower No. 15MEN2008. This has been issued as Non Compliance Minor No. 15 at criteria 2.1.2. Decree of designation of health examiner doctor No. Kep 45PPK-PNK3KKII2009 for dr. Zukri has not been renewed according to his workplace; for this purpose the organization has applied for an extension and has obtained a response from the Muarajambi Regency Manpower Service No. 566282Sosnakertrans dated 10 September 2014 stating that the application has been forwarded to the Directorate of Manpower of the Ministry of Manpower and Transmigration. Manpower There are still jobs contracted for works which should not be contracted based on the Regulation of the Minister of Manpower No. 19MEN2012 namely empty fruit bunches application work No. 391BBB-sawitSPK-PRO-SITE012014. The job of empty fruit bunches application has ended on 10 September 2014 and the 14 applicator officers were recruited by company as a casual worker based on their request on 10 September 2014. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 27of 105 Company has subcontracted a portion of FFB transportation job to an external party as in FFB transportation job No. 002BBB-SAWITSPK-PRO-SITEIII2014, but this work is not carried out by legal entities foundations, cooperatives or limited liability companies as set forth in the Regulation of the Minister of Manpower No. 19MEN2012. For this reason, this work will then be carried out by the cooperative Koperasi Harapan Bersama located at Suko Awin Jaya Village, which based on information from the notary PPAT Rahmadhani Hidayat SH, M.Kn. No. 02NOTIX2014 is currently in the process of arranging for its deed of establishment. Compliance status : Observation No. 14 Minor Non Conformity No. 15 2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights Estate Site Permit: Site Permit for the Estate is obtained through the Decree of the Governor of Jambi Number: 1011990 dated 31 March 1990. The letter contents is allocation of land for PT. Brahma Binabakti‟s rubber plantation, Location A Hulumendahara River and Location B Kaos River in Sekernan District, Batang Hari Regency, stipulate to allocate 6,500 Ha of land for PT. Brahma Binabakti‟s rubber plantation, respectivelly Location A Hulumendahara River covering an area of 3,500 Hectares located at KM.45- KM.60 to the right of Jambi Merlung Highway and Location B Kaos River covering an area of 3,000 Ha located at KM.42-KM.60 to the left of Jambi-Merlung Highway in Sekernan District, Batang Hari Regency. Plasma I Site Permit Site Permit is obtained through the Decree of the Head of Muaro Jambi Regency Number: 242011 dated 1 February 2011 concerning the granting of site permit for the development of palm oil plantations to PT. Brahma Bina Bakti Plasma I at Suko Awin Jaya Village and Tanjung Lanjut Village, Sekernan District, Muaro Jambi Regency totaled 7650 hectares. Plasma II Site Permit Site Permit is obtained through the Decree of the Head of Muaro Jambi Regency Number: 252011 dated 1 February 2011 concerning the granting of site permit for the development of palm oil plantations to PT. Brahma Bina Bakti Plasma 2 at Suak Putat Village, Tanjung Lanjut Village, Bukit Baling Village and Gerunggung Village, Sekernan District, Muaro Jambi Regency totaled 7650 hectares SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 28of 105 Mill Site Permit Site Permit for the Mill has been obtained based on the Decree of the Head of Land Office of Batang Hari Regency No. 41997 dated 17 March 1997 covering an area of ± 50 hectares located at Bukit Baling Village, Sekernan District, and Batang Hari Regency. Forest Area Release Permit A record of land acquisition and rights derived from the release of forest area with a permit is from the Decree of the Minister of Forestry No. 125Kpts-II1993, dated 27 February 1993. Company has made a land replacement of ± 6,220 hectares in the location of High Region II Batang Hari, Jambi Province. Exploitation Right HGU Approval Decision:  Decree of the State Minister of Agrarian Head of National Land Agency Number: 61HGUBPN95 dated of 2 October 1995 concerning the granting of Exploitation Right for 25 years up to 31 December 2020 to PT. Brahma Binabakti of 6,220 Ha of land located in Muaro Jambi Regency, Jambi Province  Decree of the Head of the Regional Office of National Land Agency of Jambi Province Number: 07HGUBPN.152014 dated 27 January 2014 concerning the granting of Exploitation Right for 35 years to PT. Brahma Binabakti of 453.3 Ha of land located in the Forest Group of Hulumendahara River - Kaos River, Batanghari Regency, and Jambi Province. Based on the regional spatial plan RTRW of Jambi Province as contained in the Regional Regulation No. 91993 the area is located in the Agricultural Cultivation area and based on the letter of the Head of Forestry Service of the Government of Jambi Province dated 28 October 2013 number: S.9450DishutBIPH.1.2X2013 and map attachment to the Decree of the Minister of Forestry Number: SK.727Menhut-II2012 dated 10 December 2012 the area is located outside the forest area the Area of Other Uses.  Decree of the Head of the Regional Office of National Land Agency of Jambi Province Number: 08HGUBPN.152014 dated 27 January 2014 concerning the granting of Exploitation Right for 35 years to PT. Brahma Binabakti of 563.783 Ha of land located in the Forest Group of Hulumendahara River - Kaos River, Batanghari Regency, Jambi Province Based on the regional spatial plan RTRW of Jambi Province as contained in the Regional SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 29of 105 Regulation No. 102013 the area is located in the Agricultural Cultivation area and based on the letter of the Head of Forestry Service of the Government of Jambi Province dated 28 October 2013 number: S.9450DishutBIPH.1.2X2013 and map attachment to the Decree of the Minister of Forestry Number: SK.727Menhut-II2012 dated 10 December 2012 the area is located outside the forest area the Area of Other Uses. Exploitation Right HGU Certificate :  HGU Certificate No. 2 with location in Bukit Baling Village, Sekeran District, Batang Hari Regency, Jambi Province. The area covered is based on the letter of measurement No. 1814 1996 dated 1 May 1996 of 28,200,000 m 2  HGU Certificate No. 3 with location in Bukit Baling Village, Sekeran District, Batang Hari Regency, Jambi Province. The area covered is based on the letter of measurement No. 1815 1996 dated 1 May 1996 of 34,000,000m 2 .  