OILPALM PLANTATION MANAGEMENT VERIFICATION ... CI Tequendama...Santa Marta, Colombia Country:...

Doc. Number:

Doc. Version date: 5 May 2009

SGS QUALIPALM

(Associated Document)

Page: 1 of 39

OILPALM PLANTATION MANAGEMENT VERIFICATION REPORT

Report Nr: MY02299 Revision 1 Report Date: 28 Nov 2010

Client: The DAABON Group

RSPO membership #: 2-0006-04-000-00

Web Page: http://www.daabon.com.co

Plantation Company Evaluated:

C.I. Tequendama

Total Plantation Area 4,472 hectares

Company Contact Person:

Mr. Manuel J Davila A. – Chief Executive Officer

Mr. Carlos Reyes Movilla – Director of Certification

Mr. Felipe Guerrero – Sustainability Manager

Mr. Walter Ritzel- General Manager

Address: Head office: Carrera 1 No. 22-58 Edificio Bahia Centro Santa Marta, Colombia

Country: Colombia

Tel: 57-5-4328120

Fax Same as above

Email: [email protected]

[email protected]

[email protected]

Evaluation dates:

Main Assessment 8 – 13 August 2010

Surveillance 1 Nov 2011

Surveillance 2

Surveillance 3

Assessment against RSPO Colombia LI Requirement

C.I. Tequendama Page 2 of 39

------------------------------------------------------------------------------------------------------------------------------------------------------------------ SGS (Malaysia) Sdn. Bhd Unit 10-1 10th Floor Bangunan Malaysian Re, No 17 Lorong Dungun Damansara Heights (Co. No. 10871-T) 50490 Kuala Lumpur Malaysia. t +6 (03) 2095 9200 f +6(03) 2093 8202 www.sgs.com

Member of SGS Group (Société Générale de Surveillance)

TTAABBLLEE OOFF CCOONNTTEENNTTSS

LIST OF TABLES ...........................................................................................................................................3 LIST OF MAPS ...............................................................................................................................................3 LIST OF FIGURES..........................................................................................................................................3 LIST OF ABBREVIATIONS............................................................................................................................4 1.0 SCOPE OF VERIFICATION............................................................................................................................5 2.0 COMPANY BACKGROUND...........................................................................................................................6

2.1 Ownership & history ................................................................................................................................................... 6

2.2 Organisational Structure............................................................................................................................................. 7

3.0 OTHER OIL PALM PLANTATIONS OWNED BY THE DAABON GROUP AND PLAN FOR CERTIFICATION UNDER RSPO P&C ........................................................................................................8 4.0 PREPARATION FOR THE EVALUATION ....................................................................................................9

4.1 Pre-evaluation ........................................................................................................................................................... 9

4.2 Team................................................................................................................................................................... 9

5.0 THE EVALUATION .......................................................................................................................................10

5.1 Preparation of RSPO P&C Colombian Local Checklist ............................................................................................ 10

5.2 Stakeholders Notification & Consultation .......................................................................................................... 10

5.3 Opening Meeting............................................................................................................................................... 11

5.4 Document Review ............................................................................................................................................. 11

5.5 Sampling and Evaluation Approach .................................................................................................................. 11

5.6 Field Assessments ............................................................................................................................................ 12

5.7 Summary and Closing Meeting ......................................................................................................................... 13

6.0 BACKGROUND INFORMATION OF TEQUENDAMA CERTIFICATION UNIT ..........................................13

6.1 Palm Oil Industry in Colombia.................................................................................................................................. 13

6.2 DAABON Group Palm Oil Industry.................................................................................................................... 14

6.2.1 Tequendama Palm Oil Mill ............................................................................................................................ 14

6.2.2 DAABON Owned and Managed Estates....................................................................................................... 15

7.0 EVALUATION RESULTS .............................................................................................................................20 PRINCIPLE 1: Commitment to transparency................................................................................................................ 20

PRINCIPLE 2: Compliance with applicable laws and regulation .................................................................................. 21

PRINCIPLE 3: Commitment to long term economic and financial viability ................................................................... 22

PRINCIPLE 4: Use of appropriate best practices by growers and millers: ................................................................... 22

PRINCIPLE 5: Environmental responsibility and conservation of natural resources and biodiversity ......................... 26

PRINCIPLE 6: Responsible consideration of employees and of individuals and communities affected by growers and mills 29

PRINCIPLE 7: Responsible development of new plantings ......................................................................................... 32

PRINCIPLE 8: Commitment to continuous improvement in key areas of activity ......................................................... 32

8.0 ISSUANCE OF NON-COMPLIANCE.........................................................................................................33 9.0 ASSESSMENT DECISION .........................................................................................................................33





10.0 ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY AND FORMAL SIGN-OFF OF ASSESSMENT FINDINGS.........................................................................................................................33 11.0 RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS ...........................................................34 12.0 RECORD OF CORRECTIVE ACTION REQUESTS (CARS) AND OBSERVATIONS .............................36

LIST OF TABLES

Table 1: Summary of CPO and PK production by CI Tequendama mill ..................................................................5

Table 2: Summary of production areas and annual Fresh Fruit Bunches (FFB) by estates.....................................5

Table 3: DAABON Group's Timeline for RSPO Certification of Oil Palm Plantations...............................................8

Table 4: Summary experience and qualification of the audit team member .........................................................9

Table 5: List of Stakeholders Contacted................................................................................................................10

Table 6: Audit Itinerary..........................................................................................................................................12

Table 7: Land statement and the crop age profile of DAABON estates................................................................16

Table 8: Smallholder Scheme ................................................................................................................................18

Table 9: Age Profiles of the Alliances ....................................................................................................................18

Table 10: Criterion of Non-Compliance and Explanation......................................................................................20

LIST OF MAPS

Map 1: Location of DAABON Agricultural Farms.....................................................................................................6

Map 2: Ariguani Estate ..........................................................................................................................................16

Map 3: Tequendama Estate ..................................................................................................................................17

Map 4: Gavillan Estate...........................................................................................................................................18

LIST OF FIGURES

Figure 1: DAABON Group Core Operations Structure.............................................................................................7

Figure 2: C.I Tequendama Palm Oil Industries' Structure .......................................................................................8





LIST OF ABBREVIATIONS

CAR Corrective Action Request

CPO Crude Palm Oil

EFB Empty Fruit Bunch

EIA Environment Impact Assessment

EMS Environmental Management System

ERT Endangered, Rare and Threatened species

FFB Fresh Fruit Bunches

Ha Hectare

HCV High Conservation Value

IPM Integrated Pest Management

ILO International Labour Organisation

ISO International Organisation for Standardisation

IUCN International Union for Conservation of Nature and Natural Resources

K Potassium

kW Kilowatt

LI Local Indicator

M Meter

Mg Magnesium

Mm Millimetre

Mt Metric ton

N Nitrogen

NGO Non Governmental Organisation

OER Oil Extraction Rate

OSH Occupational Safety & Health

P Phosphate

P & C Principles and Criteria

PK Palm Kernel

POME Palm Oil Mill Effluent

PPE Personal Protective Equipment

SGS Societe Generale de Surveillance

SOP Standard Operating Procedures

UNDP United Nations Development Programme

Yr Year





IINNTTRROODDUUCCTTIIOONN

The purpose of the evaluation was to evaluate the operations of CI Tequendama oil palm mill and plantations located in and around Santa Marta, Colombia, against the requirements of the QUALIPALM Programme, the SGS Group’s verification programme for compliance to the RSPO P&C Colombian local checklist approved by the RSPO Board in April 2010.

1.0 SCOPE OF VERIFICATION

The details of the Crude Palm Oil (CPO) mill and the oil palm plantations included in the scope of this

assessment are presented in Table 1 and Table 2 below.

Table 1: Summary of CPO and PK production by CI Tequendama mill

Table 2: Summary of production areas and annual Fresh Fruit Bunches (FFB) by estates

PLANTATION AREA NAME OF HOLDING

LOCATION

(Nearest town) Production

(ha)

Conservation

(ha)

AVERAGE ANNUAL FFB

Finca Gavilán

Directly owned

El Retén, Department of Magdalena

754 73 22.18 tons/ha

Finca Ariguaní

Directly owned

Ariguaní, Department of Cesar

1,122 122 24.19 tons/ha

Finca Tequendama

Directly owned

Fundacion, Department of Magdalena

876 40 26.88 tons/ha

Alianza Cooprocopal

Smallholder

El Retén , Department of Magdalena

200 NA 27 tons/ha

Alianza Asopalret

Smallholder


270 NA 27 tons/ha

Alianza Coopalbongo

Smallholder


500 NA 27 tons/ha

Alianza Asopaltheca

Smallholder


250 NA 27 tons/ha

Coagrobellaena Pivijay, Department of Magdalena

500 NA 25 tons/ha

Total 4,472 235 25.9 tons/ha

MILL: CI TEQUENDAMA OIL MILL

Mill location Capacity FFB input CPO output PK output

Extractora Tequendama, Municipio de El Reten

30 mt/hr 125,000 mt/yr 27,000 mt 2,000 mt





The C.I. Tequendama mill sourced FFB only from the above-mentioned group estates managed by the DAABON Group. All the FFB produced by the estate and the smallholders’ scheme produced and supply the FFB only to Tequendama mill.

