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RSPO Annual Surveillance 2

Assessment Report

PT. Brahma Binabakti

Brahma Binabakti Mill

Jambi, Indonesia

This annual surveillance assessment report has been prepared in accordance with RSPO requirements and the information included is the result of a full RSPO assessment of the Mills and supply base as included in the scope of the certificate.

Prepared by: Tuti Suryani Sirait (Lead Assessor)

PT. SUCOFINDO (Sucofindo International Certification Services – SICS) Graha Sucofindo B1 Floor,

Jl. Raya Pasar Minggu Kav. 34, Jakarta 12780 Indonesia Contact Person: TutiSuryaniSirait

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List of Contents Page

A Scope of the Certification Assessment ... 4

A.1. National Interpretation Used ... 4

A.2. Assessment Type (Estate and Mill) ... 4

A.3. Location Map ... 4

A.3.1. Location Address of the Mill and Approximate Tonnages Certified (CPO and PKO) ... 5

A.4. Description of Supply Base ... 5

A.4.1. General Description ... 5

A.4.2. Location of Supply Base ... 6

A.4.3. Statistic of Supply Base ... 6

A.5. Organizational Information and Contact Person ... 8

A.5.1 Audit Againstthe Rules for Partial Certification ... 9

A.6 Date Certificate Issued and Scope of Certificate ... 9

B. Assessment Process ... 10

B.1. Certification Body ... 10

B.2. Qualifications of the Assesment Team ... 11

B.2.1. Qualifications of the Lead Assessor and Assessment Team ... 11

B.3. Assesment Methodology ... 12

B.3.1. General Overview ... 12

B.4. Stakeholder Consultation ... 15

B.4.1. Summary of How Stakeholder Consultation was Organized ... 15

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C. Assessment Findings ... 19

C.1. Lead Assessor’s Summary and Recommendation for Certification ... 19

C.2. Summary of the Findings by Criteria ... 20

D. Certified Organization’s Acknowledgement of Internal Responsibility... 79

D.1. Formal Sign-Off the Assessment Findings ... 79

D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS ... 80

Appendix-1 List of Abbreviation ... 81

Appendix-2 Map ... 83

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A. Scope of the Certification Assessment

A. 1. National Interpretation Used

The management of the Palm Oil Mill(s) and associated suppliers of Fresh Fruit Bunches (FFB) were assessed for compliance against the RSPO Principle and Criteria 2013, RSPO Certification Systems 2007, and RSPO Suply Chain Certification Systems 2014.

A. 2. Assessment Type (Estate and Mill)

Certification Unit : PT. Brahma Binabakti – Brahma Binabakti Mill located at Desa Bukit Baling, Kecamatan Sekernan, Kabupaten Batang Hari – Jambi, INDONESIA

A.3. Location map

Please see Appendix-2 Map: 1. Map of Location, 2. Land area, 3. Topography and 4. HCV areas

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A. 3. 1. Location address of the mill and approximate tonnages certified (CPO and PK)

No Name of Mill

Location Address

GPS Reference

Annual Output

Actual (2016) Projected (2017)

CPO PK CPO PK

1. PT. Brahma Binabakti

Desa Suko Awin Jaya, Kecamatan Sekernan,

Kabupaten Muaro Jambi, Provinsi Jambi, Indonesia

Latitude: 01o20’52.81” S Longitude: 103o19’3.20” E

15,655 3,787 17,864 4,303

A.4. Description of Supply Base

A. 4. 1. General description

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A.4.3 Statistic of supply base (2016)

No Estate Name Planting Year

Age/Planting Year

Planted

Area FFB/Year CPO/Year Pk/Year

1 Brahma

Binabakti

1994 22 1,006.45 16,832 3,687 892

1995 21 1,161.10 21,122 4,627 1,119

1996 20 848.07 15,399 3,373 816

Plasma 1; 2. Plasma 2 and outside fresh fruit bunch 42,28%.

All estates are operated under one management of PT. Brahma Binabakti. All estates located in Jambi, Indonesia. PT. Brahma Binabakti is a member of RSPO and they are implementing a program to achieve RSPO Certified Palm Oil for all its production.

A. 4. 2. Location of the supply base

No. Estate Name Location

GPS

Latitude Longitude

1 Brahma Binabakti Estate

Desa Bukit Baling, Kecamatan Sekernan, Kabupaten Muaro Jambi, Provinsi Jambi, Indonesia

01o 21’ 38,04” S 103o 21’ 38,04” E

2 Plasma 1

Desa Bukit Baling, Kecamatan Sekernan, Kabupaten Muaro Jambi, Provinsi Jambi, Indonesia

01o 23’ 37,88” S 103o 24’ 19,96” E

3 Plasma 2

Desa Bukit Baling, Kecamatan Sekernan, Kabupaten Muaro Jambi, Provinsi Jambi, Indonesia

01o 27’ 05,31” S 103o 23’ 11,26” E

4 Plasma Pemayung

Desa Teluk Ketapang, Kecamatan Pemayung, Kabupaten Batang Hari, Provinsi Jambi, Indonesia

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1997 19 185.11 3,513 770 186

1998 18 397.14 7,155 1,567 379

2005 11 28,08 515 113 27

2006 10 279.21 2,901 635 154

2007 9 446.93 4,032 883 214

Total

4,352.09 71,469 15,655 3,787

2

Plasma 1

1996 20 2,474.00 37,706 7,586 1,924

1997 19 1,326.00 20,992 4,224 1,071

1998 18 478.00 8,958 1,802 457

Total 4,278 67,656 13,612 3,452

Plasma 2 2006 10 850.00 12,053 2,425 615

2007 9 998.00 12,032 2,421 614

Total 1,848.00 24,085 4,846 1,229

Plasma Pemayung

2010 6 57.42 352 71 18

2011 5 573.64 4,812 968 246

2012 4 10.38 - - -

Total 641.44 5,164 1,039 264

Total Plasma 6,767.44 96,905 19,497 4,945

Out growers 119,548 21,630 6,101

Total 119,548 21,630 6,101

Grand Total 287,922 56,782 14,833

ESTIMATED PRODUCTION 2017

No Estate Name Planting Year

Age/Planti ng Year

Planted Area

Estimated FFB/Year

Estimated CPO/Year

Estimated PK/Year

1 Brahma

Binabakti

1994 22 1,006.45 18,362 4,040 973

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A.5. Organizational Information and Contact Person

1. Company Name PT. Brahma Binabakti

2. PersonL Contact Tjandra Karya Hermanto

3. Vice Management Rudy Prasetya

4. Company Address Jl. Sultan Thaha no. 4 Pasar Jambi, kota Jambi

1996 20 848.07 18,091 3,980 959

1997 19 185.11 4,059 893 215

1998 18 397.14 8,254 1,816 437

2005 11 28,08 555 122 29

2006 10 279.21 4,316 949 229

2007 9 446.93 5,411 1,191 287

Total

4,352.09 81,200 17,864 4,303

2

Plasma 1

1996 20 2,474.00 40,503 8,101 2,147

1997 19 1,326.00 22,594 4,519 1,197

1998 18 478.00 8,403 1,681 445

Total 4,278 71,500 14,301 3,789

Plasma 2 2006 10 850.00 14,634 2,927 776

2007 9 998.00 17,016 3,403 902

Total 1,848.00 31,650 6,330 1,678

Plasma Pemayung

2010 7 57.42 462 102 24

2011 6 573.64 5,655 1,244 300

2012 5 10.38 33 7 2

Total 641.44 6,150 1,353 326

Total Plasma 6,767.44 109,300 21,984 5,793

3 Outgrower 156,781 29,005 8,309

Total - 156,781 29,005 8,309

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36113

5. Company Status PMDN

6. Phone/Fax 021-57944939 / 021-57944745

7. E-mail rudy.prasetya@tap-agri.com

8. Website www.tap-agri.com

9. RSPO Membership Number 1-0147-13-000-00 A.5.1. Audit Against the Rules for Partial Certification

The team found that PT Brahma Bina Bhakti has its own identity/number of RSPO member. Actually the company is under Triputra Agro Persada holding but the holding itselt has its own number of RSPO member. Information gathered from RSPO representative of Indonesia (RILO) stated the company with its own identity/member should be assessed within the company only for partial certification scheme; therefore the Audit against the rules for partial certification is not applicable to Triputra Group but still applicable to the smallholders which supplied FFB to the PT.Braham Bina Bhakti.

