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NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 1 OF 22 PAGES

Sustainability Information Document

Noble Plantations Pte Ltd.

September 2018


1. BACKGROUND INFORMATION ON NOBLE PLANTATIONS

Noble Plantations Pte Ltd (further referred to as Noble Plantations) is an oil palm grower and has been a

member of the Roundtable on Sustainable Palm Oil (RSPO) since October 31, 2011.

Noble Plantations entered into the palm oil business as a grower in June 2010 by acquiring a controlling

share in PT Henrison Inti Persada (PT HIP) in the Sorong Regency, West Papua Province. PT HIP is

developing a plantation with a landbank of 32,546 ha, of which 12,139.33 ha have been planted, and it is

now operating one crude palm oil (CPO) mill (coordinates: 131°33’41” E - 01°04’32” S). We do not

purchase fresh fruit bunches (FFB) from independent suppliers.

During 2013, Noble Plantations began development at PT Pusaka Agro Lestari (PT PAL) in the Mimika

Regency, in Papua Province. PT PAL has a landbank of 38,159.60 ha of which 7,155.93 ha has been

planted. A CPO mill is planned for completion by mid-2019.

The total landbank of Noble Plantations is more than 70,705.90 ha (ACOP, 2017), with a total planted area

of 19,259.26 ha (Table 1). This includes the smallholder scheme with an area of 2,236.13 ha. These two

locations are the only landholdings of Noble Plantations. The location of the concessions is publicly

available and shown in the Summary Reports of the SEIA and HCV Assessments (see section Relevant

Documents).

Table 1. Landbank of Noble Plantations for period of first half of 2018

No Remark PT HIP PT PAL Total

1. Total landbank/area controlled/managed ha 32,546.30 38,159.60 70,705.90

2. Landbank or planted area on peatland ha 0.00 0.00 0.00

3. Land title/user right (HGU/Hak Guna Usaha) ha 22,751.52 35,759.00 58,510.52

4. Land title/building right

(HGB/Hak Guna Bangunan)

ha 20.00 0.00 20.00

5. Number of estate/management units 4 3 7

6. Land controlled/managed for oil palm cultivation: ha 12,095.81 6,384.34 18,480.15

1. Oil palm planted area ha 11,241.14 5,817.99 17,059.13

2. Nursery ha 36.01 0.55 36.56

3. Area for infrastructure ha 818.66 565 .80 1,384.46

a. Mill (inside HGB) ha 5.23 0.00 5.23

b. Housing, offices, warehouses ha 48.35 18.46 66.80

c. Road. ha 770.31 547.35 1,317.66

7. Conservation area inside HGU ha 3,859.02 7,629.81 11,488.83

8. Unplanted (areas designated for future planting) ha 6,796.69 21,744.85 28,541.54

9. Plasma/scheme smallholders planted area ha 898.19 1,337.94 2,236.13

10. Land designated and managed as HCV areas

(from HCV assessment)

ha 4,696.98 3,941.81 8,638.70

11. Conservation set-aside area, including HCV area ha 1,832.24 3,837.00 5,669.24

12. Total HVC area ha 6,529.13 7,778.81 14,307.94


As a member of the RSPO, we have followed the RSPO New Planting Procedure (NPP) at both sites. This

process requires a High Conservation Value (HCV) assessment and a Social Impact Assessment (SIA) to be

conducted and a management plan implemented. Assessments are done by certified RSPO assessors,

whose work is then reviewed by an independent certifying body compliant with RSPO requirements. HCV

areas are not developed and are protected by our in house conservation teams.

Our objective is to have all our operations RSPO certified by 2020.

At Noble Plantations we understand that conservation is a practical matter and can be achieved only by a

permanently established and integrated programme, which is an integral part of our plantation

operations. We not only protect the habitats that are threatened by human activities, but restore those

that have been damaged.

For this purpose we have Conservation Departments in both PT HIP and PT PAL, which work with local

people in conserving the forest, and ensuring that the harvest of forest products in the areas concerned

remains sustainable.

2. SUSTAINABILITY POLICY AND LEADERSHIP

2.1 Organization

Sustainability is the responsibility of General Manager and Manager for Compliance and

Sustainability.

2.2 Membership to improve sustainability

Noble Group has been a signatory to the United Nation Global Compact (UNGC), since 2010,

although Noble Group is not yet a member.

Noble Group publishes annual Sustainability Reports in accordance with the Global Reporting

Initiative (GRI). Companies that are listed on the Singapore Stock Exchange are encouraged to

publish an annual Sustainability Report, though it is not mandatory. A Sustainability Report for

2018 has been published with a section about palm oil on pages 24 and 25.

2.3 Activities with academic institutions and government to improve palm oil sustainability

We are aware that responsible management of the environment, social responsibility, and good

corporate governance, are increasingly important as considerations when professional asset

managers are making investment decisions.

What is more important is that these things are just the right things to do.

A Social Impact Assessment (SIA) was done by Bogor Agricultural Institute (Institute Pertanian

Bogor, IPB) in December 2010, as is required by RSPO. In managing social impacts our activities

are focused on four main issues: solving problems related to the use of Native Customary Land

for the developing the plantation, Corporate Social Responsibility (CSR), and development of oil

palm smallholdings (plasma) for local people, and communication with stakeholders.