2.0 COMPANY BACKGROUND

2.1 Ownership & history

DAABON is a family owned and managed company, built on the passion and commitment of three generations of the Davila family. Its headquarters and farms are located in Santa Marta, Colombia. The company’s first few hectares of bananas in the Magdalena region of Colombia, established in 1914, have today grown into one of the world’s leading suppliers of organic tropical crops, with a total of 6,784 ha of certified organic produce – banana, coffee, palm oil and cacao.

The group employs around 2,000 people directly, but also supports local employment by providing assistance to over 450 palm and cocoa smallholders who are organised in Allianzas (co-ops). General locations of banana, cocoa and oil palm plantations owned by the DAABON Group in Colombia are spread throughout the three main provinces of Magdalena, Cesar and Bolivar, as shown in Map 1 below:

Map 1: Location of DAABON Agricultural Farms

Oil palm sold by DAABON is grown on two types of land – company/family-owned and smallholder owned. Land acquisition for the DAABON group is a process that involves strategic analysis and agricultural knowledge, since not always the land that is available can be used for organic agriculture. The majority of company-owned land was acquired by Davila-Abondano family in the form of estates dating back 3 generations to the 1950’s. The family originally used the land for cattle rearing, but converted into organic palm in the late 1980s. As the company grew bigger, land was bought negotiating





directly owner-to-owner. DAABON is not involved in any major expansion, with new land parcels typically consisting of 200-500 hectares. All of the land developed by DAABON has been used for commercial agriculture for centuries, and there have never been any ownership claims by indigenous groups or conflicts over land ownership.

2.2 Organisational Structure

In Colombia, the core operations are wholly-owned and governed by the Davila-Abondano family, and comprise of eight companies.

Figure 1: DAABON Group Core Operations Structure

In addition to the wholly-owned operations, DAABON also has a number of strategic joint ventures in the following establishment:

• Biocombustibles Sostenibles del Caribe S.A (Biodiesel)

• C.I. Ecofair S.A: (Banana)

• C.I. Palmed S.A. Smallholder (Oil palm, Bolivar)

• Consorcio El Labrador (Oil palm, Bolivar)

• DAABON Japan (sales)

• DAABON Australia (sales)

• DAABON US (sales)

• DAABON UK (sales)

• DAABON Germany (sales)

As for C.I. Tequendama, the structure of palm oil industries is as follows:

DAABON Group

C.I Samaria

(Bananas/cocoa)

Carmen Abondano

(Bananas)

C.I Tequendama S.A

Oil Palm

Terlica S.A

(Terminal)

Ecobio Columbia Ltda

(Coffee/cocoa)

Alberto Davila

(Cattle)

C.I Kyoto S.A.

(Coffee)

Superportaria Ltda

(Logistics)





Figure 2: C.I Tequendama Palm Oil Industries' Structure

3.0 OTHER OIL PALM PLANTATIONS OWNED BY THE DAABON GROUP AND PLAN

FOR CERTIFICATION UNDER RSPO P&C

The current verification exercise is undertaken only for C.I. Tequendama Oil Mill and its supply base from the Group’s estates and sources in Santa Marta. DAABON owns and manages other palm oil plantations located in Guajira and two smallholder alliances in Rio Viejo, Colombia.

The C.I. Tequendama certification unit, comprising three estates (Ariguaní, Tequendama and Gavilán) and its associated smallholder’s schemes, is the first to undergo assessment under the RSPO certification programme. The company’s time bound plan for certification of other plantations is as summarised in Table 3.

Table 3: DAABON Group's Timeline for RSPO Certification of Oil Palm Plantations

PLANTATION MANAGEMENT UNITS UNDER DAABON GROUP AND ITS PLAN FOR CERTIFICATION

Estates Size (ha) Location Plan for certification

Las Mercedes 380 Pelechua, Guajira

Department End 2011

Asoblanpalmas –

Smallholders 365

Rio Viejo, Bolivar Department

End 2012

Asopalrio-

Smallholders 1,100

Rio Viejo, Bolivar Department

End 2012

TOTAL 1,845

The certification plan developed by the company is quite challenging but the company has made good progress to date where at least one unit is undergoing assessment. The group is planning to bring its entire certification unit to certification in 2012. The company has good infrastructure and resources as well as commitment from top management in making the plan a reality. SGS is in the opinion that the plan made is reasonable and achievable.

Business Vice President

Alonso Davila

TAGASS Agro Manager

- Alliance (Ventilation Culture)

Administrators

Tequendama:O.Salamanca Ariguani:Rafael Rivera

Gavilan: A.Maestre

Department of South Bolivar and Agricultural

Technical Advisor

Managing Director of Alianzas

Guillermo Barrios

Manager of Production and Palm Extractor

Luis Lagos

TAGASS Administrative Coordinator

Farm Health and Nutrition Coordinator

Maintenance Supervisores

Cosecha Riego

Alliances Agricultural Technical Coordinator

Transportation Coordinator

Production Quality Maintenance

Engineers

Environmental Engineer Mechanical Engineer

Systems Engineer Industrial Engineer





4.0 PREPARATION FOR THE EVALUATION

4.1 Pre-evaluation

This evaluation by SGS was preceded by three assessments of the certification unit carried out by third party assessors in 2003, 2007 and 2008. RSPO was not formed until 2004 and the standard Principles & Criteria were only available since 2007. However, the findings made by the previous assessments have been used by the company to prepare the company for the current RSPO certification assessment.

Prior to the main assessment, communication with management is made to prepare for logistics as well as to ensure that sufficient time is agreed upon to cover specific areas and critical activities identified during the pre-assessment.

4.2 Team

The experience and qualification of the audit team members are as summarised in Table 4 below:

Table 4: Summary experience and qualification of the audit team member

Evaluation Team The team member background

Team Leader/ Lead Auditor

Salahudin Yaacob has postgraduate degree in Environment and Natural Resources management currently head Natural Resources certification programme in SGS Malaysia. Trained as a botanist, the team leader has gathered more than 10 years of auditing especially in the forestry sector. As a lead auditor in forest management and chain of custody of forest products. He is well versed in certification process and management of certification scheme. Also trained as lead auditor under EMS and SA8000 system. Has participated in RSPO Lead Auditor Training Course and conducted a number of RSPO audits in Malaysia. Also member of working groups at national level under various certification schemes.

Auditor

Rick Gregory is a forester by profession with more than 30 years experience working in America, Africa and Asia, mainly in forestry and environmental conservation. Rick is a trained ISO 9000 lead auditor and expert in forestry, biodiversity, environmental policy and management planning. Has gathered many years experience of auditing in forest management, oil palm industry and other natural resources sector mainly in Malaysia. He has been involved in the verification and audits of a number of forest management and oil palm plantation operations against RSPO requirement and other certification/verification schemes.

Social Expert

Luis Enrique Medina Bermudez has extensive auditing experience with over 20 years working with corporate and international clients. Graduated with a degree in Pharmaceutical Chemistry, Luis is a trained ISO 9000 and SA-8000 lead auditor with an emphasis in business management systems, social responsibility and human rights issues. He combines vast knowledge of best practices in supply chain and quality issues with a strong background in ethics in organizations.

Local Agronomist

Jorge Hernan Gomez is an agronomist engineer with training in ISO 9000 and qualified as a lead auditor for ISO 14000. He has experience in the floriculture and cattle industries assessing environmental impacts and developing Good Agriculture Practices. He has been involved with carbon capture methodologies and is also an auditor for BPM and BPA assessments.





5.0 THE EVALUATION

5.1 Preparation of RSPO P&C Colombian Local Checklist

In view of the lack of RSPO P&C National Interpretation for Colombia, the evaluation was preceded by a stakeholder consultation for preparation of a Local Indicators checklist (LI) for DAABON. SGS has prepared a draft local checklist based on the English version of Fedepalma’s Colombia’s National Interpretation of the Principles and Criteria for Sustainable Palm Oil developed earlier. Categorization of major or minor compliance of the indicator follows those indicated in the RSPO guidance document as well as NIs prepared for other countries.

The draft LI was circulated to local and international stakeholders as part of the process to solicit comments. Public consultation was also held to further consolidate the checklist, such as forums with a number of important NGO participants held in Santa Marta. The comments and inputs made by stakeholders were consolidated into the final checklist submitted to the RSPO Board for endorsement. The LI was finally endorsed by the RSPO Board in April 2010.

5.2 Stakeholders Notification & Consultation

A wide range of stakeholders was contacted four weeks before the planned evaluation to inform them of the evaluation and seek their views on relevant oil palm plantation management issues. These included environmental and social interest groups, local government agencies and authorities as well as workers’ unions.

During the assessment, meetings and discussions were also held with relevant stakeholders including workers’ union leaders, member of the alliances, contractors as well as relevant municipal and other authorities.

Stakeholders that were contacted prior to the assessment are as listed in Table 5.