There are Smallholders ie 1. Plasma 1; 2. Plasma 2.

During ASA 1 company does not have a detailed plan related to the proposed Certification Plasma 1, 2 and 3. When assurance to the KUD, Information was obtained that socialization / training is merely the best practices and has not related to the preparatory activities of Plasma Certification. This has been issued as Minor Nonconformity No. 31.

At the time of ASA 2 PT Brahma Binabakti has made a time-bound plan for plasma certification starting from 2018 to 2020. In 2017 there is already a socialization of the RSPO certification process to plasma 1. However, the time-bound plan is not certain to be completed within 3 years after PT. Brahma Binabakti is certified (issued certificate in 2015) so that the time-bound plan that has been made is inadequate. This has been issued as Major Nonconformity No. 12.

At the time of follow up audit of PT. Brahma Binabakti has made remedial actions to review and revise the time bound certification of PT Brahma Binabakti plasma so that all plasma will be certified in 2018.

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A.6. Date Certificate Issued and Scope of Certificate

Name of Client PT Brahma Binabakti – Brahma Binabakti Mil

Client Number RSPO 00009

Certificate Number RSPO 00009

Certification Decision Date May, 26th 2015

Issued by PT SUCOFINDO, SBU SICS

Address Graha Sucofindo, SBU SICS. Jl Raya Pasar Minggu

Kav 34 Jakarta 13640

Telephone /Fax Tel.: +62-21-7983666 / Fax.: +62-21-7987015

Email tuti@sucofindo.co.id

Website www.sucofindo.co.id

Scope :

Mill Brahma Binabakti Mill

Estate Brahma Binabakti Estate

Projected mass balance CPO & PK CPO: 17,864 MT and PK : 4,303 MT Certification Registration Code SICS-00003

Type of Certification Single site

Certifier Triyan Aidilfitri

Signed

B. Assessment Process

B. 1. Certification Body

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recognized nationally and international.Quality Management System Certification by SUCOFINDO ICS has obtained accreditation from National Accreditation Committee (KAN-Indonesia).

Lead Auditors and Auditors of SUCOFINDO ICS are trained professionals in the field of international standards, auditing and management systems and are registered in the IRCA (International Register of Certified Auditors) and IEMA (Institute of Environmental Management & Assessment), UK. SUCOFINDO ICS certification process is supported by experts at PT. SUCOFINDO who understand the industry sectors and services in Indonesia.

SUCOFINDO ICS Operational is supported by a network of branch and representative offices of PT. SUCOFINDO spread in 45 cities across Indonesia.

The services provided by International Certification Services Sucofindo are:  Quality Management System Certification

 Environmental Management System  ISO 22000 :2005

 OHSAS 18000 Certification

 Hazard Analytical Critical and Control Point (HACCP) Certification  Good Manufacturing Practice (GMP) Audit

 Product Certification

 Sustainable Forest Management Certification  Products Organic Food Certification

 RSPO certification  ISPO Certification

 Certification of Integrated Management System Certification (SMT)  Training

B. 2. Qualifications of the Assessment Team

B. 2. 1. Qualifications of the Lead Assessor and Assessment Team Tuti Suryani Sirait (ATL) :

Graduated from Institute Agriculture in Bogor (IPB), 1991

She has more than 10 years audit experiences in auditing HACCP, GMP, ISO 9001:2008, ISO 22000:2005, ISPO and RSPO.

She has successfully completion training RSPO by Komisi RSPO, Jakarta, SCC Standard Training by David Ogg & Partner – Jakarta, ISPO Lead Auditor Training by Komisi ISPO, Jakarta, Lead Auditor Training of ISO 9000/19011 organized by SICS – Sucofindo, ISO 22000 : 2005 FSMS Auditor / Lead Auditor by Moody International, Singapore; Lead Assessor for Food Safety Management System (HACCP&GMP) by QAS Sydney, Australia and Social Lead Auditor Training (SA 8000) from Social International Audit (SIA), Turkey.

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Ronald E Butar-Butar (Auditor)

S1 graduated from Catholic University Faculty of Agriculture.

Work Experience (Best Practice Estates) in oil palm estates for 6 years. He has successfully completion Lead Auditor Training ISPO by Komisi ISPO. He has completion In House Training RSPO for 4 days.

Sarsongko Wachyutomo (Auditor)

Graduated from Gadjah Mada University, Yogyakarta.

He has successfully completion Lead Auditor Training ISPO by Komisi ISPO, Lead Auditor RSPO by Proforest and Diameter, Bogor, High Conservation Value (HCV) by HCV-NI and Auditor Training VLK by Pusdiklat Kehutanan, Bogor.

Agit Supriadi (Auditor)

Graduated from Institute Agriculture in Bogor.

He has successfully completion Lead Auditor Training ISPO by Komisi ISPO, Lead Auditor RSPO by Proforest and Diameter, Bogor.

Puji Sulistiono (Auditor):

He was graduated from Bogor Agricultural University (IPB) majoring in Agricultural Engineering (bachelor) and Civil/Environmental Engineering (master). Experienced as research assistant in several agricultural development project and as engineer in several water infrastructure project. He was completed several training such as IRCA Reg. Lead Auditor Training for ISO 14001 and ISO 9001, Occupational Health and Safety Expert Training (AK3 Umum) from Ministry of Manpower - RI, Lead Auditor Training in Indonesian Sustainable Palm Oil (ISPO) from Komisi ISPO, Ministry of Agriculture - RI.

Bagus Ferry (Observer)

He was graduated from Bogor Agricultural University (IPB). He has successfully completion Lead Auditor Training ISPO by Komisi ISPO.

B.3. Assessment Methodology

B. 3. 1. General Overview

The assessment was carrying out in conformity with the SBU SICS RSPO manual and procedures for auditor and certifier. The assessment was conducted by qualified auditors and referred to RSPO standard. Partial certification audit conducted during compliance audit to check compliance with Final RSPO Certification System for partial certification.

The opening and closing meeting audit was conducted at the office of estate and then continues

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audit.

