Professional Documents
Culture Documents
Public Summary of SIP SMRM
Public Summary of SIP SMRM
RSPO
Assessment Report
PUBLIC SUMMARY
D.2. Statement by the Certifier Body on Behalf of PT. Sucofindo SBU-SICS ............... 50
Appendix ........................................................................................................................... 72
A. 3. 1. Location address of the mill and approximate tonnages certified (CPO and PK)
PT. Sumber Indah Perkasa operates 2 palm oil mills under PT Sumber Indah Perkasa, named
PT Sumber Indah Perkasa - Sungai Buaya Mill (SBYM) and PT Sumber Indah Perkasa –
Sungai Merah Mill (SMRM).
The raw material/FFB for PT Sumber Indah Perkasa - Sungai Merah Mill (SMRM) is supplied
from 1. Sungai Merah Estate (SMRE), and 2. KKPA Gedung Aji Baru (GABA) Estate -
Smallholder. Totally supplied FFB from these two (2) estates are 257,332.29 MT.
All estates are operated under one management of PT. Sumber Indah Perkasa. All estates
located in Lampung, INDONESIA. PT. Sumber Indah Perkasa is a member of RSPO and they
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
5of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
are implementing a program to achieve RSPO Certified Palm Oil for all its production.
There is no plan to expand the land holding and therefore Principles 7 is not applicable to this
assessment.
GPS
No. Estate Name Location
Latitude Longitude
8 E-mail ismu-zulfikar@smart-tbk.com
9 Website www.smart-tbk.com
10 RSPO membership number 1-0096-11-000-00
1. Introduction
The audit team has visited Head office at Sinarmas Land Plaza, Tower 2, 30th Floor, Jalan M.
H. Thamrin No. 51, Jakarta, Indonesia dated 13 September 2013, to find out the compliance
with the rules for partial certification standard in the whole group of Golden Agri Resources,
Ltd. (GAR Group). There are 17 mills and 61 estates (including plasma) within this group.
This is the first company in group to be certified by PT Sucofindo, SBU SICS for RSPO
certification. The team found that the company conforms to the RSPO requirements for
partial certification as stated in the final RSPO certification Systems documents, June 2007,
section 4.2.4. Progress and any issue will be verified and reported in subsequent surveillance
visits.
Estate
Tajur Beras
Seranau Estate
Sapiri Estate
17 Belian Mill Gaharu Estate PT. Paramitra West 2015
Muara Tawang Internusa Kalimantan
Estate Pratama
Belian Estate
Tengkawang
Kapuas Hulu
Team has been verified documents during partial certification audit. The companyhas conducted
Gap analysis to the whole group compare to P & C RSPO requirement. The Gap Analysis
conducted by BSI Certification Body. Randomly, the team checked the content of reports to
ensure the fulfillment of partial certification. From the sampling report, the team found that not all
report has the conclusion for the fulfillment regards to partial certification requirement.
The company has made the self declaration for partial certification rule and signed by
management. The self declaration stated as belows (a-d) :
a. Significant Conflicts
The company has the SOP for Conlict Land Resolution refers to RSPO criteria 6.4, 7.5
and 7.6. All the conflicts so far has been resolved with mutual agreement. GAR also
registerd as member of RSPO Dispute Settlement Facility Advisory Group as a
representative of grower. Supporting document is DSF RSPO member as a grower
dated 22 April 2013.
b. No replacement of primary forest and or area with HCV’s since November 2005 or year
2007 (National Interpretation)
PT. SMART Tbk, has been appointed to manage all companies under GAR Group. PT
SMART Tbk has conducted Historical HCV Assesment (HHA) in collaboration with
Faculty of Forestry, Institut Pertanian Bogor (IPB) April 2011. Historical HCV Assesment
(HHA) Report has been submitted to RSPO on May 2011. As a follow up from the
Historical HCV Assesment (HHA) Report, GAR has been proposed HCV Remediation
Plan to RSPO. Revision of HCV Remediation Plan are on going process/ discussion with
RSPO Biosdiversity and HCV Working Group (BHCV WG). Supporting documents is
Historical HCV Assesment (HHA) report.
c. No labor disputes that are not being resolved through an agreed
The company has the SOP and menchanism to resolve dispute with union labour with
mutually agreement. The latest resolution dispute document handled as evidence is
dispute between a worker (Hanadi) with PT. Foresta Lestari Dwikarya for terminated
employment. The worker has been assumed to be resigned as he has absent for 8
(eight) days in a month.The supporting document is available such as chronology of
resolution Industrial Relation between worker and PT. Foresta Lestari Dwikarya, copy of
legal verdict caseIndustrial Relations No. 08/G/2012/PHI. PN PKP from court of Industrial
Relations at Court of District Pangkalpinang. Collective agreement PT. FLD with Mr.
Hanadi No. 07/EM-pb/IV/2013 completed with the sign of each party.
Email tuti@sucofindo.co.id
Website www.sucofindo.co.id
Scope :
Signed
B.Assessment Process
B. 1. Certification Body
SUCOFINDO SUCOFINDO ICS INTERNATIONAL CERTIFICATION SERVICES (SUCOFINDO
ICS), which was formed in 1994, is one of the strategic business unit that provides certification
services for leading companies.SucofindoCertification by International Certification Services is
recognized nationally and international.Quality Management System Certification by
SUCOFINDO ICS has obtained accreditation from National Accreditation Committee (KAN-
Indonesia).
Lead Auditors and Auditors of SUCOFINDO ICS are trained professionals in the field of
international standards, auditing and management systems and are registered in the IRCA
(International Register of Certified Auditors) and IEMA (Institute of Environmental Management
& Assessment), UK. SUCOFINDO ICS certification process is supported by experts at PT.
SUCOFINDO who understand the industry sectors and services in Indonesia.
SUCOFINDO ICS Operational is supported by a network of branch and representative offices of
PT. SUCOFINDO spread in 45 cities across Indonesia.
The services provided by International Certification Services Sucofindo are:
Quality Management System Certification
Environmental Management System
ISO 22000 :2005
OHSAS 18000 Certification
Hazard Analytical Critical and Control Point (HACCP) Certification
Good Manufacturing Practice (GMP) Audit
Product Certification
Sustainable Forest Management Certification
Products Organic Food Certification
RSPO certification
ISPO Certification
Certification of Integrated Management System Certification (SMT)
Training
WarsidSumarlin (Auditor)
He graduated from Institute Agriculture of Bogor (IPB) majoring Economic and Social.
He has more than 5 years audit experiences in OSHAS and SMK3. He has successfully
completion from Lead auditor for SMK3, Lead Auditor for OHSAS and Lead Auditor for ISO
9001. He has successfully completion training RSPO by Komisi RSPO, Jakarta, ISPO Lead
Auditor Training by Komisi ISPO, Jakarta.
Rizky Qomaruzaman (Auditor)
Lead Auditor SMK3 since year 1997 till now. Lead Auditor OHSAS 18001 since year 2000.
Auditor ISO 14001 since 2002. Premises visited: many various industries, petrochemical, oil &
gas, EPC, general contractor, Palm Oil Plantation and Mill, chemical, pulp & paper, coal mining,
cement industries, and so on.
Attended Green Company Training year 2008, He has successfully completion from ISPO lead
auditor course year 2013, attended RSPO lead auditor Course at KL year 2013, attended
environmental seminar (Environmental Audit) from Environmental Ministry Republic Of
Indonesia year 2013.
Yusuf Mu’arif (Auditor)
He has graduated from Bogor Agriculture University (IPB Bogor) since March 1988.
He has more than 10 years audit experiences in auditing (internal and external audit) of
Australian Quarantine Scheme and Ministry of Agriculture of RI, ISPO, OHSAS and SMK3.
He has successfully completion training of ISPO Lead Auditor Training by Komisi ISPO, Internal
Auditor SMK3 from Ministry of Manpower and Transmigration RI that held by SICS – Sucofindo.
Kind of audit scope such as various industries, petrochemical, general contractor, plantation of
palm oil, chemical, electrical generator project, telecommunication etc.
Ganjar Gumelar (Auditor):
He graduated from University ofGadjahMada (UGM), Forestry Faculty, majoring in Forest
Management, Yogyakarta.
He has completed the training such as Indonesian Sustainable Palm Oil (ISPO) auditor training,
Komisi ISPO – Ministry of Agriculture & Komisi Akreditasi Nasional (KAN), Bogor (West Java) &
Pangkalan Bun (Kalimantan), Indonesia, 2013 ;ISO 9001 : 2000 Quality Management Systems
(QMS) Auditor/Lead Auditor Training Course (IRCA),PT. SUCOFINDO (Persero), Jakarta,
Indonesia, 2013 ; Awareness Hazard Analysis Critical Control Point (HACCP), PT. SUCOFINDO
(Persero), Jakarta, Indonesia, 2013 ; Life Cycle AssessmentWorkshop Oil Palm Plantation and
Oil Palm Milling, Life Cycle Sustainability Assessment Lab &State Minister for The Environment,
Jakarta, Indonesia, 2013 ; Assessor Training High Conservation Value Forest – HCVF,
Tropenbos International Indonesia Program, The Nature Conservancy (TNC), WWF Indonesia &
Institut Pertanian STIPER (INSTIPER) Yogyakarta, Yogyakarta, Indonesia (2011).
