Roundtable on Sustainable Palm Oil

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1 Roundtable on Sustainable Palm Oil Annual Surveillance Audit Report Report no.: ASA2_ Surveillance assessment against the RSPO Principles & Criteria Indonesia National Intepretaion (INA-NI) year 2008 and RSPO SCCS year 2011 (including scope extension) Name of client Wilmar International Limited PT Kerry Sawit Indonesia Head Office : Multivision Tower 12 th floor, Jl. Kuningan Mulia Kav.9B, Guntur, Setiabudi Village, Kuningan Sub District, South Jakarta District, DKI Jakarta Province, Indonesia Representative Office : Jl. Jenderal Sudirman Km. 62, Sampit-Pangkalan Bun, Seruyan District, Central Kalimantan Province, Indonesia Date of assessment : May 13 to 17, 2013 Report prepared by : Hendra Fachrurozy (RSPO Lead Auditor) Certification decision by : Manfred Herbert Lottig (COO TUV Rheinland Malaysia) Certification Body: TUV Rheinland Malaysia Sdn. Bhd. No , Jalan Perindustrian USJ 1/6, Taman Perindustrian USJ 1, Subang Jaya, Selangor Darul Ehsan, Malaysia. Tel: Fax:

2 TABLE OF CONTENTS 1.0 SCOPE OF ANNUAL SURVEILLANCE AUDIT National Interpretation Used Type of Assessment Certification Details Location and Maps Organisational Information / Contact Person Description of Supply Base Actual production volumes, tonnages and projected outputs Dates of Plantings and Replanting Cycles Area of Plantation (Total, Planted and Mature) Progress Against Time Bound Plan Compliance to Rules for Partial Certification Progress of associated smallholders or outgrowers towards RSPO compliance Approximate Tonnages Certified ASSESSMENT PROCESS Certification Body Qualifications of Lead Assessor and Assessment Team Assessment Methodology & Agenda ASSESSMENT FINDINGS Summary of Findings Status of Previously Identified Non-conformities Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions Description of Supply Chain Management System Status of Previously Identified Non-conformities Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions Noteworthy Positive Component Conclusion and Recommendation for RSPO P & C and Supply Chain Certification Issues Raised by Stakeholders and Findings Pertaining to Issues CERTIFIED ORGANISATION S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY Date of Next Surveillance Visit Acknowledgements of Internal Responsibility and Formal Sign-Off by Client APPENDICES Appendix 1: List of Abbreviations Appendix 2 : List of Stakeholders Interviewed and Contacted Appendix 3: Observations and Opportunities for Improvement... 42

3 Page 3 of SCOPE OF ANNUAL SURVEILLANCE AUDIT 1.1 National Interpretation Used The operations of the palm oil mill(s) and its supply base of FFB were assessed against the National Intepretation Indonesia year 2008 of the RSPO Principles & Criteria and RSPO SCCS November Type of Assessment The annual surveillance assessment was carried out on 2 mill and 3 estates under PT Kerry Sawit Indonesia owned by Wilmar International Limited. The date of certification of this unit was June 18, 2011 valid until June 17, The scope of this has been extended to include 1 mill i.e PT Kerry Sawit Indonesia mill 2 (POM2). 1.3 Certification Details The details of RSPO certification of PT Kerry Sawit Indonesia area as per the table below Table 1: RSPO Certification details of PT Kerry Sawit Indonesia RSPO Membership no.: RSPO Certificate no.: Date of first RSPO certificate & validity: June 18,2011 & validity : to Date of certification audit: December 06 to 12, 2010 Date of previous surveillance audit: March 27-31, 2012 Date of revised RSPO certificate & validity (if applicable): CPO tonnages claimed: PK tonnages claimed: Not applicable 51,656 ton 9,392 ton

4 Page 4 of Location and Maps Figure 1: Location map of PT Kerry Sawit Indonesia in Seruyan District, Central Kalimantan, Indonesia

5 Page 5 of 43 Table 2: GPS locations for all estates and mills included in annual surveillance assessment Name of mill / estate PT KSI Mill 1 PT KSI Mill 2 KSI 1 Estate KSI 2 Estate KSI 3 Estate Location Danau Sembuluh I Village, Danau Sembuluh subdistrict, Seruyan district, Central Kalimantan, Indonesia Tebiku Village, Seruyan Raya subdistrict, Seruyan district, Central Kalimantan, Indonesia Jenderal Sudirman Km. 62 Road, Sampit-Pangkalan Bun, Seruyan district, Central Kalimantan, Indonesia Jenderal Sudirman Km. 62 Road, Sampit-Pangkalan Bun, Seruyan district, Central Kalimantan, Indonesia Jenderal Sudirman Km. 62 Road, Sampit-Pangkalan Bun, Seruyan district, Central Kalimantan, Indonesia GPS locations Latitude Longitude S E S E S E S E S E 1.5 Organisational Information / Contact Person Contacts details of the company are as follows: Company Name: Address: PT Kerry Sawit Idonesia Jenderal Sudirman Km. 62 Road, Sampit-Pangkalan Bun, Seruyan district, Central Kalimantan, Indonesia Contact Person: Mr. Tan Tong Sin Telephone: tst@wilmar.co.id 1.6 Description of Supply Base Table 3 : FFB Supply Information for PT Kerry Sawit Indonesia Mill (POM1 & POM2), year 2012 and year 2013 FFB Contributors PT Kerry Sawit Indonesia Mill 1 Company owned estates : FFB supplied Year 2012* FFB supplied Year 2013** Tonnes % Tonnes % Kerry Sawit Indonesia 1 estate 95, , Kerry Sawit Indonesia 2 estate 76, , Kerry Sawit Indonesia 3 estate 41, , Other Wilmar estate : Sub Total 214, , Mustika Sembuluh 1 estate Mustika Sembuluh 2 estate 3, Rimba Harapan Sakti 1 estate , Rimba Harapan Sakti 2 estate 71, ,

6 Page 6 of 43 FFB Contributors FFB supplied Year 2012* FFB supplied Year 2013** Tonnes % Tonnes % Sarana Titian Persada 1 estate , Sarana Titian Persada 2 estate Sarana Titian Persada 3 estate Sub Total 4, , Total 218, , PT Kerry Sawit Indonesia Mill 2 Company owned estates : Kerry Sawit Indonesia 1 estate , Kerry Sawit Indonesia 2 estate , Kerry Sawit Indonesia 3 estate ,435, Sub Total , Other Wilmar estate : Mustika Sembuluh 2 estate , Sarana Titian Persada 1 estate Sub Total , Total , Note : *). January to December 2012 **). January to April Actual production volumes, tonnages and projected outputs. Table 4 : Certified tonnages claimed, certified tonnages purchased or sold, total and projected CPO and PK production from PT Kerry Sawit Indonesia Amount (MT) CPO PK Certified tonnages claimed 51, , Certified tonnages sold - - Certified tonnages purchased - - Actual Production** 49, , Conversion Factor year 2012 (average) OER : KER : 4.38 Projected output for next 12 months (budget 2013)*** 86, , Note : **) CPO & PK Production from PT Kerry Sawit Indonesia mill 1 (POM 1)

7 Page 7 of 43 ***) Budget of CPO & PK production in year 2013 for both of mill (POM 1 : CPO = 50,328 tonnes and PK = 9,961 tonnes; POM 2 : CPO = 36,639 tonnes and PK = 6,372 tonnes). 1.8 Dates of Plantings and Replanting Cycles The company follows a replanting cycle of 25 years. Information on the dates of plantings is as per the table below. Table 5 : Age and year of plantings of company estate supplying to PT Kerry Sawit Indonesia Age & Year of Plantings Oil palm planted area at each estate(ha) KSI 1 KSI 2 KSI ( ) ( ) 5, , , TOTAL 5, , , Company has no replanting plan because all plantation in PT KSI still young, as seen on the above information. 1.9 Area of Plantation (Total, Planted and Mature) Table 6 : Oil Palm Planted Area Summary, FFB Production and Average yield/ha for PT Kerry Sawit Indonesia Estate Name Oil Palm Mature Immature FFB Production* Total area Average Planted area (Production) (Non-production) (ha) yield/ ha (ha) area (ha) area (ha) (tonnes) KSI 1 7, , , , KSI 2 6, , , , KSI 3 5, , , , TOTAL 18, , , , * Period of January to December 2012 and total estate production, not all production FFB supply to KSI mill. Table 7: Land use data for PT Kerry Sawit Indonesia Estate Name Total area (ha) Oil Palm Planted Area (ha) HCV/ Potential HCV areas (ha) Housing, Road, Drainage, Nursery Land used for other purposes (ha) Land Clearing & unplanted Area Manageagement* Not plantable area** Mill Enclave*** KSI 1 7, , KSI 2 6, , KSI 3 5, , TOTAL 18, , , , Note : *) The company on their own initiative to allocate additional area as HCV areas **) Consist of sand, swamp, pond, burial and production forest areas ***) Include of overlap areas with PT Selonok Ladang Mas (PT SLM) (± 720 ha) 1.10 Progress Against Time Bound Plan Table 8 : Time Bound Plan of the Other Management Units Name of Holding Location Time bound plan for certification Remarks PT Perkebunan Milano North Sumatra 2009 certified

8 Name of Holding Location Time bound plan for certification Page 8 of 43 Remarks PT Mustika Sembuluh Central Kalimantan 2009 certified PT Tania Selatan South Sumatra 2010 certified PT Kencana Sawit Indonesia West Sumatra certified PT Kerry Sawit Indonesia Central Kalimantan 2010 certified PT Agro Masang Plantation (AMP) West Sumatra 2011 certified PT Primatama Muliajaya West Sumatra 2011 certified PT Bumi Sawit Kencana Central Kalimantan 2012 Planned PT Sarana Titian Permata Central Kalimantan 2012 certified PT Buluh Cawang Plantations South Sumatra 2012 Main Assessment completed PT Agro Nusa Investama (Sambas) West Kalimantan 2012 Planned PT Daya Labuhan Indah North Sumatra 2013 Main Assessment completed PT Citra Riau Sarana Riau 2013 Planned PT Gersindo Minang Plantations West Sumatra 2013 Main Assessment completed PT Permata Hijau Pasaman West Sumatra 2013 Planned PT Mentaya Sawit Mas Central Kalimantan 2013 Planned PT Pratama Prosentindo West Kalimantan 2013 Planned PT Putra Indotropical West Kalimantan 2013 Planned PT Sinarsiak Dianpermai Riau 2013 Planned PT Agro Nusa Investama (Landak) West Kalimantan 2014 Planned PT Murini Sam Sam Riau 2014 Planned PT Agro Palindo Sakti South Sumatra 2013 Planned PT Musi Banyuasin Indah South Sumatra 2014 Planned PT Karunia Kencana Permaisejati Central Kalimantan 2014 Planned PT Agro Palindo Sakti West Kalimantan 2014 Planned PT Daya Landak Plantation West Kalimantan 2014 Planned PT Indoresins Putra Mandiri West Kalimantan 2014 Planned There are several changes to the company s timebound plan due to some reason such as : 1. PT Bumi Kencana Sawit, some social issues still not resolved and community still not agree with the company s proposed Memorandum of Understanding (MoU) regarding conflict resolution process according to RSPO criteria.

