Progress Update on Action Plan

Issues Actions, progress & related documents Status

A review of IOI Group’s Standard Operating Procedures that are intended to ensure compliance with principle 5 of the RSPO Principles and Criteria.

1. Internal review of the requirements under Principle 5

2. Identification of all relevant legislation and regulation pertaining to

Principle 5 using reference from P&C Indonesian Interpretation, verification with the relevant local authorities including the Ministry of Agriculture, Forestry Department, Department of Environment and Local Governor

document Legal Register Prinsip 1 to 8 submitted to RSPO and Aidenvironment

3. Identifications of all guidelines and requirement under Principle 5

particularly on the assessments and management of HCV sites and Amdal requirements

document 05-2016 (No 4) Pemantauan dan Pengelolaan submitted to RSPO and Aidenvironment

4. Consolidation of all the company’s SOPs pertaining to Principle 5

New SOPs adopted, see point (5) below

IOI is in process of adopting a new Sustainable Palm Oil Policy. A draft version has been submitted to selected group of stakeholders (NGOs, MNCs and investors) for consultation. Target date for launching new policy: mid-June

Completed Completed

Completed Completed

Issues Actions, progress & related documents Status

5. Perform Gap Analysis of the SOPs in line with the Principle 5 and the

above stated legislation & regulations and necessary guidelines and requirements in point (2) and (3) above

Completed for NPP process and used as input for item 6: revision of SOP

6. Make revision of the SOPs, if necessary, and circulate company’s SOPs

to all relevant department accordingly

SOP for NPP completed: document 02-2016 (No5) SOP NPP v01 & 05-2016 SOP Pembangunan Kebun and 20160514 Komitmen Sustainability SNA Group submitted to RSPO and Aidenvironment

Completed Completed

A statement of the means employed to ensure the identification, compliance and implementation of national and local laws and regulations related to conservation and forest areas, in order to ensure that all corrective actions are in line with principle 2 of RSPO Principles and Criteria.

7. Preparation of a Legal Register of all relevant Legislation and

Regulations pertaining to conservation and forest areas – Guided by the P&C Indonesian Interpretation and further reference with the relevant local authorities and government departments particularly the Forestry Department

Legal Register Prinsip 1 to 8 has been submitted to RSPO and Aidenvironment

8. Perform stakeholder engagement with all relevant parties on the

above Legal Register with company’s palm oil planting and our subsequent actions particularly related to forestland-kawasan hutan to determine if any further corrective actions are required and to prepare a timetable for the implementation of these corrective actions if necessary

Completed

- Completion of stakeholder engagement with Forestry Services and clarification letter is expected before Mid June 2016

Issues Actions, progress & related documents Status

discussion between IOI, AsM law firm and Aidenvironment took place 29th April 2016, minutes recorded and shared with Aidenvironment (Pending Aidenvironment’s comments)

Clarification letter from Forestry Services is expected by mid June 2016

9. Flowchart Procedure to track relevant legislation and regulations

pertaining to Palm Oil Plantation and Conservation & Forest areas

document 20160511 Flowchart Dokumen Perijinan kebun submitted to RSPO and Aidenvironment

10. Induction briefing and circulation of the Legal Register and Flowchart

Procedures to all relevant personnel

document 20160511 Flowchart Dokumen Perijinan Kebun, Legal register RSPO Prinsip 2 and Legal Register Prinsip 1 to 8 submitted to RSPO

- waiting feedback from Aidenvironment

Completed Completed

A detailed chronology of the relevant companies’ legal compliance to the requirement of Indonesian laws and regulations on the establishment and operation of oil palm plantation for each of the 3 subsidiaries which are the subject of the complaint, to ensure

11. Compilation of all Indonesian legislation, regulations, requirements

and guidance for the establishment and operations of oil palm plantation; specific reference to the P&C Indonesian Interpretation, Local Governor, Ministry of Agriculture, Forestry department, Department of Environment, Indonesia Capital Investment & Company Law, Labour Law in Indonesia and any other relevant ministries and legislations

Completed: document Legal Register Prinsip 1 to 8 submitted to RSPO and Aidenvironment

12. Preparation of the flowchart detailing the process of business

document 20160511 Flowchart Dokumen Perijinan kebun submitted to RSPO and Aidenvironment

Completed Completed

Issues Actions, progress & related documents Status

that principle 2 of the RSPO Principles and Criteria has been adhered to.

13. Sharing of all business permits, licenses, documentations and other

assessment reports for the 3 subsidiaries with the Complainant

All document stated in 20160511 Tabel Perizinan SNA Group submitted to RSPO and Aidenvironment

14. Analysis of the company’s legal applications and processes chronology

against the LUC analysis to review the correct sequential steps for all 3 subsidiaries – This sequential steps shall be adopted as the Comprehensive Checklist for future developments; The company shall also provide information on correct steps taken for PT BSS

document 20160511 Matrix of Legal Analysis and 20160511 Tabel Perizinan SNA Group performed by AsM Law firm submitted to RSPO and Aidenvironment. Feedback Aidenvironment in minutes meeting 29th April 2016

Land Use Change (LUC) analysis to be performed with the assistance of Aidenvironment and/or GEC.