Table 5: List of Stakeholders Contacted

Group Category Name of the agency

Academic

Universidad del Magdalena - Vice rectoría de Investigación Universidad Del Norte - Sede Santa Marta Universidad Sergio Arboleda Sena - Regional Cesar Sena – Regional Bolívar Sena - Regional Magdalena Observatorio Del Caribe Colombiano

Association Fundepalma Fedepalma

Local government

Gobernación Del Magdalena Gobernación Del Cesar Alcalde De El Retén, Magdalena Alcalde De Aracataca, Magdalena Alcalde De Fundación, Magdalena Corporación Autónoma Regional del Magdalena - CORPAMAG – Corporación Autónoma Regional del Cesar - CORPOCESAR – Unidad Administrativa Especial del Sistema de Parques Nacionales Naturales - Santuario de Fauna y Flora Ciénaga Grande

NGOs

WWF Instituto Humboldt – IAvH Fundación Natura Censat Agua Viva Organización Gonawindua Tayrona - O.G.T Indepaz





Grupos Semillas

Smallholder

Asopaltheca Asopalret Cropocopal Cooagrobellaena Coopalbongo

Following RSPO standard procedures, a public announcement and stakeholder consultation was made at least four weeks prior to field assessment.

SGS also looks into issues raised by the public pertaining to the company’s operation. The issues raised and corresponding SGS responses are as listed in Appendix 1.

The steps for conducting main assessment are as outlined below.

5.3 Opening Meeting

An opening meeting was held at DAABON Group Headquarters in Santa Marta on 9 August 2010. The scope of the evaluation was explained and schedules were determined. A record was kept of all persons that attended this meeting.

5.4 Document Review

A review of the main plantation management documentation was conducted to evaluate the adequacy of coverage of the RSPO P&C Colombian LI requirements. This involved examination of policies, management plans, systems, procedures, work instructions and record controls.

5.5 Sampling and Evaluation Approach

The schedule for field visits was determined during the opening meeting after a briefing given by the DAABON management team.

The focus of the assessment visit was to sample the implementation of management practices and procedures in the palm oil mill and the three associated estates owned by the Group, plus a sampling of smallholder operations among the five different associations.

The ISO standard formula of √n x 0.8 was applied to determine the sampling size, with at least 12 members (out of the 163 total) required to be visited.





5.6 Field Assessments

Field assessments aim to determine how closely activities in the field comply with documented management systems and RSPO Colombian LI requirements. Interviews with staff, operators, contractors and smallholders were conducted to determine their familiarity with and their application of policies, procedures and practices that are relevant to their activities. After discussions with staff, a carefully selected sample of at least nine smallholder sites, based on seeing members of the different smallholder alliance groups and logistics and access availability, was visited to evaluate whether practices met the required performance levels The samples are chosen by the audit team based on information given during the debriefing.

As part of the effort to cover more locations, the verification team split into teams and worked independently. The activities and areas visited on a daily basis by the audit team are as tabulated in the table below.

Photo 1: On site interviews with smallholders

Table 6: Audit Itinerary

Date Area visited Notes

Opening meeting Briefing by DAABON Discussion on assessment schedule.

9 August 2010

Document review Documents for review were made available. Documents reviewed at the mill and individual estates.

Visit to Gavilán and Ariguaní Estates

Areas covered include harvesting area, weeding, conservation area, boundary demarcation, workshop, waste management system, fragile soil areas etc.

10 August 2010

Visit to the mill

Receipt of FFB, Mill operation, Mill design, OSH aspects, POME, EFB, CPO production. Environmental monitoring records, Licensing

Visit to Smallholders

1 member of Coopalbongo 4 members of Coprocorpal 1 member of Asopalteca 2 members of Asopalret 2 members of Coagrobellaena

Meeting with Water Authority Discuss issues pertaining to water distribution

11 August 2010

Meeting with the Alliances Issues include the agreement with the smallholders, management control, conflict resolution etc.

12 August 2010 Visit to Tequendama Management documents and SOPs. Observation on

management practices. Mill’s management documents such as the OSH plan, EIA, production





records etc.

Discussion with

SENA (National Learning Center)

Corpamag (Local Environmental Agency)

Personería Municipal

Defensoría del Pueblo (Ombudsman)

13 August 2009

Closing meeting Preliminary results of the assessment exercise were presented to the management.

5.7 Summary and Closing Meeting

At the conclusion of the field evaluation, preliminary findings were presented to company management at a closing meeting held on 13 August 2010. Any areas of non-conformance with the RSPO requirement were raised as one of two types of Corrective Action Request (CAR):

� Major CARs - which must be addressed and re-assessed before certification can proceed.

� Minor CARs - which do not preclude certification, but must be addressed by the following surveillance, otherwise will be raised as a Major.

6.0 BACKGROUND INFORMATION OF TEQUENDAMA CERTIFICATION UNIT

6.1 Palm Oil Industry in Colombia

Photo 1: Aerial view of Tequendama mill

The Republic of Colombia is a constitutional republic in northwestern South America. Colombian territory encompasses a great range of landscapes, including Amazon rainforest, tropical grassland and both Caribbean and Pacific coastlines. Ecologically, Colombia is one of the world's 17 mega diverse countries, meaning that it has extraordinary biodiversity per unit area. With a population of 45.4 million people, Colombia has the second largest populated nation in South America, with a highly diverse ethnic mix and a rich cultural heritage, resulting from the interaction between descendants of the original native inhabitants, as well as African, European and Middle Eastern descendants. Colombia has an average annual income of around USD 5,000 per capita and is classified as a lower-middle income country.

Despite this, Colombia rates relatively well on most development indicators, and is ranked in the UNDP High Human Development category due to indicators like high levels of literacy (92.7%), life expectancy (72.3) and gender equality. However, according to the UNDP there is still widespread poverty, particularly concentrated in remote, rural areas with 16% living on incomes of less than USD1.25 per day and over 40% below the national poverty line.





For many years serious internal armed conflict haunted the country, causing many farmers to abandon rural locations for more urban locations. In recent years, the situation has improved dramatically due to the government’s "democratic security" strategy, which has included significant increases in military strength and police presence throughout the country to enforce security and rules of law.

Another key security strategy has been the development of Alianzas por la Paz (Alliances for Peace) that supports the establishment of agricultural co-operatives in conflict-ridden areas, particularly focusing on high-income crops such as banana and oil palm. With the support of increased security measures, access to credit and technical support from the private sector, the program is helping displaced communities return to their homelands, whilst at the same time creating sustainable livelihoods and limiting the potential for armed conflict.

Photo 3: The view of Tequendama mill showing a clean environment at the mill

The DAABON Group’s mill and plantation operations are centered in Santa Marta, which is the capital city of the Magdalena Department. Formed by four drainage basins, the landscape of Magdalena is relatively flat and dominated by the Magdalena River. The Department comprises an area of 23,188 km2 with a population around 1.1 million. Annual rainfall ranges from 250 mm in the driest areas to over 4000 mm in the Sierra Nevada Mountains, with averages from 1500 mm to 2000 mm per year. The rainy season extends from April to November with less intensity from June to August and a dry season from December to March.

All of DAABON’s oil palm plantations are located on flat, low-lying areas without any significant portions on high ground.

6.2 DAABON Group Palm Oil Industry

DAABON palm oil mill and supply base subjected to the evaluation are all those that are certified under organic certification system. The mill and its supply base can be summarised as below:

6.2.1 Tequendama Palm Oil Mill

Doc. Number:

Doc. Version date: 5 May 2009

SGS QUALIPALM

(Associated Document)

Page: 15 of 39

Tequendama Palm Oil mill was commissioned in 1989 with initial capacity of 4 mt/hr. The mill was then upgraded to 32 mt/hr to cater for more FFB produced by the DAABON Group’s plantations and smallholders. As it is now, the mill has capacity of 32 mt/hr processing and is consuming about 190,000 metric tons of FFB per year. As the DAABON Group specializes in organic farming, the mill is designed to process and produce both organic and conventional material. Photo 2 below shows the aerial view of the mill, the office, the ramp where the FFB is received and the 3 CPO storage tanks catering both for organic and the conventional products.

Photo 4: The well kept Tequendama mill showing the ram and the CPO storage tank

It has two separate ramps (organic and conventional) for receiving FFBs. On a daily basis, organic fruits are processed first before non-organic fruits. Every section of the mill is cleaned with hot water to ensure that there are no non-organic residues remaining in the system prior to processing of the organic materials the next day.

The mill has three boilers producing steam that use fibre for power generation. There are six series of ponds for treating the POME (including two anaerobic) prior to releasing and applying it to plantation land within the Tequendama estate via channels and drains. The total land applications cover about 100 ha of the Tequendama estate.

About 70 % of the EFB produced by the mill is shredded and used for composting, while the remainder is applied direct to the Tequendama estate. The kernel shell produced is also used for power generation at the company’s refinery located in Santa Marta.

6.2.2 DAABON Owned and Managed Estates

DAABON Group owned and managed the three estates subjected to this evaluation. Prior to planting with oil palm, the estates either were a cattle ranch or planted with other agro-crop such as coffee or banana.

Land statement and the crop age profile of DAABON palm oil estates are tabulated in Table 7.





Table 7: Land statement and the crop age profile of DAABON estates

The land distribution in each estate are as illustrated in the maps below where green indicate conservation zones.

