PTPN VII PTPN VII
3.4 Identification of Findings, Corrective Action, Observations, Opportunity for Improvement and Noteworthy Positive Components
3.4.2. Identification of Findings, Corrective Actions and Observations at ASA-4
NCR No. : 2023.01 Issued by : Haikal Ramadhan K
Date Issued : 06 April 2023 Time Limit : 05 July 2023
NC Grade : Major Date of Closing : 01 July 2023
Standard Ref. &
Requirement
: 2.1.1
The unit of certification complies to relevant regulations.
Evidence observed (filled by auditor):
1. Decree of the Minister of Public Works and Public Housing Number 285/KPTS/M/2021, regarding the Granting of Water Resources Exploitation Permits to the Limited Liability Company Perkebunan Nusantara IV for Oil Palm Processing in the Hessa River, Asahan Regency, Sumatra Utara Province, March 9, 2021, period valid 2 years. The permit states:
a. In part DECIDES letter C, the permit to exploit water resources as referred to in Letter A of the First DIKTUM is granted for a period of 2 (two) years from the enactment of this Ministerial Decree, in Letter D The permit period as referred to in Letter C of the First Dictum may be extended subject to the provisions no later than 3 (three) months before the license expires, the permit holder must apply for a license extension
b. Letter B Sixth Dictum In addition to the permit revocation provisions referred to in letter A of the SIXTH DICTUM, a permit is declared invalid if: 1 the validity period of the water resources exploitation permit ends
2. Letter Number: 04.01/X/128/III/2023, dated March 8, 2023, Regarding Application for Extension of Underground Water Permits to the Governor of North Sumatra cq. Head of the One Stop Integrated Investment and Licensing Service Office, for underground water permits for Air Batu Gardens (Emplasmen Afdeling I – IX)
Non-Conformance Description (filled by auditor):
The unit of certification has not been able to provide sufficient evidence:
1. The process of extending the Water Resources Exploitation Permit which ended on March 9, 2021.
2. Submission of an application for an extension of the Underground Water Permit (ABT) for the Air Batu Plantation.
Root Cause Analysis (filled by organization audited):
There is no PIC who has conducted monitoring of the validity period of permits in the plantation unit and Air Batu Mill.
Correction (filled by organization audited):
1. Make a Letter to the Legal Asset Department regarding the Management of ABT Permits that have Expired.
2. Sending the results of the Recommendations given from the legal Asset sub bag.
3. Create SK PIC which monitors validity period of permits.
Corrective Action (filled by organization audited):
Monitoring the validity period of the permit (Available Document).
Assessor Evaluation and Conclusion (filled by auditor):
Verification date 6 June 2023
The company has shown evidence of improvement in the form of:
Memo of application for extension from the unit to the Secretariat Section of the Office of the Board of Directors of PTPN IV on 3 May 2023.
List of monitoring permits with information on the validity period.
Decree stipulation of PIC in monitoring and evaluation related to license validity period.
However, the company has not been able to demonstrate corrective action, namely the results of the recommendations given from
the legal assets sub bag, so that the discrepancy in this indicator has not been fulfilled.
Auditor Verification June 14, 2023:
The company shows evidence of improvement as follows:
Letter Number: 04.01/X/128/III/2023, dated March 8, 2023, Regarding Application for Extension of Underground Water Permits to the Governor of North Sumatra cq. Head of the One Stop Integrated Investment and Licensing Service Office, for underground water permits for Air Batu Gardens (Emplasmen Afdeling I – IX).
The evidence presented above is evidence that has been verified during the audit, the company has not been able to show:
1. Evidence of submitting the results of the recommendations given from the legal asset sub bag
2. Efforts to extend the surface water utilization permit process which ended on March 9, 2023 (Decree of the Minister of Public Works and Public Housing Number 285/KPTS/M/2021, regarding the Granting of Water Resources Exploitation Permits to Limited Liability Company Perkebunan Nusantara IV for Oil Palm Processing in the Hessa River, Asahan Regency, North Sumatra Province, March 9, 2021, validity period of 2 years).
3. Proof of submission of Letter Number: 04.01/X/128/III/2023, dated March 8, 2023, Regarding Application for Extension of Underground Water Permits to the Governor of North Sumatra cq. Head of the One-Stop Integrated Investment and Licensing Service Office, for underground water permits for Air Batu Estate (Emplasmen Afdeling I – IX) to the One-Stop Integrated Investment and Licensing Service Office of North Sumatra Province.
Based on the verification results above, the evidence is insufficient and the 2023.01 discrepancy cannot be closed yet.
Auditor Verification July 1, 2023
The company shows the latest documents, namely:
1. Letter Number 27/KH.DTL/S-PERNY/VI/2023, dated 05 June 2023, regarding the ABT Permit Arrangement Statement, from the Advocate and Legal Consultant Office, Law Firm Dicky Tarigan, stating that the licensing process is handled by the Law Office is currently in the process of submitting application documents to the OSS system, and is waiting for the permit to be issued.
2. Screen Shoot Web OSS, contains information on applications for renewal of new groundwater concession permits. PTPN 4, with status awaiting verification of document completeness, June 5, 2023.
Based on the above, the discrepancy in this indicator has been fulfilled by observation in the next assessment.
Follow up on next audit (filled by auditor):
Verified by : Haikal Ramadhan Kharismansyah
NCR No. : 2023.02 Issued by : Haikal Ramadhan Kharismansyah Date Issued : 06 April 2023 Time Limit : Next Surveillance
NC Grade : Minor Date of Closing :
Standard Ref. &
Requirement
: 2.1.2
A documented system for ensuring legal compliance is in place. This system has means to track changes to the law and also includes listing and evidence on evaluation of legal compliance of all contracted third parties, such as: recruitment agencies, service provider and labour contractor.
