ST-1 [ ] ST-2 [v] [ ] · Prepared by Mutuagung Lestari for Selabak POM – PT Swadaya Andika...

PT. MUTUAGUNG

LESTARI

ASSESSMENT REPORT

Roundtable on Sustainable Palm Oil Certification

[ ]ST-1 [ ] ST-2 [v] Surv-1 [ ] Re-Assessment

Plantation Management/Owner : MINAMAS Plantation - Sime Darby Group

Plantation Name : Selabak Factory PT Swadaya Andika

Location :

Pamukan Utara Sub District, Kotabaru District, South Kalimantan Province

Certificate Code : MUTU-RSPO/015

Date of certificate issue : 16 03 - 2012

Date of expiry of certificate : 16 03 - 2017

Assessment Assessment

Date PT. Mutuagung Lestari

Auditor Checked

by Approved

by

ST1 04/04/2011 08/04/2011

Taufik Margani (Lead Auditor), Nanang Mualib (Lead Auditor Witnessed), Muardi Marwas

(Auditor), Junser Naibaho (Auditor)

Tony Arifiarachman

Tony Arifiarachman

ST2 06/05/2011 11/05/2011 Nanang Mualib (Lead Auditor),

Muardi Marwas (Auditor), I Wayan Sudi Antara (Auditor)

Taufik Margani

Tony Arifiarachman

S1 21/01/2013 23/01/2013

Taufik Margani (Witnesser), Oktovianus Rusmin (Lead Auditor

Witnessed), Yudwi Wisnu Rahmanto (Auditor), Ardiansyah (Auditor), Moh. Arif Yusni (Trainee

Auditor)

Octo H.P.N. Nainggolan

Tony Arifiarachman

Mutuagung Lestari Raya Bogor Km 33,5 Number 19 Cimanggis Depok 16953 Indonesia

Telephone (+62) (21) 8740202 Fax (+62) (21) 87740745/6

Email : [email protected] www.mutucertification.com

MUTU Certification Approved by RSPO Secretariat on June 2008

Submitted to RSPO on:

Approved by RSPO on:

Approved by Certification Body on:

01 April 2013 - 16 March 2013

http://www.mutucertification.com/

PT. MUTUAGUNG

LESTARI

ASSESSMENT REPORT

SPO 4006a.5 ii Prepared by Mutuagung Lestari for Selabak POM PT Sawadaya Andika

TABLE OF CONTENT

FIGURE

Figure 1. Location Map of PT Swadaya Andika Figure 2. Operational Map of PT Swadaya Andika

2 3

1.0 SCOPE of the SURVEILLANCE ASSESSMENT

1.1 National Interpretation Used 4

1.2 Organization Information 4

1.3 Type of Assessment 4

1.4 Location of Plantations, Mill and Area Statement 4

1.5 Description of Supply Base 5

1.6 Dates of Plantings and Cycles 6

1.7 Tonnage Certified 6

1.8 Other Certifications 7

1.9 Time-Bound Plan for Other Management Units 7

2.0 ASSESSMENT PROCESS

2.1 Certification Body 8

2.2 Assessment Team 9

2.3 Assessment Methodology, Assessment Process and Locations of Assessment 9

2.4 Stakeholder Consultation and List of Stakeholders Contacted 10

2.5 Date of Next Surveillance Visit 10

3.0 ASSESSMENT FINDINGS

3.1 3.2

Summary of Assessment Report of the RSPO Certification Summary of Assessment Report of Supply Chain Requirement

11 29

3.3 Conformity Checklist of Certificate and Logo Use 33

3.4 Summary of RSPO Partial Certification 34

3.5 Identification of Findings, Corrective Actions, Observations, Opportunity for Improvement and Noteworthy Positive Components

35

3.6 Summary of Arising Issues from Public, Management and Auditor Responses 42

4.0 CERTIFIED ORGANIZATIONS ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY

4.1 Formal Signing of Assessment Findings 47

APPENDICES

1. List of Stakeholders Contacted in the RSPO Certification Process 48

2. Assessment Program 49

3. Glossary 50

PT MUTUAGUNG LESTARI

ASSESSMENT REPORT

SPO 4006a.5 2 Prepared by Mutuagung Lestari for Selabak POM PT Sawadaya Andika

Figure 1. Location Map of PT Swadaya Andika

PT MUTUAGUNG LESTARI

ASSESSMENT REPORT

SPO 4006a.5 3 Prepared by Mutuagung Lestari for Selabak POM PT Sawadaya Andika

Figure 2. Operational Map of PT Swadaya Andika

PT. MUTUAGUNG LESTARI

ASSESSMENT REPORT

SPO 4006a.5 Page 4 Prepared by Mutuagung Lestari for Selabak POM PT Swadaya Andika

1.0 SCOPE OF THE CERTIFICATION ASSESSMENT

1.1 National Interpretation Used National Interpretation, RSPO Principles and Criteria (P&C) for Sustainable Palm Oil

Production, Republic of Indonesia - RSPO INA-NIWG, May 2008 and RSPO Supply Chain

Certification Standard November 2011.

1.2 Organization Information

1.2.1 Company name MINAMAS PLANTATION SIME DARBY Group

1.2.2 Contact person Mohamad Pirabaharan

1.2.3 Company address and site address The Plaza Officer Tower. 36th Floor Jl. M.H Thamrin Kav 28-30 Jakarta Pusat 10350.

1.2.4 Telephone +6221 29926000

1.2.5 Fax +6221 29922686

1.2.6 E-mail [email protected]

1.2.7 Web page address www.simedarby.com

1.2.8 Company status Private

1.2.9 Management Representative who completed the application for certification Mohamad Pirabaharan

1.2.10 Registered as RSPO member September 8, 2004

1.3 Type of Assessment

1.3.1 Scope of Assessment Mill and Estate

1.3.2 Type of certificate Single

1.3.3 Company names listed in the certificate

PT. Swadaya Andika PT. Langgeng Muara Makmur (Lanting Estate)

1.3.4 Number of management unit 1 (unit) mill namely Selabak Mill which has FFB source from 4 (four) estates namely Selabak Estate, Randi Estate, Sangkoh Estate, and Lanting Estate.

1.4 Locations of Mill, Plantations and Area Statement

1.4.1 Location of Mill

Name of Mill Location

GPS

Latitude Longitude

Selabak Mill Selabak Village / Sungai Durian Sub District / Kotabaru District / South Kalimantan Province

2 29 86 LS 116 12 23 BT

1.4.2 Location of Supply Base

Name of Supply Base Location

GPS

Latitude Longitude

Randi Estate

Manunggal Lama Village/ Sungai Durian Sub District/ Kotabaru District/ South Kalimantan Province

23120 - 22428 1160935 - 1161331

Selabak Estate

Selabak Village / Sungai Durian Sub District / Kotabaru District / South Kalimantan Province

23007 - 22746 1160808 - 1161306

mailto:[email protected]://www.simedarby.com/


ASSESSMENT REPORT


Sangkoh Estate

Manunggal Lama Village/ Sungai Durian Sub District/ Kotabaru District/ South Kalimantan Province

23120 - 22617 1161219 - 1161558

Lanting Estate

Harapan Baru Village/ Pamukan Utara Sub District/ Kotabaru District/ South Kalimantan Province

22926 - 22609 1161509 - 1162025

1.4.3 Tenure

Private -

State 13,680.23 Ha

Community -

1.4.4 Area Statement

PT. Swadaya Andika Lanting Estate

Total area 10,430.97 3,249.26 Ha

Mature area 8,594,09 2,637.06 Ha

Immature area 0 98.00 Ha

Mill 14.21 0 Ha

Infrastructure 531.81 100.92 Ha

Nursery 0 0 Ha

Occupation 498.79 0 Ha

Others area 573.07 413.28 Ha

HCV 219.00 0 Ha

1.5 Description of Supply Base

1.5.1 Description of Mill

Name of Mill Capacity

(tonnes/ hour)

FFB Processed

(tonnes/ year)

CPO Palm Kernel PKO

Out put (tonnes)

Extraction (%)

Out put (tonnes)

Extraction (%)

Out put (tonnes)

Extraction (%)

Selabak POM 30 152,467 33,777 22.15 7,000 4.67 0 0

*Source Production Data January December 2012

1.5.2 Description of Estate(s)

Name of Estate(s) Total Area

(Ha)

Planted Area (Ha)

FFB (tonnes/year)

Yield (tonnes/ha/year)

Supplied to Mill

FFB (tonnes/year)

%

Randi Estate 3,190.72 2,677.01 54,802.82 20.47 21,933.49 40.03

Selabak Estate 3,757.65 3,366.90 63,680.31 18.91 28,678.34 45.04

Sangkoh Estate 3,482.59 2,550.18 56,925.67 22.32 51,174.03 89.90

Lanting Estate 3,249.26 2,637.06 56,624.83 2.47 50,583.68 89.34

Total 13,680.23 11,231.15 232,033.63 20.66 152,369.54 65.67


1.5.3 Smallholder(s) and other source

Name of source(s)

Member(s) Location Total Area

(Ha) FFB

(tonnes/year)

Supplied to Mill

FFB (tonnes/year)

%


ASSESSMENT REPORT


KKPA - ASC - Rantau Buda 498.34 1,827.28 378.87 20.73


1.5.4 Product categories FFB/CPO/PK

1.6 Dates of Plantings and Cycles

1.6.1 Age profile of planted palms*

Planting Year Hectar Age (Year)