Revision of HGU certificate No. 3 on 20 November 1998 to become 33,902,275 m 2 due to the purchase of 97,725 m 2 by PGN.  HGU Certificate  HGU Certificate No. 94 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 68Muaro Jambi2014 dated 14 April 2014 is 135.63 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 95 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 69Muaro Jambi2014 dated 14 April 2014 is 157.01 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 96 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 70Muaro Jambi2014 dated 14 April 2014 is 17,29 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 97 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 71Muaro Jambi2014 dated 14 April 2014 is 16,94 Ha. The rights expiration date is 27 January 2049. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 30of 105  HGU Certificate No. 98 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 72Muaro Jambi2014 dated 14 April 2014 is 60,13 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 99 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 73Muaro Jambi2014 dated 14 April 2014 is 30,44 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 100 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 74Muaro Jambi2014 dated 14 April 2014 is 1,44 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 101 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 75Muaro Jambi2014 dated 14 April 2014 is 6 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 102 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 76Muaro Jambi2014 dated 14 April 2014 is 1,56 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 103 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 77Muaro Jambi2014 dated 14 April 2014 is 3,7 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 104 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 78Muaro Jambi2014 dated 14 April 2014 is 4,37 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 105 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 79Muaro Jambi2014 dated 14 April 2014 is 1,94 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 106 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 80Muaro Jambi2014 dated 14 April 2014 is 4,66 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 107 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 31of 105 Province. Area covered based on the letter of measurement No. 81Muaro Jambi2014 dated 14 April 2014 is 5,73 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 108 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 80Muaro Jambi2014 dated 14 April 2014 is 6,46 Ha. The rights expiration date is 27 January 2049.  HGU Certificate  HGU Certificate No. 77 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 51Muaro Jambi2014 dated 14 April 2014 is 10,414 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 78 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 52Muaro Jambi2014 dated 14 April 2014 is 7,266 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 79 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 53Muaro Jambi2014 dated 14 April 2014 is 2,910 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 80 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 54Muaro Jambi2014 dated 14 April 2014 is 93,467 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 81 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 55Muaro Jambi2014 dated 14 April 2014 is 45,196 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 82 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 56Muaro Jambi2014 dated 14 April 2014 is 2,197 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 83 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 57Muaro Jambi2014 dated 14 April 2014 is 3,5 Ha. The rights expiration date is 27 January 2049. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 32of 105  HGU Certificate No. 84 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 58Muaro Jambi2014 dated 14 April 2014 is 26,19 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 85 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 59Muaro Jambi2014 dated 14 April 2014 is 13,947 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 86 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 60Muaro Jambi2014 dated 14 April 2014 is 98,5 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 87 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 61Muaro Jambi2014 dated 14 April 2014 is 68,97 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 88 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 62Muaro Jambi2014 dated 14 April 2014 is 1,901 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 89 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 63Muaro Jambi2014 dated 14 April 2014 is 25,809 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 90 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 64Muaro Jambi2014 dated 14 April 2014 is 110,09 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 91 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 65Muaro Jambi2014 dated 14 April 2014 is 47,751 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 92 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi Province. Area covered based on the letter of measurement No. 66Muaro Jambi2014 dated 14 April 2014 is 2,697 Ha. The rights expiration date is 27 January 2049.  