SurveillanceAudit

Number of assessor participating: 5 auditors

Number of days spent for the assessment on site: 5 days

Total number of mandays used for the assessment on site: 25 days

Date/Time Functions / areas / Department / activities to be audited (include related requirements)

Auditor(s)

13 Mar 2017 Day 1st (Monday)

09.00 -10.25 Trip form Jakarta to Jambi Team

10.25-13.00 Trip from Jambi to sites Team

14.00-14.30 Opening Meeting All

14.30-17.00 Check completeness of previous NCR minor and observation from ASA 1

Team 17.00 End of audit day 2

14 Mar 2017 Day 2nd (Tuesday)

08:00-12.00 Check completeness of previous NCR minor and observation from ASA 1

12.00-14.00 Lunch Break 14.00-17.00 Document audit

 Compensation to legal and customary right (6.4)

 Legality regarding land (2.2.1, 2.2.2) & 1.2.1 regarding land title

 NPP (7.1-7.8)  FPIC (2.3)

SSW

 Worker welfare (6.5)  Anti-discrimination (6.8)  Schemed Smallholder (6.1.5)

TSS

 Best practice at estate (4.1)  Erosion control and peat (4.3)

 Land dispute and conflict (2.2.3, 2.2.4, 2.2.5, 2.2.6)  Development of local businesses (6.11)

RB

 Safety in pesticide (4.6.5 – 4.6.12)  Pest management (4.5

Pesticide (4.6.1 – 4.6.4)

AGT

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regarding EIA

POME for land application (4.4.3) 17.00 End of audit day 2

15 Mar 2017 Day 3rd (Wednesday])

07:30 Visit estate

Visit to harvesting, spraying and manuring TEAM Visit to HCV location

Visit to housing facility, warehouses, bathing facility, day care Visit to BPN Pole

Visit to land application 12:00-14.00 Break

14:00-16.00  Best practice mill (4.1)

 Practices maintain soil fertility (4.2)  Water management at estate (4.4.1)  Complaint handling 6.3

Business plan (3.1)

RB

 NKT/HCV (5.2) and 1.2.1 regarding HCV

Protection of water courses

and wetlands (4.4.2)

Partial Certification

SCCS RSPO

SSW

 FFB reception from small holder and local business (6.10)  Child labour (6.7)

 Social responsibility (6.1.1 – 6.1.4)

TSS

 Water efficiency at mill (4.4.4)  Water for worker (4.4.1)

 Occupational health and safety and legal requirement regarding heath and safety ( 4.7)

 Training 4.8

AGT

 Compliance to regulation (2.1)

Waste management (5.3) PS

16.00-17.00 Visit to mill Team

17.00 End of audit day 3

16 Mar 2017 Day 4th (Thursday)

08:00  Stakeholder consultation TEAM

12:00-14.00 Break

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 Human right (6.13)

Sexual harassment (6.9)

 Use of fire for preparing land or replanting (5.5)

 Continuous improvement (8.1) 

Trade Union (6.6)

RB

 Ethical conduct (1.3)

 Information provision (1.1, 1.2)  Consultation and

communication 6.2,

SSW

 Renewable energy (5.4) 

GHG mitigation (5.6)

PS  Water management at mill

(4.4.1)

AGT

17:00 End of audit day 4

17 Mar 2017 Day 5 (Friday)

08.00-12.00 Continuing pending matter TEAM

12.00-14.00 Break

14.00-15.00 Reporting TEAM

15:00 Closing meeting ALL

B. 4. Stakeholder Consultation

B. 4. 1. Summary of How Stakeholder Consultation was Organized

Stakeholders Consultation part 1 at District Office Pemayung, Thursday, 16 March 2017, 10.00-12.00

Issue Company Responses Assessor

Findings Kuak Village Head, Mr. Peri Yulman

1. Transport related demand during flood, so that the company provides transportation assistance so that workers can come to the workplace (site)

2. The handover of community land for plasma land so far has been running smoothly and safely

3. The company employs local workers,

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especially from the Village of Kuap Senanin Village Head , Mr. Muhammad 1. Villagers give up land voluntarily. Land

measurement submitted already using coordinate point (GPS)

2. Religious proposals submitted by the village are always responded by the company. Likewise with other proposals, the response given the company no longer one week after the proposal submitted. Communication of village members with the Company is running smoothly.

3. In the Pemayung subdistrict there is no indigenous tribe (Suku Anak Dalam – Jambi)

Conform

Lubuk Ruso Village Head, Mr. Syaukani Darma The company always gives CSR to the village. Hopefully this year the CRS given increased

Conform

Ola Rambahan Village Head, Mr. Rojali 1. The village proposal on road improvement

has been responded by the company. The company has improved access to village roads. Companies should be involved in village planning.

2. The company has socialized the animals and plants that are protected to the village community. Protected animals include Ungko, Deer, Tiger, various species of birds

Conform

Chief of Akso Dano KUD , Mr. Junaidi

1. Currently comparison between the area of own estate is 270 Ha and plasma is 413 Ha. The number of plasma farmers 202

In early 2017, a meeting between the company and KUD was established. The results of the meeting

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people.

2. The current payment method is done quarterly. KUD propose to the company to change the payment into every month.

discuss the monthly payments. The meeting was proven with the minutes. Is currently being formulated by the company.

Stakeholders Consultation part 2 at District Office Sekernan, Thursday, 16 March 2017, 15.00-17.00 PM

Issue Company Responses Assessor

Findings Representative Office of Manpower and Transmigration Kab. Muaro Jambi, Mr M. Amin NS 1. Currently wages in kab. Muara Jambi still

follows the provincial minimum wage (provincial minimum wage) because there is no wage council in the district. Muara jambi.

2. In 2016 there are no reports of work accidents in PT BBB.

3. The company undertakes a MOU with a third party related to the wholesale work to be reported to the Manpower Office

Conform

Representative Office of Estate Crops Kab. Muaro Jambi, Mr. Hendri Agustian 1. Disbun has conducted plantation grade

assessment on PT BBB. PT BBB got grade I.

2. The company has formed a fire care group 3. SPUP has been made, but can not be

given to the company

Conform

Representative of Environmental and Forestry Agencies

1. No public complaints related to environmental pollution.

2. The Company already reports regular environmental monitoring and

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management

Tanjut Lanjut Village Head, Mr.Edi Sugito 1. The company always responds to the

proposals submitted by the village. Response is usually by mail, short message or telephone.

2. No land conflicts

3. No environmental pollution

Conform

Ketua KUD

1. Companies provide tangkos, solid and ash for fertilizer in plasma plantations

2. Communication between the company and the board of KUD runs smoothly

3. The company repaired the ditch and culvert in the plasma plantation 2, so the flood condition in plasma 2 was reduced 4. Related planting plan KUD hope can still

cooperate with company. KUD proposes that the felling of oil palm trees should begin in stage.

5. Payments made by the company run smoothly

6. Technical guidance in preparation for RSPO certification to farmers has been done

7. With regard to the RSPO certification plan already undertaken:

A. Identification of land that already has a

certificate of 1200 Ha

B. Land of 2000 Ha of production forest status will be cultivated into Other Use

Areas (APL)

C. Best practices socialization has been

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done for example related to harvesting, fertilizer and maintenance activities

B. 5. Date of Nexts Surveillance Visit

One (1) year after date of 2017 surveillance audit

C. Assessment Findings

C. 1.

Lead Assessor’

s Summary and Recommendation for Certification

The Surveillance audit has been carried out through field visit to mill and estate using

RSPO principle and criteria 2013 and RSPO Supply Chain Certification Standard

2014

Audit Team has published the nonconformities, comprising 7 majors and 5

observations. The company has made the corrective actions to the respectives

nonconformities graded as 5 observations. All of the major findings have been closed.

The team will see the evidence of implementation on the next surveillance audit.

Since there are no major non conformities unsettled, the audit team found that PT.

