PT. PP London Sumatera Indonesia Tbk. Dolok Mill and Its Supply Base

Surveillance Audit for PT. PP London Sumatera Indonesia Tbk. Dolok Mill and Its Supply Base FMS40044 RSPO Membership number: 1-0015-04-000-00 RSPO Member Name: PT PP London Sumatra Indonesia Tbk Audited Address: Dolok Mill: Desa Perkebunan Dolok, Kecamatan Limapuluh, Kabupaten Batubara, North Sumatera IDN Its supply bases: Dolok Estate: Kecamatan Limapuluh, Kabupaten Batubara, North Sumatera IDN Bah Lias Estate: Kecamatan Bandar, Kabupaten Simalungun, North Sumatera IDN Bah Bulian Estate: Kecamatan Raya Kahean, Kabupaten Simalungun, North Sumatera IDN Si Bulan Estate: Kecamatan Tebing Syahbandar, Kabupaten Serdang Bedagai, North Sumatera IDN Date of audit: 27/05/2016 COMMERCIAL- IN CONFIDENCE I The contents of this report must not be disclosed to a third party without the agreement of the SAI Global Client Doc ID: 3843 / Issue Date May 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 1 of 230

Table of contents Page Executive Overview 4 Abbreviations Used 5 1.0 SCOPE OF THE ASSESSMENT 1.1 Introduction 7 1.2 Audit Objective 7 1.3 Scope of Certification 7 1.3.1 Palm Oil Mill 8 1.3.2 Oil Palm Estate 8 1.4 Location of Mill and Estates 8 1.5 Description of Supply Base 16 1.6 Date of Plantings 16 1.7 Area of Plantation 17 1.8 Approximate Tonnages Offered for Certification (CPO and PK) 18 1.9 Other Certificates Held 22 1.10 Organisational Information/Contact Person 22 1.11 Time Bound Plan for Other Management Units 22 1.12 Partial Certification Requirements 23 1.13 Date of Issue of Certificate dan Date of Previous Assessment 24 2.0 AUDIT PROCESS 2.1 Certification Body 24 2.2 Audit Methodology 24 2.3 Qualification of the Lead Auditor and Audit Team Members 25 2.4 Stakeholder Consultation 26 2.5 Date of Next Surveillance Visit 27 3.0 AUDIT FINDINGS 3.1 Action taken on previous audit issues 27 3.2 Claim and use of certification mark and or logo 27 3.3 Description of audit findings 28 3.3.1 RSPO Principle and Criteria, Indonesian National Interpretation 28 3.3.2 Mill Supply Chain Requirements 160 3.3.2.1 Supply Chain Certification Standard 160 3.3.2.2 Supply Chain Certification System 170 3.4 Recommendation 171 3.5 Environmental and social risk for this scope of certification for 171 planning of the surveillance audit 3.6 Acknowledgement of Internal Responsibility and Formal Sign-off of 172 Assessment Findings Page List of Tables 1 Mill and Estates GPS Locations included in certification assessment 8 2 FFB Production of the supply base May 2016 April 2017 16 3 Estate Age Profiles of Planted Palms 2016 16 4 Land use description of Dolok, Bah Lias, Bah Bulian and Si Bulan 17 Estate in 2016 5 Estates and Area Planted 2016 18 6 FFB Production Trend 2011 2015 18 7 Total CPO and PK Production 2015 and Estimate Production of 2016 18 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 2 of 230

8 Mill Production and Delivery of ALL Certified Products (CPO and 20 PK), actual volume since date of last reporting period 9 Estimated Production of Certified CPO and PK 21 10 Certificates Held by Mill and Estates 22 11 RSPO Certification Time Bound Plan 22 12 List of internal and external stakeholder 26 List of Figures Page 1a-d2 Map of Mill and Estates Location 9-15 List of Appendices Page A Audit Record 173 B Previous nonconformities, corrective actions and status 180 C Nonconformities, Corrective Actions and Observations 196 Summary D Stakeholder s issues and comment 227 E Definition of, and action required with respect to audit findings 230 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 3 of 230

Executive Overview This is the first (1 st ) annual surveillance audit visit on 23 27 May 2016 against the Generic RSPO Principles and Criteria for Sustainable Palm Oil Production, May 2013 and RSPO Supply Chain Certification Standard, CPO Mill, Module D Identity Preserved, November 2014. PT PP London Sumatra Indonesia Tbk Dolok Mill operations is comprised 1 (one) Palm Oil Mill and 4 (four) FFB supply bases owned by PT PP London Sumatra Indonesia Tbk. There was no supply base from independent third party. Six (6) minor and sixteen (16) major non-conformances were issued during this audit.the organisation has followed up by submitting correction and corrective action plan. Follow up audit for verification on the correction and corrective action of the major and minor NCR issued was done on 25 August 2016. The issued findings in the 1 st annual surveillance audit has been rectified and considered as closed. The audit concluded that PT PP London Sumatra Indonesia Tbk Dolok Mill and its supply bases operation were found complies with the requirements of the Generic RSPO Principles and Criteria for Sustainable Palm Oil Production, May 2013 and RSPO Supply Chain Certification Standard, CPO Mill, Module D Identity Preserved, November 2014. The estimate figures of production offered for certification 2016 are: Estimated tonnage of certified CPO produced Estimated tonnage of certified PK produced 39,970 MT 10,033 MT Therefore PT PP London Sumatra Indonesia Tbk Dolok Mill and supply bases can continues to be certified as RSPO Identity Preserved Model CPO and PK producer. WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 4 of 230