In January 2012 PT HIP cooperated with the University of Indonesia on the Assessment of

Social Culture in PT HIP. This assessment included an analysis of various problems that had

arisen with surrounding communities, an ethnographic description of communities,

identification of community needs, and what social programmes could be implemented.

PT HIP is participating in the program of the Ministry of Natural Environment and Forestry

called "Proper". The full title of this program is “Program Penilaian Peringkat Kinerja

Perusahaan dalam Pengelolaan Lingkungan” which means “ Program for Evaluating Company

Achievement in Environmental Management”, which has been running for several years. It is

intended to maintain our commitment to environmental awareness and responsible

environmental management, as is required by the ISPO and RSPO certification systems.

2.4 Traceability to Plantation Level

PT HIP uses the Identity Preserved (IP) supply chain model. The mill uses fruit bunches only

from plantations that are owned by the company and will be certified by RSPO (Table 2). All of

the fruit bunches are traceable to plantation level for all operations, including smallholdings

which are managed as an integral part of the group operations. This makes it possible to certify

the group and the smallholdings at the same time.

The mill at PT PAL is still in under construction, and will start operating in 2019. PT PAL has a

time-bound commitment by which 100% of FFB will be traceable as at PT HIP.

Table 2. Time-bound plan to achieve 100% traceability to plantation level

Oil Palm Company Location Target Remark

PT Henrison Inti Persada West Papua, Indonesia 2012 Already 100% traceable since

the mill started operating,

because the mill uses FFB only

from plantations that are

owned by the company.

PT Pusaka Agro Lestari Papua,

Indonesia

2020 Awaiting completion

of construction

3 ENVIRONMENTAL ASPECTS

3.1 Deforestation

Since November 200 no new plantings have replaced primary forest, and since July 2010 new

plantings have not replaced any area required to maintain or enhance High Conservation

Values (HCVs) (see section Relevant Documents, SOP New Non-Compliant Land Clearance

Guidelines, Doc. No. HIP-SOP-COM-1603-001, Procedure 6.3 (p.5)). This applies also to all of

our smallholdings.

Noble Plantations announced proposed new planting, in accordance with the RSPO New

Planting Procedure (NPP); at PT HIP dated 21 May 2014, and at PT PAL dated 14 February

2012. Based on the NPP, Noble Plantations will not clear areas for new planting that have been

identified as areas of High Conservation Value (HCV).


Noble Plantations has a Conservation Department responsible for establishing and monitoring

conservation areas inside and outside of estate boundaries, to detect encroachment or

disturbance by local people or by workers. The department is also responsible for informing

local people about the value of conservation, including that they are not allowed disturb

conservation areas by, for example, growing crops, clearing vegetation, erecting buildings, and

hunting (see Relevant Document, SOP Conservation and Environmental Guidelines, in the

Responsibilities).

The Security Department and the Conservation Department conduct routine patrols and

monitoring to make sure that there is no undesirable or illegal activity in areas of High

Conservation Value.

There is a GIS Department that serves both PT HIP and PT PAL. Images from satellites and

drones are used to create detailed maps, which are used in the operational management of the

oil palm estates and the conservation areas. With the drones we can also monitor the

occurrence of fires and disturbance of the forest in the conservation areas.

3.2 Biodiversity

The landscape approach has been used to ensure biodiversity is protected. Conservation and

environmental protection include:

a. Conservation of habitats or ecosystems that contain representative communities of

plants and animals, especially those that are rare, threatened or endangered (RTE).

b. Conservation of forest areas that have high carbon stock, to minimize the release of

greenhouse gases that might be caused by conversion to oil palm.

Noble Plantations is committed to not endangering species of conservation concern, with

reference to international and national system of classification as stated in the executive

summary of HCV assessment. Both plant and animal species are clasified based upon the

Regulation of Ministry of Environmental and Forestry No.

P.20/MenLHK/Setjen/Kum.1/6/2018, CITES and Red List of IUCN.

Our conservation efforts ensure that not only we meet certification standards for sustainable

palm oil production, but also create long-term structural improvements to lessen our

environmental impact.

3.3 Conservation of High Conservation Value Areas

New plantings are planned and managed according to the New Planting Procedures (NPP) of

RSPO, including the identification of areas of High Conservation Value (HCV) so that they can be

maintained, and enhanced (see section Relevant Documents, SOP New Non-Compliant Land

Clearance Guidelines).


At PT HIP, a comprehensive HCV assessment was done in July 2010, and management and

monitoring plans were drawn up for the whole concession area, with stakeholder consultation,

before land was cleared for planting. This is a requirement of both RSPO Principles & Criteria

(P&C) and the Standard Operating Procedure (SOP) of Noble Plantations. At PT PAL an

assessment was done in September 2011.

Noble Plantations uses HCV assessors who are licensed by the HCV Resource Network’s

Assessor Licensing Scheme (ALS). The HCV assessments for PT HIP and PT PAL were done by

Dr Nyoto Santoso from the Bogor Agricultural Institute (Institute Pertanian Bogor, IPB). He was

selected from the RSPO list of approved assessors, and has been a Licensed assessor since 23

December 2014, with License number ALS14013NS.