At the opening meeting, the team audit confirm to conduct the audit at :
Regional Office at Tulang Bawang - Lampung, include
Documentation review for transparencies
CSR plan and policy
Internal Audit program & Management Review Meeting
Land ownership and compensation mechanism
At estate, include :
Worker interviews: OSH. Sexual, religious, racial harassment. Payment scheme,
contracts. Child labor. First aid. Awareness.
Chemical stores:Storage. MSDS leaflets. Herbicide mixing areas. PPE. Ventilation.
Security.
Field inspections: Fertilizing operations. SOP’s., Herbicide application program.
Harvesting sites and efficiency. Soil maps. Land preparation. Ground cover. IPM. First
aiders and boxes. Soil erosion.
HCV’s:Identification. Management plans. Environmental Impact Assessments
Riparian zones:Width. Current and future management, monitoring system
Water management:Water courses. Water monitoring.
Road maintenance:Program and progress of road improvement.
Social amenities:Social Impact Assessments.
Workshops:Oil traps. Safe working environment. PPE.Diesel tanks. Environmental waste
management.
Line sites:Interviews with householders. Inspection of water discharge points. Water
improvement plans. Waste disposal.
Local communities. Contributions made. Employment opportunities. Social impacts.
Complaints procedures, Transparency.
At Mill include :
Mill and workshop inspections.
Documentation.
Worker interviews. SOP’s. Safe working environment. Gen sets. Walk ways. Signs. EFB.
POME treatment. Emissions. Mass balance. Diesel tanks. PPE. Fire extinguishers. First
aiders and boxes. Fuel and water usage.
OSH. Training. Management structure. First aiders.
Full document review. Completion of the checklist. Review and documentation of
evidence. All aspects of RSPO P&C’s applicable.
Worker interviews. OSH. Sexual, religious, racial harassment. Payment scheme,
contracts, union labor.
Supply Chain Certification System from receiving until finish products (CPO and PK).
Assessment. (YM)
Social Aspects : Meeting Stakeholders, Kepala Desa and Confirmation of
Local Contribution /CSR. (TSS)
Worker Welfare:Housing, Clinic, Labor Union, Worker Welfare. (WS)
12.00 Break
14.00 Location : Sungai Merah Mill (SMRM)
Best Practices & Environment Aspect. (RQ, YM & GGU)
Worker Welfare, Training, Management (WS)
OSHAS/SMK3 (WS & YM)
Social Legality, & SCC System (TSS)
16.30 End of audit
19 Jul’13 5th Day
07.30 Reporting (All Team)
12.00 Break
14.00 Closing Meeting (All Team)
17.00 Back to Lampung
22.00 Arrive at Lampung
20 Jul’13 6th Day
06.50 Back to Jakarta
always on time
C.Assessment Findings
C. 1. Lead Assessor’s Summary and Recommendation for Certification
The audit is conducted jointly Roundtable on Sustainable Palm Oil (RSPO) Certification Scheme
and Indonesian Sustainable Palm Oil (ISPO) Certification Scheme. There are 2 (two) mills and 5
(five) estates has been audited at the same time during preliminary (June, 10th-14th 2013) and
certification audit (July, 15th-19th 2013). Some of the issues between ISPO and RSPO are mainly
same such as commitment to transparency,compliance with applicable laws and regulations,
commitment to long-term economic and financial viability, environmental requirements, social
aspects, best practices of estates and mill and continuous improvement. The significant
differences which is only for RSPO requirements such as term of findings, HCV’s issue, SIA,
sexual harassment requirement, specific requirements of contractor (should be meet with
manpower regulation and well trained), and NPP requirement.
The audit conducted twice i.e. preliminary audit and certification audit. The scope of the audit for
this unit is a mill (SMRM) and two (2) estates. One (1) of the two (2) estates are smallholder
schemes KKPA Gedung Aji Baru (GABA) Estate and the own estate is Sungai Merah Estate
(SMRE). The Mill and estates has been visited during preliminary and certification audit (no
sampling).
The management (Mill and estate) showed the commitment to the implementation of the
principles and criteria of the RSPO NI-INA. The assessment has been carried out through field
visit to head office, mill and estate.
The public announcement for certification has published on RSPO website prior 30 days from
the audit certification to give the opportunity to stakeholders for comments and feedback. There
is no a grievance or complaints received from the stakeholders during 30 days of public
consultation period. Team auditors also conducted separate meeting with village head, local
community, union labor team, and government official representatives. There is some
clarification received regarding the HCV issue, conflict land, Socialization of rare and
endangered flora and fauna, transparencies, charity, etc.
There is 1 NCR minor and 8 Observations issued during certification audit. There is commitment
of management to make corrective action and for continuous improvement. There is also
improved plan for social and environmental area.
The audit team found that PT Sumber Indah Perkasa (Sungai Merah Mill (SMRM), Sungai
Merah Estate (SMRE),KKPA Gedung Aji Baru (GABA) Estate, are comply against RSPO P & C
approved for Indonesia. Therefore the recommendation of the Lead Auditor that Certificate of
RSPO is awarded to PT Sumber Indah Perkasa, Sungai Merah Mill and its estates.
Signed :
1.1 Palm oil growers and millers provide adequate information to other
stakeholders on environmental, social and legal issues relevant to RSPO
Criteria, in appropriate languages & forms to allow for effective participation in
decision making.
Company has in place a list of information that can be accessed by relevant stakeholders. Any
request for information outside the list will require Top management’s consideration and
approval.
Confidential documents are documents outside the list of information to Stakeholder, such as
commercial data and data causing negative impacts that are accessible only upon
management’s approval, e.g. conflict data. In general, data may be accessed /asked by relevant
stakeholders as long as relevant. In addition there are data that can be given only to relevant
agencies, for example production data is given to the Regency and Provincial Plantation Service.
Compliance status: Full Compliance
2 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS
2.1 There is compliance with all applicable local, national and ratified international
laws and regulations.
Company has in place evidence of its compliance with regulations related to permits,
employment, and environment. Evidence of updates to new regulations is a periodic evaluation
conducted
Sucofindo ICS by the unit’s HO and SPO officers. The last revision is dated 01 April
FRM2013
3.04 for
Issue 04 Rev. 6
22of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
2.2 The right to use the land can be demonstrated, and is not legitimately contested
by local communities with demonstrable rights
Company has a Decree of Governor No. C/202/DA/HK /1989 on Land /Site permit and land use
totaling 9,000 Hander the name of PT Sumber Indah Permai. After that, there are site permit
changes no. C/309/BPH/HK/1990 to become 9,522.11 Ha.
Company previous name is PT Sumber Indah Permai and then changes name to become PT
Sumber Indah Perkasa. Change in the company name has been notarized by a Notary Deed
dated 20 September 1990 (Benny Kristianto and associate) and secured in the Decree of the
Minister of Justice no. C2-5826 HT.01.01.Th90./HK/1990.
Companyalready has a certificate of HGU from BPN with no. 1/HGU/BPN/93 totaling 9,522.11
Ha dated 30 January 1993.
Companyalready has a certificate of HGU that consists of :
HGU issued by the Regency of North Lampung with no. 08.04.2.00037 dated 26November 1993
totaling 2,088.13 Ha and No 08.04.2.00038 dated 26 November 1993 totaling 1,899,68 Ha for
the location of SMRE
All HGUswill expire in 2027.
HGB for SMRM Mill no. 08.06.02.17.2.00062 totaled 58.20 Ha issued by Tulang Bawang
Regency dated 21 July 1999. Valid until 2029.
Company has in place a Plantation Business License (IUP) no. 956/Menhutbun-VII/2000 dated 8
August 2000 for MILL 1 unit with a capacity of 30 ton TBS/hour for a total land area of 9046.63
Ha.
Company previously has operating permit of one (1) mill for the capacity of 30 ton/hour. At the
time of preliminary audit, nonconformity was found in which the company had two (2) mills with a
capacity of 60 ton/hour each, totaled 120 ton/hour. At the time of certification audit, the company
had been following it up by processing the IUP for Mills of 120 ton FFB/hour capacity. The
company already has a letter from the Board of Investment and Regional Integrated Permit
Service with No. 800/200/BID.V/II.06/2013 dated 1 July 2013 for the management of mills with a
capacity of 120 ton FFB/hour.
Companyalready has IMB no. 503/600/XI/MB/1999 and no. 642/540/PUK-LU/94 for MillSMRM.
Compliance status: Full Compliance
2.3 Use of land for oil palm does not diminish the legal rights, or customary rights,
of other users, without their free, prior and informed consent.
Companyis a takeover from earlier company in 1990. Company states that during the period
from 1990 until the time of the audit there was no purchasing of land.
There is SOP of Land Conflict Settlement (SOP/SPO/SMRT/LH-04). So far the company and
KUD inform that there was no dispute during the period from 2010 to the present time in the area
around company site. It is said in the SOP to prioritize deliberation over legal action.
At the time of audit the Location Map of PT. Sumber Indah Perkasa No. Reg:
948/214/PMNP/VI/12 with the scale of 1: 250,000 were showed. The map should have a
sufficient scale of minimum 1: 100,000 in accordance with Decree of the Ministry of Forestry No.
48/menhut-II/2004.
