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No : 012/IP/LA/XI/2014 21 November 2014 RSPO Secretary General Unit A-37-1, Level 37, Tower A Menara UOA Bangsar No. 5 Jalan Bangsar Utama 1 59000 Kuala Lumpur Attn. : Mr. Darrel Webber Secretary General

Dear Mr. Webber, RE : Closure Request for PT. Sisirau Progress on Actions Taken in Response to RSPO

Complaints Panel’s Requests Further to our 17th of November 2014 communication, where we strongly requested for a review of the Complaints Panel’s 13th of November 2013 decision to recommend the suspension of PT. Sisirau/PT. Ibris Palm for failure to submit a Land Use Change Analysis and a Compensation proposal, we would like to highlight our substantial progress on actions taken in response to RSPO Complaints Panel’s requests. Throughout the complaints process we have demonstrated our commitment and cooperativeness with RSPO and have exhibited a very high degree of tolerance towards the SOS’ continued non-compromising and negative demeanor. We have progressed above and beyond the RSPO’s Complaints Panel’s corrective action requests, which is clearly evident in the chronology of events presented below for your consideration. 29 October 2012 On the 29th of October 2012, SOS submitted a complaint to RSPO alleging that PT. Sisirau: (1) had cleared High Conservation Value (HCV) forests, within the PT. Sisirau concession area,

which are orangutan habitats; (2) PT. Sisirau failed to comply with criterion 5.1 and 5.2 of the RSPO Principles & Criteria. 12 November 2012

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 1 and No. 2, both dated 12th of November 2012

Through the above stated email communication to RSPO Indonesian Director, Ms. Desi Kusumadewi, our Mr. Bungaran Sitorus submitted a change in PT. Ibris Palm’s contact persons responsible for RSPO matters; they being:

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Primary Representative Name : Gamal Ahimsa Designation : Group Head - CSR Telephone : 62-21-5795 0111 Fax : 62-21-5790 1330 Email : gamal@ibris.co.id Secondary Representative Name : Bungaran Sitorus Designation : CSR - Manager Telephone : 62-21-5795 0111 Fax : 62-21-5790 1330 Email : bungaran.sitorus@ibris.co.id Ms. Desi Kusumadewi proceeded to forward our above communication to RSPO’s Ms. Eileen Ho and Ms. Victoria Ramalingam. It should be well noted that such communication was made 4 days prior to SOS’ reference to PT. Sisirau’s contact details as per 16th of November 2012. 22 March 2013 Following various PT. Sisirau and RSPO email and letter communications, our Mr. Gamal received RSPO Mr. Ravin Krishnan’s 22nd of March 2013 communication letter in which the RSPO Complaints Panel requested that: 1. PT. Sisirau engages a RSPO approved Certifying Body to review and verify that the

Environmental Assessment and Environmental Management Plan (DELH-UKL/UPL 2011) is indeed adequate and meets Criterion 5.1 and 5.2 under Principle 5 of the RSPO P&C; in particular environmental responsibility and conservation of natural resources biodiversity to prevent a recurrence of the events that led to the SOS complaint.

2. The Same Certifying Body shall also review and verify PT. Sisirau’s actions in the rescue of the orangutans to ensure that proper procedure has been followed on each occasion.

3. The RSPO shall select the RSPO approved Certifying Body – to ensure that they are expert in high conservation value status, particularly in relation to rare threatened and endangered species – and the cost of the review shall be borne by PT. Sisirau.

01 August 2013 After further communications, RSPO appointed its approved assessors to carry out an independent third party verification and for which our Mr. Gamal signed the respective acceptance of the RSPO “Terms of Reference Review and Verification of PT. Sisirau Compliance with the RSPO HCV Principle 5” on the 1st of August 2013.

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16 August 2013

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 3, dated 16th of August 2013

PT. Delima Makmur and PT. Sisirau submitted their individual “RSPO Membership Resignation Form”, dated the 16th of August 2013, which was immediately emailed to membership@rspo.org. The reason for membership resignation being that both companies are a business unit of PT. Ibris Palm/RSPO membership # 1-0103-11-000-00; therefore, there was no need to have a separate membership for either of the companies. October 2013 Review and Verification of PT. Sisirau’s Compliance with the Roundtable on Sustainable Palm Oil Principle 5 – Criteria 5.1 and 5.2, an independent verification report was accomplished and prepared by the Malaysian Environmental Consultants Sdn Bhd; being the RSPO approved and appointed assessor for the required independent third party verification. April 2014 14 April 2014 The RSPO Complaints Panel deliberated on the October 2013 independent third party verification report and issued a 14th of April 2014 communication letter, in which the RSPO Complaints Panel requested PT. Sisirau to : 1. Review all the Standard Operating Procedures based on the recommendations of the

independent verification report on the conservation, discovery, rescue and relocation of orangutans and train the ground staff in the concession on the same.

