Roundtable on Sustainable Palm Oil

Transcription

1 Roundtable on Sustainable Palm Oil Supply Chain Certification 1st Surveillance Report Report no.: SCCS-ASA Assessment against RSPO Supply Chain Certification Systems 2014 PT LDC Indonesia Refinery Lampung Province Indonesia Date of assessment: September 10 to 11st, 2015 Report prepared by: Mhd Fundy Cholis Kurniawan (RSPO Lead Auditor) Certification decision by: Abdul Qohar (Director of PT TUV Rheinland Indonesia) Certification Body: PT TUV Rheinland Indonesia Menara Karya, 10 th Floor Jl. H.R. Rasuna Said Block X-5 Kav.1-2 Jakarta 12950,Indonesia Tel: Fax:

2 TABLE OF CONTENTS 1.0 SCOPE OF SUPPLY CHAIN CERTIFICATION ASSESSMENT Executive Summary and Scope of Assessment Certification Details Organisational Information / Contact Person Actual production volumes and projected outputs Summary of Previous Assessment ASSESSMENT PROCESS Certification Body Qualifications of Lead Assessor and Assessment Team Assessment Methodology & Agenda ASSESSMENT FINDINGS Description of Supply Chain Management System Previously Status Identified of RSPO SCCS Requirement Non-conformities Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions Conclusion and Recommendation for RSPO Supply Chain Certification CERTIFIED ORGANISATION S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY Date of Next Surveillance Visit Acknowledgements of Internal Responsibility and Formal Sign-Off by Client APPENDIX Appendix 1: Details of Supply Chain Certification Certificate Appendix 2: List of Abbreviations Appendix 3: Observations and Opportunities for Improvement Appendix 4: Supply Chain Certification Audit Closing Meeting Summary Appendix 5: List of Certified Product and Projection for year Appendix 6: List of Certified Suplier and Buyer... 27

3 Page 3 of SCOPE OF SUPPLY CHAIN CERTIFICATION ASSESSMENT 1.1 Executive Summary and Scope of Assessment During the 1st surveillance audit, there is no change of principle license of PT LDC Indonesia. The operations of PT LDC Indonesia were assessed against General Module, Module B and Module C of the RSPO Supply Chain Certification (SCCS) document (November 2014). The scope of Supply Chain Certification assessment covers the implementation of the Segregation and Mass Balance supply chain model of PT PDC Indonesia. This is a single site certification. According to information stated on Foreign Investment Principle license ( Ijin Prinsip perluasan Penanaman Modal Asing ) No. 21/1/IP/II/PMA/2013 dated January 29, 2013, the mill has capacity has: Product Type Capacity (tones)/year Cooking oil 10,000 RBDPO 600,000 Olein 440,000 Stearin 124,000 PFAD 30,000 Biofuel 161,700 Oleo-Chemical 120,000 The assessment was carried out on September 10 to 11st, 2015 and a total of 6 non-conformities were found. During the 1st surveillance audit, there is update condition related location of PT LDC Indonesia. Now, location of PT LDC Indonesia has change to Bonded Zone based on Decree of Ministry of Finance Republic of Indonesia Number 35/WBC.05/KPP.MP.04/2015, dated on June 18, Certification Details The details of RSPO certification of PT LDC Indonesia are as per the table below Table 1: RSPO Supply Chain Certification details of PT LDC Indonesia Refer to Appendix 1 for further details of the RSPO Supply Chain certificate. RSPO Membership No.: RSPO Supply Chain Certificate No.: Certificate Reg No RSPO (e-trace) No.: RSPO_AC Date of RSPO Supply Chain certificate & validity: Valid until

4 1.3 Organizational Information / Contact Person Contacts details of the company are as follows: Company Name: Address: Contact Person: Position: PT LDC Indonesia Jl. Soekarno Hatta, Km 10 RT 23 LK 2 Kelurahan Way Lunik, Kecamatan Panjang, Bandar Lampung, Lampung Province Indonesia Mr. Arie Rizki Management Representative Telephone: Office: Ext: 129/ Arie.rizkie@Idcom.com Page 4 of Actual production volumes and projected outputs Certified tonnages claimed, certified tonnages purchased or sold, total and projected CPO and PK production from PT LDC Indonesia Table 3: Records of Certified Material Received/ Purchased * Supplier RSPO Certificate Number Product UTZ Number Volume Table 5: Records of Palm Oil Product Sold* Buyer RSPO Certificate Number Product UTZ Number Volume Note: During the 1st surveillance audit, PT LDC Indonesia is not purchase yet certified material and not claim yet certified product. 1.5 Summary of Previous Assessment During the main audit, PT LDC Indonesia, willing to audit they system to prepared the RSPO SCCS implementation. From the main audit, organization has got 5 non-conformities related the organization procedure, third party activities and others, and organization has make improvement. Then the organization get the RSPO SCCS certificate with certificate number is Reg No To ensure the organization implementation of RSPO SCCS standard was fully compliance, and then surveillance audit was conducted. Result of 1st surveillance audit will explain below.

5 Page 5 of ASSESSMENT PROCESS 2.1 Certification Body PT TUV Rheinland Indonesia is member of Group TÜV Rheinland Group, a global leader in independent testing and assessment services. The TÜV Rheinland Group was established in 1872 with offices located in over 490 locations in 62 countries on all five continents. PT TUV Rheinland Indonesia offers certification for a wide range of management systems according to established international standards including ISO 9001, ISO 14001, OHSAS 18001, SA 8000, RSPO, ISPO (Indonesian Sustainable Palm Oil Certification), ISCC, Timber Legality Verivication (SVLK), as well as CDM Validations and Verifications. PT TUV Rheinland Indonesia s office is located in Jakarta, Indonesia. 2.2 Qualifications of Lead Assessor and Assessment Team Name Position Qualifications / Experience Mhd Fundy C Kurniawan Lead Auditor Education: Master Degree in Natural Resource and Environmental Management, Bogor Agriculture University Trainings attended: Environmental Impact Assessment (EIA), Ecological Risk Assessment (ERA), Internal Quality Audit Training for Quality Management System, IRQA-QMS ISO 9001:2000, IRQA-EMS ISO 14001:2004, High Conservation Value (HCV), Timber Legality Verification (SVLK), RSPO Lead Auditor Course, ISPO Auditor Course, RSPO SCCS training by BM Trada. Working experience: Experienced in Environmental Impact Assessment, Environmental Health Safety Senior Officer (EHS- Officer) in Wilmar International Plantation, Internal Auditor for Wilmar International Plantation, Auditor for Roundtable on Sustainable Palm Oil (RSPO), Indonesian Sustainable Palm Oil (ISPO), Certification for Timber Legality Verification (SVLK) in PT TUV Rheinland Indonesia since June 2012 present. 2.3 Assessment Methodology & Agenda The supply chain 1st surveillance assessment was conducted between September 10 11, 2015 in PT LDC Indonesia as per the assessment program below. The assessment was carried out in accordance PT TUV Rheinland Indonesia s RSPO audit procedure as well as the RSPO Supply Chain Certification document through the method is sampling, interview, field visit, document check such as procedure and record of process. An on-site assessment was conducted and the assessment team carried out field (sea port, storage tank and refinery) and document assessments of compliance to RSPO Supply Chain Certification System requirements November The company proposed the correction and corrective action for all identified non-conformities raised to the certification body 30 days after the closing meeting. Verification of closure of non-conformances was conducted 30 days after the closing meeting of the main assessment. The certification assessment agenda is as explained below.