9 Page 9 of PT Sinarsiak Dian Permai, PT Citra Riau Sarana, PT Mentaya Sawit Mas, due to some social issue and land legality still not finished. 3. PT Asiatic Persada has been sold to other company and not belong Wilmar International Plantation 1.11 Compliance to Rules for Partial Certification Compliance of the uncertified management units of Wilmar Plantation Limited against the rules for partial certification according to RSPO Certification System clause was assessed by submission self assessment report. A summary of findings is as stated below. Partial Certification Requirements (a) The parent organization or one of its majority owned and / or managed subsidiaries is a member of RSPO. (b-d) A challenging time-bound plan for certifying all its relevant entities is submitted to the Certification Body (CB) during the first certification audit. The time-bound plan should contain a list of subsidiaries, estates and mills. Any revision to the time-bound plan or to the circumstances of the company shall cause the plan to be reviewed. for whether it is still appropriate, such that changes to the timebound plan are permitted only where the organisation can demonstrate that they are justified (e) No replacement of primary forest or any area identified as containing High Conservation Values (HCVs) or required to maintain or enhance HCVs in accordance with RSPO criterion 7.3. Any new plantings since January 1st 2010 must comply with the RSPO New Plantings Procedure (f) Land conflicts, if any, are being resolved through a mutually agreed process, e.g. RSPO Grievance procedure or Dispute Settlement Facility, in accordance with RSPO criteria 6.4, 7.5 and 7.6. (g) Labour disputes, if any, are being resolved through a mutually agreed process, in accordance with RSPO criterion 6.3. (h) Legal non-compliance, if any, are being resolved in accordance with the legal requirements, with reference to RSPO criteria 2.1 and 2.2. Audit Findings Wilmar International Indonesia is RSPO member with membership number See table above, there were some changes on company s time bound plan due to several reason explained above. There is some new development plantation under Wilmar Indonesia such as in Jambi and West Kalimantan. None of new plantation area replace of primary forest. Wilmar has been following RSPO New Planting Procedure (NPP) for new plantation areas such as PT Agrindo Indah Persada Jambi by TUV Rheinland Indonesia in year 2012 the NPP report was submitted to RSPO and approved by RSPO Executive and PT Agri Nusa Indah West Kalimantan by PT Mutugung Lestari in year PT Asiatic Persada has been sold to other company and not belong Wilmar International Plantation so land conflict in Asiatic Persada Jambi not continued. Labour conflict in Tania Selatan regarding worker s bonus has finished Some of Wilmar s other management units have not complied with certain legal requirements, for example in PT Sarana Titian Permai, and PT Kerry Sawit Indonesia estates under another Wilmar International management unit, there is an issue with the land area stated in the land use right certificate (HGU). However, the company is taking action by inviting the National Land Agency (BPN) to remeasure the land and resolve the issue. The process is still ongoing.

10 Page 10 of Progress of associated smallholders or outgrowers towards RSPO compliance Based on incoming FFB data and clarification from mill manager, PT Kerry Sawit Indonesia Mills are no received FFB from smallholder or outgrower. This requirement is not applicable for PT Kerry Sawit Indonesia Approximate Tonnages Certified The approximate tonnages certified shall be the same as per original certificate, which is as follows : Crude Palm Oil (CPO) : 51, tonnes Palm Kernel (PK) : 9, tonnes

11 Page 11 of ASSESSMENT PROCESS 2.1 Certification Body TUV Rheinland Malaysia Sdn. Bhd. is member of Group TÜV Rheinland Group, a global leader in independent testing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. TUV Rheinland Malaysia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, as well as CDM Validations and Verifications. TUV Rheinland Malaysia s office is located in Subang Jaya, Malaysia. 2.2 Qualifications of Lead Assessor and Assessment Team The assessment team members of this surveillance audit that were part of the same assessment team for the certification audit are as follows: 1) Hendra Fachrurozy New assessment team members that were not part of the previous assessment team are as per the table below : Name Position Qualifications / Experience Aswan Hasibuan Irpan Kadir Auditor Auditor Education: Bachelor of Indudstrial Engineering, University of North Sumatera. Trainings attended: ISO 9000:2000 Series Auditor / Lead Auditor Training - PE International (Jakarta), IEMA Advanced EMS Auditor (IEMA / EARA ISO 14001) Auditor / Lead Auditor Training Course - PE International (Jakarta), OHSAS Lead Auditor Training Course - PE International (Jakarta). Working experience: Experienced in Quality Control from Auditor for Quality Management System since 2004 present. Auditor for Environmental Management System since 2005 present. Auditor for OHSAS since present. Conducted over 100 Quality Management System audits since 2004, over 50 Environmental Management System audits since 2006, and over 25 OHSAS audits since 2007 Education: Bachelor of Agriculture, Department of Social and Economic of Agriculture, Bogor Institute of Agriculture. Trainings attended: Sustainable Natural Production Forest Management (Pengelolaan Hutan Alam Produksi Lestari - PHAPL) assessor training (May 2003); Forest Plantation Management (August 2003) training - Indonesian Ecolabel Institute (LEI). Working experience: 2 years experienced as external auditor of PT. TUV International Indonesia for Sustainable Forest Management and RSPO Principles & Criteria. Has experience in conducting assessments of performance and social mapping for mining and forestry companies. He is a senior researcher and trainer at A + CSR Indonesia. 2.3 Assessment Methodology & Agenda The surveillance assessment was conducted from May 13 th to 17 th, 2013 as per the assessment program below. The assessment was carried out in accordance with TUV Rheinland Malaysia s RSPO audit procedure as well as the RSPO Certification Systems document. During the assessment, the qualified TUV Rheinland as-

12 Page 12 of 43 sessors used the RSPO standard as endorsed for the country in which the assessment took place and recorded their findings. Due to the location and proximity of the estates, combined with common management systems, it was possible to carry out both field and document assessments of all estates and the mill within the time frame without compromising the integrity of the assessment in anyway. All 3 estates and 1 mill were visited and the assessment team carried out field and document assessments of compliance to all the RSPO principles and criteria and RSPO SCCS year Common systems were identified and specific evidence was recorded for individual estates. Interviews were conducted at all estates and the mill. The company proposed the correction and corrective action for all identified non conformities raised to the certification body 30 days after the closing meeting. Verification of closure of major non-conformances was conducted 2 months after the closing meeting of the main assessment and implementation of corrective actions for minor non-conformities will be verified during the next surveillance audit. The certification assessment agenda is as explained below. Surveillance Audit Agenda. Date Location/ Main sites Main activities 13 May 2013 KSI main Office Opening Meeting Verification for Prveious audit findings 14 May 2013 KSI 3 Estate Boundary stone maintenance program HCV management and monitoring implementation. 15 May 2013 KSI 2 Estate Field Verification for Land Application program in KSI 2 estate Interview with woman worker (sparyer, plantation maintenance), Implementation of OSH Checking for EFB application Checking waste management at housing area Hazardous waste management at estate office Integrated Pest Management program application blok 74 Beneficial plant 16 May 2013 Villages Tebiku village, Sembuluh 1 village and Sembuluh 2 village KSI mill Plant Tour Cheking for CPO production record Waste management and disposal Hazardous waste management SCCS 17 May 2013 KSI 2 Office Land application (after raining) block 89 KSI 1 Domestic waste management Land fill area for final disposal of domestic waste River Riparian Wet land area /Water catchment Subcontractor housing (CV Sepindo) Sand mining area KSI 2 Preparation for closing meeting Closing Meeting

13 Page 13 of ASSESSMENT FINDINGS 3.1 Summary of Findings The following is a summary of findings during this surveillance audit for the criteria listed in the RSPO Principles & Criteria Indonesian National Interpretation year Principle 1: Commitment to transparency Criteria assessed : CR1.1, CR1.2 Criteria not assessed : - Findings : Companies keep records of requests and responses for information from stakeholders. Checks on incoming mail from external between periods April 2012-April 2013 found a letter from the Environment Agency of Seruyan District No. 660/130/BLH.I/II/2013 which asks companies declared themselves as participant for Environmental Proper (Company Performance Rating Program on Environmental aspect) agenda. In addition there is a letter from Forestry and Plantation Office of Seruyan District No /1169/Dishutbun/IV/2012 requesting fuel consumption data. The second letter was addressed companies. The shelf life of the document request and response information set forth in SOP 36/CKP/ (1)/0310 rev 01, effective date of March 1, 2010, which states the record is saved for 3 years, and moved to the filing room for the next 3 years. Provision of information to external parties is set using SOP 47/PR / (2) / 0312 effective since March Documents and information available includes: EIA, annual report, HGU permits and other related permits, monthly reports of estate production, the company's operational area, river maps, organizational structure, company policy, HCV report, SIA report, labor data CPO sales data, the area statement, CSR Program report, SOP and Procedure. In the past year, the period April 2012-April 2013, there were no requests for information from stakeholders relating to publicly available documents. As for the shelf life of information request responses determined for 3 years. Compliance status: Full Compliance. Principle 2: Compliance with applicable laws and regulations Criteria assessed: CR2.1, CR2.2, CR2.3 Criteria not assessed: - Findings: PT Kerry Sawit Indonesia s estates and mills have a list of applicable legal and other requirements documented under Register of OSH and Environmental Laws and Regulations ( Daftar Ketentuan Hukum & Peraturan & Perundangan Bidang Lingkungan Hidup, Keselamatan dan Kesehatan Kerja ) (Form No. 02/SOP 08/CKP/(2)/0111 Rev.06 dated on January 01, 2013). The company also carries out evaluations of compliance to applicable local, national and ratified international laws based on procedure of identification and evaluation of laws and regulations. Moreover, the company has a law register document listing the expiry dates of their various licenses or permits and applicable regulations, which is used to monitor when the licenses or permits are to be renewed but that is mechanism has not implemented with effective which proved that KSI 1 POM have not carried out update equipment permit when it permit has experied i.e dump truck (permit of No.566/586/NAKTRAN/V/2010), loader (permit of No. 566/585/NAKTRAN/V/2010)

14 and static crane (permit of No. 566/520/NAKTRAN/V/2012). This was raised Non-Conformity. Page 14 of 43 There made several effort to comply with legal requirements such as the company has been plantation bussiness permit (IUP), assessment permit of the utilization of effluent from POM in order to get permit for land application, the company revises the wages of their workers in accordance with changes in minimum wage as per decree letters issued by the local government, the company has an operating license from the Indonesian State Minister of Investment / Chairman of Investment Coordinating Board i.e approval of foreign investment ( Izin Prinsip Perubahan ) No. 570/1/IP/III/PMA/2012 (issued date on 29 October 2012), the implementation of action plan to comply with Government regulation Central Kalimantan No.5 year 2011 such as approval of PT KSI conservation area from BLHD, submit list of flora and fauna identification result (February 01, 2010) to local government, submit letter to Central Kalimantan Governor regarding request of guidance for local regulation No.5 year 2012 implementation (allocation of 5% CPO and maximum company s area 1 group only 120,000 ha) but there has been no response from Governor for this letter, the company (KSI 2 POM) has got approval of Building Construction Permit / Izin Mendirikan Bangunan (IMB) from Head of Seruyan District, the company has got approval of UKL/UPL document from Head of Environmental Agency in Seruyan District, ensure of all boiler operators on duty has certificate, etc. However during 2 nd surveillance audit there is several issues relating inconsistency to legal compliance were checked and found such as : - There is no evident fostering activity on three Posyandu (Integrated Health Centre (IHC)) and Unit Kesehatan Sekolah (Medical School Unit) of elementary school as required by Decree of Head Health Seruyan District regarding Licence of PT KSI Clinic. - Its found three heavy equipment ( Dump Truck nomor 566/586/NAKTRAN/V/2010,Loader number 566/585/NAKTRAN/V/2010, and Static Crane number 566/520/NAKTRAN/V/2012), was not perform regular inspection due to PKS KSI I just propose maintenance request on Mei 10 th, 2013 (Letter number 001/EXT/KSY-POM/DC/V/2013). - Plantation Business Permit (IUP) No. 525/184/EK/2005 issued on July 6, 2005 a.n PT Kerry Sawit Indonesia was not covering Palm Oil Mill (POM) as required in Regulation of Agricuture Minister No. 26/Permentan/OT.140/2/2007 dated 28 February 2007 chapter 1 Number 10. Condition above is raised as a non confomity. During 2 nd surveillance audit, the land use right (HGU) for PT KSI was not yet issued by the National Land Agency where based on letter No VIII/2012 dated on August from the regional office of National Land Agency in Central Kalimantan Province that the petition had been submitted previously in year 2006 have been returned back by National Land Agency head office with reason is 1). Consideration of the status of region and revision of spatial plan in Central Kalimantan Province has not been finished, 2). Government regulation No. 13 year 2010 about tariff of service applicable at National Land Agency, 3). Minister of forestry decree No. SK.292/Menhut-II/2011 about changes in forest areas to be not in the forest area in Central Kalimantan Province, and 4). Overlaping area with PT Salonok Ladang Mas area. Before issue letter above it has been implemented presentation by National Land Agency of Central Kalimantan Province to the management of PT KSI with results is 1). Conducted land inspection, remeasurement and overlay area between map of field and release of forest area with map of land use right PT PT Salonok Ladang Mas, and 2). Application of land use right PT Kerry Sawit Indonesia will be submitted again if there is a new format changes. During 2 nd surveillance audit has been the hand over of operation (dated on February 27, 2013) on most of PT KSI area (720 ha) from PT KSI to PT Salonok Ladang Mas (PT SLM) where both parties have conducted field survey and will conducting re-position of boundary trench, waiting for approval from the management (group estate manager, group manager and plantation head) for the additional budget as determined on internal office memo No. 012/KSI-1/II/2013 dated on April 29, Whereas the other boundary stone in good condition where it position is based on map of land (peta bidang tanah). There is a document summary settlement of land from 2003 to When the second surveillance conducted, there are still about 18 hectares of land in Block 5B65 were claimed by a villager. Companies still continue to make approaches for the value agreed compensation with the claimer. Checking the documents of land claims settlement in block 2B45 area of Ha on April 23, The company has made photographic documentation at the time of payment of compensation. There is evidence of receipt of payment and compensation payment agreement letter of crops along with a map of the claim area. The Company recognized customary rights and legal rights of land and stated in the SOP 43/PR/(2)/0510 applicable on May 17, Under the SOP, for lands that are claimed as traditional rights of community