2. Implement all recommendations contained in the MEC report on the conservation of forests to aid the transient orangutan population within the concession notably: i. All remaining secondary forest and unplanted areas should be preserved as

buffer/allowing the orangutans the freedom of movement between the concession and other concessions in the area and the nearby National Park.

ii. HCV 4 (steep area, river and stream buffer) should be established and enhanced to serve as refuge for transient orangutans.

iii. Socialization of these conservation areas with local community to prevent harm to any orangutan that may exist in the area.

3. Identify, evaluate, comply and implement national laws and regulations related to conservation and forest areas to ensure that all corrective actions are in line with Principle 2 of the RSPO P&C.

4. Demonstrate that all works undertaken within the concession is in compliance with the boundaries specified in its Hak Guna Usaha.

5. PT. Sisirau to do a Land Use Change analysis and submit a compensation proposal to the Compensation Panel for review. Compensatory actions shall be agreed upon by RSPO, Complaints Panel and the complainant.

6. Engage with the complainant, Sumatran Orangutan Society (SOS) and consult them on the implementation of all the above.

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7. PT. Sisirau must submit an Annual Communication of Progress and a Time Bound Plan as required by Article 2.2 and 3.8 of the RSPO Code of Conduct within 4 weeks of the date of this letter.

8. Submit an action plan with the timelines for the implementation of 1-6 above within 2 weeks of the date of this letter.

21 April 2014 The RSPO Secretary General, Mr. Darrel Webber, sent a communication letter to: (1) PT. Sisirau for the attention of Mr. Gamal Ahimsa and (2) PT. Delima Makmur for the attention of Mr. H. Bahrumsyah Usar (for which the change in

PT. Ibris Palm’s contact persons responsible for RSPO matters was reported to RSPO on the 12th of November 2012 and the resignation of PT. Delima Makmur and PT. Sisirau was submitted on the 16th of August 2013);

regarding the non-submission of the Annual Communications on Progress (ACOP) reports for the reporting periods 2010/2011, 2011/2012 and 2012/2013. RSPO requested an explanatory letter to clarify reasons for non-submission of the ACOP report. 25 April 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 4, dated 25th of April 2014 and No. 5, dated 28th of April 2014

PT. Sisirau’s letter No. 01/SSR-J/IV/2014, dated the 25th of April 2014 acknowledged receipt of the RSPO Complaints Panel’s 14th of April 2014 communication letter and related concerns regarding the RSPO Complaints Panel’s requests, as well as the unethical conduct of the complainant. Matters addressed by PT. Sisirau essentially encompassed the following: (1) PT. Sisirau’s major concern is that RSPO has yet to censure SOS for their categorical breach

of the “RSPO Code of Conduct for Members” in accordance with clauses 5.1 and 5.2 which states : 5.1 Associates will seek to resolve grievances directly with other member organisations

in a timely fashion, and will not make unsubstantiated allegations of breaches against other associates.

5.2 Breaches of this Code of Conduct, or the by-laws and statutes of the RSPO may lead to exclusion from the organisation.

We firmly stated that SOS should be investigated for possible exclusion from RSPO, as SOS chose to air their grievance in the public domain and made no attempt to resolve their grievance directly with PT. Sisirau. Adherence to the “RSPO Members Code of Conduct” is an ethical requirement that ensures fairness to all members and not promoting victimization.

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Further, we stated that we would like the RSPO Complaints Panel to record our compliance to clause 5.3; being. 5.3 Prior to taking public action in cases of unresolved allegations of breaches of this

Code, members will report breaches to the Executive Board, which will deal with the alleged breaches in accordance with the RSPO Grievance Procedure.