6 Page 6 of 28 Main Assessment Agenda Date September 10, 2015 September 11, 2015 Location/ Main sites PT LDC Indonesia production facility process PT LDC Indonesia facility Main activities 1. Opening Meeting 2. Plant Tour - Incoming material at Jetty for MB and SG - Storage tank for MB and SG - Production process for MB and SG 3. Documentation system 4. Purchasing and goods in 5. Outsourcing Activity 6. Sales and good out 7. Registration of transaction 8. Training 9. Record keeping 10. Claims 11. Complaints 12. Management review 1. Mass Balance and Segregation 2. Supply chain requirement for MB and SG 3. Processing for MB and SG 4. Record keeping for MB and SG 5. Mass balance system 6. Conservation ratio for MB 7. Yield schemes for MB 3.0 ASSESSMENT FINDINGS 3.1 Description of Supply Chain Management System The following is a description of the findings pertaining to the company s supply chain management system according to the RSPO SCCS requirements, including status of compliance of the company and their outsourced third parties to RSPO SCCS requirements: Section 5: General Chain of Custody System Requirements for the Supply Chain 5.1. Applicability of the General Chain of Custody System Requirements for the supply chain During the 1 st surveillance audit, PT LDC Indonesia is still a member of Louis Dreyfus Commodities. It is strategically located adjacent to Port of Lampung (now is Bonded Zone), Indonesia. It is a bulk oil facility to refine and fractionate palm oil, and palm kernel oil. Management PT LDC Indonesia has commitment to implement RSPO SCCS. The company s supply chain management system integrated with the implementation of quality management systems at ISO Following the nature of company s material purchased availability for production facilities. PT LDC management decided to implement Mass Balance and Segregation system supply chain model (Module B and C), as stated on company s quality manual to include all RSPO SCCS requirements. A set of standard operation procedure has been established for RSPO SCCS implementation. During the 1st surveillance audit, PT LDC Indonesia has implemented of RSPO SCCS system in their operational process from incoming material and delivery certified product. But until the 1st surveillance audit, there is still no certified prodcut claimed by the company.

7 Page 7 of 28 PT LDC Indonesia is RSPO member under LDC Asia (Louis Dreyfus Commodities) with membership number , and RSPO SCCS certificate reg number SCCS Compliance status: Full Compliance 5.2. Supply chain model PT LDC Indonesia has implemented the RSPO SCCS model SG and MB in organization activity. Compliance status: Full Compliance 5.3. Documented procedures PT LDC Indonesia has a set written procedures and working instruction to ensure implementation of all elements stated on RSPO SCCS year The procedures were updated and covering all activities in PT LDC including their subcontractor. As stated on master list documents and records, there are : 1. QM001 Quality manual of ISO 9001:2008 and Sustainability (RSPO SCCS and ISCC) 2. QP001 Control of Document 3. QP001 Control of Record 4. QP008 Product Identification and Traceability 5. SMR001 Mass Balance Calculation 6. SMR004 Product Segregation 7. SOK001 Raw Material Transfer from Land 2 to Refinery Tank 8. SQC001 Incoming Material and Finish Product Out Spec 9. SQC001 Handling Non Conforming Product Raw Material and Finished Product 10. WOK002 Transfer Material 11. WOK003 Transfer Product 12. WOK004 Incoming Liquid Material from Truck 13. WOK005 Dispatch Liquid Material use Truck During the 1st surveillance audit, there are revision for some procedures related the RSPO SCCS, i.e.: 1. QP014 Quality procedure about control of purchasing commercial bulk Rev 01, effective date 04/03/2015. The procedure has explained about trading departement shall responsible for search/found and conduct the supplier selection/evaluation for fulfill the raw material certieid RSPO SG and ensure the product delivery certified SG will not contaminated with others non certified product. 2. QP015 Quality procedure about RSPO SCCS Rev 01, effective date 04/03/2015. The procedure has explained about every departement related SCCS implementation shall ensure and demonstrated with clearly RSPO SCCS requirement, and ensure the delivery process will recorded in the same document, ensure the outsourcing activity understood with RSPO SCCS SG and MB requirement in their activity. 3. QP016 Quality procedure about control non conforming product RSPO SCCS Rev 01, effective date 04/03/2015. The procedure has explained about handling for non confroming product, speciality for in case the contamination of SG product. But, the procedure containt sett yet about handling non-conforming document related RSPO SCCS. So this is non confromity. 4. SOP SRS001 Rev 01 date issued 04/03/2015 about receiving and storage activity of RSPO SCCS product. Procedure explained about the SG product shall pure 100% without contamination. And also shall ensure the SG product process in deodorizing and bleaching process not contaminated, through the cleaning/washing process. Receiving raw material from mill (shipping transportation and truck transportation) in to storage tank. Procedure not sett the handling of incoming and storage the raw material certified specially SG product. Procedure no explained how the cleaning/washing process will be conducted to minimize the contamination for SG product. So, this is non-conformity. 5. SOP SRS002 Rev 01 date issued 04/03/2015 about the RSPO SCCS cargo product. Procedure explained specially for SG product, the surveyor officer and crew shipp conduct the sounding