Abbreviations Used AK3U AMDAL AME BHL BKM BLE BLH BLRS BOD BPN COD CPO CSR DLE DO EFB EMS EWS FFB GAPKI GPS Ha HCV HGU GHG HIPERKES HO IDN IPM ISCC ISO ISPO Jamsostek Kepmen KTU LA LD Lonsum LSU LTI MCU MSDS MT NCR NGO OER OHS OHSAS P2K3 Occupational Health and Safety Expert (Ahli K3 Umum) Environmental Impact Analysis (Analisis Dampak Lingkungan) Area Manager Engineering Daily worker (Buruh Harian Lepas) Log book of group leader activity (Buku Kegiatan Mandor) Bah Lias Estate Environmental Agency (Badan Lingkungan Hidup) Bah Lias Research Biological Oxygen Demand National Land Agency (Badan Pertanahan Nasional) Chemical Oxygen Demand Crude Palm Oil Corporate Social Responsibility Dolok Estate Delivery Order Empty fruit bunch Environmental Management System Early Warning System Fresh Fruit Bunch Indonesian Palm Oil Association (Gabungan Pengusaha Kelapa Sawit Indonesia) Global Positioning System Hectare High Conservation Value Land Use Title (Hak Guna Usaha) Green House Gases Industrial Hygienist Head Office Indonesia Integrated Pest Management International Sustainability Carbon Certification International Standards Organisation Indonesia on Sustainable Palm Oil Man Power Social Assurance (Jaminan Sosial Tenaga Kerja) Degree of Man Power Ministry (Keputusan Menteri Tenaga Kerja) Head of Administration (Kepala Tata Usaha) Land Application Lethal Dosage London Sumatera Leaf Sampling Unit Loss Time Incident Medical Check-Up Material Safety Data Sheet Metric Ton Non Conformance Report Non-Government Organisation Oil Extraction Rate Occupational Health and Safety Occupational Health and Safety Assurance Services OHS Committee WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 5 of 230

P&C Principle and Criteria PEL Environmental Evaluation Presentation (Penyajian Evaluasi Lingkungan) Permen/Permenaker Regulation of Man Power Ministry (Peraturan Menteri Tenaga Kerja) Permentan Regulation of Agricultural Ministry (Peraturan Menteri Pertanian) PK Palm Kernel PKB Joint Working Agreement (Perjanjian Kerja Bersama) PKWT Contracted worker (Pekerja Waktu Tertentu) POM Palm Oil Mill POME Palm Oil Mill Effluent PP Government Regulation (Peraturan Pemerintah) PPE Personal Protective Equipment PUK Caretaker Unit (Pengurus Unit Kerja) QC Quality Control R&D Research and Development RABQSA Quality Society of Australia RKH Daily Work Plan (Rencana Kerja Harian) RKL Environmental Management Plan (Rencana Pengelolaan Lingkungan) RPL Environmental Monitoring Plan (Rencana Pemantauan Lingkungan) RSPO Roundtable on Sustainable Palm Oil SCCS Supply Chain Certification System SG Segregation SIA Social Impact Assessment SIO Operator Lisence (Surai Ijin Operasi) SMK3 Occupational Health and Safety Management System (Sistem Manajemen Kesehatan dan Keselamatan Kerja) SPSI Indonesian Worker Union (Serikat Pekerja Seluruh Indonesia) SOP Standard Operational Procedure UKL Environmental Management Effort (Upaya Pengelolaan Lingkungan) UPL Environmental Monitoring Effort (Upaya Pemantauan Lingkungan) Walhi (Wahana Lingkungan Hidup Indonesia) WWF World Wild Fund WWTP Waste Water Treatment Plant WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 6 of 230

1.0 SCOPE OF THE ASSESSMENT 1.1 Introduction SAI Global conducted an audit of PT PP London Sumatra Indonesia Tbk. Dolok Mill and Its Supply Base on 23/05/2016 to 27/05/2016 with Major Nonconformities identified. Follow up audit has been conducted on 25 August 2016 for verification of corrective action taken by the organisation. The purpose of this audit report is to summarise the degree of compliance with the relevant criteria, as defined on the cover page of this report, based on the evidence obtained during the audit of your organisation. SAI Global audits are carried out within the requirements of SAI Global procedures which also reflected the requirements and guidance provided in the international standards relating to audit practice such as ISO/IEC 17021, ISO 19011, RSPO Certification System, relevant RSPO Supply Chain Certification System and other normative criteria. SAI Global Auditors are assigned to audits according to industry, standard or technical competencies appropriate to the organisation being audited. Details of such experience and competency are maintained in our records. The audit team is detailed in the attached audit record. In addition to the information contained in this audit report, SAI Global maintains files for each client. These files contain details of organisation size and personnel as well as evidence collected during preliminary and subsequent audit activities (Documentation Review and Scope) relevant to the application for initial and continuing certification of your organisation. Details of your primary contact persons and their contact details and site addresses are also maintained. Please take care to advise us of any change that may affect the application/certification or may assist us to keep your contact information up to date, as required by SAI Global Terms and Conditions. Please note that this report is subject to independent review and approval. Should changes to the outcomes of this report be necessary as a result of the review, a revised report will be issued and will supersede this report. 1.2 Audit Objective This is the 1 st annual surveillance audit. The purpose of this audit was to determine continuing compliance of your organization s management system with the audit criteria Generic RSPO Principles and Criteria for Sustainable Palm Oil Production, May 2013 and RSPO Supply Chain Certification Standard, CPO Mill, Module D IP, November 2014 and its effectiveness in achieving continual improvement and system objectives. It was also to verify the volume of certified and uncertified FFB entering the mill and volume sales of RSPO certified producers. 1.3 Scope of certification The scope of certification is the CPO production from one (1) Palm Oil Mill and four (4) FFB supply base owned by PT. PP London Sumatera Indonesia Tbk. WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 7 of 230

1.3.1 Palm Oil Mill Dolok Mill PT. PP London Sumatera Indonesia Tbk. Location: Desa Perkebunan Dolok, Kecamatan Limapuluh, Kabupaten Batubara, North Sumatera IDN GPS Location: East 99 o 25 49.18 North 3 o 9 53.68 Mill capacity: 45 MT FFB/hour 1.3.2 Oil Palm Estate 1.3.2.1 Dolok Estate PT. PP London Sumatera Indonesia Tbk. Location: Kecamatan Limapuluh, Kabupaten Batubara, North Sumatera IDN GPS Location: East 99 o 25 47.76 North 3 o 9 54.15 1.3.2.2 Bah Lias Estate PT. PP London Sumatera Indonesia Tbk. Location: Kecamatan Bandar, Kabupaten Simalungun, North Sumatera IDN GPS Location: East 99 o 25 47.76 North 3 o 10 53.77 1.3.2.3 Bah Bulian Estate PT. PP London Sumatera Indonesia Tbk. Location: GPS Location: East 99 o 33 39.61 North 2 o 41 40.47 Kecamatan Raya Kahean, Kabupaten Simalungun, North Sumatera IDN 1.3.2.4 Si Bulan Estate PT. PP London Sumatera Indonesia Tbk. Location: GPS Location: East 99 o 9 39.11 North 3 o 15 1.11 Kecamatan Tebing Syahbandar, Kabupaten Serdang Bedagai, North Sumatera IDN 1.4 Location of mill and estates Table 1: Mill and Estates GPS Locations MILL AND ESTATE EASTING RTHING Dolok Mill 99 o 25 49.18 3 o 9 53.68 Dolok Estate 99 o 25 47.76 3 o 9 54.15 Bah Lias Estate 99 o 25 47.76 3 o 10 53.77 Bah Bulian Estate 99 o 33 39.61 2 o 41 40.47 Si Bulan Estate 99 o 9 39.11 3 o 15 1.11 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 8 of 230

