PUBLIC SUMMARY REPORT

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1 App./Cert. Date RSPO /05/2011 Rev.01 12/09/2011 PUBLIC SUMMARY REPORT Client: Site Address: PT. SOCFIN Indonesia Tanah Gambus Mill and Its Supply Bases Tanah Gambus Mill: Tanah Gambus, Kecamatan Lima Puluh, Kabupaten Batubara NORTH SUMATERA IDN Its Supply Bases: Tanah Gambus, Kecamatan Lima Puluh, Kabupaten Batubara NORTH SUMATERA IDN Standard(s): National Interpretation of RSPO Principles and Criteria for Sustainable Palm Oil Production, Republic of Indonesia, May 2008 Supply Chain Certification System (SCCS) Requirements COMMERCIAL- IN CONFIDENCE The contents of this report must not be disclosed to a third party without the agreement of the SAI Global Client DISCLAIMER: This report has been prepared by SAI Global Indonesia (SAI Global) in respect of a Client's application for assessment by SAI Global. The purpose of the report is to comment upon evidence of the Client's compliance with the standards or other criteria specified. The content of this report applies only to matters, which were evident to SAI Global at the time of the audit within the audit scope. SAI Global does not warrant or otherwise comment upon the suitability of the contents of the report or the certificate for any particular purpose or use. SAI Global accepts no liability whatsoever for consequences to, or actions taken by, third parties as a result of or in reliance upon information contained in this report or certificate. ACTIVITY ID: QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 1 of 52

2 Table of contents Executive Overview Abbreviations Used Page 1.0 SCOPE OF THE CERTIFICATION ASSESSMENT Introduction Audit Objective Scope of Certification Location of Mill and Estates Description of Supply Base Date of Plantings Other Certificates Held Organisational Information/Contact Person Time Bound Plan for Other Management Units Area of Plantation Approximate Tonnages Offered for Certification (CPO and PK) Date of Issue of Certificate and Scope of Certification AUDIT PROCESS Certification Body Audit Methodology Qualification of the Lead Auditor and Audit Team Members Stakeholder Consultation Date of Next Surveillance Visit AUDIT FINDINGS Summary of findings Recommendation 38 List of Tables Page 1 Mill and Estates GPS Locations 5 2 Organisation FFB Production 8 3 Age Profiles of Planted Palms 8 4 Other Certificates Held by Mill and Estates 9 5 RSPO Certification Time Bound Plan of PT. Socfin Indonesia 10 6 Estates and Area Planted 10 7 Plantation Hectare Statement 10 List of Figures Page 1 Map of Mill and Estates Location 6 2 Boundaries Pegs with Estate name 17 3 Facility to mix agrochemicals 25 4 Swamp Forest (1) 30 5 Swamp Forest (2) 30 List of Appendices Page A Audit Record 39 B Nonconformities, Corrective Actions and Observations Summary 42 C Stakeholder s issues and comment 50 D Definition of, and action required with respect to audit findings 51 QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 2 of 52

3 Executive Overview SAI Global audited PT. Socfin Indonesia operations comprising one mill, one oil palm estate, support services and infrastructure. PT. Socfin Indonesia operation was found complies with the requirements of the National Interpretation of RSPO Principles and Criteria for Sustainable Palm Oil Production, Republic of Indonesia, May 2008 and Supply Chain Certification System (SCCS) Requirements. The recommendation from this audit is that PT. Socfin Indonesia be approved as a producer of RSPO Certified Sustainable Palm Oil and Palm Kernel. Abbreviations Used AK3U ANDAL BOD BPN BPS CPO CSR EFB ERP FFB GPS HCV HGU HPH IPM ISO KHT kwh LCC MSDS MT NGO OHS PKOF POM PPE PRA PK PKB RABQSA RKL RPL RSPO SA SCCS SIO SPSI WWTP OHS Expert (Ahli Kesehatan dan Keselamantan Kerja Umum) Environmental Impact Analysis (Analisis Dampak Lingkungan) Biological Oxygen Demand National Land Agency (Badan Pertanahan Nasional) Central Bureau of Statistic (Biro Pusat Statistik) Crude Palm Oil Corporate Social Responsibility Empty fruit bunches Enterprise Resources Planning Fresh Fruit Bunch Global Positioning High Conservation Value Land Use Title (Hak Guna Usaha) Forest Authority Concession (Hak Penguasaan Hutan) Integrated Pest Management International Standards Organisation (Karyawan Harian Tetap) Kilo Watt Hour Legume cover crops Material Safety Data Sheet Metric Ton Non Government Organisation Occupational Health and Safety Palm Kernel Oil Factory Palm Oil Mill Personal Protective Equipment Participatory Rural Appraisal Palm Kernel Joint Working Agreement (Perjanjian Kerja Bersama) Quality Society of Australia Environmental Management Plan (Rencana Pengelolaan Lingkungan) Environmental Monitoring Plan (Rencana Pemantauan Lingkungan) Roundtable on Sustainable Palm Oil Social Accountability Supply Chain Certification System Operation License (Surat Izin Operasi) Indonesian Worker Union (Serikat Pekerja Seluruh Indonesia) Waste Water Treatment Plant QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 3 of 52

4 1.0 SCOPE OF THE CERTIFICATION ASSESSMENT 1.1 Introduction SAI Global conducted an audit of PT. Socfin Indonesia Tanah Gambus Mill and Its Supply Bases on 10, 13, 14 and 16 May The purpose of this audit report is to summarise the degree of compliance with the relevant criteria, as defined on the cover page of this report, based on the evidence obtained during the audit of your organisation. SAI Global audits are carried out within the requirements of SAI Global procedures that also reflect the requirements and guidance provided in the international standards relating to audit practice such as ISO/IEC 17021, ISO 19011, RSPO Certification System and other normative criteria. SAI Global Auditors are assigned to audits according to industry, standard or technical competencies appropriate to the organisation being audited. Details of such experience and competency are maintained in our records. The audit team is detailed in the attached audit record. In addition to the information contained in this audit report, SAI Global maintains files for each client. These files contain details of organisation size and personnel as well as evidence collected during preliminary and subsequent audit activities (Documentation Review and Scope) relevant to the application for initial and continuing certification of your organisation. Details of your primary contact persons and their contact details and site addresses are also maintained. Please take care to advise us of any change that may affect the application/certification or may assist us to keep your contact information up to date, as required by SAI Global Terms and Conditions. Please note that this report is subject to independent review and approval. Should changes to the outcomes of this report be necessary as a result of the review, a revised report will be issued and will supersede this report. 1.2 Audit Objective Certification Audit To determine the implementation of your organization s RSPO system; the capability and effectiveness of the RSPO system to ensure continual compliance with the requirements of the National Interpretation of RSPO Principles and Criteria for Sustainable Palm Oil Production, Republic of Indonesia, May 2008 and Supply Chain Certification System (SCCS) Requirements. and in meeting its specified objectives (indicator); and the conformity of the RSPO system to the stated principles, criteria and indicator. 1.3 Scope of certification The scope of certification is the CPO production from one (1) Palm Oil Mill and one (1) FFB supply base owned by PT. Socfin Indonesia. Tanah Gambus Mill PT. Socfin Indonesia Location: Kecamatan Lima Puluh, Kabupaten Batubara 21255, Sumatera Utara, Indonesia GPS Location: see table 1. Total Capacity (annual MT CPO): CPO: 23, ton in 2010 PK: 4, ton in 2010 QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 4 of 52

5 Certified capacity (annual MT CPO): CPO: 18, ton in 2010 PK: 3, ton in 2010 Tanah Gambus Estate PT. Socfin Indonesia Location: Kecamatan Lima Puluh, Kabupaten Batubara 21255, Sumatera Utara, Indonesia GPS Location: see table 1. FFB Production: 78, ton in 2010 Total Area: Ha Planted Area: Ha 1.4 Location of mill and estates PT. Socfin Indonesia mill and estate are located in North Sumatera Province. The geographical coordinate of the mill and estates are shown on Table 1. Table 1: Mill and Estates GPS Locations MILL AND ESTATE EASTING NORTHING Tanah Gambus Mill 99 24'14" E 3 12'15" N Tanah Gambus Estate 99 o o E 3 o o N QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 5 of 52

6 Figure 1 Map of Mill and Estates Location QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 6 of 52

7 QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 7 of 52

8 1.5 Description of supply base Audit Report The FFB is sourced from one (1) organisation owned by PT. Socfin Indonesia. The hectarage and FFB production of the plantation is shown on Table 2. Table 2: FFB Production of the supply base ESTATE PLANTED AREA (HA) FFB (TON/YEAR) Tanah Gambus , The third party (excluded from certification) , Source: Socfin Indonesia, March Date of plantings Table 3: Age Profiles of Planted Palms Year Tanah Gambus Estate Planted Area (Ha) % of Planted Area Mature Immature Mature Immature QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 8 of 52

9 Total 2, Grand Total Source: Socfin Indonesia, March Other certificates held The organisation is implementing quality, environmental, and occupational health and safety management system based on ISO 9001:2008, ISO 14001:2004, and OHSAS 18001:2007. The details of other certifications held are shown in the following table. Table 4: Certificates Held by Mill and Estates MILL/ESTATE ISO 9001:2008 ISO 14001:2004 OHSAS 18001:2007 Tanah Gambus Mill Since 2007 Since 2007 Since 2008 Tanah Gambus Estate Nil Since 2007 Since Organizational information/contact person PT. Socfin Indonesia Jl. K.L. Yos Sudarso No. 106, Medan Phone : (+62-61) Fax : (+62-61) Contact person : Mr. Hasan Bisri Head of System Management and Social Department Time bound plan for other management units PT. Socfin Indonesia is committed to RSPO certification of all its Management Units located in North Sumatera and Nanggroe Aceh Darusallam. Time bound plan has been developed to achieve the RSPO certification for all its Management Units by The time bound detail was shown on Table 5. It is realistic and challenging. The number of certified Estates is more than previous year. It was evident that the organisation is committed to meet the target that had been set in the time bound plan. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 9 of 52