Brahma Binabakti mill and its estates is still complying against RSPO P&C 2013 and

RSPO SCCS 2014. Therefore, certification can be continued to PT. Brahma Binabakti

(Mill and supply bases).

12 June 2017

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C. 2 Assessment Findings

C.2.1 Summary of Findings

1 COMMITMENT TO TRANSPARENCY

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 in decision making.

1.1.1

Evidence should be provided that information is received in appropriate form(s) and language(s) by relevant stakeholders. Information will include information on the RSPO mechanisms for stakeholder involvement, including information on their rights and responsibilities.

Minor

The Company has determined the type / level of information provided to stakeholders as required by the RSPO P & C.

At the time public meeting with stakeholders that is Akso Dano cooperative, they already understand the mechanism to request information from the company. no SOP / SUPP / II / 2017/001 dated February 20, 2017 Revision 02 related Reception and Handling of Requests for Information have set the frequency of updating the list of stakeholders conducted every 6 months.

The Company has appointed The KTU officer as responsible personnel to receive and reply for any information request.

Companies should make provisions related to complaints submitted by email from stakeholder to the company.

Conclusion : Observation No. 9

1.1.2

Records of requests for information and responses shall be maintained.

Major

The related SOP (No SOP / SUPP / II / 2017/001 dated February 20, 2017 Revision 02) has been revised. The company has set up a hierarchy of officers who provide information replies to relevant stakeholders. Officers who provide information starting from the level of Assistant KTU to the highest level of the Board of Directors in the head office.The approved grant period is provided within a maximum of 5 business days. For the type of information that is not approved will be given the answer within a maximum of 2 working days. In point 4.8.4 states every incoming letter requires a response no later than 14 working days.

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Conclusion : Conform

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

1.2.1 Publicly available documents shall include, but are not necessarily limited to: Land titles/user rights (Criterion 2.2)

Occupational health and safety plans (Criterion 4.7);

Plans and impact assessments relating to environmental and social impacts (Criteria 5.1, 6.1, 7.1 and 7.8);

HCV documentation (Criteria 5.2 and 7.3);

Pollution prevention and reduction plans (Criterion 5.6); Details of complaints and grievances (Criterion 6.3); Negotiation procedures (Criterion 6.4);

Continual improvement plans (Criterion 8.1);

Public summary of certification assessment report; Human Rights Policy (Criterion 6.13).

Major

The company has the procedure (SOP No. 106 181 / TAP / PRO-CSR-HO / VI/13) that the content has been completed as required under RSPO standards for public accessed such as the concession, Complaints & Grivence Procedure, Negotiation Procedure, Continues improvement, Public Summary of the Certification audit report, and Human Rights Policy.

The Company has been disseminated type of relevant information and can be accessed by all relevant parties to the stakeholders.

The Company has set up the website of PT. BBB under the group name Triputra Agro Persada. In the website, the procedure of Complaint System has been addressed as a part of disseminion of communication procedure.

Conclusion : Conform

1.3 Grower and millers commit to ethical conduct in all business operation and transaction

1.3.1 There shall be a written policy committing to a code of ethical conduct and integrity in all operations and transactions, which shall be documented and communicated to all levels of the workforce and operations.

Minor

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K-DIR / II / 2013 date February, 22. In each SPK has been stated a prohibition of all forms of corruption, bribery and fraudulent. Sampling has been taken from FFB Suppliers, they have understood of this policy and commit to ethical conduct and integrity in their operation and transaction.

Conclusion: Conform

2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

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

2.1.1 Evidence of compliance with relevant legal requirements shall be available. Major

At the time of ASA, it is found that there are planted areas for 785 ha which planted in Forest Area (based on Forestry Minister Decree No. 727/2012) without release of forest area decree. This is not in accordance with Government regulation number 104 of 2015. This finding was issued as Major Nonconformity.

At the time of ASA 2 visit, the status of the area is still the same so that in accordance with RSPO cerfication system, client is suspended per date March, 31, 2017

The meeting is held among client, RSPO secretariat and Sucofindo to resolve this case. RSPO asked the client to make the responsible timeplan to achieve the legal status for this are.

The company has submitted the evidence for the coorective action.

On May 5, 2017 the auditor clarified the status of the release process of PT. Brahma Binabakti to one of the data processing staff at the Directorate of Inauguration and Structuring of Forest Areas, Ministry of Environment and Forestry, on behalf of Mr. Opik Sukarsana.

He explained that the process of releasing forest areas is as follows: 1. Application by the applicant

2. Preliminary review by processing staff and forwarded to Section Head for concept of current regional status and regional history according to previous decisions.

3. If the concept has been approved by the Section Head (Echelon 4) it will be forwarded to the Head of Sub-Directorate (Echelon 3)

4. If the Head of Sub-Directorate has agreed then it will be forwarded to the Director (echelon 2) 5. If the Director has agreed then it will be forwarded to the Director General (echelon 1).

6. Wait for response from the Director General.

7. If the Director General has agreed then it will be conceptualized assistance to the integrated team from multi parties

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9. An integrated team preparation to the field. 10. Field verification

11. Preparation of recommendation report by integrated team 12. The report then reported to the minister by the Director General

13. Based on the report that given, the minister will issue decree on the release of forest area, its boundary and the establishment of new forest area.

Decree of Minister of Public Works and Public Housing No. 238 / KPTS / M / 2016 concerning the Granting of Water Resources Utilization Permit to PT BBB for Industrial Enterprises in Sungai Sekawan dated May 9, 2016 is available and valid for 5 (five) years.

Terms of the permit:

Maximum debit quota: 16.55 liters / sec Schedule of taking: 24 hours

Location of take: Sungai Sekawan, Suko Awin Jaya Village, Kec. Sukernan, Kab. Muaro Jambi, Prov. Jambi

Coordinates: S 01 21 20.2 E 103 19 19.5

Liability:

 Daily water collection report, and monthly water quality test result every 3 (three) months to BWS Sumatera VI, Dinas PSDA

 Calibration of volumetric meter every 1 (one) year

 Daily measurement of daily water level per 3 (three) months to BWS Sumatra VI, PSDA Service

Monthly Water Utilization Report of Sungae and has been reported to BWS Sumatra VI

Monthly Water Utilization Report of Sungai Sekawan for the period October - December 2016 was available and has been reported to BWS Sumatra VI

Water quality testing of river has been done by UPTB Lab Environment of Jambi Province on September 1, 2016 with evidence of LHU no. 990 / LHU / L2JBI / IX / 16 - Upstream and Downstream Sekawan River - PP No. 82/2001 Class II with BOD, COD, TSS, oil & fat, NH3-N, pH parameters and all parameters are still in accordance with the required quality standards.

Evidence of the flow meter calibration has been available with evidence of Test Result Certificate No. 510.31 / DPP / Met / SKHP / III / 2017 from UPTD Metrology Disperindag on March 14, 2017 for 3 (three) flow meter units for process, boiler and domestic needs.

Conclusion: Major NCR No.7

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Minor requirements, shall be maintained.

The Company has set a periodic evaluation to meet regulatory and written in the TAP/SOP/120

– SHE / 001 BAB III (Legal and Other Requirements). SPO Officer recapitulate compliance regulations in each unit, which includes in the area of legality, agronomy, best practices mill, employment, SMK3, and the environment.

Conclusion: Conform

2.1.3 A mechanism for ensuring compliance shall be implemented. Minor

The Company has made a legal compliance verification through internal audit conducted with frequency once a year.