15 have been enclave. Page 15 of 43 Enclave area in estate 2 until March 2013 is Ha. Enclave in the form of rubber plantation and shrub land belongs to the people in the concession that are not willing to be compensated. The company has made the list of enclave area in the Estate 1, 2 and 3 and map area spreading. Compliance status : Non Compliance NCR of 6 There is several issues relating inconsistency to legal compliance such as : - There is no evident fostering activity on three Child Healthcare Unit and Elementary school medical unit SD as required by Decree of Head Healty Seruyan District regarding Licence of PT KSI Clinic - Its found three heavy equipment ( Dump Truck nomor 566/586/NAKTRAN/V/2010,Loader number 566/585/NAKTRAN/V/2010, and Static Crane number 566/520/NAKTRAN/V/2012), was not perform regular inspection due to PKS KSI I just propose maintenance request on Mei 10th, 2013 (Letter number 001/EXT/KSY-POM/DC/V/2013). - Plantation Business Permit (IUP) No. 525/184/EK/2005 a.n PT Kerry Sawit Indonesia was not covering Palm oil Mill as required Regulation of Agricuture Minister No. 26/Permentan/OT.140/2/2007 dated 28 February 2007 chapter 1 Number 10. NCR of 6 There is no evidence of implementation of documented mechanism (SOP No.08/CKP/(2)/0111) as renewable permit of machinery in KSI-1 POM is behind the schedule.

16 Page 16 of 43 Principle 3: Commitment to long-term economic and financial viability Criteria assessed: CR3.1 Criteria not assessed: - Findings: There is no revision in company long years term management plan which is established since year 2009, company only revised budget for year 2012, 2013 and PT KSI s 5 years plan consist information about company activities such profit and loss information from Total Revenue and Total Operating Cost, including information about gross operating cost, profit/loss before tax and profit and loss after tax. The company has a financial schedule for yearly budget. Information on document consist of general routine operational activities such plantation maintenance, harvesting, fertilizer, investment plans such enrichment planting (planting of various plant species to enhance biodiversity), mill activities such FFB processed, projected oil extraction rate (OER) and kernel extraction rate (KER), projected crude palm oil (CPO) and palm kernel (PK) production, CSR programmes and environmental monitoring, HCV management plan and other activities to fulfil RSPO requirements. While for company s 3 years budget plan only focus to company s expenditure for each activity (including activities for environmental management programmes and all CSR related expenses, legal compliance and RSPO P & C compliance) and revenue from company's production including all company's liabilities. The amount of profit estimated to be achieved each year was clearly calculated, and all information is clearly explained in PT KSI s projection plan for a period of 5 years from 2010 to Since 2010 company has been earned profit. Documentation of cost projection for estates and mill are integrated, and the projected financial feasibility of the company for next 5 years based from the current FFB price can be seen from these documents. The company implements a replanting cycle every 25 years, and the company s plan for a replanting activities will begin in 2028, because the first plantings in PT KSI were in 2003 for for an area of ha, while in 2004 the planted area was 2, ha, and in 2005, the planted area was 1, ha. The total planted area up to 2013 is 15, ha. Compliance status: Full Compliance Principle 4: Use of appropriate best practices by growers and millers Criteria assessed: CR4.1, CR4.2, CR4.3, CR4.4, CR4.5, CR4.6, CR4.7 Criteria not assessed: 4.8 Findings: The estates and mill (include POM 2) still maintains and kept up date SOPs for all estate and mill activities, including nursery, land clearing without burning, planting, treatment, harvesting, usage of pesticides (circle and path spraying, selective and spot spraying), manuring, weighbridge operation, reception of FFB, sales of CPO, reception of FFB administration etc. Several SOPs have been revised following the actual condition of existing activities. Monitoring of implementation of SOP was done though internal audit activities except PT KSI POM 2 due it was commenced operations on January 14, One of results internal audit is inconsistency for implementation of EFB in field with SOP. In field found EFB piles has not been finished implemented in one block but there are other EFB piles in other block such as block 030D, block 061 and block 083. These conditions are not appropriate with circular agriculture No.24. This was raised Non- Conformity. All estate manager are required to make monthly reports of harvesting statistics and other operational results as defined in their SOPs, which includes data on the amount (tonnes) of FFB harvested from each estate block, no. of bunches harvested, average bunch weight and yield per ha. The estates also maintain records of amounts of chemicals used each month (recorded in 'Agrochemical Use Summary' for each year). Annual leaf nutrient analysis is conducted annually (April 9-14, 2012) and documented the fertilizer rec-

17 Page 17 of 43 ommendations report for each respective estate, while visual analysis results are documented under Field Observation Report on Leaf Sampling for each estate. Annual reports are prepared by the Environmental Management Unit (EMU) of Central Kalimantan Regional Office Wilmar and last report for KSI was combined and produced in January Each annual report includes a summary of findings and recommendations for fertilizer activities for year There is evidence of company s efforts to maintain and increase soil fertility through manuring activities following fertilizer recommendation from EMU as well as land application of POME and EFB from mill. The manuring records were kept by estate office while POME land application was kept by mill officer. Empty Fruit Bunches (EFB) are only applied for sandy area, records of EFB apllication were kept by estate officer. Realization of EFB mulching in year 2012 is 28,958 tonnes or ha (these condition has appropriate with standard/procedure (chapter 10 of EFB mulching that standard of EFB mulching on mature area is tonnes/ha/year). PT KSI has measured other parameters of the peat soil area as required by Government Regulation No. 150, 2000 which states a requirement that the ph, pyrite content, electrical conductivity and other chemical parameters of the peat, this is an improvement program compared to condition in year 2010 during first certification audit and year 2011 during verification audit. The company has been maintained water table at a mean of 60 cm in peat area. There are fragile soils in PT KSI area i.e sandy soil (buso, miri and serai). Management strategy for fragile soils has been conducted with development of drainage (dimension : 1.2x0.9x0.6 m, 1.8x1.2x0.9 m, and 1.2x1.0x0.6 m). PT Kerry Sawit Indonesia has a plan for protection of river riparian buffer zones for year 2013 including planting of various tree species along riparian river zones and water cathment. The company has been monitoring of effluent BOD with conducted monthly test by external laboratory. Results of monitoring is accordance with standard (< 5,000) (based on Ministry of environmental decree No. 29 year 2003). Whereas in year 2012, consumption of water for production in mill (POM 1) is a mean of 0.91 m 3 /tonnes (FFB process : 233, tonnes and consumption of water : 211,149 m 3 ). During 2 nd surveillance audit there is no pest and diseases in all PT Kerry Sawit estate as reported on census records year 2012, the company has an SOP for Detection and Census of Oil Palm Pests and Diseases. All estates maintains records of IPM implementation with records of census activities conducted to determine attacks of pests such as bagworms, nettle caterpillars, rats, termites, ganoderma, rhinoceros beetles and wild boars. Planting of Beneficial Plants as part of their IPM program such as vertiver grass (to reduce erosion) and turnera subulata (a plant which attracts natural predators of leaf pests) still continue until the audit time. The company uses only agrochemicals which are registered under the Department of Agriculture Indonesia (Indonesia Commission of Pesticides). The company has the following list of all agrochemical used for year 2012 and 2013 and their active ingredients : A. Herbicides: 1. Basta 150WSC, Methyl metsulfuron 20% 2. Trap 20 WP, Methyl metsulfuron 20% 3. Sanvit, 4. InteamL, Isoproplyamine glyphosate 480 g/l 5. Glisat 480 SL, Isoproplyamine glyphosate 480 g/l B. Fungicides 1. Antracol 70 WP, Propineb 70% C. Rodenticides 1. Petrokum RB, Brodifacoum 0.005% D. Surfactants 1. Agristick 400L, Alkyl Aryl polyglycol ether 400 g/l, The application of agrochemicals above has been according to correct dosage, target species in accordance with the product label and storage instruction. The company uses trained sprayers to prevent impacts and health risks that occur during chemical application. Waste material from agrochemicals including pesticides containers are properly stored and be treated as hazardous waste in accordance with laws and regulations. The empty container will be disposed to PT MAJU JAYA as lincesed waste collector. However PT MAJU JAYA has no scope to collect empty agrochemical container currently and PT MAJU JAYA is in progress to extend their scope of waste collector to include agrochemical container (letter No.Pur-RO/IV/ , dated on April 30, 2012). The company has submitted letter to environmental egency to discuss about list of company which has licensed waste collector with scope for empty agrochemical container.

18 Page 18 of 43 There is no change on company s policy for occupational health and safety that was signed by Mr. Goh Ing Sing as Group Plantation Head issued on September The policy has been communicated to all employees, e.g. through posters, company regulations book, etc. The policy is also applicable to all contractors performing work for the company. However, a noncompliance with the company s OSH regulation was observed. It is stated by the mill head in decision letter number: 004-DC-KSY POM/II/2012 dated February 11, 2012 regarding restriction for smoking in all mill area, however Ms. Kurnia Maya aasigned as new PIC for responsible person for Health and Safety programme as define in Organization Chart The OSH committee as the responsible team for health and safety programmes still exists and actively conduct regular meetings to discuss health, safety and welfare issues. Even though, some members of the committee are new because of resignation of the previous team member, the company still complies with regulation that the member of committee especially for the secretariat of committee has been certified as OSH expert from ministry of Man Power and Transmigration. Records of OSH meetings kept maintained by OSH secretariat. However there is no evidence that company submit to local government regarding their OSH meeting for the last one year, this is raised Non conformity. The company provides Social Security insurance (JAMSOSTEK) for permanent daily workers, both at the estate and mill, which covers accidents and fatalities. The company only provides accident insurance for temporary workers under JAMSOSTEK, with evidence in the form of a valid Jamsostek card for all existing employees and workers. Insured workers involved in accidents are treated for free. Payment of insurrance was sighted and the records were kept by Human resource department. According to company s regulation regular health examinations for workers which has high risk to health will be conducted every six month by company s paramedic, such as for sprayers, manurer and mill workers. During this surveillance audit, it was found that medical test for sprayer was done only for physical checking not include cholinesterase test, due to trained paramedic is not available even though the company has bought cholinesterase tester. According to company s planing the test will be conducted on June & december for sprayer in KSI 1, April 2013 for sprayer in KSI 2 and KSI Mill, April and October for Spayer in KSI 3. Audiometric test was also conducted yearly for mill workers who work at the noisy area. Updated occupational safety risk assessment for all work related activities was conducted by the company. It was found that the risk of working on sterilizer area during unloading hot fruit to conveyor with slippery floor caused by stewed fruit, has not included in the risk assessment, company should provide clear guidance to prevent accident happen on these area. The company provides first aid equipment, in all location especially location with high risk condition. OSH training is conducted regularly for all employees and contractors. An OSH training schedule for employees is available in each estate. An accident and emergency preparedness procedure is available in each estate, and is documented under procedure Emergency Fire Response PT Kerry Sawit Indonesia No. PTD 03/CKP / (0) / 0409, issued on April The procedures for emergency preparedness and response developed not only to land burning, but also fires in the office and housing area. The company also established the emergency procedure for handling chemicals and oil spills. The mill has an emergency response team and procedure as stated on PROS/KSYPOM-EHS-016. Personal Protective Equipment is provided by the company to be used by workers according to the type of work done by the workers and identified risks. For example, all sprayers are required to wear rubber boots, goggles, aprons, masks and rubber gloves, manurers are required to wear aprons, masks and rubber gloves and harvestors are provided with PPE such as helmets, boots and gloves by the company. The PPE is provided free by the company, as confirmed through on-site interviews with the workers. The company also provides a first aid room, safety shower, and eye wash facilityin the mill as required by a decree from the Minister of Manpower and Transmigration no. Per-15/MEN/VIII/2008 regarding first aid facilities. First aid kits are available throughout the estates and mill i.e. for KSI1, first aid kits were available at the estate office, chemical store, and genset, while at the mill, first aid kits were available at the workshop, near the sterilizers and oil room, and FFB tranport truck drivers are also required to carry a first aid kit. Most of first kits equipment are well maintained. Records of the occurrence of any work accidents are maintained and regularly reviewed, investigation for any work accidents was done following SOP No. 05/EHS/(1)0909 dated december There is a accident investigation of work accident dated June 05th, 2012, the accident has been reported to JAMSOSTEK by HR officer through letter No. KSI-1/BAK-ADM/1/2012 and coverd by Jamsostek.