10 Table 5: RSPO Certification Time Bound Plan of PT. Socfin Indonesia, approved in May 2011 NO NAME OF MILL SUPPLY BASE LOCATION YEAR 1 Bangun Bandar Mill Bangun Bandar Estate North Sumatera Tanah Gambus Mill Tanah Gambus Estate North Sumatera Negeri Lama Mill Negeri Lama Estate North Sumatera Matapao Mill Matapao Estate North Sumatera Sungai Liput Mill Sungai Liput Estate Nanggroe Aceh Darusallam 6 Lae Butar Mill Lae Butar Estate Nanggroe Aceh Darusallam 7 Seunagan Mill Seunagan Estate Nanggroe Aceh Darusallam 8 Seumayam Mill Seumayam Estate Nanggroe Aceh Darusallam Aek Loba Mill Aek Loba Estate Source: Socfin Indonesia, May 2011 Padang Pulo Estate North Sumatera Area of plantation The areas details for organisation owned estates are shown on Table 6. Table 6: Estates and Area Planted ESTATE MATURE (HA) IMMATURE (HA) Tanah Gambus 2, Source: Socfin Indonesia, March 2011 Table 7: Plantation Hectare Statement AREA HECTARES Mature area 2, Immature area Total area planted Emplacement and Mill QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 10 of 52

11 Nursery 3.93 Effluent, Isolation Drain 6.59 Reserve 9.27 Bamboo 1.29 Swamp HCV 3.35 Other area 0.89 Total leased area 3, Source: Socfin Indonesia, March Approximate tonnages offered for certification (CPO and PK) The approximate tonnages certified are: CPO/year: 18, ton and PK/year: 3, ton 1.12 Date of issue of certificate and scope of certification The scope of certification is the CPO production from one (1) palm oil mill and one (1) organisation owned by PT. Socfin Indonesia. Date of issue of certificate will be the date on approval of this Assessment Report by the RSPO Secretariat. 2.0 AUDIT PROCESS 2.1 Certification body PT. SAI Global Indonesia Graha Iskandarsyah, 4 th floor Jl. Iskandarsyah Raya No. 66 C Kebayoran Baru, Jakarta 12160, Indonesia Phone : , Fax : Contact person : Mr. Joko Prayitno Certification Manager SAI Global is one of the world s leading business providers of independent assurance. SAI Global provides organisations around the world with information services and solutions for managing risk, achieving compliance and driving business improvement. We provide aggregated access services to Standards, Handbooks, Legislative and Property publications; we audit, certify and register your product, system or supply chain; we facilitate good governance and awareness of compliance, ethics and policy issues and provide training and improvement solutions to help individuals and organisations succeed. The SAI Global business is driven by two equally important client needs - the mandated need for QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 11 of 52

12 organisations to conform to regulations, standards and legislation in all their locations, and the operational need for organisations to improve business processes and procedures as well as corporate culture. As we are a global company, we can meet these needs for any client - those operating within one country's borders and in one language or those operating across borders and in many languages. There are three business units/divisions within SAI Global namely the Information Services Division, the Compliance Division, and the Assurance Division. The Assurance Division helps organisations manage risk, achieve process or product certification and drive improvement by providing training, registration audits and supplier management programs that can improve business performance. We provide independent audits, assessments and certification of your products or business processes to ensure they comply with industry standards or customer specific requirements. We understand how compliance with those standards can improve the efficiency, economy and profitability of your operation. With auditing and assessment staff located around the world, our clients include large global corporations as well as single site organisations. 2.2 Audit methodology SAI Global performed a pre-audit to RSPO Principles and Criteria on 9 March 2011 to review PT. Socfin Indonesia Tbk. s RSPO system, confirm the scope for certification, determine organisation s preparedness for Stage 2 (Certification) Audit; review the adequacy of the SAI Global audit program and resources for Stage 2 (Certification) Audit including confirming and preparing the draft audit plan. The Certification Audit was performed on 10 to 12 and 16 May The audit programme was included in the body of report. The audit methodology for collection of objective evidences is site inspection, documentation and record review and interview with staffs, workers, and other stakeholders. Objective evidences from documentation/record review in one area may also be cross checked with other objective evidences in other areas and with the evidence of implementation on site during the audit. Inputs from stakeholders via letter, , or other communication media were also considered for this certification audit. 2.3 Qualification of the lead auditor and audit team member Ria Gloria Lead Auditor Ria Gloria graduated with Bachelor of Chemical Engineering degree from Bandung Institute of Technology in She worked as an Environmental Consultant for many years. She has completed ISO (1995), ISO 9001 (2004), and RSPO (2009) lead auditor training courses, and SCCS (2010). For the last 8 years she has been involved in quality (ISO 9001) and environmental (ISO 14001) management system audits for very broad industrial and in the palm oil sector since 2003 for several plantations and mills. She has received training for good agricultural practices including integrated pest management and high conservation value ( ). Inge Triwulandari Audit Team Member Inge Triwulandari graduated with Bachelor of Chemical Engineering degree from Bandung Institute of Technology in She has completed ISO 9001 (2000), ISO (1997) lead auditor training courses, RSPO auditor (2008), and SCCS (2010). For the last 12 years she has been involved in quality (ISO 9001) and environmental (ISO 14001) management system audits including the palm oil sector since 2006 for several plantations and mills. She has received training for good agricultural practices including integrated pest management and high conservation value QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 12 of 52

13 ( ). Audit Report Sigit Yulianto Audit Team Member Sigit Yulianto graduated with Bachelor of Metallurgical Engineering degree from University of Indonesia in 1993 and Master of Occupational Health and Safety from the same university in He worked in the manufacturing industry for many years. He is also a certified OHS Expert in Indonesia. For the last 14 years he has been involved in quality (ISO 9001) and occupational health and safety management system audits for very broad industrial and service sectors including in the palm oil sector since 2008 for several plantations and mills. He has received training for good agricultural practices including integrated pest management and high conservation value ( ). Fadjar Deniswara Audit Team Member He graduated with Bachelor of Industrial Engineering degree from National Institute of Technology in Malang. He is a Lead Quality Auditor for ISO 9001:2008 with SAI Global and registered in RABQSA. He has an experience for more than 11 years in auditing. He has an experience in audit with company with labour intensive type (e.g. textile, garments, shoes, etc). He has also registered as SA 8000 certified auditor. He has received training for good agricultural practices including integrated pest management and high conservation value ( ). Irawan Y Bawono Audit Team Member Irawan Y Bawono graduated with Bachelor of Food Technology from Gadjah Mada University in He has completed ISO 9001 (2008), ISO (2005) lead auditor training courses, RSPO auditor (2008), and SCCS (2010). For the last 5 years he has been involved in quality (ISO 9001) and food safety management system (ISO and HACCP) audits including the palm oil sector since 2007 for several plantations and mills. He has received training for good agricultural practices including integrated pest management and high conservation value ( ). Resit Sözer Technical Specialist for HCV Issues Dutch nationality Biologist, since 1994 active in Indonesia in the field of Endangered Species research (Bornean Peacock Pheasant, Javan Hawk-eagle), Endangered Species surveys (Sumatran Rhino, Orang Utan, Javan Tiger), habitats surveys (conservation areas, HPH, oil palm plantations), wildlife trade surveys, wild animal rescue, reintroduction and restocking of wildlife, endangered species breeding programs (Bornean Peacock Pheasant, Javan Warty Pig, Blackwinged Starling), scientific publications and community involvement. 2.4 Stakeholder consultation Stakeholder consultation was performed to internal and external stakeholders. Internal stakeholders include staff and workers. External stakeholders were notified by placing an invitation to comment on the RSPO, PT. Socfin Indonesia and SAI Global websites. Letters were sent to individual stakeholders and telephone calls were performed to arrange meeting. Meetings and interviews with stakeholders as part of the audit were held. External stakeholders include government, NGO and civil societies who have interest in the organisation s area and resident communities. Consultations with interested parties were conducted during the audit, and some of the interview concerns the social aspect and HCV. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 13 of 52

14 List of stakeholders contacted Workers and Staffs Riyanto Harvester Watini Sprayer Herianto Processing operator at Mill Samsul Bahri Processing operator at Mill Sahala Labor Union Chairman Local community and Government Sudirah Head of Tanah Itam Ulu Village Soetiyono Head of Lubuk Besar Village Eddy Cendana CV. Rezza Pratama (FFB Supplier) 2.5 Date of next surveillance visit The next surveillance visit will be one year from approval of this report by the RSPO. 3.0 AUDIT FINDINGS 3.1 Summary of findings As mentioned above, objective evidences were obtained during the certification assessment for the entire RSPO indicator for 1 Mill and 1 Estate. The evidences for each major and minor indicator from each of these operational areas were aggregated to provide overall findings. Statements were provided for each of the Indicators to support the finding of the assessment team. During audit, 41 minor nonconformities against minor compliance indicators and 10 opportunities for improvement were issued. Detail of minor nonconformities and opportunities for improvement was provided in the body of report. PRINCIPLES 1: COMMITMENT TO TRANSPARENCY Criterion 1.1 Oil palm growers and millers provide adequate information to other stakeholders in environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation in decision making. Information request and their respond were determined in the procedure SOC/PSM/9.01 social communication. Communication procedure was established and implemented by the organisation. Communication procedure describes the method to follow up the information request from interested party. All requests received from stakeholder are responded by the organization in timely manner. Records of information request from stakeholder were kept by Mill and Estate. Most requests were initiated from community around the Estate (School Principal, Village Head, Village Institution) and also some request from Labour Department (Dinas Tenaga Kerja) and BPS (Central Bureau of Statistic/Biro Pusat Statistic). Some requests are pertinent to information labour data from Dinas Tenaga Kerja, production report from BPS and donation request from village head and village institution that were used for social activities for the community around the Estate. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 14 of 52