SHE Sustainability Officer PT. Brahma Binabakti recapitulates and evaluate compliance regulations in each unit estate and mill. The Company has evaluated the compliance with laws and regulations regularly.

A list of applicable and appropriate legislation that in line with the company's activities was available in Annex 1 (MI-005 / MD / SUST / XII / 2012) and evaluated on March 2017.

Evaluation of compliance related to PUPR Candidate No. 37 of 2015 was available with evidence of the Decree of the Minister of Public Works and Public Housing no. 238 / KPTS / M / 2016 concerning the Granting of Water Resources Utilization Permit to PT BBB for Industrial Enterprises in Sungai Sekawan dated May 9, 2016 and valid for 5 (five) years.

Proof of payment of withdrawal and utilization tax of surface water has been available based on evidence of recording no. 000541 as of February 23, 2017 for the use of water 38,239 m3.

Conclusion: Conform

2.1.4 A system for tracking any changes in the law shall be implemented. Minor

The Company has established TAP/SOP/120 – SHE / 001 BAB III which regulate the mechanism of updating the latest regulations relating to the Company's activities.

Conclusion: Conform

2.2 The right to use the land is demonstrated, and is not legitimately contested by local people who can demonstrate that they have legal, customary or user rights

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Major actual legal use of the land shall be available. Location Permits

PT Brahma Binabakti has location permits ie:

1. The Company had estate location permits based on the Decree Governor of the Jambi Province No. 101/ 1990 dated March 31, 1990 regarding reserve land for the Rubber Plantation PT BBB. Estate is located in location A Hulumendahara river and location B Kaos River in Sekernan district, Batang Hari regency with an area of ± 6.500 Ha.

2. Location permits explained that the reserve land covering an area 6.500 Ha for rubber plantation PT Brahma Binabakti was divided to each location.Location A (Sungai Hulumendahara covering an area 3500 Ha located approximately KM 45-KM 60 right the way Jambi-Merlung and Area B (River Kaos) covering an area 3000 Ha located around Km 42-KM 60 in left the road Jambi - Merlung in Sekernan district, Batang Hari regency.

3. The Company had letter decree of Muaro Jambi regency with No. 529/ 2011 concerning amendments to the decision of Muaro Jambi regency No. 24/2011 concerning location permit for development of Palm Oil Estate PT Brahma Binabakti (Smallholder I) in Suko Awin Jaya village, Tanjung Lanjut village, Sekernan district, Muaro Jambi covering an area 6.830 Ha 4. The Company had letter decree of Muaro Jambi regenct with No. 25/ 2011 concerning

location permit development of Palm Oil Estate PT Brahma Binabakti (Smallholder II) in Suak Putat village, Tanjung Lanjut village, Bukit Baling village, Gurunggung village, Sekernan district, Muaro Jambi covering an area 5.350 Ha

5. The Company had mill location permits based on Decree Letter Head of the Land Office Batang Hari No. 4/1997 dated March 17, 1997 covering an area ± 50 Ha located in Bukit Baling village, Sekeran district, Batang Hari Regency.

6. Company also had location permits from Head of Badan Pelayanan Terpadu Satu Pintu Batang Hari Regencywith No. 08/2011 regarding location permit for development plan of Palm Oil Estate PT. Brahma Binabakti in Pemayung district, Batang Hari regency, Province Jambi covering an area 6.400 Ha

7. There is decree Head of Badan Penanaman Modal dan Pelayanan Perizinan Terpadu Batang Hari Regency No. 66/2014 concerning the extension of the location permit for the development plan of oil palm estate PT Brahma Binabakti In Pemayung district, Jambi Province, Batang Hari covering an area of 6000 Ha.

Plantation Business Permit (IUP)

Related Document of Plantation Business Permit (IUP) ie :

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land reserve covering an area 6.500 ha brutto commodities rubber.

2. Letter of Approval of Change Type Plant PT. Brahma Binabakti, Jambi Province of the Directorate General Plantation - Department of Agriculture Number: HK.350 / E5.363 / 05.96 dated May 28, 1996. The change of Commodity rubber with an area of 6.000 ha to the type of commodity rubber and oil palm plantations with a total area of 6.000 hectares (Rubber with an area of 3000 ha and 3.000 ha of oil palm) on an concession area about 6.220 Ha.

3. PT Brahma Bina Bakti already have Plantation Business Registration License (SPUP) from the Directorate General of Plantation Production Number: HK.350 / 425 / Dj.Bun.5 / VI / 2001 dated June 6, 2001. This SPUP set business a rubber plantation culture with plantation area of 6.220 Ha and processing unit type Latek Pekat with a capacity 3.500 tons / year.

4. Decree of the Head of the Investment Coordinating Board (Badan Koordinasi Penanaman Modal) No. 2/1 / IU / IV / domestic / Agriculture / Industry / 2010 dated May 20th, 2010 concerning business licenses in the framework of the Merger (Merger). The business sectors were rubber and palm oil plantation integrated with the palm oil industry and palm kernel. The capacity license for FFB production was 67 800 tonnes / year, latex rubber plantation was 3,500 tons / year, crude palm oil (CPO) was 60,000 tons / year, and palm kernel was 12,720 tons / year. The land area was listed in the permit was 2,820.00 ha for palmoil plantation and 3390.00 hectares for rubber plantation and 726.00 m2 for the industry. If the license has been stated that the shortage of FFB as many as 193,200 tonnes (equivalent to 8,050 hectares) was supplied from around smallholder, the company could carry out product diversification within the scope of the edible oil industry (crude oil) and vegetable.

5. PT. Brahma Bina Bakti applied for changes in types of plant and processing on SPUP No. HK.350/425/Dj.Bun.5/VI/2001 through a letter no. 105492/BBB/SPM-R01-HO/IX/13, dated September, 2nd 2013.

6. Forestry and Plantation Letter No. 525/1193 / Dishutbun / 2013, dated September, 24th 2013 approved the recommendation of Plantation Business Permit (IUP) covering an area of 3,661 hectares of oil palm and its management with a capacity of 60 tons / hour and Aquaculture Plantation Business Permit (IUP- B) of rubber covering 2,559 hectares located in the village of Suko Awin District of Sekernan, Muaro Jambi.

7. The Company has processed the changes in plant type and processing on SPUP no. HK.350/425/Dj.Bun.5/VI/2001 and obtained the letter from One-Door Integrated Service Agency (Badan Pelayanan Terpadu Satu Pintu) no. 503/213/BPTSP/XI/2013 dated November, 15th2013. The letter explained that the issuance of changes in plant type and processing of the license was still in process in the Agency One Stop Muaro Jambi.

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commodities along with oil palm processing with a 60 tonnes/hour capacity with a total area of rubber plants of 2,559 Ha and oil palm of 3,661 Ha.

9. The Company has obtained Decree Letter from Regent of Batang Hari no. 640 year 2013 on granting permission of plantation business permit for cultivation (IUP-B to PT Brahma Binabakti with area of 3,500 hectares in the Pemayung district.

HGU Decree :

1. Decree of the State Minister of Agrarian/ Head of National Land Agency Number: 61/HGU/BPN/95dated of 2 October 1995 concerning the granting of Exploitation Right for 25 years (up to 31 December 2020) to PT. Brahma Binabakti of 6,220 Ha of land located in forest group of S. Hulumendahara-S. Kaos, Batanghari Regency, Jambi Province.