The report on HCV Assessment at PT HIP was peer reviewed by Rachmad Hermawan as an

Independent Consultant, in December 2010. For PT PAL the same person did the peer review in

October 2011. The reviews showed that there was room for improvement on some minor

points, and these have since been attended to.

The total land area that has been set aside for forest and HCV conservation is 14,307.94 ha (PT

HIP 6,529.13 ha and PT PAL 7,778.81 ha). The HCV assessments performed after November

2005 are publicly available on the RSPO website. Please see:

https://www.rspo.org/certification/new-planting-procedures/public-consultations/noble-

plantation-pt-henrison-inti-persada

• RSPO Notification of Proposed New Planting

• Summary Report of Planning and Management

• Summary Report of SEIA and HCV Assessment

http://www.rspo.org/certification/new-planting-procedures/public-consultations/noble-

plantation-pte-ltd-pt-pusaka-agro-lestari-papua-province-indonesia-new-planting-assessment

• RSPO Notification of New Planting_PT PAL_December 2011

• RSPO NPP_SEIA_HCV Summary Report_PT PAL_December 2011

• RSPO NPP_Summary of Management Plan_PT PAL_December 2011

Management plans have been compiled for preservation and enhancement of HCV areas

identified by the assessments (see section Relevant Documents, SOP New Non-Compliant

Land Clearance Guidelines).

The aforementioned statements also apply to all of our smallholders.

Since January 2016, all High Conservation Value (HCV) assessments should be reviewed by the

HCV ALS Quality Panel (HCVRN) who will decide if the assessment is satisfactory. At that time

Noble Plantations had already uploaded the notification of proposed new plantings, and there

were no objections (for PT HIP dated 21 May 2014, and for PT PAL dated 14 February 2012). In

these cases the requirement as specified in January 2016 does not apply.


3.4 Maintenance of High Carbon Stock

Noble Plantations is commited to responsible development of new plantings in compliance with

all RSPO Principles and Criteria, including 5.6 and 7.8, concerning carbon stocks and

greenhouse gases, and the identification and estimation major potential sources of emissions.

We use the High Carbon Stock (HCS) approach, as defined by the HCS Approach Toolkit, for all

landholdings, and we refrain from developing HCS areas (see section Relevant Documents,

SOP Conservation and Environment Guidelines).

An independent assessment of carbon stock has been done by Noble Plantations, using methods

that are approved by RSPO (Carbon Assessment Tool for New Oil Palm Plantings, RSPO,

December 2012),

The Carbon Stock Assessment for PT Pusaka Agro Lestari was done in November 2013 and the

Study of Carbon Stock for PT Henrison Inti Persada was done in July 2014. The average carbon

stock is 58.69 ton C per hectare at PT HIP, and 68.08 ton C per hectare at PT PAL.

To ensure that operational practices adhere to the RSPO P&C, we work closely with

internationally renowned experts to assess and map the change in land use and land cover.

3.5 No Planting on Peat Soils

No new development takes place on peat soils including all of our smallholdings (see section

Relevant Documents, SOP Conservation and Environment Guidelines). As mentioned

previously in the section concerning landbank (Table 1), Noble Plantations does not have peat

soil.

The Ministry of Natural Resources and Forestry has provided letters to Noble Plantations

stating that based on Technical Review there is no indication of peat soil or primary forest in

the oil palm plantation area:

• PT Pusaka Agro Lestari, Letter No. S.174/BPKH.X-3/2017, dated 10 August 2017.

• PT Henrison Inti Persada, Letter No. S.156/BPKH.XVII-1/2017, dated 18 September 2017.

PT HIP has a Sustainability Policy, dated 09 September 2014, that states that Sustainable

Agricultural Best Management Practices (BMPs) will be used to achieve optimal profitability

while providing satisfaction to its customers, and without damaging the environment.

3.6 Zero Burning, Fire Management and Monitoring

Noble Plantations is committed to a strict policy of zero burning during land clearing for new

planting or replanting (see section Relevant Documents, SOP New Non-Compliant Land

Clearance Guidelines). This policy applies also to all of our smallholdings.


The companies have established Firefighting Teams which have followed the Fire-fighting

Training Classes D and C, to comply with the government regulations. In both the estates and

the mill, training in firefighting has been done with simulated fires, so that if a fire occurs the

staff will know how to extinguish it. Equipment and procedures for fire prevention are being

prepared.

According to weather data (rainfall and rain days), there is rain somewhere in the plantation

almost every day and the average rainfall during the past four years is 3,040 mm/year, with

180 rain days. The fire risk is low, and there have been no fires both in estate and mill.

We submit a report “Efforts to Avoid and to Control Fires” (Laporan Upaya Pencegahan dan

Penanggulangan Kebakaran) every year to the local authorities as a part of our compliance with

applicable laws and regulations.

Noble Plantations, as a member of RSPO, has submitted the RSPO Internal Hotspot & Fire

Monitoring Fire Report to the RSPO Secretariat ([email protected]), although there has not

been any fire.