Figure 1a Map of Mill and Estates Location Lima Puluh Note : DLE Dolok Estate. BLE Bah Lias Estate Source: Lonsum, April 2014 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 9 of 230

Figure 1b Map of Mill and Estates Location Serdang Note: BBE Bah Bulian Estate, SIE Si Bulan Estate Source: Lonsum, April 2014 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 10 of 230

1.5 Description of supply base The FFB sources are four (4) organisations owned by PT. PP London Sumatera Indonesia Tbk. No supply base from independent third party. The hectarage and FFB production of the plantation is shown on Table 2. Table 2: FFB Production of the supply base May 2016 April 2017 ESTATE PLANTED AREA (HA) FFB (TON/YEAR) Dolok Estate 2,997.08 50,398.39 Bah Lias Estate 3,653.56 71,699.50 Bah Bulian Estate 1,055.86 26,473.45 Si Bulan Estate 870.68 11,952.30 Total 8,577.18 160,523.65 Source: Lonsum, May 2016 1.6 Date of plantings Year Dolok Estate Table 3: Estate Age Profiles of Planted Palms 2016 Bah Lias Estate Bah Bulian Estate Si Bulan Estate Total % of Planted Area 1984 0 0 0 0 0 0 1989 0 0 0 0 0 0 1992 105.52 81.28 0 0 186.80 2.18 1993 172.58 33.21 0 26.06 231.85 2.70 1994 286.65 0 0 0 286.65 3.34 1995 0 16.49 0 0 16.49 0.19 1996 80.79 77.86 0 0 158.65 1.85 1997 0 19.89 0 74.69 94.58 1.10 1998 500.61 162.28 0 7.83 670.72 7.82 1999 208.39 7.46 84.26 114.46 414.57 4.83 2000 239.94 258.45 28.46 108.20 635.05 7.40 2001 115.70 194.90 88.76 136.88 536.24 6.25 2002 305.48 102.11 74.15 35.79 517.53 6.03 2003 159.45 154.67 0 0 314.12 3.66 2004 0 43.71 0 0 43.71 0.51 2005*) 28.44 328.51 321.58 0 678.53 7.91 2006*) 392.79 193.21 0 0 586.00 6.83 2007*) 0 1,017.43 0 0 1,017.43 11.86 2008*) 0 231.91 458.65 0 690.56 8.05 2009*) 244.85 164.90 0 0 409.75 4.78 2010 48.13 238.23 0 0 286.36 3.34 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 16 of 230

Year Dolok Estate Bah Lias Estate Bah Bulian Estate Si Bulan Estate Total Audit Report % of Planted Area 2011*) 107.76 91.78 0 0 199.54 2.33 2012*) 0 108.08 0 0 108.08 1.26 2013*) 0 0 0 0 0 0 Mature 2,997.08 3,526.36 1,055.86 503.91 8,083.21 94.24 2013*) 0 55.97 0 0 55.97 0.65 2014**) 0 33.49 0 68.54 102.03 1.19 2015**) 0 37.74 0 298.23 335.97 3.92 Immature 0 127.20 0 366.77 493.97 5.76 Total 2,997.08 3,653.56 1,055.86 870.68 8,577.18 100.00 Source: Lonsum, May 2016 Note: *) replanting **) conversion from rubber to oil palm 1.7 Area of plantation The areas details for organisation owned estates are shown on Table 5. Review of estate boundary maps could be done. There is no new open area since November 2005. Planting year above 2005 was replanting. Table 4: Land use description of Dolok, Bah Lias, Bah Bulian and Si Bulan Estate in 2016 AREA DOLOK BAH LIAS HECTARES BAH BULIAN SI BULAN TOTAL Mature area 2,997.08 3,526.36 1,055.86 503.91 8,083.21 Immature area 0 127.20 0 366.77 493.97 Total area planted 2,997.08 3,653.56 1,055.86 870.68 8,577.18 Emplacement and Mill Other plantation (Rubber/Cocoa/Coco nut) Other area (enclave, water ponds, land with slope >30%) 189.64 235.45 26.93 34.15 486.17 0 59.41 0 336.00 395.41 4.07 103.74 163.67 0 271.48 Total leased area 3,190.79 4,052.16 1,246.46 1,240.83 9,730.24 HCV Area (included in planted area 23.95 86.97 194.04 7.55 312.51 Source: Lonsum, May 2016 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 17 of 230

Table 5: Estates and Area Planted 2016 ESTATE MATURE (HA) IMMATURE (HA) TOTAL (HA) DOLOK 2,997.08 0 2,997.08 BAH LIAS 3,526.36 127.20 3,653.56 BAH BULIAN 1,055.86 0 1,055.86 SI BULAN 503.91 366.77 870.68 TOTAL 8,083.21 493.97 8,577.18 Source: Lonsum, May 2016 1.8 Approximate tonnages offered for certification (CPO and PK) Approximate tonnages offered for certification is estimated based on the organisation last three years actual FFB production of Dolok, Bah Lias, Bah Bulian and Si Bulan Estate as well as last year CPO and PK, OER and KER of Dolok Mill. The OER and KER of each supply bases were estimated based on laboratory analysis. Table 6: FFB Production Trend 2011 2015 Actual Production (MT) YEAR Dolok Estate Bah Lias Estate Bah Bulian Estate Si Bulan Estate Total 2011 60,800.97 74,751.97 25,955.59 14,746.34 161,523.28 2012 55,532.87 79,409.31 27,381.34 13,086.52 175,410,04 2013 57,000.13 76,528.40 26,756.24 12,451.38 172,736.15 2014 55,303.93 80,023.85 28,055.55 13,860.97 177,244.30 2015 54,365.36 75,115.72 27,878.72 12,851.09 170,210.89 Source: Lonsum, May 2016 Table 7: Total CPO and PK Production 2015 and Estimate Production of 2016 Supply Base FFB Processed (MT) CPO Production (MT) OER (%) Actual production May 2015 April 2016 Dolok Estate 54.943,95 13.400,74 PK Production (MT) 3.531,64 Bah Lias Estate 72.991,49 17.802,50 4.691,69 Bah Bulian Estate 27.574,23 6.725,31 24.39 1.772,39 Si Bulan Estate 12.769,28 3.114,41 820,77 Total 168.278,95 41.042,96 10.816,50 KER (%) 6.43 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 18 of 230

