Trendy 20 WP Conclusion : Conform

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 49of 164

4.6.2 Records of pesticides use including active ingredients used and their LD50, area

treated, amount of active ingredients applied per ha and number of applications shall be provided. Major Mixing of herbicide dose is set on PPG GMO ASD 42 SOP. The company have a pesticide application program. The company has provided a recording of pesticide that was used includes active ingredients contained in it, LD50, the target area of application, as well as the dosage. The active ingredient used in the eradication of plant pests, such as deltamethrin, glyphosate isopropyl amine, and methyl metsilfuron. Conclusion : Conform 4.6.3 Any use of pesticides shall be minimised as part of a plan, and in accordance with Integrated Pest Management IPM plans. There shall be no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Major The Company has established SOP Integrated Pest Management Guidelines No. PPGGMOASD03SOP. SOP also explain how to use of PPE in the handling of chemicals and adequate working equipment to avoid environmental pollution. The Company has had list of pesticides used. The Company also minimize the use of pesticides for preventing disease on plant except the level of pests and diseases over the threshold that has been set. Since February 2015, The Company was no longer using the pesticide Paraquat dichloride. Types of pesticides which is used today by companies include: a. Agristik b. Garlon c. Lindomin 865 SL d. Roundup

e. Trendy 20 WP Conclusion : Conform

4.6.4 Pesticides that are categorised as World Health Organisation Class 1A or 1B, or that

are listed by the Stockholm or Rotterdam Conventions, and paraquat, are not used, except in specific situations identified in national Best Practice guidelines. The use of such pesticides shall be minimised and eliminated as part of a plan, and shall only be used in exceptional circumstances. Minor The Company had a complete list of chemicals that classified as WHO 1A, 1B, and Stockholm conventions. Currently, The Company is not using paraquat. Non Paraquat Herbicide Use Policy has SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 50of 164 been set by the President Director on April 15, 2015. Conclusion : Conform 4.6.5 Pesticides shall only be handled, used or applied by persons who have completed the necessary training and shall always be applied in accordance with the product label. Appropriate safety and application equipment shall be provided and used. All precautions attached to the products shall be properly observed, applied, and understood by workers see Criterion 4.7. Major Mechanism handling of chemicalspesticides have been set in SOP Chemical Hazards Communication no. PASPPGEHS28SOP rev 0. These procedures include procedures for handling chemicals, first aid in case of accidents related to chemicalspesticides, MSDS, labeling packaging chemicalspesticides, training for workers who are dealing with substance chemicalspesticides, as well as, procedures for storage of chemicalspesticides. Training on chemical hazards is done every year. On May 31, 2017 there was a training record given to the spray unit team and the fertilizer unit team. The training was attended by 16 spray unit team employees. During the field visit, the workers have been using a complete PPE from cartridge masks, apron, glasses, shoes, rubber gloves. Based on interviews with workers, if the PPE is damaged then immediately replaced by reporting first to the foreman. The company already provides about 10-25 of the stock of PPE located warehouse estate. Workers know that chemical used is roundup container of chemicals already equipped with MSDS. Estates provide spray shed facilities such as bathroom and washing facility and room for keeping PPE and Overalls appron after used and assigned person for PPE cleaning after work. This is to ensure all pesticide workers come and go home are clean and safely. Conclusion : Conform 4.6.6 Storage of all pesticides shall be according to recognised best practices. All pesticide containers shall be properly disposed off and not used for other purposes see Criterion 5.3. Major SOP Waste Management PAS PPG EHS 32 SOP rev. 1 has been available since July 1, 2016. The procedure has identified the categories of waste, waste sources and management methods. Category types of waste that have been identified include: - Waste water mill - Domestic waste water - Waste from Mill empty bunch, solid decanter, fiber, kernel shell, boiler ash - Other organic wastes wood, twigs and leaves SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 51of 164 - Other inorganic wastes used bags, plastic, used beverage cans, scrap tires and scrap metal - Boiler exhaust emissions, gensets, vehicles heavy equipment and methane gas from WWTP - Hazard liquid waste used lubricating oil, diesel fuel, sludge, laboratory analysis, expired liquid chemicals - Hazard solid waste used chemicals packaging, used batteries, used filters, used fabrics, hazard material B3 contaminated gloves, B3 contaminated packaging, used batteries, used light bulbs, used neon, paint cans and thinner, used toner catridge, Ribbon typewriter printer. - Medical waste syringes, used gauze, used medical gloves, expired drugs and pathological waste Conclusion : Conform

