Table A: ISSUES CITED IN THE ORIGINAL COMPLAINT. IOI Action Plan (April 28, 2017)

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1 Action by 1 Adequate Standard Operating Procedures (SOPs) that are in compliance with RSPO P&C and national laws and regulations 1.1 Specific SOPs to be developed and/or updated are: July 2017 Completed Documents listed as per requested: A review of IOI Group s Standard Operating Procedures that are intended to ensure compliance with principle 5 of the RSPO Principles and Criteria. While the standard SOPs for HCV, Buffer Zone, Peat and Fire Prevention and Control have been put in place, a detailed methodology in each of the Document title: Rehabilitasi Kawasan 1. Management of Peat and HCV Areas Konservasi (SOP.SNA.RKK.34) Document title: Prosedur Pengelolaan Kawasan Hcv/Nkt (SOP.SNA.HCV.21) 2. Buffer Zones areas Document title: Rehabilitasi Kawasan cited will be further Konservasi (IK-SOP.SNA.RKK.02) 3. Water Table Management enhanced as per the panel s Document title: Standard Operating recommendation Procedure (SOP) Water Management (Final Draft) PT Sawit Nabati Agro 4. Fire Prevention and Control Document title: Prosedur Peringatan Dini Bahaya Kebakaran Lahan dan Hutan (SOP.SNA.PDBK.35) 1.2 The above SOPs must address the specific conditions in the Ketapang Region and be translated into Bahasa Indonesia. 2 Specific training programmes 1.2 Specific training program to be developed and implemented for the following areas, for workers at all levels with specific responsibilities, as well as for contractors: 1. Sustainable peatland management, including peat measurements, monitoring and protection. 2. Management of HCV areas and buffer zones 3. Water management 4. Fauna and flora monitoring General Training Schedule & Program are in place but Management takes the recommendation by the Panel to further enhance our knowledge & skill by the following: 1. Training centre is established and centralized in PT SKS 2. Training matrix for relevant staff will be provided & training conducted accordingly by experts in July 2017 July 2017 The SOPs are completed and translated into Bahasa Indonesia. vember 2017 training schedule: Staff: May - July 2017 Workers: August - Sept 2017 Contractors: Sept 2017 Training for following areas to estate staff and SNA top management have been completed. 1. Sustainable peatland management, including peat measurements, monitoring and protection. 2. Management of HCV areas and buffer zones 3. Water management 4. Fauna and flora monitoring 5.Fire Prevention and Control The training has been conducted by GEC, Flora Fauna Institute (FFI) on July 2017 centralized at PT SKS For legal compliances, briefing on rules and regulations is continuously updated to SNA management. 1

2 Action by 5. Fire prevention and control 6. Legal compliance 3 Availability of all legal permits and licenses relevant for the establishment 3.1 Review and update list of all laws and regulation, including recent government regulations on peat management and protection. 4 Buffer zones 4.1 Procedures for maintenance and monitoring of buffer zones to be strengthened and included in the Integrated Management Plan and its Programme. This should include detailed mapping to identify degraded and non-degraded buffer zone areas to establish baseline for development of monitoring and restoration plan. A detailed chronology of the relevant companies legal compliance to the requirement of Indonesian laws and regulations on the establishment and operation of oil palm plantation for each of the 3 subsidiaries which are the subject of the complaint, to ensure that principle 2 of the RSPO Principles and Criteria has been adhered to. The buffer zone between the plantation and the forest areas is adequate and allows for the protection and conservation of HCV areas. their field: Fire Management, EHS, BMP, Legal Compliance 1. As soon the Indonesian Government s licenses, permits and legal documents are given to us, the HGU will be applied by Management 2. RSPO will be notified on the progress in our quarterly update 3. Update list of law regularly and legal manager to monitor As per our Sustainable Palm Oil Policy, we undertake rehabilitation rather than restoration (to its original state). According to our Integrated Management plan, we have already: 1. A clear target and time frame for peat enrichment and rehabilitation 2. A 3-Years Integrated Management Plan with specific target for the rehabilitation plan. Every quarterly till end of v 2017 Completed & Agreed July 2017 September 2017 As afore-mentioned, IOI can only undertake rehabilitation instead of restoration (to its original state). Training Centre: Permanent Training Centre is currently being built in PT SKS for training facility. Target to be completed: vember 2017 List of law update as of August 2017: PT Sawit Nabati Agro - Daftar Ketentuan Hukum Dan Peraturan Perundangan - Lingkungan Hidup Detailed procedure for maintenance and monitoring of buffer zone to be included in the Integrated Management Plan. The mapping of the buffer zone is in progress and is expected to be completed in September