Estimated production May 2016 April 2017 Dolok Estate 50.398,39 12.549,20 3.149,90 Bah Lias Estate 71.699,50 17.853,18 4.481,22 Bah Bulian Estate 26.473,45 6.591,89 24.90 1.654,59 Si Bulan Estate 11.952,30 2.976,12 747,02 Total 160.523,65 39.970,39 10.032,73 Source: Lonsum, May 2016 6.25 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 19 of 230

Table 8: Mill Production and Delivery of ALL Certified Products (CPO and PK), actual volume since date of last reporting period Audit Report Month Dolok FFB Production (ton) Palm Oil (MT) PK (MT) Bah Bah Si Bah Bah Si Bah Bah Total Dolok Total Dolok Lias Bulian Bulan Lias Bulian Bulan Lias Bulian 2015 August 6,424 8,480 2,892 1,369 19,165 1,594 2,104 717 340 4,755 417 551 188 89 1,245 September 6,069 7,274 2,554 1,344 17,241 1,498 1,795 630 332 4,255 395 474 166 87 1,122 October 6,951 8,654 3,061 1,685 20,351 1,720 2,140 758 417 5,035 451 561 199 109 1,320 November 4,709 5,695 2,133 1,215 13,752 1,148 1,388 520 296 3,352 302 366 137 78 883 December 4,114 6,179 2,591 1,432 14,316 994 1,493 626 346 3,459 282 423 178 98 981 2016 January 3,125 3,182 1,294 611 8,212 763 777 316 149 2,005 207 211 86 40 544 February 2,678 4,029 1,380 707 8,794 649 977 335 171 2,132 174 261 90 46 571 March 3,478 4,032 1,788 779 10,077 848 983 436 190 2,457 229 265 118 51 663 April 2,867 3,893 1,712 557 9,029 691 938 412 134 2,175 185 252 111 36 584 Total 40,415 51,418 19,405 9,699 120,937 9,905 12,595 4,750 2,375 29,625 2,642 3,364 1,273 634 7,913 Source: Lonsum, May 2016 Si Bulan Total WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 20 of 230

Table 9: Estimated Production of Certified CPO and PK Month Dolok FFB Production (ton) Palm Oil (MT) PK (MT) Bah Bah Si Bah Bah Si Bah Bah Total Dolok Total Dolok Lias Bulian Bulan Lias Bulian Bulan Lias Bulian 2016 May 3,825 5,714 1,386 779 11,704 952 1,423 345 194 2,914 239 357 87 49 732 June 5,993 6,927 2,775 1,265 16,960 1,492 1,725 691 315 4,223 375 433 173 79 1,060 July 4,119 9,645 1,395 1,230 16,389 1,026 2,402 347 306 4,081 257 603 87 77 1,024 August 4,819 8,734 1,983 1,186 16,722 1,200 2,175 494 295 4,164 301 546 124 74 1,045 September 6,210 7,780 2,865 1,515 18,370 1,546 1,937 713 377 4,573 388 486 179 95 1,148 October 4,755 5,576 2,775 996 14,102 1,184 1,388 691 248 3,511 297 348 173 62 880 November 4,744 5,437 3,336 971 14,488 1,181 1,354 831 242 3,608 297 340 208 61 906 December 5,167 7,280 3,304 1,296 17,047 1,287 1,813 823 323 4,246 323 455 207 81 1,066 2017 January 2,474 2,843 1,433 689 7,439 616 708 357 171 1,852 155 178 90 43 466 February 2,394 4,111 1,523 646 8,674 596 1,024 379 161 2,160 150 257 95 40 542 March 3,164 4,125 1,902 734 9,925 788 1,027 473 183 2,471 198 258 119 46 621 April 2,732 3,526 1,797 646 8,701 680 878 448 161 2,167 171 220 112 40 543 Total 50,396 71,698 26,474 11,953 160,521 12,548 17,854 6,592 2,976 39,970 3,151 4,481 1,654 747 10,033 Source: Lonsum, May 2016 Si Bulan Total The FFB only comes from Dolok, Bah Lias, Bah Bulian and Si Bulan Estate, therefore Dolok Mill used RSPO Supply Chain Identity Preserved Model Module D. Based on the above figures, the estimated of certified CPO and PK offered in period May 2016 April 2017 for 1 st surveillance audit are: Estimated tonnage of certified CPO produced Estimated tonnage of certified PK produced 39,970 MT 10,033 MT WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 21 of 230

1.9 Other certificates held Table 10: Certificates Held by Mill and Estates MILL/ESTATE Dolok Mill, Dolok Estate, Bah Lias Estate, Bah Bulian Estate, Si Bulan Estate OTHER CERTIFICATION HELD ISPO by PT SAI Global Indonesia FMS40035, valid through 8 May 2020 Source: Lonsum, May 2016 1.10 Organizational information/contact person PT. PP London Sumatera Indonesia Tbk. Jl A. Yani No.2 Medan 20111 Phone : (+62-61) 4532300 Fax : (+62-61) 45504621 Contact person : Mr Muhammad Waras Head of Environmental and CSR Email : Muhammad.Waras@londonsumatra.com 1.11 Time bound plan for other management units PT. PP London Sumatra Indonesia Tbk. is committed to RSPO certification of all its Management Units located in North Sumatera, South Sumatera and East Kalimantan. Time bound plan has been developed to achieve the RSPO certification for all its Management Units and Plasma by 2016. The time bound plan is realistic and challenging. The plan is detailed on Table 5. Table 11: RSPO Certification Time Bound Plan Name of Mill Turangie Dolok Gunung Malayu Begerpang Mill Address Langkat, Sumatera Utara Batubara, Sumatera Utara Asahan, Sumatera Utara Deli Serdang, Sumatera Name of Supply Base Plantation Turangie Pulo Rambong Bungara Dolok Sibulan Bah Bulian Bah Lias Gunung Malayu Sei Rumbiya Begerpang Sei Merah Estate Address Langkat, Sumatera Utara Batubara, Sumatera Utara Serdang Bedagai, Sumatera Utara Simalungun, Sumatera Utara Asahan, Sumatera Utara Labuhanbatu, Sumatera Utara Deli Serdang, Sumatera Utara Time Bound Remarks 2014 Certified on 9 January 2015 2014 Certified on 19 August 2015 2014 Certified on 23 July 2015 2014 Certified on 10 August 2015 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 22 of 230

