Roundtable on Sustainable Palm Oil Supply Chain Certification 1st Surveillance Audit Report Report no.: SCCS-ASA1-15016 Assessment against RSPO Supply Chain Certification Systems [2014]

PT PELITA AGUNG AGRINDUSTRI Kernel Crushing Plant Duri, Riau Province Indonesia Date of surveillance audit: November 24 to 25, 2015 Report prepared by: Riki Harpan (SCCS Auditor) Certification decision by: Mr. Abdul Qohar (Head of Certification Body of PT TUV Rheinland Indonesia)

Certification Body: PT TUV Rheinland Indonesia Menara Karya, 10th Floor Jl. H.R. Rasuna Said Block X-5 Kav.1-2 Jakarta 12950,Indonesia Tel: +62 21 57944579 Fax: +62 21 57944575 www.tuv.com/id

TABLE OF CONTENTS 1.0 SCOPE OF SUPPLY CHAIN CERTIFICATION ASSESSMENT

3

1.1 Executive Summary and Scope of Assessment 1.2 Certification Details 1.3 Organisational Information / Contact Person 1.4 Actual production volumes and projected outputs. 1.5 Summary of Previous Assessment

3 3 3 3 4

2.0 ASSESSMENT PROCESS

5

2.1 Certification Body 2.2 Qualifications of Lead Assessor and Assessment Team 2.3 Assessment Methodology & Agenda

5 5 6

3.0 ASSESSMENT FINDINGS

6

3.1 Description of Supply Chain Management System 6 3.2 Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions 18 3.3 Conclusion and Recommendation for RSPO Supply Chain Certification 20

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY

21

4.1 Date of Next Surveillance Visit 4.2 Acknowledgements of Internal Responsibility and Formal Sign-Off by Client

21 21

APPENDICES

22

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

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 3 of 26

1.0 SCOPE OF SUPPLY CHAIN CERTIFICATION ASSESSMENT 1.1 Executive Summary and Scope of Assessment The operations of PT Pelita Agung Agrindustri were assessed against General Module and Module C of the RSPO Supply Chain Certification (SCC) document (November 2014). The scope of the Supply Chain Certification assessment covers the implementation of the Mass Balance supply chain model of PT Pelita Agung Agrindustri (PAA). This is a single site certification. For Kernel Crushing Plant to produced CPKO, according to information stated on Foreign Investement Principle License (Surat Persetujuan Peluasan Penanaman Modal) Number 330/II/PMA/2007 dated on September 17, 2007, with capacity CPKO production 600,000 ton per year.: The surveillance audit was carried out on November 24 to 25, 2015 and a total of 4 (fours) non-conformities were found. 1.2 Certification Details The details of RSPO certification of PT Pelita Agung Agrindustri Lestari are as per the table below Table 2: RSPO Supply Chain Certification details of PT Pelita Agung Agrindustri RSPO Membership no.:

2-0043-06-000-00

RSPO Supply Chain Certificate no.:

824 503 15014

Refer to Appendix 1 for further details of the RSPO Supply Chain certificate. Date of RSPO Supply Chain certificate & 2015-02-25 to 2020-02-24 validity: e-Trace Number

PO-1000002328

1.3 Organisational Information / Contact Person Contacts details of the company are as follows: Company Name:

PT Pelita Agung Agindustri

Address:

Office: Jl. Sultan Iskandar Muda, No. 107, Kelurahan Babura, Kecamatan Medan Baru, Medan – North Sumatera – Indonesia Plant: Desa Sebangar, Kecamatan Mandau, Kabupaten Bengkalis, Riau Province – Indonesia

Contact Person:

Mr. Hardi Harmen

Position:

Management Representative

Telephone:

Office: 08126536327 Ext :061-4577777

Email:

[email protected]

1.4 Actual production volumes and projected outputs. Table 3: Certified tonnages claimed, certified tonnages purchased or sold, total and projected PK production from PT Pelita Agung Agrindustri

Table 3: Records of Certified Material Recived/ Purchased * Supplier -

RSPO Certificate Number -

Product

UTZ Number

Volume

-

-

-

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 4 of 26 Table 5: Records of Palm Oil Product Sold* Buyer