1994 1,023.29 18

1995 184.22 17

1996 4,243.89 16

1997 2,102.22 15

1998 2,316.58 14

1999 43.12 13

2000 423.07 12

2001 124.04 11

2006 262.10 6

2007 270.15 5

2008 183.98 4

2009 54.49 3

2010 98.00 2

TOTAL 11,329.15

1.6.2 New Planting area after November 2007 - Ha

1.6.3 Planting Cycle 25 Years

1.7 Approximate Tonnage Certified

1.7.1 Past Annual Claim Certified Product

FFB Production 132.389,.51 Tonnes/year

CPO Production 28.590,97 Tonnes/year

Palm Kernel (PK) Production 6.197,21 Tonnes/year

Palm Kernel Oil (PKO) Production 0 Tonnes/year

1.7.2 Claim Certified Tonnage of FFB

Name of Estate(s) Total Area

(Ha) Planted Area

(Ha) FFB

(tonnes/year) Yield

(tonnes/ha/year)

Randi Estate 3,190.72 2,677.01 21,933.49 8.19

Selabak Estate 3,757.65 3,366.90 28,678.34 8.51

Sangkoh Estate 3,482.59 2,550.18 51,174.03 20.06

Lanting Estate 3,249.26 2,637.06 50,583.68 19.18

Total 13,680,23 11,231.15 152,369.54 13.56


1.7.3 Claim Certified Tonnage of Palm Product


ASSESSMENT REPORT


Name of Mill Capacity

(tonnes/ hour)

FFB Processed

(tonnes/ year)

CPO Palm Kernel PKO

Out put (tonnes)

Extraction (%)

Out put (tonnes)

Extraction (%)

Out put (tonnes)

Extraction (%)

Selabak POM 30 152,369.54 35,425.92 23.25 7,313.74 4.80 0 0


1.8 Other Certifications

1.8.1 ISO 9001:2008/ISO 14001: 2004 -

1.8.2 OHSAS 18001:2007 -

1.8.3 HACCP -

1.8.4 Others ISPO

1.9 Time Bound Plan for Other Management Units

Management Unit

Address Hectarage

(Ha) *) Time Bound

Plan Status

PT. Indotruba Tengah Seruyan and Kotawaringin Barat District Central Kalimantan Province

7,734.60 2009 Certified

PT. Laguna Mandiri Kotabaru District South Kalimantan Province

15,300 2011 Certified

PT. Aneka Inti Persada Pekanbaru and Siak District Riau Province

11,134.00 2010

Certified

PT. Bahari Gembira Ria Muaro Jambi District Jambi Province 1,202.04 2010 Certified

PT. Bina Sains Cemerlang Musi Rawas District South Sumatera 6,513.00 2010 Certified

PT. Bhumireksa Nusa Sejati Indra Giri Hilir District Riau Province 25,662.00 2010 Certified

PT. Kridatama Lancar Seruyan and Kotawaringin Timur District Central Kalimantan Province

14,779.92 2010

Certified

PT. Lahan Tani Sakti Rokan Hilir District Riau Province 3,759.02 2010

Certified

PT. Ladangrumpun Suburabadi

Tanah Bumbu District South Kalimantan Province

6,077.00 2010 Certified

PT. Sajang Heulang Tanah Bumbu District South Kalimantan Province

7,794.00 2010

Certified

PT. Bersama Sejahtera Sakti Kotabaru District South Kalimantan Province

13,925.00 2010 Certified

PT. Teguh Sempurna Seruyan and Kotawaringin Timur District Central Kalimantan Province

16,601.66 2010

Certified

PT. Budidaya Agro Lestari Ketapang District West Kalimantan Province

1,002.00 2011 Audited

PT. Guthrie Pecconina Indonesia

Musi Banyuasin District South Sumatera Province

10,139.91 2011

Certified

PT. Langgeng Muaramakmur Kotabaru District South Kalimantan Province

16,361.77 2011

Certified

PT. Mitra Austral Sejahtera Sanggau District West Kalimantan Province

8,741.29 2011 Audited

PT. Paripurna Swakarsa Kotabaru District South Kalimantan Province

14,892.00 2011

Certified

PT. Perkasa Subur Sakti (Blang Simpo POM)

Aceh Timur District Nanggroe Aceh Darussalam Province.

6 2011 Audited

PT. Perusahaan Sri Kuala Aceh Tamiang District - Nangroe Aceh 1,128.90 2011 Audited


ASSESSMENT REPORT


Darussalam Province

PT. Sandika Natapalma Ketapang District West Kalimantan Province

8, 406.21 2011

Audited

PT. Swadaya Andika Kotabaru District South Kalimantan Province

10,361.18 2011

Certified

PT. Tamaco Graha krida Morowali District Central Sulawesi Province

4,145.00 2011

Certified

2.0 ASSESSMENT PROCESS

2.1 Certification Body

PT Mutuagung Lestari

Jl. Raya Bogor Km 33,5 No. 19, Cimanggis - Depok 16953

Telp. +62-21-8740202; Fax +62-21-87740745/46

Website: www.mutucertification.com Email : [email protected]

2.2 Assessment Team

2.2.1 Lead Assessor and Assessment Team

S1 1) Taufik Margani (Lead Auditor Witnesser). A bachelor of Forestry, Majoring in Forest Management. A specialist in Environment. He had led a number of audits for Sustainable Forest Management in Indonesia (under the scheme of LEI-Lembaga Ekolabel Indonesia/Indonesia Ecolabel Body and FSC-Forest Stewardship Council) and Lead Auditor for FSC Chain of Custody. Other experiences: He was the certified Lead Auditor of IRCA for Environmental Management System and Quality Management System. Since 1999, he had worked for an independent certification body and had conducted a number of Audits of Environmental Management System, Quality Management System and RSPO in Malaysia and Indonesia. Currently, he works as The General Manager of Management System Certification.

2) Oktovianus Rusmin (Lead Auditor Witnessed). Bachelors Degree in Social & Political Sciences Department of Anthropology. Specialists in the field of Social and Cultural (Social Impact & Conflict Resolution) and HCVF. Followed the Forest Management Auditor Training (FSC Standard), ISO 14001 Environmental Management System Training & SVLK (wood legality) auditors, Indonesian Sustainable Palm Oil (ISPO) Auditor, Management System Certification (ISO 9001-2008/SNI 19-9001:2008) and RSPO Lead Auditor Training by Proforest & Wild Asia in Kualumpur. He was several times involved in the assessment of Sustainable Forest Management Certification (Standard LEI). Had worked at the Center for the study of Anthropology, University of Indonesia; and experts to the field of Social Tropical Forest Trust (TFT) Indonesia. He was numerously involved the Social Impact Study and Identification HCV in Oil Palm Plantations and natural forest concessions. In this assessment activity, he conducted assessment of social and land concession.

3) Yudwi Wisnu Rahmanto (Auditor). Bachelor of Forestry with Silviculture background. He has attended in selected

training, such as Auditor/Lead Auditor Course Quality Management System (QMS) ISO 9001:2008, Timber Legality Assurance System (SVLK), Verification Organization Training C.A.F.E Practices (Starbucks), Organic Standard (EU, NOP, JAS), Forest Stewardship Council (FSC), Program Endorsement of Forest Certification (PEFC) and Organic Exchange for Textile. He also has experience as an auditor and involved in certification program auditing, such as Sustainable Forest Management by FSC FM/COC Scheme, Coffee And Farmer Equity (C.A.F.E Practices) Starbucks, Sustainable Palm Oil by RSPO Scheme, Organic Standard (EU, NOP, JAS) for Coffee Farmer and Organic Exchange for Textile. Currently, he worked at Professional Certification Body and assigned to verify in Social aspect during this Assessment.

4) Ardiansyah (Auditor) Bachelor of Forest Resources Conservation, Department of Forestry, Bogor Agricultural

University. He has followed several activities such as preparing EIA document for Palm Oil Plantation and Industrial Plantation Forests, assistance in the GAP analysis, and helped draft the HCV document. It has been several times following audit activities related to sustainable palm oil certification system as an auditor. In this Surveillance-1

http://www.mutucertification.com/mailto:[email protected]


ASSESSMENT REPORT


assessed the environmental aspects, soil and water conservation. 5) Moh. Arif Yusni (Auditor) A bachelor of Agriculture, majoring of Plant Pest and Deseases (Plant Protection). He has a

working experience for 2 (two) years in oil palm Plantation Company in Indonesia. Trainings attended namely: Indonesian Sustainable Palm Oil (ISPO) Lead Auditor training course. Now he worked at Professional Certification Body. he has been several times following audit activities related to sustainable palm oil certification system as an obeserver and auditor. In the assessment activity, he assessed on, best practices, environment aspect, and workers welfare

2.3 Assessment Methodology, Assessment Process and Locations of Assessment

2.3.1 Figure of person days to implement assessment

S1 Number of auditors : 5 auditor Number of days at site : 3 days Number of working days at site : 15 Working days