Name of Mill Pahu Makmur Belani Elok Arta Kencana Sei Lakitan Gunung Bais Terawas Mill Address Utara Kutai Barat, Kalimantan Timur Musi Rawas, Sumatera Selatan Lahat, Sumatera Selatan Musi Rawas, Sumatera Selatan Musi Rawas, Sumatera Selatan Musi Rawas, Sumatera Selatan Source: Lonsum, May 2016 Name of Supply Base Plantation Rambong Sialang Pahu Makmur Isuy Makmur Kedang Makmur Belani Elok Bukit Hijau Batu Cemerlang Ketapat Bening Sei Kepayang Arta Kencana Kencana Sari Sei Lakitan Riam Indah Sei Gemang Gunung Bais Eka Sari Region (Plasma) Estate Address Serdang Bedagai, Sumatera Utara Kutai Barat, Kalimantan Timur Musi Rawas, Sumatera Selatan Lahat, Sumatera Selatan Musi Rawas, Sumatera Selatan Musi Rawas, Sumatera Selatan Musi Rawas, Sumatera Selatan Time Bound Remarks 2015 Stage-1 audit in December 2014 2014 Certified in September 2015 2015 Stage-1 audit in October 2015 2015 Stage-1 audit in December 2015 2016-2016 - 1.12 Partial Certification Requirements The organisation conducted the site visit and reviewing regarding 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, land conflict, labour disputes and legal noncompliance to all management units which have not been certified to ensure that partial certification requirements were fulfilled. Site visit was conducted by the organisation for ensuring compliance against partial certification requirements according to RSPO Certification System clause 4.2.4: PT PP London Sumatra Indonesia Tbk: Terawas Indah Mill and their supply bases on 17 November 2015 PT PP London Sumatra Indonesia Tbk: Gunung Bais Mill and their supply bases on 18 November 2015 Based on the reviewing it was concluded that: There was 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. There were no land conflict and labour disputes There was no non-compliance with regulations. WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 23 of 230

1.13 Date of issue of certificate and date of previous assessment Date of issue of certificate: 19 August 2015 Date of previous audit: 21 24 April 2014 2.1 Certification body 2.0 AUDIT PROCESS PT. SAI Global Indonesia Graha Iskandarsyah, 4 th floor Jl. Iskandarsyah Raya No. 66 C Kebayoran Baru, Jakarta 12160, Indonesia Phone : +62 21 720 6186, 720 6460 Fax : +62 21 720 6207 Contact person : Ms Inge Triwulandari Technical Manager Email : inge.triwulandari@saiglobal.com SAI Global is one of the world s leading business providers of independent assurance. SAI Global provides organisations around the world with information services and solutions for managing risk, achieving compliance and driving business improvement. We provide aggregated access services to Standards, Handbooks, Legislative and Property publications; we audit, certify and register your product, system or supply chain; we facilitate good governance and awareness of compliance, ethics and policy issues and provide training and improvement solutions to help individuals and organisations succeed. The SAI Global business is driven by two equally important client needs - the mandated need for organisations to conform to regulations, standards and legislation in all their locations, and the operational need for organisations to improve business processes and procedures as well as corporate culture. As we are a global company, we can meet these needs for any client - those operating within one country's borders and in one language or those operating across borders and in many languages. There are three business units/divisions within SAI Global namely the Information Services Division, the Compliance Division, and the Assurance Division. The Assurance Division helps organisations manage risk, achieve process or product certification and drive improvement by providing training, registration audits and supplier management programs that can improve business performance. We provide independent audits, assessments and certification of your products or business processes to ensure they comply with industry standards or customer specific requirements. We understand how compliance with those standards can improve the efficiency, economy and profitability of your operation. With auditing and assessment staff located around the world, our clients include large global corporations as well as single site organisations. 2.2 Audit methodology The Surveillance Audit was performed on 23 27 May 2016 integrated with ISPO Peraturan Menteri Pertanian #19/Permentan/OT.140/3/2011. The audit programme was included in the body of report. The audit methodology for collection of objective evidences is site inspection, WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 24 of 230