RSPO Certificate Product UTZ Number Volume Number Note: Until the last surveillance audit, PT PAA still not purchased certified material and sold certified product. *Data from [period of one year starting before February to November 2015] 1.5 Summary of Previous Assessment PT Pelita Agung Agrindustri (PT PAA) is a member of Permata Hijau Group. It is strategically located adjacent to highway of Duri - Dumai, Riau, Indonesia. It is a bulk oil facility to refined and fractionated palm oil, palm kernel oil also biodiesel process and kernel crushing plant. All production process was conducted internally; company has outsourcing process for material transportation and final product transport. The company has been implementing quality management system ISO 9001:2008, 14001, Halal and ISCC and has been providing complete standard operation manual and standard operation procedure for all strategic operation units for daily operation activities as seen on Document Company’s quality manual and other standard operation procedure documents. During certification audit it was verified that company still not purchases certified material, and sales certified product for RSPO.However the company conducted the cimulation process on October 17, 2014. There are found some non conformtities regarding company’s implementation SCC system according RSPO SCC standard November 2011 Module C (Mass Balance). The last ssessment was carried out on December 09 to 10, 2014 and no nonconformity has been established. All non-conformities has been closed before 1st surveillance audit conducted.

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 5 of 26

2.0 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 (RSPO-ACC-013 dated on June 06, 2014), ISPO (LS-P&K-005-ISPO dated on May 10, 2012), 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

Riki Harpan

Position

Qualifications / Experience

Auditor

Education: 2001 – State University of Jakarta (Universitas Negeri Jakarta) Bachelor degree majoring in Germany language education 2010 – Budi Luhur University (Universitas Budi Luhur) Magisterial Management (not passed. Trainings attended:
January 19 to 20, 2015 – Training for Auditor RSPO Supply Chain Certification Standard and Systems from David Ogg and Partners Ltd.
December 12 to 16, 2014 – Training for Auditor CoC PEFC-IFCC from Indonesian Forestry Certification Cooperation (IFCC)
September 29 until October 9, 2104 – Training for Timber Legality Verification (VLK) Auditor Mandatory from Ministry of Forestry
September 28, 2014 – The Introduction of ISO 9001:2008 Workshop with AJA Academy
November 27, 2013 – FSC/PEFC-Chain of Custody Standard with Jobst Dustersiek (Lead Auditor QM/FSC/PEFC System LGA InterCert GmbH
August 27 to 28, 2012 - FSC/PEFC-Chain of Custody Standard with Jobst Dustersiek (Lead Auditor QM/FSC/PEFC System LGA InterCert GmbH
May 17, 2012 - International Sustainability & Carbon Certification (ISCC) Sales Training with Dr. Rüdiger Meier Product responsible for sustainable Biomass and FSC TÜV Rheinland Cert GmbH at PT TUV Rheinland Indonesia
August 18 to 19, 2011 – The Awareness Training for Health, Safety and Environmental Management Systems at PT TUV Rheinland Indonesia
2011 – Training for FSC/PEFC-Chain of Custody Standard with Mr. Klaus Schatt (LGA InterCert Gemany) at PT TUV Rheinland Indonesia
2011 – Training for FSC/PEFC-Forest Management Standard with Mr. Klaus Schatt (LGA InterCert Gemany) at PT TUV Rheinland Indonesia
January 18 to 19, 2011 – Awareness Training Roundtable on Sustainable Palm Oil (RSPO) with Mrs. Dian S. Soeminta (Lead Auditor RSPO of TÜV Rheinland Indonesia) at PT TUV Rheinland Indonesia.
March 04, 2012 – Pelatihan Pengenalan SNI ISO/IEC 17021:2008 from National Standardization Agency of Indonesia (BSNI)
November 30 to December 04, 2009 – Training for Quality Management Systems (QMS) Auditor/Lead Auditor at PT TUV Rheinland Indonesia Working experience: 2007 – 2012 Technical Support Assistance acting as Document controller for Quality Management System (QMS), Forestry Certification and Agriculture Certification Department. QMF: RSPO-007c-13 rev.2

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 6 of 26 2012 – now VLO Auditor, VLK Trainee Auditor, CoC FSC Auditor, CoC PEFC-IFCC Auditor, RSPO SCCS Auditor, V-Legal Inspector and Facilitator Expert Panel I (pre-assessment) for Sustainable Forest Management (PHTL) & Chain of Custody (CoC) LEI certification.

