Aspects of estate and mill management that have social impacts are identified

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 55of 117 months. The last test has been carried out on 10 June 2011. Measurement of emission air of genset shows that the result is met with the quality standard of Decree of the Minister of Environment No. KEP-13MENLH31995. Measurement of emission air of boiler shows that the result is met the quality standard of Decree of the Minister of Environment No. Per- 07MENLH2007 and Ambient air measurement results comply with Government Regulation No. 411999. The records of greenhouse gas emission reduction efforts are in the form of shell and fiber use report and empty fruit bunch use report. In addition, Company also implements zero burning policy and routine maintenance of equipment and operational vehicles. Compliance status: Compliance 6 RESPONSIBLE CONSIDERATION OF EMPLOYEES AND OF INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS

6.1 Aspects of estate and mill management that have social impacts are identified

in a participatory way, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement Social aspects from estates and mills can be seen on Amdal document and SIA Social Impact Assessment and have been identified by third party from Research Institute of the University of North Sumatra. SIA assessed positif impacts that continuous to be developed and then was made plans to reduce negative impacts which may occur. There was management plan and social impact monitoring with participation of community which were conducted regularly on UKL-UPL document report or RKL-RPL to the related agency and were done by all estate: Batang Toru, Hapesong, Aek Nabara Utara, Sisumut dan PKS Sisumut periodically. For Sisumut village, there are 5 villages surrounding estate i.e. Desa Sisumut, Desa Kota Pinang, Desa Sei Rumbia, Desa Pekan Tolan and Desa Air Merah. As a result of the identification of the SIA, it can be summarized existing problems in the villages nearby, such as problem of limited agricultural land, limited venture capital, lack of entrepreneurial skills, labor problems unemployment and the lack of expertise skills of working age, as well as issues of land disputes in the concession area between villagers and PTPN 3 SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 56of 117 Persero Sisumut estate. The company as a private own company BUMN has the program which is called Program Kemitraan dan Bina Lingkungan PKBL Partnerships and community development programs. As a BUMN, the company is mandatory to allocate the funds for 5 of profit refers to Indonesian Law for BUMN. The PKBL department responsibles to make the program and allocate the funds to improve the welfare of the local community. The company has set up the Community development program and Social for year 2011 such as - Providing training for women to improve their skills sewing and embroidery - Procurement thrasher Feedmill 7 units - Create jobs by giving priority villagers Sisumut as employees of PTPN III. - Training of the company based interest group of villagers. - The opening of unused land by the company. - Education: a. Provide scholarships for talented children. b. Soft loans for education expenses. c. The addition of educational facilities - Training to farmers for planting TBS. - Providing capital to oil palm cultivation treatments. - Granting credit pattern palm seeds installment Compliance status: Compliance 6.2 There are open and transparent methods for communication and consultation between growers andor mills, local communities and other affected or interested parties The company has the SOP for Communication and Consultation with stakeholders PK-3.00-03. For the response that needed from District Manager should be refered to IK-3.00-0103 Tata tertib dan kodering Surat menyurat. The company has had SOP for Information and Request Response IK-3.00-1301. A list of information that can be accessed by relevant stakeholders has been available. Any request for information that is not listed in the list will require asking for Top management consideration and approval. A list of stakeholders has been available for each unit and consists of, among others, Customary leaders community leaders, Muspida and village chief, Company trade unions, SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 57of 117 Contractors and suppliers. Mostly, incoming letters containing funds proporsal from local community for religion activities. Compliance status: Compliance 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties Conflict of Batugodang Village – Hapesong Estate During prelimenary audit, it was found such cases such as : At Batugodang village, there was a conflict resolution that was lack of transparency, not effective and unable to ensure the solving problem complete. It was found the members of society who had yet to receive compensation tenants, while the organization had given the compensation by representative who could not be ascertained. The company has made the corrective action by re-identified the local community to ensure the people involved have been identified completely. The company has invited the related people and makes the agreement with them for the right compensation for the right people. The company has the evidence of the list of the people involved and completed with the the sign for compensation received. The corrective action done by the company has been adequate so the non conformity can be closed. Conflict of Sumuran Village – Batangtoru Estate While in Batang Toru estate, it was found conflict in Sumuran Village, Batang toru where the conflict resolution could not ascertained because there was difference on the nominal of compensation between organization and community so major non conformity was published. The company has made improvement by doing approach again to the community and the company made agreement about the nominal of compensation and coordinate with relevant section at director office for its approval. During audit certification, it was found problem on difference of nominal on the compensation between company and Sumuran Village, Batang Toru. It was associated with land handover which was 175,84 Ha used by farmers. The rootcaused was because there is no agreement of compensation value for payment of land right farmed by local community. They asked for 50 million rupiahHa while the company is only SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 58of 117 able to give Rp. 5 million rupiahHa. The company has planed to make solution for time bound plan on the land in 2012. The team will see the case progress on the next surveillance. Compliance status: Minor Non-conformity

6.4 Any negotiations concerning compensation for loss of legal or customary