documentation and record review and interview with staffs, workers, and other stakeholders. Objective evidences from documentation/record review in one area may also be cross checked with other objective evidences in other areas and with the evidence of implementation on site during the audit. During the audit, particular attention has been paid to previous non-conformities. The previous major and minor non-conformities were checked for being closed. Assessments plan has included but not be limited to areas of potential environmental and social risk. Considering previous audit findings, the mill and supply base were audited during this surveillance audit. Audit has paid special attention on some potential risks in the following areas: - All environment aspects of P&C including reporting of environmental management, waste handling (Dolok Mill and Dolok, Bah Lias, Bah Bulian and Si Bulan Estate) - All social aspects of P&C including land conflict issue (if any), customary right, labour issue, organization contribution (CSR program, empowerment of local community) (Dolok Mill and Dolok, Bah Lias, Bah Bulian and Si Bulan Estate) - All HCV aspects of P&C including identification, management and monitoring HCV (Dolok Mill and Dolok, Bah Lias, Bah Bulian and Si Bulan Estate). Audit plan is available in Appendix A of this report on page 173. 2.3 Qualification of the lead auditor and audit team member Ria Gloria Lead Auditor and audited mill and estate operation, legal aspect and SC Ria Gloria graduated with Bachelor of Chemical Engineering from Bandung Institute of Technology in 1994. She has working experience as Environmental Consultant for many years. She has completed ISO 14001 (1995), ISO 9001 (2004), RSPO P&C (2009) lead auditor training courses, RSPO SCCS (2010), ISPO (2012) lead auditor training courses. Supply Chain (2016) lead auditor training courses. For the last 11 years she has been involved in quality (ISO 9001) and environmental (ISO 14001) management system audits for very broad industrial and in the palm oil sector since 2003 for several plantations and mills. She has received training for good agricultural practices including integrated pest management and high conservation value (2008-2009). Mujinius Jalaraya Audit Team Member and audited HCV and Social Aspect Mujinius Jalaraya, Bachelor from Faculty of Forestry, Bogor Agricultural University (IPB) in 2008, Majoring in Forest Resources Conservation. He has a working experience in palm oil plantations as SHE Assistant at PT. Astra Agro Lestari Tbk in 2008-2012 and as Supervisor Sustainability at Teladan Prima Group in 2012 2014. He joined the SAI Global since April 2014 as Auditor ISO 9001: 2008, ISPO and RSPO. Various training has followed, such as : Supply Chain Lead Auditor Courses (2016), Lead Auditor ISO 9001: 2008 Training (2014), Auditor ISPO Training (2014), Lead Auditor RSPO Training (2014), HCV Assessor Training (2013), Internal Auditor ISO 14001: 2004 Training (2013 ), Training for Trainers (2013), Training OHS Expert/Ahli K3 Umum (2010), etc. He has much experience in application of quality management system, environmental and OHS management system in the company and much involved in audit of the management system. During work at SAI Global he has had experience for audit ISO 9001: 2008 in various industries and services, RSPO and ISPO audit for several oil palm plantation companies. Daniel Sitompul Audit Team Member and audited OHS Aspect Daniel Sitompul graduated with Bachelor of Chemical Engineering degree from Indonesia Institute of Technology in 1995. He has working experience as Quality, Environment and Safety Consultant for many years. He has completed ISO 14001 (2007), OHSAS 18001 (2010), Ahli K3 Umum (2007), ISO 9001 (2009), RSPO PC Training (2013), Auditor SMK3 (2013) dan ISPO Auditor WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 25 of 230

Training (2013). He has also completed the training form government regarding to Safety Management System (SMK3), PROPER and AMDAL (environment). For the last 5 years he has been involved in quality (ISO 9001), Safety (OHSAS 18001) and environmental (ISO 14001) management system consultancy and audits for very broad industrial and in the palm oil sector since 2013 for several plantations and mills. Fitria Rahmayanti Audit Team Member and audited Environmental and OHS Aspect Fitria Rahmayanti owned bachelor degree majoring health nutrition from Gadjah Mada University. She has experience as nutritionist at hospital in Jakarta. She joined SAI Global Indonesia in 2012. She has followed the lead auditor training ISO 9001:2008 (2012), ISO 14001:2004 (2012), lead auditor training ISPO (2013) also registered in local government ministry of manpower AK3U. She is also the ISPO auditor who has obtained a certificate from the ISPO Commission, Ministry of Agriculture of Indonesia, in February 2013. 2.4 Stakeholder consultation Stakeholder consultation was performed to internal and external stakeholders. Internal stakeholders included staffs and workers. External stakeholders were selected by considering that they have an interest in the organisation activities, directly border with organisation, area where the workers live. External stakeholders included NGO, government and civil societies. Letters were also sent to external stakeholders to invite for comment or individual / group discussion. Group and individual discussions with stakeholders (Table 12) were conducted during audit, to verify compliance against relevant criteria and indicator related to land status and conflict, environmental, social aspect and HCV. Surrounding village of estate and mill has been chosen to represent societies. Group and individual discussions were conducted for two sessions. First session was conducted especially for around stakeholder directly affected on estate and mill, i.e. Head of village, farmers. Second session was conducted especially for labour union, gender committee and selected workers. Group interview was conducted for workers with similar job while others were interviewed individually in the scope to verify compliance against relevant criteria and indicator related to infrastructure facility, labour, social aspect (discrimination and sexual harassment), environment and HCV. The result of stakeholder consultation used to justify fulfilment of some indicators, e.g. criterion 2.2 indicator major 3, minor 1 and minor 2, criterion 2.3 indicator major 1, criterion 6.5 indicator minor 1, criterion 6.6 indicator minor 1, criterion 6.7 indicator minor 1, criterion 6.8 indicator minor 1, criterion 6.9 indicator minor 1, 2 and 3, criterion 6.10 indicator minor 1 and 2, criterion 6.11 indicator minor 1, etc. The result of these consultations was provided in Appendix D on page 212. Table 12: List of internal and external stakeholders STAKEHOLDERS Internal stakeholder (mill and estates) Head of SPSI Head of Gender Committee Workers External Stakeholder (mill and estates) Head of Village: METHOD OF CONSULTATION Individual discussion Group Discussion Group discussion for workers with similar role, otherwise individually interviewed Group discussion WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 26 of 230

- Dolok - Si Bulan - Bah Bulian Transmigration and Labour Department of Kab. Simalungun, Batubara and Serdang Bedagai Agriculture and Plantation Department of Kab. Simalungun, Batubara and Serdang Bedagai Environmental Agency of Kab. Simalungun, Batubara and Serdang Bedagai National Land Agency (BPN) of Kab. Simalungun, Batubara and Serdang Bedagai Sub District Head (Camat) of Lima Puluh, Bandar, Se Balai, Bosar Maligas District Police of Bandar GAPKI AMAN (Aliansi Masyarakat Adat Nusantara) WWF Indonesia Sawit Watch An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent An invitation letter to comment was sent 2.5 Date of next surveillance visit The next surveillance visit will be conducted around May 2017 three months before datum month of the certification period. 3.0 AUDIT FINDINGS 3.1 Action taken on previous audits findings All non-conformances (Major and Minor) from the previous audits have been followed up by taking corrective actions. Corrective actions have been implemented and verified. All corrective actions were considered as closed satisfactorily. However there was recurrence of NC in Supply Chain Clause D.2.2. 3.2 Claim and use of certification mark and or logo CPO and PK were sold under Green Palm. The organisation did not register the transaction in etrace (Refer to NCR 2016-20). During 2015 the organisation did not record and balance CPO and PK certificate sales for each mill, but overall record for PT PP London Sumatera and started recorded for each individual mill on 2016. The data is presented in Table 13a to d below. Table 13a: Green Palm CPO Certificate Sales 2015 all PT PP London Sumatera DATE VOLUME (MT) BUYER REF 6-May-15 10.346 Fritolay (A Division of Pepsico) 11670 8-May-15 200 Kappus Seifen GmbH Riesa & Co Kg 11681 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 27 of 230