HGU Certificate No. 93 dated 25 April 2014 with location in Muaro Jambi Regency, Jambi SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 33of 105 Province. Area covered based on the letter of measurement No. 67Muaro Jambi2014 dated 14 April 2014 is 2,978 Ha. The rights expiration date is 27 January 2049. Plantation Business Permit The Company has obtained the Letter of Approval of Changes in Plant Type and Processing of the SPUP Plantation Business Registration Letter No. HK.350425Dj.Bun.5VI2001 PT. Brahma Binabakti from One-Door Integrated Service Agency of Muaro Jambi Regency number: 50301BPTSP2013 dated 20 November 2013 from originally Rubber commodity and Latex Processing into rubber and palm oil commodities along with oil palm processing with a 60 tonneshour capacity with a total area of rubber plants of 2,559 Ha and oil palm of 3,661 Ha. Plantation Business Permit of Plasma 1 Decree of the Head of Muaro Jambi Regency Number: 287Kep.BupBPTSP2012 dated 18 June 2012 on the granting of plantation business permit for cultivation with other development patterns which are mutually beneficial, strengthening, dependent between growersfarmers and plantation company to PT. Brahma Bina Bakti Plasma 1 covering an area of 6,830 hectares located in Suko Awin Jaya Village and Tanjung Lanjut Village, Sekernan District, Muaro Jambi Regency. Plantation Business Permit of Plasma 2 Decree of the Head of Muaro Jambi Regency Number: 177Kep.BupBPTSP2012 dated 20 April 2012 on the granting of plantation business permit for cultivation to PT. Brahma Bina Bakti Plasma Pemayung covering an area of 3,500 hectares located in Suak Putat Village, Tanjung Lanjut Village, Bukit Baling Village and Gerunggung Village, Sekernan District, Muaro Jambi Regency. Company has an Internal Memo No. 027MI-DIRXII2012 dated 12 December 2012 that regulates the boundary marks of HGU. Company has conducted the maintenance of HGU pegs which is contained in the report of construction and maintenance of HGU boundary marks of August 2014 period. The Company has drawn a map of HGU pegs according to the Internal Memo issued by company. To ensure the HGU pegs, a field visit was made to the HGU pegs and the pegs were sampled that include: 1. HGU peg KP 51 PT. BBB with coordinates UTM 0316067; 9852040 2. HGU peg KP 53 PT. BBB with coordinates UTM 0316626; 9851764 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 34of 105 3. HGU peg KP 89 PT. BBB with coordinates UTM 0315830; 9851660 4. HGU peg KP 90 PT. BBB with coordinates UTM 0315962; 9851655 Based on the field check, data of the coordinates of the pegs conforms to the data of coordinates in the HGU certificate and conform to the data of coordinates of monthly monitoring carried out by company. Compliance status : 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. Company already has a documented mechanism of land dispute resolution. It is listed in the internal memo MI of Stakeholder Complaint Handling in the Site Estate Mill No. MI- 005MDSUSTX2012. In addition, SOP of Stakeholder Complaint Receiving and Resolution No. 106899TAPPRO-CSR-HOVI13 is also already established which is accompanied with a flowchart that starts from identification to report preparation process, valid since 13 June 2013. Its scope includes: complaints from stakeholders, complaints on contracts, and land dispute resolution. Company has data records on disputes with the local community and their settlement status. The results of verification interview with a Malay Jambi Customary Leader Rozali HS suggest that there is no communal land or customary land within company‟s site. List of land conflictdispute: - A land conflictdispute with the community of Tanjung Laut Village submitted by the NGO FMP and resolved in 2013 both through the local government and the law. - A land claim filed by Parjin Suko Awin Jaya Village covering 2,992 M2 located in the Afd F Blok E1.3 and already resolved on 11 February 2014. Compliance status : 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 Company already has a long term projection blue print 2013-2036. In the blue print company has incorporated the estate and mill social and environmental factors and best practices. For example, for 2014 the target mill yield is 23 for main estate, 22.5 for plasma, 21 for external fruits and in SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 35of 105 general 4.7 for KER. The data does not show a trend of rise in OER CPO from 2014 – 2036. The OER is flat i.e. 23. Mill cost per FFB for 2014 is 5 per ton of FFB. It is recommended that company reviews the OER target so that there is a rise in OER trend to show a continual improvement. This recommendation has been raised as an Observation No. 20. The annual plan is presented in the 2014 Budget report containing the production cost of the overall operation. Company does not have replanting plans for the next 5 years. The oldest planting age is 1996 for which replanting is planned to be done in the next 7 years to come. The data does not show a trend of rise in OER CPO from 2014 – 2036. The OER is flat at 23. It is recommended that company reviews the OER target so that there is a rise in OER trend to show a continual improvement. It is recommended that the proposed certification process of cooperative Akso Dano and cooperative Dano Bangko is incorporated in the co mpany‟s long term plan Blue print according to the RSPO certification system requirements. These recommdation has been raised as an observation No. 20. Compliance status : Observation No. 20 4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS 4.1 Operating procedures are appropriately documented and consistently implemented and monitored Company has SOP‟s ranging from land opening to harvesting that is listed in the Agro Persada Triputra Group Technical Guidelines on Agronomy approved by the Groups CEO Arif P. Rachmat. For example, the technique of applying fertilizer for TBM, the fertilizer is spread 20 cm from the base to the end of the canopy around the palm circle by walking around the circle. For TM, the fertilizer is applied onto the frond pile in the space between two palm rows where pile fronds are piled to which the fertilizer is applied. To ensure the fertilization techniques, a field visit was conducted to Block B-7 with NPK fertilizer. During the field visit, interviews were conducted with the workers applying fertilizer where company provides personal protective equipment and working toolssuch as goggles, gloves, masks, apron, boots, and buckets. Company also gives extra fooding of milk which is given in the morning before performing the work. Company also conducts training of fertilizing workers on a good fertilizing. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 36of 105 For harvesting, the SOP lists personal protective equipment that should be worn including shoes, helmets, gloves, sickle sheath, and glasses. Tools such as bucket and sackcloth lined TPH. The SOP specifies that the harvest rotation is 67 and using fixed working plots ancak where the plot number is made permanent. The SOP also specifies that the stalk should be V- or frog mouth shaped and the fruit is arranged in 5 rows. To ensure the harvest technique, a field visit was conducted to Block C-6. During the field visits, interviews were made with the workers where personal protective equipment and working tools are provided by the company including wheelbarrows, sickles, goggles, gloves, boots, and helmets. Company also conducts training of harvesters on a good harvest. At the time of the visit in Block C-6 the harvest rotation on the block is 6 days and the working plots used is a fixed plot. The condition of palm circle and TPH is clean where the fruits is arranged in 5 rows and loose fruits are supported by sacks and the stalks of fresh fruit bunches are cut in V or frog mouth shaped. To ensure spraying activities, a field visit was conducted to Block A-13. There were 8 employees working. During the field visit interviews were conducted of sprayer where personal protective equipment and working tools are provided by the company including knapsack, glasses, gloves, apron, and boots. Company also conducts training of sprayers on a good spraying. Company also gives extra fooding of milk. The jerricans have been labeled dangerous and there is a containment bucket during pouring herbicide into the knapsack to prevent herbicide from spilling into the ground. Company has conducted inspection or monitoring of its operations through internal audit mechanism on 2-5 April 2014 resulting in 29 findings. Company has followed up on the results of the internal audit findings. Company has produced monthly reports regarding the estate activities where the latest report is the monthly reports for August 2014. The report provides information on planned and actual work in August 2014. MILL Company has established SOP for production process from receiving the fruits, producing CPO PKO to loading the CPO into CPO Oil Tanks. The standard of fruit received is the agronomy and RND test results. The SOP includes: Weighbridge POM-SOP01, Revision: 00 dated 1 June 2012, CPOPK Storage Delivery POM-17, FFB Quality POM 16, Loading Ramp POM-SOP02 Sterilization Station POM- SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 37of 105 SOP03, Thressing POM-SOP04, Revision: 0, 1 June 2012, Pressing Station POM-SOP05, Clarification Station POM-SOP06, Depericarping POM-SOP07, Kernel Recovery Station POM- SOP08, There are also SOP for support processes, including utility; Boiler House POM-SOP09, Power Plant POM-SOP10, Water Plant POM-SOP11, Waste treatment and Land Application POM-SOP12, Empty Fruit Bunch Utilization POM-SOP13, Environmental Management Program POM-SOP 21, Solid Waste Treatment POM-SOPOP 001, Revision: 01, dated: 1 July 2012 There are work instructions on mill equipment maintenance and process of each production machine. SOP is prepared by TAP Mill Development Team, in which engineering is also covered. The SOP is adequate to establish the targeted CPO quality, one that become observation is that page 1 and 2 of SOP Quality have POM-SOP01 written in them owned by weighbrige which should be numbered POM-SOP16. This has been raised as an observation No. 3 Company has development activities by the management and resulting in nonconformity findings and corrective actions have been made adequately. There are the results of Mill Audit findings and recommendations in June 2014, the contents are nonconformity findings, root causes, impactsrisks, follow up actions, auditee corrective action, due date, and PIC. Company has shift production reports prepared by mill assistant, press station reports, daily production reports, power house station reports, reports on the use of diesel genset 1 2, boiler station reports [there are estimated fuel consumption solid waste], decanter log sheet, clarification station reports on oil tank drain control check sheet, sterilizer station reports, sterilizer pressure and termperature control reports, hoist crane reports, water treatment station reports, empty bunch press station reports, kernel station reports. Company has year 2014 activity plans, one of which is covering the training of hoisting crane and static crane operators in October and November. Company has 2 hoisting cranes and 2 operators and have K3 license from manpower related agencies. There is a one year policy which is the guidance of a one year planning with detailed activity plan. Compliance status : Observation No. 3 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 38of 105 Company already has Soil Analysis SOP: 69PTVIII2014 and Leaf Analysis SOP: 50PTVIII2014. Company has performed a leaf analysis on 30 July 2013 with a total of 84 sample packs that are sent to the Research Department of PT. Sarana Inti Pratama in Pekanbaru. Company has conducted sampling for soil analysis on 22 April 2013 from block C-1, C-2 and D-1 at a depth of 0-15 cm and 15- 45 cm with the total sample of 6 packs that are sent to the Research Department of PT. Sarana Inti Pratama in Pekanbaru and analysis of the soil samples has been made. Recommendations for fertilization for 2015, the company has sent a total of 12 packs of soil samples and 105 packs of leaf samples for analysis by the the Research Department of PT. Sarana Inti Pratama on 7 July 2014. Company has made recommendations for fertilization for 2014 based on the results of leaf analysis. Fertilizing realization TAP COM 2 for 2014 up to August 2014 is 9.513,58 hectares. In January - August 2014, Company has applied empty fruit bunches with a total of 18.079.150 kg. Compliance status : Conform 4.3 Practices minimize and control erosion and degradation of soils. Company has soil type maps, topographic maps and slope steepness maps at 