(2) PT. Sisirau’s second concern was in regards to Point No. 5 of the RSPO Complaints Panel’s

14th of April 2014 communication letter which stated: 5. PT. Sisirau to do a Land Use Change analysis and submit a compensation proposal to

the Compensation Panel for review. Compensatory actions shall be agreed upon by the RSPO, Complaints Panel and the complainant.

We related that we will conduct a study on this aspect and present it to RSPO as soon as we have engaged an independent consultant, as our opinion on the matter is that the compensation process should not include SOS to ensure the absence of any “conflict of interest”; the compensation process being independent of the complainant and based only on technical evidence.

(3) PT. Sisirau’s third concern was in regards to Point No. 6 of the RSPO Complaints Panel’s 14th of April 2014 communication letter which stated: 6. Engage with the complainant, Sumatran Orangutan Society (SOS) and consult them on

the implementation of all of the above (Points 1 - 5). We strongly objected to this engagement request, as the complainant is seen as biased and is not likely to have the spread of expertise required for the implementation of points 1 – 5. Furthermore, we reserve the right to engage independent experts to fulfill the RSPO Complaints Panel’s requests; nevertheless, we have no objection if RSPO engage with the complainant to review our independent reports if deemed necessary.

(4) To prepare for a better Annual Communication of Progress and a Time Bound Plan

(request Point 7 of the RSPO 14th of April 2014 communication letter) and Action Plan for points 1 – 5 (request Point 8 of the RSPO 14th of April 2014 communication letter), PT. Sisirau requested the following extension : Point 7 RSPO request : within 4 weeks of the date of the letter, (14 April 2014). Requested extension : within 6 weeks of the date of the letter. Point 8 RSPO request : within 2 weeks of the date of the letter, (14 April 2014). Requested extension : within 4 weeks of the date of the letter.

(5) We also informed RSPO of the current Ibris Group contact persons responsible for RSPO

matters; they being:

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Primary Representative Name : M. Leksin Awal Designation : Head of Sustainability Telephone : 62-21-5795 0111 Fax : 62-21-5790 1330 Email : leksinawal@ibris.co.id Secondary Representative Name : Rajendran Palaniappan Designation : Chief Operations Officer Telephone : 62-61-414 4777 Fax : 62-61-452 0671 Email : rajendran@ibris.co.id

The above PT. Sisirau response letter was communicated through a 25th of April 2014 email sent to RSPO’s Complaints Coordinator, Mr. Ravin Krishnan, and cc to RSPO’s Secretary General, Mr. Darrell Webber. May 2014 20 May 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 6, dated 21st of May 2014

In furthering the PT. Sisirau communication letter No. 01/SSR-J/IV/2014, dated the 25th of April 2014, an additional PT. Ibris Palm communication letter No. 002/IP/LA/V/2014, dated the 20th of May 2014, was addressed to the RSPO Secretary General, Mr. Darrell Webber and cc to Ms. Amalia Prameswari, in which we related the following : - Acknowledgement of receipt of the RSPO Secretary General’s 21st of April 2014

communications to PT. Delima Makmur and PT. Sisirau, as well as RSPO’s Ms. Amalia Prameswari’s 16 May 2014 email to our Bungaran Sitorus, regarding ACOP submission.

- Noting the PT. Delima Makmur and PT. Sisirau member resignation, which was mediated through a 16th of August 2013 RSPO Membership Resignation Form and current organization identity name as PT. Ibris Palm.

- Reiteration of our current contact persons responsible for RSPO matters: Primary Representative Name : M. Leksin Awal Designation : Head of Sustainability Telephone : 62-21-5795 0111 Fax : 62-21-5790 1330 Email : leksinawal@ibris.co.id

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Secondary Representative Name : Rajendran Palaniappan Designation : Chief Operations Officer Telephone : 62-61-414 4777 Fax : 62-61-452 0671 Email : rajendran@ibris.co.id

20 May 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 7, dated 19th of May 2014 and No. 8, 21st of May 2014

PT. Ibris Palm’s communication letter No. 003/IP/LA/V/2014, dated the 20th of May 2014 and addressed to RSPO’s Complaints Coordinator, Mr. Ravin Krishnan, presented RSPO with the following documents: - “Action Plan For The Implementation For RSPO Complaints Panel Request to PT. Sisirau”

(to comply with request point No. 8 as contained in the RSPO’s communication letter, dated the 14th of April 2014, requesting PT. Sisirau to submit an action plan with the timelines for the implementation of points 1-6).