4.6.7 Application of pesticides shall be by proven methods that minimise risk and

impacts. Minor Organization has had written procedures related to use pesticide substance in SOP PPGGMOASD28SO P “Procedure of weeds control chemically” and conducted training as for this SOP. Training on chemical hazards is done every year. On May 31, 2017 there was a training record given to the spray unit team and the fertilizer unit team. The training was attended by 16 spray unit team employees. Conclusion : Conform 4.6.8 Pesticides shall be applied aerially only where there is documented justification. Communities shall be informed of impending aerial pesticide applications with all relevant information within reasonable time prior to application. Major There is no record that shows the company has conducted pesticide application aerially. The company does not have equipments and facility to apply pesticide aerially aeroplane, airfield Conclusion : Conform 4.6.9 Maintenance of employee and associated smallholder knowledge and skills on pesticide handling shall be demonstrated, including provision of appropriate information materials see Criterion 4.8. Minor The Company has had SOP about Competence, Awareness and Training. The Company has been made training plan annually periode June 2017 - July 2018 both for estate and smallholders. There is training form needs assessment that will be compiled by each of HRD unit before it is made into training plan. Training plan already contained aspects of K3 healhty and safety, environment, best practice, and management aspects. Training is conducted both internally and externally. Training at Mill in the period 2016-2017 consists of 45 internal training programs and 10 external SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 52of 164 training. Some of the documented trainings include Electrical K3 training in November 2016, First Aid for 7 people held on 12-14 December 2016, 10 class D class fire training on 27-29 Oct 2015, K3 field scaffold 15-19 August 2016 3 people , RSPO principles training on July 12, 2017 and on July 10, 2017 supply chain management training. Conclusion : Conform 4.6.10 Proper disposal of waste material, according to procedures that are fully understood by workers and managers shall be demonstrated see Criterion 5.3. Minor SOP Waste Management PAS PPG EHS 32 SOP rev. 1 has been available since July 1, 2016. The procedure has identified the categories of waste, waste sources and management methods. Category types of waste that have been identified include: - Waste water mill - Domestic waste water - Waste from Mill empty bunch, solid decanter, fiber, kernel shell, boiler ash - Other organic wastes wood, twigs and leaves - Other inorganic wastes used bags, plastic, used beverage cans, scrap tires and scrap metal - Boiler exhaust emissions, gensets, vehicles heavy equipment and methane gas from WWTP - Hazard liquid waste used lubricating oil, diesel fuel, sludge, laboratory analysis, expired liquid chemicals - Hazard solid waste used chemicals packaging, used batteries, used filters, used fabrics, hazard material B3 contaminated gloves, B3 contaminated packaging, used batteries, used light bulbs, used neon, paint cans and thinner, used toner catridge, Ribbon typewriter printer. - Medical waste syringes, used gauze, used medical gloves, expired drugs and pathological waste Conclusion : Conform