2.3 Assessment Methodology & Agenda The supply chain 1st surveillance audit was conducted on November 24, 2015 as described in the details agenda below. The audit was carried out in accordance PT TUV Rheinland Indonesia’s RSPO audit procedure as well as the RSPO Supply Chain Certification document. An on-site assessment was conducted and the auditor carried out field and document assessments of compliance to RSPO Supply Chain Certification System requirements. 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 3 months after the closing meeting of the surveillance audit. The certification assessment agenda is as explained below. Main Assessment Agenda. Location/ Date Main sites 24 Nov 2015 KCP

Main activities - Opening meeting - Plant tour - Documentation system - Purchasing and goods in - Outsourcing activities - Sales and good out - Registration of transaction - Training - Record keeping - Claims - Complaints - Management review RSPO SCCS Module C (MB) Record keeping Processing Mass balance system Conversion ratio Yield schemes

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

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 7 of 26 5.1. Applicability of the General Chain of Custody System Requirements for the supply chain Findings: PT Pelita Agung Agrindustri (PT PAA) is a member of Permata Hijau Group. It is strategically located adjacent to highway of Duri - Dumai, Riau, Indonesia. It is a bulk oil facility to refined and fractionated palm oil, palm kernel oil also biodiesel process and kernel crushing plant. All production process was conducted internally; company has outsourcing process for material transportation and final product transport. The company have implemented the Quality Management System ISO 9001:2008 and ISO

14001:2004 therefore the general production procedure from raw material receipt until finished goods delivery have been made and implemented. The company has applied Mass Balance system ( Module C) due to the nature of incoming material from company’s supplier are Mass Balance and company’s production facilities are not sufficient to implement others supply chain model. During surveillance audit, the organization still not purchased certified material and sold certified products, however the company has demonstrate their implementation to SCCS system and relevant requirement through the simulation process. PT Pelita Agung Agrindustri is RSPO member under PHG Group (Permata Hijau Group) with membership number 2-0043-06-000-00. PT NPO has registered number PO-1000002328 in RSPO IT platform (e-Trace) for all transaction of physical shipment. Compliance status: Compliance 5.2.Supply chain model Findings: The company has applied Mass Balance system ( Module C) due to the nature of incoming material from company’s supplier are Mass Balance and company’s production facilities are not sufficient to implement others supply chain model. In the last surveillance audit, the organization still not purchased certified material and sold certified products, however the company has demonstrate their implementation to SCCS system and relevant requirement through the simulation process. Compliance status: Compliance 5.3. Documented procedures Findings: The company have implemented the Quality Management System ISO 9001:2008, therefore the general production procedure from raw material receipt until finished goods delivery have been made and implemented. PT Pelita Agung Agrindustri (PT PAA) has a set written procedures and working instruction to fulfil all requirement in the new standard RSPO SCCS year 2014. The procedures were updated and covering all activities in PT PAA including their subcontractor. The documentation are 1. No.PAA-PM-TU-01 administration of FFB receipt procedure 2. No.PAA-PM-TU-02 administration of palm kernel receipt procedure 3. No.PAA-PM-TU-03 administration of liqud commodities receipt procedure, supported with a. Security and inspection work instruction (PAA-IK-TU-08) b. Weighbridge operating work instruction (PAA-IK-TU-01) c. Material receipt work instruction (PAA-IK-PBA/TF-01) 4. No.PAA-PM-QA-01 laboratory analysis procedure, supported with a. Sampling for palm oil and derivatives work instruction (PAA-IK-PBA/QA-73) b. Sampling for palm kernel work instruction (PAA-IK-KCA/QC-06) 5. No.PAA-PM-TU-05 admininstration of product delivery 6. No.PAA-PI-BS-02 incoming material procedure 7. No.PAA-PI-BS-03 incoming material from tankers procedure 8. No.PAA-PI-BS-04 loading export or local product to tankers procedure

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 8 of 26 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21.

No.PAA-PM-BS-02 product delivery administration procedure No.PAA-PSU-TU-01 mass balance and traceability procedure No.PAA-IK-TU-05 mass balance data input work intruction No.PAA-PM-MR-02 non-conforming material handling procedure No.PAA-PI-MR-01 document control procedure No.PAA-PI-MR-02 record control procedure No.PAA-IK-BLK/TF-05 sounding and temperature measurement work intruction No.PAA-IK-BLK/TF-02 product storage work intruction No.PAA-PI-MR-03 internal audit procedure No.PAA-PI-TU-01 training procedure No.PAA-PSU-MR-05 information provision of enhancement amount of production procedure No.PAA- PM-MR-03 costumer satisfaction survey and complaint handling procedure No.PAA-PI-MR-04 corrective and preventive action request procedure