3.7 Reduction of Greenhouse Gas Emissions

We have identified all sources of greenhouse gas (GHG) emissions from our operations in

accordance with RSPO P&C 5.6 and 7.8, and are committed to reduce these emissions. To

maintain our commitment in relation to land use change, we avoid areas with high carbon stock

and have a zero burning policy. This applies to all of our smallholdings, which are managed as

an integral part of the group operations.

Noble Plantation has calculated GHG emissions from land use change for 2017 is 201,737.50

tCO2e/ year (Table 3). The total amount of GHG emmisions stands at 121,420.39 tCO2e/year.

Methodology used to calculate GHG emissions is RSPO Palm GHG Calculator version 3.0.1, dated

30 October 2016.

Table 3. Greenhouse gas emissions of Noble Plantations (t CO2e)

Source of Emissions 2017 2016

Land use change 201,737 300,226

Crop sequestration -113,125 -167,612

Fertilizer 19,695 1,530

N2O 14,109 1,651

Field fuel 1,113 3,691

Peat 0 0

Conservation credit -16,322 -28,831

POME 13,584 13,351

Mill fuel 629 961

Credit (excess electricity exported) -1 -16

Total emissions 121,420 124,953


3.8 Water Mangement Plan

We are developing a comprehensive “Sustainable Water Management Plan” for our operations

in order to fulfil the requirements of the RSPO P&C 4.4 and specifically for 4.4.1. We are

committed to improving both water supply and water quality in our programme.

Scope

• Protection of water sources and wetlands, including securing and maintaining appropriate

riparian and other buffer zones.

• Monitoring of effluent, and compliance with legal requirements.

• Monitoring of mill water use per ton of FFB.

3.8.1 Monitoring of mill water use per ton of FFB (Fresh Fruit Bunches)

PT HIP has established time-bound commitment to improve water use per tonne of FFB

processed. The use of water by the mill to process FFB has been recorded since 2014. The

target is 1 tonne of water per tonne FFB, so all values for the past three years are within

the target (Table 4).

Table 4. Use of water for processing FFB

2016 2017 First half 2018

Water consumption (metric ton) 52,268 50,254 20,842

FFB processed (ton) 93,127 97,097 56,509

Water used/tonne FFB processed 0.56 0.52 0,37

3.8.2 Protection of water sources and wetlands

Areas of High Conservation Value (HCV) have been assessed, and management and

monitoring plans have been made for all newly planted areas. Forested buffer zones next

to the rivers (riparian zones) are maintained. The width of the riparian zones is as follows:

Width of river

Width of Riparian Zone

(on each side)

>15 m 200 m

15 m – 5 m 100 m

< 5 m 50 m

(see Relevant Document, SOP New Non-Compliant Land Clearance Guidelines).

Water sources are protected by prohibiting the spraying of chemicals and use of fertilizers

in the riparian zones (SOP Conservation and Environmental Guidelines). The Conservation

Department has implemented enrichment planting of forest trees in the riparian zones,

and does regular inspections to ensure that the riparian zones remain protected. The

palms depend on natural rainfall for their water supply, except in the nursery where a

sprinkler irrigation system is used.


In monitoring water quality for domestic use, we refer to the Government Regulation

Number 82 of 2001 on Water Quality Management and Water Pollution Control (Water

Class of IV). In February 16-17, 2018 we submitted 14 samples of domestic water, as used

by employees, to an accredited laboratory to be tested for quality. All of the samples met

the standard as specified in Government regulations (Table 5).

Table 5. Water Quality in Company Housing, February 2018

No. Measurement Unit Standard Sample Result

I. Microbiology:

1. Fecal Coliform MPN/100 mL 100 7.12

2. Total Coliform MPN/100 mL 1,000 114

II. Chemical:

1. pH mg/L 6-9 7.9

2. BOD mg/L 12 11.6

3. COD mg/L 100 33.6

II. Chemical Inorganic:

1. Arsenic (As) mg/L 0.05 0.0012

2. Fluoride (F) mg/L 0.50 0.38

3. Chromium (Cr) mg/L 0.05 0.0042

4. Cadmium (Cd) mg/L 0.01 0.0063

5. Nitrite (NO2) mg/L 0.06 0.007

6. Nitrate (NO3) mg/L 10 1.54

7. Cyanide (CN) mg/L 0.02 0.0035

8. Selenium (Se) mg/L 0.01 0.0084

3.8.3 Water for domestic use

The two main water sources are rivers and rain. Water from rivers is stored in reservoirs

for sediment settling before being distributed to houses. Water consumption for domestic

use is not metered because the volume is small compared that used in the mill for

processing of fruit. Houses have drums and tanks for water storage. If there is insufficient

rain, the Company provides fresh water from the local water supply company (PDAM,

Perusahaan Daerah Air Minum).


3.8.4 Monitoring of mill effluent

Palm Oil Mill Effluent (POME) is treated in aerobic and anaerobic ponds, to ensure that

Biological Oxygen Demand (BOD) and Chemical Oxygen Demand (COD) levels are safe

before being discharged to the water body. The quality of river water is monitored by

taking samples for analysis every month, from both downstream and upstream of the

discharge point.

The quality of mill effluent is monitored monthly in cooperation with an accredited

laboratory (PT Unilab - Jakarta), with test results meeting all standards as set by the

regulation Peraturan Menteri Negara Lingkungan Hidup No. 5/2014 Appendix III (Table 6).