2.3.2 Detail process of assessment

S1 Surveillance activity one aims to measure the the implementation of that has been done by the company (PT Swadaya Andika) against the requirements of the Republic of Indonesian National Interpretation of RSPO Principles and Criteria (P & C) RSPO Sustainable Palm Oil (RSPO INA-NIWG, May 2008). Assessment done three ways, ie: (1) assessment company documents, aiming to see the completeness, validity and sufficiency of substance of the required documents, (2) interview, aiming to get a more in-depth information, and (3) observation, aiming see directly adequacy of implementation in the field compared with the result data interview and information contained in the document. Some directions for improvement of the Surveillance 1 assessment results is delivered by an auditor QUALITY to the manager (PSA), and the results are used as material verification of Survaillance stage 2 (S2). All obtained information are recorded in the Checklist (Check List) Mutuagung PT Lestari and being a primary attachment of Assessment Reports. The complete assessment process as follows: January 21, 2013. The auditor team did opening meeting at the RSPO Secretariat of PT Swadaya Andika Kantor Estate RandiAndika, followed by a study of the documents related to the legal aspects, social, production and environmental. January 22, 2013. The auditor team (Oktovianus Rusmin and Taufik Margani) did stakeholder consultation until 12.00 p.m. Other audit team (Yudwi Vishnu Rahmanto, Ardiansyah and Moh. Arif) conducted field visits in accordance with their respective fields (Yudwi Vishnu Rahmanto: visiting the factory, Ardiansyah: visiting the sites related to environmental management such as monitoring of erosion, soil conservation and water, Moh Arif: harvesting site visits, interviews with labor and observation facilities for employees). In the afternoon after the lunch break, Oktovianus & Taufik Margani conducted field visits to observe the locations that have been identified as HCV area, to check the leasehold boundaries and to interview the head of village and the community leaders. Other audit team also continued its visits. Januari 21, 2013. The auditor team is presented the results of audit (closing meeting) at Randy Estate The assessment program please find Appendix 2

2.3.3 Locations of Assessment

S1 Dated January 22, 2013

Location 1 - Selabak Estate, Division III, Block F20: interviews of harvester related to the compliance of Personal

Protective Equipment (PPE) and health and accident insurance. The Company has completed the PPE and harvesting

tools according to the needs of employees.

Location 2 - Selabak Estate, Division III, Block F14: Observations relating to the implementation of monitoring erosion

stakes. Stakes erosion is in good condition and well maintained.

Location 3 - Selabak Estate, Division III, Block F17: Observations related to the implementation of effluent land application and monitoring wells condition. Monitoring wells are in good condition, no spillage of flowing waste into waterways. Location 4 - Selabak Estate, Division III: Observations related to the implementation of storage of hazardous materials and toxic (B3), Hazardous and Toxic (B3), employee housing, condition of fire extinguishers and First Aid Emergency tools, hazardous materials warehouse has been equipped with the Safety Data Sheet, PPE, etc. Hazardous materials warehouse has been given permission and symbols. Location 5 - Selabak Estate, Division III, Block E19: Observations related to the implementation of the protection of areas


ASSESSMENT REPORT


identified as High Conservation Value (HCV). There have been tagging boundaries in the riparian and reservoirs, and there is prohibition boards related to activities that are not allowed to do in the riparian and reservoirs. Location 6 - Block I 33 Sangkoh Estate: Observation and interview with sprayers team and the supervisor related to the company's policy on the application of chemicals in the riparian, periodic medical examinations, and the adequacy of PPE usage, spraying techniques training, OHS Training, First Aid Emergency training, mechanisms gender-specific complaints, employee benefits and remuneration Location 7 - Block E36 Sangkoh Estate: Observations and interviews with permanent personnel associated with the criteria harvesters ripe harvest, harvesting techniques, the use of PPE and other employee benefits and housing facilities are available Location 8 - Komplek Sangkoh housing Estate: Conducting observations and interviews with residents in cottage 2 related to the facilities provided by the company as employee housing, places of worship (mosques), Child Care Center, clean water and household waste management. Location 9 Klinik Unit Sangkoh Estate: Conductiong oberservation of environmental clinic (examination room, ward room, and drugstore). Interview with paramedics related to the periodic health checks, accident, health, and medical waste management. Location 10 - Location Warehouse Oli, Agrochemical and Fertilizer Sangkoh Estate: Implementation of OHS, such as: the availability of hazardous and flammable material symbols, MSDS, Work Instructions of taking agrochemical, oil and fertilizer, PPE, Fire Extinguisher and hazardous material landfill of Sangkoh Estate:

Location 11 Fire Fighting Post of Sangkoh estate: Inspection of fire fighting facilities and infrastructure, including; tank fire engines and tractors furnished with the pumps, hoses, nozzles.

Location 12 Hazardous material Landfill of Sangkoh Estate. Implementation of OHS; such as availability of OHS symbols, flowcharts of spill, PPE and fire extinguisher. Location 13 - Palm Oil Processing Factory,Selabak Factory. Field observations related to plant operations from receipt fruit (weight bridge), grading FFB in loading ramp, processing mechanisms. Location 14 - Palm Oil Processing Factory, Selabak Factory. Reviewing the implementation of OHSAS at processing stations, such as Sterilizer, Thresher, Digester, Nut Cracker, Engine Room, Boiler. Location 15-Temporary hazardous waste storage in Selabak POM . Reviewing the availability of hazardous waste remaining in storage locations, verifying the balance of waste, availability of oil trap observations, etc Location 16 - Division 3 Block C26 - 27, Rawa Gelam: Observation of processing in HCV area Location 17 Stakes 4 Sangkoh Estate: Checking the boundaries pole. Location 18 - Division III Block B28 - 29 Sangkoh Estate: Observation of processing in HCV

Location 19 - Manunggal Lama Village: Interview with the village head about the program CD / CSR and the social interaction between the company and the locals.

Location 20 - Bakau Village: Interview with Community Leader about the program of CD / CSR and the social interaction between the company and the locals.

2.4 Stakeholder Consultation and List of Stakeholders Contacted

2.4.1 Summary of stakeholder consultation process.

Summary of stakeholder consultation process Consultation of stakeholders for PT Swadaya Andika was held by public consultation meeting with internal stakeholders by interviews and local stakeholders conducted by visits to villages and interviews with local peoples. Numbers of input from stakeholders were clarified by PT Swadaya Andika. See 3.6

2.4.2 List of stakeholder contacted

Please find appendix 3

2.5 Determining Next Visiting

The next visit (S-2) will be determined one year after this S-1 (January 2014).

3.0. ASSESSMENT RESULTS


ASSESSMENT REPORT


MUTUAGUNG LESTARI has conducted a Surveillance-1 assessment of PT Swadaya Andika Selabak POM, Sime

Darby Operation consisting of 1 (one) mill and 4 (four) oil palm estates. MUTUAGUNG LESTARI found that PT Swadaya

Andika comply with the requirements of RSPO Principles & Criteria and National Interpretation, RSPO Principles and

Criteria (P&C) for Sustainable Palm Oil Production, Republic of Indonesia - RSPO INA-NIWG, May 2008 and for

Scheme Smallholders, October 2009.

Therefore MUTUAGUNG LESTARI recommends a certificate of compliance is maintained.

3.1. Summary of the RSPO Certification

Ref Std.

VERIFICATION RESULT of MUTU-Certification

PRINCIPLE #1 COMMITMENT TO TRANSPARENCY

1.1 Plantation and Palm Oil Factory have to give adequate information for stakeholders in appropriate language and forms, to ensure the effective participation of stakeholders in decision-making.

Log External Communications Year 2012 is available in each estate. The document contains information about all incoming mail from external parties and the following response. Based on the Log External Communications year 2012 there are no information requests from external but it has a support request. Based on SOP of Answering Information Request (056/SAA-JPI/12) dated on June 15, 2012 said that the shelf life of request and response information record is 5 years.

Complied

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.

SOP of Answering Information Request (056/SAA-JPI/12) dated June 15, 2012 is available. These procedures have been grouped on the list of documents that can be accessed or provided and the information can not be given to the public. The information can be accessed by the public (stakeholders) are:

1. Broad of Land Clearing 2. Evidence of Labour Social Assurance payments 3. Evidence Employee Treatment payments 4. General Facilities Employees 5. Pests and Diseases Offensive Data 6. Lightweight Vehicle and Heavy Equipment Data 7. Supporting Machines Data 8. Conducted CSR Data 9. Bridge Data 10. Length Of The Road Data 11. Work Building Data 12. General Building Data 13. School Building Data 14. Types of fertilizers used 15. Agrochemical types used 16. SKU Employee Data 17. Students Data

Information / documents that are not accessible to the public are: 1. Budget and finance / Financial 2. Legal and Corporate License 3. Best Paractice Operational Note 4. Medical and Health Screening (Early, Periodic and Special) 5. Tender, Purchasing and Sales

Special information request of the concerned parties should be guided by the Code of Conduct Procedures (440/HRM-


ASSESSMENT REPORT


COC/07) and Sustainable Plantation Management Guidelines Procedures (724/TQEM-SPMS/09) and does not against the laws and regulations

Complied

PRINCIPLE #2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

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

There is evidence of regulations compliance of the company in the form of updated regulations list (up to date) on December 28, 2012 and the following evaluation. These evaluations illustrate compliance with any referred regulations and comes with proof of compliance. example:

1. The company has fulfilled the Law No. 5 year 1960 with evidence of Certificate No. HGU. 15 In 1999 (9370.6 ha), no. 32 of 2002 (507.579 ha) & No.. 33 in 2002 (4.83 Ha). Total 10361.179 Ha.

2. Reporting Environmental Management Plan and Environmental Monitoring Plan related to PP 27 year 1999 every six months, has been done despite the delay. Company Parties conduct intensive efforts to better internal communication done on time. Evidence of delivery of Environmental Management Plan and Environmental Monitoring Plan report can be demonstrated by the organization to the Plantation Service Department (PSD) section in Bajarbaru.

