3.4 Identification of Findings, Corrective Action, Observations, Opportunity for Improvement and Noteworthy Positive Components
3.4.3. Opportunity for Improvement
No Ref. Std. Description
1 2.1.1 The unit of certification complies to relevant regulations.
Regarding Hazardous Storage it is known that Teluk Bakau Estate, Nusa Lestari Estate, Nusa Perkasa Estate, Rotan Semelur Estate, and Mandah Estate already have Hazardous Storage Permits as stated in DPMPTSP Decree of Indragiri Hilir Regency Number 503/DPMPTSP-IPSL.B3/2 dated 15 March 2018 The permit is valid for 5 years from the date of stipulation, namely until 2023. The types of waste that are allowed to be stored according to the permit are in the form of; used oil, used batteries, used filters, used TL lamps, used rags, contaminated waste, and used hazardous packaging. Based on interviews with management, the company will extend the permit as well as add infectious medical waste items to the permit.
Therefore, companies are encouraged to ensure that the permit is in accordance with the type of waste that is allowed to be stored.
2 3.7.1 A documented programme that provides training is in place, which is accessible to all staff, workers, scheme smallholders, and outgrowers taking into account gender-specific needs, and which covers applicable aspects of P&C Principles, in a form they understand and includes assesment of the training.
Mandah Factory already has 4 Boiler Operators (steamers) where 2 of them already have Class 1 K3 licenses. Related to this, the company has registered operators who do not yet have licenses for K3 license certification (3 people) as stated in a statement from PJK3 PT Arpindo Multi Utama January 19, 2023 regarding K3 license registration. Based on the letter, the training plan will be held in May and August 2023.
Based on this, companies are encouraged to have licensed operators according to applicable regulations.
3 3.8.16 Registration of Transactions
i. Shipping Announcement in the RSPO IT platform shall be carried out by the mills when RSPO certified products are sold as certified to refineries, crushers, and traders not more than three months after dispatch with the dispatch date being the Bill of Lading or the dispatch documentation date.
ii. Remove: RSPO certified volumes sold under different scheme or as conventional, or in case of underproduction, loss or damage shall be removed in the RSPO IT platform.
Based on documents verifications it was known there were shipping announcements issued more than three months since the product was dispatched, for example, a shipping announcement with transaction id TR- e405db19-9683 on 19 October 2022 where the product shipped on 03 June 2022 (shipping announcement was issued after 4 months and 16 days since the product dispatch)
Regarding those situations, the management has identified the issues with the carried-out meeting between the SQM department and the Global Trade Marketing (GTM) department on 09 January 2023 with the conclusions of the meetings are:
SQM department monitoring CPO & PK sales at the Mill as well as declarations on the Palm Trace IT platform every 3 months
SQM department coordinates with GTM Department Jakarta regarding RSPO-certified products that are produced and sold on the Palm Trace IT platform every 3 months via email
GTM Department Jakarta will remove RSPO-certified volumes that are sold under other schemes, conventionally or if there is a shortage of production, and will inform if there are certified products allocated as credit sales
No Ref. Std. Description
GTM Department Jakarta sends evidence of products that have been removed or allocated as credit sales on the Palm Trace IT platform to the Dept. SQM by Email.
Regarding this situation the company encouraged to ensure shipping announcement issued not more than three months since the product dispatch.
4 6.2.4 The unit of certification provides adequate housing. Sanitation facilities, water supplies, medical, educational and welfare amenities to national standards or above, where no such public facilities are available or accessible. In the case of acquisitions of non-certified units, a plan is developed detailing the upgrade of infrastructure. A reasonable time (5 years) is allowed to upgrade the infrastructure.
At the time the audit assessment was carried out, the company was able to show progress in the “1,000 Door Permanent Housing Development Program” which had been planned from 2022 to 2028. This progress could be proven since the previous assessment, where in 2022 to January 2023 the condition of workers' homes had experienced a lot of repairs and in 2023 to 2028 new constructions have been planned to replace the old house with the following description:
● For the period 2022 to 2023 (January) 153 new permanent houses have been built to replace semi- permanent and wooden houses whose conditions are damaged.
● In the 2023 period (January-December) it is planned to add 66 permanent houses of the G6 type (11 G6 units) in each unit with the following description, 4 G6 units in Rotan Semelur Estate, 4 G6 units in Mandah Estate, and 3 G6 units in Mandah Factory.
● In the 2024-2028 period it is planned to add as many as 228 permanent houses of the G6 type (a total of 38 G6 units), in each unit with the following description, 4 G6 units in Rotan Semelur Estate, 30 G6 units in Mandah Estate, and 4 G6 units in Mandah Factory.
Based on the results of field visits and interviews with residents of housing and workers in each unit, it is known that workers have known since 2022 that the company has a "1,000 Door Permanent House Development Program" which is planned to be completed in 2028 and is currently still in stages for construction. Currently there are still a number of old houses (semi-permanent and wooden) whose condition has started to deteriorate, but the residents of the housing understand this well because the new permanent houses are still being gradually realized by the company. The company is also still making makeshift repairs to the damaged houses, at least ensuring that workers can still live in them until they get a new house.
The company has the opportunity to ensure that the realization of new housing construction in all units runs according to a predetermined timeframe.
5 6.2.7 Permanent fulltime employment is used for all core work performed by the unit of certification.
Casual, temporary and day labour is limited to jobs that are temporary or seasonal.
At the time the audit was carried out the company still had contract workers (PKWT) as much 129 out of 2,139 total workers at PT Bhumireksa Nusasejati. There are still 2 contract workers (PKWT) who work in permanent jobs (harvesting) at Mandah Estate. Apart from the 2 contract workers with PKWT status, the rest are contract workers (PKWT) who work in jobs that are not permanent/seasonal, such as TBM (Immature Plants) maintenance work and in replanting activities (planting and upkeep). In contrast to the previous assessment, when using PKWT for permanent work (harvesting), the company has currently made a proposal to appoint contract workers (PKWT) to permanent workers (SKU/PKWTT) simultaneously when workers start work. This is done so that the contract workers (PKWT) immediately become permanent workers (SKU/PKWTT) after the agreement period ends (3 months).
No Ref. Std. Description
The results of interviews with management stated that every PKWT worker employed in (permanent) harvest work, since the previous assessment, will always be submitted for appointment to become permanent workers (SKU/PKWTT) with an estimated time of around + 3 months after undergoing the contract period (PKWT contract validity period is 3 months). at the company. If this is considered and reviewed, there has been a significant improvement in the use of contract workers (PKWT) by the company since the previous assessment. But the use of contract workers (PKWT) is still used in work that is permanent (harvesting).
The company has the opportunity to ensure that the use of contract workers (PKWT) is no longer used for permanent jobs (harvesting) in accordance with the provisions stipulated in Government Regulation No. 35 of 2021 so that in the next assessment the recruitment system for permanent jobs is appropriate.