Table 6. Analysis of palm oil mill effluent (POME) for August & September 2018

Measurement Units Standard

Result

August September

BOD5 mg/L 100 82 61

COD mg/L 350 257 243

TSS mg/L 250 97 34

Oil and Fat mg/L 25 2 4

Nitrogen Total (as N) mg/L 50 3 18

pH (26oC) 6 - 9 8 8

Date of test on 24 July – 07 August, 2018 and 7-25 September, 2018

The Company has permits for mill effluent from the Regent of Sorong (Izin Pembuangan

Limbah Cair kepada PT Henrison Inti Persada). Monitoring of POME is carried out regularly

by external and internal parties and reported to the Environmental Agency (Dinas

Lingkungan Hidup Kabupaten Sorong) every three months.

3.9 Pesticides and Fertilizer

To fulfill the requirements of RSPO P&C 4.6, Noble Plantations is committed to minimize the use

of chemicals, including pesticides and chemical fertilizers, and has a time-bound plan for

phasing out their use (Tables 7, 8 and 9). Noble Plantations has committed to the following:

• Pesticides are used in ways that do not endanger health or the environment.

• Use of only approved and registered pesticides permitted by the relevant authorities

(Buku Pestisida Pertanian dan Kehutanan, Kementerian Pertanian Republik Indonesia).

• No use of chemicals that are categorized as World Health Organization Class 1A or 1B,

or listed by the Stockholm or Rotterdam Conventions, and paraquat.


Table 7. The time-bound plan of agrochemical use

Agrochemical Year Status

No use of paraquat 2018 Will no longer be used,

after existing stock finished

No use of chemical are categorized

as World Health Organisation (WHO)

Class 1A and 1B

2018 Stopped

No use of chemicals listed

under the Stockholm and

Rotterdam Conventions

2018 Stopped

Table 8. Pesticides currently (first half/January-June 2018) in use

Pesticide name Active ingredient UoM Total use Classified

WHO Stockholm* Govn. Reg.

Ken-Amine 865 SL 2,4-D dimethyl amine L 552.00 II No Registered

Mega 9 865 SL 2,4-D dimethyl amine L 299.50 II No Registered

Amiron – M20 WG Metsulfuron-methyl kg 308.50 U No Registered

Tiara 20 WDG Metsulfuron-methyl kg 98.00 U No Registered

Kenlly 20 WG Metsulfuron-methyl L 111.75 U No Registered

Fascinate 150 SL Glufosinate-ammonium L 2,166.80 II No Registered

Farm Up 480 SL Glyphosate-IPA L 5,535.75 III No Registered

Wintag 490 SL Glyphosate-IPA L 1,789.00 III No Registered

Kenlon 480 EC Triclopyr L 1,441.55 II No Registered

Kentec 276 SL Paraquat dichloride L 336.50 II No Limited

Remark:

1. WHO classified, Ia = Extremely hazardous; IB = Highly hazardous; II =Moderately hazardous; III =

slightly hazardous; U = Unlikely to present acute hazard in normal use.

2. * = No use of pesticides listed under the Stockholm and Rotterdam Convention.

3. Govn. Reg. acronym from Government Regulation of the Republic of Indonesia which is Peraturan

Menteri Pertanian No. 39/Permentan/SR.330/7/2015 tentang Pendaftaran Pestisida.

4. Pesticide with trade mark Kentec 276 SL contain active ingredients of Paraquat dichloride. Stock

in store are 44 liters and will no use longer.


Table 9. Fertilizer currently in use (tons)

No Type of fertilizer 2017 First half 2018

1. Urea 109.70 2,100.00

2. Compound NPKMg 12.12.17.2 17,834.50 607,400.00

3. Compound NPKMg 15.15.6.4 32.00 0.00

4. Compound NPKMg 12.6.22.3 36.70 0.00

5. Rock Phospate 43.10 11,400.00

6. MOP 982.00 0.00

7. Borate 74.60 0.00

8. Kieserite 82.10 0.00

3.10 Integrated Pest Management (IPM)

The primary aim of pest management should be not to eradicate all pest organisms, but to

manage pests and diseases that may negatively affect production of plantation crops so that

they remain at a level that is under an economically and environmentally damaging threshold.

Pesticides should be managed to avoid their migration into off-site land or water environments

by establishing their use as part of an Integrated Pest Management (IPM) strategy documented

in a Pesticide Management Plan (PMP).

Noble Plantations is developing an Integrated Pest Management system (IPM) which fulfills the

requirements of RSPO P&C 4.5.1. The Integrated Pest Management system includes cultural,

biological, and physical methods to minimize the use of chemicals. The programme includes:

• the use of only those chemicals that are allowed by Government regulations.

• confirmation of whether chemicals are listed under the Stockholm Convention and the

WHO classification as being in Class 1A and 1B.

• chemicals may be used, with control over the kind of chemical, the dose, the area and

rotation.

• an Early Warning System (EWS) that includes a census for leaf-eating caterpillars, rats,

ganoderma disease, rhinoceros beetles, and others.