8 Page 8 of 28 level to ensure the quantity product receiving, and shall ensure the SG product shall move to different location and documented through the minutes of record. 6. SOP SRS003 Rev 01, date issued 04/03/2015 about traceability RSPO SCCS. Explained about: - Ensure the shipping process raw material from SG product will not mixing and contaminated by the non SG product or non certified product. - Ensure the document of delivery note/do/bl covered information (name and addressed of buyer and seller, loading date, delivery date, date of document issued, product explained, SCCS model, amount of product, and others document related tranportation. - To traceability material purposes, the officer shall recorded the true information about raw material information (name of raw material, code, date, tank number, supplier, and related identification shall recorded) and product information. 7. SOP SRS004 Rev 01 date issued 04/03/2015 about handling non conforming SG product. For SG non conforming product, management representative shall ensure for clearly the noncorming problem through the declassification from SG to MB. 8. SOP SR005 Rev 01 date issued 04/03/2015 about control and monitoring outsourcing activity. Procedure mentionade that the LDC Indonesia ensure that the third party will provide the accsess to certification body id needed to check and confirmation about operational, system and aslo all of information related SCCS implementation, conduct the SCCS brief in once year and LDC Indonesia also shall ensure that the third party could segregate the RSPO SCCS SG with others raw material/product non certified SG, to keep off the contamination. 9. SOP SR006 Rev 01 date issued 04/03/2015 about handling SG product in outsource activity. Explained that SG prdoduct shall keep in different compartment with others raw material/product non certified SG, and will document through the minutes of record. Both of procedure number 3 and 4, still not sett clearly about handling RSPO SCCS SG and MB because still possible contamination for SG product or raw material (NCR of 06). The organization has conducted the RSPO SCCS training with the evidenced is attendant list training dated on August 28, 2014, attendant by 45 person from different depertement such as quality departement, utility maintenance, production, mechanic, security, finance, HR, safety and health of PT ISAB (outsource), purchasing and others. The name of the person having overal responsibility for and authority for the implementation of all RSPO SCCS requirement has bees assigned, i.e. the quallity assurance/control manager (Mr. Arie Rizki) is apointed as RSPO SCCS management representative. Organization also established the organization flowchart responsible for SCCS implementation i.e.: Factory manager, management representative, internal auditor, sustainability officer, document controller, GHG officer and mass balance. During the 1st surveillance audit, Mr. Arie Rizki has good knowledge and able to demonstrate awareness of the facility s procedures and process. Compliance status: Non Compliance NCR of 06 Procedure number QP016 and SRS001 still not sett clearly how to handling the RSPO SCCS SG and MB, because based on explanation in the procedure still possible the contamination 5.4. Purchasing and goods in During the 1st surveillance audit, there is no revision for procedure related purchasing. The procedure number QP014 Rev 01 Effective date on 15/04/2014 about Control of Pruchasing Commercial Bulk, mentioned trading for purchase order, information on the document shall consist of: - Name of product - Product price - Spesification - Time for receive - Payment term - Stamp SG for SG product and MB for MB product

9 Page 9 of 28 On the procedure also mentioned about product purchase shall ensure for SG, shall not contamination by others product non-sg since transportation, shipment, and discharge. The supply chain/logistic section has responsibility for dealing with supplier, transporter and tank rental (outsource process) for order, keeping and incoming raw material together with trading departement for CPO procurement. Logistic section provide Information to another department or section for CPO incoming schedule, prepare & ensure all sustainable documents such as Contract, shipment schedule CPO, Requested for Surveying Service, Fixture Note, Delivery Note and etc for Sustainability purpose. Logistic section with Sustainable person incharge to be verify sustainable certificate model IP; SG or MB on website and requested for surveying service and distribute to surveyor, verify & ensure delivery notes from Supplier for Sustainability purpose. The facility also has mechanism to ensure validity of the Supply Chain Certification of suppliers through checked via the list of RSPO Supply Chain Certified facilities on the RSPO website During the 1st surveillance audit, organization has record of purchased raw material (CPO) certified and uncertified for August time period. During that period, LDC Indonesia still no purchase/buy yet certified raw material from certified supplier because the there is no request certifed product from buyer. But the organization has record of uncertified purchase activity very well. When in the contract document between LDC Indonesia with PT Menggala Sawitindo has mentionade information about name of buyer and seller, quantity dan quality product, date of purchase, loading date, port of discharge and others. Organization also has record of list supplier in August periode. Please see Table on Appendix 6. Organization registered in RSPO IT platform (e-trace) with number RSPO_AC Based on e- Trace information website, there is no record sales activity certified palm product, because there is no request the certified palm product from buyer. Organization has established the mechanisme/procedure to handling of non-conforming material and/or documents through the document number SRS004 Rev 01 date issued 04/03/2015. Compliance status: Full Compliance 5.5. Outsourcing activities During the 1st surveillance audit, there are 2 (two) activity related outsourced activity by PT LDC Indonesia. Only outsource activity related transport with trcuk have changed information, i.e.: 1. CPO Storage tank for raw material located in same location with refinery, because the CPO storage tank company is also member of LT Louis Dreyfus Indonesia with the name is PT Intisentosa Alambahtera (PT ISAB), accordance to agreement number 010/IA-TF/VII/2011 on July 6, 2011 and valid for ten (10) years, about the storage tank rent with capcity MT. The number of storage tank is rent for PT LDC Indonesia i.e.: - A MT - A MT - A MT - B MT - B MT - B MT - C1 940 MT - C2 940 MT - D1 380 MT - D2 380 MT - D3 940 MT - E MT - E MT - E MT - F MT - F MT