- “Ibris Palm Annual Communication of Progress”, for the reporting period 01 June 2013 thru 31 May 2014, in which the Time-Bound Plan was embedded on page 4 of the Annual Communication of Progress (to comply with request point No. 7 as contained in the RSPO’s communication letter, dated the 14th of April 2014, requesting PT. Sisirau to submit an Annual Communication of Progress and a Time Bound Plan).

July 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 9, dated 24th of July 2014

PT. Ibris Palm’s communication letter No. 004/IP/LA/VII/2014, dated the 24th of July 2014 and addressed to the RSPO’s Complaints Coordinator Mr. Ravin Krishnan, furthered the implementation of the action plan that was presented in our previous communication letter No. 003/IP/LA/V/2014, dated the 20th of May 2014. A comprehensive update was submitted on PT. Sisirau’s progress and the initiation of significant actions in addressing RSPO Complaints Panel’s requests as contained in the RSPO Complaints Panel’s 14th of April 2014 communication letter. PT. Ibris Palm’s report consisted of a total of 4 Volumes, where Volume I comprised of an attachment to the PT. Ibris Palm’s communication letter No. 004/IP/LA/VII/2014, dated the 24th of July 2014, and in which its contents consisted of:

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Volume I : PROGRESS ON ACTIONS TAKEN IN RESPONSE TO RSPO COMPLAINTS PANEL’S REQUESTS

Contents :

Introduction

Progress

The Future

Matrix of The Progress of The Actions Taken in Response to RSPO Complaints Panel’s Requests

Due to the size of the Volume II – IV file, PT. Ibris Palm arranged to have the list of actions taken, along with supporting documentation in the form of reports, photographs, official communications, attendance lists and presentations to be physically handed over to RSPO by the 25th of July 2014 and in the form of a CD. The contents of Volume II – IV consisted of: Volume II : Supporting Documents

Laporan Studi Pemantauan Orangutan Dan Kesesuaian Habitatnya Di PT. Sisirau

PT. SISIRAU: A Management Plan for HCV Compliance with RSPO Requirements

Volume III : Appendices 1-14 Appendix 1 : Standard Operation Procedures (Summarised version) Appendix 2 : Collaboration letter with BKSDA Appendix 3 : Formal training with BKSDA Appendix 4 : Attendance list for the training programs with BKSDA Appendix 5 : Attendance list for the training programs with consultants Appendix 6 : Information sheets size F4 Appendix 7 : Information Poster size 80 x100 cm Appendix 8 : Boundary marker placed in the conservation sites Appendix 9 : Signboard placed in the conservation sites Appendix 10 : Training photos Appendix 11 : Training Documentation Appendix 12 : Signboards along river buffers Appendix 13 : Monitoring Schedule Appendix 14 : Socialisation on Protected Wildlife Volume IV : Appendix 15

Monitoring and Evacuation Reports August 2014 11 August 2014 The RSPO Secretary General’s 11th of August 2014 communication letter confirmed that the RSPO Board of Governors reviewed and accepted PT. Ibris Palm’s explanation for not submitting the Annual Communications of Progress for the reporting periods 2010/2011, 2011/2012 and 2012/2013. PT. Ibris Palm was also expected to submit the current on-going Annual Communications of Progress 2013/2014 by the 19th of September 2014.

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15 August 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 10, dated 18th of August 2014

PT. Ibris Palm’s 15th of August 2014 communication letter No. 005/IP/LA/VIII/2014 responded to the RSPO Secretary General, Mr. Darrel Webber, 11th of August 2014 communication letter, by reiterating that: - Since the 21st of July 2011, our registered membership is under the holding company PT.

Ibris Palm and membership number is 1-0103-11-000-00. - PT. Delima Makmur, PT. Sisirau and PT. Satya Agung come under the holding company as

subsidiaries managing oil palm plantations in Aceh, Indonesia. - A collective ACOP for the 3 companies for the reporting period 2013/2014 was submitted

to the RSPO Complaints Coordinator, Mr. Ravin Krishnan, through a No. 003/IP/LA/V/2014 communication letter that was dated the 20th of May 2014.