2. Decree of the Head of the Regional Office of National Land Agency of Jambi Province Number: 07/HGU/BPN.15/2014 concerning the granting of Exploitation Right for 35 years to PT. Brahma Binabakti of 453.3 Ha

3. Decree of the Head of the Regional Office of National Land Agency (Badan Pertanahan Nasional) of Jambi Province Number: 08/HGU/BPN.15/2014 concerning the granting of Exploitation Right PT. Brahma Binabakti of563.783 Ha, located in Muaro Jambi Regency, Jambi Province.

HGU Certificate:

1. HGU Certificate No. 2 with location in Bukit Baling Village, Sekeran District, Batang Hari Regency, Jambi Province. The area covered is based on the letter of measurement No. 1814/ 1996 dated 1 May 1996 of 28,200,000 m2

2. HGU Certificate No. 3 with location inBukit Baling Village, Sekeran District, Batang Hari Regency, Jambi Province. The area covered is based on the letter of measurement No. 1815/ 1996 dated 1 May 1996 of 34,000,000 m2.

3. Revision of HGU certificate No. 3 on 20 November 1998 to become 33,902,275 m2 due to the purchase of 97,725 m2 by PGN.

4. HGU Certificate no. 94 – 108 that is issued by National Land Agency (Badan Pertanahan Nasional)of Muaro Jambi Regency in 2014 with total area of 453.3 Ha in accordance with Decree Letter no. 07/HGU/BPN.15/2014.

5. HGU Certificate no. 77 – 93 that is issued by National Land Agency (Badan Pertanahan Nasional) of Muaro Jambi Regency in 2014 with total area of 563.783 Ha in accordance with Decree Letter no. 08/HGU/BPN.15/2014.

SK HGB:

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years with an area of 492,280 m2 located in the village of Bukit Baling, District of Sekernan, Regency of Batanghari, Province of Jambi, whis is described in measurement certificate dated September 23rd, 1999 No. 05 / BKB / 1999.

HGB Certificate

HGB certificate no. 2, located in Bukit Baling Village, Sakernan District, Batanghari Regency, and Jambi Province with an area of 49,228 ha, which is ended on October, 9th 2030.

The company has had a Standing Instruction No.027 / MI-DIR / XII / 2012, which contains instructions on how to manufacture and maintenance concession boundary markers such as the size of the mark, the type and color of paint, as well as the identity of the article reporting deadline. However, maintenance and monitoring reporting of the concession boundary markers should be reported every month before the 7th of each month was not appropriate. The last reporting was reported once in the last 3 months i.e from July to September 2013. The Company has reported the maintenance and monitoring of the concession boundary marker in accordance with a standing instruction.

Release of forest area

The company had permit letter regarding the release of forest area through Decree of Minister Forestry No. 125 / Kpt-II / 1993 dated February 27, 1993. Letter explained the release of some forest group S. Hulumendahara - S. Kaos located in Batang Hari regency, Jambi covering an area of 6.220 (Six Thousand and Two Hundred Twenty) ha for the cultivation of rubber plantations with the name of PT.Brahma Binabakti.

There are observations finding on previous audit, i.e PT. Brahma Binabakti does not have HGU for Pemayung Estate. During surveillance audit the company shows corrective action in the form of Letter of Assignment Preparation Measurement issued by BPN Regional Office of Jambi province on March 3, 2017. In the letter it is known that on March 6, 2017 until March 10, 2017 there are taskforce for preparing cadastral measurements of PT. Brahma Binabakti in Pemayung District covering an area of 2.463.500 m2. In the absence of SK HGU for the Pemayung area, the area is excluded from the scope of certification and included in the Company's time bound.

There is a major finding in the previous audit that there are areas of plasma that has been planted for 189 ha in the concession area of PT. Brahma Binabakti. This is not correct accordance to Government Regulation No. 40 1996. During surveillance audit the company has taken the corrective action i.e identified the location of the plasma as outlined in the map the location and conduct negotiations with land owners. Last negotiations conducted on November 8th to November 12th 2016, with the agreement that some landowners request that their land be removed from the company's HGU. Some again requested that their land be owned by the company but was given a replacement for another adjacent land. Corrective actions have been considered adequate so the finding can be closed.

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2.2.2 Legal boundaries shall be clearly demarcated and visibly maintained. Minor

PT. Brahma Binabakti has a Standing Instruction No. 027 / MI-DIR / XII / 2012. The company already has a list of inventory coordinates HGU. Sampling at visit time to poles border No. KP

39 (S 01°20’40,7”; E 103°24’16, it found that the pole is in good condition. Conclusion: Conform

2.2.3 Where there are or have been disputes, additional proof of legal acquisition of title and evidence that fair compensation has been made to previous owners and occupants shall be available, and that these have been accepted with free, prior and informed consent (FPIC).

Minor

The information of land dispute is with the village community who have finished 8 issue of dispute through Muaro Regent Decree No.25 of 2011.

Conclusion: Conform

2.2.4 There shall be an absence of significant land conflict, unless requirements for acceptable conflict resolution processes (see Criteria 6.3 and 6.4) are implemented and accepted by the parties involved.

Major

Until now, there are no areas that are still disputed by others. Related to land disputes between the Company and the NGO FMP (Farmer Community Forum), the Company has been doing land dispute resolution process in accordance with the agreement of both parties.

Conclusion: Conform

2.2.5 For any conflict or dispute over the land, the extent of the disputed area shall be mapped out in a participatory way with involvement of affected parties (including neighbouring communities where applicable).

Minor

The Company already has mapping-related areas of conflict in accordance with SOP No. 106 899 / TAP / PRO-CSR-HO / XI / 16 and the boundaries are adjacent to areas of conflict as well as the coordinates of the area.

Conclusion: Conform

2.2.6 To avoid escalation of conflict, there shall be no evidence that palm oil operations have instigated violence in maintaining peace and order in their current and planned operations.

Major

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procedure containedthe provision of granting compensation process transparentlyand fairly, involved government and traditional leader.

Conclusion: conform

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

2.3.1 Maps of an appropriate scale showing the extent of recognised legal,customary or user rights (Criteria 2.2, 7.5 and 7.6) shall be developed throughparticipatory mapping involving affected parties (including neighbouringcommunities where applicable, and relevant authorities).

Major

The Company has had SOP of Land Acquisition (002/TAP/PRO-SCP-HO/IV/10). In point 4.1.3 has stated land acquisition and compensation based on FPIC.

Conclusion: Conform

2.3.2 Copies of negotiated agreements detailing the process of free, prior and informed consent (FPIC) (Criteria 2.2, 7.5 and 7.6) shall be available and shall include:

a) Evidence that a plan has been developed through consultation and discussion with all affected groups in the communities, and that information has been provided to all affected groups, including information on the steps that shall be taken to involve them in decision making;

b) Evidence that the company has respected communities’ decisions to give

or withhold their consent to the operation at the time that this decision was taken;

c) Evidence that the legal, economic, environmental and social implications for permitting operations on their land have been understood and accepted by affected communities, including the implications for the legal status of

their land at the expiry of the company’s title, concession or lease on the

land. Minor

The Company requires certain documentation requirements that must be stored in any settlement of the conflict and compensation. It is listed in the SOP Acquisition of land (002 / TAP / PRO-SCP-HO / IV / 10) and SOP Acceptance and resolution of complaints from stakeholders (106 899 / TAP / PRO-CSR-HO / VI / 13). All data is stored in a separate file for each case. Related to compensation to Mr. Pajrin in Afd E, Block E1 PT. Brahma Binabakti have to take corrective action as follows :

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b. Minutes of Measurement Result of Land No. 01 / BBBS / 1/2014 has been improved by adding the approval of the authorities on behalf of the village.

c. Receipts are received by Mr. Pajrin as the landlord

Related to the observations findings on previous audit, PT. Brahma Binabakti has make corrective action i.e: agreement on release of land of Mr. Pajrin been repaired by bringing the signature page of the witnesses be under the signature of Mr. Parjin, the Board of Directors and Chief of Desa Jaya Suko Awin (Hidayah). Corrective actions have been considered adequate therefore, the previous observation can be closed.