10 Page 10 of 28 - F MT Organization has brief the outsource/third party of RSPO SCCS SG and MB through send the memo internal to 14 outsource company dated January 1st, 2015, but in the brief information still no yet inform about RSPO SCCS new standard 2014 for SG. This non conformity (NCR of 06). 2. Transporter for material from supplier location and for product to buyer location. There are 14 outsourcing company (10 by shipping and 4 by truck), i.e.: Company name PT Karunia Pratama Sejahtera PT Josh Tirto PT Samudera Mulia Karsa PT Teraratai Raya PT Nusantara Shipping Lines PT Baruna Trans Logistic PT Segara Trasindo Mandiri Sutomo PT Citra Armanda Nusantara Address Rukan Artha Gading Niaga Blok E No. 22, Kelapa Gading, Jakarta Utara Jl. Indragiri Barat No. 1, Pontianak, Kalimantan Barat Komplek Ruko Duta Square Blok B No. 11, Jl. Tubagus Angke Kav. 10, Grogol, Jakarta Barat Ruko Newton Square Legenda Wisata Blok U-23 No. 22, Jl. Transyogi Alternatif Cibubur KM 6 Jakarta Jl. Bukti Gading Raya, Komplek Rukan Gading, Bukit Indah Blok Q/17, Kelapa Gading, Jakarta Utara Jl. Kenanga II, No. 2 Sunter, Jakarta Utara Rukan Bahari, Jl. Bahari No. 41 Panjang, Bandar Lampung Jl. Dr. Susilo No. 83 Pahoman Teluk Betung, Bandar Lampung Jl. Raya Kumpai KM 9, RT/RW: 2/8, Kapur Sungai Contact person Mr. Sumitra Mr. Ricky Setiawan Mr. Ray- Raymond Mr Mika Mr Bahar Mr Anwar Telph number sumitra_smr@yahoo.com shansui_ku@ymail.com pt_spmm@yahoo.com teratairaya_tr@yahoo.com nsl-mkt@nsl.co.id PT Anugerah Santang Samudera anwarpalewai@yahoo.com Mr Zaini zai_ktm@yahoo.com Ms Selly pt_sjim@yahoo.com Mr Anton kashipping@yahoo.com

11 PT Mulia Borneo Mandiri CV AWU Transportation CV AAF PT Sutomo Agroindomas Lampung PT Aman Jaya Perdana Raya, Kubu Raya, Pontianak, Kalimantan Barat Jl. Budi Karya Blok D, No , Pontianak, Kalimantan Barat Jl. Candimas 1, KM 25, No.889, Bandar Lampung Jl. Lintas Sumatera KM 37, Simpang Masgar, Lampung Jl. Dr. Susilo No. 83 Pahoman, Teluk Betung, Bandar Lampung Jl. Ir. Sutami, KM 7, Tanjung Karang Timur, Bandar Lampung Mr Willy Mr Abun Mr Ibrahim Mr Jeanny Mr Ronald muliaborneomandiri@yahoo.co.id Page 11 of 28 awu_transportation@yah oo.com jeny_deva@yahoo.com During the 1st surveillance audit, found the contract between LDC Indonesia with contractor transport example: 1. PT Samudera Mulia Perkasa, contract Ref Number 05/SMK/VIII/2015 dated August 20, 2015, valid from August 27 30, 2015 about delivery CPO by tanker with volume 2,000 mt, from Bengkulu to Lampung. 2. PT Sutomo Agroindomas Lampung, contract Ref Number 057/LDC-INDO/EXT/VIII/2015 dated August 19, 2015 about delivery CPO with volume 1,500 mt from storage tank of Garuda Bumi Perkasa to storage tank of PT ISAB, by truck. Both of contract above, not yet mentionade clearly information about if needed in audit process, the contractor will provide accsess to the certification body to check the system and related others document in tranposrtation and outsourcing process for certified material and/or certified product. This is non conformity (NCR of 06). Organization has established the procedure for handling and monitoring outsourcing activities, document number SRS0005 Rev 01 date issued 04/03/2015. The procedure has sett the monitoring to handling the outsourcing activity through: - LDC Indonesia will ensure the third party provide access to certification body if needed to verification their system, data and others related of RSPO SCCS implementation - LDC Indonesia in once year will conduct of RSPO SCCS brief to all outsourcing activity - LDC Indonesia will ensure the contractor understood the different of certied and non certified raw material and/or product, specially for SG product shall 100% pure SG without contamination. - LDC Indonesia shall ensure that the contractor make the minutes of record activity in every process loading, delivery and/or receiving RSPO SCCS SG and MB, and between the MB and SG shall separate from incoming until storage process. During 1st surveillance audit, there is no plan for added new supplier, but if the facility have plan for that, the facility will be informed to certification body. Compliance status: Non Compliance NCR of 06

12 Page 12 of 28 Organization has conduct the RSPO SCCS brief to all contractor through the send of memo internal related RSPO SCCS implementation and requirement, but, on the memo not yet explained about RSPO SCCS New standard NCR of 06 Found both sampling contract between LDC Indonesia with contractor above, still no mentionade yet the contractor will provide accsess to the certification body to check the system and related others document in tranposrtation and outsourcing process for certified material and/or certified product Sales and goods out During the 1st surveillance audit, there is no claimed and/or sales activity related certified palm oil product by the organization. During times periode of August, only non-certified palm oil product sold by the organization. Example record PFAD sales from LDC Indonesia to Louis Dreyfus Commodities Asia, Pte. Ltd, with invoice number LD date on December 17, The sales document was include Bill if Lading, Export Note issued by Indonesians Custom (nota pelayanan ekspor), sales contract. And in all related that document completed with name of buyer and seller, origin, commodity, quantity, quality, loading port, discharge port, document issued date and others. Those documentation above has compliance with organization procedure about Traceability RSPO SCCS procedure number SRS003 Rev 01 date issued 04/03/2015. Several records issued for outgoing product depend on the transfer method used such as: - Vessel: Shipping Instruction (SI); Bill of lading (B/L); Certificate of Analysis, Cargo Manifest, Statement of Fact, and others - Container or ISO Tank: Packing list, Bill of Lading (B/L), Certificate of Analysis, Manifest, Statement of Fact, and others In every document will stamp with SCCS system i.e. MB and SG. Where the person responsible for this have been getting training and simulation on the purchase and sale of the product certified MB and SG, also the facility will distinguish the stamp. Compliance status: Full Compliance 5.7. Registration of transaction During the 1st surveillance audit, PT LDC Indonesia is producing Edible and Non Edible Oil from supplied CPO and PK, and organization has registered in RSPO IT Platform (e-trace) with reg number certificate SCCS and RSPO e-trace number RSPO_AC But during the surveillance audit there still no yet sales activity related certified product sales/and or claimed the certified product by the organization. The implementation of this requirement will be checked during next surveillance audit after sales of certified product will realized. Compliance status: Not Applicable for 1st surveillance 5.8. Training During the 1st surveillance audit, organization has record of training program for 2015, when the RSPO SCCS training will conduct in November But in 2014, the organization has conduct the RSPO SCCS training with the evidenced is attendant list training dated on August 28, 2014, attendant by 45 person from different department such as quality department, utility maintenance, production, mechanic, security, finance, HR, safety and health of PT ISAB (outsource), purchasing and others. But for new person who responsible for document controller still don't have RSPO SCCS training. This is nonconformity (NCR of 06).

