Aspects of estate and mill management that have social impacts are

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 50of 77 volume of waste produced is measured daily and recorded. Monitoring of emission from pollution sources like boiler and genset is carried out every 6 months. Measurement of emission air of boiler and genset shows that the result is below the quality standard of Decree of the Minister of Environment No. KEP-13MENLH32005. Ambient air measurement results comply with Government Regulation No. 411999. The latest emission and ambient air measurement was conducted on 28 June 2013. 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 to that, Company also implements zero burning and reserve an area of 445.45 Ha within the HGU for conservation. Peat land water reduction by controlling water level through trenching. Routine maintenance of equipment and operational vehicles is one of the pollution reduction programs. 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 Company has developed activity plan for CSR activity 20132014 based on Consultant recommendation of ‘Social Impact Assesment” carried out by LINKS Palm Community Circle Association Consultant. CSR plan consists of : Educational activity in the form of scholarships at elementaryjunior-senior high school and university level, teacher honorarium and educational facility assistance of sport facility in Baung Village, Jahitan Village and MuaraDua village Religious activity in the form of religious festival assistance, place of worship facility physical assistance in Baung Village, Muara Dua Village and Jahitan Village Social activity in the form of public facility improvement such as road construction in MuaraDua Village and assistance for celebration of Indonesian Independence Day Health activity in the form of mass circumcision in Baung Village, Jahitan Village and MuaraDua Village. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 51of 77 Company internal CSR activity in the form of Safari Ramadhan, Christmas celebration, Indonesian Independence Day celebration and Security Officer development. It may be helpful if CSR plan developed ensure a comprehensive program according to the SIA result. Company has realized some of its CSR plan for current year such as assistance for SMA TelagaPulang school renovation which was given TWICE i.e. January and June 2013 in the form of construction of building foundation and assistance given to Baung Village Mosque in the form of 2 rolls of carpet in August 2013. Company together with communities from 3 villages of Jahitan Village, Baung Village, MuaraDua Village is preparing plasma area totaled 265 HA APL Status for nursery and 3,088 Ha with HPK status for plasma planting. Community plantation development will be carried out after the process of release of forested area has obtained approval from the Minister of Forestry. No plasma is developed so far. The current progress is that Letter of recommendation from Seruyan Regent and Governor has been obtained to be passed to the Ministry of Forestry. Community development cooperation scheme in the form of an MOU between company and Cooperative “Usaha Mandiri“ signed on 17 January 2012 is the revitalization partnership scheme single management program. Total number of registered plasma members is 1,773 households. The current status is a change No.5008001EKVIII2012 from a total membership of 1,770 into 1,090 households through Seruyan Regent letter. The memo says that Tanjung Rangas Village 386 households and Sembuluh II Village 400 households belong to other company’s plasma so that the remaining 1,090 households which will become CPP are with PT GBSM. Revision of MOU between Company and the cooperative related to the exclusion of 2 village plasma members has not been made, awaiting completion of legal process of release of forested area from the Ministry of Forestry. Compliance status: Compliance 6.2 There are open and transparent methods for communication and consultation between growers andor mills, local communities and other SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 52of 77 affected or interested parties Company has Acknowledgement and Handling of Information Requests Procedure No. 106181TAPRO-CSR-HOVI13. The procedure has established the person responsible for handling information requests. At Estate the person in charge is CSR Assistant and at Mill it is KTU. Information requests through a letter have been registered in the Letter Monitoring Log Book. Direct information requests will be recorded in the Response to Information Request Log Book. Any complaint will be recorded in the Stakeholder Complaint Log Book. There is a list of stakeholders consisting of: Cooperative, village head of the 3 villages of Baung Village, Jahitan Village, and MuaraDua Village, community leaders represented by customary leaders from each village and religious leaders, contractorssuppliers, government, police and NGOs, and journalists. Company has job description that ensures there is personel who carries out public consultation and communication CSR Plasma Area and subordinates CSR Assistant. CSR Plasma area make coordination of implementation, while CSR Assistant ensures that Company’s CSR program is implemented. 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 Company has SOP Stakeholder Complaint Acknowledgement and Resolution No. 106899TAPPRO-CSR-HOVI13 that ensures deliberation is sought as a step to conflict resolution. Sampling is conducted on Mr. Jamhuri’s land claims to 10.89 HA in the GBSM area. Company resolved the conflict on 10 May 2013 by giving a compensation of Rp. 190 millions. Documentation has been provided with a map complete with coordinates and signed by both parties. Relating to grievance, it has been regulated in Company Regulation Article 49 concerning Settlement of Dispute and Article 50 Settlement of Grievance. Company improves Internal Memo of Suggestion Box by creating SOP concerning Employee Grievance Settlement No. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 53of 77 TAP-PRHRD-GN063-0113-0, which is prepared by HR Operation Dept. Social Impact Dept., verified by HR Div.Head and Sustainability Dept. Head, and approved by Managing Dir. It comes into force as per 18012013. Compliance Status : Compliance 6.4 Any negotiations concerning compensation for loss of legal or customary rights are dealt with through a documented system that enables indigenous peoples, local communities and other stake holders to express their views through their own representative institutions Company has SOP Stakeholder Complaint Acknowledgement and Resolution No. 106899TAPPRO-CSR-HOVI13 that ensures deliberation is sought as a step to conflict resolution. Sampling is conducted on Mr. Jamhur i’s land claims to 10.89 HA in the GBSM area. Company resolved the conflict on 10 May 2013 by giving a compensation of Rp. 190 millions. Documentation has been provided with a map complete with coordinates and signed by both parties. Compliance Status : Compliance 6.5 Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages Relating to regional minimum wage UMR implementation, Company has implemented regencymunicipal sector minimum wage UMSK provisions that refer to Regulation of the Governor of Central Kalimantan No. 272012 dated 26 November 2012 concerning UMK and UMSK 2013 of Seruyan Regency. UMSK of Agricultural, Animal Husbandry, Forestry, Plantation and Fisheries sectors is stipulated to be Rp. 1,697,892,-. Company has issued Internal memo No. MI-024CEOHRXII2012 dated 26122012 concerning PT. Gawi Bahandep Sawit Mekar Employee Wage Stipulation 2013, for Permanent KTProbationary Employee as well as Casual Worker KL. For KTProbationary Employee it is stipulated to be Rp. 1,698,000,- per month, while for KL it is Rp. 67,920,- per working day. Sampling interviews with permanent, fertilizing and spraying workers, all of them say that their minimum wage is Rp. 1,698,000,- per month or Rp. 67,920,- per working day. Similarly, based on the result of sampling on a number of pay slips of January 2013 for level Category 0 the lowest, it is recorded that the basic wage is Rp. 1,698,000,- SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 54of 77 Company has a payroll and incentive system. It is in the Payroll Management of the Manual Book of Human Resource. 2. It is in the Attachment of Director Letter of Decision No. 104017TAPSKD-HRD-HOXI12, Roman letters I – VII. It consists of harvest, loose fruit, foreman, harvest penalty, seedling transport for driver, other premiums, and foreman functional and attendant allowances, valid since 1 January 2013. Company does not have agreements work contracts requiring contractors to comply with applicable employment regulations, for example, competence requirements such as SIO, wages, overtime and working hours, etc. Company should ensure that working hours and overtime hours comply with the provisions of the Ministry of Manpower i.e. working hours is 40 hours and overtime is a maximum of 14 hoursweek. Here is the data that is on site facilities: Type of Infrastructure in Unit Mill PT. GBSM No. Facility Quantity 1. Emplasment type G2 70 Unit 2. Mosque 1 Unit 3. Musholla 1 Unit 4. Lapangan Sepakbola 1 Unit Type of Infrastructure in Unit Estate PT. GBSM No. Facility Quantity Emplasment type: Permanent Non-Permanent 1. G1 EM 3 - 2. G2 Askep 2 - 3. G2 Asisten 20 - 4. G2 25 - 5. G5 - 2 6. G8 - 2 7. G10 37 48 8. Koperasi 1 - 9. Toilet - 24 10. Tandon Air capacity 1100, 2200, 5200 ltr - 14 11. Clinik - 1 12. Docter 1 - 13. Paramedic and bidan 4 - 14. Musholla - 8 15. Daycare 1 - 16. Ambulance 1 - 17. School Bus 2 - SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 55of 77 Compliance Status : Minor NCR No.4 Observation No.7 6.6 The employer respects the right of all personnel to form and join trade unions of their choice and to bargain collectively. Where the right to freedom of association and collective bargaining are restricted under law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel Freedom to form trade union is regulated in the Preamble of PP for the Period 2012-2014 paragraph 2 point 1. Trade union formation is recorded in the Minutes of GawiBahandep Sawit Mekar Worker Association Formation, dated 05 September 2012. The union’s board consists of: Sri Pujianto Chairman, Jajuli Vice Chairman, Kurniawan Wijaya Secretary, and Jumiati Treasurer. The formed trade union has been registered and recorded in accordance with Decree of the Head of Manpower, Transmigration and Tourisms Service of Seruyan Regency No. 5601533DisnakertransparIX2012 dated 26 September 2012 concerning Registration of Plantation Trade Union of PT. GawiBahandep Sawit Mekar. The Trade Union’s facilities supported by Company are: Trade Union office space located at employee housing block G-5, desks, and chairs. The Trade Union has established its by-laws ADART, dated 5 September 2012, signed by the Chairman and Secretary. Collective Labor Agreement CLB is currently under preparation. In addition to Trade Union, the Bipartite Cooperation Body LKS also has been established in PT. GBSM as recorded in the Minutes of Bipartite LKS Establishment dated 11 December 2012, which is provided with data of Bipartite LKS Structure, with a total member of 10 people from the workers Trade Union and Company management, respectively. Data of workers joining the trade union as members are kept by the Secretary. There are currently 