15 All information request from stake holder was listed and recorded by Mill and Estate. Record of information and respond was kept by the organisation. Retention time for records was determined with the minimum of 5 years. Criterion 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. SOC/PSM/9.01 dated 01 April 2011 was established in relation to responding to public s request in regards to legal documents. The form to record the respond and associated follow up on response has been established. However, according to the record, there was no request from public in regards to legal documents so far. The retention time on such record is 5 years. Management documents such as: HGU (Land Use Title), Plantation Operation Permit, ANDAL (Environmental Impact Analysis), RKL (Environmental Management Plan), RPL (Environmental Monitoring Plan) and CSR Program are available and accessible by the public. Initial Environmental Impact Assessment documents (ANDAL, RKL and RPL) which were approved by Department of Agriculture of Republic of Indonesia on March 17, 1994 for Tanah Gambus Mill and Estate were available. The document was revised and approved by Head of Asahan District Environmental Agency on August 8, The revised RKL and RPL were available at Tanah Gambus Mill and Estate. It was informed that the document is available to the stakeholders by request. CSR programs were available. The CSR program involved estates community. Activity plan for the year 2011 was available and approved by the top management. Social activity report for the year 2011 was established. Some activities were conducted such as road repairs, book donation to school, etc. Public s comments for CSR program are welcomed and their requests will be recorded in the annual CSR program. Opportunity for improvement It could be considered to use form that is required in the procedure SOP/PSM/9.01 for information and respond from stakeholder although information request was followed up with respond. It could be considered to evaluate CSR programs that were conducted by mill and estate in order to review the effectiveness of the CSR programs from mill and estate. It could be considered to improve employees understanding in relation to the CSR programs and related RSPO procedure by conducting socialisation of CSR programs and related RSPO procedure to all personnel at Mill and Estate. In the interview session during the audit, it was found that some employees and staff did not fully understand the RSPO procedures and CSR programs. PRINCIPLES 2: COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS Criterion 2.1 There is compliance with all applicable local, national and ratified international laws and regulations. Evidence of compliance with applicable local, national and ratified international laws and regulations of Tanah Gambus Mill and Estate have been provided, including valid permits (waste water discharge permit, river water and ground water abstraction permits, hazardous waste storage permit), provision of required infrastructure (waste water treatment ponds, hazardous waste storage), availability of MSDS, periodic environmental parameter monitoring (stationary QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 15 of 52

16 emission, ambient emission and ambient noise, moving source emission, waste water discharge quality, and ground water quality), system of plant cultivation, oil palm plantation, list of flora and fauna protected, management of guard area, minimum wage, labour law, occupational safety, and employee social benefit. The records were sighted for period January 2010 to March Evidence of compliance with applicable environmental laws and regulations which concern the operation of Tanah Gambus Mill and Estate has been evaluated internally as required by the procedure SOC/PSM/4.05. The procedure also describes mechanism for ensuring information of applicable environmental legal and other requirements were accessed, reviewed and applied. Updating of law and regulations change activities were well documented, and last update was performed in October Information on applicable legal and other requirements have been reviewed and summarised. Evaluation of compliance was documented within Identification, Summary and Status of Compliance. Last evaluation of compliance was performed in March There were some gaps identified for the utilisation of rain water against Environment Ministry Decree #12/2009. The gap was already completed with action plan that described the actions to be taken, delegation of responsibility and timeframe. Technic Department of Head Office in Medan is responsible to review most suitable application of the requirements, e.g. bio-pori or well. Minor non-conformance against criterion 2.1 Ministry of Agriculture Decree #7/permentan/sr.140/2/2007 have not been included in evaluation of compliance with law and regulations performed in March Moreover regulation regarding management of peat land Ministry of Agriculture Decree #14/permentan/PL.110/2/2009 was evaluated as non applicable regulation. Actually there is peat land in the organisation. The result of evaluation of compliance with regulation Act No. 3/1992 in regard to employee social benefit was reported complied to. In fact not all requirements have been complied, e.g. in regard to employee social benefit for non permanent employees. Criterion 2.2 The right to use land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights. The legal documents showing ownership and operation for Tanah Gambus Estate were evident, i.e.: The land use title o HGU #2/Perk. Tanah Gambus o Total area: Ha. o Make reference to land situation map #76/04/IV/1997, dated 23/01/1997. o Valid to May 7, 2020 Plantation operation unit: o Decree #HK.350/821/Dj.Bun.5/II/2002 o Total area: Ha o Palm Oil Mill: Permit capacity: 37 ton FFB/hour, Installed capacity 23 ton FFB/hour o Valid to December 31, 2023 Legal boundaries (peg) were indicated on land situation map. Totally, there re 40 pegs on the map. The availability of peg on plantation area was verified by sampling and found satisfactory. Regular maintenance was performed and included in inspection of HSE. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 16 of 52

17 Figure 2 Boundaries Pegs with Estate name There is no land conflict in Tanah Gambus Estate. Conflict settlement mechanism was described in the Procedure: Identification and Land Compensation Calculation SOC/PSM/9.05. Minor non-conformance against criterion 2.2 The maintenance of peg was reported on report of HSE inspection. However, in the report does not mentioned the number of peg, and therefore it was not clear if all pegs within map covered in maintenance activity. Criterion 2.3 Use of land for oil palm does not diminish the legal rights, or customary rights, of the other users, without their free, prior and informed consent. Planted areas of the estates are wholly on Government s land, leased under HGU as indicated above. No land settlement for the estate area mentioned above. Maps have been developed for estate indicating Legal demarcation and planted areas. PRINCIPLES 3: COMMITMENT TO LONG-TERM ECONOMIC AND FINANCIAL VIABILITY Criterion 3.1 There is an implemented management plan that aims to achieve long-term economic and financial viability. The long term plans for period 2011 to 2013 have been established. Key indicators have been included in the long term plan which include, crop projection = FFB yield trends, mill extraction rates = OER trends, Cost of Production = cost per tonne of CPO trends, forecast prices and financial indicators. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 17 of 52

18 The replanting plan for Tanah Gambus Estate has also been established for period 2011 to PRINCIPLES 4: USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS Criterion 4.1 Operating procedures are appropriately documented and consistently implemented and monitored. The organisation has developed Standard Operating Procedures for Oil Palm Plantation in SOC/PSM/7.10 dated 1 February The SOPs consist of procedures for several processes including land clearing, nursery, preparation before replanting, fertilizing, drainage system, integrated pest management, maintenance of immature and mature upkeep and harvesting. Other than there were also other procedures, e.g. SOC-KKS/IK/00 for planting of oil palm, SOC- KB/IK/07for road maintenance, SOC-KB/IK/01 for fertilising, SOC-KB/IK/02 for pesticide spraying, SOC/PSM/ for water management. Estate activities are programmed in annual program. Activities program such as fertilising, spraying, cleaning of trench and harvesting. Estate Manager and Assistant check and monitor the activities at site regularly. Site observation was performed during audit to some activities: fertilising, spraying, road maintenance, replanting, cleaning of trench, caterpillar census, picking of larva, harvesting. Activities have been performed at defined interval. Records of activities were sighted, e.g. Foreman Book, Daily Attendance and Overtime Sheet, General Workgroup Task, Data Collection Sheet. The record covered activities type, number of workers, quantity of agro chemical use, quantity of activities output and area of activities. FFB that processed by Tanah Gambus Mill is received from own estate (Tanah Gambus estate) and third party, CV. Reza Pratama that was not certifiable against RSPO requirements. The proportion of FFB from own estate is around 73% of all. All of the FFBs are processed in same facility (Tanah Gambus Mill). See the capacity on scope certification above. Tanah Gambus Mill s CPO and palm kernel delivered to FRF (Fractionation & Refinery Factory). Standard Operating Procedures (SOP) has been established that describes processing and quality control including its reporting from reception of FFB up to dispatch of Crude Palm Oil and Palm Kernel. The procedures are documented on SOC-POM/PSM/7.08 (FFB receiving), SOC- POM/PSM/7.09 (processing of CPO and palm kernel) and SOC-POM/PSM/7.06 (delivery). Work instructions for supporting Mill activities were also sighted: SOC-POM/IK/01 to SOC-POM/IK/16 for loading ramp, sterilizer, hoisting crane operation, stripper, screw presser, continuous tank operation, purifier, vacuum dryer, decanter, sludge separator, fat pit operation, nut silo, nut cracker, separating tank, kernel silo, and clay bath. A review operation daily report (January May 2011) and site observation found that in general the documented procedures described above has been consistently implemented and monitored, with few exceptions. FFB is graded according to the quality. Grading is recorded in FFB Receiving from Estate. Items recorded were date and hour received; block estate, division, weight and quality. The record is input to ERP (Enterprise Resources Planning) system; Harvest Plus. Rejected FFB is returned to supplier (only for third party FFB) Delivery of CPO and palm kernel is conducted according to the quantity of CPO and kernel in daily tank and virtual stock, respectively. In general, records reviewed found that this activity has been done appropriately as described by internal procedure. In process quality inspection and the final product inspection are conducted by laboratory and the daily record is sent to POM. Compliance to the specification was observed. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 18 of 52