4.6.11 Specific annual medical surveillance for pesticide operators, and documented

action to treat related health conditions, shall be demonstrated. Major The company has 19 workers as sprayer unit. The workers have specific annual medical surveillance, twice in a year. The last special medical examination was conducted on March, 2017. From the conclusion of the cholinesterase, all of pesticide operator is fine. Conclusion : Conform 4.6.12 No work with pesticides shall be undertaken by pregnant or breast-feeding women. Major Employed women who are pregnant and breastfeeding prohibited from doing work related to SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 53of 164 chemical pesticides as defined in Procedure Weed Control Chemist No. PPGGMOASD28SOP and medical center procedure SOPPPGMC-01. This provision is also contained in the womens reproductive rights policy set directly by the president director. There are 19 sprayers per July 2017. As much 17 workers are women. The company can ensure that sprayer do not work in pregnant condition. The Company conducts pregnancy tests every 1 months. Pregnancy tests using positive and negative test packs. When there is positive then the sprayer will be moved assigned. Conclusion : Conform 4.7 An occupational health and safety plan is documented, effectively communicated and implemented 4.7.1 A health and safety policy shall be in place. A health and safety plan covering all activities shall be documented and implemented, and its effectiveness monitored. Major The Company has set a policy that is integrated Environment, Health and Safety, Quality and Safety of Food, corporately signed by the Chief Executive Officer and President Director of PT. Poliplant Group, on April 1, 2015. K3 Healhty and safety policy already contains a commitment to improve the performance of K3, communicate policies and procedures to all employees and stakeholders, obey laws, identifying and assessing, and controlling all the risks and perform continuous improvement to prevent workplace accidents and occupational diseases. It is written billingual Idonesia and english language. The worker aware and understand the policy. K3 policy communication was conducted through various ways such as through the morning master, induction of new employees and contractors, P2K3 monthly meetings, management meetings, or display in workplaces. The Company also has established a work program of K3 part in form of P2K3 Work Program. The objective of K3 for the second semester in 2017 period is to reduce the level severity and loss work day due to snake bite incident. Another objective is to reduce the level severity bleeding from exposed sharp things. The prepared program is equipped with PIC and implementation deadlines. Conclusion : Conform 4.7.2 All operations where health and safety is an issue shall be risk assessed, and procedures and actions shall be documented and implemented to address the identified issues. All precautions attached to products shall be properly observed Major SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 54of 164 and applied to the workers. The Company has established procedures to conduct assessment of operational risks. It is Identification and Evaluation of Environmental Aspects and K3 Procedures PPGMR001SOP revision 01, dated June 1, 2017. The company has identified all of operation in the mill and estate. Indentify list of aspects of environmental impact and K3 has been set, dated June 1, 2017. However Hazard Identification and Risk Control aspects K3 were set and need to do reconsideration because of labor accidents when maintained spinning objects were not according to the excisting control. To calculate the risk of the Companys working environment, has been monitored and measured work environment in accordance with Permenaker no. 132011 about value of the threshold factor of physics, chemistry, and biology in each work area. The company has revised HIRAC. The company does engineering or modification of trucks to transport chemicals and labor. Trucks have been modified by making a special space to transport chemicals. The major finding raise at the time of the certification was: 1. There are still activities that has not been identified the risk such as transporting chemicals which used trucks along with workers transporting. 2. There are no technical specifications for masks which was being used by sprayers. Follow-up audit verification: 1. The company has committed corrective action to the audit findings by revising HIRAC and conducting engineering or modification of trucks that was being used for transporting chemicals and labors. The trucks has been modified by creating a special space for transporting chemicals. In addition, sprayers has been health examined with cholinesterase and spirometry method every 6 months. The company has not revised HIRAC comprehensively to all of activities as in the pressing operations at Siriham Mill has not been identified the risk of noise. The result of noise test from PT. Unilab Perdana on October 25 th of 2016 has shown that noise level is 90 dBA with standard of 85 dBA. 2. There is proof for sprayers mask cartridge specification based on document review as follows : a. The company already had policy about the procurement of PPE as stipulated in Company Regulation 2016-2018 Subsection 44 Clause 1 and 4. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 55of 164 b. The company has monitored of PPE in every working day at muster morning. c. The SOP of PPE Number: PASPPGEHS18SOP has been included specification as required PPE. d. The company has determined budgets related to PPE each year and listed the requested PPE specifications. e. Based on sampling of PPE procurement both at estate dated March 17 th of 2017 for chemical masks and at Mill dated March 10 th of 2017 for filter cartdridge has already included the technical specifications related to the requested PPE. f. The PPE handover has been done and sampled as in the mask handover for sprayers in March 2017, boots handover for harvesters in March 21 st of 2017, and safety shoes handover for mill workers in April 2017. g. There is availability stock for PPE both in estate and mill warehouse. Based on visitation to a press station Siriham Mill with noise level of 90 dBA, it has been found the operator was not using standardized PPE ear plug or ear muff. The operator only used cotton as an earplug. In this case, the company has not determined the type of standard PPE in the location. Therefore, the findings can not be closed and the company is suspended refers to RSPO certification system standard At surveillance audit, the company has thoroughly identified HIRAC in the estate and mill areas. At the time of the visit to all stations in the mill area July 18, 2017, workers are already using adequate PPE such as in the pressing station workers wear what is ear muff, glasses, helmet, and shoes. At the time of the visit to the harvesting process in block K48, the harvesters already use adequate PPE. Therefore, the findings can be closed and suspension status is uplifted. Conclusion : Conform 4.7.3 All workers involved in the operation shall be adequately trained in safe working practices see Criterion 4.8. Adequate and appropriate protective equipment shall be available to all workers at the place of work to cover all potentially hazardous operations, such as pesticide application, machine operations, and land preparation, harvesting and, if it is used, burning. Major The company has a PPE matrix Mill Jetty Estate Support dept. The matrix describes the type of PPE, the period of change, the type of work, and specifications. Types of PPE adjusted to the identified hazard identification. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 56of 164 The company has a certified workforce and SIO for first class boiler operator 3 people. The Company has also identified personnel requirements related to certification and SIO for crane and loader operators. In addition, the estate also has qualified personnel SIO loaders, excavators, tractors and dump trucks. The major finding raise at the time of the certification was: The number of qualified boiler operators was not sufficient. Currently the company only had a boiler operator class I, while the mill has operated 2 shifts in a day. Follow-up audit verification: The company already has had a certified workers and also SIO for first class boiler operator 3 workers. This condition will be sufficient for a mill which operates in 2 shifts. The company has also identified personnel requirements which related to certification and SIO for crane and loader operators. In addition, the estate also has qualified personnel and SIO for loaders, excavators, tractors, and dump trucks. Corrective action is sufficient and the major finding can be closed The company has thoroughly identified HIRAC in the estate and mill areas. At the time of the visit to all stations in the Siriham Mill area July 18, 2017, workers are already using adequate PPE such as in the pressing station workers wear what is ear muff, glasses, helmet, and shoes. At the time of the visit to the harvesting process in block K48, the harvesters already use adequate PPE. During the field visit estate divisi block G36, the workers have been using a complete PPE from cartridge masks, apron, glasses, shoes, rubber gloves. Based on interviews with workers, if the PPE is damaged then immediately replaced by reporting first to the foreman. The company already provides about 10-25 of the stock of PPE located warehouse estate. Workers know that chemical used is roundup container of chemicals already equipped with MSDS. During visit siriham estate division I block E46, from interview with harvesters workers Julius, Fransiskus, Tumani they used appropiate PPE and they know what will do if PPE demage before working. Conclusion : Conform 4.7.4 The responsible personpersons shall be identified. There shall be records of regular meetings between the responsible persons and workers. Concerns of all parties about health, safety and welfare shall be discussed at these meetings, and any issues raised shall be recorded. Major The Company has formed a P2K3 team. They have responsibilities to manage about safety in this SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 57of 164 company. The head of P2K3 is Mr Hasmen Sijintak and Mr Hikmatul Huda. The secretary of P2K3 team is Mr Pidomanta Sembiring S.T. The appointed letter to Mr Pidomanta as secretary based on Decision of the minister of labor RI No. p.1176 naker-binwasK3II2017 since 08 February 2017. It is previal for 3 years. Ratification of P2K3 is still in process based on letter No. 04 PK-KTP VII 2017 on July 14, 2017 from the labor and transmigration service of West Kalimantan province. P2K3 monthly meetings have been conducted in Estate and Mill. Minutes of meeting has been reported to Social Service Manpower and Transmigration Ketapang Regency. It is reported on 20 Juny for the first quarter January-March 2017 and 12 July for the second quarter April-June 2017. Conclusion : Conform 4.7.5 Accident and emergency procedures shall exist and instructions shall be clearly understood by all workers. Accident procedures shall be available in the appropriate language of the workforce. Assigned operatives trained in First Aid should be present in both field and other operations, and first aid equipment shall be available at worksites. Records of all accidents shall be kept and periodically reviewed. Minor The Company has established some procedures and work instructions regarding work accidents and emergencies situation. Procedures and work instructions applies to all units under PT. Poliplant Group. Here are some procedures SOPs and work instructions IK that have been made: - SOP Incident Investigation PASPPGEHS37SOP. - SOP Emergency Response Plan PASPPGEHS43SOP. - SOP Medical Services PASPPGEHS23SOP. - Flow chart Medical Emergency Plan PASPPGEHS43F.07 - Decision-making matrix when medical emergencies PASPPGEHS43F.04 - Matrix hospital capability PASPPGEHS43F.05. - Emergency Transport Approval Requirement Matrix PASPPGEHS43F.05 The company already has 15 officers who have attended the first aid training from the ministry. In addition, the company also conducts internal P3K training to each foreman. The company has been training for First Aid for the foreman on February 21, 2017. P3K box has provided in each division or unit that is class A accordance with Permenaker no. 152008. While for field operations foreman have provided a P3K bag for class A. In addition there are other tools to support the emergency response preparedness such 1 Ambulance car and SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 58of 164 complete tools and there is a paramedic who accompanied the patient. However, the company has not been effective in monitoring the completeness and use of first aid equipment in the field. There are still of out-of-date medicines such as providone iodine carried by foreman the fourth division harvesting on K48 block Exp Feb. 2017, carried by foreman loose fruit picker on block J47 exp Sep 2016, located at daycare facility div. IV Exp Sep 2014, and at Temporary hazardous waste storage Exp Nov 2016. There is also a rivanol in daycare facility Division IV Exp Nov. 2016 and at Temporary hazardous waste storage Exp Nov 2016, Boorwater in first aid box at Mill offices and laboratories Exp Nov 2016. Conclusion : Observation No.1 4.7.6 All workers shall be provided with medical care, and covered by accident insurance. Minor The Company had policy about social worker assurance in The Company rules article 19. It stated that The Company covered against every employee towards risk of accident of theirselves. The Company gave social assurance in form of BPJS health assurance and BPJS Manpower. Employees that got facility were at any levels such PHL, SKU-H, PB, PI, and Staff. The Company has paid BPJS health assurance for employees in estate and mill. The latest BPJS payout of 1554 workers was conducted in June 2017. Based on interviews with workers, they have received membership cards of BPJS. Conclusion : Conform 4.7.7 Occupational injuries shall be recorded using Lost Time Accident LTA metrics. Minor The Company has calculated the frequency rate FR and the severity rate SR every months. Calculations refer to the provisions in Ministerial Regulation No. 03MEN1998, and had counted lost working days Lost Time Accident. Calculation results were recorded in Form SRFR Monthly. There are Guidance of Procedure Charging FR Format - SR. During fiscal 2016-2017 there is a accident at siriham estate but no lost work day. In Siriham Mill an accident occurred on August 26, 2016. Accidents struck material against contractor workers. This results in a 24-day weekday breakdown lost working day. The company has already made work accident identification EHS 562 form and made its report to the relevant offices. So based on the safety index 9.17 and FR 1.45. Conclusion : Conform 4.8 All staff, workers, smallholders and contractors are appropriately trained. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 59of 164