PT. Ibris Palm also resubmitted its 20th of May 2014 communication letter No. 003/IP/LA/V/2014 and respective ACOP to the RSPO Secretary General, Mr. Darrell Webber for his perusal. September 2014 03 & 04 September 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 11, dated 3rd of September 2014 and No. 12, dated 4th of September 2014

RSPO Indonesian Complaints Coordinator Ms. Amalia Falah Alam’s 03rd of September 2014 email communication requested that PT. Sisirau send the complete documents with annexes of the PT. Ibris Palm’s 24th of July 2014 communication letter No. 004/IP/LA/VII/2014 "Progress on Actions Taken in Response to RSPO Complaints Panel's Requests", in Google Drive. The requested documents were submitted through a 04th of September 2014 email communication. 10 September 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 13, dated 10th of September 2014

On the 10th of September 2014, RSPO Indonesian Complaints Coordinator Ms. Amalia Falah Alam’s email communication raised some points on the progress of the PT. Sisirau’s 24th of July 2014 report and pertaining to:

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1. - The inclusion of the 15 conservation sites in PT. Sisirau’s HGU. - Plans to connect the 15 conservation sites and tieing it into a compensation. 2. Detailed plans for river buffers and compliance with local and national regulations. It was

suggested that, besides our restriction on the use of chemicals, the river buffer should be planted.

3. Evaluation and identification of gaps with respect to compliance with government regulations, as well as our upcoming plan to furnish the gaps.

4. ACOP submission. October 2014 01 October 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 14, dated 2nd of October 2014

PT. Ibris Palm’s 01st of October 2014communication letter No. 007/IP/LA/X/2014 responded to the RSPO Indonesian Complaints Coordinator Ms. Amalia Falah Alam’s 10th of September 2014 email communication. PT. Ibris Palm provided background information, based upon an independent investigation, so as to render a better understanding of the site.

The PT. Sisirau area was fully planted between 1992 and 1996 (planting records), but confirmed by Landsat 5 image, 1999 (see Map 1).

The area is clearly being replanted and terraced and it is not a new development.

Clearing and replanting began in 2010 and has continued through to 2013.

It has been assumed that forest has been cleared and the orangutans will be starved; however, this may be more of a reactionary accusation and not based on holistic information.

There was no HCV to start with, as the area was completely cleared and planted by 1999.

Secondary forests areas have developed due to the abandonment of fields, as harvesting in non-terraced steep areas were not undertaken by the previous management.

Due to recent stresses in the adjacent areas, the orangutans might be recent migrants seeking refuge.

The orangutans could also be longer term users as the secondary forest areas could have offered not only relative security but food too.

Conservation value attributes have only developed over the past few years, but this could have been ascertained if the land manager had undertaken a HCV assessment in 2010 or earlier. Records show that PT. Ibris Palm purchased the holding in 2010 and PT. Sisirau is only now getting familiar with RSPO requirements. The fact remains that in PT. Sisirau’s interpretation of the RSPO P&C, a HCV assessment was not required because of the planted status of the estate.

Most of the secondary forest areas has been cleared and replanted. Only a small proportion of 36.54 ha is left and currently being given conservation status by PT. Sisirau.

It is in this setting and with this understanding that the PT. Sisirau case must be viewed.

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Further detailed information and explanation covered the following areas: - PT. Sisirau’s HGU renewal process was in 2013 with an official area of 2,113 ha; denoting a

loss of approximately 1,000 ha to land grab by the local community and land grab approximating 183 ha within the new HGU.

- The current land use status was presented in Map 2; indicating that the total area available to PT. Sisirau is 1,932 ha, of which 36.54 hectares has been set aside for conservation purposes and the replanting area constitutes 250 ha.

- Also indicated in the map is the theoretical buffer for rivers. The main river flowing through the estate has been allocated a 10 meter buffer on both sides; thus, covering an area of 25 ha. Minor streams have been attributed a 5 meter buffer and covers an area estimated to be 28.5 ha. The river flowing from north to south passes through area planted prior to 1999 and only an insignificant length in the south flows in and out of the replanted area. The buffer creation for this river can only be achieved at the time of replanting in the planting block it flows through and thus, the 10 meter buffer on both sides is populated with oil palm.