1: 100,000 scale. Company has a strategy for planting on a given sloped area as specified in land conservation SOP including rorak construction, top soil applications, horse shoes and conservation terraces. Company has SOPs for roads and bridges including land contours, land roads and swamppeat land and road maintenance and pavement. Data of road pavement program up to August 2014 is covering a length of 2,010 meters, while road maintenance using a grader and compactor up to August 2014 is 40,179 meters. Company has technical guidelines on floodgates and dams aimed at maintaining the level of water at 60-70 cm from the ground surface. There are no peat lands in the field. Company has a marginal land and critical land management strategy as specified in land conservation SOP including rorak construction, top soil applications, horse shoes and conservation terraces. The realized horse shoe for 2013 is totaled 78 trees, while the planned horse shoe for 2014 is 780 trees. Compliance status : Conform 4.4 Practices maintain the quality and availability of surface and groundwater SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 39of 105 Company issued a Standing Instruction Number: 048SI-DIRVIII2014 dated 7 August 2014 regarding implementation of remediationrecovery program to improve the value and function of HCV area. Company has conducted the management activities of marking palm trees in the area designated as a river border 20 meters to the right and left from the river edge by giving palm trees a yellow circular sign. During a visit to the border of the Suak Putat river in the afdeling A Block 5, the proof of palm tree markings was found. Company has identified the source of water in the estate area, i.e. Suak Putat River, Kaos River, and MendaharaRiver. The management and maintenance of water sourcerivers have been carried out by posting warning signs prohibiting poisoning, dumping palm fronds, and spraying chemicals with a limit of 20 m from the edge of the river course ± 2 trees. Water management programs include river quality testing carried out to Kaos River, Mendahara River, Putat River, and Sekawan River. Test parameters refer to Government Regulation No. 822001. The final test results on Semester 1 – June 2014 still meet the quality standard requirements for Kaos River and Suak Putat River. The results of measurement of Mandahar River exceed the environmental quality standard BML for BOD 3.22 whilst standard reference is 3.0. The BOD value that exceeds the BML is due to excavation activities by local residents. So far, company has conducted river tested by using samples from upstream of the river. Company should also measure the river water quality by using samples from downstream of the river.This has been issued as an observation no. 04. In managing mill waste, Company has a WWTP consisting of 13 ponds. None of liquid waste generated is discharged into a water body; instead it is utilized and applied to the soil. The quality of liquid waste is tested on a monthly basis by the Jambi Province BLHD testing laboratory which refers to Decree of the Minister of Environment No. 2829 of 2003 Governor Regulation No. 20 of 2007. The results of test of liquid waste BOD is still below the quality standard requirements. When land application is made there is monitoring well 1 in the Estate E.5.1, monitoring well 2 in the Estate E.5.5, monitoring well 3 in the Estate E.6.3, resident well 1 in the Estate E.5.2, and resident well 2 in the Estate E.5.4. Testing of monitor wells and a resident well is carried out every 3 months for monitoring well 1 and 2; resident well 1 and 2. The testing agency is Jambi Provincial Government, Bapedalda, and Environmental Testing Laboratory. The mill‟s source of water comes from the Sekawan River. Surface water exploitation permit has been available through Decree of the Head of Energy and Mineral Resources Service of Muaro Jambi Regency No. 012012 concerning the Granting of Permits to Extract Surface Water to PT Brahma Bina SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 40of 105 Bakti. The maximum permitted is 50 literssecond, dated 4 April 2012 which is valid for 1 year. Company has arranged the extension of Surface Water Extraction Permit which is contained in a letter dated 7 October 2013 No. UM.03.02BWSSUMVI5572013 from the Director General of Natural Resources of River Regional Center Sumatera VI of the Ministry of Public Works on Applying for Renewal of Surface Water Extraction Permit and known by the Head of River Regional Center Sumatera VI. Company also has a backup water source i.e. bore well and has been licensed with Decree of the Head of Energy and Mineral Resources Service of Muaro Jambi Regency No. 012012. The letter concerning Groundwater Extraction Permit to PT Brahma Binabakti, the maximum permitted level of 50 literssecond, dated 4 April 2012 which is valid for 2 years. Company already has Decree of the Head of Energy and Mineral Resources Service of Muaro Jambi Regency No. 052014 concerning the Granting of Groundwater Extraction Permit to PT Brahma Binabakti and No. 082014 dated 28 March 2014 with a validity period of 3 years. The extension of surface water use permit in a letter dated 7 October 2013 from the Director General of Natural Resources of River Regional Center Sumatera VI of the Ministry of Public Works is on going process in the process of data verification. This permit is not yet issued because there is a change of authorities in issuing permits in the government agencies that there is still a difference of understanding between the government agencies. Company still can make use of surface water by paying the taxes each month. Mill There are two sources of water into the mill. Firstly, from surface water sources extracted from Sekawan River and secondly by using bore wells in the mill. There is the use of surface water of Sekawan River which is pumped to water treatment plant then is used in the mill and residential area, and each has a flow meter. There are the results of water use for boiler water, process water, and domestic water. There is a calculation of the volume of water used