3 Action by 4.2 Integrated regular patrols (i.e SMART Patrols) to be conducted at PT BSS in buffer zones and HCV areas to provide sufficient data on the threat to, and status of, the area and RTE species, in order for management to respond to actual existing conditions (RSPO P & C indicators and 5.2.4). 5 Peat Management and Mapping 5.1 Map the current peat distribution, peat types and peat properties PT BSS, PT SKS and PT BNS to ensure compliance with recent laws and regulations. Clear mitigations and restoration plans on the peat area that was cleared. On patrolling and monitoring of HCV and Buffer zone areas, a more detailed methodology and guideline (as per IOI s Internal Forest & Wildlife Ranger in Sabah) will be modified to suit the local environment. Plotting and monitoring on vegetation has been done and analysis on its progress will be drafted if necessary. Peat distribution maps : PT. BSS ( ) Available PT. SKS ( )Available PT. BNS ( )Available Peat type maps : PT. BSS ( ) Available PT. SKS ( )Available PT. BNS ( )Available Peat properties maps : PT. BSS (x) In progress PT. SKS ( ) Available PT. BNS (x) In progress Immediate Completed SMART Patrolling has been initiated in SNA Group. On July 2017, Flora Fauna Institute (FFI) has been engaged to give training to sustainability and estate management on SMART methodology (theoretical and practical). Prior to this, equipment on SMART patrolling were purchased (system software, GPS etc) and second round of SMART patrolling training with real ground implementation will be done in September 2017 with FFI personnel to assist in the implementation. July 2017 Completed Completed October 2017 Following the new regulations by Kementerian Lingkungan Hidup dan Kehutanan, water zonation and topographic map for peatland area need to be done. Prior to this, as part of IOI initiative on peatland mapping, we engaged a consultant to assist in conducting a survey of peatland areas in all our PT. Even though some data such as peat distribution, peat types, etc. are already available, we continue to have our data updated. The consultant s first assessment was done in August 2017 in SNA. Due to the nature and coverage of the wide work scope, the expected time frame given by the consultant to finish the data compilation is until end of the year

4 Action by 5.2 Ensure availability of accurate topographic maps to identify peat dome areas, and thus construct water zonation. Clear mitigations and restoration plans on the peat area that was cleared Topographic maps and water zonation maps : PT. BSS ( ) Available PT. SKS (x) In progress PT. BNS ( ) Available July 2017 October 2017 New Law on water zonation MLHK P14, P15, P16 came into force in Feb Restoration of deep peat areas in PT BSS to: - be fully verified and possible peat areas in PT BSS to be identified on a map; - map existing areas planted on peat soil; - establish plan of water zonation. 5.4 Standard Operating Procedures on Peat Restoration and Management to include: (refer 1.1 above) - a standardized size of seedling such as a minimum height of seedling; - number of species per ha; - number of trees per species per ha; - other parameters which will ensure low mortality rate and good growth rate; - stages of restoration to decide which area should commence with pioneer seedlings first, then the native forest tree species, and which area should be planted with native forest tree species depending on the A review of IOI Group s Standard Operating Procedures that are intended to ensure compliance with principle 5 of the RSPO Principles and Criteria. Rehabilitation of 141 ha in PT BSS has commenced and being closely monitored. The area has been mapped and turn into conservation area Detailed methodology in our SOP will be enhance as per panel s recommendation July 2017 July 2017 Verification of rehabilitation of deep peat areas in PT BSS has been completed Mapping of peat areas (planted and not planted) have been completed Completed and translated into Bahasa Indonesia. Continuous work done to rehabilitate and conserve the 141 ha in PT BSS. Establishment of water zonation according to the new enforce law will be done by internal SNA with assistance from external consultant. As per our policy, peat rehabilitation rather than peat restoration (especially for deep peat) is being undertaken Documents listed as per requested: Document title: i. Pembibitan Tanaman Hutan Rawa Gambut (IK- SOP.SNA.PHT.01) ii. Pembibitan Tanaman Hutan Rawa Gambut (SOP.SNA.PHT.30) 4