- The best practice for this scenario is the current PT. Sisirau practice of not spraying in the 10 meter zone and weeding manually. Where the smaller streams are concerned, the streams are less than 3 meters in depth and hardly 1 meter wide. Due to the hilly terrain, most, if not all of these streams are ephemeral. The issue of establishing buffers on these streams can only be restricted to the cleared areas but because these streams are ephemeral at the time of replanting the buffers were not established. Most of these streams flow through blocks that were planted post 1999. Keeping to PT. Sisirau’s best practice, the areas adjacent to streams are not chemically treated and manual weeding is done and thus, a total of 53.5 ha (25 +28.5) ha is managed in this manner. The establishment of stream buffers can only be addressed at time of complete replanting and at the present moment is a non-issue.

- Map 3 was presented to show the conservation sites distribution that has been set aside by PT. Sisirau, which totals 15 sites and range between 0.3 to 6.90 hectares. The connection of these sites can only be partially considered through a stream network at the time of future replanting. In essence, this will be an unproductive exercise and most of the conservation patches do not have any streams flowing though.

- An argument can be raised that if the 250 ha that was replanted between 2010-2013 were maintained then conservation would have been served better in this oil palm concession; however, it must be realized that most of the area replanted and terraced had vegetation composed of pioneers species and old oil palm, this would have excluded it from any form of compensation (based on the current indices).

- In reality, though PT. Sisirau replanted without undertaking a High Conservation Value (HCV) assessment, the areas replanted had less than 8 meter vegetation with oil palm and technically cannot be categorized as areas having HCV potential. The remnant patches can however currently serve as refugee sites temporally. Nevertheless, PT. Sisirau is committed to monitoring for “refugee” orangutan and collaborating with the relevant stakeholders to undertake translocation. Maintaining the intactness of the conservation sites, monitoring and evacuation is all that can be expected of a small concession like PT. Sisirau. Anything beyond this seems rather impractical and overzealous.

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Ms. Amalia Falah Alam’s queries were also addressed and attachments were provided with regards to (1) Gap Analysis Laws of Regulating River Flow Areas and (2) Gap Analysis Laws of Regulating Conservation Areas. 02 October 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 15, dated 2nd of October 2014

On the 02nd of October 2014, RSPO Indonesian Complaints Coordinator Ms. Amalia Falah Alam’s email communication raised inquiries of issues pertaining to: - LUC analysis submission. - Our communication with HOCRU and whether or not we informed HOCRU of our

progress. 03 October 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 16, dated 03rd of October 2014

Responding to the RSPO Indonesian Complaints Coordinator Ms. Amalia Falah Alam’s 02nd of October 2014 email communication, PT. Ibris Palm sent a communication letter No. 008/IP/LA/X/2014, dated 03rd of October 2014, which cited the following: - As communicated through our 01 October 2014 email reply to Mr. Dillon Sarim –

Compensation Executive, cc. RSPO representatives Soo Chin Oi, Desi Kusumadewi and yourself, we are still in the process of completing the Disclosure of Areas Cleared without Prior HCV Assessment, along with the respective reporting template for RSPO Historical Land Use Cover Change Analysis and Compensation Liability templates. The required data, records, analysis and its relevant review covers periods back to year 2005; however, we will be submitting the templates shortly and would appreciate RSPO’s patience on the matter.

- Furthermore, it is our firm opinion that the Sumatran Orangutan Society (SOS) should have fully attempted to resolve their grievances in adherence with the “RSPO Code of Conduct for Members”.

- SOS made a cursory attempt to send a communication, but to an individual who was no longer employed by PT. Ibris Palm and in this instance, should have checked and consulted with RSPO in order to obtain the proper contact details. Although this breach of membership conduct was brought up to RSPO, there has been no reaction to this to date.

- PT. Ibris Palm had attempted to get the Yayasan Orangutan Sumatera Lestari – Orangutan Information Centre (YOSL- OIC), an offshoot of SOS, involved in a training and socialization process; however, but they seemed to have taken on a rather negative stance and was actually against us involving the Indonesian government agency responsible for conservation, Badan Konservasi Sumber Daya Alam (BKSDA).

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- The fact remains that PT. Ibris Palm, together with BKSDA and The Human Orangutan Conflict Response Unit (HOCRU), the latter being an initiative funded by YOSL-OIC, have successfully trans-located a number of orangutan to safety. We are clearly collaborating with all the necessary parties to ensure that any form of orangutan conflict is managed and resolved successfully.

- A non-compromising stance taken by certain individuals, rather than the whole organization itself, is detected and comes across as negative and SOS needs to seriously review its approach in dealing with RSPO members. The generated perception is that PT. Ibris Palm has destroyed Primary Forest and caused the extinction of the orangutan. We find this not only unacceptable but also unethical, especially when the root of the problem is habitat loss outside our concession which was planted in 1999.