per ton of TBS, the KPI is 1.5 m 3 ton of FFB. Every month a report is given on water use efficiency associated with the process and the boiler. Sampling data of mill‟s water use in August 2013 is 49.437 m 3 for processing 33.630 ton FFB so that efficiency is 1,47 m 3 ton of FFB. Water use efficiency still complies with the KPI. Compliance status : Observation No. 4 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Company has the SOP for pest and disease system. Company also has an early warning systemEWS through the OPT observations at regular intervals. Company also has a team of trained pest and disease controllers, with training conducted internally by the assistant and foreman in SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 41of 105 respective afdeling performing monitoring and census of pest and diseases. Company has conducted the census of nettle caterpillar attack for the period of August 2014 where from census data the average number of caterpillars in a single tree is 6.57 per frond which is categorized as minor case in the SOP. Company conducts manual control by hand picking. Company also has planted a host species including Turnera surbulata, Antigonon leptosus and installation of owl Tyto alba cage. The realization of planting up to August 2014 is 615.08 hectares for Turnera surbulata and 54 stands for Antigonon leptosus. An owl Tyto alba cage installed up to August 2014 is 30 and the monitoring has been conducted. Data shows that 7 cages are identified to show a sign of OWL presence. Company has an activity plan for the installation of owl cage up to December 2014 i.e. 144 cages. Company also breeds owls where in the first phase there are 9 owls that have been released and in the second phase there are 6 owls still in breeding. During field trips, there were palm trees found uprooted due to Ganoderma. From August 2014 census and monitoring data, the trees have positively been identified to have Ganoderma and have been followed up by making isolation trenches to cut the palm rooting to prevent from infecting other palm trees and these mitigation measures have conformed to the existing SOPs. Data of the results of rat attack inspection in August 2014 from fruit sorting at loading ramp shows 3.24. Company should speed up the construction of gupon owl cages planned up to the year 2015 so that the rate of rat attack in the field can be reduced. This has been raised as an observation No. 1 Company has appointed a joint team of pests and plant disease in each afdeling through the stipulation of Estate Manager dated 14 August 2014. The EWS team has been given training and the evidence shows that the training is carried out lastly on 20 December 2014. The training evidences are training photos and attendance list. Company also has a list of chemicals use according to the WHO classification. Company has conducted pesticide toxicity monitoring for August 2014 such as Prima Up 480 AS with active ingredient of Gliphosate isopropylamine salt of 0.0000036675 kgLD50ton and 0.1285213332 literhectare. Compliance status : Observation no. 1 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 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 42of 105 identify alternatives, and this is documented Company has a list of agro-chemicals use according to the WHO classification for the period 2014 that includes: 1. Herbicide  Metaprima 20 WDG Methyl metsulfuron belonging to classification U  Starlon 665 EC Triklopir belonging to classification II  Prima up 480 AS Isopropilamina gliphosat belonging to classification III 2. Insecticide  Acephate Asefat belonging to classification II  Ratgone Brodifakum belonging to classification II 3. Rodenticide  Mitac 200 EC Amitraz belonging to classification II Company has records of chemicals use. As an example, for August 2014 company has applied Prima Up Isopropilamina gliphosat totaled 558.92 liter and Metaprima Methyl metsulfuron to a land area of 1,548.59 hectares with work items of CPT spraying, spot spraying and weed spraying. Company has conducted spraying training for staff, foremen and employees working as a sprayer. Company has a policy of no longer using paraquat which is recorded in an MI Internal Memo No. 001TAPMIN-EST-HOII2013 concerning Paraquat Herbicide Booking Termination dated 22 February 2013. Company has not used Paraquat since March 2013. Pesticide packaging waste is stored in hazardous waste warehouses and then transported by a licensed third party. Before being stored in the warehouse, used pesticide packages are washed and rinsed in advance 3 times in the washing area. Activities of used pesticide package management are contained in environmental management program POM-SOP 21, Solid Waste Management POM-SOPOP 001, revision: 01, date: 1 July 2012. Company has the minutes of used pesticide package handover to hazardous waste TPS. Company manages used water from used pesticide package washing by flowing the water to a collection pond and the water can be reused for plant spraying by mixing with chemicals. The storage area of pesticide packaging already has safety signs in accordance with regulatory requirements. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 43of 105 Based on Regulation of the Minister of Manpower No. 03MEN1986, agricultural chemical handlers are required to have their health examined twice a year. Company carried out medical examination for chemical handlers spraying, mixing personnel, fertilizer. on 24 April 2014 and has reported it to the Manpower Service of Jambi Province. The examination is planned to be conducted in October 2014. The medical test is found satisfactorily. There has been a spraying instruction work IK-12PALMBB-2014 that prohibits pregnant women and nursing mothers to perform spraying job. During the audit to afdelling D, from the 4 female sprayers, it was found none of them is breastfeeding or pregnant. Company distributes pregnancy testers every 3 months as prevention and to detect pregnancy in female workers. The system has been improved since September 2014 based on the company doctor‟s work plan that pregnancy test is carried out every month. Compliance