3. The Compliance of riparian wide in the field is more than 50 meters in accordance with the regulation No. 41 year 1999.

The Compliance of regulation No. 14 year 2008 concerning with Freedom of Information have been made with the SOP of Code of Conduct, SOP of Answering Request Information & Communications availability.

Complied

2.2 The right to use the land can be demonstrated, and is not legitimately contested by local communities with demonstrable rights Tenure and land usage by PT. Swadaya Andika demonstrated through several documents, such as:

1. The release of forest land by decree of the Minister of Forestry No. 583/Kpts-II/1994 about the release of most of the

forest area of the forest and surrounding Manunggal River located in District II Kotabaru, provincial-level regions of

South Kalimantan covered 10 252 (ten thousand two hundred fifty two) hectares for the cultivation of palm oil

plantation in the name of PT. Swadaya Andhika dated on December 20, 1994.

2. Plantation Business Permit Revision in accordance with Decree of Kotabaru Regent No. 357 year 2006 on

Plantation Business Permit Re-registration PT Swadaya Andika in Kotabaru District dated on March 25, 2006.

3. Plantation Business Permit Revision in accordance with Decree of Kotabaru Regent No. 188.45/387/KUM/2009

regarding to the Approval of Re-registration of Plantation Business Permit of PT Swadaya Andika in Kotabaru District

dated on December 7, 2009 "Business License applies to an area of 10424.139 ha and 1 POM unit with a capacity

of 60 tons FFB / hour"

4. Land Use Title there are 3 Land Use Title ie;

Land Use Title certificates No. 15 year 1997 dated on December 1, 1997 in accordance with the Decree of the

State Minister of Agrarian / Head of National Land Agency (BPN) No.131/HGU/BPN/1997 dated on November 28,

1997 with an area of 93.706 million m2 is valid until 22 November 2032.

Land Use Title certificates No.32 year 2002 dated March 26, 2002 in accordance with Decree of Head of National

Land Agency of Kotabaru District No. 7/HGU/BPN/2002 dated March 7, 2002 covering an area of 507.579 ha is

valid until September 24, 2037.

Land Use Title certificates No. 33 Year 2002 dated on March 26, 2002 in accordance with Decree of Head of

National Land Agency of Kotabaru District. No. 7/HGU/BPN/2002 dated on March 7, 2002 covering an area of 483

hectares is valid until September 24, 2037.

5. Land Use Title compensation process, in this case taken from documents sampling of Occupational and Land Plant

Growing Compensation Payment Report in the Area of Oil Palm Plantations of PT Swadaya Andika II (Randi Estate)

Manunggul Lama village / Sungai Durian Sub District of 10 ha and Bakau village, Pamukan Utara Sub Disctrict


ASSESSMENT REPORT


covering area of 123, 25 hectares are equipped with statement letter of Waiver of land known by the village and sub

district officials, the evidence of compensation (receipts) and the indemnity minutes.

There is also a new development in the form of a letter Number 104/SAA/PSD-Bjb/XI/2012 dated on November 13, 2012 on the application of Land Use Title on behalf of PT. Swadaya Andika sent to the National Land Agency as the follow-up of completeness requirements that must be met for the issuance of Land Use Title Certificate covering area of 62.93 ha in Randi Estate is on process of completion in National Land Agency of South Kalimantan Office.

Complied

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.

Based on information from management, the area identification report document is High Conservation Value (HCV), based on description locals/ locals leader around the plantation, it is known that there is no areal around plantations are taken by indigenous people and there are no indigenous people as well. There is also a letter from the National Land Agency of Kotabaru District No. 000/02/KP-10 dated on 2 September, 2010 on the Status of Indigenous Rights / Tanah Ulayat states that: 1. Status of land, especially in Kotabaru District, has never have the regulations governing the status of indigenous

rights / Tanah Ulayat until now. All Land Use Title issued by National Land Agency and during its right processing the status of Indigenous Rights Lands / Tanah Ulayat are not found especially for Kotabaru District.

Complied

PRINCIPLE #3 Commitment to long-term economic and financial viability

3.1 There is an implemented management plan that aims to achieve long term economic and financial viability.

The company owns Budget Presentation of year 2013/2014 and Projection of year 2013/2014; 2014/2015 and 2015/2016 which contains the plan (1) Areal Statement (2) New Planting status, (3) Nursery Status, (4) average production projection and production costs in Rp/ kg, and the Size of the harvest. Replanting plans are available as well: over 15 years beginning in the period 2013/2014.

Estate Sangkoh: the period of 2013/2014 = 170.02 Ha

Estate Randi: the period of 2014/2015 = 49.27 Ha

Estate Selabak: the period of 2014/2015 = 113 Ha

Estate Lanting: Period 2015/2016 = 212 Ha

Compled

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

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

Minamas Plantation Indonesia Standard Operation Procedure is available, agronomy Manusl Reference with Policy No.: 110/EST-ARM/08, endorsed by the CEO on August 19, 2008. The procedure consists of: plant material (Planting material), Nursery technique, replanting, Land Preparation, planting density, maturity age, field upkeep, manuring, Canopy management, water management in coastal soil / peat, ablationof Ripeness standard), harvesting interval, Traceability, loose fruit collection, and Plant protection. Inspection or monitoring activities implemented by the operations of the internal audit activity at least 2 times a year (SOP Internal Audit No. 421/HRM-DIQ/08 dated 01.02.2009), which includes oversight of all activities of mills and plants, for example: There is an internal audit report of the last plantation adviser held on September 20-22, 2012 Each conclution worksheet of period 1 February to september 2012 is available. There are reports of the last advisory mill conducted on September 25-26,2012 Record of operations result contained in the Plant Unit Report conducted periodically every 1 month. Plant Unit Report is a compilation of reports of each operational division activities compiled by Estate Manager. The information contained in the report is a unit plant: a brief review; Areal statement; organizational structure, personnel and residents; Housing,


ASSESSMENT REPORT


buildings, facilities and infrastructure; rainfall; FFB Production; Mature Plants; nurseries; Traction / transport; common costs; production cost; Stock; Capital; Socio-Economic and Security of employees; Fare and additional information in the form of maps. As for the activities of mill, monthly report which includes production and delivery, quality analysis include the quality of production, loss of production, FFB quality analysis received, copy of empty fruit bunch (EFB) aplication, losses and applications, and production cost are available.

Complied

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

Available: 1. Record of soil analysis The results of soil analysis in 2012 in selabak estate conducted by the Institution of environmental research center of Lambung Mangkurat University. Based on the research with sample code MM/EF/12/SLE/PK-1 resulting: soil texture (31.76% sand; dust 27, 405; Liat 40, 84% and clay texture classes), elements of C: 1, 84%, N; 0.34%, pH (H2O; KCl 6.19 and 3.51), 2. Record of Leaf Analysis Record of leaf analysis period of August 2011 is used as a material for determining fertilizer recommendations period 2012-2013. The results of the analysis showed the leaf content (%) Ash, N, P, K. Mg, CA and B (ppm). Recording sample of leaves analysis result of Sangkoh Estate is available, for example in Block E015 division 1with planting year 1997, LSU no SNE 101 implies: (%) Ash 9.83, N 2.80, P 0.160, K 0.944. 0.325 Mg, Ca and B 17.8 0.650 ppm. Selabak Estate e.g. D01 block division 1 planting year 1994, LSU no SLE 101 implies: (%) Ash 10.28, N 2.45, P 0.180, K 1.081. 0.290 Mg, Ca and B 14.6 0.583 ppm. Fertilizer recommendations (type and dose of fertilizer, organic and inorganic fertilizers) applied in each Estate, based on the results of soil analysis (including soil type), leaf analysis, age of the plant and the climate (rainfall). There are also the activities records to maintain and improve fertility through fertilization, empty fruit bunch applications and effluent applications. For example: Records of JJK organic fertilizer result based on the results of document review in Selabak estate until December 2012 has been realized as much as 3, 535 tons from 8080 tons budget for the period of July 2012 to June 2013 and monitoring of JJK fertilization realization result has been available which has been realized for 312,621 kg until December. Aplication Records of POME Application Monitoring which in December 2012 has been applied to volume 11.375 meter cubic , the blocks of F013, F012, G011 and G012 and based on permits issued by the Kotabaru Regent with the district's decision No: 188.45/373/KUM/2009 Record of inorganic fertilizer analysis result, based on documents review until December 2012 is as follows (in kg)

Fertilizer Realization Plan

NK Blend 1.906,613 2,286,249

RP - 634,839

Kies - 555243

HGFB 11,539 17403

Total 1108152 3493786

There are also objectives, targets and action plans to ensure that the company's plan of inorganic fertilization is achieved as recommended and Its targets are to be inorganic fertilizer uniformly performed on all palm oil plantations, in time and appropriate dosage.

Complied

4.3 Practices minimize and control erosion and degradation of soils. Soil survey final report is available and land suitability classes evaluation conducted by the Research Department of Minamas

Plantation for:


ASSESSMENT REPORT


Lanting Plantation (3249 ha), based on the results of a survey conducted on area of 2518 Ha is known that:

- S3 (less fit): an area of 1312 ha (52.1%) potential to S2 with a few treatments.

- N1 (not appropriate): an area of 547 ha (21.7%) potential to S2 with a few treatments.