- We see it best that RSPO acts as liaison and SOS receives information regarding our progress through RSPO, as our previously submitted “ACTION PLAN FOR THE IMPLEMENTATION FOR RSPO COMPLAINTS PANEL REQUEST TO PT. SISIRAU” matrix chart clearly states :

“PT. Sisirau will engage with all relevant stakeholder who can contribute towards attempts to reduce wildlife conflicts in PT. Sisirau. We are committed to conservation. A series of progress reports will be sent to RSPO. These reports can be forwarded to SOS / OIC / HOCRU by RSPO. We will seek active collaboration with BKSDA, the legal authority dealing with wildlife management and other collaborating stakeholders.”

27 October 2014 RSPO 1) Through a 27th of October 2014 email communication, RSPO Indonesian Complaints

Coordinator Ms. Amalia Falah Alam’s requested us to submit the Time Bound Plan. 2) Through a 27th of October 2014 email communication, RSPO Complaints Coordinator Mr.

Ravin Krishnan requested information on the dates when OIC & HOCRU were involved in the relocation of Orangutans in PT. Sisirau.

PT. Ibris Palm

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 17, No. 18 and No. 19, all dated 27th of October 2014

Our Mr. Rajendran Palaniappan responded to the above RSPO email communications through his 27th of October 2014 email communication where the ACOP was attached and noting that the Time Bound Plan was on page 4 of the report. At this point, the ACOP had already been submitted to: - RSPO’s Complaints Coordinator, Mr. Ravin Krishnan, through letter No. 003/IP/LA/V/2014,

dated the 20th of May 2014. - RSPO Secretary General, Mr. Darrel Webber, through letter No. 005/IP/LA/VIII/2014,

dated the 15th of August 2014.

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28 October 2014

Reference: ATTACHMENT 1 – REFERENCE EMAIL COMMUNICATIONS No. 20, dated 27th of October 2014 No. 21, No. 22 and No. 23, all dated 28th of October 2014

PT. Ibris Palm’s communication letters No. 009/IP/LA/X/2014 and No. 010/IP/LA/X/2014, respectively being PT. Sisirau Time-Bound Plan and its revision, both dated the 28th of October 2014, was sent to the RSPO Indonesian Complaints Coordinator, Ms. Amalia Falah Alam, as per requested format. Through a 28th of October 2014 email communication addressed to both the RSPO Complaints Coordinator, Mr. Ravin Krishnan, and the RSPO Indonesian Complaints, Coordinator Ms. Amalia Falah Alam, we submitted PT. Sisirau’s latest reports on the progress of orangutan monitoring for the period 23rd of June 2014 through the 22nd of September 2014. The chronology of events presented undeniably demonstrates our commitment and cooperativeness with RSPO and that there is no merit to any allegations that PT. Sisirau is “uncooperative”. In response to the RSPO Complaints Panel’s requests, we have progressed and submitted documentation above and beyond the corrective action requests made. Furthermore, our monitoring processes are continuous and we aim to sustain such efforts. The PT. Sisirau Land Use Change Analysis is not an issue, as there are no new plantings and all were done prior to year 1999 and thus, the 13th of November suspension decision holds no merit nor is it justifiable. We view this episode as being a very unfortunate experience as it has been undeniably tainted by: 1) a serious lack of clear and objective communication and decision making, 2) strong and feverish victimization, 3) the magnification of circumstances that have been completely blown out of proportion, 4) inconsistent interpretation of RSPO technical requirements, 5) a failure to immediately address breaches of membership code of conduct, 6) non-recognition of Balai Konservasi Sumber Daya Alam (BKSDA) as Indonesia’s authority in

handling human wildlife conflicts and the legal authority in-charge of orangutan translocation,

7) weaknesses in the complaints mechanism itself. It is with this in mind that we request closure for PT. Sisirau Progress on Actions Taken in Response to RSPO Complaints Panel’s Requests, as we want to move forward for RSPO certification. We thank you for your time and attention and would like to reiterate that the PT. Ibris Palm management and team remains committed to the pursuit of achieving sustainability and subsequent RSPO certification. Please kindly forward this communication to the Board of Governors and members of the Complaints Panel.