19 Page 19 of 43 Compliance status: Non Compliance NCR of 06 Empty Fruit Bunch implementation among the three on block 030, block 083, and block 061 not appropriate with circular agriculture no.24. NCR of 06 There is no review on procedure related effort to avoid accident investigation result on Juni 05th, 2012 upon Mr. Said Hasan Basri, the investigation generate the causes for the accident was working in Height without Safety Harness. NCR x of 06 There is no evident of Reporting OHS Committee to Head of Labor for the last one year. Principle 5: Environmental responsibility and conservation of natural resources and biodiversity Criteria assessed: CR5.1, CR5.2, CR5.3, CR5.6 Criteria not assessed: CR5.4,CR5.5 Findings: PT. Kerry Sawit Mill and estate Indonesia has an approved environmental impact assessment (EIA) or AMDAL document based on the decision of the Minister of Agriculture as per letter no. 357/Kpts/HK.350/2002 dated May 23, 2002, and permit no. 86 / 2003 approved for an area of 19,200 ha of approval of Location Decision and for Factory capacity 45/90 tonnes on 28 June The company also has an environmental management and monitoring plan ( Rencana Pemantauan Lingkungan - RPL / Rencana Pengelolaan Lingkungan - RKL) prepared based on the AMDAL document as required by Indonesian law. Development of the second plant is being done to anticipate of higher crop production from three KSI s estates. Reports on implementation of the RKL and RPL documents are prepared and reported to Environmental Body of Central Kalimantan once every 6 months as required by law. As seen on-site, reports on implementation of the RKL and RPL were available for Semester 2 year 2010 which is submitted on January The company conducted re-identification and re-assessment by the company s staff of protected, rare and endangered species flora and fauna including their habitat and High Conservation Value (HCV) areas in PT Kerry Sawit Indonesia. Based on result of re-identification and re-assessment process (dated on May 04, 2012) that the company has revised map of HCV indentification area and relevant official statement. Total of HCV areal is ha consist of riparian ( ha), HCV area ( ha), swamp ( ha), water cathment (92.68 ha), water reservoir (23.62 ha) and HCV3 and HCV4 (9.5 ha). There is a letter from Environmental Agency in Seruyan District (No. 660/271/BLH/VI/2012 dated on June 05, 2012) about an area of ha (HCV area) will be used as a conservation area where will managed by the company and will not be used for the benefit of others. On area statement per April 2013 has been considered of new HCV areas. There are some records of implementation of the company s management and monitoring HCV program were sighted, such as additional signboard on river (block 051), additional signboard about prohibition of burn land, repair water level stick, and instalation a camera trap on dated December 20, 2012 (block 059). The activities conducted such as maintain signboard, illegal logging and fishing patrol, to ensure that signboard is still in good condition, no spraying in near riparian, no illegal activities occur within the riparian belt area and the forest is not destroyed. All waste and pollutions sources are identified and documented; wastes produced as part of the company s activities are identified as part of the company "Environmental Aspects and Impacts Identification document. The company has waste management and disposal as determined on SOP waste management SOP 22/EHS/(2)/0711 rev 02 July Domestic wastes from housing and offices are separated into recyclables wastes and non-recyclable/organic materials. Non-recyclables and organic waste are sent to landfills

20 Page 20 of 43 which are available in each estate, while recyclables and hazardous wastes are collected by contractor and the company maintains records of amounts collected. Hazardous waste such as used diesel oil, contaminated rags and mops, used paint can, used agrochemical container etc will be disposed to licensed waste collector, currently company s assign PT Maju Jaya to collect hazardous waste, however that company only has a permit allowing collection of used oil and residues. Their permit does not include information on collection of other types of hazardous wastes such as empy agrochemical container. Waste management in KSI estate is well implemented and it was sighted good improvement compare with last year audit, however KSI mill has no good implementation of waste management program and mill housekeeping. It was observed that used iron and zinc are disposed in a haphazard manner, used paint containers are not disposed in the right place, while oil leakage is found in many locations of the mill. This is raised as nonconformities. Licence for temporary storage of hazardous wastes which was issued by the Seruyan Government through letter No. 301 year 2010 still valid for 5 years. The company also sends reports of their hazardous waste inventories to the Seruyan Environmental Department once every three months. Sources of pollution and emissions of the mill are identified in the company s Environmental and OSH Aspects and Impacts, and include pollutants / emissions such used oil, air emissions, decanter cake, empty shell, liquid waste, used chemical containers (for laboratory chemicals such as phenolphathalein indicator, oxalic acid, sodium hydroxide, hexane, isopropyl alcohol, ethanol, etc. As required by law, monitoring and analysis or identified sources of pollution is performed once every 6 months and analysis results are reported to the environmental agency and plantation institution as evidence of implementation of the company s environmental management and monitoring (RKL/RPL) document such as report on 2 nd semester (July-December) year 2012 submitted on March 25, These report has received by both institution on March 26, The mill has records of monitoring POME application levels to block 074, 087, 088, and 089 amount of 158,915 m 3 (January 01, 2012 to April 30, 2013). The mill has conducted sampling and analysis of the discharge point of field drains at land applications sites to ensure water quality does not exceed legal standards (location of sample is block 074 (land application area), block 058 (control) and block 275 (housing of employee)). From checks of the land application field drains, the rainwater discharged from these fields is contained in the estate drains and would not enter any main waterways. The company has constructed an oil trap for oily water discharged to Lindung Bulan River. This is noted as a positive observation as part of the company s improvement program. Compliance status: Non Compliance NCR of 06 Submission hazardous waste to licenced collector (PT Maju Asri Jaya Utama) on May 07 th, this is exceeding storage period (90 days interval (after Januari 10 th,2013) as permit given to PT Kerry Sawit Indonesia. Principle 6: Responsible consideration of employees and of individuals and communities affected by growers and mills Criteria assessed : CR6.1, CR6.2, CR6.3, CR6.4, CR6.5, CR6.6, CR6.7, CR6.8, CR6.9, CR6.10, CR6.11 Criteria not assessed : - Findings: The company has made EIA document and was approved by Bapedalda (Regional Environmental Impact Management Agency) of Kota Waringin Timur District No. 70/Komisi-Amdal-Kotim/VI/2008 dated June 28, 2008 which covers the entire estate and KSI Mill I. While KSI mill II using UKL and UPL document (document of environmental monitoring and management) which was made in While to identify the specifics of the social impact, in March 2010 conducted Social Impact Assessment made by IndRI involving relevant stakeholders. There is a document management plan and monitoring of social impact for year Indicators are monitored and managed, namely employment, health and safety, facilities and benefits for workers, consultation and communication mechanisms, stability of employment, business opportunities, regional revenue, household income, institutional, community perception, social and cultural change, health of communities

21 and employees, as well as tenure issues. Page 21 of 43 PT KSI has made RKL and RPL (Management and monitoring environmental aspect) report for semester I and II in 2012 and also reports on social impact monitoring (SIA) for 2011 and 2012 period. Communication and consultation procedure using SOP document No. 44/PR/3/0313 revised 03 dated March 18, The SOP also regulate the appointment of consultation and communication officers with the community. Officer shifting and information related SOP of communication has been informed to the parties through meetings with community in the village Sembuluh 2 on 19 april Obtained photos and list of attendees of the meeting documentation. In addition to informing communications officer, the company has also made the documents MoU (Memorandum of Understanding) with Sembuluh I, II and Tabiku people. There is an minutes of the meeting document containing agreement include: community development, development of the plasma, education, infrastructure and other issues The company has a document which consist of stakeholders list No. 02/BM-KSI/LS/2013 dated January The document is an update of the previous document that was made in January to June Stakeholder grouped into governments, universities and NGOs, mass media, civil society organizations, farmers' groups, unions, contractors and partners, suppliers FFB. Checks on the document, there are data that is not in accordance with the latest information, the name of the Director of WALHI (Friends of Earth Indonesia). Communication and consultation procedure using SOP No. 44/PR/3/0313 documents. In practice, complaints, objections, requests for information from the public can be submitted through regular meetings, ask to community development officer, delivered directly to the estate or mill office, as well as through a suggestion box. As for employees, report complaints and objections discussed in the meeting of bipartite cooperation institution (LKS Bipartit), or report to the leader of the neighborhood in employee housing. Community land compensation claims made by first calculating the crop grown in the area. Compensation value decided through negotiations between claimer and the company. At the time of the payment of compensation, the company invited a team from the village as a witness. Interview with claimer in Block 5B65 stated that the company had invited him to a meeting to negotiate the compensation value. The company has made monitoring documentation on tenure issues. Acquired documents of land tenure issues which are updated on 24 April As of April 2013, there is remaining a claimer in Block 5B65, who has not been agreed on the price and area land compensation. The company has already made a land settlement roadmap. There is a summary documents of land compensation in the concession area of PT Kerry Sawit Indonesia covering an area of 10, with a compensation value of Rp 6, 884,875,075. Central Kalimantan Governor Decree No. 27 of 2012 set minimum wages for the agricultural sector Rp Checks on the employee s payslip, they got the basic salary Rp As a reference work relationship (rights and obligations of both the company and employees), the company has a company policy that has been approved by the Labor Office through Decree No. 560/320/Disnakertranspar/III/2013. The company regulations apply 13 March March Confirmation to the workers, in block 023, claimed they had seen and read the rules of the company. While a sprayer who interviewed at time of surveillance claimed not to know about the company regulation documents, but when he signed a letter of appointment as Permanent Daily Worker was given an explanation of the rights and obligations of workers. The company provides facilities for workers. Facilities include homes built for permanent employees (type D, E, and G) that is equipped with electricity and clean water. In addition the company provides a Child Daycare, Clinic, places of worship, sports facilities. School transportation is also available to take employee s children to a school that was in the village surrounding the company. Contract with the contractor requires they comply with applicable regulations which were related to minimum age of workers, wages, safety equipment and Social Security. There is a construction project registration document No in the name of CV Indah Jaya Kusuma for development Child Daycare dated February 19, Value of Social Security subscriptions to be paid Rp There is evidence of payment of subscriptions receipts Construction services. The company has a policy of freedom for employees to organize. Employees choose to form a bipartite organization as an employee representative. Bipartite cooperation institution (LKS Bipartit) meetings conducted once a month. There are six recording of the last meeting is on April 24, 2013, March 27, 2013, February 28, 2013, December 27, 2012 and 23 November LKS bipartite meeting to discuss, among others, report the condition of facility employees (the fulfillment of clean water, electricity use), payday market, conditions of Child Daycare.