19 Minor non-conformance against criterion 4.1 Violation to the defined procedure was observed at sterilization process. The cycle of sterilization was not conducted as required by working instruction. One peak of sterilization is done separately with the rest two peaks. Working Instruction for Sounding has not been established. Sounding reporting was not conducted in appropriate manner. Only one sounding record is reported in the daily report. Thermometer used for sounding has not been calibrated. Round test (proficiency test has been regularly conducted; however the result has not been analyzed (evaluated). Opportunity for improvement Consider to provide AC in laboratory. Criterion 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to, a level that ensures optimal and sustained yield. Soil and leaf sampling is analysed regularly to determine the nutritional status of soil, to assist and to be guided in the preparation of annual fertilising programme recommendation. Procedure of soil analysis SOC/PSM/ dated 1 March 2011 mentioned that soil is analysed every 5 years. Procedure of leaf sampling SOC/PSM/ dated 1 March 2011 mentioned that leaf is analysed annually two months after the first application. Method of sample taken and preparation of analysis was described in the procedure. Last soil and leaf sampling analysis was conducted by the external laboratory. Soil analysis was conducted by Param Agricultural Soil Surveys (M) SDN.BHD and leaf sampling analysis was conducted by CIRAD (Centre de coopération internationale en recherche agronomique pour le développement). Last report of soil analysis was issued in February 2007 and last report of leaf analysis was issued in June and July Method of soil sampling during analysis in 2007 was not clear. The method of sample taken was improved and described in the procedure. Schedule of soil analysis has been established. Next soil analysis will be conducted in Visual analysis of leaf is conducted by staff from Socfin Medan Head Office during site visit to Estate. Schedule for site visit to Estate was sighted. Visual analysis was conducted in January and February Result of visual analysis was reported in Nutritional Status of the Palms and Field Visit of Blocks. Report included observation result and its recommendation for improvement. Fertilising programme was developed by Agriculture Department in Socfin Medan Head Office assisted by CIRAD as consultant for all Division of Estate based on result of soil and leaf sampling analysis. PT. Socfin Indonesia does have own research institution. Fertilising programme covers area and time of application and type and dosage of fertiliser. Fertilising is performed manually. Result of fertilising was well recorded including date of application. It was noted that most of fertilising activity in the first semester has been applied. For the block which is replanted in 2012 was not fertilised. Fertilising activity was described in SOC-KB/IK/01. Legume cover crops (LCC) are grown to protect soil from erosion, improve soil fertility and control weed. The LCC grown is Mucuna brachteata. LCC is maintained through manual maintenance (cleaning from weed), fertilising and agrochemical spraying. Rock phosphate is used as fertiliser to grow LCC. LCC growth is monitored regularly. Fertilising program for LCC was sighted including the realisation. Empty fruit bunches (EFB) are applied in mature upkeep. Quantity and area applied was based on recommendation from Agriculture Department in Socfin Medan Head Office. EFB application was sighted. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 19 of 52

20 Land application of POME was not applied in the Estate. Minor non-conformance against criterion 4.2 Last soil analysis was reported in February Report mentioned that not all divisions were analysed. Criteria of soil analysed and location coverage of sampling point was not clear. Criterion 4.3 Practices minimise and control erosion and degradation of soils. Map of soil for Tanah Gambus Estate were available and documented in Soil of Tanah Gambus Oil Palm Estate issued by Param Agricultural Soil Surveys (M) SDN.BHD in June Map of soil mentioned that there were no fragile soil, there was 10% of area that poorly drainage and 15 ha is peat soil. Tanah Gambus Estate has slopes 0 to 24%. Work instruction SOC-KKS/IK/00 dated 1 November 2009 describes preparation for planting including planting on slopes area. The organisation do not recommend plantings on slopes >60%. System for planting on slopes area is provided through terracing, levelling of terrace, and determining of planting space. To minimise and control erosion in slope area, several practices have been implemented such as terracing and growing of legume cover crops. Procedure of road maintenance is described in SOC-KB/IK/07. Estate has established annual road maintenance programme for government road, primary road, and secondary road. Road maintenance in Tanah Gambus Estate was conducted manually and mechanically. Besides the annual program, road maintenance activity was also conducted according to road condition. Record of road maintenance realisation was sighted included block of plantation maintained and distance of road maintained. However, several parts of road was not well maintained. A work instruction on Best Management Practices for Peat Lands is available (Work instruction for peat land management, SOC-KB/IK/08 1 st May 2011). The ca. 15 ha peat area has been accurately mapped ( Map of peat land deepness ); this includes the distribution and depth of the peat. A water dam has been constructed to effectively maintain water level at cm in the peat area. It was noted that SOC-KB/IK/08 mentioned that peat land with deep >3 metre is not managed and if the area has been planted, the area should be maintained until the end of land use title. The organisation has procedure of soil erosion control on marginal land at mature planting. The procedure mentioned that soil erosion in mature upkeep is monitored every three months. It was noted that there was no area which has slope >60%. Minor non-conformance against criterion 4.3 Work instruction for peat land management, SOC-KB/IK/08 1 st May 2011 does not mention Piezo meters and monitoring procedures, the dam does not have a watergate which can be opened and closed, no Piezo meters have been applied, and no weekly water level monitoring data was available. Criterion 4.4 Practices maintain the quality and availability of surface and ground water. Bangun Bandar Estate was traversed by little river: A, B, C and Pluit River. Policy of riparian buffer zone management was provided in procedure SOC/PSM/9.06 dated 1 January 2011 and policy #PD-GM/KS/Bi/470/10 dated 2 September Policy mentioned that Estate is prohibited to straighten the river, activities with chemical are prohibited to be implemented in the riparian buffer zone, e.g. herbicide spraying and fertilizing, and oil palms in riparian buffer zone is not replanted and let them grow naturally. The width of riparian buffer zone was adjusted with the width of river and defined based on consideration of technical, social and economical. The width of riparian QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 20 of 52

21 buffer zone is range 8 meter to 100 meter. Border of riparian buffer zone was clearly identified by planting a line of Dracaena (Pohon Andong) or other vegetation which can propagate, easy to distinguish from surrounding vegetation. Warning board not to poison the fish, not to hunt and not to disturb riparian buffer zone was placed. Procedure of water management SOC/PSM/ has been established in Tanah Gambus Estate. Cleaning of primary and secondary trench is programmed annually. Realisation of cleaning the primary and secondary trench was recorded including length of trench cleaned. It was noted that primary and secondary trench in Block 8 Peat land area is planned to be maintained monthly. Record of trench maintenance was sighted. Quality of A, B, C and Pluit Water River is planned to be analysed annually. Quality of A, B, C and Pluit Water River is being analysed by Laboratory of North Sumatera District Environmental Agency. Water sample was sent to the Laboratory on 8 April Result of analysis has not been finished by the Laboratory yet. The quality of Water River in analysed annually. Tanah Gambus Mill has established Water Management Plan, SOC/PSM/4.22, which was issued in October The plan described identification of water supply and arrangement of any necessary permit, measurements of water consumption, and water distribution. It was sighted that currently there were six ground water wells (deep well) which currently still held valid permit from relevant authorities. Tanah Gambus Mill is located in the same area with Tanah Gambus Fractionation and Refining Factory also Tanah Gambus Palm Kernel Oil Factory. The three factories shared the same water supplies. The water supply, distribution and consumption were described in water management document, SOC/DP Distribution and consumption of water for each area was reported monthly (SOC/Form/ ). The volume abstracted from each well was monitored monthly, and well water logbook was sighted. Tanah Gambus Mill water consumption was estimated about 35% of total water consumption (Fractionation and Refining Factory, Palm Kernel Oil Factory, domestic, office and laboratory. Portion of water consumption by Tanah Gambus Mill was monitored monthly including its efficiency (cubic meter of water per ton of FFB processed). Environmental Monitoring Plan requires that quality of waste water discharged from Tanah Gambus Mill waste water treatment ponds were monitored monthly including BOD. Evidence of monitoring of BOD was reviewed for period January 2010 to March 2011 against environmental limit required by Environment Ministry Decree #51/Menlh/10/1995 annexure BIV. Minor non-conformance against criterion 4.4 Quality of A, B, C and Pluit Water River and swamp water outlet is being analysed by Laboratory of Bapedalda Sumantera Utara. Water sample was sent to the Laboratory on 8 April Result of analysis has not been finished by the Laboratory yet. Criterion 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques. Procedure for IPM to control pests, diseases and invasive introduced species has been established in SOC/PSM/ for IPM of Caterpillar and Bagworm Attack, SOC/PSM/ for IPM of Oryctes rhinoceros, circular letter #Tan/Keb.KS/Bi/88/2005 dated 6 May 2005 for IPM of rodent, circular letter #TN/KS/Bi/016/2006 dated 22 December 2006 for IPM of beneficial plant program. These procedures include setting out of technique to be implemented, chemical to be used, locations to be applied, and time frame for implementation. Program for IPM implementation is established annually. IPM programme includes pest and diseases detection, census and controlling of pest population, use of pesticide and herbicide. The implementation of IPM is monitored. Census of caterpillar is conducted regularly to determine its controlling. Controlling is performed based on level of attack and level of mortality. There are QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 21 of 52

22 three levels of attack: low, medium and high. Result of census was recorded including area of census, type of caterpillar, quantity of caterpillar and level of incident. Types of controlling of caterpillar are hand picking, truck injection, agrochemical spraying, high pressure spraying or fogging. These controlling is applied based on level of incident. The use of agrochemical (dosage and concentration) was also recorded when caterpillar was controlled by agrochemical use. One of controlling of Oryctes rhinoceros is through picking of Oryctes rhinoceros and its larva. Picking of the Oryctes rhinoceros and its larva was conducted at the decayed parts of such palms, the palms naturally fallen and the palms still standing but presenting rotten tissues at the bottom. The controlling was conducted in immature and land clearing area. Quantity of Oryctes rhinoceros and its larva was recorded. Census of Oryctes rhinoceros is also performed monthly. Result of Oryctes rhinoceros attack and map of attack was sighted. Agro chemical spraying is performed if Oryctes rhinoceros attack are higher than the critical point. Planting and nursery of beneficial plant was reported however the growth and length of beneficial plant was not monitored. Training of IPM has been performed to Division Assistant, Pest Foreman, and Census Foreman. List of participant attendance was sighted. Pesticide toxicity units (a.i. / LD 50 / FFB tonnage) to illustrate reduction of pesticide use have not been monitored to active ingredient. The organisation requested the external laboratory to analyse the residue of active ingredients (i.e. deltametrin, sipermetrin and λ-sihalotrin) of agro chemical in FFB and CPO. The result mentioned that the active ingredients were not detected in FFB and CPO. Minor non-conformance against criterion 4.5 There was no monitoring extent of IPM implementation regarding growth of beneficial plants. Circular letter #Tan/Keb.KS/Bi/88/2005 regarding rodent controlling required that census of rodent is conducted monthly at the same time with census of caterpillar. There was no evident that census of rodent was conducted. There was no monitoring of pesticide toxicity units (a.i. active ingredient / LD50 per tonne of FFB or per hectare). Opportunity for improvement Although IPM techniques regarding rodent controlling and beneficial plant program has been developed in the circular letter, it could be considered to establish the IPM techniques in the documentation system. Criteria 4.6 Agrochemicals are used in a way that does not endanger health or the environment. There is no prophylactic use of pesticides, except in specific situations identified in national Best Practice guidelines. Where agrochemicals are used that are categorised as World Health Organisation Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented. Agrochemicals used by Tanah Gambus Estate has been registered and licensed by Agriculture Department, e.g. Round up 486 SL license RI expired on 18 March 2016, Gramoxone 276 SL license RI 36/8-2006/T expired on 8 September 2011, Ally 20 WDG license RI 837/4-2009/T expired on 30 April 2014, Metaprima 20 WDG RI 1897/7-2008/T expired on 7 August It was noted that there were no agrochemicals being used which are not on this register during this audit. Agrochemicals use and their register number refer to Pesticide Commission Book Buku Komisi Pestisida Agrochemicals used have been recorded including active ingredient used, area treated, amount applied per ha, use of selective product and number of applications. Several record of pesticide used was sighted, e.g. application schedule, list of pesticide use in oil palm estate, work QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 22 of 52

