Identification of Findings, Corrective Actions and Observations at ASA-1.4

Verification 15 July 2022

3.4.3. Identification of Findings, Corrective Actions and Observations at ASA-1.4

NCR No. :

2023.01 Issued by :

Radytio Puspanjana

Date Issued :

2 February 2023 Time Limit : Next Assessment

NC Grade :

Minor Date of Closing :

Standard Ref. &

Requirement

: 3.4.2

For the unit of certification, a SEIA is available and social and environmental management plan and its monitoring have been developed with participation of affected stakeholders.

Evidence observed (filled by auditor):

As a form of social management, the company has developed / compiled by involving independent parties in conducting social impact assessments related to the company's operational activities. In the social study, the affected villages were Betung Village, Bakau Village, Balaemea Village, Bepara Village, and Sekayu Village. The social impact assessment was first carried out in January 2010 by the Indonesian Sustainable Coconut Foundation as a follow-up to the results of the assessment, there are several recommendations / matrices for social impact management and monitoring plans, including:

• Transparency

• Plasma KKPA

• Overlapping land

As one of the efforts to improve and pay attention to the latest situation from 2022 the company carried out an SIA review which was carried out on December 20 2022, where this was due to the dynamic social situation. The results of the SIA review for impacts that are managed and monitored include:

• Replanting activities.

• Improving the community's economy from plantation and factory activities.

• Improvement of labor education and health from plantation and factory activities.

• Maintenance of local wisdom

The company also shows the SIA Planning and Monitoring matrix for 2021/2022 (compiled on 8 June 2022), such as:

• Health services.

• Educationn

• Community assistance.

• Community empowerment around the plantation

• Infrastructure development.

In an effort to follow up on the 2010 SIA review recommendations, the company has developed a social management and monitoring plan for 2022, but in the process of preparing the document it was discovered that:

• External stakeholders involved in preparing social management and monitoring plans are still limited to several affected stakeholders, for example Bepara Village, Balaimea Village, Sekayu Village, Betung Village, Sekayu Baru Village and foreman I, have not paid attention to parties who are broadly affected, for example the representatives of indigenous peoples, the government, plasma farmers, the users of water resources around, and the cultivators / enclaves. The meeting was held on 16 December 2022.

• Internal stakeholders have not been directly involved in the management plan and social monitoring.

• Stakeholder internal belum secara langsung dilibatkan dalam rencana kelola dan pantau social.

• There is no synergy between the SIA review and the SIA Planning and Monitoring matrix.

So that with the limited number of parties involved in preparing the social management and monitoring plan, there are several

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issues that have not been identified that have been monitored and managed in a comprehensive and integrated manner, for example:

• Issue regarding horn beetle attack from the impact of replanting activities (information from Environmental agency and Betung Village)

• Employee housing facilities.

Environmental Aspect

Meanwhile, the environmental aspects are explained in the RKL-RPL documents for semesters 1 and 2 of 2022. Based on these documents, the impacts that have been managed and monitored are:

• Air Quality

• Soil Fertility.

• Water management.

• Soil fertility

• Air quality and noise

• River water quality

• Waste

• Flora and fauna

• Land Fire

• Social problems.

• Community and employee income

• Public health

• Aquatic biota

• Transportation / vehicles

• Oil palm replanting

Non-Conformance Description (filled by auditor):

The plan for managing and monitoring environmental and social impacts has not been developed in a participatory manner by involving all stakeholders who are widely affected so that there are several social issues that have not been identified that have been monitored and managed in a comprehensive and integrated manner.

Root Cause Analysis (filled by organization audited):

Correction (filled by organization audited):

Corrective Action (filled by organization audited):

Assessor Evaluation and Conclusion (filled by auditor):

Follow up on next audit (filled by auditor):

Verified by :

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NCR No. :

2023.02 Issued by :

Radytio Puspanjana

Date Issued :

2 February 2023 Time Limit : Next Assessment

NC Grade : Minor Date of Closing :

Standard Ref. &

Requirement

: 7.3.2

Proper disposal of waste material, according to procedures that arefully understood by workers and managers, is demonstrated.

Evidence observed (filled by auditor): Hazardous waste

No. Policy 709/TQEM-EHS/10 dated 16 December 2010: Management and monitoring of hazardous waste explains that hazardous waste used batteries, used oil, used oil filters, used pesticide packaging, used sacks contaminated with hazardous and used TL lamps are stored in the hazardous waste hazardous storage then transported by carriers licensed by the government. Management of hazardous contaminated packaging, used chemical pesticide packaging and used POM water chemical packaging, namely washing 3 times in a special washing place.

Based on the results of field visits in several locations, for example:

- Used/damaged TL lamps are placed in a used goods warehouse/archive warehouse at Sekayu Estate.

- Sacks of used fertilizers are placed in the scrap warehouse / archive warehouse at Sekayu Estate.

- Used pesticide packaging and used oil packaging were placed in the back of the car (write off) at the Betung estate traction.

- Used fertilizer sacks are disposed of in the area behind traction at Betung Estate.

- Used batteries are placed in a junkyard at the Betung Estate traction.

- Used oil is collected in used helmets and used oil filters are placed behind the Betung Estate traction.

- Used water purifier packaging (Nalco) for cleaning in the dispatch machine room at Betung POM.

POM Waste

- Based on the results of interviews with Betung PKS and verification of SOP documents for the use of solid and liquid waste, it was explained that solid waste in the form of empty fruit bunches was collected at the POM and then applied to the land.

- Based on the results of a field visit, a large pile of empty fruit bunches was found at the empty bunch collection site, thus burying the leachate storage pond and the pump that pumps the leachate into the WWTP pond. So that the piles of empty fruit bunches produce leachate, which is a liquid resulting from exposure to rainwater in the garbage piles, including the solid waste of empty fruit bunches, which is released into the environment through the Betung POM rainwater drainage.

- The company showed data (work program for stock of empty bunches) which explained that the excess empty bunches occurred due to the lack of maximum evacuation, the transport equipment was damaged and the performance of the leachate pump to the WWTP pool was not optimal.

- Timeline document for empty fruit bunches for February 2023 which explains the amount of EFB stock on 1 February 2023 in the morning (MT) 2,500 to the final stock on 28 February 2023 of 540 MT. In the evacuation action plan, 2 contractors will carry out each day and use BTE and SYE units for every FFB delivery to the Mill. The document is approved by the mill manager.

The company has not been able to show comprehensive evidence of the normalization of EFB including a work plan for the application of EFB to the land, the number of workers who will carry out the application and early anticipation that can prevent leachate from being released into the environment.

Non-Conformance Description (filled by auditor):

The company has not been able to show sufficient evidence that the management of hazardous waste and POM solid waste

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(empty fruit bunches) is in accordance with procedures and is fully understood by all workers and managers.