- N1 (not appropriate): an area of 658 ha (26.2%) potential to S2 with some treatments such as water management.

Randi Plantation (3090 ha), based on the results of a survey conducted on an area of 2512 Ha is known that:

- S3 (less fit): area of 36 ha (1.4%) potential to S2 with a few treatments.



Selabak Plantation (3845 ha), based on the results of a survey conducted on an area of 3212 Ha is known that:

- S3 (less fit): an area of 939 ha (29.2%) potential to S2 with a few treatments.


Sangkoh Plantation (3443 ha), based on the results of a survey conducted on an area of 2516 Ha is known that:



Strategy pursued for planting on particular slope is by making rorak (silpit), u-shape, and the continued terrace. The Company

has also conducted monitoring erosion by making erosion poles. 12 erosion poles have been available in PT SAA.

Monitoring road maintenance is available in each Estate, for example:

Selabak Estate: in December 2012, Budget: 19 081 m and Actual: 12 370 m

Selangkoh Estate. in December 2012, Budget: 15 290 m and Actual: 20 930 m

Based on the document of soil survey review and evaluation of suitability of soil classes in PT SAA, there is no peat in the

work area of the company.

PT SAA has made the management of marginal land with some treatments such as:

Low Area by making water management e.g. Lanting Estate

Undulating Areas by making silt pit, terrace, and individual terace, for example in Selabak Estate, Field F013, Block F20 (Undulating Areas) investment strategy using terrace.

Complied

4.4 Practices maintain the quality and availability of surface and ground water. The Company has conducted water flows protection such as:

Tree Planting Activities in the HVC area

Making signboard dan riparian boundaries pole in Yellow.

Not allowing spraying and fertilizing activity in buffer zone.

Socialization regarding the ban on spraying fertilizing in buffer zone.

Based on the field visit in pond E19 (NKT 4,1) there is a signboard regarding to the buffer zone and also forbidden board to

not allowing to fish, influencing water, menyetrum ikan and cutting down the trees in the pond/river bank. There are also

boundaries of the area which may not been aplicated in the form of yellow paint in pokok sawit.

The company has conducted surface water quality monitoring in one river (S. Tandilang) in its upstream and downstream part

and 12 reservoirs (4 in SLE, 2 in LNE, 3 in RDE, 1 in SLF, 2 in SNE). The results of the quality monitoring of surface water

(rivers and reservoirs) have been evaluated by the company.

The company also has monitored every month, for example te result of the monitoring on May 2012 was BOD = 420 mg / l

and pH = 7.28.

The monitoring of water consumption for domestic operations data is available , such as the use of water in December 2012 in Salabak Plant was 22,310 m3 consisting of 11,615.94 m3 and the use for domestic purpose was 10,694.06 m3.

Complied

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

Integrated Pest Management Program (IPM) of the company include: Program budget and the real planting of beneficial plants of Sangkoh Estate for Turnera Subulata, Casia cobanensis


ASSESSMENT REPORT


and Antigonon leptosus planting.

Monitoring Pest Rats attack carried out periodically every month

Monitoring the nettle caterpillars attack is carried out every month.

Monitoring owl monitor

Controling of bag worms and nettle caterpillars by monitoring and supervising attack signs, and the development of beneficial plants for natural leaves pest control to encourage the population of natural enemies (predators and parasites) of caterpillars and nettle caterpillars and bag worms.

IPM program monitoring conducted by the company include:

Monitoring the planting beneficial plants which in Selabak Estate investment has been realized as much as 3988 meters for the period 2012-2013 of all the 11.223 meter plan

Owl developments monitoring is available which are based on observations in December there were 14 olws homes in Selabak Estate and 8 of the are active (there are puppies, bird droppings, dead mice, etc.)

The nettle caterpillars attack monitoring record is available where in Sangkoh Estate until the month of December 2012 there were no nettle caterpillars attack, but in the Selabak estate there is nettle caterpillars attack in November October in 2012 in area of 68 hectares with 15 caterpillars /tail sheath and is controlled with Decis with dose / ha 0.25 liters / ha.

Termite attack monitoring is available which does not reveal any signs of termite attack until December 2012

Ganoderma attack monitoring is available which does not reveal any signs of ganoderma attack until December 2012.

Recordings of socialization and training of the pulsfog usage for fogging team on March 22, 2012 has been available (absences and documentation list record is available) The Company regularly monitors the use of pesticides that are reported each month, for example the monthly usage of December 2012:

Glyphosat. Use 500.30 769 liters with broad application and dose per ha ha 0.65 l / ha of active ingredient / ha, 0.195 liters / ha

Methyl metsulfuron, use of 0.98 kg with a wide range of applications 8 ha and 0.1225 ha dose per kg / ha of active ingredient per hectare 0.024 kg / ha

Fluoroxypir. Use of 73.64 liters, 490 ha area of application. Dose per ha 0.150 liters / ha, 0.045 ha of active ingredient per liter / ha

Triclophyr: Use of 219.70 liters, 490 ha area of application. Dose per ha 0.44 ltr / ha, 0.984 ha of active ingredient

Complied

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 categorized as World Health Organization Type 1A or 1B, or are listed by the Stockholm or Rotterdam Conventions, growers are actively seeking to identify alternatives, and this is documented.

Types of pesticides used by the company are:

Trade Mark Active Ingredients

Sifat Target Registration Number

Lentrek Klorpirifos Systemic Gulma daun lebar RI.798/4-99/T

Kenlon Triklopril butoksida, etil ester

Selective Gulma umum RI. 01030120062433

Metafuron Metyl metsulfuron Selective Broad and Narrow Leaf Weeds

RI. 1224/5-2006/T

Decis Deltametrin Contacs Pengendalian hama RI.387/11-2002/T

Prima up Isoprolamina glifosat

Contac Broad and Narrow Leaf Weeds

RI.1779/11.2007/T


ASSESSMENT REPORT


Starane Fluoroxypir systemic Broad Leaf Weeds RI. 854/7-2009/T

Metaprima Metyl metsulfuron Selective Broad and Narrow Leaf Weeds

RI. 1897/8-2008/T

There are material usage monitoring period 2012-2013 are reported each month. For example, the usage of December 2012:

Glyphosat. Use 500.30 769 liters with broad application and dose per ha ha 0.65 l / ha of active ingredient / ha, 0.195 liters / ha

Methyl metsulfuron, use of 0.98 kg with a wide range of applications 8 ha and 0.1225 ha dose per kg / ha of active ingredient per hectare 0.024 kg / ha

Fluoroxypir. Use of 73.64 liters, 490 ha Broad application. Dose per ha 0.150 liters / ha of active ingredient per hectare 0.045 ltr / h

Chemicals MSDS has been available used in each estate explaining Trademarks, active ingredient, active ingredients contains, LD - 50, Nature of pesticides and pest targets (please also reffer to 4.6.1 above). MSDS is also available in Indonesian as a reference for workers related to the use, storage, and first aid emergency when exposed to the body. Based on the results of the documents verification it is known that the use of pesticide contains dose, target is in conformity with usage instruction of the product. Doses used are still below recommended doses for example for the use of Methyl Metsulfuron companies use a dose of 122 grams / ha which is still below the recommended limit of 250 g / ha for the purpose of broad leaf weeds.

Complied

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

No significant changes in policies related occupational health and safety program for PT. SAA. The OHS implementation form of the policy implemented by creating and delivering Guiding Committee Of Occupational Safety & Health (P2K3) reports to the Labour and Transmigration Agency periodically every 3 months. The report presents the data as follows: Number of Labor, Structure of Guiding Committee Of Occupational Safety & Health (P2K3), Guiding Committee Of Occupational Safety & Health (P2K3) Recommendations, Accident Reports, Cleanliness Inspection Report, Inspection Report Information, Work Environment Chemistry, Harvest PPE Inspection, Periodic Health Examination Records.

Person In Charge of OHS programs in each management unit include: Sangkoh Estate (Mr. Firlan Edi), Selabak Estate (Mr. Nice Tri Ferifianto), POM Selabak (Mr. Saut DH Siahaan). The last Guiding Committee Of Occupational Safety & Health (P2K3) meeting held on November 27, 2012 which was attended by 12 participants (Sangkoh Estate), November 22, 2012 which was attended by 16 participants (Selabak Estate), December 3, 2012 was attended by 7 people (POM Selabak). Agenda of the meeting focused on the use of PPE Discipline, Evaluation Accident and dissemination / reminder of the importance of safety for temporary workers, suppliers, contractors and other employees.

Concern and responsibility of all employees by the company related to the OHSAS done by: providing social security for workers who are paid to the relevant institutions and in time, as well as health checks for employees. From the results of a medical examination in December 2012 (Sangkoh Estate, Selabak Estate, MCC Selabak), all employees of PT. SAA did not identified any serious health problems and could still be addressed through therapy and medication / vitamins.

Hazards Identification, Risk Assessment & Risk Control (HIRAC) applicable to plant and mint, no significant change. Risk Analysis Record is int the form Work Accident Monitoring form in each unit of work, including the results of the analysis for each individual case is very well presented. During a visit to the factory, it shows that the signs and boards such as informative and sufficient HIRAC board to control workplace risks that may occur. Meanwhile, obedience every worker in using Personal Protective Equipment has been fairly well implemented.