Compliance status:Observation no.4
PT SIP long term replanting program up to 2020 has been established. The replanting plan will
commence in 2017 up to 2020 covering 5 estates with a total area of 23,443.87 Ha.For
plantations under the SMRE Estate, including GABA, replanting area is determined as follows:
- 2017 (planting year (TT) 1991) is 503.03 ha;
- 2018 (TT.1992) is 513.19 ha;
- 2019 (TT.1993) is 1,230.45 ha; and
- 2020 (TT.1994) is 834.23 ha
Companyhas financial statement that has been audited by the public accountant office of
Tanubrata Sutanto Fahmi & Rekan, in 2011. Tax report data for 2012 was not available yet but
there is a statement letter dated 16 April 2013 issued by the public accountant office that it is
under audit completion process.
Compliance status: Full Compliance
4 USE OF APPROPRIATE BEST PRACTICES BY GROWERS AND MILLERS
There is no TBM maintenance because the youngest is the planting year 2000
- TM maintenance includes:
(1) Tree census,
(2) Maintenance of weeded circle, harvest path, control path, and collection path
(3) Maintenance of space between palm rows
(4) Weeding
(5) Road and bridge maintenance
(6) Pest and Disease Control
(7) Pruning and Stacking of Fronds
Maintenance activities are recorded in:
- Foreman Activity Log (BKM)– daily
- Work Outcome Log (BHK) – wholesale.
- For main estate, the content of BKM and BHK is inputted into Check roll program (SAP), while
for Plasma, the BKM is summarized in the Report of Plant Maintenance.
Company has protected river border area by clearing free from oil palms with clearance space of
50 meter from river edge, and the river banks are planted with bamboo and fertifer grass to
prevent erosion. The document is SOP of PT. SIP-GALA/SOP/34 Revision 00 dated 1 March
2012. The details of rivers location and condition is described in Criteria 5.2 (HCV)
Compliance status: Full Compliance
4.4 Practices maintain the quality and availability of surface and groundwater.
Revised ANDAL Document of AMDAL of Oil Palm Plantation and Oil Palm Processing into CPO,
sources of water from Sungai Buaya and Sungai Merah. There are 3 drilled wells. The depth of
drilled wells are 10-15 meter
Water needs for Mill 1 ton TBS are 1.5 m3 of water, for domestic needs are 100 m3/day,so with
mill with a capacity of 60 ton TBS per hour, the total use of river water is 2,800 m 3/day.
The efficiency of water use for processing in the SMRM in 2013 from January to April is 0.705 m 3
per ton TBS.
The efficiency of water use for processing in the SMRM in 2012 from Januaryto Decemberis
0.479 m3 ton TBS, where the target of 1.5 m3 per ton TBS has been achieved.
River area has been planted with bamboo to prevent erosion.
The organization conduct a surface water quality monitoring program utilized by plantation
communities through RKL and RPL activities that conduct surface water and groundwater quality
measurement periodically. The report sends to the BLH of Mesuji/Tulang Bawang Regency, the
BLH of Lampung Province, and the Ministry of Environment Jakarta every six months.
The results of surface water measurement can be found in RKL and RPL that cover Sungai
Buaya, Sungai Merah mill, and 4 resident wells.
Organization has measured the quality of clean water in the resident wells with 4 resident well
sampling points. The results of clean water quality measurement of resident well number 3 is
below the Environmental Quality Standard=50 for coliform biological factor, for pH the resident
well number 1 and 4 are below the Environmental Quality Standard =6.5–9.
Routine measurements and reporting are carried out every 6 months based on RKL and RPL
activities to undertake measurements and reporting to the BLH of Tulang Bawang Regency, the
BLH of Lampung Province, and KLH Jakarta.
Organization conducted environmental measurement during the period of Semester I of 2013
that covers surface water and groundwater. For the SMRM area it covers Tapa River. The
regulatory references are the Regulation of the Governor of South Sumatera No. 16/2005
(Attachment I). The measurement results meet with the Environmental Quality Standard
requirements.The results will be reported to the government in accordance with RKL and RPL
requirements.
.
Compliance status: Full Compliance
4.5 Pests, diseases, weeds and invasive introduced species are effectively
managed using appropriate Integrated
The company has the SOP on Plant Disease and Pest Control (SOP/SMART/MCAR/VII/TA-
HPT, 1/9/2012)
The data found for IPM program at SMRE,and KKPA GABA:
(2) UPDKS (Oil Palm Leaf Eating Caterpillar), monthly since 2009-2013.
(3) Maintenance of Bio controls Plants (APH), 2009 – 2013, monthly, covering: Turnera
subulata, Antigonon sp. and Nephrolephis biesserata.
(4) Sprayers, for GABA there are 1 group @10 personnel. There is evidence of Training
Attendee List of Restricted Pesticide Use, 18/10/2011 for GABA. There are 64 attendees.
4.6 Agrochemicals are used in a way that does not endanger health or the
environment. There is no prophylactic use of pesticides, except in specific
situations identified in national Best Practice guidelines. Where agrochemicals
are used that are categorized as World Health Organization Type 1A or 1B, or
are listed by the Stockholm or Rotterdam Conventions, growers are actively
seeking to identify alternatives, and this is documented
TPS Hazardous and Toxic, whereas in implementation not in TPS Hazardous and Toxicbut in a
warehouse in which there are also used paint and thinner cans. Company needs to provide
hazardous waste warning signs in the warehouse.
Companyalready has a list of agricultural and forestry pesticiderecommended by
PesticideCommission of the Republic of Indonesia both synthetic and natural for weeds and
caterpillars such as, among others, synthetic herbicide Rolixon, Gromoxone, Roll up and natural
insecticide Cordiceps for ulat api pest control. However, company should reduce the use of
herbicide of paraquat active substance (restricted pesticide), and use herbicidesfor weeds that
are powerful but safe for operators in the long run (observation).
Compliance status: Observation no. 2
Company has established and implements occupational safety and health management system
to fulfill the obligation as per government regulation. Evidence of implementation found as
follows :
- Has established Occupational Safety, Health and Hygiene Policy of PT. SIP – Lampung
Region, dated 2/9/2011. The policy was signed by the officials of RC, PC, and PUKSPSI. The
policy goal is continually seeking to reduce hazards leading to work accidents that result in
injuries, work related diseases, goods damage, fire and explosion as well as production
process disruption and environmental pollution. Socialization of OSHPolicy is carried out in
class, through training, meetings, morning calls, morning circles, as well as displayed in the
workplace.
- Company has had and established OSHAS documentation that includes OSHAS Manual,
SOP/Procedures, Work instructions and forms that has been implemented per 1 July 2010.
Currently, most of documentation has undergone revision once.
The company has the Organizational structure and personnel in charge of OSH aspects,
i.e.OSH Officer. In order to comply with government regulatory, theCompanyhas established
P2K3 team in each Unit, consists of General OSH Expert (AK3U) who serves as the Team
secretary and team leader which are the Unit’s Manager. All P2K3 Teams have obtained
approval from local manpower agency. The approval data are as follows:
SMRM:
SMRE :
SMRE Unit, the P2K3 Team has been set up without decree from Manpower Department, but
there is a letter from an employee in the Manpower and Transmigration Service of Mesuji
Regency in the name of Drs. Rozali, MH, dated 11/01/2013. This letter explains that PT. SIP
MRE has established P2K3, and has been approved, as per 2/01/2013. However, the document
is not found in SMRE, whereas the Secretary in the name of Indra Kurniawan has received
assignment with Decree No. Kep.4118/M/DJPPK/I/2013. This issue has been raised as an
observation.
GABA:
P2K3 Teamhas obtained approval from Social, Manpower and Transmigration Service of Tulang
Bawang Regencywith No. 560/35/HIPK/II.TB/P2K3/IV/2013 with Secretary Dwi asGeneral
OSHExpert.
P2K3 Team has been conducting routine monthly meetings, on a regular basis. Minutes of
meeting are already listing the topics, description of meeting/discussion results, due date of
settlement follow up (start, finish), and PIC. The completation status of each case complete
withcompletion date, and if not yet completed then sit will be brought to the next meeting.
All work units under PT. Sumber Indah Perkasahas included its employees in the Social Security
Program (Jamsostek), starting from daily wage workers (BHL), PKWT, and SKU. The program
varies in package according to the employee status. Those with BHL status will be included after
3 consecutive months because their status rises to Daily-SKU (SKU-H). Employees with SKU-H
and PKWT status are only included for ½ packages, i.e. only JKK and JKM, whereas employees
with Monthly-SKU (SKU-B) and SKU status up to staff get full package programs, namely: JKK,
JKM, JHT, and JPK. List of Jamsostek membership is stored and recorded on manpower data
base, and already has KPJ Number. But PKWT in particular, does not have KPJ number. The
Jamsostek Insurance is not willing to give KPJ Number for reasons of non-permanent status.
The company has conducted worker health examination of BHL, PKWT, and SKU. Evidence of
examination can be shown as follows:
1) There is a recapitulation of staff and employee health examination results in 2013: (a). SMRM,
examination date: in stages from the 2nd to 5th month of 2013, for 168 workers (SKU+PKWT).
(b). SMRE, examination date: in stages from 2nd to 4th month of 2013. and (c) SMRE,
examination date: in stages from 2nd to 4th month of 2013.