status : Conform 4.7 An occupational health and safety plan is documented, effectively communicated and implemented Policy Company has established a safety and environmental policy which was signed by the President Director on 5 February 2013. This policy has included a commitment to accident and work related disease prevention, regulatory compliance and sustainable improvement. Safety Program and Target January to August 2014 achievement for mills and estates is 0 for SR and 0 for FR. Safety program is listed in one year policy and detailed in the activity plan 2014 The company has delivered PPE on 26 April 2014 in afdelling E and in the mills based on the minutes dated 05 September 2014. From interviews and observations of 4 female herbicide sprayers in afdeling D, they have been equipped with PPE i.e. masks, safety glasses, apron, rubber gloves and rubber boots in good condition. Based on the observations in the mill‟s loading area there is still external workers that do not use safety shoes while unloading the FFB. To follow up this case, company has invited the Management of Akso Dano along with the chairman of Plasma group fostered by KUD Akso Dano cooperative into a meeting to be held on 18 September 2014 on dissemination of PPE for workers entering the mill area of PT. Brahma Binabakti. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 44of 105 Company has established work instructions and procedures of work permits in dangerous areas in chapter IV of SOP TAPSOP120-SHE0001. For dangerous jobs such as welding job above the height of 2.5 meters, boiler furnace repairs, tank repairs, and working at location lower than 2.5 meters. In the mill it was found that the packing seal from boiler to silencer was damaged that gave rise to noise and the boiler furnace door lock was damaged. In this case company has made a repair based on the minutes of No. 2BBBBA-MIL-SMX2014 dated 11 September 2014. Company has set up P2K3 which was approved by the Manpower Service of Jambi on 23 August 2011. The Secretary of P2K3 has a qualification of AK3 which conforms to the applicable laws and regulations Ministerial Regulation No. 04men1987. During 2014 the P2K3 has routinely held monthly meetings and reported its activities regularly every 3 months to the Manpower Service from April 2012 to June 2013. Since the P2K3 Secretary is not always present in the site, a new AK3 working on the site should be appointed and trained. This suggestion has been raised as an observation no. 13. Company has a policy related to the granting of worker social security facilities jamsostek as regulated in Jamsostek Policy document No. Doc. TAP-PRHRD-GN055-1112-0 issued 1 November 2011 and approved by the CEO of PT. Triputra Agro Persada, as the parent Company. Point d. 1.1 says that Company will include employees in the Jamsostek social security Program for package A only, namely: work accident insurance JKK, death insurance JK, and old age insurance JHT. Point d. 1.5 says that all employees will be included as a participant in the Jamsostek scheme from the time they have passed probationary period to become permanent employees KT or after having worked for three 3 months for contract workers. Point d. 1.6 says that employees under probationary period and casual workers KL are not included in the jamsostek program, but in case of work accident, or death they will remain become the company responsibility. For Estate Casual Workers, since September of 2014 they have been registered to the Manpower BPJS for accident insurance and death insurance as in a letter of Manpower No. BPJS B8895092014 dated 09 September 2014 As for JPH program company runs its own program, because health maintenance insurance that is run internally is considered better. See explanation on sub 4.1. Sampling for a worker named A. Kodir has his base salary cut by 2 by jamsostek. Jamsostek payment of August 2014 has been made on 03 September 2014 theough BNI Jambi for 670 workers SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 45of 105 from data, total number of permanent worker is 694 24 workers are in probationary period. For mill workers, the BPJS of July was paid for 150 out of 164 workers, because 12 staffs have their BPJS payment made in Jakarta. Company has conducted environmental monitoring on 25 March, 2013 and 15 April 2013 covering noise and chemical factors and on 23 August 2014 covering noise, ISBB heat stress, vibration, and illumination. Medical examination for chemical handlers was held on 24 April 2014 and the result is found satisfatorily. The result has been reported to the Manpower Service of Jambi Province and the workers in the mill. Audiometry examination was conducted in August 2014. There were 8 people suffering from mild conductive deafness and a recommendation for consultation has been made by dr. Zukri to the specialist doctor. During audit, the test result from specialist is not yet published. Decree of designation of health examiner doctor No. Kep 45PPK-PNK3KKII2009 for dr. Zukri has not been updated to his workplace, in this case the organization has applied for an extension and an answer has been received from the Manpower Service of Muarojambi Regency No. 566282Sosnakertrans dated 10 September 2014 stating that the letter has been forwarded to the Directorate of Manpower of the Ministry of Manpower and Transmigration. Health care service of workers and their family members children and spouses is carried out by the estate polyclinic polibun, which is located in the estate office, Suko Awin Jaya Village. The polibun has obtained a license from the Health Service of Muara Jambi Regency i.e. No. No. 445004SIKPDinkes2011, valid until 15082015. The polibun is led by a physician named dr. Zukri Nasution with SIP-DU No. 445006SIP-DUDinkes2013, and 1 paramedic named Khotibul Iman with a practice license No. 445001SIKPDinkes2013. Both the doctor and the paramedic have had hiperkes certificate with registration number: No. 17.525DH-I07 and No. 10.495PM-I09, respectively. Polibun has an observation room, a unit of ambulance, and sufficient supplies of good quality drugs. Monitoring of the