Map 2: Ariguani Estate

Age category (year)

Tequendama (ha)

Ariguaní (ha)

Gavilan (ha)

Allianz (ha)

Total (ha)

0 – 3 0 0 0 0 0

3 – 6 0 48.39 68.98 0 117.37

6 – 12 152.76 256.0 684.99 1720 2813.75

12 – 18 114.5 817.5 0 0 932

18 - 30 487.9 0 0 0 487.9

> 30 120.8 0 0 0 120.8

Net area cultivated 876 1,121.9 754.0 1720 4471.82

Conservation area 40 122 73 0 235

Others

(e.g. mill, office, nursery, compost, cattle ranch and other crops)

458.2 71.3 60.3 80 669.8

Total 1,374.2 1315.3 887.3 1800 5,376.6





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0 575 1.150 1.725 2.300287,5Miles

SISTEMA DE INFORMACION GEOGRAFICA

C.I TEQUENDAMA S.A

PLANTACION ARIGUANI

AREAS DE CONSERVACION

CONVENCIONES

Rio Ariguani

Area de conservacion

Lotes

110.31 ha

16.20 ha

8.84 ha

27.6 ha3.81 ha

Map 3: Tequendama Estate

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Piscinas de

Oxidación

Planta

Extractora

COMPOSTERA

Cantera

de material

Jagüey

346,50908

m

2237 ,437

417

m

2180,59 4557 m

2180,594557

m

1962,789189 m

1962,789189

m

1587,108744

m

15

87

,10

87

44

m

15

30

,22

29

99

m

1530,222999 m

14

2

4,513516

m

1424,513516

m

1410

,022429 m

1084,868088 m

10 84,868088 m

895,572031 m

895,572031 m

58

3, 2

748

3 m

583,27483 m

519

,26

284

5 m

51

9,26

28

45

m

490,500088 m

48

9,27

8889 m

489,278889

m

47

8,556109 m

474,8 53

47

5 m

474,853475

m

409,07382

m

38

6,6

247

31

m

37

4,9

03

34

1

m

363 ,4

3404

8 m

346,50908

m

325

,617566 m

296

,50

593

8 m

26

8, 60

553

7 m

234,491092 m

186,5272

m

149,599

89

8 m

43

18,5

129

22

m

410

5,235

079

m

410

1, 0

348

22 m

3376,72

3252 m

2749,207732 m

2394,820826 m

2327,412975 m

2205,127227 m

1623,578347 m

14

71, 5

29355

m

1341,097872 m

1285,339063 m

1149

,23

88

56 m

1107,324139 m

1088,155932 m

10

66

,53

55

8 m

1037,93 8384 m

97

5,615516 m

970,821805 m

970,428695

m

9 18,697042 m

85

4 ,2 03

4 6 m

835,490954 m

830,501186 m

82

2,55

82

14

m

73 7

,95

982

7 m

72

7, 7

59

141

m

726,887902 m

684,13

86 9

5 m

6 49

,44 5

14 4

m

648,091912 m

641,76649 8

m

627,77569 m

598 ,879121 m

563,92 2

66 1

m

553,300214 m

549,464619

m

542

,766

99 m

539,225935 m

529,206409 m

527,876999 m

520, 0

49

536

m

502,91234 m

491,112145 m

475

,86

044

8 m

469,200275 m

46 8

,62

8291

m

46

6,335

128

m

463,704404

m

461

,186

672

m

459,818591 m

45

5,4

48

41

6 m

44

8 ,0 39

3 06

m

443,769067 m

439

,902788 m

439,546574 m

430,258037 m

429,414433 m

424,723082 m

421 ,837722 m

410,34543 m

393 ,544981 m

386,814895 m

377, 701595 m

369,99226

9

m

367,108156

m

366,044233 m

356,67619 m

3 56

,30

3 48

2 m

355

,4 42301

m

352,92409 m

345,191539 m

33

1,1 70814 m

329,50921 m

318

, 334

47 4

m

318, 235161 m

311,295993

m

310,678458 m

3 01,6361 23

m

299,197216 m

297,112054 m

295,821901 m

290

, 59 6

3 63 m

289,15544 m

2 80

, 422

33 1

m

268,994762 m

264, 869579 m

25

9,9

14

77

5 m

251,77905 m

25

1,5

91

33

7 m

251,573512 m

251,527324 m

25

1,4 8

673

m

248,0116 m

245,810612 m

23 7,8 4

5 23

m

22

7,5

212

19 m

223,191889 m

219,815555 m

21

6, 297

055

m

21

5,94 3

89

6

m

213,963888

m

212,421328 m

211,

775

7 1 m

21

1 ,31

725

9 m

209,063995 m

19 8

,109

102

m

192,752229 m

187,725368 m

186,819679 m

185,17861 m

185,055177 m

18

4,8

425

07

m

175,35282 m

166,027057 m

15

7,7

38

16

5 m

15 5

,876

86 m

151,302989 m

149,435052 m

148,239117 m

144,054043 m

138,825023 m

119,75317 m

105,670302

m

96,2

066

45 m

94, 949089 m

91,079926 m

89,739901 m

78,089 223 m

66,509185 m

58,0 2

61

52

m

51,733049 m

48,598174 m

48,236102 m

46,050708 m

40,962246 m

30,230645 m

20,735017 m

18,623451 m

7,767637 m

2,89 ha

4,79 ha

19,43 ha

25,97 ha

19,76 ha

Lote 19C

Lote 43B

Lote 35C

Lote 34C

Lote 32C

Lote 33C

Lote 31C

Lo

te 3

0C

Lo

te 2

9C

Lote

23C

Lote 23C

Lote 24C

Lote 22C

Lote 21C

Lote 20C

Lote 18C

Lote 17C

Lote 16C

Lote 13C

Lote 12C

Lote 11C

Lote 09C

Lote 26C

Lote 14C

Lote 15C

Lo

te 2

5C

Lote 08C

Lote 40C

Lote 07C

Lote 06C

Lo

te 2

8C

Lote 05C

Lote 28C

Lote 04C

Lote 10C

Lo

te 0

1C

Lote44B

Lote 42B

Lote 40B

Lote 41B

Lote 39B

Lo

te 3

7B

Lote 37B

Lo

te

38

B

Lote 34B

Lote 35B

Lote 33B

Lote 32B

Lote 31B

Lo

te 3

0B

Lo

te 2

9B

Lote

28B

Lo

te 2

7B

Lo

te 2

3B

Lote 23B

Lo

te 2

1B

Lote 22B

Lo

te 2

2B

Lote

21B Lote 20B

Lote 01C

Lote 19B

Lote 02C

Lote 18B

Lo

t e 3

6C

Lote 39C

Lote 27C

Lo

te 0

3C

Lote

16B

Lote 17BLote 16B

Lote 15B

Lote 14B

Lote 13B

Lo

te 1

2B

Lote 11B

Lote 24B

Lo

te 1

0B

Lo

te 0

9B

Lote 08B

Lote 07B

Lo

te 2

5B

Lote 06B

Lote 05B

Lote 04B

Lote 03B

Lo

te 0

2B

Lo

te 0

1B

Lote 12ALote 11A

Lote 10A

Lote 08A

Lote 09A

Lote 07ALote 06A

Lote 04A

Lote 03A

Lo

te 0

2A

Lo

te 0

5A

Lo

te 0

1A

Convenciones

¼ Estaca

Vias

Ferrea

Intermunicipal

!

! Principal

"

" Auxiliar

Construcciones

Lotes palma

Conservación0 100 200 300 40050

Meters

72,8 ha





Map 4: Gavilan Estate

Table 8 provide the location, date of establishment, number of families and area under each alliance or association. Table 9 shows area statement and palm age.

Table 8: Smallholder Scheme

Association Location Date No. of Families No. of Palms

Showed Hectares

Coagrobellaena Pivijay Jun-2001 58 66,146 500

Cooprocopal El Reten Jan-2002 12 28,600 200

Asopaltheca Aracataca Sep-2003 32 32,919 250

Asopalret El Reten Oct-2003 30 33,024 270

Coopalbongo El Reten Oct-2004 31 66,146 500

Total 163 226,835 1,720

Table 9: Age Profiles of the Alliances

Age category

(year)

Coagrobellaena (ha)

Cooprocopal (ha)

Asopaltheca (ha)

Asopalret (ha)

Coopalbongo (ha)

Total (ha)

< 2.5 0 0 0 0 0 0

2.5 – 5 0 0 0 0 0 0





6 – 10 500 200 250 270 500 1720

11 – 20 0 0 0 0 0 0

21 – 25 0 0 0 0 0 0

> 25 0 0 0 0 0 0

Total cultivated

500 200 250 270 500 1720

*Total not cultivated

15 9 10 14 12 60

* Total not cultivated includes areas set aside as nursery, buildings and roads.





7.0 EVALUATION RESULTS

Results of the evaluation are summarised below. The findings made under each criterion are discussed where non compliances issued are raised against each individual indicator of the RSPO P&C Colombian LI. Classification of the non compliance to the requirement is categorised as tabulated in Table 9 below.

Table 10: Criterion of Non-Compliance and Explanation

Level of Non Compliance Explanation

Minor CAR

The management system applied complies with parts of the requirement or the system was inconsistently implemented. Improvements are required.

� Minor non compliance to the stated requirement

� Inconsistencies in documentation and implementation

� Will not prohibit recommendation for certification

Major CAR

The management system failed to comply with the requirement or the written policy, procedures etc were not implemented.

