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

PTPN VII PTPN VII

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-1 Assessment

NCR No. : 2020.1 Issued by : Asystasya Aishah Silalahi

Date Issued : 26 October 2020 Time Limit : ASA-2

NC Grade : Minor / Non Critical Date of Closing : 13 July 2021 Standard Ref. &

Requirement : 2.1.2

There is a documented system in place to ensure legal compliance. This system has a means to track changes to applicable regulations, and includes a list and evidence of evaluation of legal compliance by all contracted third parties, including: recruitment agencies, service providers and workers

Evidence observed (filled by auditor):

Company uses a third party to carry out several operational activities, such as the transportation of CPO and maintenance in the nursery area. Then, the company shows the evaluation for the contracted third party. Matters that become the criteria for assessment include standard work quality, work completion, and payment to workers. However, the company does not yet have a list and proof of legal compliance by the contracted third parties.

Non-Conformance Description (filled by auditor):

In this regard, the company has not been able to demonstrate a system to ensure legal compliance, including by all contracted third parties.

Root Cause Analysis (filled by organization audited):

The third party has not showed the regulation compliance related to operational activities.

- No comprehensive vendor evaluation has been carried out.

- There is no special PIC who is responsible for evaluating the implementation of vendor activities Correction (filled by organization audited):

Show evidence of evaluation of the implementation of legal compliance in work activities carried out by third parties.

Corrective Action (filled by organization audited):

- Make a comprehensive monitoring of legal compliance evaluation in the implementation of activities carried out by third parties - Establish a PIC who is responsible for evaluating legal compliance in the implementation of activities carried out by third

parties

Assessor Evaluation and Conclusion (filled by auditor):

Verification on 22 January 2021

The company shows proof of improvement in the form of an Agreement Letter between PTPN IV and PT Wahana Adidaya Pertiwi with agreement number 04.05 / S.Perj / 10 / I / 2020 issued on January 17, 2020. In addition, there is also a document on the technical requirements for the transportation of CPO No. 04.09 / PPABE / MS / 02 / XI / 2019 which describes the transporter's obligations, sanctions, and other requirements including to comply with applicable government regulations.

However, companies need to answer the auditor's questions contained in the root cause analysis, corrections, and corrective actions section. Thus, the nonconformity No. 2020. 2 has not been fulfilled.

Verification on 13 July 2021

The company shows evidence of improvement, including:

- Record of Job Requirements Evaluation Conducted by Vendor a/n CV TS Brother (January 2020 – December 2020 period).

- Records of Job Requirements Evaluation Conducted by Vendor a/n CV Alif Utama (January 2020 – December 2020 period).

In the evaluation record, there is an explanation of the requirements and indicators that must be met in carrying out the work, such

as: minimum wages, BPJS program, implementation of OHS and also the use of PPE. In addition, the company also shows the document of the Decision of the Manager of the Air Batu Business Unit (No.: ABA/MU/Kpts/01/I/2021) regarding the Evaluation Officer for the Implementation of Third Party Work. The document aims to establish a special officer who is responsible for evaluating the results of the implementation of the work of third parties and vendors. The appointed officers consist of 4 people, with details of 1 chairman and 4 members. The decision is effective from January 20, 2021.

Based on the document evidence, the non-conformance is met and will be re-verified regarding the consistency of its application to the onsite assessment.

Verified by : Asystasya Aishah Silalahi & Briyogi Shadiwa

NCR No. : 2020.2 Issued by : Asystasya Aishah Silalahi

Date Issued : 26 October 2020 Time Limit : 11 October 2021 NC Grade : Minor / Non Critical upgrade

to Major / Critical Date of Closing : 27 September 2021 Standard Ref. &

Requirement : 2.2.2

All contracts, including contracts with FFB suppliers, have separate clauses regarding the fulfillment of relevant legal obligations, and can be proven by the third party concerned Evidence observed (filled by auditor):

Based on field observation to nursery area, it is known that there are 5 contractor workers. Based on interviews with maintenance workers in the nursery area, it is known that workers do not have a work agreement with the vendor, the monthly wage is Rp.

2,200,000 (below the provincial minimum wage. Minimum wage of North Sumatera Province year 2020 is Rp. 2,499,031), and has not been included in the social insurance program. Third parties through the company have also not been able to show proof of compliance with regulations, for example: payment of contractor workers' wages, examples of work agreements, and BPJS membership.

Non-Conformance Description (filled by auditor):

Based on this explanation, it is known that the contractor has not been able to show evidence of fulfilling the relevant legal obligations, for example regarding the fulfillment of wages according to the minimum wage, has been included in the BPJS program, contractor workers have work agreements, and other relevant regulations.

Root Cause Analysis (filled by organization audited):

- No comprehensive vendor evaluation has been carried out.

- There is no special PIC who is responsible for evaluating the implementation of vendor activities Correction (filled by organization audited):

- Provides payment of wages to workers, BPJS and agreement of contractors workers.

- Make a memo to the contractor containing compliance with legal regulations.