Conclusion: Conform

2.3.3 All relevant information shall be available in appropriate forms and languages, including assessments of impacts, proposed benefit sharing, and legal arrangements.

Minor

There was a relinquishment of rights letter between the company and claim maker; Mr. Pajrin dated February 11, 2014. The relinquishment of rights agreement was made in 3 pieces and there are initials on each of the sheet and also signatures of the witnesses made in a same page. Therefore the previous observation can be closed.

Conclusion : Conform

2.3.4 Evidence shall be available to show that communities are representedthrough institutions or representatives of their own choosing, including legalcounsel.

Major

In the procedure of land acquisition has already contained provisions of compensation document storage of 15 document types. The documentation was complete as required in the procedure. For example, there were document receipt and compensation minutes.

Conclusion: conform

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

3.1.1 A business or management plan (minimum three years) shall be documented that includes, where appropriate, a business case for scheme smallholders. Major

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production of CPO, OER and good production capacity for plasma and own estate. Conclusion: conform

3.1.2 An annual replanting programme projected for a minimum of five years (but longer where necessary to reflect the management of fragile soils, see Criterion 4.3), with yearly review, shall be available.

Minor

The Company has replanting plan program from 2018 until 2021. Replanting plan distribution of palm plantation PT Brahma Binabakti :

• In 2018 the Company plans replanting of an area of 1,006 Ha • In 2019 the Company plans replanting of an area of 1,113 Ha • In 2020 the Company plans replanting of an area of 896 Ha

• In the year 2021 the Company plans replanting of an area of 582 Ha

Conclusion: conform

4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS

4.1 Operating procedures are appropriately documented and consistently implemented and monitored

4.1.1 Standard Operating Procedures (SOPs) for estates and mills shall be documented.

Major

The company has procedure land clearings with the principle of non-burning (zero burning). Land clearing methode have contained in Agronomy Procedure revision 1: TAP-PR / AGR / OP-001 / V09-1. The company also has a SOP for Mill Operation set out in the Technical Guidelines Mill.

Conclusion: conform

4.1.2 A mechanism to check consistent implementation of procedures shall be in place.

Minor

The Company has a monitoring mechanism for each activity, such as in the implementation of crop rotational that have been defined in the SOP (7 days). The Company has monitoring crop rotation for all afdeling and they also has a list of monitoring crop rotation. The company also has monthly reports as material control operational activities of the Company.

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4.1.3 Records of monitoring and any actions taken shall be maintained and available, as appropriate.

Minor

Company has the documentation for each activity that summarized for each month activities and recorded in the monthly progress report.

Conclusion: conform

4.1.4 (M) The mill shall record the origins of all third-party sourced Fresh Fruit Bunches (FFB).

Major

Company has the data for each origin of FFB that incoming to PT. BBB Mill, the following is the documentation of the origin of FFB (kg) in 2016 and recorded in the "Statistics Of Supply Base (2016)".

Supply Base FFB (Ton) Own Estate 71,469 Plasma I 67,656 Plasma II 24,085 Out grower 119,548

Conclusion: conform

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

4.2.1 There shall be evidence that good agriculture practices, as contained in Standard Operating Procedures (SOPs), are followed to manage soil fertility to a level that ensures optimal and sustained yield, where possible.

Minor

Company has SOP for soil sampling procedure (069 / PT / VIII / 2014) and leaf sampling (LSU) procedure (050 / PT / VIII / 2014). The frequency of the soil sampling conducted once every five years, while the Company conducted leaf sampling (LSU) for fertilizer recommendations once a year. The Company has been analyzing samples of the leaves that have been done on September 19, 2016, with reference number 51L / HAL-HPS / int / IX / 2016 to determine the nutrient content in plants. The nutrients that are measured include the percentage of N, P, K and Mg. The company also had analyzed soil samples to determine the available nutrients in the soil on November 17, 2016 by PT Hijau Persada Sejahtera with reference number 16S / HAL-HPS / Int / XI / 2016.

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4.2.2 Records of fertiliser inputs shall be maintained. Minor

Company has SOP manual fertilization No. PPG / GMO / ASD / 45 / SOP to support optimal production by improving soil nutrient.

The Company also conducts application of empty bunch to add nutrients to the soil as much as 26,105 tons at a dose of 40 tons/ha/year. To improve soil nutrients, the company also conducted fertilizing based on analysis of leaves that have been done. The realization of fertilization during 2016 were:

Type of Fertilizer

Realization (Kg) Jan-Des 2016

TAP COM 1 -

TAP COM 2 440.469

TAP COM 3 3.203.593

Urea 824.049

Borate 54.915

DOLOMITE 175.874

KIESERITE 293.842

MOP 449.216

Conclusion: conform

4.2.3 There shall be evidence of periodic tissue and soil sampling to monitor changes in nutrient status.

Minor

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Conclusion: conform

4.2.4 A nutrient recycling strategy shall be in place, and may include use of Empty Fruit Bunches (EFB), Palm Oil Mill Effluent (POME), and palm residues after replanting.

Minor

The Company also conducts application of empty bunch to add nutrients to the soil as much as 26,105 tons at a dose of 40 tons/ha/year.

Conclusion: conform

4.3 Practices minimize and control erosion and degradation of soils. 4.3.1 Maps of any fragile soils shall be available.

Major

The Company already had map to reflect the conditions of land suitability of palm oil with a scale of 1: 60,000. In the land condition map PT BBB indicates that the entire area of PT BBB currently on mineral land. Company also had the technical guidelines for the conservation of marginal areas. As for soil and water conservation techniques that Company has done such as:

• Maintenance of cover crops and vegetation • Application of empty bunch

• Preparation of midrib

• Making rorak

• Terrace of contour Conclusion: conform

4.3.2 A management strategy shall be in place for plantings on slopes above a certain limit (this needs to be soil and climate specific).

Minor

Company has SOP (060 / PT / VIII / 2014) manufacture of hooves as a management strategy for planting in slopes area with the aim of providing optimal space and potential soil fertility can be maintained in a long period of time and efforts to prevent erosion. Making hoof performed on bumpy areas with a slope of 12% -24%. The conservation techniques based on the slope:

• Choppy area ( slope of 0-12%) should be planting wheat and preparing the midrib.

• Corrugated area (slope of 12-24%) need to manufacture hoof

• Hilly (slope of 24-38%) need terracing, contour

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Conclusion: conform

4.3.3 A road maintenance programme shall be in place. Minor

The Company has a plan and realization of road repair by hardening the road along the 21,395 meters and the realization data up to 1,620 meters until February 2017 with using grader. The company also has a road maintenance plan during the year 2017 that set out in the Annual Budget. To improve and maintain the quality of the road, the company is also working on creating the trenches, culverts and rorak.

Conclusion: conform

4.3.4 Subsidence of peat soils shall be minimised and monitored. A documented water and ground cover management programme shall be in place.

Major

The company has no peat areas, it is based on the identification type of land. The company has mineral soil types.