13 Page 13 of 28 The name of the person having overal responsibility for and authority for the implementation of all RSPO SCCS requirement has bees assigned, i.e. the quallity assurance/control manager (Mr. Arie Rizki) is apointed as RSPO SCCS management representative. Organization also established the organization flowchart responsible for SCCS implementation i.e.: Factory manager, management representative, internal auditor, sustainability officer, document controller, GHG officer and mass balance. The facility has kept record of training well done, and also the facility has a procedure for control of record number QP002 Rev 1 Effective date on 01/07/2014, mentioned all document relating to ISCC and SCCS system shall be stored for 10 years. NCR of 06 Found the document controller who responsible for RSPO SCCS implementation training yet by the organization. Compliance status: Non Compliance 5.9. Record keeping Organization has established mechanism/procedure about retention time for record and document related RSPO SCCS document and record will keep in 10 years. Until surveillance 1st audit the organization has implemented very well maintenance record keeping. Organization has record of volume certified and non certified raw material and palm oil product in to mass balance record for MB, and for SG will record based on requirement buyer, then organization will record that. But during the 1st surveillance audit, still no yet the certified palm oil product sold by the organization. During the 1st surveillance audit, total stock non-certified product produced by organization with time periode September 2014 until August 2015 is: - RBDPO is about 52, mt - PFAD is about 20, mt - Stearin is about 24, mt - Olein is about 15, mt Compliance status: Full Compliance Conversion Factor Organization also has record or conversion raw material to palm oil product for September 2014, until August 2015, but this is for non certiifed product including conversion of raw material into PFAD, refining oil loss, RBDPO, stearin, olein, and others. Organization has established the quality procedure with document name is Indonesia Quality Matrix, for conversion standart raw material i.e.: - PFAD maximum is 5.3% - Refining oil loses maximum 0.7% - RBDPO is 94% - Stearine is 20% - Olein is 80% This conversion standard was established to estimate the amount of certified product and noncertified product. The organization has a mechanism for raw material conversion. This conversion established by the organization to control the palm oil product process especially for SG product. In receiving SG product, organization will exaggerate purchase the SG raw material ± 25.9 ton for flushing, piping, ang refinery flusihing process. This was explained in organization procedure number SRS001, Rev 02, date issued 14/09/2015. Then for certiifed product there is no record, because there still no yet the certified palm oil product sold by the organization. Conversion record for raw material into palm oil product certified will imple-

14 Page 14 of 28 mented if organization has production request from buyer. Compliance status: Full Compliance Claims The company has an SOP for making claims certified product according RSPO communication and claims. However company not claim the product diretly, only require in relevant certified product, duecompany only produce intermediate product not finsihed good consumer product Compliance status: Not Aplicable for this time Complaints Organization has established mechanism for costumer complaint handling document number QP007 Rev 01 effective date 01/07/2014. Procedure explained about handling costumer complaint, when the handling will take time maximum in 4 weeks from investigation, and will take immediate action to take corrective and correction action. Until 1st surveillance audit, there is no complaint record by organization. Compliance status: Full Compliance Management Review Organization has conducted the management review on May 12, 2015 in PM, attendant by 5 person from oil keeper, internal audit, quality control, fico, and Management Representative as represent of Top Management, this is an observation for improvement for the next management review the organization management review should attendant by top management. The result of internal audit has covered the costumer satisfaction, process performance, conforming product, corrective and correction action, corrective action for last management review and changes that could affect the management system if any and recommendation for improvement. Result of management review in 2015, showed the result was discussed is internal audit, costumer complaint, realization production RBDPO and PFAD compared with budget, work program to cleaning the storage tank, pipe lines, loading container, if the SG raw material receiving by the organization to keep 100% pure of the SG product, procedure revision, and others. Organization has established the management output in order to continual improvement i.e.: prepared the surveillance audit for RSPO SCCS SG and MB and also commit to implemented the sustainability implementation in refinery process, and also ensure the resource always available to maintain the sustainable process. Compliance status: Compliance with Observation Section 2: Modular Requirements: Module B Segregation B.1. Definition During the 1st surveillance audit, organization still commit to implemented the RSPO SCCS SG as a supply chain model from incoming raw material until delivery process of palm oil product to the buyer. And the organization has established the procedure and work instruction related the RSPO SCCS SG

15 Page 15 of 28 implementation, and will ensure there is no contamination for SG product and keep pure 100%. All of mechanism has explained in organization procedure as describe above in General Requirement- Documented Procedure. All documents related sustainability SG product since receiving material until product discharge will be stamped by sustainable stamp with SG code and keep the records for 10 years accordance to facility procedure for control of record number QP002 Rev 1 Effective date on 01/07/2014, mentioned all document relating to ISCC and SCCS system shall be stored for 10 years. Compliance status: Full Compliance B.2. Supply chain requirements During the 1st surveillance audit, organization still no yet purchased and sold the certified palm oil SG product. But to ensure the RSPO SCCS SG will implement very well, the organization has prepared the procedure and work instruction related SG. Example in procedure number SOP SRS001 Rev 01 date issued 04/03/2015 about receiving and storage the RSPO SCCS raw material and product. Procedure explained that the SG raw material and product shall keep and store with different with others raw material and product non certified to ensure there is no contamination in SG product and keep in 100% pure SG. When the main audit last year, organization has conduct the simulation of RSPO SCCS SG to ensure the person who responsible for RSPO SCCS SG understood very well. Because there is no purchased and sales activity related SG raw material and product during the 1st surveillance, this indicator will verified in the next surveillance and/or when the organization has get request from buyer about SG product production. Compliance status: Full Compliance B.3. Processing During the 1 st surveillance, the organization still no yet purchased, refines and sold the raw material and palm oil SG product from supplier and/or to buyer. So for implementation SG processing still no could be verified for this time, and will check in the next surveillance audit. Nevertheless, the organization shall have mechanism to ensure the SG product will keep pure in 100% without contamination. And the organization has the procedure for that, but when the conduct field visit from port, loading container, pipe lines, refine process, and storage tank, and demonstration receiving raw material, found the possibility contamination for SG raw material and palm oil product. In port, the organization has 6 port for pipelines, but only 4 in active condition, i.e.: - Pipelines A and B is only for palm oil product such as RBDPO, Stearin and Olein - Pipelines C is only PFAD - Pipelines D is only for raw material/cpo So far, the organization used the pipelines for all activity to transfer raw material and/or product from port to storage tank and from storage tank to tanker with cleaning activity in first step. So, if the organization want to transfer raw material and palm product they conduct cleaning before transfer, i.e.: - If transfer CPO to CPO, pipelines will cleaned with blowing and pigging method - If transfer CPO to palm product, pipelines will cleaned with blowing, flushing, blowing and pigging method - If transfer PFAD to fractionation, pipelines will cleaned with blowing, flushing, blowing and pigging method. In the organization procedure there is no explain about how to keep the SG product 100% pure without contamination. This non-conformity (NCR of 06). Compliance status: Non Compliance