� Major non conformance resulting in breakdown of the whole system

� Major failure in documentation and implementation

� Will prohibit recommendation for certification

DAABON has a Communication Protocol (July 18, 2009) that define the responsibilities and actions required for receiving, recording and responding to enquiries and requests from international and local stakeholders. The Sustainability Manager is designated as the ‘stakeholder keeper’’ that is responsible for providing information, getting feed backs and responding to stakeholders.

Internally, complaints and conflict resolution with employees and dealt with through the ‘Worker’s Committee’ which include management and worker’s representative. The Committee met every quarterly or whenever necessary to discuss issues pertaining to the workers welfare and other matters related to work. Procedurally, complaints received will be minuted in the worker’s committee meeting and actions taken within 10 working days. Each estate and mill maintains an “Enquiry Register Book” for recording verbal and written communications. Inspections of records showed that written requests are held on file together with DAABON’s response. The registers were commenced in mid 2007 and local managers had replied to requests within 10 working days. The audit team review comments/complaints received and the management responses which were kept both in hard and soft copies. To facilitate input and submit complaints, suggestion box are provided located at many locations throughout the mill and estate office.

Discussion with small holders (the member of the Alliances) however revealed that the smallholders do not fully

understand the contract (Observation 01), which suggest inadequate communication and awareness.

PRINCIPLE 1: Commitment to transparency

Criterion 1.1 Oil palm growers and millers provide adequate information to other stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages & forms to allow for effective participation on decision-making.





It was observed during the assessment that the company has clear land titles on all the land / estates involved. Similarly, the smallholders have clear legal title to the land, which is a prerequisite before joining the alliances. Land titles are publically available at Land Office. Information on the group, its oil palm estates and mills as well as information of the alliances are available in the GRI report which is made available annually for public at www.DAABON.com. Initially the company has prepared an environmental and social profile of the establishment made it available to the stakeholders (August 2008). As a communication toll, the company also produced and made publicly available on web, the following documents:

o Fair News – published annually (for BioFach) o Agroalianzas bulletin - published quarterly o InfoDAABON - published quarterly

Register of international conventions and local laws for the mill and estate management and operations are

available (File – Normatividad). Complete list of relevant laws are also listed in the EIA reports prepared for the

mill and estate. Changes in laws are monitored through LEGIS which is managed by the DAABON’s legal

department. The information on the changes is communicated to each relevant department via internal mail.

Person responsible for monitoring compliance to laws & regulations is formally identified in the guideline

The company has valid licenses and permits for the mill and estate operation. These licenses and permits are posted on the wall as part of procedures to monitor its validity period.

It was however observed that working hours posted on the latest version of the internal procedure manual do not reflect the scheduled work hours due to a mistake in printing. However the working hours do not exceed the maximum permitted by law since regardless of the typing mistake, the workers followed the correct schedule. (Minor CAR-01).

As described earlier, legal documents showing land tenureship for each estate and the smallholders are available. The planting of oil palm on the land is not in conflict with the land titles.

The estate and the smallholder land are clearly demarcated on the ground using fences, which is a traditional way of demarcating land as well as to keep livestock within the property.

There was no known land conflict within the certification unit.

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.

PRINCIPLE 2: Compliance with applicable laws and regulation

Criterion 2.1 There is compliance with all applicable local, national and ratified international laws and regulations.

Criterion 2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights.





There are no indigenous people within the vicinity of the plantations. Surrounding landowners and communities, however, do use estate roads for public access across plantation areas. No indigenous people land within / in the vicinity of the plantation

Land is all with proper title. Each estate and the alliances members land are with clear boundary demarcation (fenced up) and no dispute/claims with neighbors.

‘Manual de Administración y producción para plantaciones orgánicas de palma – Grupo DAABON 2010/2015’ described 5 year plan for the group’s plantation. In addition, public information of the group is available in the GRI report which is publicly available at the company’s website.

Tequendama has an annual budget that is projected for 5 years Budgets included allocations for social & environmental/biodiversity conservation programme

The projections include forecasts of FFB yields/ha and oil extraction rates for each of the mills. Tequendama has implemented a management system for monitoring and reporting of performance against production targets for achieving long-term economic and financial viability. Production and performance are reported monthly to

Tequendama senior management.

Significant areas of the plantation in Tequendama estate has reached 30 yrs of age, but the company has yet to document a clear SOP and plan for replanting programme (Minor CAR-02).

The company has the following management document that described the procedures for specific activities and the plantation and the mill:

o ‘Manual de Administration y production para plantaciones organicas de palma – grupo DAABON 2010/2015 (Manual of management and production of organic palm oil crop)

o Proceso de Extraccion de los Aceites crudos de palma y palmiste (Feb 2010).

It was observed that the procedures are adequately implemented in the field. There are records (include in smallholders) available to provide evidence of monitoring of relevant activities. However, there are only 2 agronomist engaged to monitor activities of 163 smallholders (Observation -02) which could results in compromising best practices.

Manual, SOPs, template of records are not adequately controlled where there was no reference number or date on the document to ensure that only latest or updated documents are used at all location (Observation -03).

Criterion 2.3 Use of the land for oil palm does not diminish the legal rights, or customary rights, of other users, without their free, prior and informed consent.

PRINCIPLE 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.

PRINCIPLE 4: Use of appropriate best practices by growers and millers:

Criterion 4.1 Operating procedures are appropriately documented and consistently implemented and monitored





DAABON oil palm plantations are all located on flat land and ex cattle ranches or other agriculture crops. The company practiced zero burning and applied EFB and POME into the field and evidence of monitoring where it is applied. At the time of the assessment, the company is operating a compost plant where EFB, POME and boiler ash are mulched together in an open field to make into compost for field application.

Annual fertiliser recommendation is stated in the budget with the appropriate allocation. Application progress is recorded by date and block and mentioned in the half-yearly review. Examples include: “Progress Report May 08 – Nov 08”. Fertilizers used for organic palm oil nutrition are of mineral origin and there is a small range of sources for essential elements, as follows:

• Nitrogen - Nitrogen ammends are based on three different sources: Ground cover with leguminose plants, Organic matter such as compost and EFB and aplication of organic certified fertilizers with 7-10% content.

• Potassium - Mineral compounds linked to Sulfates or Chlorides and application of compost and EFB.

• Phosphorous - Mineral source phosphoric rock application is done

• Calcium - Done at planting from sulfate mineral sources.

• Borum - Organic certified products that contain traces of Borum.

• Sulfates - Applied through sulfates in association with other ammendments. Regarding nutrition monitoring, DAABON has established what is termed as UMA in Spanish (Agronomic Management units). These units have certain chemical and physical characteristics that determine the types of soils on the farms. This is done to ammend only with the strict amount of input needed for the crops health and production. Furthermore, every year, leaf and soil samples are taken from each of the UMA and sent out to analysis, as to mass balance what the requirements of each lot is on age and production.

Annual leaf sampling and sampling for soil nutrients have been undertaken with the most recent records viewed.

Ground cover is established in open area to protect soil nutrients from excessive leaching by rainwater run-off, and soft weeds are tolerated in the fields for the same beneficial effect. The company applied methods to minimise soil erosion and maintaining soil fertility (e.g. frond stacking and planting of cover crop).

There is Zero-burning policy in place and field observations indicate compliance is consistent. Agronomist report and internal audit reports are available providing recommendation on management improvement.

Photo 5: Shredded EFB are mixed with POME and fibre to make compost.

DAABON group plantations are on flat land. Erosion within the land is a non-issue; however Standard Operation Procedures (SOPs) and guidelines for erosion control is documented.

Bare areas are planted with cover crop (Mucuna bracteata) and soft grasses are maintained along the planted palm line. Fronds cut from pruning activities are placed between the palms where soft grass is allowed to grow. The company only apply circle weeding around the palm to maintain grass cover in most of the estate’s floor.

An annual road maintenance programme is routinely prepared, and a five-year road-resurfacing programme in place that follows the replanting schedules where applicable.

Criterion 4.2 Practices maintain soil fertility at, or where possible improve soil fertility to a level that ensures optimal and sustained yield.

Criterion 4.3 Practices minimise and control erosion and degradation of soils.





Fragile soil is being actively monitored, but no systematic identification throughout the plantation (Observation-04). There are no peat areas in any of the Tequendama estates.

Irrigation in the Northen Colombia area, and specially for the DAABON requirement is done based on the general water requirements that is needed by the crops, usually a well distributed 2200 mm of water per year does the job. However, no DAABON plantations has met this criteria, where the real scenario is a poorly distributed (between March and December) rainfall that barely reaches 1200 mm of water is a normal occurrence. As for the irrigation, Daabon has established a water balance system that feeds from evaporation tanks and humidity retention curves (infiltrometers) to irrigate only what is necessary in terms of time of day and amount. The company use flood irrigation, with primary, secondary and tertiary cannals, that on average use 1 litre/sec/ha. The smallhoders has canal system managed by the authority. The water were distributed according to a specific schedule by the local water district authority that strictly controls the amount of water given to each farm.