Conclusion: N/A

4.3.5 Drainability assessments shall be required prior to replanting on peat to determine the long-term viability of the necessary drainage for oil palm growing.

Minor

The company has no peat areas, it is based on the identification type of land. The company has mineral soil types

Conclusion: N/A

4.3.6 A management strategy shall be in place for other fragile and problem soils (e.g. sandy, low organic matter, acid sulphate soils).

Minor

The Company has a strategy for the fragile and problem soils, such as the company use empty bunch applications to add nutrients in the sandy soil. Generally, PT Brahma Binabakti has mineral soil type so it does not need a lot of treatment to improve the structure of the soil.

Conclusion: conform

4.4 Practices maintain the quality and availability of surface and groundwater. 4.4.1 An implemented water management plan shall be in place.

Minor

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with reference to the Permenkes 416/1990 for clean water. The results of test showed that result for all parameters meet requirement quality standards. Therefore, the previous observation can be closed.

In 2016, total water consumption for process activities about 112,470 M3 and total boiler water usage 281,688 M3. The amount of water usage as much as 394,158 M3. Total FFB processed until the end of December as many as 287,937 tons. The water usage ratio is 1:37. This value is still far from the target of 1:20, but decreased from 2015 at 1:42.

Aside from the water surface, the water needs for office activities drawn from underground water for POM in the two points of underground water. With the permission of the Head of Department of Energy and Mineral Resources Muaro District No. 05 of 2014 and No. 08 of 2014 dated March 28, 2014 with a validity period of 3 years. The allowable discharge were 50 liters/sec for

each. Whereas, taking underground water licensing for estate’s office needs with number 06/2014 is the same discharge of 50 liters/sec.

PT BBB groundwater source map with scale of 1: 100.000 with the number of groundwater uptake points as much as 7 (seven) has been available. Groundwater uptake permits from the seven are already available from related agencies.

Decision of the Head of Department of Investment and Integrated One-Stop Services of Jambi Province concerning GRANTING LICENSE OF LAND WATER OPERATION TO PT BRAHMA BINABAKTI dated January 26th , 2017 and valid for 3 (three) years has been available. Therefore the previous major can be closed.

Monthly Water Pollution Reports Period February 2017 to Head of ESDM Department of Muaro Jambi based on Permit no. 5/2014 and No. 8/2014 with withdrawal amount 8475 m3 and 2971 m3 dated March 4th , 2017 - at POM locations already available.

Monthly Water Pollution Reports Period February 2017 to Head of ESDM Department of Kab. Muaro Jambi based on Permit no. 20, 21, 22, 23 with a total of 280 m3, 140 m3, 140 m3 and 1680 m3 dated March 6th, 2017 - at the estate and POM is available.

Groundwater uptake permits and water quality results for 7 (seven) groundwater sources identified in PKS and estate, but for water sources in afdeling E and A are still in the identification stage for permit handling. This has been raised as observation.

Conclusion: Observation No.2

4.4.2 Protection of water courses and wetlands, including maintaining and restoring appropriate riparian and other buffer zones (refer to national best practice and national guidelines) shall be demonstrated.

Major

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biji, and Karet) along riparian of Sekawan river. During field visits it is found that the sign board has been installed and trees planted in good condition. The company already has a monitoring program to ensure that the embedded trees can grow well. Adequate corrective action has been made and non-conformity can be closed.

PT. Brahma Binabakti has the river map for Own and Pemayung Estate. The rivers that crosses the own estate area according to the river map and based on identification of HCV in 2013 are Putat river (width 1,5 – 3 m), Anak Mendahara river (width 2 – 4 m), and rivers that crosses the Pemayung estate are Danau Bangko river (width 10 – 15 m) and Batanghari river (width 250 – 400 m). In the HCV identification report, assessor set the width of riparin river as follows:

- 20 meters each side of the Suak Putat river along 3.472 m

- 20 meters each side of the Anak Mendahara river along 4.192 m - 50 meters each side of the Danau Bangko river

- 50 meters each side of the Batanghari river

In the previous audit found major non-conformity about recommendation from HCV assessor which set the width of riparian for Suak Putat and Mendahara river are 20 m. The recommendation has get approval from Badan Lingkungan Hidup of Muaro Jambi written in letter No: 660.4/36/BLH.3/2016 dated 4 April 2016. However, during field visit to Block D-12 (Afd. E) Auditor found that the company has set the riparian with the width 50 m from the river (marks with yellow paint around the palm oil trees). This is consistent with the interviews results with sprayers stating that trees with yellow paint was banned for a given chemical treatment. PT. Brahma make efforts to protect water bodies and the riparian with :

1. Test the water quality of the river to determine the chemical pollution that enter the river water.

2. Establish limited treatment zones without fertilizer and agrochemical applications for border that had already planted.

Adequate corrective action has been made and non-conformity can be closed. Conclusion: Conform

4.4.3 Appropriate treatment of mill effluent to required levels and regular monitoring of discharge quality, especially Biochemical Oxygen Demand (BOD), shall be in compliance with national regulations (Criteria 2.1 and 5.6). Minor

Decree of One Stop Agency Muaro Jambi Sub decree No. 07 / Kep.KaBPTSP / VI / 2016 dated June 23, 2016 on the extension of Wastewater Utilization Permit PT. BBB POM with an area of 300 Ha and license valid for 5 (five) years.

Obligations related to the license :

- Monitoring the quality of waste water (coordinates S 1 21 00.7 103 19 29.2) with parameters of pH (daily), BOD, COD, oils / fats, Pb, Cu, Zn, and Cd

(39)

parameters of BOD, COD, pH, NO3, NH3-N, Cd, Cu, Pb, Zn, Cl, SO2 every 6 (six) months

- Monitoring of land (6 layers: 0-120 cm) conduct every 1 (one) year

The Company reports on the monitoring activities to the BLH Muaro Sub district. Conclusion: Conform

4.4.4 Mill water use per tonne of Fresh Fruit Bunches (FFB) (see Criterion 5.6) shall be monitored.

Minor

In 2016, total water consumption for process activities 112,470 M3 and total special boiler water usage 281,688 M3. The amount of water usage as much as 394,158 M3. Total FFB processed until the end of December 2016 as many as 287,937 tons. It found that the water usage ratio is 1:37. This value is still far from the target of 1:20, but decreased from 2015 at 1:42.

Conclusion: conform

4.5 Pests, diseases, weeds and invasive introduced species are effectively managed using appropriate Integrated Pest Management Techniques

4.5.1 Implementation of Integrated Pest Management (IPM) plans shall be monitored.

Major

The Company has Guideline Technical Agronomy in which there are SOP Pest and Plant Disease Control such as pest control of Worm Eater Leaf (UPDKS) 041 / PT / VI / 2014, pest control rats 042 / PT / XII / 2014 and pest control beetle horn 045 / PT / VI / 2014.

The Company also has early warning system (EWS) through regular pests monitoring every month such as fire caterpillar, bags caterpillar and ganoderma.

Conclusion: conform

4.5.2 Training of those involved in IPM implementation shall be demonstrated. Minor

Company had census worker for each Division, coordinated by the foreman of each Division. The company also had census worker that has been appointed as EWS team. Company has conducted EWS Training to the team in the form of Agronomy Technical Training on May 21, 2016 and introduction of pests and diseases of oil palm plantations training and also early detection activities in preventing pests and palm plant diseases on February 26, 2016.

The company also conduct planting host plants enemies such as Turnera s

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