Evidence observed (filled by auditor):
-
Non-Conformance Description (filled by auditor):
The unit of certification has not been able to show the Compliance Evaluation Report document on Legislation, Regulations and Other Requirements Related to the Application of RSPO/ISPO as stipulated in the Procedure for Identification and Access to Environmental Regulations and Other Regulations (PL-MR-02).
Root Cause Analysis (filled by organization audited):
There is no PIC yet to evaluate statutory regulations.
Correction (filled by organization audited):
Making Monitoring evaluation of laws and regulations.
Create decree PIC which conducts monitoring of laws and regulations.
Corrective Action (filled by organization audited):
Conduct training for PICs related to making statutory evaluation reports.
Assessor Evaluation and Conclusion (filled by auditor):
Verification date 6 June 2023
The company shows evidence of improvement in the form of:
Decree PIC which conducts Monitoring of laws and regulations with No. ABA/MU/kpts/22/V/2023 on 6 May 2023.
Evaluation of the company's compliance with relevant laws and regulations.
However, the company has not shown evidence, namely:
In corrective action, to be able to complete the document update date and to be sure that the relevant regulations have been evaluated, such as government regulations 35 of 2021, government regulations 36 of 2021, etc.
In terms of corrective action, training has not been shown to the PIC regarding making statutory evaluation reports.
Based on this, the discrepancy in this indicator has not been fulfilled.
Follow up on next audit (filled by auditor):
Verified by :
NCR No. : 2023.03 Issued by : Haikal Ramadhan Kharismansyah
Date Issued : 06 April 2023 Time Limit : Next Surveillance
NC Grade : Minor Date of Closing : 17 June 2023
Standard Ref. &
Requirement
: 2.1.3
Legal or authorized boundaries are clearly demarcated and visibly maintained and there is no planting beyond these legal or authorized boundaries.
Evidence observed (filled by auditor):
The unit of certification has procedures for monitoring and maintaining HGU stakes listed in document No. SPO 12.0 (Rev.02) dated 02 January 2015 which states that monitoring and maintenance of stakes is carried out every semester. Based on the monitoring results of the HGU benchmarks which were last implemented in December 2022, there is information as follows:
Afdeling I → A total of 72 stakes with details of 51 good conditions; broken 9 pieces; and missing 12 pieces.
Afdeling II → A total of 36 stakes with details of 34 good conditions and 2 missing.
Afdeling III → A total of 36 stakes with details of 36 good conditions.
Afdeling IV → A total of 61 stakes, 60 of which are in good condition and 1 is missing.
Afdeling V → A total of 44 stakes with details of 44 in good condition.
Afdeling VI → A total of 58 stakes, 4 of which are damaged and 5 are missing.
Afdeling VII → A total of 66 stakes with details of 3 in damaged condition and 63 in good condition.
Section VIII → A total of 43 stakes, with details of 1 damaged, 20 missing and 22 in good condition.
Afdelin IX → A total of 36 stakes with details of 16 missing and 20 in good condition.
Based on the results of field visits to stakes No. 162 and 163 Afdeling VII; stakes No. 136 and 137 Afdeling; stake No 79 Afdeling VI;
stakes No. 66 and 66A Afdeling V; HGU stake No. 37 Afdeling III and HGU stake No. 31 Afdeling 2 are known to be in good condition according to monitoring results.
Management said that they had made progress on repairing and re-installing missing/damaged stakes and were currently entering the stage of ordering materials for field stake installation. However, up to the time the assessment was completed, documentation related to this matter could not be shown.
Non-Conformance Description (filled by auditor):
The unit of certification has not been able to show sufficient evidence that it has consistently maintained its boundary markers (HGU benchmarks) as stipulated in its own procedures.
Root Cause Analysis (filled by organization audited):
Lack of Unit coordination with the Asset Legal Sub-Section in the Directors' Office, where the maintenance and construction of HGU markers is the responsibility of the Assets Legal Sub-Section in the Directors' office.
Correction (filled by organization audited):
Shows the last Boundary monitoring.
Demonstrate approval of the budget for the maintenance and development of HGU stakes.
Corrective Action (filled by organization audited):
Monitoring the timeline of boundary marker improvement activities.
Assessor Evaluation and Conclusion (filled by auditor):
Verification date 6 June 2023
The company shows evidence of improvement in the form of:
Decree PIC in monitoring the inspection of stakes on 6 May 2023.
Letter of application for the need for new installation or repair of boundary stakes to the Corporate Secretariat Section of the Office of the Directors on May 3, 2023.
However, companies need to evaluate and show evidence, namely:
On the root of the problem, to re-evaluate the root cause of the non-conformity.
In corrective action, to re-evaluate the corrective action taken to adjust the root of the problem that has arisen.
In corrective action, to be able to show monitoring of the timeline for boundary improvement activities.
Based on this, the discrepancy in this indicator has not been fulfilled.
Verification on June 17, 2023
The company has provided evidence in the form of approval for the budget for maintenance and construction of HGU stakes and planned activities for 2023.
Based on this, the discrepancy on this indicator is fulfilled.
Follow up on next audit (filled by auditor):
Verified by : Haikal Ramadhan Kharismansyah
NCR No. : 2023.04 Issued by : Sentot Adi Subandono
Date Issued : 06 April 2023 Time Limit : 05 July 2023
NC Grade : Major Date of Closing : 05 July 2023
Standard Ref. &
Requirement
: 3.6.2
The effectiveness of the H&S plan to address health and safety risks to people is monitored Evidence observed (filled by auditor):