Company has issued a Policy for medical examination, on Lampung Region Worker Health
Examination, approved by the Regional Controller and Production Controller, dated 1/6/2011,
containing prior-employment, periodic, and specific examination. During preliminary audit, the
examination of cholinesterase aspect has not been conducted for workers who work closely with
Hazardous and Toxic, such as: sprayers, Hazardous and Toxic waste officers, chemical
warehouse and laboratory officers. Application for this examination has just submitted. Also for
personnel working in the noisy area, the audiometry measurement has not been conducted. At
the time of the audit stage 2, company has been conducting cholinesterase and audiometry
examination for these personnel. Spirometry examination should also be programmed for
sprayers, Hazardous and Toxic waste, chemical warehouse and laboratory personnel.
The company also provides health care service by establishing a Clinic located in the SBYE
Central Office. The clinic had received permit from the Department of Health of Tulang Bawang
with Private Health Care Service Licence No. 455/503/014/SIT-BP/DK-TB/III/2004, dated
19/3/2004 and valid until 01/4/2007. License reapplication is currently under process in
connection with the regency expansion so that the status of the clinic becomes under the Mesuji
Regency. The clinic is led by a company doctor and a paramedic, both are medical certified.
Employeeshave medication in the clinic free of charge, for both PKWT and BHL status. The
service also covers the employee’s family.
There is a Procedure for Hazard Identification, Risk Assessment and Risk Control (HIRARC)
(No. SOP/SMK3/SMART/LH-02, Rev. 01). Company has conducted ISBPPR that covers the
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
30of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
whole Estate and Mill. The ISBPPR resultsare recorded in Risk Analysis Form (FP 02/SMK3-
SOP-02) and Risk Analysis Follow up Form (FP 03/SMK3-SOP-02). The reference for
preparation is the ASNZ method. Preparation of ISBPPR for Estates covers from maintenance
(fertilizer, spraying, space between palm rows, OPT, roads), harvesting, emplacement
maintenance, warehouse, workshop (all machinery), clinic, central office, washing place for keep
and Fertilizer Bags (shower sprayers).
As for Mills, it has covered the entire process from transport, security, weighbridge, TBS grading,
loading ramp, transfer carriage, sterilizer, tippler, thresher, press, clarifier, boilers, kernel,
engineering, effluent, workshop, warehouse, Hazardous and Toxicwarehouse, diesel fuel tank,
lab, office, CPO dispatch, machine unit installation, fire engines, and vehicle traffic. ISBPPR is
reviewed annually to see the effectiveness of earlier risk control application. If deemed
necessary, the additional control will be added until "low" (L) risk level is achieved. This activity is
carried out together between the operating officials and the P2K3 Secretary and Chairman.
In each Unitcompany has conducted a number of trainingrelated to safety and health
(OSH)aspects, some of which can be reported as follows:
SMRE and GABA Units:
- First aid Training, 21/5/2013, by dr. Wiyangga, from the clinic. 6 participants (4 foreman and 2
assistant clerks), materials include simulations on how to deal with accidents.
- Socialization of ISCC, ISPO, RSPO, OSH, P3K, APD, MSDS, on29/05/2013. There were 13
participants. The presenter was OSH officer.
- Socialization of procedure for handling natural disaster and fire (KTD), on 16/03/2013.
Participants were 7 security personnel.
- First aid Training, combined participants of Regional level, totaling 75 participants, on
10/10/2011.
- General OSH Expert for P2K3 secretary.
- Restricted pesticide use training, on 18/10/.2011, participants from SMRE with a total of 67
participants, on 19/10/2011. There was “Restricted Pesticide User Certification” from the
Department of Agriculture, Food Crops and Horticulture of Lampung Province.
- Special skill training, including: welder and heavy equipment operator license.
SMRM Unit:
- First aid Training, 21/5/2013, 11 participants (4 foremen, 1 security personnel, book keeper, 2
analysts, nurses, P2K3 secretary, cashier).
- Socialization of MSDS on 14/5/2013 at SMRM to 38 workers by OSH officer.
- Special skill training, including: welder and heavy equipment operator license.
Companyhas developed and established SOP related to fire prevention and mitigation, i.e.:
- SOP on Emergency Handling (SOP/SMK3/SMART/LH-09), applicable in Estates and Mills.
- Technical guidelines for dealing with emergency situation in the form of Emergency Response
Mechanism Diagram contained in form of FP 02/SMK3-SOP-10, according to conditions, i.e.:
(1) Fire
(2) Hazardous and Toxic Spill Handling
(3) Earthquake
(4) Chemical Poisoning through Ingestion.
These SOPshave been effective since 1 July 2010.Socialization has been carried out to all
workers by means of displaying at strategic locations, such as: Estate office, division office, Mill
office, workshop, and parking area in the form of banners or billboards.
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
31of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
Companyhas established Emergency Response Team by appointing its personnel. The capacity
to prevent and mitigate fireis sought to by providing the following training:
- SMRM Unit, some of the Dry PowderSquad members have attended training in the use of
portable extinguishers (Light Fire Extinguisher), dated 20/11/2010, but, only 2 out of the 7
squad members, i.e. Sudarso and Sugiarto.
- GABA Unit, Light Fire Extinguishertraining has been conductedas seen in the List of Attendees
of Light Fire Extinguisher Training, dated 7/6/2013. But, out of the Light Fire Extinguisher Team
members, there is one not yet attending the training i.e. Sulisiyanto.
- SMRE Unit, some of the Light Fire Extinguisher Team membershave attended Light Fire
Extinguisher training on 29/05/2013 and 20/11/2011 in Division 1 office. But out of that number
of Light Fire Extinguisher Team the TTD/ERP Structure has not received training.
For SMRM mill area, company should have fire mitigation officers in accordance with the
provisions of the Decree of the Minister of Manpower No. 186/MEN/1999. Based on Annex 1
and 3, a processing plant (Mill) is classified as vegetable oil mill with Moderate Fire Potential III.
A factory with a total workforce of over 100 people should have fire mitigation officers: 1 for
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
32of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
class A, 1 for class B, 5 for class C, and 12 for class D. At the time of the audit stage 2, the
Company had carried out Fire Simulation Training, dated 05/07/2013 from the Department of
Social, Manpower and Transmigration, Tulang Bawang, to 20 people. However, this is only a
fulfillment for class D. Company is strongly encouraged to comply with these provisions and
required to program it in subsequent years.
Companyhas conducted various efforts related to fire prevention and mitigation, and kept the
recorded report properly. Activities carried out in various unit areas (Estates and Mills) are as
follows:
SMRM Unit:
- Fire simulation was conducted on 5/6/2013.
- Routine inspection of emergency response equipment such as: Light Fire Extinguisher,
hydrant, and sand burlap from every two week to once a month. This activity is conducted by
TTD members, or SPO Officer, or P2K3 secretary.
SMRE and GABA Units:
- Wildfire simulation was conducted on 24/3/2012 and in mid July 2013, regional level participant
unit, 68 participants. There is scenario, evaluation, photos, and attendee list.
- In GALA, simulation was conducted for potential earthquake and fire emergency situation,
dated 25/6/2013, in the location of Central Housing, complete with scenario and evaluation
but simulation for chemical spill mitigation is not yet conducted.
- Patrol activity is conducted by Security Team to monitor HCV and wildfire, recorded in the
Patrol Book per 2 weeks.
- Creating fire breaks in the area bordering the community plantations and or being fire
potentials, in each division – Unit.
- Develop Division’s Fire Vulnerable Area Map.
- Provide list of phone number both internal and external including for local police, local military,
hospital, fire brigade.
- Routine inspection of emergency response equipment, such as: Light Fire Extinguisher,
hydrant, and sand bag from 2 weekly to monthly. This activity is conducted by ERP
members, or SPO Officer, or P2K3 Secretary.
- Report fire prevention to the Department of Social, Manpower and Transmigrationevery 3
months,
Company has provided equipment related to OSH aspect, including PPEfor the workers. Below
are some data that can be reported through sampling:
- SMRM Unit, there is certificate of acceptance for: (1) leather gloves (2) safety shoes-workshop
for 25 people, on 9/2/2013, (3). Helmet on 15/1/2013, 5 people, (4 Boots on 4/2013, for 4
people,
- SMRE and GABA Units, there is a list of name of PPE recipient in Div.4, certificate of
acceptance dated 24/5/2013, of AP Boots (7 people), sprayers: rubber gloves, AP boots, mask
(12 people), harvesters: AP boots, helmet, safety glasses, sickle covers (27 people).
Company has an effort to fulfill with P3K provisions. Work sites have been provided with first aid
kits, though some of them are not complete in accordance with the regulatory requirements. In
the field, every foreman such as harvest and sprayer foreman carry small first aid kits containing
the required medicine. All foremen have received first aid training from company doctor. Also, in
each Unit (both Estate and Mill), a number of first aid officers have been appointed based on the
Letter of Decision on Appointment of First Aid Officer signed by P2K3 Chairman or Unit
Manager.
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
33of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
Other records related to accident recording are: (1) Recapitulation of Accident Report Every
Month (FP 03/SMK3-SOP-10), and (4) Recapitulation of SR and FR Counting (FP 04/SMK3-
SOP-10).