As part of management, the company monitored rainfall in each estate. Water consumption is also being monitored and records are kept. In average, the company used 940 litre of water ton of FFB processed. Water quality sampling is carried out twice a year by a certified lab. Parameters monitored depending on what the purpose. Results are sent to the local environmental authority for the re-expedition of the “use” permits.

The company set aside 30 m buffer zones along the stream. Such areas are maintained under natural vegetation, mapped, demarcated and protected from any invasive activities.

Palm oil mill effluents are not released into waterways, but used as fertiliser through land application. Oil traps were installed at the workshop to prevent run offs into the waterways.

Chapter 6 of the manual provide description on procedures for IPM. The group planted the following beneficial plants as part of its IPM programme:

- Bajagua (cassia reculata) – for ants - Bicho (Cassia tora) – for ants - Cascabelilo (Crotolaria sp) – for bees - Escobilla (Sida rhombofolia) – humidity

retention - Uvito (Cordia dentada)- humidity retention - R. Armaddillo (Stachytarpeta cayennensis) –

host plant for ants - Leucaena (Leucaena leucocephala) – for

nitrogen fixation - Higuerilla (Ricinus communis) – host plant for

butterflies and food plant for larvae. It fixes nitrogen when leafs are composted, as it is done regularly.

- Campano (Samanea saman) – for nitrogen fixation

- Roble (Quercus sp)- species migrations and conservation (birds and fruit bats)

- Joba (Spondia mombin) – species migrations

- Photo 6: Planting of beneficial plants.

-

The functions of each plant are described in the EIA report.

Criterion 4.4 Practices maintain the quality and availability of surface and ground water

Criterion 4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management (IPM) techniques.





As part of its organic farming procedures, the company does not use chemicals for pest control. Butterfly traps, made with plastic bags filled with honey and water to attract only a few undesirable species, were observed placed in Tequendama estate but not in other estates due to frequency of its occurrence in that estate. The traps used for pest control are very selective in the case of the Lepidopters and only the Opsiphanes Cassina is sensible to this type of control. Through the monitoring conducted so far, the company has not observed any other insect attracted. In the case of the Rhincophorus palmarum, a specific pheromone

is used to attract this type of beetle.

Besides the problems associated with butterflies, there are no serious problems with pests at the estates. However, butterfly and other insect surveys are done monthly and the company did report the presence of the rhinoceros beetle to the National Database. Daabon has done a thorough evaluation of plagues and deseases occurring in palm oil plantation as part of the implementation of IPM.. Diseases are

monitored through monthly visual inspections, palm by palm as to identify for example “red rings”, basal rottening and/or pestalotiophis. For plague control, the company used a 5 by 5 evaluation, meaning, every 5 palms and 5 lines a count is done at the 25 and 17 level, this is done classifiying every species. Also the company conduct palm to palm monitoring to look for basal rottening using a noise indicator.

Photo 7: Butterfly traps are placed in problem areas

As an organically certified operation, DAABON uses no chemicals in any of its plantations.

In all estates and mill site, signboards on health and safety are displayed at appropriate places such as main entrance, management office, and workshop area and along the road.

Workers have been adequately trained in safe working practices and PPE supplied for all workers, both in the estates and mills. There is a daily briefing by the assistant manager during the morning for workers prior to commencing work, during which workers are reminded of OSH requirements and their PPE.

The “Safety and Health Plan” (SHP) document was viewed. This includes a policy on the health and safety which is filed together with other policies available for public viewing. A safety and health risk assessment has been carried out and is documented. The company used Entomopatogenous fungi as an alternative to pesticide to control plague. The fungus was collected from the field, bred and amplified in the laboratory and then reapply to the field when required. This method is considered an alternative to pesticide that does not harm water, soils or human health. The risk assessment conducted does not include evaluation on use of this fungus for the laboratory personnel (Minor CAR-03) to determine its hazards to the worker. This issue was raised concerning the security of the personnel handling the fungus. Appropriate PPEs were used, but the work/activity was not properly included in the Tequendama Risk Assessment.

Criterion 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 the national Best Practices 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.

Criterion 4.7 An occupational health and safety plan is documented effectively communicated and implemented.





There is an awareness and training programme which involves safe working practices, precautions related to the equipment employed and the use of PPE. However it was observed that there was a high number of accidents occurred which may due to lack of training/supervision or check on worker’s competency (Observation-05).

The workers undergo a health & safety self-evaluation after each training session. PPEs are issued to workers but it was observed that some PPEs provided were not in good conditions suggesting lack of supervising to ensure workers use functional PPE. No goggle for harvester (Observation-06).

The auditors observed both proper and improper use of PPE gear at the various estates. The company does provide appropriate PPE gear and replaces any worn out or unsuitable equipment without limits. Some workers either do not take advantage of this policy or the situation requires more monitoring to ensure all gear is reliable and effective. In this case, it does not merit a minor non-compliance, however, an observation serves as a red flag to be more consistent in PPE use

The company has established a worker’s committee (COPASO) but the meetings were not regularly conducted (Observation-07).

Photo 8: Workers were observed operating with appropriate PPEs.

EIA reports in the form of Environmental Management Plans were prepared for each of the estates and one for the Alianzas plantations and are updated each year:

• Environmental Management Plan for oil palm crop organic and sustainable for Ariguani estate – July 2010

• Environmental Management Plan for oil palm crop organic and sustainable for Gavila estate – July 2010

• Environmental Management Plan for oil plam crop organic and sustainable for Tequendama estate – July 2010

• Environmental Management Plan for oil palm crop organic and sustainable for the Alinzas plantation – July 2010

• Environmental Management Plan for oil palm crop organic and sustainable for the extraction mill – July 2010

PRINCIPLE 5: Environmental responsibility and conservation of natural resources and biodiversity

Criterion 5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to mitigate the negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement.





The report follows standard format for preparation of an EIA report under the Colombian law (Natural Resources Code – Law 2811 - 1974). The potential environmental impacts and mitigation measures for effluents, emissions, and solid waste of operations are evaluated and documented.

For environmental protection, buffer zones (30 meters) are maintained for natural watercourses and about 250 ha have been set aside or restored as conservation areas to assist wildlife movement and habitation.

Inventories of estate flora and fauna are done in association with researchers from local institutions, including the Universidad del Magdalena, tabulated in a report ‘Inventario Illustrado de Fauna y Flora de la Finca Tequendama, Aracataca, Magdalena, Colombia’. Rare, threatened and endangered species could be found are identified and included in management plans for each estate.

The company conducted two major third-party biodiversity studies in 2009, covering both oil palm and coffee production areas. In 2010, the company expanded these studies to include wet season variations to aid their management plans.

Among the IUCN Red-listed species found in plantations include the following (some endemic):

• Mammals – Grey-handed Night Monkey; Northern Naked-tailed Armadillo

• Birds – Rusty-headed Spinetail; Solitary Eagle; Black-and-chestnut Eagle; Blossomcrown; Guacharaca

• Reptiles – Boa constrictor; Santa Marta Poison Arrow Frog

There is a general prohibition on hunting and fishing within the estate. Information signs are posted and the control practice is being effectively implemented. Conservation areas including river buffers set aside in natural states provide refuge for the wildlife. Operations without chemical use provide no threat to the wildlife.

Photo 9: Posters on wildlife and reminders of the company’s no hunting policy are placed at many locations through out the estates.

Criterion 5.2 The status of rare, threatened or endangered species (ERTs) and high conservation value habitats, if any, that exist in the plantation or that could be affected by plantation or mill management, shall be identified and their conservation taken into account in management plans and operations





The company maintains a register of waste streams produced from its operations and takes measures to reduce overall pollution. Waste generated at the palm oil mill is reused for composting and as biomass for boilers.

With workers living outside the estates, there is a very limited amount of solid waste produced on the plantations that is transferred to a landfill. And due to its organic operations, chemicals are not used with a small amount of hazardous waste is disposed by a third party regulated company. Waste recycling is being practiced at the estate office and mill.

EFB is one of the base constituents for making compost for application in the field as a soil conditioner. It was also observed that smallholders pay transport costs to bring back an equivalent amount of EFB to use in their plantations. The beneficial value of the EFB to provide nutrients were deemed worth the minimal but added cost to smallholder operations.

POME is applied to the field through channels / drain. Some POME is mixed with the EFB and boiler ash and used as base material for making compost for application in the field as soil conditioner.

Photo 9: Heaps of EFB applied in the field between rows less than 3 feet high to avoid methane generation

The company uses fibre for running the boiler to generate power for the CPO mill. Palm kernel shell is transported to the refinery for power generation at the refinery plant. Record of fibre used and shell transported to the refinery are available. In average, 16kW of power were for processing of every ton of FFB. Diesel is used in the mill during emergency cases.

The company conducted a life cycle analysis (LCA) of the operation which shows the efficiency of 1,504 mt of FFB production for every litre use of diesel.

Land use change and emissions from palm oil mill effluent (POME) are the biggest CO2 contributors in this industry. As DAABON palm oil developments have been on previous agricultural land, the impacts in this area have no net carbon emissions. To address POME emissions, the company is currently implementing a methane capture and control project, which is approved by the UN under the Clean Development Mechanism (CDM). The project is expected to capture approx 21,000 tonnes of methane per year from POME, which will equate to approx 55,000 tonnes of CO2 equivalents per year, increasing to 83,000 over the next 10 years. The methane captured can be used as an energy source. This project is projected to be in operation at year-end 2010.

