EVALUATE AND COMMENT OF THE INDEPENDENT ASSURANCE OF

SUSTAINABILITY REPORT PT VALE INDONESIA

We can see in PT Vale's sustainability report in 2018, the independent assurance

statement was prepared based on AA1000AS standards and has met the minimum
information that must be reported. Some of the information that has been included in the
independent assurance statement in PT Vale's sustainability report in 2018, which consists of:

1. Intended users of the assurance statement

PT Vale Indonesia has reported its independence assurance statement in its

sustainability report which aims to improve the quality of information and reduce the risk of
information mismatch presented to the actual situation. So, it can improve the quality of
information that will be addressed to management and other report users for decision making.

2. The responsibility of the reporting organisation and of the assurance provider

When viewed from the independent assurance statement contained in PT Vale

Indonesia's sustainability report, the responsibility between the assurance provider and the
organization is clear. So, SR Asia as assurance provider must be able to determine and
identify the minimum information that must be included in the independence assurance
statement. This minimum information must be able to convince the company's stakeholders
that the company in preparing its sustainability report complies with the sustainability
reporting principles and standards in preparing the sustainability report.

3. Assurance standard/s used, including reference to the AA1000AS (2008)

The assurance standard used by SR Asia is the AA1000 Guarantee Standard (US
AA1000). This standard is considered to strengthen the credibility and quality of the
organization's social, economic and environmental reporting. And also, PT Vale measures
and reports their social, environmental and ethical performance using leading principles,
standards and methods such as those adopted by the Global Reporting Initiative (GRI)
Standards, mining and metal sector supplementation (MMSS), and disclosure of management
approach. But, SR asia did not stated that they use AA1000AS conforms to ISAE3000. So, i
think, it can be better if SR asia used combination both AA1000AS and ISAE3000 because
combined use of AA1000AS and ISAE3000 would help ensure that sustainability assurance
is aligned not only to the needs of company’s clients but also their stakeholders.

4. Description of the scope, including the Type of assurance provided;

In determining the scope of independent assurance in PT Vale's sustainability report

and the assurance provider has considered in accordance with several things that must exist in
the independence assurance statemet, namely disclosure covered, suitable criteria, and the
level of assurance. SR Asia has determined the scope of PT vale's sustainability report audit
by determining what reviews will be carried out in the field to collect evidence. In addition,
SR Asia also undertook a review process of PT. Vale by using the data and information
contained in the sustainability report. and also, SR Asia identified PT Vale's topic material
based on activity priorities and based on logical accountability. The preparation and
implementation of the assurance program is the preparation of work programs that will be
carried out by SR Asia when it will guarantee the sustainability report of PT. Vale in 2018
has been based on the type and level of audits which in this context are type 1 and type 2 with
moderate levels.

5. Description of disclosures covered;

In the process of reviewing the suitability report of PT. Vale in 2018, SR Asia did not
disclose what data or information they were reviewing because PT Vale did not audit matters
relating to the financial statements. However, SR Asia revealed what material topics they
reviewed, namely occupational health and safety, economic performance, local community,
mine closure, and environmental compliance. in my opinion, SR Asia should disclose the
data and information that they review, such as the planned budget in the PT Vale
sustainability report, such as payments to engagement leaders, authority reviews, engagement
managers, and a team of experts in the economic, social and environmental sectors, includes
accommodation, transportation and communication, and a budget for conducting focus group
discussions with company stakeholders and company management. So that the review of the
company's sustainability report can run optimally.

5. Description of methodology;

The steps of methodology in the assurance program planned by SR Asia for the audit
of PT. Vale Indonesia in 2018 can be acceptable, namely the field observations, collection of
audit evidence, determination of the level of materiality of sustainability report information,
field observation, and group discussions with stakeholders and management. As we know in
the scope of assurance, SR asia has revealed the topic material that they are reviewing. But
they did not mention how they review this topic material. So, in my opinion, SR Asia better
provide that information like as determination of the level of materiality of this information
can be based on the type of industry of the company to be audited. PT. Vale Indonesia is
engaged in the nickel mining and processing industry whose business activities can affect the
surrounding social and environmental communities. But, in determining this materiality level
of information, SR Asia stated that they relate it to the inclusiveness, materiality, and
responsiveness and impact of the company's management to the principles of the company's
sustainability report.

The next step in the assurance procedures is to make direct observations to the field,
namely to the location of PT. Vale Indonesia. In my opinion, this observation is important to
be done by SR Asia to compare the information contained in the company's sustainability
report with the actual facts on the ground. The things that are observed are information that is
material to the company's management. in observing this field, SR Asia must also observe
the systems, processes and data used by the management of PT. Vale Indonesia to support the
disclosure of the company's sustainability performance that has been submitted in the
company's sustainability report.