5 Action by patch condition of the area to be restored; - The SOPs require clear methodology sections for monitoring and minimum data/parameters to be recorded/sampled. 5.5 Technical training for staff on managing and restoring peat areas. Clear mitigations and restoration plans on the peat area that was cleared Training will be provided to enhance knowledge of our staff vember 2017 Training scheduled Staff: May - July 2017 Workers: July - Sept 2017 Technical training to the staff on mitigation and rehabilitation of peat area has been conducted by GEC in July Besides theoretical training in class, ground practical training also been conducted by GEC. 6 Others Contractors: Sept To ensure that the mill site planned for PT BSS does not adversely impact the HCV areas, including adopting appropriate care to prevent effluents and emissions polluting the HCV area. The buffer zone between the plantation and the forest areas is adequate and allows for the protection and conservation of HCV areas While KPAM is not part of the ToR, we appreciate the panels suggestions and will take it under consideration. For information, our HCV assessment for KPAM has been sent to HCVRN in May 2017 Continuously monitoring. Agreed This is still in proposal stage. However, the planning of the mill location will be done thoroughly with consideration on HCV areas. 5

6 Table B: ISSUES NOT CITED IN THE ORIGINAL COMPLAINT Action by 1 Adequate Standard Operating Procedures (SOPs) that are in compliance with RSPO P&C and national laws and regulations 1. Landscape Management Plan July The nature of this recommended action is ongoing and be continuously monitored. 2. timeline by CP is not applicable. t in Original Complaint Landscape management plan is an initiative of IOI Group to contribute to the conservation and rehabilitation efforts along with multistakeholders in Ketapang area. The first draft of concept document has been developed by GEC and continuous engagement has started. Updates on this plan was agreed by Aidenvironment, Wetlands International as well as local government and communities to participate. First stakeholders meeting for the Landscape Management Plan is proposed by Aidenvironment in mid September in PT SKS. 2. Operation of Plasma Documents listed as per requested: Document title: Standard Operating Procedure (SOP) Panduan Pelaksanaan Kemitraan is available and translated in Bahasa Indonesia 2 Management structure of the company 2.1 Adopt measures to address the high turnover of staff, including filling in vacant staff positions. 2.2 Ensure recruitment of qualified staff in area of biodiversity and forest management to support the implementation of the required SOP s and action plan. t in Original Complaint To maintain and retain our worker, we have already started to improve the living facilities of our workers, set up clinic and sport facilities, improve road conditions, provide transportations, for their children to go to school as well as providing more training to help upgrade the workers skills and knowledge. vember Vacancies have been filled. Measures to address high turnover have been taken. 2. October 2017 To date, SNA sustainability team comprises of 13 personnel. Another 1 staff recently joined on August 2017 to lead on SMART patrolling. The Sustainability team are assisted by estate management in fire patrolling, maintenance of water management and also supervising sensitive areas (HCVs, conservation areas, fire prone etc) The recruitment is based on qualification and continuous training programme (internal and external) has been developed to reduce knowledge gaps and increase competency among the staff. 6

7 Table B: ISSUES NOT CITED IN THE ORIGINAL COMPLAINT Action by 3 Buffer zones 3.1 Restoration and detailed restoration plan for buffer zones in Sungai Buluh, Sungai Air Hitam and Kendawangan. t in Original Complaint Rehabilitation work for buffer zone of our adjacent area in Sungai Buluh, Sungai Air Hitam and Kendawangan to be developed and implemented. vember 2017 Detailed rehabilitation plan can be completed in September 2017 The rehabilitation of the buffer zone will require discussions and cooperation from the villagers to address this issue Detailed rehabilitation plan for buffer zones which include Sg Buluh, Sg Air Hitam and Muara Kendawangan will be incorporated in the update Integrated Management Plan. GEC will assist to provides information and assessment in their next visit in September

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