Records related to the OHS training programs that have been conducted such as: 1) Sangkoh Estate: P2K3 training (November 27, 2012), training materials include: Safety Briefing, Evaluation and First Aid Emergency OHS Training. Speakers: dr. Irwan Kertajaya, attended by: 15 employees. 2) POM Selabak: Operator Loading Ramp Training, Stews & Engine Room (June 12, 2012). Attended by 9 participants, of which five operators and one Process Supervisor. While examples of OHS Training Program 2013 in Sangkoh Estate, such as: Monthly Meeting P2K3 (monthly); Firefighter Training (January & July 2013); Harvest Training (February and August 2013); FFB Transport Training (March & September 2013); fertilizer Training (April & October 2013); Team Spray Training (May & November 2013); Emergency Training (June and December 2013); MSDS Training (July & December 2013).


ASSESSMENT REPORT


Emergency response procedures have not changed in the document, but there are significant development regarding the implementation of training to workers. Evacuation routes and lay-out distribution extinguisher at each work station either in the garden or in the plant looks very adequate.

Completeness of emergency response equipment and safety available is quite good and is maintained, the equipment includes: extinguisher, Hydrant, First Aid Emergency Box, Water Tank and PPE. Example: Evidence of PPE Helmet handover (July 25 2012) to 9 harvest employees; 3 employees of FFB, 1 supervisor. Workers who have been trained OHS program are in suitable work place / location. The results of field observations POM: Mr. Eryadi (Opr. Grading), Mr.. Joseph (Opr. Sterilizer), Mr.. Ambran (Opr. Boiler). The number of occupational accidents in PT. SAA during the period from July to December in 2012 by 2 cases (Sangkoh Estate), 31 cases (Selabak Estate), 1 case (POM Selabak). Recordings are stored either in monthly Safety Officer, while the evaluation of the determination of root cause and corrective actions are listed in the form Accident Investigation Reports every event in the form of recommendations.

Complied

4.8 All staff, workers, smallholders and contractors are appropriately trained.

Program Training and Human Resources Development OF PT. SAA in 2013 are 16 items and 15 kinds of program participants (positions). This type of training such as: Problem Solving Training (July 2013), Leadership Training (May, November 2013). There are records related training programs that have been implemented OHS example: 1) Sangkoh Estate: Training P2K3 (27 November 2012), training materials include: Safety Briefing, Evaluation and Training First Aid Emergency OHS. Speakers: dr. Irwan Kertajaya, attended by: 15 employees. 2) POM Selabak: Operator Training Loading Ramp, Stews & Engine Room (June 12, 2012), attended by nine participants,such as: five operators and one Process Supervisior

Complied

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

5.1 Aspects of plantation and mill management, including replanting, that have environmental impacts are identified, and plans to negative impacts and promote the positive ones are made, implemented and monitored, to demonstrate continuous improvement. Environmental impact analysis documents available that describe:

Environmental Impact Assessment (EIA) approved as letter No. 008/ANDAL/BA/II/95 dated February 27, 1995 with

an area of 77 290 ha of the study area, consisting of 4 PT (Langgeng Mutiara Makmur, Laguna Mandiri, Paripurna

Swakarsa and Swadaya Andika). Broad of Swadaya Andika in the study was 11 250 ha. The capacity of each plant

in the EIA is 60 tons FFB / hour.

Management Plan and Environmental Monitoring Plan approved in accordance with Letter No. 049/RKL-

RPL/BA/III/95 dated on March 30, 1995.

There are also reports of implementation of the Environmental Management Plan (RKL) and Environmental Monitoring Plan

(RPL) Period of 2012 (January-June 2012) Plantations and Palm Oil Processing Factory of PT. Swadaya Andika which has

run all aspects of the EIA document. Available evidence of RKL and RPL delivery to BLHD South Kalimantan Provincial

Government on 30 - 10 - 2012 (Wet Stamp).

There are no changes in operations or activities of the company's acreage.

Complied

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

The results of the identification of protected species are described in the document Assessment for HCV PT Swadaya Andika for Selabak, Randi Plantation and Sangkoh Plantation. From the analysis made by the identification of HCV conducted by Indonesia Sustainable Palm Oil Foundation, there are areas are still forested and identified as HCV 1.3, located in the Randi Plantation Block L 26, K 17-19, L 20-21, and J 26. Selabak Plantation in block D 17-21, and Sangkoh Plantation in Block I, 28/29, I 30, I 37/37, G 29/30, F 30/31, D 32, E 32 and G 35/36.


ASSESSMENT REPORT


From the results of identification:

- Areas of HCV 1 (region have a high level of biodiversity in the broad location of Block L 26 2.69 ha block with an area of 29.03 K 17-19 ha, block L 20/21 wide 15.97 ha, with a block J26 16.04 ha, block K26 - 27 and L 27-L 28 with an area 89.24 ha. Blok K 27-29, A 28-29, and 29-30 with a Block L 75, K 70 and Block 23, J32 -J34 with a 26, 27 ha.

- HCV Area 2 (the landscape is important for ecological dynamics naturally) on the location of Block K17-19 with an area of 29.03 ha, Block L 20/21 wide 15.97 ha, Block J 26 with an area 16.04 ha, block of K 26-27 and L 27-L 28 with 89.24 ha wide. Block K 27-29, A 28-29, and 29-30 with a Block L 75, 70.

- Areas of HCV 3 (areas that have rare ecosystems) in Block K locations 27-29, A 28-29, L 29-30, K 32, J 32-34 covering 101, 97 ha.

- Areas of HCV 4 (region provide a natural environmental services) at the location block H9, H10, H 11, H 12, H 14, H 16, H 19-H 21, I 10 - I 24, J 23-26 square 92, 51 ha. Block H 06, H 07, I 07, J 08, J 09, K 16-K19, L 20 - L 25 area of 61.41 ha. Block J 21 of 3, 67, L 22 covering 0, 36 ha, H 21 covering 0, 15 and J9 covering 0, 22 ha with a total of 158, 32 ha.

- Area HCV 5 (Region which has an important function to fulfill the basic needs of local communities, the location of Block J 21 of 3, 67 ha, and 22 L of 2, 53 ha.

Protection measures implemented are: 1. Make management plan of HCV Program in PT Swadaya Andika 2. Creating Buffer Zone Management SOP (024/SAA-PBZ/10) and to ensure the application of chemicals in

riparian Inspection Work Instructions of Chemicals Non Application issued in the area of the buffer and also conducting the monitoring of the chemical examination in bufferzone a week after the spraying and 1 day after fertilizing, the event of application of fertilizers is carried out by collecting cleaning then applied on the principal outside the buffer zone. In addition, prior to the application of chemicals do safety briefings.

3. Make signboard and riparian boundaries in yellow paint. 4. Tree planting activities in the area of HCV. 5. Installation of warning signs / restrictions in HCV areas 6. The appointment of a special officer who has been assigned to carry out the monitoring and management of

HCV areas.

Complied

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

PT SAA has made identification of the sources of waste and pollution in POM and Estate. Waste generated is classified into

non hazardous waste and hazardous wastel.Hazardous wastel is managed in collaboration with a third party that has

obtained, while the non- hazardous waste is managed by considering the health and environmental aspects.

Available documentation of waste, such as:

Hazardous waste in landfill, set out in the balance of hazardous waste e.g. hazardous wastein data in October-

December 2012 as: used Accu: 315 Kg, 110 Kg stored in Hazardous Waste Landfill , 205 Kg sent to PT Maju Asri

Jaya Utama ( Manifest No: KQ 0.01283 million).

Application of Effluent (POME) contained in the Manager Report, for example POME application in December 2012

as 5.8000 in Block F013 Block F012 M3 and M3 as 3935.

Available:

The temporary storage of hazardous waste in accordance with the decree of Kotabaru Regent No. 188.45 / 126 /

KUM / 2011 Date on March 8, 2011 regarding to Temporary Storage of Hazardous Waste Permit and of PT Swadaya

Andika in Manunggal Lama Village, Sungai Durian sub District, Kotabaru District of South Kalimantan Province.

Types of waste allowed to be stored is used lubricating oil (used oil), used filter, used bulbs, rags, used batteries /

batteries, and used medical waste / used chemicals / pesticides packaging trace. The deadline for waste storage

can be stored for 180 days in condition of hazardous waste generated is less than 50 Kg / day.

Environment Agency Certificate of Kotabaru District No.660/439 / BLHD dated on November 26, 2012 which

describes the hazardous waste storage permit of Randi Estate, Selabak Estate, Lanting Estate and Sengkoh Estate

is no more than 15 days.

Monitoring of waste is available, such as:


ASSESSMENT REPORT


Monitoring of hazardous waste contained in the hazardous waste Balance Sheet.

Monitoring of POME Application contained in the Monthly Report Manager.

Monitoring the production and use of shell and fiber to fuel boilers at the Daily Production Report and Monthly

Report to GM.

Complied

5.4 Efficiency of energy use and use of renewable energy is maximized.

The average of actual fiber use and shell is over budget (141%). This is because the supply of fruit and FFB production is bigger than the planned budget, so boiler operations become longer. While the actual of turbine and generator usage average is efficient enough compared with the budget. This is influenced by the capacity of the turbine diesel power is maximum from 900 to 1.000 KWh, while the total load reaches 700-750 KWh.

Complied

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 guidelines or other regional best practice.