4.8.1 A formal training programme shall be in place that covers all aspects of the RSPO

Principles and Criteria, and that includes regular assessments of training needs and documentation of the programme. Major The Company has had SOP about Competence, Awareness and Training. The Company has been made training plan annually periode June 2017 - July 2018. There is training form needs assessment that will be compiled by each of HRD unit before it is made into training plan. Training plan already contained aspects of K3 healhty and safety, environment, best practice, and management aspects. Training is conducted both internally and externally. Training at Mill in the period 2016-2017 consists of 45 internal training programs and 10 external training. Some of the documented trainings include Electrical K3 training in November 2016, First Aid for 7 people held on 12-14 December 2016, 10 class D class fire training on 27-29 Oct 2015, K3 field scaffold 15-19 August 2016 3 people , RSPO principles training on July 12, 2017 and on July 10, 2017 supply chain management training. Harvesting Safety: Training of harvesting is carried out every week. The training material is appropriate to ensure a safe harvesting methods. Training associated with the incidence of harvesting first aider schedule on 29 Maret 2017 by Asisten dan dokter. There were training material and evidence of presence about 37, consisting of harvesting workers and harvest foreman. Post test associated with the material provided. The training has been adapted to the specific type of work mainly related to the potential hazards and how to handle it. Sprayer Training: There are training materials for spraying. Training of herbicide mixing and weed control chemist was conducted on 29 March 2017 for a total of 24 workers. There are post-training results that ensure a level of understanding training material. Existing training materials are still using many with scientific terms and words. The training material has been adapted to the level of understanding and are made specifically to ensure retention of material so that it can be applied in the work as sprayers. The major finding raise at the time of certification was: 1. There has been found no evidence of emergency response training for harvests in the event of experiencing an accidentincident. Based on the results of interviews in the field, the SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 60of 164 harvesters has claimed that they have not received the kind of training. The harvesters has already equipped with a whistle for gathering another workers when an accident occured. Based on the verification, harvesters has already sounded the whistle but there is no foremans or other workers which has approached. 2. The company has conducted meeting and training every month for smallholders. The last training was held on August 18 th of 2015 with 43 people as a participants. So far the training materials were related to health safety environment. There is no training material has been found in accordance with the RSPO standard clause 4.8.1, for example related to the pesticides handling and potential risks and hazards to the workers and their families. Follow-up audit verification: 1. The company has conducted corrective action to the audit findings by providing socialization training in using whistle for all of divisions. As in held in division 3 on March 16, 2017, which was been attended by harvesters, harvest foreman, harvest crane, and emplasment. Based on sampling visitation at Block F38, the harvesters has already understood the use of the whistle. The documentation that has been seen such as : a. There are harvesters’ data which not only has been stipulated in the employee data, but also in each information board of the workers names in the divisions. b. There is a Work Instruction for Emergency Whistle Using PASPPGEHS 43INK.10 which became guidance for using whistle as a communication tool in the event of experiencing an accident. 2. The company has conducted corrective action for audit findings by establishing smallholders training programs which was related to RSPO standards and its covering work training with pesticides, chemical hazards, fertilization, pruning, etc. For example in May 4 th of 2016, the company has provided training to smallholders with materials such as fertilization, nutrient deficiency, BBC FFB census, and pruning. Corrective action is sufficient and the major finding can be closed Conclusion : Conform 4.8.2 Records of training for each employee shall be maintained. Minor At the mill and estate, records of training are kept based on the training programme attendance. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 61of 164 Some training can be proven by certificate. A competence test is conducted to evaluate the participant achievement. HR has responsibility for maintaining training records using software program. Conclusion : Conform 5 ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY 5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate

5.1.1 An environmental impact assessment EIA shall be documented.

Major AMDAL Documentation of Plantations and Palm Oil Mill PT PSA in Air Upas, Marau and Manismata Subdistricts, Ketapang District, West Kalimantan Province with PIR - Trans method are available. The scope of this environmental document covers a total area of 40,000 ha gross, 20,000 ha of plantation area and 60 ton FFB hour mill capacity. At the time of certification audit, the Company is still making progress on arrangement of Environmental permit change in relation to the change of the ownership of the company according to PP RI no. 27 2012 article 50 clause 2. It was advised that company to focus on working until the issuance of the permit. Ketapang Regent Decree No. 863 KLH-B 2015 concerning Change of Environmental Permit Data of Oil Palm Plantation and Processing in Mill by PT Poliplant Sejahtera Located at Ketapang Sub- District of Air Upas dated December 29, 2015 has been available. The corrective action is sufficient and this nonconformity can be closed. The Company has Bupati Ketapang No. 863KLH-B2015 tentang Perubahan Data Izin Lingkungan Kegiatan Perkebunan Kelapa Sawit dan Pabrik Pengolahan oleh PT Poliplant Sejahtera yang Berlokasi di Kecamatan Air Upas Kabupaten Ketapang tanggal 29 Desember 2015. The document has been approved by the West Kalimantan Provincial Assessment AMDAL Commission. 660.1 03 BAPEDALDA-A dated 4 January 2005. Important environmental impacts have included the impact of land clearing on soil erosion rates, the impact of wastewater disposal, the potential for land fires, the impact of changing protected flora and fauna habitats, impacts on pests, impacts on social anxiety, impact on community incomes, impacts SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 62of 164 on land conversion and impacts on public health. RKL RPL Report for the period of First Semester 2017 has been available in place and has been reported to related institutions. The monitoring is conducted by Unilab Perdana Laboratory on the following aspects: - The quality of clean water mess employees 1, 2, 3, C-26, divisions 2, 4, 5 - Well water quality monitor 1, 2, 3 and 4 - Upper and downstream Garu River surface water quality, Datar River, Upper of Silat River, Central and Downstream of Siriham River - Ambient air quality employees inn 1, 2 and office employee 1 - Quality of POM air front office - Air emission quality SHMM generator No. 1, 2 and 3, SHME II, III, IV and V SHME generators, SHMM boiler No. 2 - Quality of outdoor courtyard noise and work environment - Quality of emission of mobile sources vehicles - Wastewater quality waste pool No. 6 and oil trap Conclusion: Conform 5.1.2 Where the identification of impacts requires changes in current practices, in order to mitigate negative effects, a timetable for change shall be developed and implemented within a comprehensive management plan. The management plan shall identify the responsible personpersons. Minor The Company has identified aspects of environmental impact of the whole activities in the estate and mill and also other facilities to support operations such as warehouse, workshop etc. The identification of environmental impact needs to be conducted for the environmental management and monitoring activities that impact negatively to the environment based on RKL RPL documents. Report of RKL RPL implementation on first semester 2017 has reported to BLH District of Ketapang and West Kalimantan Province. Conclusion: Conform 5.1.3 This plan shall incorporate a monitoring protocol, adaptive to operational changes, which shall be implemented to monitor the effectiveness of the mitigation measures. The plan shall be reviewed as a minimum every two years to reflect the results of monitoring and where there are operational changes that may have positive and negative environmental impacts. Minor SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 63of 164 Environmental monitoring plan has been set in the RKL RPL matrix, included monitoring and measurement parameters, reference rules, location of measurement, coordinate, frequency of monitoring, implementation of compliance evidence, testing laboratory, PIC. The Company reported that environmental management is conducted every six months to BLH district and KLH West Kalimantan Province. Monitoring environmental management that is reported including test of wastewater, groundwater, soil physical and chemical, ambient air, generatoremissions, boiler emissions, odor, surface waterriver, water biota, clean water, noise, emission of moving vehicles. At the time of certification audit, it was found the minor NC that the RKL RPL report for second semester of 2015 to BLH level 2 of Ketapang district and level 1 of West Kalimantan Province has not been conducted, but there is result analysis from laboratory. The RKL RPL report has been reported to the BLHD of Ketapang and BLH in East Kalimantan Province by the Company. The corrective action is sufficient and the NC can be closed. Conclusion: Conform. 5.2 The status of rare, threatened or endangered species and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and operations managed to best ensure that they are maintained andor enhanched