Corrective Action (filled by organization audited):

- Conduct vendor evaluation

- Assign a designated PIC to conduct vendor evaluation Assessor Evaluation and Conclusion (filled by auditor):

Verification on 22 January 2021

The company provides proof of improvement in the form of proof of payment of Worker Insurance of Tri Bina Karya for the November 2020 period and Worker Insurance of Angkasa payment for the December 2020 period. However, there are still further questions for the evidence correction that have been sent, namely:

- Please explain what activities Tri Bina Karya BHL works for.

- Please explain what BHL “Angkasa” works for.

In addition, companies need to answer auditors' questions contained in the root cause analysis, corrections, and corrective actions section. Thus, the nonconformity No. 2020. 3 has not been fulfilled.

Verification on July 13, 2021

The company shows documents as follows:

- Track record form for goods and services providers for ongoing work. From these documents known that There are several agreement with third parties for upkeep activity, FFB transportation and transportation of EFB as follows CV TS Brother, CV Putra Mandiri, CV Anugrah Cahaya, CV Gas, CV Novita Sari, CV Angkasa, CV Fauan Grup, CV Monsabel Utama and CV Alif Utama.

- List of BPJS details and evidence of payment of BPJS Tri Bina Karya for November 2020. Based on the list of contractors shown, it is known that CV Tri Bina Karya is no longer working with the Air Batu unit.

- List of workers names who are included in BPJS of CV Alif Utama for May 2021.

- Payment slip for May 2021 for 20 nursery workers (no information for which contractor). Based on this document, it is known that the wages of nursery workers for 54 working days are Rp. 2,160,000 (not in accordance with the minimum wage) with a daily wage of Rp. 40,000. Based on information from management, known that the document was a payment in the third week of May.

However, the document informs the number of working days as many as 54 working days.

- Revised May 2021 salary/nursery payment slip for 21 workers (no information for which contractor). Based on these documents, it is known that the wages of nursery workers for 26 working days are Rp. 2,815,000. (data not consistent with previous data) - Evaluation of work done for CV Alif Utama and CV TS Brother vendors.

The company has not been able to show evidence of improvement to previous non-conformities, including payment of wages for contractor workers, samples of work agreements, and BPJS membership for contractors who are still working with the company.

Based on the explanation above, concluded NC No. 2020.03 with minor category upgrade to Major category.

Verification August 18, 2021

The company shows evidence of improvement:

- Evaluation of job requirements carried out by CV Monsabel Utama vendors CV Fauzan Group, CV Angkasa, CV Gas, CV Novita Sari, CV Anugrah Cahaya, CV Putera Mandiri, CV TS Brother, CV Alif Utama in January – December 2020

- Payment slip for nursery wages for May 2021 CV Alif Utama to 21 workers with a wage of Rp. 2,815,000.

- Record of payment of BPJS employment of CV Alif Utama in May 2021 with UNPAID status. Evidence of payment has not been shown

- Work contract for CV TS Brother's FFB transportation activities with 13 workers - CV Alif Utama work contract with 21 workers.

- Payment slip for upkeep work wages for June 2021 CV TS Brother to 8 workers with a value of 2,815,000 - Calibration of wages per person loading FFB in June 2021 CV TS Brother

- Evidence of payment of BPJS Employment of CV TS Brother for maintenance and loading and unloading of FFB on July 30, 2021. Evidence of details of the BPJS for labor has not been shown.

Based on the explanation above, it is concluded that the discrepancy is still open.

Verification September 27, 2021

The company shows evidence of improvement in the form of:

- Evidence of payment for BPJS employent of contractor workers CV Alif Utama along with the details of the workers, totaling 21 workers

- Details of the list of wages and the number of CV TS Brother workers who are included in BPJS employment in July 2021.

Based on the explanation above, NC No. 2020.02 is declared fulfilled and will be observed again during the onsite audit.

Verified by : Asystasya Aishah Silalahi & Rizliani Aprianita Hasibuan

NCR No. : 2020.3 Issued by : Yudhi Yuniarto Tallutondok

Date Issued : 26 October 2020 Time Limit : 11 October 2021 NC Grade : Minor / Non Critical upgrade to

Major / Critical Date of Closing : 27 September 2021 Standard Ref. &

Requirement : 6.7.2.

Accident and emergency procedures in Indonesian language are in place and clearly understood by all workers. Assigned operatives trained in first aid are present in both field and

other operations. First aid equipment is available at worksites. Records of all accidents are kept and periodically reviwed.

Evidence observed (filled by auditor):

1. Hydrant

a. The results of the verification of the Hydrant Inspection document on September 30, 2020, it was found that the tool was in good condition (no leaks) and ready to be used.

b. The results of field observations in fire fighting simulation activities at the Seed Mill Station revealed that the Hydrant was in an unusable condition.

c. The unit of certification shows the procedures for handling emergency and post-emergency situations Number 4.3.16.

December 14, 2013.

2. First aid kit

a. The results of the verification of the First Aid Box Inspection documents that are carried out every month, it is known that all the first aid kits are in complete condition and ready to be used.

b. The results of field observations at the Sterilizer Station showed that the first aid kit was empty.

c. The results of field observations at the Pump Machine found that the first aid kit only contained alcohol.

d. The results of field observations at Capstan Station showed that there was no monitoring of the completeness of the contents of the first aid kit.

e. The results of field observations in Block 19M revealed that the contents of the first aid kit were incomplete (there was no aquadest and eye wash glasses).