• biological control by cultivating beneficial plants such as Turnera subulata and

Antigonon leptopus, which act as hosts to parasitic wasps which can keep insect pests

under control.

• installation of nesting boxes are provided for barn owls to help control rats.


4. SOCIAL ASPECTS

4.1 Human Rights

Noble is a signatory to and fully supports the UN Global Compact. This is a strategic policy

initiative for businesses that are committed to aligning their operations and strategies with ten

universally accepted principles. These include principles relating to human rights (freedom of

association and effective recognition of the right to collective bargaining, elimination of forced

and compulsory labour and abolition of child labour); to environmental challenges and

responsibilities; and to Anti-Corruption measures (see Related Document, Code of Business

Conduct and Guidelines - Noble Group, point 5.e. page 3).

Noble seeks to identify and manage human rights impacts within our spheres of influence and

activities in line with the following policy aims:

4.1.1 Employees

We are committed to respecting the human rights of our employees as established in the

Fundamental ILO Conventions or Free and Fair Labour Principles. These include:

• Providing equal opportunities and treatment to obtain employment.

• Pay and conditions for employees and contract workers must always meet at least

legal or industry minimum standards.

• We respect the rights of all personnel to form and join trade unions of their choice

and to bargain collectively. Children under the age of 18 years are not employed or

exploited.

• We prohibit any form of discrimination based on race, caste, national origin, religion,

disability, gender, sexual orientation, union membership, political affiliation, or age.

• We prevent sexual and all other forms of harassment and violence in the work place,

while protecting the reproductive rights of all, with no form of forced or trafficked

labour to be used.

The aforementioned policy apply to all of our smallholdings.

4.1.2 Suppliers and Contractors

To establish and maintain appropriate procedures to evaluate and select major suppliers

and contractors, based on our human rights and sustainability policies, and to monitor

their performance where appropriate. We are moving towards application of the

Fundamental ILO Conventions or Free and Fair Labor Principles through engagement and

collaboration where necessary.


4.1.3 Local Communities

We respect the cultures, customs and values of the people in communities in which we

operate.

We recognize and respect all legitimate tenure right holders and their rights as stated in

FAO Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries

and Forests in the Context of National Food Security (2012).

We endeavour to contribute, within the scope of our capabilities, to promote the

fulfillment of human rights through improving economic conditions (including to ensure

food security for local communities), environmental and social conditions, and serve as a

positive influence in communities in which we operate. We have open dialogue with

stakeholders and participate in community engagement activities.

4.1.4 Society

We participate where appropriate in public affairs in a non-partisan and responsible way

to promote internationally recognized human rights.

We are committed to play a positive role, within our spheres of influence, in capacity-

building for the realization of human rights within countries of operation.

We promote the realization of environmental sustainability and development through our

core business and through our participation in other multi-stakeholder activities where

appropriate.

We will uphold the highest standards in business ethics and integrity and where

appropriate support efforts of national and international authorities to establish and

enforce high ethical standards for all businesses.

4.2 Undertaking of Free, Prior and Informed Consent (FPIC)

We acknowledge our responsibility to uphold the right of indigenous peoples to their

traditional lands through undertaking Free, Prior and Informed Consent (FPIC), which forms

the foundation of achieving social and environmental sustainability. FPIC is the right of

indigenous peoples and other local communities to give or to withhold their consent to any

project affecting their lands, livelihoods and environment.

We are committed to obtain the FPIC in advance of any development, and to follow

international best practices as required by:

• UN Declaration on the Rights of Indigenous Peoples (2007): "Right to distinctive

relationship with land; right to own, use, develop and control their lands, territories and

other resources."


• ILO Convention 169 (1989) on Indigenous and Tribal Peoples: "Respect and safeguard

rights to lands and natural resources traditionally occupied and used; respect for customs

of inheritance; no forced removals; compensation for loss and injury."

FPIC Flowchart:

Scoping

Pre-FPIC, Socialization to the local communities/indigenous people who have land

Identify community’s self-chosen representative institutions

The community agrees, and will consider a plantation

Community meetings verify & validate mapping and land tenure

Negotiation

Obtain agreement endorsed by government/ where communities are willing to

enter agreement in written and any other agreed form

Implement agreement:

� Participatory monitoring

� Establish plantation and all associated benefits

� Periodic multi-stakeholders evaluation of agreement implementation

� Resolve any emerging dispute and grievances

4.3 Employees

The number of employees in all operations (working in the field and in the offices) in the first

half 2018 was 3,016 (Table 10). Percentage of temporary employees was 16 % (482 workers)

while the percentage of female employees was 31 % (943 workers).

Table 10. Data Manpower by Contract and Gender, First half 2018

PT HIP PT PAL

Total F M Total F M Total

Permanent 532 1,179 1,711 274 549 823 2,534

Temporary 23 163 186 114 182 296 482

Total 555 1,342 1,897 388 731 1,119 3,016


Pay and conditions for employees and for contract workers always meets at least the legal

minimum standards, and are sufficient to provide for decent living (Table 11).