On Saturday 11 May 2013, an accident occurred to a plane of Fletcher type conducting air
maturing on oil palms. According to the explanation of Mr. Humala Sinaga (Lampung Regional
Controller), the results of investigation of accident of plane coming from Air Manuring Division
could not be obtained because of PT. Sumber Indah Perkasa (SIP) is just as a lessee who
provides fertilizer and aircraft runway. Investigation is immediately undertaken by the National
Commission for Transportation Safety (KNKT) on Sunday 12 May 2013 or a day after the
incident with a note that parties who want the result of the investigation are asked to contact
KNKTdirectly.
Companyhas established annual training programs. Training activities are based on SOP on HR
Development Training (SOP/SPO/SMART/LH-10, 1/7/2010, rev.01), covering: preparation,
implementation, and evaluation. There is Training Need Analysis set by Regional Training
Center Coordinator (RTCC) and the results are in the form of Training Need Identification Matrix
(FL/Estate/TRAD/10), prepared by SPO Officer, and approved by Estate Manager. The Matrixes
developed by SMRM, SMRE, and GABA units.
Annual training program is prepared and established by respective Unit. For 2013, it is:
- SMRM and SMRE: P2K3 Training Program of PT Sumber Indah Perkasain 2013, prepared
and established by P2K3 Secretary, and P2K3 Chairman. Also, there is P2K3 Training
Program (for Sustainability areas) covering: OSH, Environment, social, HCV, greenhouse
gas emission, sexual harassment, and PHT.
- GABA : Training Program 2013, signed by person in charge of SPO Unit and approved by
Unit Head as per 05/01/2013. Training materials include: P3K, proper, socialization/training
of ISCC, ISPO-RSPO, PHT, harvesting, HCV, Kompes, procedures & WI, PPE, Hazardous
and Toxic waste control, GHG mitigation, GHG emission calculation, preventionof sexual
harassment, socialization of communication and consultation, socializationof SOP on
contractor control, socializationof jamsostek to contractors.
All recordsshowing evidence of training implementation, such as: attendee list and photographs,
and certificate are kept by KTU, while training records for sustainability are also kept by SPO
Officer. Each Unit records training realization. For example, in GALA as well as MSJA Units. It is
recorded in Training Recapitulation form that includes information: name of training, instructor,
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
34of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
Company is deal with trained contractor personnel. As mentioned in the above training program,
each contractorof SMRM Mill, SMRE Estate, as well as GABA Unit has been provided with
related to RSPO, which includes :
Companyconducted impact analysis in the Revised ANDAL document ofAMDAL of Oil Palm
Plantation and Oil Palm Processing into of CPO PT Sumber Indah Perkasa with an land area of
9,254 Ha and MILL with the capacity of 60 ton FFB/Hour No. Document is
16/KOMDAL/11.04/IV/2008 dated 14 April 2008.
In ANDAL document the scope of environmental impact analysis is oil palm plantationactivity
and processing into crude palm oil (CPO). The scope of environmental impact analysis is Sungai
Buaya Estate, Sungai Merah Mill and Estate, Gedung Aji Baru Plasma, Gedung Aji Lama
Plasma, Mesuji Estate, Sungai Buaya Mill, and Sungai Merah Mill. In ANDAL document, the
environmental impact analysis is still scoping company current activity and condition.
Environmental impact management is contained in RKL and monitoring plan is contained in
RPL. The RKL and RPL is implemented every 6 months and report every 6 months to BLH of
Mesuji Regency (SBYE, GABA, MSJE, SBYM), Tulang Bawang Regency (SMRM, SMRE,
GALA, GABA)
ANDAL Document also covers land biodiversity in the form of flora and fauna (biological aspect),
social cultural aspectto the population of villages around unit and division.
Compliance status: Full Compliance
5.2 The status of rare, threatened or endangered species and high conservation
value habitats, if any, that exist in the estate or that could be affected by estate
or mill management, shall be identified and their conservation taken into
Aquatic Flora around the project location of PT. Sumber Indah Perkasa, among others:
Ganggang Hijau (Chlorophyta)
Enceng Gondok (Eichornia grassipes)
Palam (Corypha sp)
Teratai Putih (Nelumbium sp)
Pakis Air (Ceratopteris sp)
Lumut (Bryophyta)
Data of terrestrial fauna diversity in the project location of PT. Sumber Indah Perkasa prior to
plantingincludes:
Aves
Manyar (Ploceus manyar)
Tekukur (Streptopelia sp)
Jalak (Strurnus contra)
Emprit (Lanchura sp)
Cucak Rowo (Pycmonotus sp)
Elang (Bustantur sp)
Mammals
Gajah (Elephan sp)
Kijang (Cervis timorensis)
Babi (Sus vitatus)
Beruang (Urus sp)
Reptilia
Ular Piton (Phyton sp)
Kadal (Mobvia multifaciata)
Ular Sawah (Phyton molurus)
Insect
Kupu-kupu (Papilio sp)
Capung (Gomphus sp)
Kumbang (Aryetes sp)
The following is details of Identification and Analysis of the Existence of High Conservation
Value Area (HCV) of Sungai Merah Estate andKKPA Gedung Aji Baru(GABA) Estate:
HCVmonitoring is conducted every 2 weeks. Document used is Patrol Log Book which is
summarized into HCVMonitoring Form No. Document F/SMART/LH003/09 every 6 months. In
addition, there are documents:
Erosion Control Crop Planting Report
HCV Area Patrol Report
Boundary Peg Maintenance Report
Water Level Report
Socialization Invitation
HCV SocializationReport
HCV Monitoring Form has specified recommendations for improvement as well as
recommendations based on routine monitoring carried out every 2 weeks, but Person in Charge
(PIC) and a due date for the completion of recommendation should be determined to see the
progress of follow up to HCV monitoring results. (Observation)
Compliance status:Observation no.5
5.3 Waste is reduced, recycled, re-used and disposed of in an environmentally and
socially responsible manner
Companyperforms impact analysis in the revised ANDAL document of AMDAL of Oil Palm
Plantation and Oil Palm Processing into CPO of PT Sumber Indah Perkasa with a total area of
9,254 Ha and 2 Mills(SMRM and SBYM) with a capacity of 60 ton FFB/Hour.
SOP of Waste Management, SOP/SPO/SMART/LH-09, revision: 00 approval date: 1 July 2010,
covering mill waste: solid, liquid, gas (including LB3).
Plantation: expesticide packaging’s, land application, ex agrochemicals (such as fertilizer bags)
Current practice of waste flow rate measurement is only on waste that flows out directly from the
mill to Land Application recorded using flow meter every 7o’clock in the morning and at the time
when pumping is finished.
Company performs ambient air and emission quality measurements (mobile and non-mobile
sources). None of the measurement results exceeds the Environmental Quality Standard.
Company reports the measurement results every 6 months to BLH of Tulang Bawang Regency
(SMRM), BLH of Lampung Province, and Jakarta KLH, with evidence of their receipt. Liquid and
Hazardous and Toxic Substance waste results are reported every 3 months.
SMRM has 8 liquid waste ponds. Internal daily measurement in SMRM covers pH, Alkalinity, and
VFA parameters. In SMRM, company has external parties (Health Polytechnic of Tanjung
Karang Health Department) carried out the measurement of waste water, which is used for land
application, and with reference to the Decree of the Minister Environment No 29/2003. The
result showed the BOD and COD concentrations have meet with the Environmental Quality
Standard.
The organization has in place a SOP of Waste Management, SOP/SPO/SMART/LH-09, with
revision: 00, approval date: 1 July 2010, covering plant wastes: solid, liquid, gas that includes the
utilization of empty fruit bunch, shell, and fiber wastes.
The organization has Waste Processing Work Instruction of LA and Empty Fruit Bunch (EFB),
SIP-SMRE/IK/09.
The organization has in place an extended permit of liquid waste utilization for SMRM in the form
of Certificate of Extension of Permit to Utilize Waste Water on Soil (Land Application) to PT
Sumber Indah Perkasa – Sungai Merah Mill Number: 660/322/III.7/TB/XI/2012. The letter issued
from Government of Tulang Bawang Regency, Regional Environmental Agency, Menggala,
Dated 23 November 2012, which is valid for 2 years.
The utilization of empty fruit bunches at SMRE in January – April 2013 was 21,763 tons with a
total land application area of 382.89 hectares. The targeted land area for empty fruit bunch
(EFB) application for 2 years is 668 hectares. In 2012 it was 63,634 tons of EFB on 1,155.74
hectares of land, with the target of 672 hectares and 49,915 tons of EFB.
Compliance status: Full Compliance
5.4 Efficiency of energy use and use of renewable energy is maximized
Company has performed identification of GHG emission sources of estate and mill activities.
Company has calculated GHG emission of the SMRM, which includes calculation of respective
GHG of estates supplying the fruit. Diesel fuel efficiency at SMRM in 2010 was 27.46%, 2011
was 44.32%, and 2012 was 33.94%, so that on average the efficiency was 35.92%. Diesel fuel
use in 2010 was 1.88 liter/ton CPO, in 2011 was 1.51 liter/ton CPO, in 2012 was 1.12 liter/ton
CPO.
SMRM use of palm shell and fiber as fuel substitutes in 2012 was 10,916,000 kg and 37,891,121
kg, respectively, with the total energy used /ton CPO of 1,288,881 KKAL.
