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

4. Controlling of Certificate and Trademark, including withdrawing inappropriate

3.4 Identification of Findings, Corrective Action, Observations, Opportunity for Improvement and Noteworthy Positive Components

3.4.1. Identification of Findings, Corrective Actions and Observations at ASA-4 Certification Assessment

NCR No. : 2019.01 Issued by : Steve Mualim

Date Issued : 26 January 2019 Time Limit : ASA-1.1

NC Grade : Major Date of Closing :

Standard Ref. &

Requirement :

7.3.1

There shall be evidence that no new plantings have replaced primary forest, or any area required to maintain or enhance one or more High Conservation Values (HCVs), since November 2005. New plantings shall be planned and managed to best ensure the HCVs identified are maintained and/or enhanced (see Criterion 5.2).

Non-Conformance Description & Evidence observed (filled by auditor):

PT Satya Kisma Usaha has conducted disclosure of liability and LUC analysis in accordance with RSPO template on December 14, 2015. During 2016-2019 periods, company shown intensive communications to RSPO compensation panel. Until ASA-4.

Company is not able to shown evidence that RaCP for PT SKU has been approved by RSPO.

Root Cause Analysis (filled by organization audited):

PT SKU has followed up the RaCP procedure since 2015 namely conduct the disclosure of liability, LUC analysis on 2016 – present. Intense communication with the reviewer of RSPO also has been done by the company, last communication is on 2 Jan 2019 by sending email to RSPO regarding the LUC analysis and concept note, the RSPO has been response on 8 Jan 2019 with statement of “will reviewed immediately”

In the previous surveillance audit, against the PT SKU has raised an observation namely to confirm the RaCP process to RSPO and it was mentioned that the P.7.3 were comply and can be continued the certificate. Up to ASA – 4, since the company has do confirmation to RSPO, then the management are confident to conduct the surveillance audit.

Correction (filled by organization audited):

The management unit was sent the email to RSPO on 28 Jan 2019 to gather information and statement related to P.7.3 compliance.

Corrective Action (filled by organization audited):

Continuously communication to RSPO in regards of RaCP process, the confirmation should done at least one month before next audit.

Assessor Evaluation and Conclusion (filled by auditor):

Verification on 25 Feb 2019.

The management unit shows the evidence of communication to RSPO regarding the LUCA follow up of PT SKU, the communication are done through email on 28 Jan 2019 and 1 Feb 2019, respectively. And on 20 feb 2019 the compensation panel has response the email with statement that the RSPO is on process to review the LUCA.

Verification on 26 April 2019

The RSPO has explained through email on 25 April 2019, stated that “based on RSPO internal discussion, agreed that NC raised on PT SKU can be left open until the next audit next year. We do hope that the process of completing the RaCP can be completed by then. Monitoring of the progress needs to be conducted closely to ensure you can meet the timeline."

Verification on Recertification & ASA-1 (9 April 2021)

On March 26, 2021 RSPO sent an email to CB along with the RSPO Compliance Advisory letter No: 0002/03/21 Assurance - Integrity dated 25 March 2021. The document shown explains that the company units under GAR are going through the LUCA review process or the concept of Note RaCP, whether units that have been certified or not yet certified, the validity period of the advisory Note and others. Compliance Advisory was recommended by Wan Muqtadir Wan Abdul Fatah as Senior Manager of Integrity on March 24, 2021 and approved by Tiur Rumondang as Assurance Director on March 25, 2021. Briefly the contents of.

Compliance Advisory as follows:

The approval to continue with certification can only be done for the unit of certification that will be expiring in the next six months from the issuance of this Advisory Note. The NC that is raised will be allowed to be open until the next surveillance/recertification audits.

 For the other units that have expiring license from October 2021 onwards would need to continue its follow-up with RSPO on the RaCP status and completion continuously. Those units will be evaluated again on its progress.

 For any unit that is at the initial certification stage, issuance of a certificate can only be done after the compensation plan has been approved.

Based on the evidence above, this non-conformity is allowed to open until Next ASA and will be re-verified during the ASA-1.1 audit.

Verified by : Moh Arif Yusni .

3.4.2. Identification of Findings, Corrective Actions and Observations at Re-Certification Assessment

NCR No. : Issued by :

Date Issued : Time Limit :

NC Grade : Date of Closing :

Standard Ref. &

Requirement

: Evidence observed (filled by auditor):

DURING THE AUDIT RC, THE AUDITOR TEAM DOES NOT IDENTIFY ANY NC WITH THE RSPO REQUIREMENTS Non-Conformance Description (filled by auditor):

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):

Verified by :

3.4.3. Opportunity for Improvement

No Ref. Std. Description

1 3.4.3

(C) Social and environmental management and monitoring plans are implemented, monitored and updated periodically in a participatory manner.

