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Summary of Assessment Report of Supply Chain Requirements

Clause (Module D) CPO Mills – Identity Preserved Requirements D1 Definition

D.1.1

A mill is deemed to be Identity Preserved (IP) if the FFB used by the mill are sourced from its own supply base certified to the RSPO Principles and Criteria (RSPO P&C). Certification for CPO mills is necessary to verify the volumes and sources of certified FFB entering the mill, the implementation of any processing controls (for example, if physical separation is used), and volume sales of RSPO certified products. A mill may be taking delivery of FFB from uncertified growers, in addition to those from its own certified land base. If a mill processes certified and uncertified FFB without physically separating the material then only Module E is applicable.

The results of ASA-1 audit showed that the SCCS module for CPO Mill chosen by Leidong West Mill is segregation (standard 2011) or Identity Preserved (standard 2013), but at the time of ASA-2 audit known that the mill received FFB from plantations that have not been certified RSPO since March 2015. The results of interviews and field visits showed that Leidong West Mill is processed certified and non-certified FFB without separating the materials. based on the description found Non conformity No. 2016.01

Status: Non Conformity No. 2016.01 D.2 Explanation

D.2.1

The estimated tonnage of CPO and PK products that could potentially be produced by the certified mill must be recorded by the CB in the public summary of the P&C certification report. This figure represents the total volume of certified palm oil product (CPO and PK) that the certified mill is allowed to deliver in a year. The actual tonnage produced should then be recorded in each subsequent annual surveillance report.

Estimated tonnage of CPO and PK described in the report of RSPO ASA-2.

Status: Comply D.2.2

The mill must also meet all registration and reporting requirements for the appropriate supply chain through the RSPO supply chain managing organization (RSPO IT platform or book and claim).

RSPO IT Platform member registration number: RSPO_PO1000001372

Leidong West Mill did not sell CSPO during the period of May 16, 2015 to February 23, 2016 to outsiders or other units. As for CSPK, there are delivery to PT Sumber Indah Perkasa (Lampung) and PT SMART (Belawan) with details:

Certified Palm Kernel sold to each buyer in the period of May 16, 2015 to February 23, 2015

Date Buyer/Aim Volume (Ton)

April 24, 2015

PT Sumber Indah Perkasa (Lampung)

253.90

April 6, 2015 350.00

May 26, 2015 300.00

June 8, 2015 200.00

June 8, 2015 500.00

June 16, 2015 346.00

May 26, 2015 150.00

June 23, 2015 200.00

July 2, 2015 46.10

June 16, 2015 103.90

June 23, 2015 150.00

July 2, 2015 300.00

SPO – 4006a.7 Page 38

July 28, 2015 250.00

July 8, 2015 350.00

July 15, 2015 150.00

July 28, 2015 500.00

August 5, 2015 304.91

August 26, 2015 50.00

August 5, 2015 195.09

August 11, 2015 450.00

August 26, 2015 300.00

September 2, 2015 400.00

September 8, 2015 450.00

September 15, 2015 424.65

September 23, 2015 200.00

September 15, 2015 75.35

September 23, 2015 200.00

November 5, 2015 124.65

December 15, 2015 39.65

November 5, 2015 125.35

October 6, 2015 200.00

October 20, 2015 350.00

December 15, 2015 PT SMART (belawan) 60.35

January 27, 2016 PT SMART (belawan) 139.650

Total 8,239.65

Status: Comply

D.3 Documented procedures D.3.1

The site shall have written procedures and/or work instructions to ensure the implementation of all the elements specified in these requirements. This shall include at minimum the following:

a. Complete and up to date procedures covering the implementation of all the elements in these requirements;

b. The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements. This person shall be able to demonstrate awareness of the site procedures for the implementation of this standard.

Leidong West Mill has had SOP of RSPO Supply Chain Products of Segregation Model. This procedure of which describes the parties involved in the process of SCCS, duties and responsibilities of each party, the admissions process of FFB, weighing the weight / volume, checking the quality of raw materials, processing, monitoring of processed products and delivery of products.

The results of field visits and interviews at the security post and Weigh bridge known that the workers have known their duties related to SCCS.

Status: Comply D.3.2

The site shall have documented procedures for receiving and processing certified and non-certified FFBs.

Leidong West Mill has had SOP of SCCS as described in the report of ASA-1. The results of field visits, document review and interviews is known that the plant received FFB from the estates that have been certified RSPO and estates that have not received RSPO certificate since March 2015. The procedure owned does not explain how the mechanism for separating certified and non-certified FFB at the time of processing, Based on the explanation is found Non conformity No. 2016.02.