Company has SOP on Calculation of Green House Gas Emission at SMRM of PT-
SMRM/SOP/02
The use of empty fruit bunches at SMRE in January – April 2013 was 21,763 ton with total
application land area of 382.89 hectares. Target area to be applied with empty bunches for 2
years is 668 hectares. In 2012 it is 63,634 ton of empty bunches 1,155.74 hectares of land, with
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
39of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
Companydoes not burn wastes and there are no replanting activities. Companyalready bans the
use of fire for replanting. Also, Company has instructed its workers and encouraged local people
not to burn domestic garbage.
Compliance status: Full Compliance
5.6 Plans to reduce pollution and emissions, including greenhouse gases, are
developed, implemented, and monitored.
6.1 Aspects of estate and mill management that have social impacts are identified
in a participatory way, and plans to mitigate the negative impacts and promote
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
40of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
Companyhas conducted Social Impact Assessment internallyin 2012. Based on the results of
SIA it is identified that there are 14 villages around PT SIP affected by the social impact of estate
and mill operations. SIA report says that the area of main estate is 9102.2 Ha and plasma estate
is less than 15,000 Ha with total KUD member of 17,254 KK
Company has had the list of stakeholders of all units.
Based on the results of SIA and input from the units, companyhas established a strategic plan
for CSR Program of 2014-2018:period (5 years). The program has included the short-term and
long-term plans covering the aspects of education, health, infrastructure, sport, religion, arts,
culture and micro business. The existing program does not include specific efforts made by
company to preserve the native culture of indigenous people living around the company
environment.
Based on the SIA report, Company has conducted road improvement activities in 2009-2011 for
21 villages around the company site. Educational assistance is given to areas in the location of
main estate and plasma estates. Religious assistance given in 2010 period already represents
Islam and Christian religions and in 2013 it is for Hindu in the form of pura Talang Batu Village
construction.
Based on the SIA report there is negative perception because of jealousy felt by villages from
not receiving social assistance (Batu AmparVillage and Tri Rejomulyo Village). Company
responded by launching Cheap Oil Market Operation in 2012 in Batu Ampar Village and
educational assistance in the form of building materialsfor the development of local primary
school in SDN 01 Tri Rejomulya in 2013.
Compliance status: Full Compliance
6.2 There are open and transparent methods for communication and consultation
between growers and/or mills, local communities and other affected or
interested parties
There is SOP on Land Conflict Settlement (SOP/SPO/SMRT/LH-04). So far the company and
KUD give informationthat there is no dispute in the period from 2010 until now in the company’s
surrounding areas. The SOP says to give first priority to deliberation for consensus over legal
action.
Compliance status: Full Compliance
6.5 Pay and conditions for employees and for employees of contractors always
meet at least legal or industry minimum standards and are sufficient to provide
decent living wages
Companymaintains SKU Detailed Payroll (sample, May 2013), for SKU-H, SKU-B, as well as
PKWT, while for BHL and BHB such list is contained in BHL Detailed Payroll (sample, May
2013). For BHL the salary is paid twice per month, from 26th to 10th day of subsequent month,
and from 11th to 25th of ongoing month, so the payroll is made twice.
Company has company rules in the form: (1). Collective Labor Agreement between PT. SIP of
Tulang Bawang Regency, Lampung: BH.NO: 182/PT.SIP/1989 and PUK.SPPP-SPSI Trade
Union of Tulang Bawang,with Registration No.: 063/KPTS/PC/SPPP.SPSI/TB/XII/2005, for
period of 2011-2013, and (2). Company Regulations of PT. SMART Tbk, version 2013-2014.
For 2013 payment system, company refers to the Decree of the Governor of Lampung No
G/30/III.05/HK/2013 concerning Stipulation on Tulang Bawang Regency Minimum Wage (UMK)
in 2013 of Rp. 1,155,000.-, effective as per 01/01/2013. This provision has been socialized
based on SK No. 036/CEO 2/HR PSM 2/01/2013 concerning the Wage of Daily Labor (BHL) PT.
SIP-Lampung. In consideration of the above Governor Decree then decide to adjust the wage of
daily workers (BHL) to become Rp. 46,200/day. This decision comes into force from 01/01/2013.
With respect to the UMK (regency minimum wage) provisions the workers in the field have know
it precisely. This is known from the interviews with a number of BHB workers (taken by sampling)
of harvesting personnel. They inform that daily wages are Rp. 46.200,- working fulltime for 25
working days per month they will receive basic wages of Rp. 1.155.000,-,. On the wage payment
receipt of May 2013, under the name of NIK: 12003/Abdul Majid (SKU-H status) and on the
payment receipt of NIK: 12004 /Kadek Artawan a worker of GABA Unit (SKU-H status) the
wages are written Rp. 1.155.000,-. The UMK provisions are imposed to the workers with BHL
and PKWT status, and the first year SKU-H.
Company maintains companyrules in the form of: (1). Collective Labor Agreement (PKB)
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
42of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
between PT. SIP of Tulang Bawang Regency, Lampung: BH.No: 182/PT.SIP/1989 and
PUK.SPPP-SPSI Trade Union of Tulang Bawang with Registration No.:
063/KPTS/PC/SPPP.SPSI/TB/XII/2005, for 2011-2013 period, and (2). Company Regulation of
PT. SMART Tbk, version 2013-2014.
Company provides facilities and infrastructures to support and ensuring decent life. The following
is the List of Existing Welfare Facilities in PT. Sumber Indah Perkasa, SMRM Mill, SMRE Estate,
and GABA KKPA per June 2013.
Companyhas entered into a contract with contractor that requires the contractorsto comply with
applicable regulations on employment. Evidence can be seen in the contract or SPK (Working
Order) :
1). SPK No. 001-GABA/SPK-L/I/2013 -FFB Transportation & Loading between GABA Manager
vs Supradi (contractor), as follows:
- Article 5 on Terms and Specification of Work, paragraph 4 the requirements to be furnished
with Vehicle Holder Book, Vehicle Registration Card, Inspection Certificate, and First Aid Kit.
Companyalready has a Trade Union. The policy concerning permission to establish a trade
union is contained in the Circular Letter from the CEO-2 concerning Trade Union Freedom, No.
094/CEO2/SE/12/2010, dated 14/12/2010, that the freedom of association in a trade union is the
worker or employee’s fundamental rights as regulated in Act No. 21/2000 on Trade Union or
Labor Union.
The existing trade unionsare only one and covering all Unitsboth Estatesand Mills. The union
has been registered as in the Decree of Branch Board of Agricultural and Plantation Trade Union
Federation of SPSI of Tulang Bawang Regency No. 026/Kpts/PC/SP.PP-SPSI/TB/VI/2007,
dated 5/06/2007 concerning Endorsement of Work Unit Leaderships of SP.PP SPSI PT. SIP for
2007-2012 service period and has a Collective Labor Agreement (PKB) book with a registration
numberaccording to the Decree of the Head of Department of Manpower of Lampung Province
No. KEP.188.4/4811/III.05/03/I/2011. The applicable PKB is that of 2011-2013 periods.
The Trade Union Leadership terms are now extended in accordance with SK No.
100/Kpts/PC/SP.PP-SPSI/TB/VI/2012 concerning Stipulation on Work Unit Executive Board of
SP.PP-SPSI PT SIP, dated 11/06/2012, in the third dictum: “to give a full mandate to PLT PUK
SPSI PT SIP to organize the work unit meeting (Musnik)in November 2013. The second dictum:
to endorse executive boards of PUKSPSI PT SIP (there are 6 workers being endorsed).
Currently the total number of PT SIP Trade Union members, data of May 2013, is 1,102 people.
This membership is automatic in nature, when one becomes a worker of minimum SKU-H
status. Currently, the member card as proof of membership is not produced yet. The names of
members are registered in the List of Trade Union Member of respective work unit.
Bipartite Cooperation Body (LKS)has also been established in each Unit and is already
approved by local Department of Manpower. For example, the LKS Bipartite KUD Krida
Sejahtera of KKPA GABA, 2013-2015 Period, No.: 560/HIPK/II.TB/BP/IV/2013 dated 15/04/2013
by Head of Department of Manpower and Transmigration of Tulang Bawang Regency. The
membership is composed of 8 company representatives to 8 worker representatives.
Currently, the total number of PT SIP trade union members based on May 2013 data is 1,102
members. The membership is automatic once they become an employee with a minimum status
of SKU-H. Names of members are registered in the Trade Union Member List of each work unit.
Recordsof meeting both internal and external, as sample some can be reported as follows:
- Minutes of SPSI meeting with the Management of PT SIP Lampung dated 31/01/2013, with
subject “Discussion on workers’ aspiration and request”, attended by 17 workers at TT by PUK
SPSI-Sopuan, EM Gala, and HRD Jakarta.
- Minutes of PT SIP GABA Bipartit meeting, dated 15/4/2013, discussion on harvesting
personnel wages 2013 and fines of production foreman, attended by 17 workers.
- Minutes of coordination meeting between PUK and a delegation from PT. SIP Lampung SPSI
on 8/01/2013 with the agenda: discussion on various issues, among other things, working day,
employee’s (family member) death, socialization on how to establish SPSI in the units,
harvesting tools, hand tractor, request for copies of any circulars from the management, format
of expected payroll, bonus. The minutes are signed by the chairman and secretary.