Completed

- LUC analysis targeted to be completed by Mid June 2016

Clear mitigations and restoration plans on the peat area that was cleared

15. Preparation of restoration & mitigation plans for the Peat area and

the progress monitoring plans

See 16

16. Review and endorsement of the restoration & mitigations plans and monitoring plans by GEC – Mr Faizal Parish

GEC report Initial independent assessment of peatlands and HCV issues at PT BSS submitted to RSPO and Aidenvironment

GEC presented findings to Aidenvironment in meeting. Findings also shared by IOI with Greenpeace in meeting (25th May 2016)

Completed Completed

Issues Actions, progress & related documents Status

IOI is committed to execute recommendations listed in GEC report

IOI also committed to peat protection plan at landscape level

GEC will monitor progress on implementation of recommendations

17. Implementation of the above endorsed restoration works

Targeted completion by end May 2016

18. Review the implementation of the mitigation and restoration work Note: Monitoring and management of the peat areas along with quarterly reportings to be prepared for RSPO upon completion of restoration works. First report due end of August 2016 (3 months after GEC report)

Completed Completed

Peer Review of HCV assessment for the 3 Subsidiaries

19. Complainant to provide inputs to Reviewers

20. Submission of HCV assessments to Licensed Assessors for Peer

Review; Peer Reviewer is Aisyah Sileuw as agreed by Aidenvironment and RSPO

The HCV assessment reports submitted to HVC peer reviewer-Aisyah Sileuw

21. Completion of Peer reviews are subject to the Licensed Assessors

timeline

The Peer review for PT BSS and BNS has been completed and submitted to RSPO and Aidenvironment

Peer review reports for PT SKS expected to be completed by end of May 2016

Completed Completed Completed

Issues Actions, progress & related documents Status

that the planting activities conducted on land which was under forest cover up to time of development and the area outside of the Izin Usaha Perkebunan (IUP) was due to the discrepancy of the maps furnished by the Indonesian authorities

22. Jointly review of the company’s Licences, Permits, Local Decrees and

other supporting document and/or instructions with the Complainant to clarify and highlight the process adopted by the company

document 20160511 Matrix of Legal Analysis performed by AsM Law firm submitted to RSPO and Aidenvironment

document AsM Surat to RSPO on BNS Map-IUP w Kehutanan attachment submitted to RSPO and Aidenvironment

Clarification of Forest Area PT BNS with forestry services is APL – Areal Pengguna Lain: expected to be completed mid-June 2016

23. Verify any non-compliances and make corrective action if necessary

and appropriate

- Per Point 8 above :

Clarification of Forest Area PT BNS with forestry services is APL – Areal Pengguna Lain; expected to be completed mid-June 2016 (Clarification letter from Forestry Services)

- Per above if necessary

the buffer zone between the plantation and the forest areas is adequate and allows for the protection and conservation of HCV areas

24. Joint review of the Estate records and documentation along with any

relevant legislation requirements and HCV guidelines for buffer zones

Initial field visit conducted 19 – 22 April 2016

Second field visit in progress 23 May – 27 May 2016

25. Verification by technical consultants on the adequacy of the identification, monitoring and management of the HCV sites in our concession

GEC report Initial independent assessment of peatlands and HCV issues at PT BSS submitted to RSPO and Aidenvironment

IOI is committed to execute recommendations listed in GEC report

Note: Preparation of additional management systems and timetable for implementation, if necessary

Completed Completed

Issues Actions, progress & related documents Status

the construction of the canal did not harm or destroy any HCV that was on the land and complied with all legal requirements under Indonesian laws.

26. Clarification of maps, records, water diversion plan and other site

information to highlight the situation on the ground before the flood alleviation works

Completed during initial field visit 19 – 22 April 2016, see also GEC report

27. Site review and verification by Technical Consultant, GEC – Mr Faizal

Parish, of the water management & drainage network referenced in the Intertek report

Completed during initial field visit 19 – 22 April 2016, see also GEC report

28. Mr Rezit Sozer - Aksenta to provide comments on the water diversion

canal in relation to the connectivity of the HCV Site

Via email on 17th March 2016

Completed Completed Completed

List of reports submitted to RSPO

List of reports submitted to RSPO Item

1 2 3 4 5 6 7 8 9 10

20160511 Flowchart Dokumen Perijinan kebun 20160511 Matrix of Legal Analysis AsM Surat to RSPO on BNS Map-IUP w Kehutanan attachment 20160511 Tabel Perizinan SNA Group Legal Register RSPO Prinsip 2 05-2016 (No 4) Pemantauan dan Pengelolaan HCV 20160514 Komitmen Sustainability SNA Group Legal Register Prinsip 1 to 8 02-2016 (No5) SOP NPP v01 05-2016 SOP Pembangunan Kebun

9, 10 & 12 14, 22 22 13 & 14 10 3 6 2, 7, 10 & 11 6 6

11 Legal document for PT SKS

BA Pemeriksaan Lapangan IUP

DELH Kegiatan Perkebunan

Izin Lokasi

Kelayakan Lingkungan Keg Perkebunan

Kesepakatan KA-Andal BNS

Pemberian IUP BNS

13

12 Legal document for PT BNS

B.A Pemeriksaan Lap. IUP

DELH Kegiatan Perkebunan

Izin Lokasi BNS

Kelayakan Lingkungan Keg Perkebunan

Kesepakatan KA-Andal BNS

Keterangan Amdal dal Pengurusan

Pemberian IUP BNS

Telaah BPKH BNS Peta

13

List of reports submitted to RSPO Item

13 Legal documents for PT BSS

BSS peta legis

BSS SK Men Kehutanan Pelepasan Kawasan Hutan

Izin Lokasi

IUP

Surat Keterangan IUP dalam proses

13

14 15 16

Peer Review Report of HCV report for PT BNS Peer Review Report of HCV report for PT BSS Peer Review Report of HCV report for PT SKS

21 21 21

13 Initial Independent Assessment of Peatlands and HCV issues at PT BSS by GEC 16, 25, 26 & 27

14 Closing meeting PT BSS Orangutan Survey 28