SPO – 4006a.7 Page 39 Status: Non Conformity No. 2016.02

D.4 Purchasing and goods in D.4.1

The site shall verify and document the volumes of certified and non-certified FFBs received.

Verification of certified FFB performed in the Delivery Order Letter (SPB) and the weigh tickets, and it will be recapitulated every day in the daily reports.

Certified and non-certified FFB received in the period of May 16, 2015 to February 23, 2015

Month FFB

RSPO Certified Non Certified Total

May 16, 2015 12,262.90 637.21 12,900.11

June 2015 21,488.12 1,111.51 22,599.63

July 2015 26,380.48 666.96 27,047.44

August 2015 22,128.20 1,034.24 23,162.44

September 2015 22,400.82 1,981.38 24,382.20

October 2015 24,468.88 2,705.13 27,174.01

November 2015 27,221.09 3,242.93 30,464.02

December 2015 26,424.63 3,812.18 30,236.81

January 2016 19,303.40 2,804.34 22,107.74

February 1 to 23, 2016 9,629.77 1,778.06 11,407.83

TOTAL 211,708.29 19,773.94 231,482.23

Status: Comply D.4.2

The site shall inform the CB immediately if there is a projected overproduction of certified tonnage.

Leidong West Mill has informed the Certification Body (CB) when there is excess of certified products as shown by letter No.

001 / MGR / I / 2016 on January 27, 2016 about the reporting of excess production of RSPO-certified products. This letter informed that the production from May 16, 2015 to December 2015 is:

Product type Projection on the certificate attachment (May 16, 2015 to May

15, 2016)

Actual production in the period of May 16,

2015 to December 2015

Projection of production in the period of January 2016

to May 15, 2016

Production Total

FFB 218,784 189,816 81,468 271,284

CPO 49,773 41,248 18,330 59,579

PK 12,580 11,657 4,888 16,545

Excess production in Leidong West Mill because in that period Bukit Perak Mill which is a factory owned by PT Bumi Permai Lestari (BPL) is doing the repairing process so that, FFB from Bukit Perak Estate and Bukit Permata Estate sent to Leidong West Mill.

Status: Comply D.5 Record keeping D.5.1

The site shall record and balance all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK on a three-monthly basis.

Leidong West Mill has had a report that describes the Acceptance of FFB, CPO Production, PK Production, CPO Shipment, PK Shipment and product stocks in Leidong West Mill has been noted the entire of FFB received, CSPO and CSPK production, and shipment of CSPO and CSPK every month. During the period of May 2015 to January 2016 there is no shipment of CSPO and there is PK shipment as much as 8,239.65 tons. This is CSPO delivery during the period of May 2015 to January 2016.

SPO – 4006a.7 Page 40

Period CPO shipment (ton) PK shipment (ton)

RSPO Non Cert ISCC RSPO Non Cert ISCC

May 2015 - - 4,421.470 - 700.000 -

June 2015 - - 5,520.430 2,100.000 - -

July 2015 - - 5,081.980 800.000 - -

August 2015 - - 4,576.560 1,554.910 - -

September 2015 - 989.310 6,228.460 2,269.740 - -

October 2015 - 993.660 5,373.110 600.000 600.000 -

November 2015 - 885.830 5,907.320 - 2,150.000 -

December 2015 - 790.800 4,774.540 715.000 700.000 -

January 2016 - 658.420 2,974.310 200.000 1,000.000 -

Total - 4,318.020 44,858.180 8,239.650 5,150.000 -

Status: Comply D.6 Processing D.6.1

The site shall assure and verify through documented procedures and record keeping that the RSPO certified oil palm product is kept segregated from non-certified material including during transport and storage

Leidong West Mill has had SOP of SCCS as described in the report of ASA-1. The results of field visits, document reviews and interviews known that since March 2015 the mill is received FFB from the estates that have been certified RSPO and estates that have not received RSPO certificate. Leidong West Mill does not separate between RSPO-certified products (CSPO and CSPK) and not during the storage and shipping of products. Based on the explanation is found Non conformity No. 2016.03

Status: Non Conformity No. 2016.01 D.6.2

The objective is for 100 % segregated material to be reached

Leidong West Mill is targeting 100% on processing the FFB from the estate which is certified by RSPO.

Status: Comply

SPO – 4006a.7 Page 41

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