23 achievement and pesticide use, stock card of agrochemicals. The records were sighted in all Divisions. During audit, spraying of weed was observed in Division #3. It was noted that pesticides (gramoxone and ally) used was registered agrochemicals. Dosage of pesticides use, target weed was inline with circular letter #TN/SE/KS/Bi/020/2007. It was noted that agrochemicals used were inline with target pest, weed or disease, determined dosage, and applied by qualified person. PPE used during spraying of pesticides are boots, apron, safety glass, respiratory mask and hand gloves. Agrochemicals have been applied by qualified persons who have received usage of limited pesticide training. Training was delivered by supplier on 18 February 2009 and 11 October 2010 and by North Sumatera Health Department and Pesticide Commission on 4 April Training record was sighted for sprayers in all estates. Training covered handling of concentrate chemical and spraying method. Agrochemicals are stored in the determined area separated from fertiliser and other chemicals. Agrochemicals storage is provided in each Division. Agrochemicals storage is locked areas with limited access. The storage is ventilated through cross flow ventilation. MSDS and hazard symbol label are provided nearby of agrochemicals. Emergency shower and eyewash are also provided to anticipate in case of an emergency of chemical handling. PPE for handling of chemicals are provided including boots, apron, safety glass, respiratory mask and hand gloves. Spill kit for agrochemical spill handling is provided. Prior to be used in the field, agrochemical was diluted in Division Office. There is a designated area of mixing which was completed with roof, secondary containment and information of agrochemical hazard. The area is also used for cleaning the agrochemical containers and fertiliser sacks. Figure 3 Facility to mix agrochemicals Handling of empty agrochemical containers was described in procedure SOC/DP/ All empty agrochemical containers were triple rinsed and destroyed prior to be disposed in the designated area and separated with organic and inorganic waste landfill. Records of chemical containers quantity disposed and photograph of disposal activity were evident. The other empty agrochemical containers can be reused during spraying. Paraquat is still used in Tanah Gambus Estate. Agriculture Department of Medan Head Office has defined 20-25% reduction of paraquat use for Tanah Gambus Estate in Data of paraquat used is provided since It was observed that paraquat use was fluctuated year to year. Each QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 23 of 52

24 division has established monthly program of paraquat use. The realisation was reported to Agriculture Department of Medan Head Office to control paraquat use. There are medical checks up to all workers. Medical check up for agrochemical operators is conducted annually. Medical check up 2011 was sighted for all agrochemical operators in Tanah Gambus Estate. Results of medical check up in general were good. Ethic policy mentioned that no work with pesticides for pregnant and breastfeeding women. All divisions still involve women as pesticides sprayer. To ensure that there were no pregnant and breastfeeding women during spraying of pesticides, there are lists of women worker including data of monthly checking conducted by nurses. Minor non-conformance against criterion 4.6 Decis 25 EC with active ingredient Delta metrin was used within organisation. The agro chemical has had license from Department of Agriculture however the agro chemical has not been registered in the list of pesticide used within organisation. Opportunity for improvement: It could be considered to improve record of paraquat consumption, e.g. report the percentage of target consumption. Criterion 4.7 An occupational health and safety plan is documented, effectively communicated and implemented. It was noted that Tanah Gambus Mill and Estate has been certified to occupational health and safety management system based on OHSAS 18001: 2007 by SAI Global. Occupational health and safety policy has been established and has signed by the highest management level. The policy statement includes the commitment to prevent injury and ill health, to comply with regulation and for continual improvement. The policy was made available to be accessed by employees and other stack holder and displayed on strategic locations of Estate Office and Mill Office. Occupational health and safety target and programme are established annually for Mill and Estate. The target and programme 2011 was sighted with the main target and programme was in regard to zero accident and zero ill health. A safety committee has been established and already approved by local authority. The chairman of the committee is the highest level management of estate and the secretary of the committee is the OHS expert (AK3U) and the member consists of representative of each section. OHS expert is also a safety officer and acts as a representative on health and safety. The Safety Committee is responsible for the OHS programme and its implementation. Monthly meeting was held by Safety Committee to review the progress and implementation of OHS programme. Results of the meeting including the recommendation and action plan were recorded in the minutes of meeting - these were sighted during the audit. In the employees level, a daily briefing is performed by supervisor to his/her members. In this event, the supervisor provides briefing on the issues of production including health and safety issues such as the use of PPE and accident prevention. Health and safety inspection was performed by the Safety Officer to identify any unsafe acts and conditions. Records of health and safety inspections were sighted. The hazard exists in the operations and activities of Mill and Estate were identified and the risks were assessed using documented risk assessment methodology. Hierarchy of control principle was applied to determine risk control. It was noted that most risks were controlled by combination QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 24 of 52

25 of establishment of procedure or work instruction, safety signage and the use of PPE. Sighted procedures or work instructions were included for estate activities such as planting/re-planting, fertilizing, insecticide, herbicide and pesticide spraying, road maintenance and harvesting, clinic and warehouse. Division warehouse were observed during the audit. MSDS and hazard symbol label were provided nearby of chemicals. Emergency shower and eyewash was also provided to anticipate in case of an emergency of chemical handling. PPE for handling of chemicals were provided including boots, apron, safety glass, respiratory mask and hand gloves. Fertilizer warehouse has a good air circulation. Several activities in estate were observed during the audit e.g. spraying and harvesting. The workers for spraying were provided with PPE including boots, apron, respiratory mask, safety glass and hand gloves. Hazard symbol label was provided at the container of pesticide/herbicide/insecticide. Interview with workers indicated that they have a good understanding on hazard and risk of their work. Interview with workers also indicated that they were provided by the organisation with the medical facilities (clinic or referred hospital). The supervisors were provided with first aid kit. Transportation and heavy vehicles for Estate activities such as tractor, trailer and grader were regularly maintained. The operators (drivers) were found having license from local authority (SIO). Workshops were available at Mill. Small compressor tanks were certified by local authority. Gas cylinders were placed and chained to prevent unintended fall and also provided with flash back arrester (non-returnable valve). PPE for welder was appropriately provided. Welders were also certified by local authority. The fuel tank was also available. Hazard symbol label was provided at the tank. Fire extinguishers were also provided appropriately. As for Tanah Gambus Mill, the risk assessment has been conducted; sighted records including for receiving and handling of FFB, sterilizer, boiler, crane operation, conveyor, cleaning of CPO tank, maintenance and workshop, laboratory. Procedure and work instructions were also established to control the operation including controlling the risk. Evident of risk control were sighted e.g.: Boilers were tested and certified in accordance to local regulations. Regular maintenance was also performed except for finding below. Process parameters of boiler operation was established, controlled, and recorded. Boiler operators were certified by local authority. Regular maintenance was also performed and the operators were also certified and trained in accordance with local regulations. Pressurized vessels (sterilizer, compressor tanks) were tested and certified in accordance to local regulations and completed with safety valve and pressure gauge. Fuel tanks were completed with secondary containment and fire extinguishers. Lock Out Tag Out procedure was in place and implemented especially for maintenance activities. Permit to Work procedure was also established and implemented for high risk activities and work of contractor. Workers were wearing appropriate PPE. Safety signage was properly provided at locations of Mill. Most stair/ladders were provided with the hand rail. The organisation provides accident insurance to employees-however currently only for permanent employee, see finding below. Clinic was also available to provide medicine and medical treatment to employees and family. According to the organisation s policy, annual medical check-up to all employees is performed. Medical check up 2010 was sighted for Tanah Gambus Mill and Estate. Results of medical check up in general were good and a few employees have been referred to specialist doctors for further checking. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 25 of 52