DATE VOLUME (MT) BUYER REF 8-May-15 25 Natra SA 11683 11-May-15 2.000 Beiersdorf AG 11689 12-May-15 2.775 Vandemoortele Group 11717 19-May-15 3.731 Procter & Gamble 11742 4-Jun-15 4.848 Fritolay (A Division of Pepsico) 11820 4-Jun-15 152 Fritolay (A Division of Pepsico) 11821 4-Jun-15 25 Farmo SPA 11828 5-Jun-15 1.400 AB Foods & Beverages (Thailand) Ltd. 11829 5-Jun-15 100 Daudruy Van Cauwenberghe Et Fils 11830 11-Jun-15 893 Van Delft Biscuits BV 11862 18-Jun-15 250 Advanced Liquid Feeds Ltd 11894 24-Jun-15 1.520 Sodexo 11931 24-Jun-15 10.978 Unilever Supply Chain Company AG 11968 24-Jun-15 1.500 Agro Supply A/S 11977 3-Jul-15 1.132 Frieslandcampina 12080 7-Jul-15 420 Advanced Liquid Feeds Ltd 12106 7-Jul-15 45 Advanced Liquid Feeds Ltd 12107 22-Jul-15 1.535 Conagra Foods Inc 12164 22-Jul-15 1.000 Conagra Foods Inc 12168 15-Sep-15 6.946 Fritolay (A Division of Pepsico) 12472 15-Sep-15 3.054 Fritolay (A Division of Pepsico) 12473 15-Sep-15 125 Fritolay (A Division of Pepsico) 12474 15-Sep-15 619 Fritolay (A Division of Pepsico) 12475 15-Sep-15 570 Fritolay (A Division of Pepsico) 12476 16-Sep-15 25 Maymo Cosmetics S.A 12490 28-Sep-15 500 Lantmannen Unibake Sweden AB 12579 30-Sep-15 200 Daudruy Van Cauwenberghe Et Fils 12603 30-Sep-15 3,800 Ulker Biskuvi Sanayl A.S 12604 2-Oct-15 450 Advanced Liquid Feeds Ltd 12631 6-Oct-15 1,000 Fiska Molle AS 12641 6-Oct-15 1,000 PT Brahma Binabakti 12644 6-Oct-15 550 Oy Karl Fazer AB 12656 6-Oct-15 2,375 Oy Karl Fazer AB 12661 6-Oct-15 25 Nuova Ruggeri SRL 12662 6-Oct-15 2,477 Fritolay (A Division of Pepsico) 12663 6-Oct-15 123 Fritolay (A Division of Pepsico) 12664 8-Oct-15 2,000 Fritolay (A Division of Pepsico) 12667 13-Oct-15 50 Nove Alpi SRL 12750 13-Oct-15 2,950 AB Mauri (UK) Limited 12753 20-Oct-15 3,000 Procter & Gamble 12814 22-Oct-15 1,252 Procter & Gamble 12828 22-Oct-15 300 Daudruy Van Cauwenberghe Et Fils 12833 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 28 of 230

DATE VOLUME (MT) BUYER REF Audit Report 22-Oct-15 2,700 Nevedi (Dutch Feed Industry Association) 12836 3-Nov-15 2,000 Procter & Gamble 12939 3-Nov-15 25 Carecos Kosmetik GmbH 12946 3-Nov-15 75 Advanced Liquid Feeds Ltd 12948 4-Nov-15 74 Dulcesa S.L. Unipersonal 12949 4-Nov-15 68 Culinary Arts Specialties, Inc 12951 4-Nov-15 3,360 Fritolay (A Division of Pepsico) 12952 19-Nov-15 1,000 Daudruy Van Cauwenberghe Et Fils 13107 30-Nov-15 900 PT Salim Ivomas Pratama Tbk (Refinery) 13199 2-Dec-15 100 Valio Ltd 13252 2-Dec-15 1,200 Kaka AB 13253 2-Dec-15 25 The Belgian Chocolate Group NV 13254 10-Dec-15 3,675 Mondelez Europe GmbH 13392 10-Dec-15 2,000 Kerry Foods Limited 13407 10-Dec-15 938 Delhaize Group SA/NV 13410 10-Dec-15 200 Qualityfoodgroup Spa 13412 10-Dec-15 1,862 Colgate Palmolive Company 13422 11-Dec-15 331 Cadbury India Limited 13435 15-Dec-15 5,000 Mondelez Global LLC 13453 15-Dec-15 4,028 Mondelez Global LLC 13456 15-Dec-15 4,191 Mondelez Global LLC 13458 15-Dec-15 100 Gala Kerzen GmbH 13459 15-Dec-15 709 Moi International (Aust) Pty Ltd 13460 TOTAL 112,827 Table 13b: Green Palm PKO Certificate Sales 2015 all PT PP London Sumatera DATE VOLUME (MT) BUYER REF 24-Jun-15 5.000 Unilever Supply Chain Company AG 11976 22-Sep-15 887 Colgate Palmolive Company 12507 Unilever Supply Chain Company 30-Sep-15 500 AG 12600 2-Oct-15 495 KAO Corporation 12624 6-Oct-15 500 Fritolay (A Division of Pepsico) 12665 8-Oct-15 250 Saraya Co Ltd 12690 9-Oct-15 500 Givaudan Suisse SA 12709 12-Oct-15 760 Beiersdorf AG 12740 12-Oct-15 500 Beiersdorf AG 12742 9-Nov-15 25 Pagen AB 12998 9-Nov-15 25 Pagen AB 12999 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 29 of 230

12-Nov-15 510 L'Oreal 13060 18-Nov-15 2.179 Colgate Palmolive Company 13071 18-Nov-15 704 Colgate Palmolive Company 13072 TOTAL 12,835 WI-835265 Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 30 of 230