Criterion 5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and socially responsible manner.

Criterion 5.4 Efficiency of energy use and use of renewable energy is maximised.





In line with legal procedures and best management practices, DAABON does not use fire in plantation management. The company has a zero burning policy which is promoted to the staff and workers. Observations in the field indicate there is full compliance with no evidence of use of fire for burning waste. Trees felled for a gas pipeline project in one of the estates were buried underground to comply with the standard.

Full compliance indicates the company has the strengths to set policy goals and translate these into field practices. There are no current weaknesses for this standard.

The company has embarked on a comprehensive study of carbon emissions using the PAS standard to measure emissions from oil palm production and palm oil manufacturing. Guidelines on pollution mitigation are available with a strong awareness of land use changes and emissions from POME.

Under the U.N. Clean Development Mechanism (CDM), a methane capture project is expected to be operational by 2011 to capture 21,000 tonnes per year from POME as an additional energy source, increasing to 83,000 tonnes over the next 10 years. The company aims to be certified Carbon Neutral in 2012.

EFB produced are either transported to the field or used as a based material for composting

As part of the broader environmental evaluation, each estate has in place a Social Impact Evaluation section added to the Environment Management Plan. These annual planning documents are done in consultation with stakeholders, especially the alliance organizations that represent individual smallholders producing crop for DAABON.

The company has a Sustainability Division that proactively engages with stakeholders with dedicated staff responsible for the awareness, communication and implementation of best practices and company policies.

A comprehensive list of stakeholders is maintained and a grievance procedure is in place to deal with complaints. The company places boxes throughout the mill and estates for suggestions and maintains records of consultation with stakeholders. Additionally, a Worker’s Committee has been established and remains in operation to process complaints and serves as a communication mechanism. External stakeholders contribute through emails, where the procedures stated that the company representative must respond within 10 working days.

The company maintains a complaints and grievance procedure that is specified in its SOP documentation. Discussions and interviews during the assessment revealed no major issues with workers or the surrounding communities.

Regarding customary rights, the company works together with a local NGO (Fundacion Pro- Sierra Nevada de Santa Marta) in identifying areas reserved for native Indian peoples and protected areas. Areas for indigenous communities have been set aside by the Colombian Government since the 1970s with maps clearly marking

Criterion 5.5 Use of fire for waste disposal and for preparing land for replanting is avoided except in specific situations, as identified in the ASEAN Guidance or other regional best practice.

Criterion 5.6 Plans to reduce pollution and emissions, including greenhouse gases, are developed, implemented and monitored.

PRINCIPLE 6: Responsible consideration of employees and of 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.

Criterion 6.2 There are open and transparent methods for communication and consultation between growers and/or mills, local communities and other affected or interested parties.

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.





boundaries and distances. All DAABON plantations under this assessment are located far outside the tribal areas without any contiguous borders or need to gain access to their properties.

The three indigenous tribes located within the region include the Aruhacos, the Wiiwas and the Kogis. These tribes are self-governed.

All DAABON properties have recognized land titles with communities arising in the nearby areas only after the land was develop by the company.

The three indigenous tribes located within the region include the Aruhacos, the Wiiwas and the Kogis. These tribes are self-governed and deal with regional political and religious authorities.

Without any indigenous peoples near DAABON plantations and operations, there was no evidence of land disputes or legal and customary rights claims. Legal procedures are in place by the Colombian authorities to deal with any matters arising from native claims.

Therefore, the company does not have any specific procedures or compensation mechanisms of their own and must refer and defer to the Colombian legal system.

There are proper terms and conditions for the employment of workers that are documented. A clear and transparent remuneration system is in place with an employment agreement for individual workers.

Workers are provided with fringe benefits, such as lunch and potable water, and free bus transportation is provided by the company to pickup and return employees from nearby communities. There are no workers living on the plantation grounds and no foreign worker employed. Most staff of DAABON are local.

Interviews with workers in the field and in the mill did not reveal any dissatisfaction with working conditions or pay. With limited opportunities for work, most employees were pleased to be working for a well-established and family owned company with roots in the area However, the audit team discovered that legal labour requirements regarding working hours were contravened after interviews with workers. A discrepancy arose over working hours cited in worker agreements versus real conditions in the field and mill. (Please refer to Minor CAR-01)

The company does not provide restriction for workers to form workers union. Management statement of freedom of association is publicly available in local language. Workers are subjected terms and conditions of employment.

The mill and estates maintain a complete register of workers with details of each individual, including date of birth. There was no evidence of under age (below 18 years) workers operating in the mill or estates. Tequendama does not employ persons under 18 years old. Personal information of workers showed that all workers are above 18 years old.

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 views through their own representative institutions.

Criterion 6.5 Pay and conditions for employees and for employees of contractors always meet at least legal or industry minimum standards and are sufficient to provide decent living wages.

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 the law, the employer facilitates parallel means of independent and free association and bargaining for all such personnel.

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.





There is evidence that the company does not engage or support discrimination based on race, caste, national origin, religion or gender. An equal opportunity policy stated in the local language is available and no allegations of discrimination were submitted or revealed from documentation and interviews.

The company has documented its policy on sexual harassment and displays it at a number of locations in the office and estate premises. A complaints and grievances procedure and mechanism is in place, with additional procedures on the prevention and eradication of sexual harassment and violence. There have been not cases of harassment against women.

The company deals openly and fairly with smallholders and displays daily prices for organic and non-organic FFB at their collection center. Visitation records by DAABON field staff are maintained with very thorough explanations for plantation management. Smallholders can choose to deliver FFB to the collection center or, if the loads are sizable, request pickup from their farms by the Tequendama mill vehicles.

Discussions by the audit team with smallholders revealed some complaints regarding the policy of a 10% increase for organic FFB. Although the daily prices are publically listed, there is no formal agreement signed that protects this price policy for smallholder growers (Observation-08). The issue, according to smallholders, was the lack of a written policy to protect the 10% price increase for organic FFB as understood by all parties. Although this is an important issue and may arise in the future, it was not an immediate concern.

The company has a wide-ranging record of social contributions to sustainable development of local communities. DAABON works with the Alliances, first established by the government to maintain peace and stability, to form productive and beneficial cooperative programs with smallholders for families displaced by violence.

Land was provided by the company for schools in the town of Santa Marta and in the estates. Co-funding was also provided for a Children’s’ Attention Center that gives medical care and mother care to over 5,000 kids from violent areas. In addition, a mobile theatre, provided by the company, teaches rural communities about ethics, values and respect with movies to inculcate them in future generations.

Each estate has a social agenda to improve socioeconomic conditions of workers through micro-entrepreneur programs, such as sewing contracts to provide DAABON workers with uniforms. Other initiatives include a Cooperative Fund and contributions to improve remote communities with funds for health clinics, adult education classes and play-school facilities. Donations to the Mayor’s office help to finance hospital equipment and machinery for road improvements.

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.

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.

Criterion 6.10 Growers and mills deal fairly and transparently with smallholders and other local businesses.

Criterion 6.11 Growers and millers contribute to local sustainable development wherever appropriate.





This Principle is not applicable as there was no new plantings within the CI Tequendama estates and smallholders. All Tequendama oil palm plantations in Colombia were planted many years back during the 1960s and 1970s. There was no new plantings after November 2005. The lands were either purchased from other companies or developed by the Group in the early years. Most land was previously used for cattle ranching and/or cotton or cocoa cultivation.

Not applicable. All estates have been planted before November 2005.

Not applicable

Not applicable

Not applicable

Not applicable.

Not applicable.

As a certified organic farm, the Group does not use chemical or inorganic fertilizer in its operation. The group is making effort in recycling and minimizing waste. The EFB and POME produced are being used as a base material for making compost which is being re-used in the mill. The mill is putting up a methane capture facility to reduce GHG emissions.

Internal audits are conducted where reports are available as part of its improvement process. DAABON continuously make improvement in techniques and procedures. Continuous cooperation with experts allows continuous improvement particularly in the environment and social management. The group continuously strives to improve the livelihood of communities where it operates.

PRINCIPLE 7: Responsible development of new plantings

Criterion 7.1 A comprehensive and participatory independent social and environmental impact assessment is undertaken prior to establishing new plantings or operations, or expanding existing ones, and the results incorporated into planning, management and operations.

Criterion 7.2 Soil surveys and topographic information are used for site planning in the establishment of new plantings, and the results are incorporated into plans and operations.

Criterion 7.3 New plantings since November 2005 have not replaced primary forest or any area required to maintain or enhance one or more High Conservation Values.

Criterion 7.4 Extensive planting (to be determined by SEIA) on steep terrain, and/or on marginal and fragile soils, is avoided.

Criterion 7.5 No new plantings are established on local peoples’ land without their free, prior and informed consent, dealt with through a documented system that enables indigenous peoples, local communities and other stakeholders to express their views through their own representative institutions..

Criterion 7.6 Local people are compensated for any agreed land acquisitions, relinquishment of rights, subject to their free, prior, and informed consent and negotiated agreements.

Criterion 7.7 Use of fire in the preparation of new plantings is avoided other than in specific situations, as identified in the ASEAN Guidance or other regional best practice.