16 Page 16 of 28 NCR of 06 There is no mention in organization procedure about how to keep the SG product 100% pure without contamination. Section 3: Modular Requirements: Module C Mass Balance C.1. Definition During the 1st surveillance audit, the organization still implemented of RSPO SCCS MB. In August 2014 until August 2015, organization still no yet purchased and sold the MB product, however the organization has record all receiving raw material into mass balance record. From August 2014 until August 2015, organization has received approximately ,95 MT raw material/cpo non-certified, and null (0) certified raw material. In mass balance record has showed the information of incoming raw material, refined and fractionation, conversion ratio (yield scheme), export, stock, for certified and uncertified raw material dan product. All documents related sustainability MB product since receiving material until product discharge will be stamped by sustainable stamp with MB code and keep the records for 10 years accordance to facility procedure for control of record number QP002 Rev 1 Effective date on 01/07/2014, mentioned all document relating to ISCC and SCCS system shall be stored for 10 years. Compliance status: Full Compliance C.2. Record keeping During the 1st surveillance audit, organization still no yet produce and sold the RSPO SCCS MB, so that, record related SCCS MB implementation still no available, and will check at next surveillance. Organization has established the procedure to guide the RSPO SCCS MB implementation with document number SMR002 Re 01 date issued 15/04/2015 about mass balance calculation. Procedur explained about receiving raw material certified MB and non-certified. In delivery process, certified palm oil product, in export document shall complete with B/L document, information of seller and buyer, origin, quality and quantity, port of loading and port of discharge. Then, also mention about organization will ensure that the final stock every 3 months shall be in positive, and organization has sett the mass balance type will use in organization is fixed inventory periods but no mention in organization procedure. This is non compliance. (NCR of 06). All documents related sustainability MB product since receiving material until product discharge will be stamped by sustainable stamp with MB code and keep the records for 10 years accordance to facility procedure for control of record number QP002 Rev 1 Effective date on 01/07/2014, mentioned all document relating to ISCC and SCCS system shall be stored for 10 years. Compliance status: Non Compliance NCR of 06 The organization has choosed the fixed inventroy periods for RSPO SCCS MB system, but this is no mention in organization procedure, so the person who responsible in RSPO SCCS MB implementation will understood well C.3. Processing

17 Page 17 of 28 During the 1st surveillance audit, organization has established the mass balance record template will evaluated in every 3 months to ensure the stock of certified palm oil product in positive stock. In mass balance record template showed the information about incoming raw material, refine process and sales of certified palm oil product. Organization has sett the mass balance fix inventory system will implemented in organization and will evaluated in 3 every 3 months. And all documents related sustainability MB product since receiving material until product discharge will be stamped by sustainable stamp with MB code and keep the records for 10 years accordance to facility procedure for control of record number QP002 Rev 1 Effective date on 01/07/2014, mentioned all document relating to ISCC and SCCS system shall be stored for 10 years. Compliance status: Full Compliance C.4. Continuos accounting system The organization no choose this system as a mass balance system in organization, so this criteria is no applicable for this organization. Compliance status: Not Applicable C.5. Fixed inventory periods During the 1st surveillance audit, organization still no yet the produce of RSPO SCCS MB palm oil product, but the organization has record of mass balance for noncertified raw material and refine process. In August 2014 until August 2015, organization has received and process the noncertified raw material/cpo, presented below: Name of product Certified RSPO Non-certified SCCS MB (MT) (MT) Raw material/cpo - 262, CPO refine - 152, RBDPO - 141, PFAD - 10, Oil loses - 1, RPO fractionation - 48, Stearin - 10, Olein - 37, Based on data above, the certified palm oil product still null (0) because the organization still has no received request from buyer to produce the certified palm oil product. And for certified palm oil product will check in the next surveillance audit. Compliance status: Full Compliance C.6. Conversion ratios During the 1st surveillance audit the organization still no yet purchase and produce the certified palm oil product, so that record of conversion ratios for certified palm oil product for this time surveillance not available. This is will verify again in the next surveillance.

18 Page 18 of 28 Compliance status: Not Applicable for this time 1st surveillance C.7. Yield Schemes During the 1st surveillance audit the organization still no yet purchase and produce the certified palm oil product, so that record of yield schemes for certified palm oil product for this time surveillance not available. This is will verify again in the next surveillance. But yield scheme for non sustainable product is available based on production time periode from September 2014 until August 2015, i.e.: - RPO is 94% - Loses is 1% - PFAD is 5% - Stearin is 19% - Olein is 81% This yield scheme for non-sustainable product was meet with RSPO supply chain yield scheme model. Compliance status: Not Applicable for this time 1st surveillance 3.2 Previously Status Identified of RSPO SCCS Requirement Non-conformities SCCS Non-conformance of 05: There is no mechanism in place for handling of non-conforming material/documents. This mechanism should also be used to take appropriate steps when the Supply Chain certification of a supplier is found to be invalid. Correction: Prepare the mechanism in standard operating procedure (SOP) about handling of non-conforming material/documents for RSPO SCCS SG Model system, through the declassification from SG product to MB product. The procedure is number SRS004 Rev 00 Date Issued on 15/04/2014. Corrective Action: Ensure all of document since contract until receiving raw material is compile with facility procedure, and also ensure the supplier or raw material is supplier certified by RSPO specially for SG, MB supplier through checked in RSPO website. Auditor Conclusions: Closed Date of closure: November 22, 2014 Verification Result: The organization has established the procedure to handling nonconforming material/documents for RSPO SCCS SG and MB, through the document number SRS004 Rev 01 date issued 04/03/2015. Procedure mentioned production department shall responsible fully for handling of non-conforming product include processing and delivery. If the non-conforming product specially happens in SG product, then should be declassification from SG to MB. SCCS Non-conformance and 03 of 05: 1. The facility has no mechanism to ensure the independent third parties (subcontractors) comply with the intent and requirements of the RSPO Supply Chain Standard. 2. There is no evidence that facility has documented control system with explicit procedures for the outsourced process, which are shared with the relevant contractor. 3. On the contract agreement still not include requirement about RSPO SCCS section (5.4.2.e) that independent third parties engaged, provide un restricted access to their respective operations, systems,