22 Page 22 of 43 Companies still consistently implement policies related to minimum age of employees is 18 years. The company installed a sign board at the estate office related restrictions of child labor. Checks on staff and labor documents for the April 2013 at KSI III, there was not found workers aged less than 18 years. In the document is the youngest employees born in 1994 received as an employee in 2013 (19 years old). Similarly at the KSI 1 mill, after checking on employee data for the period March 2013, there were no employees aged less than 18 years. The company has a policy of employment and promotion opportunities are open to everyone without any discrimination. Job opportunities are also provided to local communities. In 2012, employees of local origin who worked in KSI reached 483 people from a total of 2490 or approximately 19.40%. Policy on sexual harassment and violence against women, still using SOP No. 40/HRD / (0) / 0409 in force since April The document describes a mechanism if there is a complaint. Reporting lines specifically for cases of sexual harassment/violence is through women's committees or complaint box. Companies provide maternity leave for working women before and after childbirth for 3 months and still receive a full salary. In 2013, at Estate III there are 3 female employees are given maternity leave. Currently the company does not purchase FFB from external suppliers, so the company did not inform the FFB price to the supplier, or make FFB pricing mechanism. The company makes contract documents for contractors that contain clauses scope of work, the rights and obligations of the contractor and the company as well as mode of payment. Checks on contract No. SPK 035/KONTRAK/KSY-POM/II/2013 for drainage work and the bridge construction in the employee housing in the Mill by CV Jaya Makmur Utama. Payments adjusted to the completion of work targets. There is a paper bill to Main Jaya Makmur CV for the period 25 February-25 May 2013 amounting to Rp107, on April 8, Community development fund disbursement by PT KSI in 2012 amounted Rp The company has also conducted training of oil palm cultivation on February 6, 2012 at the Village Sembuluh 1 and 2, which was attended by 42 participants. Inspection on the implementation of an integrated agricultural assistance program in the village Sembuluh 1 as well as interviews with the head of the farmer groups obtained information that PT KSI indeed perform assistance and provide support to farmer groups. Compliance status : Full Compliance Principle 7: Responsible development of new plantings Criteria assessed: - Criteria not assessed: CR7.1, CR7.2, CR7.3, CR7.4, CR7.5, CR7.6, CR7.7 Findings: There is no more new planted area is PT KSI during 2011, 2012 and 2013; explaination about company s compliance for priciple 7 was same with last year condition. Compliance status: Full Compliance Principle 8: Commitment to continuous improvement in key areas of activity Criteria assessed: CR8.1 Criteria not assessed: - Findings: Except for development of 2nd mill The company has a monitoring action plan ( Rencana Pemantauan Lingkungan Hidup RPL ) for all estates and mill dated 2008, which was developed based on the AMDAL document and approved by the local government as per approval letter 'Berita Acara no. 41/Komisi- Kotim/VI/2004'. The company prepares report to the Seruyan Government on the progress of implementation of the RKL every 6 months as required by law.

23 Page 23 of 43 All estates also have an Environmental Management Program and Activities Plan for year 2012 and 2013 based on the environmental aspects and impacts analysis, which includes plans for reduction of use of herbicides (glyphosate), reduction of domestic wastes, management of chemical containers, reduction of water used for spraying and management plan for clean water to meet the needs of workers. The program was developed in January 2013, and monitoring of implementation has yet to be conducted (to be carried out once every 6 months). There is evidence from on-site observations and documentation that the plan is being implemented. The company maintains records of follow-up actions taken against RSPO audit findings found during the certfication audit on December Mill has no Environmental Management Program and Activities Plan for year 2013 based on the environmental aspects and impacts analysis. Compliance status: Full compliance 3.2 Status of Previously Identified Non-conformities A total of 10 nonconformances were identified during the main certification assessment all categorized as.minor non-conformities. During this surveillance assessment, it was found that there was sufficient evidence for closure of all non-conformities, and these have been raised to Major Non-conformities under Section 3.3. The following is a description of the evidence of action taken to close the non-conformities raised during the previous assessment, as well as auditor s conclusions on the status of the non-conformities. Criterion 2.1. (Major indicator 1) Evidence of compliance with relevant legal requirements. NCR of 10 (Major non-conformity) There is no written action plan about company s planning to comply with Government regulation Central Kalimantan no. 5 year 2011 regarding sustainable plantation such as : - Endorsement of company s conservation area by BLHD. - Reporting to local government regarding result of Flora and Fauna Identification. - Allocation 5% of CPO production for downstream process in central Kalimantan Province. - Maximum company s area 1 group only 120,000 ha. - Etc. Correction: - To submit a letter to department of Environment Seruyan District (BLHD/Badan Lingkungan Hidup Daerah) to inform about HCV and ask for a confirmation letter from the relevant institution regarding HCV area in KSI estate accompanied by HCV map. - The company shall submits the report on flora and fauna identification result to BLHD. - The company will clarify the related subject to local government while waiting for decision from governor regarding guidance for implementation of that regulation. - To make plans and calculations regarding allocations of 5% CPO process by PT KSI or group. - The company shall identify total existing plantation area and ask the management to deduct production area in KSI if the area identified is found to be more than the defined permitted area. Corrective Action: The company will update list Law and Legal register including Local regulation No. 5 year 2011 and Ministry of Environment regulation No. 27 year Compliance will be evaluated periodocally. The company will make action plan to comply with government regulation No. 5 year Auditor Conclusions : Closed Date of closure: May 09, 2012 Verification results :

24 Page 24 of 43 The action plan about company s planning to comply with Government regulation Central Kalimantan No. 5 year 2011 has available. The company provide evidence for action plan has implemented such as : 1. Letter No. 126 /KSI/ Adn/BM/V/2012 dated May 02, 2012 regarding the conservation area in PT Kerry Sawit Indonesia estate. There is a letter from BLHD No. 660 /271/ BLH/IV/2012 regarding approval of PT KSI conservation area with total ha. 2. The company provided a list of flora and fauna identification result dated February 01, 2010 and copy of letter to local government regarding submission of flora and fauna identification result dated April 23, Letter to central Kalimantan Governor No. 127/KSI/ADM/BM/V/2012 regarding request of guidance for Local Regulation no. 5 year 2012 implementation (allocation of 5% CPO and maximum company s area 1 group only 120,000 ha). Until now, there has been no response from Governor. 4. Summary of workshop (development sustainable palm oil in Central Kalimantan) dated on May 15-16, 2013 where include topic of road map Central Kalimantan Province in plantation sector and implementation of the government regulation Central Kalimantan Timur no. 5 year 2011 such as bring order of licencing, preserving forest areas in non-forest areas, providing support of umbrella law on lands which enabled the conservation areas (HCV). Criterion 2.1. (Major indicator 1) Evidence of compliance with relevant legal requirements. NCR of 10 (Major non-conformity) The company has yet to obtain all necessary legal permits required for KSI 2 mill development, with evidence as follows: - Development is conducted without approved environmental impact assessment (AMDAL/UKL/UPL) as required in local regulation Per menlh no. 27 year No IMB (Izin Mendirikan bangunan/bulding Construction Permit) issued from government Correction: Would require a statement to the local government to carry out development activities Seruyan mill can still be made up to the IMB and UKL / UPL completed. The company requested a confirmation letter to local government for continuing mill construction while waiting for approval of IMB/Ijin Mendirikan Bangunan (Building Construction Permit) and Document UKL/UPL to be completed and approved. Corrective Action: Company will identify all applicable legal regulation and permit needed for new building construction and will follow that regulation accordingly. Auditor Conclusions: Closed Date of closure: April 30, 2012 Verification Result : The company provided the documented decision letter from Seruyan District head of IMB no /42/ KPPT/V/2012 issued on May 01, 2012 regarding approval of IMB (Izin Mendirikan Bangunan/Building Construction Permit) for POM 2 area of 6,942 m 2 (6.94 ha) in block 064 and block 024). The company has got approval from head of Environmental Agency in Seruyan District (Badan Lingkungan Hidup (BLH)) No. 750/004/BLH/VII/2012 dated on July 11, 2012 about UKL/UPL document. Criterion 2.1. (Major indicator 1) Evidence of compliance with relevant legal requirements. NCR of 10 (Major non-conformity) There are found inconsistency to applicable legal regulation such as: 1. There is no permit from relevant institution regarding quarrying laterit (called galian C ) inside com-

25 pany s area for road maintenance; there is no evidence that company has been paying retribution for that activity. 2. One of stelizer operator no 4 without required certificate as stated on permit act no. PK/18/H Page 25 of 43 Correction: 1. The company requested confirmation letter to relevant institution regarding quarrying laterit (called galian C ) including relevant restribution. 2. Non-qualified operator without relevant certificate is not allowed to operate sterilizer. The company provide moving letter assignment for non qualified operator to other area of work. Corrective Action: The company will identify all applicable legal regulation and permits needed for qualified operator and follow that regulation accordingly Auditor Conclusions: Closed Date of closure: April 20, 2012 Verification Result: The company provided documents, such as: Letter no 127/KSI/ADM/BM/IV/2012 to Head of Seruyan District regarding request of permit for quarrying laterit for internal used. Response letter from head of Seruyan District No.973/ 48/V/UPT-PPD-SRY/2012 dated May 10, 2012 regarding confirmation of permission for quarrying laterit for internal used and information that such activities for internal use is not subjected to tax or retribution payment. Moving/mutation letter No. 68/HRD-RO/SK/B/IV/2012 dated on April 23, 2012 on behalf Mr Yakobus moving/mutation from sterilizer operator to Kernel Plant operator. Based on list of sterilizer operator (per April 2013) that there is not name of Mr Yakobus and all sterilizer operators has been certificate and OHS license card still valid. Criterion 4.1. (Major indicator 1) Records of checking or monitoring of operations. Minimum requirement: once a year. NCR of 10 (Major non-conformity) escalation from previous audit findings The mill has no records of internal audits to ensure that the mill's SOPs for operation activity are followed. PT KSI has SOP Internal Audit i.e. SOP 65/CKP/(0)/0811. However the mill still not conduct internal audit as required by SOP, there is no audit planning, and audit program for year 2011 and year Correction: Conduct Internal Audit activity as required SOP 65. Corrective Action: The mill head will make internal audit programs in the begining of the year and assign internal audit team according to the program. Auditor Conclusions: Closed Date of closure: Verification result: The company provided documents: - Internal audit schedule and agenda dated April 26, Minutes of audit activity for PT Kerry Sawit palm Oil Mill shows the audit was conducted on April 26, 2012 to ensure implementation of all existing standard operation procedure at PT KSI Palm Oil Mill. - Checklist used for internal audit activity conducted for all Palm Oil Mill activities. - In year 2013, the company has conducted internal audit.

26 Page 26 of 43 Criterion 4.7 (Minor indicator 6) Evidence of OHS and first aid equipments available at worksites NCR of 10 (Minor non-conformity) It is stated by the mill head in decision letter number: 004-DC-KSY POM/II/2012 dated February 11, 2012 regarding restriction for smoking in all mill area, however the auditor found a lot of cigarette butts in front of security office PT KSI mill. In addition, some workers at FFB grading area did not use safety shoes as one of the specified PPE that must be worn by workers in this section. Correction: - Provide penalties to anyone who does not smoke at designated place. - Provide sanctions for employees who do not use PPE at work - Complete first aid kit for wheel loader Corrective Action: Morning briefing and safety talk agenda will include instruction to use PPE and discipline during working time following company s regulation. Auditor Conclusions : Closed Date of closure: April 26, 2012 Verification result : During 2 nd surveillance audit in mill (POM 1) that no found cigarette butts and personil smoking in front of security office PT KSI mil. In FFB grading area, all employee use safety shoes. Criterion 5.2 (Major indicator 1) Records of results of identification of any protected, rare, threatened or endangered species, and HCV habitat. NCR of 10 (Major non-conformity) There is no evidence that HCV re-identification result has been considering in approved land use system PT KSI, as basic for developing new HCV management plan and considering on KSI area statement. Correction: The company revised HCV area considering to approval land system and used to make HCV management & monitoring plan. The company also will make official statement regarding revised HCV document. Corrective Action: The company will regularly evaluate and review existing HCV area considering applicable regulation regarding land use system and also considering result form HCV area management and monitoring action. Auditor Conclusions: Closed Date of closure: May 02, 2012 Verification result: Company provided the following documents as evidence : - Revised Map of HCV identification area and relevant official statement dated May 04, New area statement considering revised new HCV area. Criterion 5.3 (Major indicator 2) Estates and mills waste management and disposal are implemented to avoid or reduce pollution.