200 workers registered, as listed in PT. Gawi Bahandep Sawit Mekar Plantation Trade Union Member List, dated 11 September 2013. The trade union membership is not limited to certain level. Those listed are charged with fees of Rp. 5000,- per month as specified in Article 8 of the union’s ADART. It would be helpful if the record of meeting with trade union is kept by both parties, i.e. the SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 56of 77 management and trade union, because it is found that meeting records are kept by the management only. It is suggested the frequency of trade union meeting follows the ADART o n monthly meeting among the trade’s board personnel. Draft Collective Labor Agreement CLB should be finalized within target time agreed i.e. by December 2013. Compliance Status : Observation No.5 6.7 Children are not employed or exploited. Work by children is acceptable on family farms, under adult supervision, and when not interfering with education programmes. Children are not exposed to hazardous working conditions Company has a policy concerning worker age requirements according to applicable Laws. This is incorporated in: 1 Recruitment Standard Operating Procedure 01TAP-HRDPSO- RFIII07 that comes into force from 1 March 2007, point E.2 that general requirements in recruiting workers is “aged a minimum of 18 years old at the time of employment”. 2. Memorandum of Employee Status Upgrade of Foreman Rank and Below, No. 704HRD- IRRXII11 dated 1122011, Concerning Employee Status Appointment, on Sub Chapter B. Employee Recruitment Requirements, point 1, aged 18 - 45 years old. During site visit to the estate area, there was no worker aged below 18 years old. The harvesters, fertilizing, and spraying personnel are on average aged above 23 years old. Likewise, based on Employee Master Data of the Period July 2013, there is no employee whose date of birth is after 1995, meaning that company is currently employing workforce with age above 18 years old. Compliance Status : Compliance 6.8 Any form of discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, or age, is prohibited Company has a policy concerning equal opportunities and treatment to get job. This is regulated in: 1. Article 10 of Company Regulation does not mention about gender. 2. Recruitment Standard Operating Procedure see 1.7.6, point E. General requirements in recruiting new employees are: a. Indonesian Citizen, b. Aged a minimum of 18 years old at the time of recruitment, c. Mentally and physically healthy, d. Meet functional requirement demand at the time of recruitment, e. Obey company regulations and rules, SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 57of 77 f. Not involved in the banned partyorganization, g. Not bound by work relations with other partylegal subject. Based on Employee Master Data of the Period July 2013 it can be seen that Company recruits workers from various ethnic groups both local and non-local from outside the region. Out of 2,141 Estate employees, 45.35 is the Banjar; 47.97 Javanese; 2.62 Bimanese; and 1.12 Flores ethnic. The rest is of Bataknese, Dayaknese, Madurese, Sundanese, etc. By gender, approximately 36 is female. And by percentage, local workforce is 44 and non-local is 56. Compliance Status : Compliance 6.9 A policy to prevent sexual harassment and other forms of violence against women and to protect the reproductive rights is developed and applied Gender Committee was established on 24 June 2013 with memberships respectively from afdeling and division. Information dissemination to employees has been held with representatives from each division and afdeling. Dissemination materials constitute gender definition, examples of gender injustice, sexual harassment, and domestic violence. Anyone commits harassment will be sanctioned from a warning letter up to a dismissal. It would be helpful if information dissemination on harassment is conducted by ensuring that all workers understand how to report to the gender committee which has been established because when audited the workers did not know the mechanism of reporting to the gender committee. Compliance Status : Observation No.6 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses. Company conducts business with local suppliers and contractors in a transparent and fair manner. Any form of cooperation is provided with the Letter of Mutual Agreement, which also specifies terms of payment agreed by both parties. Sampling is conducted on suppliers in the name of BpkSarmiji. submitted is totaled 23,118 kg at a price of Rp. 1450,-kg as per 02 September 2013. In the agreement it is stated that payment for will be made within 7 working days after the fruits have been delivered and SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 58of 77 invoice is received by supplier. Compliance Status : Compliance 6.11 Growers and millers contribute to local sustainable development wherever appropriate Company makes cooperation with local businesses in the form of purchasing local and using local contractors. In addition, company with its CSR program participates in the development of surrounding communities in the form of granting scholarships, school development assistance, and village road construction. Company has made a short-term and long-term program 5 years, which is provided with SOP to evaluate the effectiveness of CSR program implemented. Compliance Status : Compliance 7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS 7.1 A comprehensive and participatory independent social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations NA 8 COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY

8.1 Growers and millers regularly monitor and review their activities and