Table 11. Minimum Wages, 2015-2018 (IDR per month, for minimum 13 months)

Year

2015 2016 2017 2018

PT. Henrison Inti Persada

(West Papua Province) 2,166,125 2,343,500 2,422,700 2,667,000

PT. Pusaka Agro Lestari

(Papua Province) 2,244,000 2,487,474 2,663,545 3,000,000

4.4 Occupational, Health and Safety

Health and safety at work of all our employees is paramount, as stated in our Environmental,

Health and Safety Policy. It is our policy to provide and maintain a working environment for our

employees that is, so far as is reasonably practicable, safe and adequate, without risks to health

at work.

Employees include permanent, part-time and temporary staff. The sustainability of our assets

and the environment in which we operate is a key consideration in how we do business now

and in the future. The frequency and severity of accidents is recorded and reported routinely

(Table 12).

Table 12. Frequency and Severity of Accidents for First Half 2018

Total work hours, all Departements (hours) 1,487,548.80

Total accidents needing first aid 0

Total work accident handled by clinic 13

Total work accident reported to BPJS TK 0

Time lost because of accidents (days) 21

Fatalities 0

FR - (Frequency Rate) * 8.74

SR - (Severity Rate) ** 14.12

* Frequency = (Total accidents x 1,000,000)/work hours

** Severity = (Time lost x 1,000,000)/ work hours


4.5 Personal Protection Equipment and Pesticide Training

The Company provides personal protective equipment (PPE) appropriately according to the

results of a hazard identification survey for every work place. Training in the use of pesticides

has been given, including in the use of limited pesticides, and the calibration of spraying

equipment.

4.6 Certification

4.6.1 RSPO

Noble Plantations is working towards obtaining RSPO certification for the mill and supply

base by the end of 2020. PT HIP did pre-assessment for RSPO certification on 13-17

December, 2016. The Land Use Change Analysis (LUCA) has been done and approved by

RSPO. We are now working on the Remediation and Compensation Plan.

4.6.2 ISPO (Indonesian Sustainable Palm Oil)

PT HIP has obtain ISPO Certification from the ISPO Commission, Ministry of Agriculture,

on April 2017. The certificate was presented by the Director General of Plantations at an

International Conference on ISPO in Jakarta.

4.7 Smallholders

Plantation Companies that have a business license for an oil palm plantation are required by

law to provide smallholdings (referred to as “Plasma”) for the local community with an area of

at least 20% of the total planted area that is managed by the company (Law Number 39 of

2014, Article 58).


Our smallholders are grouped into cooperatives, with business use licenses (HGU) in the names

of the cooperatives (Tables 13 and 14). The smallholdings are managed as an integral part of

the group operations. The companies organize various programme for the smallholders (Table

15). All of smallholders (100%) are involved in programmes.

Table 13. Smallholder Cooperatives at PT HIP, period first half 2018

Smallholder

Cooperative

Members

(households)

Area of HGU

(ha)

Area already planted

(ha)

Pawbili Klagilim 46 182.34 217.02

Klagima Sinifagu 55 495.62 497.53

Klimagasi Sinagi 39 305.60 183.63

HIP Total 140 983.56 898.19

1st Phase: 140 Members, 2nd Phase: - (in process)

Table 14. Smallholder Cooperatives at PT PAL, period first half 2018

Smallholder

Cooperative

Members

(household)

Area of HGU

(ha)

Area already planted

(ha)

Buh Bau Yamane 325 1,556.38 717.47

Owaipuwe 84 337.29 306.70

Komorawe Mitra Pusaka* 415 2,137.47 408.84

Makime* 225 1,235.87 268.54

PAL Total 1.049 5,267** 1.701.55

1st Phase: 458 Members, 2nd Phase: 561 Members (in process)

* For Komorawe 102 members and Makime 31 members still have to be registered

** PAL plasma HGU includes 824, 10 ha conservation area.

The companies organise various programmes for the smallholders. All smallholders (100%) are

involved in programmes.

Table 15. Programmes organized by the companies for the smallholders, Year 2018

1. Programmes

Achieve legal land registration, through land title/user right (HGU)

Strengthen market access for smallholders (e.g. fair pricing mechanisms)

Share knowledge to help smallholders to increase their yields and profitability

Provide technical assistance to smallholders on Best Management Practices to

support smallholders’ capacity and farm productivity

Support programmes involve supporting increased yields and productivity; providing

thorough training on good agricultural practices, and financial management;

supporting cooperative development; and supporting certification


2. Implementation of programmes

Obtain HGU Certificate (land titles/user right).

Establishment and renewal of the Cooperative as a legal body.

Socialization in development of smallholders plantation

Arranging the annual member’s meeting for Cooperatives

Attend the FFB price meeting every month in Plantation Office, West Papua

Socialization of FFB price, revenue and costs of smallholders to the Cooperative every

month

Giving smallholders income to the Cooperative (money from FFB price)

Visit the smallholdings with the members of the Cooperatives to monitor their

progress.

Give direction to the smallholders to help in increase the yields and profitability

Arrange Comparative Study for the members of the Cooperatives

The boundaries of the smallholdings have been made available to the RSPO as part of estate

maps, but not all may be publicly available because of the confidentiality constraints.

4.8 Suppliers

In line with our Sustainability Policy, dated September 9, 2014, we give priority to local

suppliers. This includes ensuring compliance with safety policy, quality, and social aspects

during the process of selectiing contractors and suppliers.