PRINCIPLE 8: Commitment to continuous improvement in key areas of activity

Criterion 8.1 Growers and millers regularly monitor and review their activities and develop and implement action plans that allow demonstrable continuous improvement in key operations.





8.0 ISSUANCE OF NON-COMPLIANCE

Four Minor CARs and nine observations were issued as a result of the assessment. The non-conformances are as tabulated under section 12 of this report.

C.I. Tequendama S.A. has prepared a Corrective Action Plan for addressing the identified Minor Nonconformities and observations. SGS has reviewed and accepted C.I. Tequendama’s Corrective Action Plan.

9.0 ASSESSMENT DECISION

With no outstanding Major CAR, the C.I. Tequendama’s management of Tequendama Palm Oil Mill and its supply base estates in Department of Magdalena, Colombia, is now recommended for the certification against the RSPO P&C Colombia Local Indicators. The issues highlighted as Minor CARs must be adequately addressed and the adequacy of the actions taken will be verified during the first surveillance visit to be conducted within 12 months from the date of assessment.

10.0 ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY AND FORMAL SIGN-OFF

OF ASSESSMENT FINDINGS

It is acknowledged that the assessments cited in this report have been carried out as stipulated and we confirm the acceptance of the assessment report contents including assessment findings.





11.0 RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS

As described in the earlier sections of this report, letters were sent to stakeholders as apart of process for informing them on the assessment to be carried out as well as a mechanism to solicit comments. During the assessment, discussion and consultation were held with a number of agencies, communities, workers etc. Follows are the comments/issues received or highlighted by the stakeholders and responds from the audit team:

Nr Comment Response

Main Evaluation

1

Las Pavas Farm Occupation

In 2009, local and international news reported and condemned the expulsion of local farmers and families from lands scheduled to be cultivated with oil palm in the Las Pavas farm by the DAABON Group.

The DAABON Group, as part owner of the property, was denounced as the cause of the eviction and the target of demonstrations and campaigns in Colombia and Europe. An independent commission, made up of the Body Shop, a buyer of DAABON palm oil, and Christian Aid, produced a report in September 2010 to investigate the issue.

The auditors derived the following response from evaluations and conclusions made by the independent report from the Body Shop-Christian Aid commission and discussions with DAABON staff involved with the issue.

According to the “Report Independent Commission Land Conflict -Las Pavas-Bolívar, Colombia” of September 2010, there was no resolution of the land dispute, but rather a series of recommendations for all parties involved, whether private or public sector, NGO or farmers. The DAABON Group, as part of the consortium, agreed to implement the recommendations to find a satisfactory resolution to the Las Pavas case.

The report recognizes the difficulties of land tenure rights and the roles of various government agencies and NGOs to overcome a lack of proper consultation and communication mechanisms to resolve economic and environmental issues. The commission encourages greater participation of the private sector to adhere to social responsibility and human rights concerns to respect and improve the living conditions of marginalized communities, such as Buenos Aires, in rural areas.

The DAABON Group responded to the occupation of the Las Pavas farm in the following manner. From a legal perspective, the consortium held proper land title to the Las Pavas area that was recognized by the local and federal authorities. Any previous land disputes by the previous owner were not an issue when the land was bought, nor was there any occupation at the time of purchase.





Nr Comment Response

Main Evaluation

1 DAABON staff held numerous meetings with the occupants to resolve the situation and offered partial farm land for community use. After refusal and a lengthy occupation, the consortium requested the authorities to remove them before Colombian law allowed occupiers to make claim on the land.

News reports of the eviction were not entirely truthful with false film footage and accusations of temporary structures being torn down by DAABON. No DAABON personnel were either involved in the eviction procedure, nor did they dismantle any temporary shelters. In fact, farmers broke down these structures to use back in their villages.

DAABON respects the findings of the independent report and has started to address the recommendations made by the commission. To date, the offer to use part of the Las Pavas farm for community use is still viable. However, in view of the circumstances of the Las Pavas case, DAABON is rethinking its involvement with the consortium to continue with oil palm cultivation in the area.





12.0 RECORD OF CORRECTIVE ACTION REQUESTS (CARS) AND OBSERVATIONS

RECORD OF CORRECTIVE ACTION REQUESTS (CARS)

Organisation: C I Tequendama (DAABON) Project Nr: MY02299

Assessment: Main assessment agains RSPO P&C Colombian LI

Date: 13 August 2010

Lead Assessor: Salahudin Yaacob Auditor:

Rick Gregory Luis Enrique Medina Bermudez Jorge Hernan Gomez

CAR #

Indicator CAR Detail

Date Recorded> 13/08/10 Due Date> Date Closed>

Non-Conformance:

Inconsistent implementation of working hour requirement for the estate operation.

Objective Evidence:

The company document stated that work hours are between 6 am – 2 pm, but the actual hours spent by workers was between 6 am – 3 pm.

Close-out evidence:

01 2.1.1 & 6.5.2

Date Recorded> 13/08/10 Due Date> dd MM yyyy

Date Closed> dd MM yyyy

Non-Conformance:

Lack of management prescription and plan for replanting.

Objective Evidence:

Significant areas of the plantation have reached 30 yrs of age or more, but the company has yet to document a clear SOP and plan for a replanting programme.

Close-out evidence:

02 3.1.2

Date Recorded>

13/08/10 Due Date> dd MM yyyy

Date Closed>

dd MM yyyy

Non-Conformance:

Inadequate risk analysis that does not cover all aspects of estate operation.

Objective Evidence:

Health and safety risk assessment does not include evaluation on application of fungus spraying.

Close-out evidence:

03 4.7.1





CAR #


Date Recorded>

13/08/10 Due

Date> Dd MM

yyyy Date

Closed> dd MM yyyy

Non-Conformance:

Inadequate training programme for estate’s workers and smallholders to identify training needs

Objective Evidence:

Training programmes were provided but not based on specific training programmes.

Close-out evidence:

04 4.8

RECORD OF OBSERVATIONS

OBS #


Date Recorded> 13/08/10 Due Date> Date Closed>

Non-Conformance:

Inadequate information dissemination and awareness programme to smallholders on RSPO requirement.

Objective Evidence:

Smallholders do not fully understand the contract.

Close-out evidence:

Obs 01

1.1.3

Date Recorded>

13/08/10 Due Date> Dd MM

yyyy Date

Closed> dd MM yyyy

Non-Conformance:

Inadequacy of competent staff to effectively monitor the implementation of operational procedures in smallholdings.

Objective Evidence:

Only 2 agronomists are currently available to monitor 163 smallholders.

Close-out evidence:

Obs 02

4.1.2

Date Recorded>


Date Closed>

Dd MM yyyy

Non-Conformance:

Manual, SOPs, template of records not adequately controlled (i.e. no reference number or date).

Obs 03

4.1.1

Objective Evidence:





Manual and SOPs are not consistently and properly dated and identified with systematic reference numbers.

Close-out evidence:

Date Recorded>


Date Closed>

dd MM yyyy

Non-Conformance:

Lack of identification and formal management strategy for handling fragile soils.

Objective Evidence:

Fragile soil is being actively monitored (e.g. Ariguani Estate), but there is no systematic identification throughout the plantation.

Close-out evidence:

Obs 04

4.3.1

Date Recorded>

13/08/10 Due

Date> Dd MM

yyyy Date

Closed> dd MM yyyy

Non-Conformance:

High number of accidents may be due to lack of training/supervision or an analysis of worker competency.

Objective Evidence:

Record of high number of accidents in past two years.

Close-out evidence:

Obs 05

4.7.2

Date Recorded>

13/08/10 Due

Date> dd MM yyyy

Date Closed>

dd MM yyyy

Non-Conformance:

PPE provided not in good conditions/ lack of supervising to ensure workers use functional PPE. No goggle for harvester.

Objective Evidence:

Some workers found wearing inadequate footwear and inappropriate aprons, together with harvesters not wearing goggles.

Close-out evidence:

Obs 06

4.7.3

Date Recorded>

13/08/10 Due Date> Dd MM

yyyy Date

Closed> dd MM yyyy

Non-Conformance:

Inadequate awareness on COPASU activities and its benefits to workers.

Objective Evidence:

COPASO meetings were regularly conducted but its roles and functions were not broadcasted wide to all workers with full understanding.

Obs 07

4.7.5

Close-out evidence:





Date Recorded>

13/08/10 Due

Date> Dd MM

yyyy Date

Closed> dd MM yyyy

Non-Conformance:

General agreement for 10% increase in price for organic FFB benefits not formally instituted

Objective Evidence:

The smallholder suppliers are paid a 10 % benefit in price but the documents making commitment to the price were not properly signed by DAABON management.

Close-out evidence:

Obs 08

6.10.2

Date Recorded>

13/08/10 Due

Date> Dd MM

yyyy Date

Closed> dd MM yyyy

Non-Conformance:

Missing link in traceability of FFB delivered from smallholders to the mill. No clear link between the Delivery Notes from the supplier, the weighbridge ticket issued and the bin of the FFB delivered to the mill.

Objective Evidence:

Observation of procedures at CI Tequendama collection center.

Close-out evidence:

Obs 09

END OF REPORT

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