5.2.1 Information shall be collated in a High Conservation Value HCV assessment that

includes both the planted area itself and relevant wider landscape-level considerations such as wildlife corridors. Major HCV assessment is performed by Lead Assessors who have an ALS license, namely Felicia Lasmana ALS14007FL. HCV assessment already includes the possibility of protected areas being affected by oil palm plantations. This can be seen from the map of the location of nature reserves and protected forests around PT. Poliplant Sejahtera. From the map it can be seen that the location of nature reserves and protected forest far from plantations PT. Poliplant Sejahtera 40 km so there is no need for an animal corridor. The HCV public consultation was conducted on 10 June 2015 at the Air Upas Sub-District Office and attended by 44 people from 12 villages and 4 dusun around the plantation site of PT. Poliplant Prosper and Dayak Customary Council. In the HCV Full Assessment report, all identified HCVs have been mapped except for HCV 6. The assessor has not attached the maps because parcipatory mapping with community is required. The company has conducted participatory mapping with the village community and the result has been SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 64of 164 input in GIS data, one of which is grave in Gajah Village. The major finding raise at the time of certification was: In the HCV document, it has been defined that the areal of HCV 4.1 is about 780 ha, in the form of river border S. Batar, S. Siriham, S. Silat, S. Garu and S. Gahang and swamp. There are source of spring in block G36 which was being used by local people and the company workers as a water resources both during the rainy and dry seasons. Based on site verification, it has been known that the company has made a protective effort by limiting the area of source of spring with a radius of 200 m and marking the palm stem to ensure there is no spraying and manuring activities. In the documentation of HCV assessment reports and HCV maps, the source of spring was not identified and set as HCV areas. Follow-up audit verification: On the HCV map, it has been added the source of spring area. Based on the field visitation, the marking on the stem of plants as a sign not to be sprayed in radius of 200 m from the source of spring. Corrective action is sufficient and the major finding can be closed Conclusion : Conform 5.2.2 Where rare, threatened or endangered RTE species, or HCVs, are present or are affected by plantation or mill operations, appropriate measures that are expected to maintain andor enhance them shall be implemented through a management plan. Major The HCVs identified are HCV 1.1, HCV 1.2, HCV 1.3, HCV 3, HCV 4.1, HCV 4.2, HCV 5 and HCV 6. The Company already has a PT Poliplant Sejahtera FY 1718 HCV-MA Management Program. In the proram it already covers for the identified HCV criteria HCV 1,3,4,5 and 6. In the program the company has also identified threat sources, threats, and threat categories that may exist for each HCV criterion. From each type of threat will then be determined different types of management. For example: for the type of threat in the form of exploitation of animals by the community the type of management determined by the company is the socialization to the community about HCVA and protected animals and plants periodically. There is daily monitoring conducted by workers, for the next day delivered to the foreman assistant krani at morning muster. Sampling of evidence on census monitoring and monitoring of wildlife and plants in June 2017 in accordance with PAS-PPG-EHS-42-F.08 form. While annual monitoring activities to identify the point of the spread of animals through the recording of coordinate points. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 65of 164 Conclusion : Conform 5.2.3 There shall be a programme to regularly educate the workforce about the status of these RTE species, and appropriate disciplinary measures shall be instigated in accordance with The Company rules and national law if any individual working for the Company is found to capture, harm, collect or kill these species. Minor The Company has a policy to protect the species of RTE contained in SOPs of Endangered or Protected Species Protection. PAS PPG EHS 45 SOP. The Company has a program to educate employees about RTE species listed in the PT Poliplant Sejahtera FY 1718 HCV-MA Management Program, which is socialization to employees on HCVA and protected animals and plants periodically. The sampling obtained evidence of socialization that is: 1. Report on the socialization of buffer zone area on 6-13 August 2016 2. Report on the socialization of HCV-MA and protected flora fauna on 3 November 2016 3. Report on the socialization of HCV-MA and protected flora fauna on 10-11 March 2017 4. Report on the socialization of the buffer zone area on June 6, 2017 During field visits to the K48 and J47 Blocks in Division 4, interviews were made to harvesters and loose fruit picker. From the results of the interviews they already understand about the buffer zone, the area of HCVMA and protected flora andfauna. The Company has SOP for Endangered Species Management, Limited or Protected Spread. PAS PPG EHS 45 SOP points 4.5 Sanctions Criminal Provisions are written: For employees who are proven to have committed deliberate violations will be dealt with in accordance with the prevailing laws and regulations Law No. 5 of 1990 Article 40 and Will be sanctioned by the Company in accordance with the applicable provisions in the Company. Conclusion : Conform 5.2.4 Where a management plan has been created there shall be ongoing monitoring: The status of HCV and RTE species that are affected by plantation or mill operations shall be documented and reported; Outcomes of monitoring shall be fed back into the management plan. Minor The Company has a Management Program of HCVMA PT Poliplant Sejahtera FY 1718 there is SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 66of 164 already a management program in the form of Monitoring, Identification Inventory of Diversity and Abundance of Flora and Fauna in HCVMA Area. The results of the monitoring will be summarized in a report that will be reported to management. The results of monitoring will be the basis for evaluating the management plan that has been set and used as a reference for making the next management plan. Conclusion : Conform 5.2.5 Where HCV set-asides with existing rights of local communities have been identified, there shall be evidence of a negotiated agreement that optimally safeguards both the HCVs and these rights. Minor HCV assessment is done with the scope of location permit owned by PT Poliplant Sejahtera. Therefore, there are HCVs identified in the location permit but the location is outside the HGU of the company. HCVs located outside of HGU are located in community-owned lands, such as Mekar Jaya Village, Mukti Valley Village, Bukit Gajah Village, and Harapan Baru Village. HCVs outside HGU such as HCV 6. For HCVs located outside the HGU the company can only conduct himbauan through socialization to the community as the owner of the land to continue to maintain the HCV. However, based on groundchecking, there are several HCVs located within HGU that are still used by the community to meet clean water and food needs. HCV used as a source of clean water by communities such as springs in G36 Division 4 and used to find food sources is Batar River in G46 Division 4. Companies allow people to use HCV to meet their basic needs provided they do not damage HCVs There is like catching fish with poison, cutting down trees and taking out garbage. No communities are affected because they can still use existing HCVs to meet their daily needs clean water and fishing. HCV Public Consultation has been conducted in Air Upas Village on June 10, 2015. In the public consultation, a discussion about identified HCV has been made and several discussion points are as follows: 1. Companies should conduct a review about planted areas that close to rivers and slopy areas Dayak Air Day Customary Council 2. To overcome the hunting of wildlife, the preservation of the conservation area should be maintained Mekar Jaya Village community Conclusion : Conform 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner

5.3.1 All waste products and sources of pollution shall be identified and documented.

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 67of 164 Major SOP Waste Management PAS PPG EHS 32 SOP rev. 1 has been available since July 1, 2016. The procedure has identified the categories of waste, waste sources and management methods. Category types of waste that have been identified include: - Waste water mill - Domestic waste water - Waste from Mill empty bunch, solid decanter, fiber, kernel shell, boiler ash - Other organic wastes wood, twigs and leaves - Other inorganic wastes used bags, plastic, used beverage cans, scrap tires and scrap metal - Boiler exhaust emissions, gensets, vehicles heavy equipment and methane gas from WWTP - Hazard liquid waste used lubricating oil, diesel fuel, sludge, laboratory analysis, expired liquid chemicals - Hazard solid waste used chemicals packaging, used batteries, used filters, used fabrics, hazard material B3 contaminated gloves, B3 contaminated packaging, used batteries, used light bulbs, used neon, paint cans and thinner, used toner catridge, Ribbon typewriter printer. - Medical waste syringes, used gauze, used medical gloves, expired drugs and pathological waste Conclusion : Conform

5.3.2 All chemicals and their containers shall be disposed of responsibly.

Major Chemical Inventory Document ID PAS PPG EHS 28 F02 for the period July 2017 has identified the name of the chemical trademark, chemical type, chemical characteristics, location area of use, storage location and MSDS. It was used in Siriham Estate and Mill. Chemicals that have been identified in the estate include various types of macro fertilizer, micro fertilizers, fungicides, herbicides, rodenticides, insecticides, fuels, lubricants and grease. In chemical lab inventory list document LAB PSA SHMM 01 F01 has identified the various types of chemicals used in the laboratory and their numbers. Temporary storage permit for B3 waste based on Ketapang Regent Decree No. 394 KLH-B 2013 on temporary storage permit of B3 waste to PT Poliplant Sejahtera dated August 19, 2013 which is valid for 5 five years has been available. The storage location has coordinates S 02o 17 8.9 E 110o 52 51.3. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 68of 164 Approval Letter of Environment Office of Ketapang Regency. 660.1 179 KLH-B concerning the extension of B3 waste storage on 11 April 2014 is available. The letter contains approval for extending the storage period of B3 waste from 90 days to 360 days for all types of B3 waste in accordance with the B3 waste storage permit. B3 waste has been stored in TPS B3. It contained symbols and labels of B3 waste and stored in accordance with its classification. B3 waste management was carried out on last June 15, 2016 in cooperation with B3 waste transporter, PT Bank Sampah Indonesia with transport vehicle numbered AD 1834 AV. The B3 waste manifest evidence of the 2nd copy of the carriage is as follows: - Manifest No. ARB 00003165 - Contaminated packaging - 229 kg - Manifest No. ARB 00003164 - used rag - 100 kg - Manifest No. ARB 00003163 - expired chemicals - 3 kg - Manifest No. ARB 00003162 - medical waste - 5 kg - Manifest No. ARB 00003161 - used filters - 144 kg - Manifest No. ARB 00003160 - used battery - 44 kg - Manifest No. ARB 00003159 - Used oil - 1215 kg The Company has balance of B3 waste for the period January - March 2017 and April - June 2017. Final transport B3 waste with third party was made on June 15, 2017. B3 waste storage activity sheet has been available until July 19, 2017 with the following amount: - Used oil - 0.5105 tons - used oil container - 0.054 tons - paint container - 0.002 tons - used chemical container - 0.064 tons - used of rag - 0.079 tons - used chemical container dirijen - 0.044 tons - Used filter - 0.0276 ton - Used batteries - 0.035 tons SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 69of 164 - Used lights - 0.003 tons - Expired chemicals - 0.005 tons - Medical waste - 0.007 tons - used packaging contaminated B3 - 0.0439 tons The Company in cooperation with third parties to transport and manage B3 waste. The Company has had permission, as follows: 1. CTP Poliplant Group with PT Bank Sampah Indonesia and PT Karya Nusa Bumi Persada with no. Agreement: 030 PPG-BSI-KNBP I 2017 dated March 16, 2017 is valid for 1 one year. It is regarding agreement of transportation and hazardous waste management. The type of hazardous material waste such as waste oil oil slurry residue sludge Water-blended lubricant, used grease, used oil and dirty oil. 2. CTP Poliplant Group with PT Bank Sampah Indonesia and PT Tenang Jaya Sejahtera with no. Agreement: 032 PPG-BSI-TJS I 2017 dated March 16, 2017 is valid for 1 one year. It is concerning of agreement of Transportation and B3 waste management. B3 waste type are medical waste, used clothrag and sludge WWTP. 3. CTP Poliplant Group with PT Bank Sampah Indonesia and PT Muhtomas with no. Agreement: 031 PPG-BSI-MTS I 2017 dated March 16, 2017 which is valid for 1 one year. It is concerning of Agreement of Transportation and B3 waste management. B3 waste type are oil filter, used battery, packaging and scrap container Iron tin metal. 4. CTP Poliplant Group with PT Bank Sampah Indonesia and PT Prasadha Pamunah Industrial Waste with no. Agreement: 029 PPG-BSI-PPLI I 2017 dated March 16, 2017 valid for 1 one year. It is concerning the Agreement of Transportation and B3 waste management. B3 waste type are B3 contaminated container, electronic waste, oil filter, toner, expired chemicals, medical waste, used scrap, oil sludge lubricant and spill kit. Conclusion: Conform 5.3.3 A waste management and disposal plan to avoid or reduce pollution shall be documented and implemented. Minor SOP Waste Management PAS PPG EHS 32 SOP rev. 1 dated July 1, 2016 has stipulated on the following matters: - General requirements of waste management SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 70of 164 - Identification and separation of waste types - Temporary storage collection of domestic waste - Special requirements for handling non-B3 waste - Special requirements for handling B3 waste - Landfills - Emergency procedures - Inspection and audit of waste management - Monitoring and measuring the quality of waste - Reporting waste management activities - Managing Waste document SOP Waste Management PAS PPG EHS 32 SOP rev. July 1, 2016 has identified the categories of waste, waste sources and management methods. Category types of waste that have been identified include: - POM waste water - Domestic waste water - Special waste from POM jankos, solid decanter, fiber, kernel shell, boiler ash - Other organic wastes wood, twigs and leaves - Other inorganic wastes used bags, plastic, used beverage cans, scrap tires and metal scrap - Boiler exhaust emissions, gensets, vehicles heavy equipment and methane gas from WWTP - Hazardous waste liquid used lubricating oil, diesel fuel, sludge, residual of laboratory analysis, expired liquid chemicals - Hazardous solid waste used chemicals, used batteries, used filters, used fabrics, B3 contaminated gloves, B3 contaminated former packaging, used batteries, used light bulbs, used neon, paint and thinner can, used toner catridge, typewriter printer ribbon. - Medical waste syringes, used gauze, used medical gloves, expired drugs and pathological waste Recover waste generated, as follows: - Palm oil fibers are utilized as boiler fuel and absorbance spill kits - Kernel shells are used as boiler fuel SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 71of 164 - Residual combustion of fiber and shell ash boiler used to pile up the hollow excavation area - The empty and solid bunch decanter cake is applied to the palm tree as organic fertilizer - Waste water POM POME is used applied to palm oil land. The management of used chemical packaging has been done in accordance with the SOP of Waste Management PAS PPG EHS 32 SOP. 3R efforts have been made in managing the non-B3 waste. Data on waste utilization metric-ton for the period of June 2016 - May 2017 in monthly report with details as follows: Periode Shell Fiber Empty Bunch Solid June 2016 244.63 1118.29 2247.83 - July 2016 127.56 583.15 832.60 - August 2016 - - 249.93 - September 2016 - - - - October 2016 121.31 554.54 4.47 - November 2016 545.59 2494.12 3208.19 225.68 December 2016 660.90 3021.26 3861.46 297.42 January 2017 640.01 2925.74 5057.47 344.78 February 2017 511.20 2336.93 4631.49 372.71 March 2017 678.72 3102.71 5260.41 466.41 April 2017 735.08 3360.36 3830.87 718.12 May 2017 741.22 3388.43 5604.77 675.81 Non-B3 waste management is conducted by collecting the waste to final waste disposal TPA by separating types of organic and inorganic waste open-dumping. At the time of certification audit, the Company issued the minor NC : 1. Inorganic Domestic landfill waste management was not applied according to SOP of waste management No. PASPPGEHS32 SOP point 4.4.1 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 72of 164 2. There was no program and long term target to reduce domestic solid waste, reduce exhaust gas emission, and reduce water consumption. The Company has made corrective action : 1. Domestic waste generated from employee housing is managed by providing organic and inorganic waste bins for disposal to final landfill. Final waste disposal has been made with adequate size and away from water sources. 2. Available objective documents and environmental programs PPG MR 001 SOP-Identification Evaluation of Environmental Occupational Aspects for the period 2016-2017 that have set environmental targets, achievement targets and indicators, activities relevant aspects, Environment, program implementation indicators, execution time long term short term, responsible implementers PIC, implementation deadlines and implementation status. The established environmental goals are: - Control of water pollution - Minimize GHG emissions - Management of B3 and non B3 waste with 3R - Water conservation - Protection of biodiversity - Energy efficiency - Community development based on environmental management The corrective action above is sufficient and the NC can be closed. Conclusion: Conform 5.4 Efficiency of fossil fuel use and the use of renewable energy is optimized 5.4.1 A plan for improving efficiency of the use of fossil fuels and to optimise renewable energy shall be in place and monitored. Minor The objective documents and environmental programs PPG MR 001 SOP-Identification Evaluation of Environmental Occupational Aspects for the period 2016-2017 have been set environmental targets, achievement targets and indicators, activities relevant aspects, environmental programs, implementation time program long term short term, responsible implementer PIC, deadline of implementation and implementation status. Energy efficiency is targeted to have a competent energy auditor to monitor energy efficiency and increase energy efficiency from biomass ton of FFB from the previous year. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 14.05 Issue 00 Rev. 1 73of 164 Evidence of energy efficiency monitoring results compared to previous year data is not yet available. As specified in the objective document and environmental program PPG MR 001 SOP- Identification Evaluation of Environmental Occupational Aspects for the period of 2016-2017. Monitoring results in the Resource Efficiency Report for the period June 2016 - June 2017 with the following usage: - Fossil fuels diesel = 247834 liters 210440 tonnes TBS = 1.18 liters ton FFB - Renewable fuels shell and fiber = 37439 ton 210440 tonnes TBS = 0.18 ton ton TBS - Electricity coming from generator and turbine = 1776846 kWh 210440 ton TBS = 8.44 kWh ton TBS Energy efficiency has been established in all operations in the company especially in the mill. But the company has not conducted any studies related to the use of biogas from POME. Conclusion : Minor Nonconformity NCR No.2

5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except