27 Page 27 of 43 NCR of 10 (Major non-conformity) KSI mill has no good implementation of waste management program and mill housekeeping, with evidence as follows: - It was observed that used iron and zinc are disposed in a haphazard manner, used paint containers are not disposed in the right place, while oil leakage is found in many locations of the mill. - There is no proper separation of organic and an organic waste in the Final Disposal Waste site of KSI 1. Correction: The company improve the implementation of waste management and improve the housekeeping at the mill. Corrective Action: Ensuring plant housekeeping awake through waste patrol and improve employee discipline to keep all working area clean. Auditor Conclusions: Closed Date of closure: May 10, 2012 Verification result : Results of verification in field and photograph regarding company s improvement activities for waste management such as infront of mill 1 (POM 1) area all used iron and zinc has been separated and placed in a proper place. Used paint containers are now kept at a proper waste store. Separation of organic and an organic waste has been implemented in mill area and worker housing area. Criterion 5.3. (Minor indicator 1) Management plan of hazardous waste and instruction of disposal of agrochemicals and their containers waste in accordance with the product label and existing regulations. NCR of 10 (Major non-conformity - escalated from previous audit findings) - The company s contactor for collection of hazardous wastes is collecting empty agrochemical containers but only has a permit allowing collection of used oil and residues, and their permit does not include permission on collection of other types of hazardous wastes. - It was found that used cartridge/toner in hazardous waste storage has been kept since January 30, This is inconsistent to government regulation no. 18 year Correction: - The company shall conduct identification of used cartridges that can be reused. For all cartridges which cannot be reused again, these will be disposed to an approved waste collector. - The company issue letter to CV Maju Jaya as assigned waste collector to extend the scope of collected waste including empty agrochemical containers. While waiting for scope extention of CV maju Jaya, PT KSI trying to find another licensed waste collector which has scope to collect empty agrochemical containers Corrective Action: Company will discuss with agrochemical supplier to find good solution for empty container which categorized as hazardous waste such as refill system. Auditor Conclusions: Closed Date of closure: May 10, 2012 Verification result : The company provides a copy of letter Nomor: Pur-RO/IV/ dated April 30, 2012 regarding request of scope extention for collected waste. Until verification document process for scope extention is ongoing waiting for approval and response from local government. The company submit letter to head of Seruyan District c.q. Environmental office regarding asking for sol-

28 lution to handling empty agrochemical container. There is not response from government related it. Page 28 of 43 Criterion 6.1 (Minor indicator 2) Regular monitoring and management of social impact, with the participation of local communities. NCR of 10 (Minor non-conformity) There is no report of social impact management and monitoring plan with participatory from relevant stakeholder, including social impact management and monitoring plan as required by document RKL/RPL such as condition and or disturbance of communities and workers health Correction: To create reports on monitoring and managing social impact in 2011, and to conduct an analysis of the health problems in the community and employees including the information on report RKL and RPL for first semester of Corrective Action: RSPO coordinator will issue a reminder letter to make report of social impact management and monitoring every once a year. Auditor Conclusions : Closed Verification result: Evidence provided by the company include: 1) RKL and RPL (Management and monitoring environmental aspect) report for semester I and II in 2012; 2) reports on social impact monitoring (SIA) for 2011 and 2012 period; 3) identification and evaluation of environmental impact aspect of KSI I, II and III Estate using Form 1/SOP 10/EHS / (1) / 0809; PT KSI also has document management plan and monitoring of social impact for year Indicators are monitored and managed, namely employment, health and safety, facilities and benefits for workers, consultation and communication mechanisms, stability of employment, business opportunities, regional revenue, household income, institutional, community perception, social and cultural change, health of communities and employees, as well as tenure issues. Community participation in the management of social impact channeled annual meetings with the community. On 19 April 2013, the company held a meeting with villagers Sembuluh 2. The result is a MoU which includes, among others: the proposed community development program, development of the plasma, contribution to education and infrastructure as well as other matters. Criterion 6.3 (Minor indicator 2) Records of handling of the complaints. NCR of 10 (Minor non-conformity) There is no follow up action for incoming complaints from workers through suggestion box on January 15, 2011 asking about company s liabilities to provide workers facilities and workers rights. Sprayer also questioned regarding their remuneration (whether lump sum or daily payment). Correction: Provide explaination to all workers relate to facilities and remuneration system Corrective Action: The procedure of handling incoming complaint will be revised to state the minimum response time for all incoming complaints and will communicate the procedure to all relevant workers for better understanding. Auditor Conclusions : Closed Verification result : A description of the rights of employees are informed through meeting of bipartite cooperation institution

29 Page 29 of 43 (LKS Bipartit). Also for employees, report complaints and objections discussed in the meeting of LKS Bipartit, or report to the leader of the neighborhood in employee housing. There are six recording of the last meeting is on April 24, 2013, March 27, 2013, February 28, 2013, December 27, 2012 and 23 November LKS bipartite meeting to discuss, among others, report the condition of facility employees (the fulfillment of clean water, electricity use), payday market, conditions of Child Daycare. 3.3 Identified Non-conformances, Corrective Actions Taken and Auditors Conclusions During this surveillance assessment, a total of 6 nonconformances were identified. These consisted of 1 (one) major non-conformities and 5 minor non-conformities. For the major non-conformances, the company has taken the necessary corrective action to close these non-conformances within 60 days of completion of the assessment, and this was verified by the audit team through checks of documents submitted by the company. For the minor non-conformances, the company has taken corrective action against these as well, and for those which could not be verified as closed through document checks, the closure of these minor nonconformities will be assessed during the next surveillance audit. A summary of all identified nonconformances, corrective actions taken and auditor conclusions is as below : Criterion 2.1. (Major indicator 1) Evidence of compliance with relevant legal requirements. NCR of 6 There is several issues relating inconsistency to legal compliance such as : - There is no evident fostering activity on three Child Healthcare Unit and Elementary school medical unit SD as required by Decree of Head Healty Seruyan District regarding Licence of PT KSI Clinic - Its found three heavy equipment ( Dump Truck nomor 566/586/NAKTRAN/V/2010,Loader number 566/585/NAKTRAN/V/2010, and Static Crane number 566/520/NAKTRAN/V/2012), was not perform regular inspection due to PKS KSI I just propose maintenance request on Mei 10th, 2013 (Letter number 001/EXT/KSY-POM/DC/V/2013). - Plantation Business Permit (IUP) No. 525/184/EK/2005 a.n PT Kerry Sawit Indonesia was not covering Palm oil Mill as required Regulation of Agricuture Minister No. 26/Permentan/OT.140/2/2007 dated 28 February 2007 chapter 1 Number Submission hazardous waste to licenced collector (PT Maju Jaya Asri Utama) on May 07 th, this is exceeding storage period (90 days interval (after Januari 10 th,2013) as permit given to PT Kerry Sawit Indonesia Correction : - To prepare plan for fostering Child Healthcare Unit and Elementary school medical unit in year 2013, and provide realization record as Minutes of Meeting and other activity documentation. - To identify permit validation each heavy equipment and provide service request on may 10th,2013 as letter no. 001/EXT/KSY-POM/DC/V/ To propose revision of Plantation Business Permit (IUP) to Head of Region fulfil PERMENTAN 26 tahun 2007 and then to add in IUP POM KS!-1 and KSI-2 into KSI IUP. - Prepare delivery schedule of Hazardous waste to third party - To keep evident of Hazardous submission within 90 days as well. - Determine personnel who responsible to ensure hazardous waste delivered as well Corrective Action : - To ensure Program of fostering Child Healthcare Unit and Elementary school medical unit well implemented. - To monitor all existing permit. - To have integrated Plantation Business Permit in next future covering Plantation and POM capacity. - To ensure that hazardous waste will be kept less than 90 days by following delivery schedule thighly

30 Page 30 of 43 and the company determine a schedule of hazardous waste delivery in one year program. This schedule as approved by Plantation Head and acknowledge by related party and this schedule must be followed strictly by EHS officer as responsible person for it. Auditor Conclusions: Closed Date of closure: June 14, 2013 Verification audit : Company provide evidence such as : - Activity plan of Pos Yandu (Integrated Health Centre (IHC)) and UKS (Unit Kesehatan Sekolah / Medical School Unit) of elementary school assistance for year Record of the implementation of activities in the form of report and documentation/photograph. Records of Pos Yandu and UKS assistance in June Evidence of periodical inspection by Head of Labor Region Seruyan. Third machinery/equipment has inspected by supervisor of manpower/osh dated on July 29, 2013 where result of re-inspection is still compliance with requirement to operate. - Letter No. 25 /KSI/ Adn/BM/VI/2013 dated June 10 th, 2013 regarding request of revision of IUP from PT Kerry Sawit Indonesia to Plantation institution. Evidence of the receipt of letter which has signed by Local Government Officer and there is note that it is has been processed. - Revised of EHS Officer/Supervisor job description to ensure that He/She responsible to ensure all hazardous waste was managed in accordance to regulation. - Yearly Hazardous Delivery Schedule for year of 2013 and year of 2014 to ensure all related party prepare themselves to ensure hazardous waste delivered as regulation as well. Criterion 2.1. (Minor indicator 2) A mechanism for ensuring that compliance with relevant legal requirements is implemented NCR of 6 The company could not prove the mechanism of the review of laws, regulations and permis (SOP of No.08/CKP/(2)/0111) has been applied. Mill KSI overdue updating of equipment permits scheduled Correction : To identify of permit validity/periodic checks for equipment / licenses that will expire. Such as renewal permit for the dump truck, the company has submitted a letter on May 10, 2013 no. 001/EXT/KSY- POM/DC/V/2013. Corrective action: Monitoring all license validity period Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next audit Criterion 4.1. (Minor indicator 1) Records of checking or monitoring of operations. Minimum requirement : once a year NCR of 06 Empty Fruit Bunch implementation among the three on block 030, block 083, and block 061 not appropriate with circular agriculture no.24. Correction : - To prepare EFB application program block by block method - To perform EFB application full block on block 030 KSI-3 Corrective Action : 1. To ensure EFB application block by block with monitoring of daily report of EFB application in field so inline with circular agriculture no.24.

31 Page 31 of To perform mothly audt by Environmental Monitoring Unit Auditor Conclusions : Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next audit Criterion 4.7. (Minor indicator 8) Records of the occurrence of any work accidents are maintained and regularly reviewed NCR of 06 There is no review on procedure related effort to avoid accident investigation result on Juni 05 th, 2012 upon Mr. Said Hasan Basri, the investigation generate the causes for the accident was working in Height without Safety Harness. Correction: - To review SOP regarding result of accident investigation of Mr. Said Hasan Basri - To perform accident investigation based on factual data Corrective Action: To ensure to implementing the safety working procedure as well by re-treat related workers.regarding safety working procedure Auditor Conclusions: Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next audit Criterion 4.7. (Minor indicator 8) Records of the occurrence of any work accidents are maintained and regularly reviewed NCR of 06 (Minor non-conformity) There is no evident of Reporting OHS Committee to Head of Labor for the last one year. Correction : - To repare report of OHS committee to government party. - To keep evident of report submission - To ensure reporting of OHS and environmental commitee made every 3 months Corrective Action: To ensure report of OHS committee to government party will be provided every 3 morth as well. Auditor Conclusions : Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next surveillance audit Criterion 5.3 (Minor indicator 1) Management plan of hazardous waste and instruction of disposal of agrochemicals and their containers waste in accordance with the product label and existing regulations NCR of 06 (Minor non-conformity) Submission hazardous waste to licenced collector (PT Maju Jaya Asri Utama) on May 07 th, this is exceeding storage period (90 days interval (after Januari 10 th,2013) as permit given to PT Kerry Sawit Indonesia Correction: - Prepare delivery schedule of Hazardous waste to third party - To keep evident of Hazardous submission within 90 days as well. - Determine personnel who responsible to ensure hazardous waste delivered as well Corrective Action:

32 Page 32 of 43 To ensure that hazardous waste will be kept less than 90 days by following delivery schedule thighly and the company determine a schedule of hazardous waste delivery in one year program. This schedule as approved by Plantation Head and acknowledge by related party and this schedule must be followed strictly by EHS officer as responsible person for it. Auditor Conclusions : Evidence of immediate action taken was accepted. Effectiveness of implementation to verified at next surveillance audit 3.4 Description of Supply Chain Management System Kerry Sawit Indonesia Palm Oil Mill (KSI POM) is located in Central Kalimantan - Indonesia. Kerry Sawit Indonesia Mill 1 (POM 1) was established in 2009 with a production capacity of 45 tonnes/hours or 250,000 tonnes per year. In year 2012, the mill 1 (POM 1) processes Fresh Fruit Bunches (FFB) from Kerry Sawit Indonesia of estate (KSI 1-3), Mustika Sembuluh 1-2 of estate (MS 1-2), Rimba Harapan Sakti 1-2 of estate (RHS 1-2) and Sarana Titian Permata 1 of estate (STP 1). The location of Kerry Sawit Indonesia Palm Oil Mill is within Kerry Sawit Indonesia 2 (KSI-2) of estate. Kerry Sawit Indonesia Mill 2 (POM 2) was established in 2013 with a production capacity of 90 tonnes/hours. In year 2013 (January-April), the mill 2 (POM 2) processes Fresh Fruit Bunches (FFB) from Kerry Sawit Indonesia of estate (KSI 1-3), Mustika Sembuluh 2 of estate (MS 2), and Sarana Titian Permata 1 of estate (STP 1). The location of Kerry Sawit Indonesia Palm Oil Mill is within Kerry Sawit Indonesia 1 (KSI-1) of estate. The company has an operating license from the Indonesian State Minister of Investment / Chairman of Investment Coordinating Board i.e approval of foreign investment ( Izin Prinsip Perubahan ) No. 570/1/IP/III/PMA/2012 (issued date on 29 October 2012) with capacity of FFB : 610,000 tonnes, CPO : 120,000 tonnes. In year 2012, Kerry Sawit Indonesia mill 1 (POM 1) is receiving approximately 98.01% of its supplies of Fresh Fruit Bunches (FFB) from 3 company-owned estates (KSI 1, KSI 2, and KSI 3 of estate), and the remaining 1.99% from sister company (MS 1, MS 2, RHS 1, RHS 2 and STP 1 of estate). In year 2013 (until April 2013), Kerry Sawit Indonesia mill 2 (POM 2) is receiving approximately 63.23% of its supplies of Fresh Fruit Bunches (FFB) from 3 company-owned estates (KS 1, KS 2, and KS 3 of estate), and the remaining 36.77% from sister company (MS 2 and STP 1). Supply of FFB from KSI (KSI 1-3), STP (STP 1) and MS (MS 1-2) estate is RSPO Certified FFB because PT Kerry Sawit Indonesia, PT Mustika Sembuluh and PT Sarana Titian Permata has RSPO P&C Certificate. In year 2012, total FFB received by Kerry Sawit Indonesia mill 1 (POM 1) is 218, MT and FFB process is 219, MT. The mill 1 (POM 1) produces Crude Palm Oil (CPO) and Palm Kernel (PK) in the amount of 49, MT and 9, MT. In year 2013 (until April 2013), total FFB received by Kerry Sawit Indonesia mill 2 (POM 2) is 52, MT and FFB process is 52, MT. The mill 2 (POM 2) produces Crude Palm Oil (CPO) and Palm Kernel (PK) in the amount of 11, MT and 2, MT. The company implements SCC-RSPO with Mass Balance (MB) model according to the nature of mill FBB supply condition. The following is a description of the company s supply chain management system according to the RSPO SCCS requirements (it was assessed/audited against Module E), including status of compliance of the company and their outsourced third parties to RSPO SCCS requirements. Results of audit/assessment as describe on the explaination below : 1. Documented procedures Findings: The company (POM 1) has a procedure for implementation of SCCS requirements. There are a set of existing procedure consisting of : 1. Procedure to receive FFB (SOP/KSYPOM-LOG-003 Rev.02, issued on December 04, 2012), This is procedure include definition of certified and non-certified FFB and mechanism validity process of FFB certified supplier list in Kerry Sawit Indonesia mill too. 2. Procedure for receiving outside FFB (SOP/KSYPOM-LOG-004 Rev.01, issued on July 02, 2012), 3. Procedure for purchasing administration of FFB (SOP/KSYPOM-LOG-002 Rev.04, issued on July 02, 2012), 4. Procedure for supply chain mass balance model (SOP/KSYPOM-LOG-014 Rev.02, issued on December

33 04, 2012), 5. Procedure for the selling CPO (SOP/KSYPOM-LOG-005 Rev.01, issued on July 02, 2012), 6. Procedure for the selling PK (SOP/KSYPOM-LOG-006 Rev.01, issued on July 02, 2012), 7. Procedure for over production (SOP/KSYPOM-LOG-003 Rev.01, issued on July 02, 2012), Page 33 of Procedure for the selling administration (SOP/KSYPOM-LOG-007 Rev.01, issued on July 02, 2012), 9. Procedure for uploading with the selling of Loco and Franco (SOP/KSYPOM-LOG-012 & 013 Rev.01, issued on July 02, 2012), 10. Procedure for sounding and reporting 501 (SOP/KSYPOM-LOG-008 Rev.01, issued on July 02, 2012), 11. Procedure for storage tank operation (SOP/KSYPOM-LOG-009 Rev.01, issued on July 02, 2012), 12. Procedure for filling kernels into sacks (SOP/KSYPOM-LOG-010 Rev.01, issued on July 02, 2012), 13. Procedure for the washing of storage tank (SOP/KSYPOM-LOG-011 Rev.01, issued on July 02, 2012), 14. Procedure for WB operation (SOP/KSYPOM-LOG-001 Rev.01, issued on July 02, 2012), 15. Procedure for control of documents (SOP/KSYPOM-MR-001 Rev.01, issued on July 02, 2012). Whereas mill 2 (POM 2) has a procedure for implementation of SCCS requirements too. There are a set of existing procedure consisting of : 1. Procedure for WB operation (SOP/KSY2POM-LOG-001) 2. Procedure for receiving administration of FFB (SOP/KSY2POM-LOG-002) 3. Procedure to receive FFB (SOP/KSY2POM-LOG-003) 4. Procedure for receiving outside FFB (SOP/KSY2POM-LOG-004) 5. Procedure for the selling CPO (SOP/KSY2POM-LOG-005) 6. Procedure for the selling PK (SOP/KSY2POM-LOG-006) 7. Procedure for the selling administration (SOP/KSY2POM-LOG-007) 8. Procedure for sounding and reporting 501 (SOP/KSY2POM-LOG-008) 9. Procedure for storage tank operation (SOP/KSY2POM-LOG-009) 10. Procedure for filling kernels into sacks (SOP/KSY2POM-LOG-010) 11. Procedure for the washing of storage tank (SOP/KSY2POM-LOG-011) 12. Procedure for uploading with the selling of Loco and Franco (SOP/KSY2POM-LOG-012 & 013) 13. Procedure for supply chain mass balance CPO model (SOP/KSY2POM-LOG-014) 14. Procedure for supply chain mass balance PK model (SOP/KSY2POM-LOG-015) 15. Procedure for control of documents (SOP/KSY2POM-MR-001) 16. Procedure for inform to CB if projected over production (SOP/KSY2POM-MR-003) However, the company does not have established procedure/mechanism for receive and delivery PK in temporary warehouse - Sampit. Moreover, there are procedures which have not been updated to be in accordance with related SCCS requirement i.e procedure of supply chain - Mass Balance model (SOP/KSYPOM-LOG-014) does not explain the type of delivery that are allowed to write the quantity of dispatch PK in column 24. This was raised as a non conformity. The name of the person having overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements has been assigned at the audit time. According to decision letter No. 01/PKS-KSI2/V/2013 issued on May 01, 2013 company assign Mr. A.Bukhari as Management Representative (MR) for ISCC & RSPO include SCCS program implementation in Kerry Sawit Indonesia mill 2 (POM 2). Whereas in mill 1 (POM 1) assign as MR RSPO SCCS is Mr Doddy Setiawan (based on decision letter No 03/KSY-MILL/V/2013 dated on May 17, 2013). The duties and responsibilities of MR are set out in document no. JD/MSPOM-MR-001 Rev.02, issued on July 26, Kerry Sawit Indonesia mill has a procedure for reception of FFB (SOP/KSYPOM-LOG-003 Rev.02 & SOP/KSY2POM-LOG-003) and procedure for receiving outside FFB (SOP/KSYPOM-LOG-004 Rev.01 and SOP/KSY2POM-LOG-004). The procedure describes instructions for receiving and processing certified and non-certified FFBs. Compliance status : Non Compliance

34 Page 34 of 43 NCR No 2013-SCCS-01 of 02 The facility does not have established procedure/mechanism for receive and delivery PK in temporary warehouse Sampit. The facility does not have up-to-date procedures (SOP/KSYPOM-LOG-014) does not explain the type of delivery that are allowed to write the quantity of dispatch PK in column Purchasing and goods in Findings: PT Kerry Sawit Indonesia Palm Oil Mill (POM 1 & POM 2) has a mechanism to receive FFB both from certified sources and non-certified sources. The document to be verified from certified sources are : material delivery letter ( Surat Pengantar Buah ) including name of estate origin and barcode code for material delivered letter. Based on name of estate origin then weighbridge operator ensure that name of estate origin include in the list certified suppliers. If include in the list certified suppliers then it is status is FFB certified. Certification status will be stated on Incoming Certified FFB Received report (daily, monthly and three monthly report) in weighbridge location. Non Certified status will be stated on Incoming Non Certified FFB Received report (daily, monthly and three monthly report) in weighbridge location. A person has been appointed to be responsible to check and ensure the FFB quality and quantity are as per purchase documents. According to FFB reception procedure (SOP/KSYPOM-LOG-003 Rev.02 and SOP/KSY2POM-LOG-003) and procedure for reception of outside FFB (SOP/KSYPOM-LOG-004 Rev.01 and SOP/KSY2POM-LOG- 004) the mechanism of receive FFB in mill is : 1) Security guard will check the FFB delivery note or delivery note from the truck driver; 2) The truck driver shall doing weighing at weighbridge. Once done, the gross weight of the truck is taken; 3) At the time of doing weighing at weighbridge, the truck driver shall submit the FFB delivery note or delivery note to weighbridge operator. The weighbridge operator shall check whether the name of estate origin is include in the list certified suppliers or not. If included in the list certified suppliers, then is the status is FFB certified. 4) Upon completion of weighing of FFB load, the FFB shall be sent to loading ramp. The truck s driver will unload the FFB and will return to the weighbridge to be weighed again; 5) The weighbridge operator will then generate the Weighbridge Slip and this will be kept together with the FFB delivery note or delivery note; 6) A copy of the Weighbridge Slip will then be given to the driver and attached with the FFB delivery note or delivery note. Both documents need to be sent back to the estate office or seller office by the truck driver; 7) At the grading platform, the quality of FFB (e.g. fresh, unripe, under ripe, rotten bunch & etc) shall be graded & recorded on the FFB Grading report. PT Kerry Sawit Indonesia mill 1 (POM 1) has recapitulation of production report for year 2012, including volumes of FFBs received which is separated into certified and non-certified FFB volumes. In 2012, total FFB received is 218, MT of which certified FFB volume is 218, MT (99.85%) and non-certified FFB volume is MT (0.15%) and in 2013 (until April 2013), total FFB received is 69, MT of which certified FFB volume is 63, MT (90.62%) and non-certified FFB volume is 6, MT (9.38%). PT Kerry Sawit Indonesia mill 2 (POM 2) has recapitulation of production report for year 2013, including volumes of FFBs received which is separated into certified and non-certified FFB volumes. In 2013 (until April 2013), total FFB received is 52, MT of which certified FFB volume is 52, MT (100.00%) and non-certified FFB volume is 0.00 MT (0.00%). The company has a procedure or mechanism to inform the CB immediately if there is a projected overproduction. Compliance status: Full Compliance

35 Page 35 of Records Keeping Findings: The company has established a mechanism for control and maintenance of the document and data control procedure No. SOP/KSYPOM-MR-001 Rev.01 issued on July 02, 2012 and SOP/KSY2POM-MR-001 and the retention time for all records and reports has defined for at least for five (5) years. The company s procedure for records keeping is applied, with evidence as follows : the company maintains records of weighbridge slips, FFB delivery notes and FFB grading reports. All records (weighbridge slips. FFB delivery notes and FFB grading reports) are collected or complied per month. Records on the quantity of FFB received and CPO/PK dispatched daily is maintained in the weighbridge software. The mechanism to update information about production (production CPO/PK, dispatch CPO/PK, stock CPO/PK, OER and KER) to related section is by notification every morning by the logistic division. The mill (POM 1 & POM 2) maintains accurate, complete and updated records and reports. Results of verification against several documents, such as : 1. Receipt FFB dated on May 11, 2013 (delivery FFB from estate dated on May 10, 2013) has been appropriate for information of the quantity and origin product/estate between detail report each delivery order (DO) with Weighbridge slip, material delivery letter (surat pengantar buah (SPB)), grading report and Vehicle Control Form (VCF). 2. Despatch CPO dated on May 11, 2013 (Mill 2) and May 13, 2013 (Mill 1) has been appropriate for information of the quantity and information buyer (name and address) between detail report each delivery order (DO) with Weighbridge slip, delivery order (DO) from mill, delivery order (DO) from transporter, quality analyst report, statement letter of truck/tank clean, and Vehicle Control Form (VCF). 3. Despatch PK dated on January 14, 2013 (Mill 1) has been appropriate for information of the quantity and information buyer (name and address) between detail report each delivery order (DO) with Weighbridge slip, delivery order (DO) from mill, delivery order (DO) from transporter, and Vehicle Control Form (VCF). The mill has records and balances of all receipts of RSPO certified FFB and deliveries of RSPO certified CPO and PK on daily, monthly and three monthly basis. The material balance includes information about incoming FFB (certified sources and non-certified sources), incoming FFB of processed, CPO production result, OER, delivered CPO, and balance stock but in mill 2 (POM 2), fill in the quantity of receipt FFB not appropriate with category of certified or non-certified FFB at the material balance or mass balance form (CSPO product daily and monthly movement summary report). This was raised as non-conformity. All volumes of palm oil that are delivered are deducted from the material accounting system according to actual daily conversion ratios. The company has established a mechanism on how to indicate the selected supply chain model in trade documents, so that in main assessment there is information of the selected supply chain model for draft of trade documents has verified but on this surveillance audit, there are not supply chain model in trade documents due there are not sold both of product (CPO and PK) under RSPO SCCS. There are no outsourced supply chain processes in Kerry Sawit Indonesia Palm Oil mill. Compliance status: Non Compliance NCR No 2013-SCCS-02 of 02 The activity of fill in the quantity of receipt FFB not appropriate with category of certified or non-certified FFB at the material balance or mass balance form (CSPO product daily and monthly movement summary report) 4. Sales and goods out