3.3 Description of audit findings 3.3.1 RSPO Principle and Criteria PRINCIPLES 1: COMMITMENT TO TRANSPARENCY 1.1 Growers and millers provide adequate information to relevant stakeholders on environmental, social and legal issues relevant to RSPO Criteria, in appropriate languages and forms to allow for effective participation in decision making. 1.1.1 There shall be evidence that growers and millers provide adequate information on (environmental, social and/or legal) issues relevant to RSPO Criteria to relevant stakeholders for effective participation in decision making. Specific Guidance: For 1.1.1: Evidence should be provided that information is received in appropriate form(s) and language(s) by relevant stakeholders. Information will include information on the RSPO mechanisms for stakeholder involvement, including information on their rights and responsibilities. a. Does the company maintain a list of stakeholders? (E.g. listed by category and stakeholders listed should be site specific) b. What is the frequency of updating the stakeholder list? c. Is there evidence of stakeholder verification? d. What type of information is provided? (E.g. Environmental, social and legal) e. What is the frequency and level of access to this information? f. How and where is the information disseminated? g. Who is responsible for providing & updating information? h. Is there an SOP available to describe the process (of information List of stakeholder, last updated in May 21 st, 2016 Communication procedure (EMS-P05), date on 10 August 2009 Public consultation and interview with stakeholder in May 23 th 25 th, 2016 Field observation and interview with employee Organization has defined list of stakeholder and updated once a year, last updated in May 21 st, 2016 both in Si Bulan Estate, Bah Bulian Estate, Dolok Estate and Dolok Mill. Stakeholder information which was updated such as contact person, name of institution, address and phone number. Stakeholder verification has been performed by organization through visiting and contacting stakeholders directly, if there is a change then immediately will be updated. It was sighted that stakeholder verification has been done and evidenced. Information provided to public and stakeholder specified in social communication procedures -Communication procedure (EMS-P05), date on 10 August 2009. Information regarding environmental, social and legal was provide for stakeholder based on their needs since it relevant such as: Plan for social and environmental impact assessment, Occupational health and safety plan, Plan for the reduction and prevention of pollution, Company policy, Certificate/land use rights, HCV management plan, FF price, etc. Information was confidential and restricted for stakeholder such as: financial information. Documents available to the public and stakeholder can be provided to stakeholders according to their relevance through a written request to the organization. The information most frequently requested by stakeholders are information related to the management of occupational helath and safety (P2K3 report) - Disnakertrans, (Minor NCR 2016-01 closed) Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 31 of 230

sharing/dissemination)? i. Are stakeholders aware of the type of information available and the procedures for accessing the information? environmental management report (wastewater, LB3) - BLH, employment report - Disnakertrans, production data and area statements - BPS, etc. Organisation has performed the stakeholder meeting on June and July 2014 to discuss regarding corporate social responsibility program and to enhance relationship between company and stakeholder. However Information provided to the public and stakeholder has not been disseminated to the stakeholder by organisation. Organization has assigned a responsible person for providing and updating information and stakeholder that was Humas/KTU. Responsibility and function was described in Humas/KTU job description. SOP to describe the process of information sharing/dissemination defined in social communication procedure EMS-P05 dated 10 August 2009. Consultation and communication with stakeholders conducted by collecting community leaders, village heads and local community or visiting the office/the village hall to meet with the village head, village officials and community. Stakeholders do not aware regarding the type of information available and the procedures for accessing the information. It was verified during public consultation and interview with stakeholder in May 23 th 2016. 1.1.2 (M) Records of requests for information and responses shall be maintained. Minor Non-conformance 2016-01 : - No evidence that organisation has communicated to stakeholder related public information which available and defined in Communication procedure (EMS- P05), date on 10 August 2009 Guidance: Growers and millers should have a Standard Operating Procedure (SOP) to respond constructively to stakeholders, including a specific timeframe to respond to requests for information. Growers and millers should respond constructively and promptly to requests for information from stakeholders. Growers and millers should ensure that sufficient objective evidence exists to demonstrate that the response is timely and appropriate. See Criterion 1.2 for requirements relating to publicly available documentation. See Criterion 6.2 on consultation. See Criterion 4.1 on SOPs. Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 32 of 230

a. Does the company have an SOP to ensure constructive response to stakeholders? b. Who is the personnel in charge (PIC)? c. Does the SOP cover the elements under 1.1.1? d. Is there a clear time frame for response to request for information? e. Are records of requests for information and responses maintained? f. Are responses to requests for information timely and appropriate? Communication procedure (EMS-P05), date on 10 August 2009 Log Book: Notes of society and stakeholders aspirations and the information request record 2015 and 2016 Public consultation with stakeholders and the local community May 23 th 25 th, 2016 Field observation and interview with employee Organization has defined the procedure to ensure constructive response to stakeholders in Procedure Communication EMS-P05 dated 10 August 2009. Procedure described the requests for information and the aspirations of stakeholders. Requests for information can be submitted in writing to the organization, all the information and aspirations will be addressed by organization with consideration couple of things before information and aspiration was rejected or approved. Responses can be handled directly by Managers, but if necessary coordination and consideration of management, information passed on to the public. The initial response was given no later than one month after receipt of the request from stakeholders. PIC whos tasked associated with social communication are Estate manager with the daily implementing are Humas. This procedure already covers elements 1.1.1. Clear time frame for response to request for information has been explain above; The initial response was given immediately after receipt of the request from stakeholders. Records of information requests and aspirations documented in the Log Book: Notes of society and stakeholders aspirations and the information request record. Records of requests for information and responses were well maintained by the document controller. Organization responses to requests for information can be demonstrated and archived properly. The responses to requests for information were timely and appropriate. Some example for information request and responses were verified during audit. Audit Report 1.2 Management documents are publicly available, except where this is prevented by commercial confidentiality or where disclosure of information would result in negative environmental or social outcomes. 1.2.1 (M) Publicly available documents shall include, but are not necessarily limited to: Land titles/user rights (Criterion 2.2); Occupational health and safety plans (Criterion 4.7); Plans and impact assessments relating to environmental and social impacts (Criteria 5.1, 6.1, 7.1 and 7.8); HCV documentation (Criteria 5.2 and 7.3); Pollution prevention and reduction plans (Criterion 5.6); Doc ID: 3843 / Issue Date May, 2014 SAI Global Limited Copyright 2008 - ABN 67 050 611 642 Page 33 of 230