Compliance status: Full Compliance
6.7 Children are not employed or exploited. Work by children is acceptable on
family farms, under adult supervision, and when not interfering with education
programs. Children are not exposed to hazardous working conditions
Companyis very stringent in selecting the candidate employee in order to prevent underage
workers, the minimum should be 18 years old. This provision is regulated in:
- PKB article 7 concerning new employee recruitment, paragraph 4, at the minimum 18 years
old.
- Government Regulation Chapter II Work Relations, Article 5, paragraph 2 that candidate
worker should be the minimum 18 years old.
- Circular Letter from HR Director to all Unit Head, No. 002/SE-HRDV/03/09, date 31/3/2009
with subject: Minimum Age Limitation, swehubu. Act No. 13, article 68, concerning child
employment prohibition, so the minimum age of employee recruitment is 18 years old.
The evidence of implementation of this policy can be seen in the following data:
- In the Summary Data of GABABHL Employee, the youngest work entry age is 19 years old,
under the name of Ari Madela, born 24/09/1993, entry into work on 01/01/2013, for PKWT
Employee , the youngest work entry age is 20 years old, under the name of Dedi Erik, born
12/12/1991, , entry into work on 07/03/2013
Compliance status: Full Compliance
6.8 Any form of discrimination based on race, caste, national origin, religion,
disability, gender, sexual orientation, union membership, political affiliation, or
age, is prohibited
requirements without discrimination by ethnic, race, and religion”. (2). Employment Recruitment
Policy: Provision on Recruitment and Selection Outside Jakarta (no. SDM A-006-00, dated
1/9/2005), regulates that recruitment of manpower does not define particular ethnic, sex, as well
as religion as requirements. It is also mention minimum age of 18 years old.”
As evidence, worker composition in each Unit can be seen in the data as per May 2013, from
data sampling as follows:
Data ofGABA Estate BHL:
- Sex: Male 260, Female 114.
- Religion: Islam 378, Hindu 4, Christian 1
- Ethnic: Javanese 375, Palembang 1, Balinese 4, and Sundanese 1.
The location of the estates and mills is in fact within transmigration areas which are mostly
inhabited by people from Muslim Javanese ethnic.
The forms of job application do not mention sex group, ethnicity, or religion for general
occupation, means that any job can be performed by men or women.
Compliance status: Full Compliance
6.9 A policy to prevent sexual harassment and other forms of violence against
women and to protect the reproductive rights is developed and applied
Company has established a policy related to prevention of sexual harassment in a circular letter
Socialization on Harassment Sexual Issues, No. 003/CEO2-SE/01/2011, dated 10/01/2011.
There should be socialization to all employees concerning prevention and handling of sexual
harassment issues, so as to increase legal awareness and respect norms and ethics in the
plantation work units of Sinar Mas II.
Samples of evidence of the implementation of prevention of sexual harassment activities of
socialization in GABA Units are as follows:
- GABA Unit, there is the Letter of Acknowledgement of Socialization on How to Deal With
Sexual Harassment held on 15/03/2013, there are 12 participants for the staff’s wife’s and
male workers.
- GABA Unit, there is the Letter of Acknowledgement of Socialization on Sexual Harassment
carried out on 15/06/2013, to 23 K3T representatives and 30 BHL Harvester.
- In front of the GABA office there is a campaign poster saying “STOP..!!! Woman and Child
Abuse”.
Nevertheless, in GABA Unit, this socializationhas been made only to 30 representative workers.
There is no evidence that it is made to 276 workers personnel. This is established as minor
nonconformity.
Company policy on protection of reproductive rights and documentedhas been included in:
- Government Regulation chapter IV, article 23 concerning Annual Leave, Article24 Long Rest
Period, Article 25 Maternity or Miscarriage.
- Memorandum No. 001/Memo/VPA PSM2/04/2011 dated 8/4/2011, concerning prohibition of
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
46of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
Company has in place a policy in the form of company memorandum to perform CSR program
throughout the company group in order to comply with Act of RI No. 40/2007. CSR plan in 2013
covers the aspects of education (scholarships), health (hospital rehabilitation, posyandu
activities, fogging, mass medication), economic empowerment (FFB transportation by local
contractors, purchasing local materials), infrastructure (road improvement, surfacing) and social
assistance for religious purpose and celebration of day of an important event.
Company has a program of prioritizing local contractors to have jobs. Jobs given include printing
materials for administration purposes and rice procurement by KUD, FFB transportation,
harvesting ladder construction. Samples taken are SPK 001-GABA/SPK-L/I/2013- FFB
Transport. The SPK has a validity period and terms of payment which is twice a month under the
name of Bp. Suradi, May 2013 period.
Compliance status: Full Compliance
7 RESPONSIBLE DEVELOPMENT OF NEW PLANTINGS
8.1 Growers and millers regularly monitor and review their activities and develop
and implement action plans that allow demonstrable continuous improvement
in key operations
We, the undersigned declare that the information and conclusions included in this report have
been prepared in accordance with rule and standard of RSPO, P&C, and that the certification
decision has been based upon this information.
Signature
Approval:
Signature
List of Abbreviation
ATTACHMENT-1
MAP
1.1. Overlay Map of Sungai Merah Estate (SMRE) and KKPA Gedung Aji Baru
(GABA) Estate
ATTACHMENT-2
NCR
Audit
No Root Cause Corrective Action & Team
. Category Clause Std Auditor Description Investigation* Evidence* Review
(1) (2) (3) (4) (5) (6) (7) (8) (9)
1 Major 2.1 1 TSS The company has a 1. Letter of the Corrective Action 1: Closed
letter of permit of the Regional Forestry Document the letter of
release of forested Office of Lampung the Regional Forestry
areas and or a letter of Province No. Office of Lampung
designation with the 1052/KANWIL-6/TGH- Province No.
APL status for the 134/90 is 1052/KANWIL-6/TGH-
plantation area of PT undocumented in the 134/90 at the estate
Sumber Indah Perkasa. estate office so that at office.Evidence 1:Letter
The company does not the time of pre audit it of the Regional Forestry
have permits/IUP for Mill could not be shown to Office of Lampung
with a capacity of 120 the auditor.2. The IUP Province No.
tons of TBS/hour. So far does not specify a mill 1052/KANWIL-6/TGH-
the company only has a with a capacity of 120 134/90 has been
letter of tons/hour, but with available.Corrective
recommendation from respect to production Action 2:Confirmation to
the Provincial Forestry capacity, there has the relevant agencies
Service for the been an approval from relating to IUP.Evidence
management of mills the State Minister of 2:The company has had
with a capacity of 120 Investment / Head of SPUP that is valid as
tons TBS/hour. BKPM.1. Letter of the IUP, while for production
Regional Forestry capacity there has been
Audit
Root Cause Corrective Action & Team
No. Category Clause Std Auditor Description Investigation* Evidence* Review
(1) (2) (3) (4) (5) (6) (7) (8) (9)
1 Minor 6.9 1 WS The implementation of Sexual harassment To completed the Closed
sexual harassment socialization has been documentation of sexual
socialization to employees is conducted to the workers, harassment socialization.
limited compared to the but the documentation Evidence :
number of workers. Data was cannot be showed at Documentation of sexual
showed : the time of audit. harassment socialization is
-In GABA Unit, the number available at SPO
of workers has been secretariat.
socialized to 30 workers. For
BHL and PKWT personnel
are30 out of 276 workers
(only 10.9 %).
2 Observasi 4.6 1 YSF Company has used The company still apply The management has Closed
herbicide registered in restricted pesticide i.e. issued memo to reduce
Pesticide Commission of the paraquat. the paraquat No.
Republic of Indonesia but 002/MEMO-VPA
the use of restricted PSM2/04/2011. The
pesticide should be reduced restricted pesticide will be
gradually and substituted by monitored yearly to see
a more environmentally the trend of paraquat
friendly herbicide and safer reduced.
to field operators. Evidence :
Graphic of
restrictedpesticide use
year 2011-2013 showed
the reduce of paraquat
used.
3 Observasi 4.7 1 YSF Company has undertaken The workers with To conduct identification Closed
workers health examination exposure to chemical the workers with risks of
covering cholinesterase and material hazard were not chemical exposure and
audiometry but for those checked for spirometry. gradually will conduct
working with risks of spirometry checking.
chemical exposure should Evidence :
be added with spirometry 1. List of worker who
examination to ensure their needs to be checked
lung health. for spirometry.
2. Medical check program
for spirometry.
4 Observasi 2.3 1 TSS/GG Organization has made a The company has the Map will be adjusted to be Closed
U map but the map should different scale for all scale 1 : 100.000
have a sufficient scale, at maps. Evidence :
least 1: 100.000 in Map with the scale
accordance with Decree of 1:100.000
the Ministry of Forestry No.
48/menhut-II/2004.
5 Observasi 5.2 1 TSS/GG Organization has performed There is no column for Completed the form with Closed
U monitoring and contained in PIC and Action Plan at edit PIC and Action Plan.
HCV Monitoring Report, but Form HCV Monitoring. Column.
it should establish Person in Evidence :
Charge (PIC) and due date Revision of Form HCV
of the recommendation Monitoring.
specified in the HCV
monitoring report to see the
follow up and progress of
such recommendation.