The company owns Agronomy Reference Manual. No. 110/EST-ARM/08, where section 4 Land Preparation clause 3.1 point (b) states that clearance shall be guided by the Directorate General of Plantations Decree No.. KB.110/SK/DJ BUN/05.95 dated May 30, 1995. Based on the interview with the plantation assistan it is known that if there is replanting activities carried out, the land clearing activities is accordance with applicable of SOP (Agronomy No. Reference Manual. 110/EST-ARM/08). The company has a fire fighting procedures (014/SAA-PKB/10) governing the control in case of fires. Fire Fighting done by making a firefighters team, identification of water sources, an inventory of fire-prone areas, making fire signs, building up a fire tower and monitoring of reporting. There is also a map of potential fire-prone areas such as Sangkoh Estate is identified that there are 8 fire prone area such as in block 136 Pringgan, G31-29 F31-29, Pringgan E32 to E42, D31 and C31, C17 and B22-21, B25-27 and B30-33 where the area is bordered with the community areas. While in Selabak estate identified fire-prone areas are F001, F002, E001, D001 and D012 where the area is bordered with the community areas. The company already has facilities and infrastructure of fire such as 1 unit of TOHATSU machine, 15 meters of input hose, 10 meter of output hose, 2 nozzle, 6 helmets, water tank, 6 hoes, 6 machetes, 2 unit of Robin machine. The company also periodically conducts routine monitoring or inspection of the fire extinguishers availability every month.

Complied

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

Identifing of sources of pollution and emissions of palm oil mills and plantation is documented in Inventory & Estimating GHG Emissions of GRK (No.: 700/PSQM-GRK-01/12) procedures. Sources of pollution and emissions from plantation operations, such as: changes in land cover, application of fertilizer, peat planting, the use of diesel fuel for generators and heavy equipment, FFB transport activity. While the emission sources at the plant include: the use of diesel fuel for the generator, the boiler combustion activity, use of electricity, the separation kernel process, disposal of effluent (POME) and transportation of CPO to bulking / refinery.

Monitoring of pollution and emissions quality done by testing done by the Company Hygiene & Occupational Health Center every 6 months.

Air Testing Results at Work

Report of PT. SAA Work Place Air Testing Result (Report of Company Hygiene & Occupational Health 2012), dated on April 3, 2012 with the following results:

No Location NO2 (g/Nm3)

SO2 (g/Nm3)

CO (g/Nm3)

TSP (g/Nm3)

Suhu (0C)

1 In Mills 14,65 3,02 51,81 116,93 31,9


ASSESSMENT REPORT


NAB 5.600 5.200 29.000 10.000

2 In Front of Mills 17,44 4,47 146,95 17,08 32,4

3 Housing 15,22 5,40 282,88 154,24 27,7

NAB 200 900 20.000 230

Acuan: PerGub KalSel No. 053 tahun 2007 tentang Baku Mutu Udara Ambien dan Baku Tingkat Kebisingan

Hasil Pengujian Emisi Sumber Tidak Bergerak PT. SAA, 4 April 2012.

No Stasiun NH3(mg/m3) Cl2(mg/m3) HCL (mg/m3)

HF (mg/m3)

NO2(mg/m3) SO2(mg/m3) Opas. (%)

Partikulat (mg/m3)

1 Cerobong Genset 1

0,01 0,01 0,01 0,02 4,43 0,12 20 266,32

2 Cerobong Genset 2

Sampling was not carried out 3 Cerobong Genset

3

NAB 0,5 10 5 10 1000 800 35 350

4 Cerobong Boiler No. 2

0,01 0,01 0,02 0,06 0,27 3,45 27 420,80

NAB 1 5 5 8 800 600 30 300

Acuan: PerGub KalSel No. 070 tahun 2008 tentang Baku Mutu Emisi Sumber Tidak Bergerak dan Ambang Batas Emisi Gas Buang Kendaraan Bermotor.

Report of Testing Intensity Noise PT. SAA (Report HIPERKES 2012), dated 3 April 2012 with the following results:

No Lokasi Intensitas (dBA) NAB (dBA) Keterangan

1 Depan Kantor 62,1 85 < NAB

2 St. Loading Ramp 71,6 85 < NAB

3 St. Press 92,0 85 > NAB

4 St. Engine Room 100,1 85 > NAB

5 St. Boiler 89,1 85 > NAB

Acuan: KepMenaKer No: Kep.51/MEN/1999 tentang Nilai Ambang Batas Faktor Fisika

The entire of parameters test is below the defined threshold quality standard. As for the testing period-2 was conducted on October 31, 2012 by the Hygiene & Occupational Health Center, according to an email dated on October 25, 2012. But until Surveillance audit in progress, test results are not available yet because Hygiene & Occupational Health Center has not sent it yet.

(5.6.3) The efforts made to reduce pollution, for example:

Source of impact: Diesel Genset 1, the efforts made: Monitoring & Measuring regularly; Preventive Maintenance; Training and Application of SOP. It has been implemented.

POM SLF has analysis / evaluation of related the quality standards parameters that is not appropriate, such as:

- Particulate Boiler Parameter No.2 is above the Environmental Quality Standard: 420, 80 mg/m3 (BML 300), thus the corrective actions include: Improvement of plate-plate that has been porous and settings in an efficiency of fuel consumption, Avoid the wet fuel.

- Noise Parameter: corrective action through the use of Ear Plug and Ear Muff in locations with noise levels> 85 dBA. While preventive action done by conducting audiometric testing for employees who work in high noise areas, once every 6 months.

Audiometric test testing plan will be conducted together with the emissions testing from Hygiene & Occupational Health Center in April and October 2013.

In the management of POME, daily monitoring of Effluent Ponds Checking report is available in weekly period, which consists of some monitoring parameters such as: levees leaks, water levelmto the levees, pH of waste pond, scum


ASSESSMENT REPORT


layer, pump applications condition, pump circulation Conditions , lighting, pool fence condition.

Monitoring of daily waste analysis include: pH, TA (Total Alkalinity), VFA (Volatile Fatty Acids), Normality, Volume H2SO4. Recapitulation POME application in 2011 and 2012.

Year 2011: Total number of 108 156 m3 volume applications Year 2012: Total number of 148 524 m3 volume applications

Complied

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

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 the continuous improvement. The impacts of the plantation and mill operations have been monitored. There are several documents, among others:

1. Document of Social Impact Assessment Report of PT SAA conducted by Yayasan Kelapa Sawit Berkelanjutan

Indonesia (YASBI) Indonesia Sustainable Palm Oil Foundation in 2010 that resulted in several recommendations include:

a. Placing people / division is responsible for communicating with stakeholders.

b. Creating SOP of external communication as a reference for public relations to communicate with stakeholders.

c. Making Division or special staff that handles CD / CSR.

2. CSR programs are more partifipatif and sustainable.

3. Environmental Impact Assessment (EIA) approved as letter No.008/ANDAL/BA/II/95 dated on February 27, 1995 with

the study area of 77 290 ha of, consisting of 4 PT (Langgeng Muara Makmur, Laguna Mandiri, Paripurna Swakarsa

and Swadaya Andika). The Broad of Swadaya Anndika in the study is 11 250 ha. The capacity of each plant in the

EIA document is 60 tons FFB / hour.

4. Environmental Management Plan / Environmental Monitoring Plan in accordance with Letter No. 049/RKL-RPL/BA/III/95

dated on March 30, 1995.

Collecting Social Impact Study Data conducted by collecting data from people around the plantation through questionnaires related socio-economic data. The results of the Social Impact Study has been followed and also described in the Implementation Environmental Management Plan / Environmental Monitoring Plan Report Period II (July-December 2012) PT. SAA regarding the Management and Monitoring Plan on Social Programs of PT Swadaya Andika.

Complied

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.

There are SOP No. 704-TQEM-ESH/10 dated on July 1, 2010 about communication adopted by the Manager of Randi Estate,

Manager of Selabak Estate, Manager of Lanting Estate, Manager of Sangkoh and POM of Selabak. The company had

socialized related to the SOP of communication conducted on January 20, 2013 held at Joglo Housing of Selabak staff.

Socialization was attended by 36 pople, consisting of company representatives of Manunggal Lama Village, Saka Doyan

Village, Lanting Village, Bakau Village, Sei Durian Village, Trombongsari Village, Rantau Buda Village, Harapan Baru Village,

and Kalian Village.

There are stakeholder list containing the names and addresses stakeholder information for the Village and su district level,

district, and Province. The names of the registered stakeholders include community leaders and villagers to the provincial

governments, agencies, and nongovernmental organizations.

Aspirations Record (Register incoming mail) and aspiration response (register mail out) are available both in the estate and in the POM. For example, application of greader heavy equipment and compactor machine from of Village Headof Manuggul Lama with corresponding letter No: 392 / DML / KSD / 9/2012 dated on September 10, 2012 and was taken on September 13, 2012 by Manager Estate of Selabak (Tri Bagus Ferifianto) by sending the heavy quipmemnet on September 16, 2012.

Complied


ASSESSMENT REPORT


6.3 There is a mutually agreed and documented system for dealing with complaints and grievances, which is implemented and accepted by all parties.