The results of document verification and interviews with management show that SIA management and monitoring review activities are carried out every 2 years and the last one was carried out in October 2019.

One of the objectives of the review is to propose improvements to the social impact management and monitoring plan to be implemented by PT SKU's units in the next period.

Based on the results of document review, field visits and interviews with management, it was found that there were several notes / issues in the area / around the company's operations that could have a social impact but had not yet been included in the social planning and management documents, for example:

 Unlicensed gold mining activities around the Kelola KILE area

 Existence of enclaves / community areas within or around the company's operational areas, for example in SBNE Division 4 and KILE division 1

 Productivity of BHB (Borongan Daily Workers) with regard to compliance with the minimum wage regulations in the SBNA

 Limited external respondents in the review of the social impact management plan (only involving village officials)

Related to this, the company will be encouraged to ensure that all identified issues / records in the area / surrounding of the company's operations have been managed and monitored as well. and representation of samples for wider external parties, such as involving local communities, migrants, enclaved land owners, women, age representatives and affected parties.

2 3.6.1

(C) All operational activities risks assessed to identify the H&S issues. Mitigation plans and procedures are documented and implemented.

The results of field visits, document review and interviews with workers at SBNE, SBNA and KILE revealed that there were HCV monitoring activities, area security patrols, fire patrols, and aerial fertilization. With regard to OHS risk mitigation, these activities have been contained in work procedures, and the results of interviews were also obtained that workers had understood the procedures regarding OHS such as the use of PPE, safety riding, OHS inspection and safety induction before doing activities. However, the HIRAC review document on February 2, 2020 at SBNE / SBNA and January 2, 2021 at KILE, the risk analysis of these activities has not been explained in detail. Based on the explanation above, the certification unit has the opportunity to carry out a comprehensive evaluation to identify and mitigate all plantation operational activities and the mill has been listed in the HIRAC document.

3 4.4.1

(C) There are documents that show legal ownership or lease, or customary land use permits granted by customary landowners (ulayat) through an FPIC process. There are documents relating to the history of land ownership and actual legal or customary use.

The total certification area at PT SKU is 4,887.61 Ha, consisting of 3,825.03 Ha of core area and 1,062.58 Ha of smallholder scheme area with a full-managed scheme. Of the total area, up to this assessment only 1,412.55 hectares have land rights documents (HGU) and an area of 3,535.53 hectares is currently in process. The latest development presented to the auditors was the issuance of Certificate No. 525/140 / Disbunnakan / 2021 dated January 26, 2021 from the Regent of Tebo Regency regarding the information on uncontrolled land and not in public interest, which explained that following up the letter from the company No. / SKU / JMBO / II / 2020 dated March 20, 2020. In this regard, according to the RSPO announcement dated April 1, 2020 concerning the RSPO Update: Statement on Business Use Rights, it is explained that for Recertification and Surveillance audits, the Certification Unit can continue their certification as long as

there is sufficient concrete evidence that the company has taken steps to obtain HGU and must comply with all requirements at that time. In this regard, the positive developments in the acquisition of HGU will be verified again in the following year.

4 5.2.1 The certification unit consults with interested farmers (regardless of farmer type), including women smallholders or other supply partners, to assess their need for support for improved livelihoods and their interest in pursuing RSPO certification.

In an effort to support the improvement of farmers' livelihoods and their participation in the sustainable palm oil value chain, the certification unit has conducted consultations with farmers who are suppliers of FFB, for example on 18 January 2020 and 21 January 2020 where one of the issues discussed was related to the program. The certification carried out by the company includes its benefits, but in the minutes of the activity, it has not yet discussed in detail the RSPO certification program, including the interest in following RSPO certification (including RSPO standards for independent smallholders). Based on this explanation, the certification unit has the opportunity to make improvements related to efforts to encourage the interest of farmers who are suppliers of FFB (both directly and indirectly) in participating in RSPO certification.

3.4.4. Noteworthy Positive Components

No Description

1 The Company's commitment to implementing sustainable palm oil management 2 Teamwork and presentation of documents that are quite good during the audit process 3 Has received RSPO, ISPO and ISCC certificates

4 Since 2019-2020 there have been no zero accidents in all PT Satya Kisma Usaha units.

3.5 Summary of Arising Issues from Public and Auditor Verification