6 Observasi 4.7 1 WS Company already complete The simulation of fire To fulfill the number of fire Closed
with the provisions of Decree fighting has conducted fighter to meet with the
of the Ministry of Manpower but the number of the fire Kepmenaker No. 186
No. 186/1999 related to the fighter was not meet with Tahun 1999.
number of fire mitigation the government Evidence :
personnel in mill area. But it regulation (Kepmenaker Documentation of fire
only trained 20 personnel for No. 186 Tahun 1999). fighter training.
both mills (it should be 12
personnel for each mill). It
should ensure to gradually
conduct training to cover the
remainder in class D, C, B
and A.
7 Observasi 8.1 1 TSS Companyshould develop a Yearly CSR Program has The company will re- Closed
specific method to evaluate been setup for each unit, identification the existing
the effectiveness of CSR but not yet covered the indigenous people. If there
program done as input to culture program. For the is then the company will
future program strategic planning year setup the CSR to develop
improvement. 2014-2018 has and maintain the culture of
addressed the vision and indigenous people.
mission to develop and Evidence :
maintain the culture of Revise CSR Program.
local people.
8 Observasi 6.10 1 TSS Company should ensure The company has The company will conduct Closed
cooperative’s efforts to conducted the monthly meeting and to
socialize aspects that socialization to the socialized the factor in
become a factor in price cooperation staff and price cutting related to
cutting related to costs coordinator staff, costs imposed to plasma
imposed to plasma members regarding the factor in members for maintenance
for maintenance and price cutting related to and transportation costs.
transportation costs. Proof costs imposed to plasma Evidence :
that all parties understand members for The documentation of
the contract agreement they maintenance and meeting schedule between
entered to, and that the transportation costs. But company and cooperation
contracts are fair, legal and the socialization was not is available.
transparent. sufficient some of the
members were found well
APPENDIX
PT. Sumber Indah Perkasa – Sungai Merah Mill (SMRM) is implemented the supply chain
system procedures as required in RSPO certification. The company has set the supply chain
system categorized as Mass Balance scheme.
A. Documented Procedures
1.1 Complete and up to date procedures covering the implementation of all the elements
in these requirements.
Records/Evidence:
There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP
Identification and Traceability) PT SIP‐SMRM/SOP/01
The name of the person having overall responsibility for and authority over the
implementation of these requirements and compliance with all applicable
requirements. This person shall be able to demonstrate awareness of the facilities
procedures for the implementation of this standard.
Records/Evidence:
Management Representative related to RSPO-SCCS implementation
Traceability Officer related to RSPO‐SCCS implementation
SMRM: Decree No. 010/PC‐SMRM/III/2013
Records/Evidence:
SOP Identifikasi dan kemampuan-telusuran (SOP Identification and
Traceability) PT SIP‐SMRM/SOP/01
Surat Pengantar Buah (Fruit Delivery Letter) (SMRE & GABA) with ‘’Mass
Balance’’ mark SMRM: Form Rekap Penerimaan TBS Per Unit (FFB
Receiving Resume Form each Unit)
CPO Production Report
SMRM = 55,362.691 ton/Year (with average OER : 21.51)
Recapitulation data of FFB certified received/process & CPO production from
January to December 2012
PK Production Report
SMRM = 13,802.922 ton/Year (with average KER : 5.37)
Recapitulation data of FFB certified received/process & PK production from
January to December 2012
CPO Dispatch Report
SMRM = 54,631.570 ton/Year
(Addition of Initial Stock, Carry over Last Year)
PK Dispatch Report
SMRM = 13,466.250 ton/Year
B. Purchasing and goods in
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
72of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
2.1 The facility shall verify and the document the volumes of certified and non-certified
FFBs received.
Records/Evidence:
There is procedure SOP Identifikasi dan kemampuan-telusuran (SOP
Identification and Traceability) PT SIP‐SMRM/SOP/01
There is a database system called Weightbridge Computerized Program
which has been designed to separate certified and non-certified incoming FFB
from own estate, Scheme small holders and independent small holders with the
specific code in database.
2.2 The facility shall inform the CB immediately if there is a projected overproduction.
Records/Evidence:
SOP Identifikasi dan kemampuan-telusuran (SOP Identification and
Traceability) PT SIP‐SMRM/SOP/01
Inform related RSPO certification body and RSPO IT System.
Re-analyze production data and mass balance report.
Calibrated and recheck for the bridge and supporting equipments.
To define the projection of certified product considering the error rate
(contamination) for maximum 5% from the total projection data.
C. Record keeping
3.1 The facility shall maintain accurate, complete, up-to-date and accessible records and
reports covering all aspects of these requirements.
Records/Evidence:
Surat Pengantar Buah (Fruit Delivery Letter) (SBYE) with “Mass Balance” mark
Form rekap Penerimaan TBS per Unit (FFB Receiving Resume from each
Unit)
CPO Production Report (daily, three-monthly, and annual)
All documents and records have been in controlled according to SOP Pengendalian
Dokumen dan Rekaman (SOP Document Control and Record Control)
SOP Pengendalian Dokumen (SOP Document Control)
PT. SIP-SMRM/SOP/18 Rev.00, dated 02/01/2012
SOP Pengendalian Catatan, dated 02/01/2012
PT. SIP-SMRM/SOP/12 Rev.00, dated 02/01/2012
3.2 Retention times for all records and reports shall be at least five (5) years.
Records/Evidence:
Retention times of all records have been determined in SOP Pengendalian
Dokumen dan Rekaman (SOP Document Control and Record Control)
Retention time for all records and reports of PT. Sumber Indah Perkasa is 10 years
3.3 The facility shall record and balance all receipts of RSPO certified FFB and deliveries
of RSPO certified CPO, PKO and palm kernel meal on a three-monthly basis.
Records/Evidence:
The company has the monthly, three-monthly, and annual report which contain
record and balance all receipts of RSPO certified FFB and deliveries of RSPO
certified CPO and PK.
(SBYM Mass Balance Monthly Report, SBYM Mass Balance Three-Monthly
Report, and SBYM Mass Balance Annual Report)
All volumes of palm oil and palm kernel oil that are delivered are deducted from the
material accounting system according to conversion ratios stated by RSPO.
Records/Evidence:
There is a database system called Weightbridge Computerized Program which
has been designed to align and integrate from the material accounting system
according to conversion ratios stated by RSPO. The supporting data such as:
Massa Balance Report ; Daily, Monthly, Three-Monthly, and Annually CPO
Production Report
Surat Pengiriman CPO dengan Cap ‘’ Massa Balance’’ (CPO Dispatch
Letter with “Mass Balance” Mark)
Tiket Timbang Pengiriman CPO dengan Cap ‘’Mass Balance’’ (CPO
Dispatch Weight Ticket with “Mass Balance” Mark)
The facility can only deliver Mass Balance sales from a positive stock. However, a
facility is allowed to sell short.
Records/Evidence:
Can be trace down in CPO Stock Report and in CPO Dispatch Report
3.4 The following trade names should be used and specified in relevant documents, e.g.
purchase.
Records/Evidence:
Can be trace down in Sales Contract
D. Sales and good out
4.1 The facility shall ensure that all sales invoice issued for RSPO certified products
delivered include the following information: a) The name and address of the buyer; b)
The date on which the invoice was issued; c) A description of the product, including
the applicable supply chain model (Segregated); d) The quantity of the products
delivered; e) Reference to related transport documentation.
Records/Evidence:
The available evidence is the invoice of oil delivery in form of Delivery Order (DO)
document issued for every oil delivery. The information written on the Delivery Order
document are: delivery no, delivery date, reference no, reference date, name and
address of buyer, ordered product details, and the transportation system for product
transportation.
The customer of SBYM for CPO and PK products are PT. SIP Bulking Tarahan.
The transporter of SBYM are:
- PT. Satrindo Jaya Agropalma (for PK and CPO)
- PT. Abadi Wijaya Utama (for CPO)
- PT. Lima Adil Makmur (for CPO)
E. Training
5.1 The facility shall provide the training for all staff as required to implement the
requirements of the Supply Chain Certification Systems.
Records/Evidence:
The facility shall provide the training for all staff as required to implement the
requirements of the Supply Chain Certification Systems.
Records/Evidence:
SOP Training dan Kompetensi Sumber Daya Manusia (SOP Training and
Human Resources Competency) Document No.: PT SIP‐SMRM/SOP/19,
issued 02/01/2012
RSPO – SCCS Training available in Identification Matrix Needs
Invitation, Attendance List, Socialization Training Material RSPO –SCCS, 07
May 2013
F. Claims
Sucofindo ICS FRM 3.04
Issue 04 Rev. 6
74of 75
SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES
6.1 The facility shall 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.
Records/Evidence:
SMRM have 7 Declaration of RSPO SCCS
1. Deklarasi RSPO ‐SCCS (RSPO SCCS Declaration)
2. Deklarasi Prosedur RSPO‐SCCS Mass Balance (RSPO-SCCS Mass Balance
Procedure)
3. Deklarasi Penilaian RSPO (RSPO Valuation Declaration)
4. Deklarasi Penjualan dan Pengeluaran Produk (Sale and Product Output
Declaration)
5. Deklarasi Penyimpanan dan dokumentasi rekaman (Retention and Record
Documentation Declaration)
6. Deklarasi Nama Produk (Product Name Declaration)
7. Deklarasi Klaim/Pernyataan (Claim Declaration)