There are SOP of Complaint Handling (010/SAA-MPK/10) dated on July 1, 2010. Time of Answering the complaint is determined 14 days after the letter of complaint received by the operational unit and SOP of Conflict Handling No. 050/SAA-PKF/10 dated July 1, 2010. There are also examples of the recorded evidence in the form of implementation of compensation based on the inventory of land, made by consensus with the involvement of the parties (claimants, Muspika, village officials, Plantation Service Department and manager). Measurements are performed by the research and results in the form of compensation agreements and activity plans. Evidence of the land claims settlement record by the Bakau villagers in Randi Estate Plantation, such as: - Minutes of Muspika Meeting, Cooperative Credit Scheme, the Company Prominent Community Leader, dated on

February 9, 2011. - Meeting Attendance Muspika, Cooperative Credit Scheme, the Company Prominent Community Leader, dated on

February 9, 2011. - The photos Muspika meeting, Cooperative Credit Scheme, the Company Prominent Community Leader, dated on

February 9, 2011.

Complied

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.

Now available SOP of Identification and Land Compensation Standards (001/PSD-L & AS) dated on June 3, 2011 which includes information of computation phases and indemnity compensation in accordance with stadar issued by the Government of Kotabaru district. The process of compensation is also set in the procedures for handling conflict (050/SAA-PKF/10) dated on July 1, 2010 which the point 6 (Council) involving Plantation Manager, PSD, land owners, village officials and or Muspika and Research section for measurement . There are recorded evidence in the form of: a. The deal of compensation value b. Implementation payments plan c. Minutes of the Council. Sample the Occupational Land Acquisition Phase V Records included in Licensing of the palm oil area of PT. Sawadaya Andika Plantation, Randi Estate in Bakau Village, Pamukan Sub District. Recordings sample consist of:

- Minutes of the Council between 6 representatives of tenants, 2 representatives of PT. Swadaya Andika dated on January 4, 1998. The Minutes respectively signed; 6 representative of tenants, two representatives from the PT. SAA witnessed by Sub District Head of Pamukan Utara and Head of Bakau Village.

- Evidence of Waiver of land in the name of Gusti Mashud from Bakau Village, Pamukan Sub District for waiver of land area of 7 hectares. The agreement between the land owner and the company held on February 9, 1998.

There are also examples of the compensation payment implementation record to land owners in the Bakau Village. The evidence of payment is a payment receipt for land compensation Persil No. 15 area of 7 hectares in the Bakau Village, payment amount is Rp 1,225,000 dated on February 9, 1998. The footage is part of the Land Acquisition Report of Phase V The Occupational Licensing Included In The Area of Palm Oil Plantation of PT. Sawadaya Andika, Randi Estate in Bakau Village Pamukan Sub District.

Complied

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.

Based on the review of documents and interviews with employees obtained information that the employee received a base salary above the province minimum wage of South Kalimantan Rp 1,250,000 (South Kalimantan province minimum wage (UMP) in 2012 was 1,225,000 based on Deccree of South Kalimantan Governor No.188.44/0548/KUM/2011) and add the natura in the form of 15 kg of rice every month.


ASSESSMENT REPORT


The company has had an collective labour agreement between worker union of PT. Swadaya Andika Plantation in the period 2011 - 2013 which has approved based on decree of head of Labour and Transmigration Social Agency with letter No. 568/KEP-973/HIPK/PDF/PKB/VIII/Disosnakertrans/2011 about signing of Collective Labour Agreement between PT. Swadaya Andika with Worker union of the PT.Swadaya Andika on August 25, 2011. Facilities and infrastructures provided by the company to the employees in the Housing Inventory, Buildings, Facilities and Infrastructure Document containing matrix of Mess Group and Housing Type (General Mess, GM House, Manager House, Askep House, Assistant / Section Head / KTU House, G1 House, G2 house, G3 House); General Building Type (GM Office, Large Office, Division Office, Warehouse, Workshop, Meeting Hall, Building for kindergarten, Elementary School,Junior High School, vocational High School, Junior Hostel, clinic, library, Laboratory Building , Employee Center, Mosque, Infants Care, Church, Ration Shops, Post Guard, Tennis Courts. Based on the results of field visits known that most of the housing are still in semi-permanent condition but the company is conducting employee housing renewal program to be permanent housing. In the agreement / contract with the contractor, the company requires that contractors comply with applicable regulations. For example in the Work Agreement Letter between the company and PT. Catur Manunggal Jaya Abadi to lease heavy equipment with no SPK LNE / SPK-LKL / EXC SK40/XI/2012/036, in Article 8 paragraph 3, explained that in order to create and support the policies of Minamas Plantation management of occupational health and safety (OHS ) - zero accidents, labor contractors must comply with the safety standards of OHS, article 8, paragraph 4 stated that the contractor must follow the related and regulated labor laws. Besides that there is also a clause that if the contractor ignored the provisions of 8.3 and 8.4 above, it will be termination. The company has a Collective Labour Agreement between the worker union of the PT. Swadaya Andika the period 2011 - 2013 which was approved by Decree of the Head of Labour and Transmigration Social Agency of Kotabaru District No. 568/KEP-973/HIPK/PDF/PKB/VIII/Disosnakertrans/2011 about signing of Collective Labour Agreement between PT. Swadaya Andika with Worker Union of the PT.Swadaya Andika on August 25, 2011. Facilities and infrastructures provided by the company to the employees in the Inventory of Housing, Buildings, Facilities and Infrastructure group document containing matrix of Mess Group and Housing Type (General Mess, GM House, Manager House, Askep House, Assistant / Section Head / KTU House, G1 House, G2 house, G3 House); General Building Type (GM Office, Large Office, Division Office, Warehouse, Workshop, Meeting Hall, Building for kindergarten, Elementary School,Junior High School, vocational High School, Junior Hostel, clinic, library, Laboratory Building , Employee Center, Mosque, Infants Care, Church, Ration Shops, Post Guard, Tennis Courts Based on the results of field visits known that most of the housing are still in semi-permanent condition but the company is conducting employee housing renewal program to be permanent housing. In the agreement / contract with the contractor, the company requires that contractors comply with applicable regulations. For example in the Work Agreement Letter between the company and PT. Catur Manunggal Jaya Abadi to lease heavy equipment with no SPK LNE / SPK-LKL / EXC SK40/XI/2012/036, in Article 8 paragraph 3, explained that in order to create and support the policies of Minamas Plantation management of occupational health and safety (OHS ) - zero accidents, labor contractors must comply with the safety standards of OHS, article 8, paragraph 4 stated that the contractor must follow the related and regulated labor laws. Besides that there is also a clause that if the contractor ignored the provisions of 8.3 and 8.4 above, it will be termination.

Complied

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.

The company provides the freedom to employees to unionize. It is stated in the Collective Labour Agreement between the company and employees on Article 4 concerning the recognition of the rights of employers and unions. In the article explains that employers recognize the unions as legitimate organizations represent and act and on behalf of all workers who have working relationships with employers.


ASSESSMENT REPORT


There are a meeting record between the company and workers, such as:

Meetings between the companies with worker unions on the establishment of cooperative employees on July 11, 2012 at the offices of Randi estate

Meeting on the November 17, 2011 related to the socialization of Collective Labour Agreement and school transport issues.

A meeting on the January 5, 2012 related to the sosisalization of Worker Union and worker unionization procedures.

Complied

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 program. Children are not exposed to hazardous working conditions.

Company's policy on age requirements listed in the document of Plantation Management Guidelines issued by the Management of Minamas Plantation dated on August 27, 2010, policy number 724/08/2010. Related to Social Policy at point 6 explained tha Indonesia Plantation Upstream did not take advantage of underage labor (children). Associated with the implementation of these policies, the results of documents verification and interviews with some of the employees on the block E36, it is known that one of the requirements to apply as an employee is to be aged over 18 years.

Complied

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.

The company already has a SOP Management Guidelines published by the Sustainable Minamas Plantation Indonesia (Policy No.: 724/TQEM-SPMS/09) page 13, dated on August 27, 2010, include the company's policies on equal opportunities and treatment in employment contained at point 1 which states that: All Staff / Employees must be treated in a fair and equitable in matters relating to the hiring, advancement, conditions and job description, regardless of race, degree, ethnicity, gender, skin color, lack of imperfections (defects), sexual orientation, membership organizations, political views, religion and age. In the document of the Collective Labour Agreement described in Article 16 of the admission of workers, such as:

1. Admission prospective workers Selection: conducted by the employers in accordance with spesifcation and qualifications of required position.

2. General Requirements: An Indonesian citizen, 18 Years Minimum Age at the time of admission or married, healthy body and soul, meet the criteria or requirements of the position required, does not engage in illegal Company, is not in criminal proceedings, not related to the employment relationship with the other party , would be placed in any location.

3. Probation: 3 months, conducted appraisals performance of prospective employee during the trial period. Career development of each employee through performance appraisal. Employees, who are considered to have a strong track record, will be proposed to follow career development training to occupy higher positions and have rights according to the standard position. There are also records in order to evaluate the implementation of career advancement for some employees. Assessment form informs the criteria and assessment results (performance) achieved by each employee. Based on the Employee List Document of PT. Swasadaya Andika per December 2012, it is known that the background of the employees come from a variety of ethnic, religious and regional lines. Based on information from the management that the mechanism of workers recruitment is to give equal opportunity to all parties in accordance with the requirements set by the company with reference to the regulated labor laws in Indonesia.

Complied

6.9 Policy to prevent sexual harassment and all other forms of violence against women and to protect their reproductive rights is developed and applied.

The company's policy on the prevention of sexual harassment and violence described in the policy to establish a gender commission by Gender Policy, signed by the Executive Vice President (April 2008). This policy aims to ensure the rights, preventing sexual harassment and violence against women, workers, and communities. The company's policy on the protection of reproductive rights is available in the document of Collective Labour

PT. MUTUAGUNG LES

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