19 Page 19 of 28 and any and all information to certification bodies that are duly approved by the RSPO when this is announced in advance. Also, the facility does not ensure that the contractor has compliance to SCCS RSPO systems. Correction: 1. Prepare mechanism such as SOP, work instruction for all subcontractor and brief all about handling RSPO certified product specially for MB and SG. 2. Prepare mechanism for PT LDC Indonesia to monitor and control all of subcontractor related transportation, and storage of certified product specially for MB and SG, through the make some procedure and work instruction for all subcontractor and added several item in work agreement and always notes about RSPO SCCS certify product specially for SG system shall be store in separate. 3. Renew all of subcontractor work agreement through the addendum or internal memo for independent third parties will allowed and provide information related RSPO SCCS implementation to certification body. Corrective Action: 1. Ensure the all of subcontractor understood with procedure about handling certified product through the brief all contractors. 2. Added in work agreement for subcontractor that the all of SG product shall store in separate, and keep record in 10 years, also ensure the contractor agree and understood with the work agreement. 3. Ensure in every subcontractor work agreement has state about independent third parties will allowed and provide information related RSPO SCCS implementation to certification body and they are will provide the information. Auditor Conclusions: Closed Date of closure: November 22, 2014 Verification Result: Organization has conducted the brief of RSPO SCCS SG and MB for all contractors, their 14 contractors related transportation and 1 contractors related storage tank evidenced by the record of internal memo dated on January 1, And other organization has sent the internal memo to all contractors related the RSPO SCCS implementation, and will allow the certification body to check and verification the system and other information related RSPO SCCS implementation. SCCS Non-conformance of 05: The facility has procedure SMR004 Rev 00 Effective date on 15/04/2014, but on the procedure not mention about: shall assure and verify through clear procedures and record keeping that the RSPO certified palm product is kept segregated from non-certified material including during transport and storage and be able to demonstrate that is has taken all reasonable measures to ensure that contamination is avoided. Correction: Prepare mechanism such as standard operating procedure/sop about receiving, storage, proses and dispatch and shall evidence by documentation that the mechanism has been verified. The procedure is SRS001 Rev 00 Date Issued 15/04/2014. Corrective Action: Ensure the procedure about receiving, storage, proses and dispatch has been understood by all person in charge in every department who implemented of SCCS, and ensure that certified product SG will separate from transportation until storage through the ensure all document related and verified. Auditor Conclusions: Closed Date of closure: November 22, 2014 Verification Result: The organization has established the procedure and has brief to all person who responsible for RSPO SCCS SG and MB implementation, but because there is revision for RSPO SCCS standard from Novem-

20 Page 20 of 28 ber 2011 to November 2014, so the organization procedure has revision and will communication again to all person by the brief again will conduct in November SCCS Non-conformance of 05: The facility shall provide documented proof that the RSPO certified oil palm product could be traced back to only certified segregated material. Correction: Prepare standard operating procedure/sop for traceability product for RSPO SG certified product. The procedure is SRS003 about traceability RSPO SCCS. Corrective Action: Ensure the procedure will be implemented through the brief all related department/person in charge to monitoring all of document specially for SG certified document from purchase until receiving product and also ensure the supplier registered in RSPO SG supplier in RSPO website so that the supplier will trace until palm oil mill and estate source. Auditor Conclusions: Closed Date of closure: November 22, 2014 Verification Result: Organization has established the procedure related traceability for SG product document number SOP SRS003 Rev 01 date issued 04/03/2015, and this procedure has communicated to all person in charge related RSPO SCCS SG. During the surveillance audit, organization still no yet the SG certified suppliers. 3.3 Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions SCCS Non-conformance f 06 Organization has established procedure, but found two procedure still no cover all activity for implementation of RSPO SCCS SG and MB, i.e.: - QP016 Rev 01 about control non-conforming product RSPO SCCS, no sett how to handling the non-conforming document. - SRS001 about receiving and storage RSPO SCCS product, in the procedure no mention clearly how to reduce and minimize possibility mixing/contamination from transportation process, pipelines process, loading container process for SG raw material and SG product. Correction: 1. Organization has submitted new revision of QP016 Rev 02 date issued 14/09/2015, in the procedure has added the new information in the procedure related handling non-conforming document. 2. To determine the possibility of contamination and/or mixing in SG product and raw material, organization will conduct the cleaning, flushing and blowing before do the transportation raw material and product SG. Detail of cleaning, flushing and blowing process was explained in procedure SRS001. Organization also submitted the minutes of cleaning process and photograph. Corrective Action: 1. Conduct the internal audit in once year to ensure the procedure implementation running well and person in charge understood how to handling the nonconforming documents. 2. Conduct the internal audit in once year to ensure the cleaning process will implemented very well to keep the SG product in 100% pure. Auditor Conclusions: Closed