26 The training in regard to occupational health and safety has been provided and sighted during the audit including for OHS expert for Mill and Estate, first aid, spraying, emergency response and preparedness, heavy vehicle operators, OHS socialization, chemical handling, manual handling, boiler operators, crane operators, etc. Training records were maintained. The procedure for emergency preparedness and response has been established. The procedures include fire and explosion, toxically emergency, chemical spillage. The organisational structures emergency response and preparedness were established at Mill and Estate. The organisation structure mainly consists of commander, medical team, evacuation team, fire fighting. The responsibilities and authorities of team were defined and documented. The important telephone numbers for external parties were also identified for emergency purpose e.g. hospital, police and local fire brigade. The emergency response and preparedness equipments are provided and regularly inspected e.g. fire extinguisher, water tank truck, water pump, and hydrant. The schedule for exercising the emergency response and preparedness was established and sighted for Fire emergency response and preparedness procedures have been exercised for the Mill and Estate. Last emergency simulation was conducted on June 2010 (Mill) and February 2011 (Estate). The first aider training was given by the organisation doctor to supervisors, assistant, supervisor and group leaders both for Mill and Estate. They were also provided with first aid kits. Records of such training were sighted. They were daily in charge in operation of the Mill and Estate and in case an emergency, they will be immediately able to provide first aids treatment. The system to record accident was established in the form of procedure. The procedure was dealing with accident reporting, investigation as well as corrective and preventive action to prevent action. Minor non-conformance against criterion 4.7: It was found non-permanent employees working for loading FFB to truck without worn PPE considering the risk. Found not well condition of road for transportation by vehicle and workers which normally using motorcycle at Division III. The wheel tractor driver was holding license from the police (SIM B) while actually need Operator license from manpower authority (SIO). It was found unsafe act where the helper of wheel tractor standing on no proper place while wheel tractor working. Found non-permanent employee (harvester) working without using glass as required by work instruction SOC-KKS/IK/07. He was wearing shoe but the shoe not provided by the organisation. The cover of harvesting tool was not a standard and creating hazard. Found several poor conditions of electricity at mill, e.g. most electrical panel with electrical hazard were accessible by un-authorized persons. Found a very un-maintained of welding machine at the mill which may create unsafe condition. Found contractor work unsafely, e.g. welding cutting operator did not wear welding mask, the LPG cylinder was put horizontally. Immediate action was performed by Manager by providing briefing to the contractor. The cleaning CPO tank just been recently performed in beginning May However, the confined space entry guideline including safe work permit was not implemented. The access way (stair and platform) for moder bath, was not appropriate. Accident insurance scheme for non-permanent employees has not been established and provided. Note: The above mentioned issues will be an important area for the surveillance audit to be assessed. Criterion 4.8 All staff, workers, small holders and contractors are appropriately trained. The competency requirements were set and established in the form of personnel qualification for QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 26 of 52

27 all functions within organization including for estate manager, factory manager, supervisors of estate and mill, foreman, sprayer, harvester, heavy equipment operator. The competency requirements consist of education, experience and training. The annual training plan 2010 was sighted and most of the plan has been realized. Evaluation of training was performed after training realization. The system to record the training record of each employee was established in the form of employee training history. The training plan 2011 has not been approved by the management, even the budget amounting IDR 540,288 for external training has been allocated. The work of contractor was occupied by the contract agreement. The requirement that the contractor provide the trained person was included in the contract, e.g. Contract with CV. Surya Baru for land clearing. The work permit system was established to control the work of contractor. Minor non-conformance against criterion 4.8 Training plan for 2011 has not been established. It was noted that some employees have not completely follow the training stated in personnel qualification e.g. Spraying Supervisor and Processing Supervisor. PRINCIPLES 5: ENVIRONMENTAL RESPONSIBILITY AND CONSERVATION OF NATURAL RESOURCES AND BIODIVERSITY Criterion 5.1 Aspect of plantation and mill management, including replanting, that have environmental impacts are identified, and plant to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. Initial Environmental Impact Assessment documents (ANDAL, RKL and RPL) which were approved by Department of Agriculture of Republic of Indonesia on March 17, 1994 for Tanah Gambus Mill and Estate were available. The document was revised and approved by Head of Asahan District Environmental Agency on August 18, Tanah Gambus Mill and Estate implemented procedure for identifying environmental aspect and evaluating its impact based on Environmental Management System ISO 14001:2004, SOC/PSM/4.04. The result of environmental aspect and impact identification and evaluation was documented within Identification of Environmental Aspect, SOC/Form/ As required by the procedure, the information of environmental is reviewed and updated regularly. Last review and update of environmental aspect and impact register for Tanah Gambus Mill and Estate was performed on March 01, Tanah Gambus Mill and Estate has ensured that all activities with significant environmental impacts were managed. Control measure were defined and implemented for ensuring that negative environmental impact were prevented or mitigated. There were two types of control measures defined: engineering control and administrative control. Detail of control measure applied for each activity was described in Significant Environmental Aspect Management, SOC/Form/ , which was last updated on March 01, The implementation of those control measures are monitored during monthly environmental patrol and also round of internal audits. Implementation of Environmental Management Plan and Environmental Monitoring Plan is reported quarterly. For 2010 report was sighted for March 2010, August 2010 and December First quarter report for 2011 (March 2011) already established and sent to Batubara District Environmental Agency completed with receipt. Minor non-conformance against criterion 5.1 Environmental impact of high pressure sprayer (HPS) has not been analysed. Criterion 5.2 The status of rare, threatened or endangered species and high conservation QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 27 of 52

28 value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations A High Conservation Value Management Plan has been prepared, and available at the site. Posters and sign boards concerning HCV areas and protected species are available in the necessary places. All staff and employees are informed about HCV areas and ERT species. Public consultation was carried out at Lima Puluh Sub-district on August 19, 2010, participated by 34 people representing the local community and government. Identification of any protected, rare, threatened or endangered species and HCV habitat has been performed by Forestry Department of Bogor Agricultural Institute (IPB) for PT. Socfin Indonesia Tanah Gambus Estate. The HCV assessment performed in September to October Appropriate measures to preserve rare, threatened or endangered species or high conservation value habitats have been taken in Tanah Gambus Estate. The organisation established procedure SOC/PSM/9.07 to manage HCV area. The HCV management and monitoring plan has been prepared. It was sighted that the management and monitoring plan were consistent with the identified HCV in the assessment report. HCV 1.1, HCV 1.2, HCV 4.1 and HCV 6 were identified. HCV 1.1 and HCV 4.1 are located in riparian buffer zone of the A, B, C and Pluit River and Swamp Forest (76.51 Ha). Swamp forest only contains vegetation of weeds not virgin forest. Species of bird endangered based on red list of IUCN was identified, e.g. Alcedo euryzona. Species of mammal found was Lutra sumatrana. Public cemetery was identified as HCV 6. Figure 4 Swamp Forest (1) The HCV management and monitoring plan described measures taken for each HCV and its monitoring. Relevant laws were taken into account for determining appropriate measure including Government regulation #7/1999, President Decree #32/1990, and Government regulation #35/1991. HCV management areas maps were established. The riparian buffer of the River is currently well managed. Activities with chemical are prohibited to be implemented in the riparian buffer zone, e.g. herbicide spraying and fertilizing. Border of riparian buffer zone was clearly identified by planting a line of Dracaena (Pohon Andong) or other vegetation which can propagate, easy to distinguish from surrounding vegetation. Warning board not to poison the fish, not to hunt and not to disturb riparian buffer zone was placed. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 28 of 52

29 Tanah Gambus Estate has appointed HCV officer to ensure the implementation of management and monitoring plan. Monitoring records were sighted to ensure that management plan is implemented, e.g. warning sign and board monitoring, monitoring of nuisance, river water quality monitoring, availability of flora and fauna classified as HCV. Figure 5 Swamp Forest (2) Minor non-conformance against criterion 5.2 Availability and condition of HCV 6 regarding public cemetery was not monitored. Opportunity for improvement It could be considered to improve monitoring of fauna sighted was also conducted by foreman. Criterion 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner. Identification of waste and pollution sources from Tanah Gambus Mill and Estate activities was evident. The source of pollution and type of waste was documented within Identification of Environmental Aspect, SOC/Form/ , last updated on March List of significant environmental aspect management described control measure applied for each waste including engineering control and administrative control. Procedure for waste handling was established and implemented, SOC/PSM/4.11. The procedure required that waste to be segregated from point of generation. Mill and Estate also established Waste Register, SOC/Form/ , which described wastes generated from each activity/location, its classification (organic, inorganic or hazardous), and its control measure. Empty agrochemical containers from Estate activities were cleaned using a triple rinse method. Empty agrochemical cans and bottles were disposed to landfill and separated from organic and inorganic. Quantity of empty agrochemical cans and bottles disposed was recorded and photograph of empty agrochemical cans and bottles landfilling was sighted. Empty agrochemical jerrycans were reused for chemical solution during spraying. Fertiliser sacks were cleaned prior to be reused for piece of FFB layer during harvesting. Quantity of empty agrochemical jerrycans cleaned fertiliser sacks cleaned was recorded. All Divisions in Tanah Gambus Estate have been completed with area to clean hazardous chemical containers and fertiliser sacks. Liquid waste from QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 29 of 52

30 cleaning was reused for chemical dilution during spraying. EFB, solid from decanter, boiler ash was used as organic fertiliser in Tanah Gambus Estate. The quantity sent to Estate was weighted and weighing docket kept as record. Organic and inorganic waste from Tanah Gambus Mill and Estate were sent to active land fill constructed at Estate Area, e.g. weighing docket #WT/E1205/2011/ May 12, 2011, of organic waste to Division 1, and weighing docket #WT/E1205/2011/ May 12, 2011, of inorganic waste to Division 3. Hazardous wastes were collected, stored and disposed inline with Procedure SOC/PSM/4.11. Temporary storage of hazardous waste was available to store hazardous waste prior to be disposed to licensed vendor. Tanah Gambus Mill hazardous waste storage still held valid permit. Disposal of hazardous waste to licensed vendor was managed in coordination with Technical Department in Medan Head Office. Disposal of hazardous waste was completed with manifest. Hazardous waste balance was made and reported regularly as part of Environmental Management and Monitoring Plan implementation report. Minor non-conformance against criterion 5.3 Some inconsistencies of waste management and hazardous material management were identified: (Estate) o Briefing regarding segregation of organic and inorganic wastes is not conducted monthly. o Provision of temporary storage of organic and inorganic waste was not reported. Some inconsistencies of waste management and hazardous material management were identified: (Mill) o Waste battery was disposed on February 2011 through PT Bekasi Environmental Service to CV Yudhi Raja Mandiri, however both vendors have no license to collect waste battery. o No evidence that vehicle used for transporting waste oil and waste battery from Tanah Gambus on February, , BK8227ND, as documented in the disposal manifests ZE and YR has valid permit for hazardous waste transporting. o Hazardous waste balance reported on February 2011 was not complete, only covered waste disposed to third party, but not covered hazardous waste stored and used. Criterion 5.4 Efficiency of energy use and use of renewable energy is maximised. Fibre and shell were used as boiler feed. Volume of fibre and shell used for boiler feed was estimated monthly. Record sighted for January April The quantity fibre generated from the Mill was estimated about 12.5% of FFB processed and shell about 7% of FFB processed. Total energy generated by steam turbine generator for Tanah Gambus Mill was recorded daily and evaluated monthly as total energy (kilo Watt Hour - kwh) per ton of CPO produced. There was improvement project to reduce the use of shell to avoid high opacity of boiler stack emission. Currently shell was only used when supply of fibre was not adequate therefore fibre is the main boiler feed supply (when only one of two screwdriver active) and set automatic. Remaining shell was kept as stock and its volume was recorded. Fossil fuel used for Mill activities were recorded in the logistic system. Total fuel consumption was summarised monthly as litre of diesel fuel per ton of FFB processed. Record sighted for January April Criteria 5.5 Use of fire for waste disposal and for preparing land for replanting is avoided QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 30 of 52