36 Page 36 of 43 Findings: The sales and goods out mechanism of the company are described in their procedure of sales of palm oil (SOP/KSYPOM-LOG-005 Rev.01 (mill 1) and SOP/KSY2POM-LOG-005 (mill 2)) and sales of palm kernel (SOP/KSYPOM-LOG-006 Rev.01 (mill 1) and SOP/KSY2POM-LOG-006 (mill 2)). Furthermore the CSPO and CSPK product was sold will be recorded in material balance sheet. CPO dispatch from mill to buyer is accompanied by documents such as : - Weighbridge (WB) slip including information about reference number, date issued, contract number, name of buyer, type of product, sales status, the quantity of the products delivered, wet stamp for product certified (CPO/MB), name of transport company and reference to related transport documentation (name of driver and vehicle number). - Delivery Order (DO) from transport company includes information about name of transport company, vehicle number, name of driver and signature driver. - Delivery Order small (part of Delivery Order (DO) from Medan) includes information about name of buyer, number of delivery order from Medan, date issued, type of product, quantity of the product delivered, contract number, weighbridge slip number, seal number, vehicle number, name of driver and id number. - Surat Pernyataan Truck/ Tangki Bersih (statement of clean tank) - Form "Berita Acara Analisa Mutu" (Note of Quality Analysis) - Vehicle Control Form. Dispatch of PK from mill to buyer is accompanied by documents such as : - Weighbridge (WB) slip includes information about reference number, date issued, contract number, name of buyer, type of product, sales status, the quantity of the products delivered, wet stamp for product certified (PK/MB), name of transport company and reference to related transport documentation (name of driver and vehicle number). - Delivery Order (DO) from transport company for driver s truck includes information about name of transport company, vehicle number, name of driver and signature driver. - Delivery Order small (part of delivery order form Medan) includes information about name of buyer, delivery order from Medan number, date issued, type of product, quantity of the product delivered, contract number, weightbridge slip number, seal number, vehicle number, name of driver and id number. - Form of Vehicle Control (Vehicle Control Form). All products (CPO/PK) dispatched to buyer, and certified products delivered have information about reference number, date of issued, Delivery Order number, buyer name including the address of buyer, seller name including the address seller, description of the product (information about the supply chain model using the stamp on the document), the quantity of the products delivered and reference to related transport documentation. The company has implemented this system for their regular product while the company will include certified product claim and SCC certificate number on each delivery document i.e. Mass Balance. Compliance status: Full Compliance 5. Training Findings: Kerry Sawit Indonesia mill has training procedure (SOP/KSYPOM-MR-004 Rev.01, issued on July 02, 2012 (mill 1) and SOP/KSY2POM-MR-004)) and matrix of annual training program for their employees, such as matrix of training program for year In the matrix of training program was training related to supply chain. SCC training was done on March 26, 2013 attended by operators in PT Kerry Sawit Indonesia mill as seen from training records such as attendance lists, documentation and training modules. The topic of training co-

37 Page 37 of 43 vers awareness or introduction and update of RSPO SCCS (standard, supply chain models, implementation of SOPs). Compliance status : Complaince 6. Claims Findings: The company has not yet prepared a procedure for certified product communication and claim according to RSPO requirements as they have not made any claims yet. According to product traceability instruction, the mill will only make claims regarding the use of or support of RSPO certified palm oil that are in compliance with the RSPO Rules for Communication and Claims after sold CPO and PK under RSPO claim. This will confirmed during the next audit. Compliance status: Compliance with observations 3.5 Status of Previously Identified Non-conformities SCCS Non-conformance of 02 : The facility does not have up-to-date procedures covering the implementation of all the elements in the SCCrequirements, with evidence as follows : The facility does not have SOP of validity process for list supplier FFB certified in Kerry Sawit Indonesia mill. So the facility does not have complete procedure covering the implementation of all the elements inthese requirements (SCCS). The facility does not have template for PK mass balance report in the procedure of supply chain Mass Balance model, the facility does not have format of sales administration report for PK product in the procedure of sales administration, and the facility does not define the mechanism of delegation of authority when MR can not carry out their duty in the procedure of Management Representative (MR) inauguration. The facility has not stated the definition of certified and non-certified FFB in the procedure. Correction : Mechanism of validity process for list supplier FFB certified in Kerry Sawit Indonesia mill has been developed. Facility will update the supply chain - mass balance procedure (SOP/KSYPOM-LOG-014 Rev.01) about format of PK mass balance report. Facility will update the inauguration MR procedure (SOP/KSYPOM-MR-002 Rev.01) about mechanism of appointment of replacement personnel if the Management Representative (MR) did not attend to their duties at the time of audit. Definition of certified and non-certified FFB is stated inside the Standard Operating Procedures for reception of FFB (SOP/KSYPOM-LOG-003 Rev.01). Corrective Action : Enhancing communication with Head Office in terms of documents fulfillments and complete requirements. Reviewing the RSPO-SCCS document with regards to document requirements. Ensure that the MR will be present during the audit time. MR has to notify if he can not be present during the audit time. Auditor Conclusions : Closed.

38 Page 38 of 43 Date of closure: November 26, 2012 Verification result : The company provided updated SOPs relevant for SCCS implementation at PT Kerry Sawit Indonesia mill, such as : 1. Supply chain-mass balance model procedure (SOP/KSYPOM-LOG-014 Rev.02). This procedure was updated about format of PK mass balance report (page 7). 2. The Standard Operating Procedure for reception of FFB (SOP/KSYPOM-LOG-003 Rev.02) now states the definition of certified and non certified FFB (page 1). In the SOP, it is also informed too about the validity process of FFB certified supplier list in Kerry Sawit Indonesia POM. Checking of the validity of the supplier performed every three month by MR. 3. The company provided an Internal Memo (No.001/DC/KSYPOM/IM/VI/12, dated on June 22,2012) about delegation of duties and authority for Management Representative. The Internal Memo states the mechanism of appointment of replacement personnel if the personnel in charge (PiC) did not attend to their duties e.g Management Representative (MR). All procedure has been up-dated and internal memo above has available and implemented in the mill (POM 1 and POM 2). Management Representative (MR) in mill 1 has been replaced from Mr Eka Saputra to Mr Doddy Setiawan. SCCS Non-conformance of 02 : The facility has been not planned and done supply chain training for supply chain procedures. Correction : Facility will plan training on the matrix of training program and do supply chain training about the explaination of supply chain procedures that had been developed to internal team. Corrective Action : Facility will inventory all required training within one year Auditor Conclusions: Closed. Date of closure: November 26, 2012 Verification result : The company provide a revision of matrix of training program 2012 in Kerry Sawit Indonesia POM. It is document explain that socialization or training of the implementation of supply chain procedure that had been developed for all staff has planned on October The company provided records of training which was conducted on October 8, 2012 including attendance list, training materials and post test results. Revision of matrix or training program 2012 and evidence that the company has conducted has been available in mill 1. In year 2013, the company has been planned supply chain training in matrix of training program. 3.6 Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions SCCS Non-conformance of 02 : The facility does not have established procedure/mechanism for receive and delivery PK in temporary warehouse Sampit.

39 Page 39 of 43 The facility does not have up-to-date procedures (SOP/KSYPOM-LOG-014) does not explain the type of delivery that are allowed to write the quantity of dispatch PK in column 24. Correction : Receive and delivery PK procedure/mechanism in the temporary warehouse - Sampit will be maked Add annotations that dispatch can be done when delivery of PK directly from the mill to the ship and from the temporary warehouse to the ship. While dispatch from the mill to the temporary warehouse not recorded in the mass balance reports. Corrective Action : Up-date of procedure/mechanism and records and reports which related when there is a change for flow of logistics in mill Auditor Conclusions : Closed. Date of closure : July 12, 2013 Verification result : The company provided new and updated SOPs relevant for SCCS implementation at PT Kerry Sawit Indonesia mill, such as : Procedure of temporary warehouse for PK product (SOP/MSPOM-LOG-015 Rev.00 issued on September 02, 2013). This is new procedure explain receive of PK and delivery of PK in temporary warehouse. The Standard Operating Procedure for Supply Chain-Mass Balance (SOP/KSYPOM-LOG-014 Rev.02) has updated where there are add annotations that dispatch can be done when delivery of PK directly from the mill to the ship and from the temporary warehouse to the ship. While dispatch from the mill to the temporary warehouse not recorded in the mass balance reports (section of information column 24 on page 7 of 8). SCCS Non-conformance of 02 : The activity of fill in the quantity of receipt FFB not appropriate with category of certified or non-certified FFB at the material balance or mass balance form (CSPO product daily and monthly movement summary report). Correction : The facility will revise of filling in quantity on the mass balance with certified FFB group (FFB from PT Mustika Sembuluh, PT Kerry Sawit Indonesia and PT Sarana Titian Permata) and non-certified FFB group which appropriated with production report in POM 2 Corrective Action : Socialization and up-date of information about supplier of certified FFB to management POM 2 Auditor Conclusions : Closed. Date of closure : July 12, 2013 Verification result : The company provide a revision of mass balace report (CSPO/CSPK product daily and monthly movement summary report) where colums of receiving FFB are divided into certified FFB/sustainable and non-certified FFB/non-sustainable. Further, information of quantity of the certified FFB/sustainable and non-certified FFB/non-sustainable has true filled it where total volume FFB in column of certified FFB comes from estates which have been certified.

40 Page 40 of Noteworthy Positive Component Criterion 5.3. (Minor indicator 1) Management plan of hazardous waste and instruction of disposal of agrochemicals and their containers waste in accordance with the product label and existing regulations. Good domestic waste storage system and house keeping well maintained at KSI 1 estate Criterion 6.5 (Minor indicator 1) Growers and millers provide adequate housing, water supplies, medical, educational, and other facilities for employees where such facilities are not available or accessible. Good worker housing and progress for new workers housing construction Criterion 4.2 (Minor indicator ) Good maintenance of decanter cake hoper, fiber catchment, the closure of liquid sewage containing calcium Criterion 4.4. (Major indicator 1) Protection of watercourses and wetlands, including maintaining and restoring appropriate riparian buffer zones at or before replanting. 1. There is a construction of oil trap for water discharged to Lindung Bulan River. 2. Improving the quality of "trench" on infiltration pond on land application 3.8 Conclusion and Recommendation for RSPO P & C and Supply Chain Certification The audit team has confirmed through the audit process that PT Kerry Sawit Indonesia has established and maintains an effective system to ensure compliance with the RSPO P & C and Supply Chain Certification System requirements (dated November 2011). It is also confirmed that the company s annual volume of CPO and PK sold for the period of 2012 has not exceeded the certified annual tonnages as claimed in the organization s RSPO certificate no because no CSPO and CSPK claimed product sold as until 2 nd surveillance audit. TUV Rheinland recommends that Kerry Sawit Indonesia Mill (POM 1 & POM 2) and estate be continuing approved for certification of compliance to the RSPO P & C and Supply Chain Certification System requirements Issues Raised by Stakeholders and Findings Pertaining to Issues None

41 Page 41 of CERTIFIED ORGANISATION S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY 4.1 Date of Next Surveillance Visit The next surveillance visit is planned for Acknowledgements of Internal Responsibility and Formal Sign-Off by Client It is acknowledged that the assessment visit was carried out as described in this report and we accept the assessment findings and report content. Signed on behalf of PT Kerry Sawit Indonesia Signed on behalf of TUV Rheinland Malaysia Simon Siburat Group Sustainability Controller July 17, Aswan Hasibuan Lead Auditor July 17, 2013

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