21 Page 21 of 28 Date of closure: September 15, 2015 Verification Result: Organization has submitted the evidence of this non-conformation through the submitted the new revision of organization procedure number QP016 Rev 02 date issued 14/09/2015 and procedure number SRS001. The new revision procedure has explained the how to handling the non-conformance document and how to ensure the receiving process for SG raw material and product will not contaminated and keep pure 100%. SCCS Non-conformance of 06 Organization has brief all outsource/third party through the sent the internal memo in January 1, 2015, but internal memo no inform about new standard for RSPO SCCS SG shall pure 100% without contamination. Correction: Organization has conduct the RSPO SCCS SG and MB brief to all contractor, evidenced with: 1. Brief attendant list date on September 22, 2015 about separated the SG product, attended by PT Karunia Pratama Sejahtera, PT Anugerah Santan Samudera and PT Samudera Mulia Karsa. 2. Minutes of internal memo received date on September 22, 2015 related to third contractor above. 3. Brief attendant list date on October 1, 2015 about handling RSPO SG product, attended by PT Baruna Trans Logistik, PT Sutomo Agro Indomas Lampung and PT Segara Trasindo Mandiri 4. Minutes of brief and photograph brief processed. Corrective Action: Include the RSPO SCCS training for contractor in training program in 2016 (will conduct in every once year). Auditor Conclusions: Closed Date of closure: September 30, 2015 Verification result: Organization has submitted the evidenced to close this non-conformity through the record of third party brief conducted by the organization, such as attendant list, photograph and others. Then the organization commitment to always brief the third party was include in the RSPO SCCS organization-training program for 2016, will conducted in every year. SCCS Non-conformance of In contract between PT LDC Indonesia with PT Samudera Mulia Karsa and PT Sutomo Agroindomas Lampung no explain about that the certification bodies will allowed to access the contractor to verified and check their system related implementation RSPO SCCS, according to the organization procedure number SRS005 Rev In contract between PT LDC Indonesia with PT ISAB only state 17 storage tank rent by organization, but the implementation in field, there are 10 storage tank also rent by organization, so amount of storage tank rent by the organization is about 27. Correction: 1. Organization has added new information related that the contractor will allowed to access the contractor to verified and check their system related implementation RSPO SCCS in to contract letter. That information only for contractor will transport of certified raw material and palm oil product. Example contract No. 07/SMK/IX/2015 dated on 30 September 2015 between PT Samudera Mulia Karsa and PT LDC Indonesia. 2. In that contract wrote that the PT LDC Indonesia and PT ISAB (as contractor) would increase gradually the storage tank capacity until 125,000 MT, and real condition during the audit the storage tank capacity only 105,480 MT (27 unit storage tank). Corrective Action:

22 Page 22 of 28 Document control shall ensure through the contract review in every six (6) month to all transporter/contractor to reduce nonconformity and contain the contract wall fulfill to RSPO SCCS requirement. Auditor Conclusions: Closed Date of closure: September 16, 2015 Verification result: Organization has submitted the evidenced, the new revision contract with information about CB will allow to conduct the verification of their system related the RSPO SCCS implementation. Organization also stated that the commitment in the organization procedure. SCCS Non-conformance of 06 The document control that s responsible for RSPO SCSS implementation has not training for RSPO SCCS. Correction: Conduct RSPO SCCS in-house training for all LDC Indonesia workers. Evidenced by attendant list training conducted dated on October 5, 2015, attendant by 19 persons who responsible for RSPO SCCS implementation, complete with training photograph. Corrective Action: Entrance the RSPO SCCS training into budget and conducted in every once year to refreshment. Auditor Conclusions: Closed Date of closure: October 5, 2015 Verification result: Organization has submitted the evidenced record of RSPO SCCS training implementation also budget for next year with included the training information refreshment. SCCS Non-conformance of 06 In the organization procedure there is no explain about how to keep the SG product 100% pure without contamination. Correction: To keep the SG product 100% pure from contamination, organization will cleaning, and flushing before SG process will start. The detail cleaning and flushing explained more in procedure SRS001 Rev 02 date issued on 14/09/2015. The organization has mentioned in the procedure about handling SG product, i.e.: - For SG raw material/product loading from truck will dedicated in loading container number 11 and 12, after the container cleaning and flushing with SG raw material/product, to cleanup from other raw material - For SG raw material/product from tanker, will dedicate in tank farm number F5, after the storage tank cleaning and heating using hot water and swap. - For SG raw material/product transfer using pipe lines from tanker and/or from loading container to dedicated tank farm, should be pigging 3 times (3x), then continue with flushing using SG raw material/product, after that continue with blowing and the transfer pipe lines marking with red color. - For SG raw material/product will use to flushing activity for dedicated tank, loading container, and pipe lines, based on management agreement is about ± 25.9 tones, with description: a. Loading container flushing ± 3 tones b. Pipe lines flushing ± 2.9 tones c. Flushing for refinery process ± 20 tones - All of RSPO raw material and product SG has been used flushing activity will down grade into RSPO MB raw material/product. - And for SG product from refinery will dedicated in tank farm number F3 for RBDPO and C1 for PFAD.

23 Page 23 of 28 Corrective Action: Management and document controller will conduct internal audit to ensure the RSPO SCCS implemented well in once year. Auditor Conclusions: Closed Date of closure: September 15, 2015 Verification result: Organization has submit the evidenced i.e.: the new revision of organization procedure document number SRS001 Rev 02, with include explanation about handling incoming raw material from tanker/port, piping, truck to keep the RSPO SG raw material pure 100%. SCCS Non-conformance of 06 In organization procedure number SMR002 Rev 01 about mass balance calculation still no yet mentioned what type of mass balance system will implemented by organization. Correction: Procedure has revised by the organization to SMR002 Rev 02 date issued 14/09/2015. On the procedure has established the mass balance system will use by organization i.e.: fixed inventory periods. Corrective Action: Document control will conduct the verification in every once year to ensure the mass balance record will implemented and fix inventory periods running well. Auditor Conclusions: Closed Date of closure: September 16, 2015 Verification result: Organization has submit the evidence, the new revision procedure document number SMR002 Rev02, was include the information about mass balance system will implemented in organization. 3.4 Conclusion and Recommendation for RSPO Supply Chain Certification The audit team has confirmed through the audit process that PT LDC Indonesia has maintained their system to ensure compliance with the RSPO Supply Chain Certification requirements (dated November 2014). PT TUV Rheinland Indonesia recommends that PT LDC Indonesia still continue their certification of compliance to the RSPO Supply Chain Certification requirements.

24 Page 24 of CERTIFIED ORGANISATION S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY 4.1 Date of Next Surveillance Visit The next surveillance visit is planned for September Acknowledgements of Internal Responsibility and Formal Sign-Off by Client It is acknowledged that the assessment visit was carried out as described in this report and we accept the assessment findings and report content. Signed on behalf of PT Louis Dreyfus Indonesia Signed on behalf of PT TUV Rheinland Indonesia Arie Rizki Management Representative Date: November 7, 2015 Mhd Fundy Cholis Kurniawan Lead Auditor Date: November 7, 2015

25 Page 25 of 28 APPENDICES Appendix 1: Details of Supply Chain Certification Certificate

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