expiration period of the drug has been carried out, the drugs that will expire in 3 months is marked on the drug list. Medical waste from polibun is sent to Abdul Manap Hospital Jambi. Periodic examinations are carried out every 6 months that include cholinesterase and audiometry. The examination is conducted for 107 estate employees including the sprayers in April 2013 and October 2013. Hazard Identification and Risk Control SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 46of 105 Identification of Hazards and Assessment of Risks Environmental Aspect Identification Environmental Impact Evaluation IBPR TAPFO120-SHE0001-12, rev. 0 have been developed and established for both Estate and the Mill. IBPR has covered all activities. Safety training has been covered in the activity plan 2014. Company has carried out training of first aid officers on 22 August 2014 internally and hazardous waste handling on 14 June 2014. Company has obtained a license for specialized operators as regulated in laws and regulations such as back hoe operators, valid until 2017, 3 OTC operators class 3, valid until 2017, tractor operators, valid until 2017, skid loader operators, valid until 2017, farm tractor operators, valid until 2017, and 2 boiler operators class 1, valid until September 2014. The point that becomes audit observation is that company does not have 1 safety officer of class A fire, 1 of class B, 5 of class C and 12 of class D, but the company currently has one personnel of class C. Training of class D has been planned to be conducted in September – December, but not yet carried out. The organization should propose for the training to related PJK3. This case has been issued as an observation no. 12 The follow up, Company has established a training program up to 2018 of fire safety officer. Company has established K3L SOP BBBSOP120-SHE0001 and signed by the Managing Director as per 2232012. SOPs related to fire mitigation are listed in: • Subsection III. 8. Emergency Response and Preparedness for Land Fire, which is specific to land and forest fires. • Subsection III. 8. General Emergency Response and Preparedness Team TKTD-General”, covers: fires, pollution, riots, earthquakes, floods and others. This applies in the mill and the estate. The executor is TKTD. • Already disseminated to staff level in both the estate and the mill. Approximately 50 bundles. Dissemination of K3L SOP was carried out through the issuance of an Internal Memo No. MI- 001MDSUSTIX2012, by Sustainability Division, which was approved by the CEO Mr. Arif Rachmat, so as to come in force across the Triputra group. The organizational structure of Emergency Response and Preparedness Team TKTD of both the estate and the mill has been established, which was signed by the Estate Manager and the Senior Mill Manager. The structure of TKTD consists of: General Chairman of TKTD directly seated by the Unit Manager, Secretary, Chairmen of TKTD who are Adm Division, Workshop Division, and FieldMill SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 47of 105 Division. Each respectivelly consists of: Emergency Mitigation Task Force, Communication, Rescue, Security, Paramedic, Investigation, and Remediation and Rehabilitation. Company has defined their respective job description. In its implementation, company held land fire simulation on 25 September 2013 and 5 September 2014, and their evaluation have been made, and mill fire simulation on 29 August 2014. Training was given to TKTD, i.e :  Mill Unit: 1 first aid, dated 382013 for Members of TKTD Paramedics and some other TKTD members, by Polyclinic doctor. 2 fire fighting, dated 30012013. Subject of the training was the use of light extinguishers APAR.  Estate Unit: 1 first aid, dated 162013 for Members of TKTD paramedics and some afdeling representative staff, delivered by company doctor. 2. Training in the use of light extinguishers APAR, dated 25092013 followed by fire handling simulation in Afd. B. During a visit in the afdeling D, sprayers have been provided with first aid kit, which is kept by sprayer foreman. This foreman according to his own statement had received first aid training. First aid officer in the field is the foreman. During a visit in the afdeling D the first aid officer for sprayer is the foreman and during a visit to the afdelling H the first aid officer was Harvest Foreman. Both the foremen are on the field and carry a first aid kit. The investigation of incident is regulated in K3L SOP of TAPSOP120-SHE0001 Chapter IV. Based on the results of sampling of accident in June 2014, an investigation has been conducted. In 2014, based on the organization ‟s records there has not been an accident that results in lost work days. Compliance status : Observation no 12 13 4.8 All staff, workers, smallholders and contractors are appropriately trained. Company already has a list of contractors that consists of 5 mill contractors and 12 estate contractors. Mill contractors consist of empty bunches application contractors and FFB contractors. Sampling of empty bunches application contractors is number SPK 391BBB-SAWITSPK-PRO-SITE012014. Company has developed a training program for the workers in both the mill and the estate in 2014. For the plasma, company also has had the dissemination program 2014. For the estate, the training that has been carried out such as oil palm nursery training on 04 April 2014, fertilization training on 03 July 2014, spraying team training on 29 August 2014, and spraying SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 48of 105 PPE use training. From the results of field interviews in the afdeling D of sprayers it was found that they had received training in spraying procedures. For workers in the mill, the training has been implemented, such as FFB grading methods on 14 and 15 February 2014, loading ramp and sterilizer on 27 March 2014. For the plasma the training has been implemented i.e. fertilization on 17 April empty fruit bunches application and FFB grading on 25 August 2014. Compliance status : Conform 5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY

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