31 except in specific situations, as identified in the ASEAN guidelines or other regional best practice. The organisation has policy of zero burning documented in Ethics Policy SOC/Dp/ clause 11, procedure of replanting and circular letter #PD-GM/KS/Bi/470/10. The requirement of zero burning was communicated to contractors who conducted replanting activities. This was documented in attachment #2 of contractual agreement between the organisation and contractor. Replanting was conducted in the early of Realisation of replanting activities was well documented and reported including activities of chipping, ripping, cleaning ditch, making ditch and total area replanted. Zero burning activity was monitored during HSE inspection. Replanting was conducted in Division #1 and #4. Procedure of responding of land burning emergencies has been established in SOC/DP/ The organisational structures emergency response and preparedness were established at Estate. The organisation structure mainly consists of commander, medical team, evacuation team, fire fighting. The responsibilities and authorities of team were defined and documented. Fire extinguisher and the other facilities (e.g. weeds hook, fire beater and water tank) to respond land burning emergencies have been provided. Simulation of land burning emergencies was conducted on 24 December 2010 in Block #23A. Result of the simulation has been evaluated. Minor non-conformance against criterion 5.5 Although emergency responses to land burning has been tested/drilled at site however scenario of land burning drill did not refer to procedure of emergency response to land burning. Moreover evaluation of drill against procedure was not accurate. Facilities to respond land burning have been provided at each division however availability and condition of all facilities have not been monitored. Criterion 5.6 Plans to reduce pollution and emissions, including greenhouse gasses, are developed, implemented and monitored. Monitoring of pollution and emission quality of sources identified were performed inline with Environmental Monitoring Plan. In addition, annual monitoring and measuring plan was established. Year 2010 and first semester of 2011 monitoring and measuring reports were sighted for boiler emission against Environment Ministry Decree #07/2007, diesel electricity generator against Environment Ministry Decree #Kep13/Menlh/3/95, vehicle and heavy equipment emission against Environment Ministry Decree #05/2006, odour emission against Environment Ministry Decree #50/Menlh/11/96, ambient noise against Environment Ministry Decree #48/Menlh/11/96, also ambient air quality against Government Regulation #41/1999. Tanah Gambus Mill waste water was processed through a series of waste water treatment ponds. The operation of waste water treatment ponds is described in work guidance SOC/DP/ Process parameter monitoring and maintenance of the ponds were sighted. Quality of waste water effluent was monitored monthly by approved laboratory. The results of monitoring of waste water effluent were reviewed including measurement of BOD for period 2010 until first quarter of Measurement result was inline with Environment Ministry Decree #51/Menlh/10/1995 annexure BIV. PRINCIPLES 6: RESPONSIBLE CONSIDERATION OF EMPLOYEES AND INDIVIDUALS AND COMMUNITIES AFFECTED BY GROWERS AND MILLS Criterion 6.1 Aspects of plantation and mill management including replanting 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. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 31 of 52

32 Social impact assessment was conducted by the organisation. Assessment was conducted through PRA (Participatory Rural Appraisal) and involved the local community. And also some interview was conducted with leaders community. This assessment was conducted during period June to September 2010 and January Scope of assessment covered villages: Tanah Itam Ulu, Perkebunan Lima Puluh, Lubuk Besar and Simpang Gambus. Positive impacts were identified, such as: increased income of the village economy ease of road access Negative impacts were identified, such as: ash and smell from the mill Action plan to implement and monitor social impact with community has been determined. Positive impacts were maintained with organisation and necessary action was planned by the organization. And negative impacts (ash and smell) were followed up with corrective action. According to public interview, they explained that ash and smell was reduced. Criterion 6.2 There are open and transparent methods for communication and consultation between growers and/or millers, local communities and other affected or interested parties. Procedure for communication and consultation with public was determined in the SOC/PSM/9.01. Stage of communication and consultation with public was described in the procedure and it has been socialized to stake holder. RSPO Officer/Estate Manger was responsible to coordinate communication and consultation. Result of communication and consultation was recorded in the log book. Stakeholder list was made and mentioned interested party. Stakeholder list covered head of villages, head of district, Forestry and Plantation Agency, Environmental Agency, National Land Agency (BPN), and NGO. Community aspirations were kept and recorded by the RSPO Officer, e.g. road maintenance, donation, scholarship. Records and interview result indicated that aspiration from community was followed up by the organisation. Interview result with farmer group was concluded that the prices paid for FFB was transparent and complied with agreement. Mill has same perception during FFB receiving. Payment is conducted based on agreed schedule every three days. Criterion 6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties Procedure for complaints and grievances was determined and agreed by related parties (head of villages). And procedure was made without compulsion from other interest parties. The procedure was described in the documented procedure SOC/PSM/ Procedure s socialization was evident and documented. There were no complaints from related parties Criterion 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 stakeholders to express their view through their own representative QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 32 of 52

33 institutions. Audit Report Compensation and calculation identification pertinent for loss legal or customary rights was determined in the procedure SOC/SPM/9.05. It was noted that there was no acquire any new land Criterion 6.5 Pay and condition for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages Documentation of employees pay rates was made by the organization. Workers were classified into daily employees (Karyawan Harian Tetap (KHT)), monthly employee (pegawai bulanan) and staff. Evidence that the workers have received wage according regulation could be shown. Wages payment refers to North Sumatera Governor s Decree Letter /674/KPTS/2010 and Worker Union Federation (SK-Gubernur Sumatera Utara /674/KPTS/2010 and Federasi Serikat Pekerja). Payments for workers were determined according to daily attendance. Workers daily attendance were recorded and controlled by the Foreman. It was evident that the wage was paid according to working hours and daily attendance. According to interview result with worker, it was assumed that wage received by the workers was complied with the determined regulations. Beside of wages, worker also receives rice that was distributed twice a month. This was mentioned in the Joint Working Agreement (PKB) year 2010 between employees and the organisation. Some contractors employed by the organisation such as land clearing by Agriculture Department and civil work by the Technical Department. Working agreement with contractor could be shown however the working agreement did not require that the contractors abide by labour laws. Public facilities were provided by the organisation and covered residential facilities, day care, education, clean water. Housing was provided for all workers. Agreement of approval for staying in the housing was made for workers. Minor nonconformity against Criterion 6.5 According to site visit to housing (Housing I and IV), it was found that the room condition is very hot due to not proper roof. There was no stock for vitamin at clinic central and clinic division where it is needed for women worker at spraying. Opportunity for improvement It can be considered to socialise wage calculation to all worker, some of worker do not understand how to calculate wage for over time. Criterion 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. A published statement in local languages recognizing freedom of association was stated in the Ethics Policy SOC/DP/ (Kebijakan Etika SOC/DP/ ) and approved by the top management. Memorandum stated that the organisation respect to comply with regulation pertinent to freedom of association. Also PKB stated that freedom of association can be conducted QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 33 of 52

34 by the worker through Labour Union. Audit Report Indonesian Worker Union (Serikat Pekerja Seluruh Indonesia (SPSI)) was established for Mill and Estate. Worker representative was available and they conduct a communication with the Labour Union at Head Office Medan. Labour Union for Bangun Bandar Mill and Estate was established. The organisation of Labour Union covered Chairman/Vice and Secretary PKB was established and agreed between workers and organisation. Minor nonconformity against Criterion 6.6. Meeting with Labour Union was conducted, however it was not recorded. Criterion 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. Organisation has policy for minimum age for worker and mentioned in the Ethics Policy and the PKB. List of worker and related document was verified and there is no worker under 18 years old. List of worker and related document was verified and there was no worker under 18 years old. According to observation result in Mill and Estate, there was no worker under 18 years old Organisation using family harvesting during harvesting, names of family members that involved during harvesting were identified. It was evidence that family members are aged more than 18 years old. Criterion 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. Policy against discrimination was determined by the organisation. All discriminations are prohibited for all area in Mill and Estate. PKB also mentioned ban of discrimination for all worker in the organisation. Worker list of Mill and Estate mentioned that all workers came from different back grounds (race, religion, gender). Criterion 6.9 A policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied. Policy for sexual harassment and violence was determined in the Ethics Policy and PKB. Gender committee was established by the organisation. The committee has representatives from all areas of work. The committee consider matters such as; trainings on women s rights, counselling for women affected by violence, child care facilities to be provided by the growers and millers, women to be allowed to breastfeed up to nine months before resuming chemical spraying or usage tasks, and women to be given specific break times to enable effective breastfeeding. Complaint handling procedure for sexual harassment was determined. All complaints can be issued verbal and or written and informed to all administrator, gender committee and Mill/Estate Manager. QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 34 of 52