By making these observations SR Asia can gather audit evidence. In my opinion,

gathering audit evidence is very important to support the independent assurance statement
which will be issued by SR Asia. In addition, in order to ensure that the principles of the
company's sustainability report are in accordance with AA1000APS standards and the
preparation of sustainability reports is in accordance with GRI standards., SR Asia evaluates
the systems and processes used by PT Vle in carrying out its report developers such as group
discussions with stakeholders and company management. Review of the Discussion Activity
is also important to confirm the information presented by the company's management in the
company's sustainability report. I think this confirmation is very important to connect the
results of field observations and audit evidence that has been collected with the confirmation
of stakeholders and company management

7. Any limitations
 The assurance provider must disclose the limitations faced when conducting audit
activities. It can also be explained how to guarantee providers to reduce the impact of the
limitations faced. SR Asia has revealed the limitations faced when implementing a assurance
program in the form of not conducting investigations or auditing reports containing
performance data, information, and disclosure of sustainability as presented in the report
content and not involving stakeholders in determining the topic material To reduce the impact
of this limitation, RS Asia immediately conducted field observations to verify the truth of the
information and data that had been audited that had been presented by PT Vale. However, in
my opinion, SR Asia as an insurance provider should also conduct an audit of PT Vale's
sustainability report to ensure that the data presented in the report is appropriate or not and to
explain in more detail how the involvement of stakeholders in this matter

8. Reference to criteria used;

The information contained in PT Vale's independent assurance statement has met the
criteria used in general. In this context the criteria used are AA1000APS which includes
assessments of the company's inclusiveness, materiality, and responsiveness in carrying out
the principles of corporate sustainability. PT Vale measures and reports their social,
environmental and ethical performance using leading principles, standards and methods such
as those adopted by the Global Reporting Initiative (GRI) Standards, mining and metal sector
supplementation (MMSS), the regulation of Indonesian finance security service. But, i think,
it can be better if SR asia used combination both AA1000AS and ISAE3000 because
combined use of AA1000AS and ISAE3000 would help ensure that sustainability assurance
is aligned not only to the needs of company’s clients but also their stakeholders.

9. Statement of level of assurance;

An independent assurance statement has been stated the level of the audit. If seen
from PT Vale's independent assurance statement, SR Asia has included the level of audit that
has been carried out, that is,. type 1 and type 2. Type 1 provides guarantee services on the
report content in connection with AA1000AS guarantee standards and AA1000AP
accountability principles. Meanwhile, type 2 is the mederate level of guarantee procedures on
the content of reports and evidence

10. Findings and conclusions concerning adherence to the AA1000 -AccountAbility

Principles (in all instances);

An independent assurance statement has been stated the findings and conclusions
relating to company compliance with AA1000APS standards that include inclusivity,
materiality, and responsiveness criteria

Inclusivity - In this independent assurance statement, I agree that PT Vale Indonesia

must provide more detailed information in the report on the methodology to define the
company's main stakeholders and identify the topics they are interested in because of this
more detailed information on the stakeholder engagement and participation process will
provide comprehensive and balanced involvement. So that it can produce strategies, plans,
actions and results that discuss and respond to social and environmental problems and
impacts, in a responsible manner.

Materiality - In this independent assurance statement, SR asia stated that PT Vale

Indonesia conducted Focus Group Discussions. Focus group discussions are conducted
internally and externally. however, discussions with internals are not very explained in the
report. It is therefore necessary to elaborate more on management involvement in evaluating
topics that will have an influence on stakeholder decision making.

Responsiveness - in addition, PT Vale Indonesia has responded to stakeholder issues

that affect its sustainability performance and has been released through decisions, actions and
performance, and communication with stakeholders. Periodic meetings with stakeholders to
discuss a number of significant issues have been carried out and are effective

11. Findings and conclusions concerning the reliability of specified performance

information (for Type 2 assurance only);

An independent assurance statement has been included the findings and conclusions related
to specific information if the type of audit carried out is type 2. In type 2 audits, the assurance
program or audit must conduct an examination of all aspects of the company's sustainability
reporting principles. SR Asia found that the risk of information and conclusions from report
errors were reduced to low, but not too low and not zero. So, it can help the management and
users in order to understand that the company's sustainability report audit process will ensure
that any information disclosed by company management will have a high level of validity and
reliability.

12. observations and/or recommendations;

 Recommendations for company management are based on deficiencies contained in
the company's sustainability report. Based on the assurance procedures taken and the analysis
conducted, I agree with the recommendations given by the assurance team such as to improve
stakeholder mapping and analysis by utilizing AA1000SES stakeholder engagement, to
produce reliable identification of stakeholder concerns. It is important, because in my
opinion, stakeholder identification can avoid the problem of conflict of interest because
stakeholder identification can provide an overview of stakeholder involvement in the
participatory process, like as in the research project, because stakeholders must be involved
in every assessment and pre-planning and planning and implementation activities. So, that
you can provide an overview of their contributions to the company and adjust them to the
interests they will receive

The advice or recommendations given by SR Asia can be used by company

management in making improvements related to the principles of sustainability in the
company's business activities. In my opinion with the recommendations that have been
prepared, company management can make improvements to the company's sustainability
report in the following year. In this stage a risk analysis can also be carried out if the
company's management does not carry out the sustainability principles that have been
suggested by the assurance provider team.

13. notes on competencies and independence of the assurance provider;

 In an independent assurance statement, the assurance provider must state the
competence and independence of the assurance provider. SR Asia has stated that they are
composed of respected Asian professionals and organizations whose aim is to support
companies and other stakeholders in adopting the principles of sustainability and social
responsibility, standards and best practices through various activities and supported by SR SR
Asia team members. experience in writing and reviewing sustainability reports and integrated
reports of organizations from various industries and understanding of standards, such as GRI
standards. they provide an honest, unbiased assessment that the SASB reporting standards,
the integrated international reporting framework, and the AA1000 series of accountability
standards are adequate mechanisms that are well implemented in organizations.

14. name of the assurance provider, and date and place

An independent assurance statement has been written about the clear name of the assurance
provider and the place and date when the independent assurance statement was signed.