The Contractor Management System allows for Exceptions From Pre-Qualification; in special

circumstances the contractor is permitted to start or continue the project with a pre-

qualification exemption letter from the local Manager or other appointed person. An exception

letter must specify particular safety procedures which the contractor must follow. A letter of

exemption is valid for a maximum of only one year.

4.9 Grievances and Complaints System for Relevant Stakeholders

There is a mutually agreed and documented system for dealing with complaints and grievances,

which is implemented and accepted by all affected parties. This is in accordance with RSPO P&C

6.3. The purpose of the system is to resolve disputes in an effective, timely and appropriate

manner, ensuring anonymity of complainants and whistleblowers, where requested, as long as

that information is supported with adequate initial evidence. It is open to all affected parties.


If any employee reasonably believes that some policy, practice, or activity of Noble is in

violation of law, or the spirit or intent or ethics of the law, a written complaint must be

immediately filed. Grievances from employees can be submitted by:

• Direct submission, whereby employees, either individually or in groups convey their

grievances, face to face, to their direct supervisor, or higher, or directly to the HR

Department or to another specific department by filling out a Grievance Form. Facts

and evidence are attached to the Grievance Form. It is to be analyzed immediately,

clarified, documented and answered.

• Indirect submission, whereby employees either individually or in groups convey their

grievances through a trade union or bipartite representative, or through a suggestion

box.

Grievances must be processed as soon as possible by consultation. The Company and

employees shall endeavor to ensure that the problem does not become an industrial dispute or

result in termination of employment.

Noble will not retaliate against employees who disclose or threaten to disclose to a supervisor

or a public body, any activity, policy, or practice of Noble that the employee reasonably believes

is in violation of a law, or a rule, or regulation mandated pursuant to law or is in violation of a

clear mandate of public policy concerning the health, safety, welfare, or protection of the

environment.

Noble has a procedure to provide adequate information to relevant stakeholders on

environmental, social and legal issues relevant to RSPO and ISPO criteria (RSPO P&C 1). Noble

recognizes the importance of open and transparent methods for communication and

consultation between the Company, local communities and other affected or interested parties.

External stakeholders, especially indigenous people, who wish to submit a complaint or

grievance can make contact by telephone, and letter (email/facsimile), or directly meet with the

Company representative, as a group or individually. They may fill out a Form of Communication

and Consultation that shows the kind of complaint, the date, and how the problem arose, with

action taken and recommendation for follow-up. The Company will respond in a timely manner.

Noble will completely resolve any problems that arise to maintain a good relationship between

all parties. All communication are recorded in a logbook.


Relevant Documents

ACOP, 2014 (Approved Code Of Practice, 2014)

https://www.rspo.org/file/acop2014b/submissions/noble%20plantations%20pte%20ltd-ACOP2014b.pdf

ACOP, 2015 (Approved Code Of Practice, 2015)

https://www.rspo.org/file/acop2015/submissions/noble%20plantations%20pt.e%20ltd-ACOP2015.pdf

ACOP, 2016

https://www.rspo.org/file/acop2016/submissions/noble%20plantations%20pte%20ltd-ACOP2016.pdf

ACOP, 2017

https://www.rspo.org/file/acop2017/submissions/noble%20plantations%20pte%20ltd-ACOP2017.pdf

Summary report of EIA, SIA, HCV assessment results in PT. HIP in 2014

http://www.rspo.org/file/HIP%20-%20R14E26%20-%20RSPO%20Summary%20Report

%20of%20Assesment.pdf

Summary report of EIA, SIA, HCV assessment results in PT. PAL in 2014

http://www.rspo.org/_v2/file/2%20%20RSPO%20NPP_SEIA_HCV%20Summary%20R

eport_PT%20PAL_December%20'11_revisi%203-final-signed.pdf

The HCV management and monitoring plans for PT. HIP

http://www.rspo.org/file/HIP%20-%20R14E26%20-%20RSPO%20Summary%20Manag

ement%20&%20Monitoring%20Plan.pdf

The HCV management and monitoring plans for PT. PAL

http://www.rspo.org/_v2/file/3%20%20RSPO%20NPP_Summary%20of%20Manageme

nt%20Plan_PT%20PAL_December%20'11_revisi%202-signed.pdf

Conservation Recap

http://www.thisisnoble.com/images/responsibility/1-NPL-D16H17_ConservationRecap_

July2016.pdf

Standard Operating Procedures (SOP) New Non-Compliant Land Clearance Guidelines, PT. HIP

http://www.thisisnoble.com/images/responsibility/2-HIP-SOP-COM-1603-001-Pedoma

nPembukaanLahanBaruNon-Compliance.pdf

Standard Operating Procedures (SOP) New Non-Compliant Land Clearance Guidelines, PT. PAL

http://www.thisisnoble.com/images/responsibility/3-PAL-D16I15_SOP-Compliant-Land-Clearing-

Guidelines.pdf

Standard Operating Procedures (SOP) Conservation and Environment Guidelines, PT. HIP

http://www.thisisnoble.com/images/responsibility/4-SOP-Conservation-Environment-G

uidelines.pdf