35 It was found that complaint pertinent to sexual harassment was followed up according to determined procedure. Refer complaint Ruhiyah Foreman, dated 30 April This case was solved according to determined procedure and organisation regulation. All actions were recorded. Criterion 6.10 Growers and mills deal fairly and transparently with smallholders and other local business. Pricing mechanisms for Fresh Fruit Bunch was described in procedure SOC-POM/PSM/7.05. Price calculation of FFB is the responsibility of Technology Sub Department and the price was set based on Crude Palm Oil price, cost of transport from Mill to Belawan Tank Installation, actual FFB specification supplied during previous period by the supplier, and processing cost at the Mill. Annual contract were made between FFB suppliers and PT Socfin Indonesia, describing FFB specification required, contract period, determination of FFB pricing, and term of payment. Information of Fresh Fruit Bunch set was available to the FFB suppliers and the commitment was stated in the procedure. The FFB price set was sent to Tanah Gambus Mill. It was evident that price set was consistently used as recorded in the record of FFB receiving. The payment of FFB received were planned and executed in timely manner inline with term of payment agreed within the contract. Pricing mechanism for other inputs and or services was described in the procedure SOP/PSM/7.04 clauses to The selection and evaluation of supplier/vendor was based on capability of supplier and vendor to supply required inputs and or services. Specification of inputs and or services required was communicated to the supplier/vendor through tender document or request for quotation. Contractual agreement was signed by both parties, including specification and work requirements agreed. Procedure SOC/PSM/7/07 was established and implemented for payment of suppliers and vendors. It was observed that payment was made consistent with term of payment stated in each contract or purchase order. Criterion 6.11 Growers and millers contribute to local sustainable development wherever appropriate. Records of organisation contribution to regional development was evident, among other levied in region, agreement contract, and social assitance list. Some activities were conducted by the local contractors such as building houses, road maintenance (road hardening). Public s comments for CSR program are welcomed and their requests will be recorded in the annual CSR program. PRINCIPLES 7: RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS A procedure regarding responsible development of new plantings is in place (Document SOC/PSM/9.04). Tanah Gambus is a very old plantation, and therefore only replanting of Oil Palm and conversion from the companies Rubber Plantation into Oil Palm (within the same concession / licence area) is practiced here. No Primary Forest of HCV area has been present since long time, as this plantation was established during the Dutch period in the beginning of the 20 th century. Since then, only implantable swamps consisting of bushes and shrubs, and riparian zones planted with oil palms remained, and these have all been identified as HCV areas. No other HCV areas or forests were present here between November 2005 and November QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 35 of 52

36 PRINCIPLES 8: COMMITMENT TO CONTINUOUS IMPROVEMENT IN KEY AREAS OF ACTIVITY Criterion 8.1 Growers and miller regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations It was sighted that several rounds of internal audits were performed to Tanah Gambus Mill. Internal audit of integrated management system was performed as one of the requirements of ISO 9001:2008, ISO 14001:2004 and OHSAS18001:2007. Currently the implementation of management system audit also covered requirements of RSPO Principles and Criteria, as described in the internal audit procedure, SOC/PSM/8.02. The internal audit of management system and RSPO requirements was programmed and performed annually under coordination of Medan Head Office. Negative findings identified were followed up by issuance of corrective action request. The corrective actions made were verified for its effectiveness. Last internal audit of integrated management system was performed on March Other round audit performed for monitoring of Mill activities were conducted through operation internal audit for ensuring compliance and efficiency. The findings made were mandatory to be responded by the Tanah Gambus Mill and reported to Top Management. The report and its response were submitted to top management, i.e and 2011 reports. The overall performance of management systems and RSPO requirements were brought to the attention of top management through management review processes, as required by procedure SOC/PSM/5.01. The inputs of the review were result of internal audit of management systems, result of evaluation of compliance against applicable legal and other requirements, customer feedback, quality performance, environmental performance, occupational health and safety performance, complaint from stakeholder, external communication, status of corrective and preventive action, opportunity for improvements and any changes applied to management systems. The output of the reviews was decision made for continual improvements. The last management review was performed on January 15, Other than decision made during management review, under requirements of management system Tanah Gambus Mill has established annual quality, environmental and occupational health and safety objective, target and programs. The target established include quality of Crude Palm Oil and Palm Kernel, compliance with air emission legal requirements, compliance with waste water quality discharged legal requirements and zero incident/accident level. Tanah Gambus Mill and Estate has also established Continual Improvement Plan and Realisation report which described continual improvement project already executed until 2010 and those which plan to be conducted for 2011 until Several projects have been executed until 2010 at Tanah Gambus Mill installation of multi-cyclone dust collector for improving quality of boiler emission. Empty palm bunch was not used as boiler feed anymore but instead sent to estate as organic fertiliser since Currently fibre was the main feed to the boiler and shell only used when one of two of fibre screwdriver was not functioned. These could reduce frequency of black smoke generated when shell was overfed to the boiler. Clay-bath was modified so that clay sludge could be reused. It was noted there was a good program to reduce the use of highly toxic substance (paraquat) Continual improvement project established for Tanah Gambus Mill for period 2011 to 2012 is composting of empty palm bunch by 2012 which estimated to eliminate methane emission from waste water treatment and eliminate waste water discharge from Tanah Gambus Mill to the environment. Opportunity for improvement: QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 36 of 52

37 Audit Report It is recommended to established audit check list to cover all RSPO indicators, to ensure minimum requirement of National Interpretation Principle and Criteria RSPO were covered during internal audit. Mill Supply Chain Certification Requirements Tanah Gambus Mill received FFB from own its Tanah Gambus Estate and from the third party supply base. All of the FFBs are processed under the same facilities; therefore the supply chain model that can be applied is Mass Balance (MB) model. 1. Documented procedure Tanah Gambus Mill has established and documented written procedure in regard to the implementation of RSPO Supply Chain Certification System (RSPO SCCS). It is described on Mechanism of Recording and Monitoring of Sustainable Palm Oil (SPO) Balance in POM PT Socfindo as well as the procedures mentioned on criteria 4.1 above which is integrated with the Quality Management System ISO 9001:2008. The procedure describes the implementation of all the elements of RSPO SCCS. In general, from the records reviewed (April May 2011) found that compliance to the RSPO SCCS has been demonstrated. The person having overall responsibility for and authority over the implementation of RSPO SCCS has been assigned (Mr. Hasymul Arbi Hasibuan). Non-conformance against requirements 1 SCCS: Documented procedure related to SCCS has been established ( Mechanism of Recording and Monitoring of Sustainable Palm Oil (SPO) Balance in POM PT Socfindo ); however it has not been registered and controlled as required. Procedure of daily reporting when Harvest System down has not been formally documented. The estimation of quantity of kernel on virtual silo has been defined at the day audit. The stock of the day audit has been calculated according to the defined arrangement. However the specific gravity (relative mass) of kernel was (use 0.6 kg/m3) not issued by laboratory. 2. Purchasing and goods in The requirements were not applied for the purchase and delivery of RSPO certified palm oil and palm oil products. However it was verified whether Tanah Gambus Mill has clear system for recording fresh fruit bunch received from certifiable supply base and non certifiable supply base. It was verified that receiving of fresh fruit bunch was traceable to the supply base unit. Weighing slip and receiving report issued clearly stated weight off fresh fruit bunch receive and its source. 3. Sales and goods out As previously mentioned, Tanah Gambus Mill s CPO are only delivered to FRF and palm kernel is only delivered to PKOF (Palm Kernel Oil Factory). Result of delivery has been well recorded and reviewed during audit. 4. Processing Supply chain model is Mass Balance since the Mill processes FFB from third party that has not been RSPO certified. See description above. 5. Record keeping A review to the records and related documentation of the implementation of the SCCS found that accurate, complete and up to date records and report have been maintained by Tanah Gambus Mill. The records and reports are easily accessible both in hard copy and soft copy. Retention time for these records and reports has been determined (5 years). Balance among all FFB, CPO and palm kernel receipts, produced and delivered are conducted in daily basis. The record has been QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 37 of 52

38 well maintained. Audit Report Non-conformance against requirements 5 SCCS: Back ERP (Enterprise Resources Planning) data has been conducted; however it was not consistently reported on daily back up report. Opportunity for improvement While the retention time has been determined; consider to specifying the filing system (particularly for manual report) at POM. 6. Training Qualification of personnel for each job function have been defined and documented within Personnel Qualification, SOC/Form/ , including training requirements necessary for Supply Chain. Procedure SOC/PSM/6.02 was established and implemented for identifying training needs, programming training, delivering training, and evaluating effectiveness of training. Training for Supply Chain requirements have been delivered to personnel in Medan Head Office, as well as personnel in Tanah Gambus Mill. The training records were made including training material, training attendance and individual training record. Individual training record, SOC/Form/ , for personnel in relation to implementation of Supply Chain requirements was sighted, e.g. Mill Manager, Mill assistant Manager, Production Supervisor, and Laboratory Head. Personnel who involved in the implementation of SCCS has been trained. Records showed that Mill manager and his team have been trained as required. Non-conformance against requirements 6 SCCS: SCCS training has not been given for Expedition personnel and Weighbridge operator. 7. Claim Claim has not been applied while the system has been prepared. 3.2 Recommendation The recommendation from this audit is approval as a producer of RSPO Certified Sustainable Palm and Palm Kernel. Audit recommendations are always subject to ratification by RSPO. This report was prepared by: Ria Gloria, Inge Triwulandari, Sigit Yulianto, Fadjar Deniswara and Irawan Bawono QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 38 of 52

39 3.3 Acknowledgement of Internal Responsibility and Formal Sign-off of Assessment Findings Please sign below to acknowledge receipt of the assessment visit described in this report and confirm the acceptance of the assessment report contents including assessment findings. Signed for and on behalf of PT. Socfin Indonesia Mr. Hasan Bisri Head of System Management and Social Department Date 23 May 2011 Signed for and on behalf of PT. SAI Global Indonesia Mr. Joko Prayitno Certification Manager Date 23 May 2011 QEF08sa.RSPO.01 / Issue Date: 2009-Apr-15 SAI Global Indonesia Copyright 2009 Page 39 of 52

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