During document check and discussion about the outsourcing process, in procedure of Mass Balance and Traceability (PAA-PSU-TU-01) Rev. 02 issued March 16, 2015 point 6.2.2 stated that beside transportation, the company also use storage (bulking) for material and finished good from third parties which is sister company PT Nagamas Palmoil Lestari (PT NPO). The controlling of material receipt and finished goods delivery will be handled by PT NPO. In the procedure related with outsourcing process still not inform about the procedure of storage (bulking facility) that will be handled by third parties and how the company ensure that third parties comply with all requirements of RSPO SCC. The company has appointed the team to control the implementation of RSPO SCC systems according to the Decision Letter of KDP Head No. KDP/DSI-PHG/164/X/15 issued on October 15, 2015. The team consists of Mr. Alkasim Fahzil as Management Representative for Refinery, Mr, Yatiman as Management Representative for KCP and Mr. Hadi Setiawan and Agung Angga Kesuma Siregar as secretary to control the documentation. From the three appointed person, there are no evidence that RSPO SCC core team have been trained new standard RSPO SCC to ensure these persons are able to demonstare awareness of the organization’s procedures for the implementation of this standard. Compliance status: Non-compliance See NCR 2015 - 02 of 04 and NCR 2015 – 04 of 04 . 5.4. Purchasing and goods in Findings: During surveillance audit, the compant still not purchased certified material, however simulation process has been conducted to describe the process of raw material receipt. The process of incoming raw material has regulated in administration of palm kernel receipt procedure (PAA-PM-TU-02) Rev. 00 dated August 01, 2015 and administration of liqud commodities receipt procedure (PAA-PM-TU-03) Rev. 00 dated August 01, 2015 and procedure of mass balance and traceability (PAA-PSU-TU-01) Rev. 02 issued on March 16, 2015. The procedure already explained about: - Raw material is a sustainable raw material (certified) and non sustainable raw material (noncertified) with kind of raw material is PK, CPO, CPKO and RBDPO. - The production clerk check the certified validity from supplier to ensure that the certificate still valid and incoming raw material can be guarranted is from certified supplier. The procedure also has explained, in part of acceptance raw material (CPO, CPKO and RBDPO) certified and non certified, in delivery note from supplier shall be include information about: - Name and certification system - Certificate number - Unique number from delivery note - Name and supplier address - Name and buyer address - Contract number - Types of product

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 9 of 26 - Delivery date - Quantity product - Country of origin Furthermore, already checked delivery order conformity, when the production clerk also must ensure: - Conformity with delivery order - Sustainable stamp should be available with certification system information (MB, SG or IP) in delivery notes or weighbridge slip from supplier. - Self declaration copy from subcontractor for transportation - Check for conformity supplier data for RSPO product certification list supplier This activity also conducted in CPKO incoming material. Next, on the traceability procedure number No. PAA-PSU-TU-01 Rev. 02 issued on March 16, 2015 about certified raw material purchase, mentioned: - Specially for sustainable product all of supplier is shall be RSPO or ISCC certified and also should be submit the copy of certificate to the facility and also in contract purchase should be include the information of RSPO SCCS Model system. - For raw material/product sustainable transporter, transport division should be brief mechanism for sustainable product acceptance and ensure the transporter understood the mechanism through by permission letter. - Specially for subcontractor/third parties designated for sustainable raw material transport should be issue of self declaration (the draft must approved by facility). - Trading division should be checked the validity of supplier certificate number in once year. On the material receipt documentation from PT PAA there is no special sign or stamp used for sustainable materials, information of the material status can only found on purchase order/contract from PT PAA to supplier and also in the mass balance control records. During document check of material receipt through simulation process on March 19, 2015 and May 04, 2015 has been found that internal weighbridge slip from PT PAA has been given a description with CPO RSPO/MB and PK RSPO/MB, this is not in accordance with procedure of material receipt both for liquid commodities or palm kernel that explained for sustainable raw material, the marks of RSPO Mass Balance and Certificate Number only stated and informed in delivery notes or weighbridge slip from supplier. The facility also has mechanisme for handling non-conforming material with document number No.PAAPM-MR-02 dated on December 4, 2012 Rev 01. The procedure explained about non-conforming product handling i.e.: - Re-process if possible to increase the quality, with notes “product does not contain the hazardous material” - Down grade - Discarded if found the material contain the hazardous material. - Non-conforming product should be placed separately. Compliance status: Non-compliance NCR 2015 – 01 of 04 In administration of palm kernel receipt procedure (PAA-PM-TU-02) and administration of liqud commodities receipt procedure (PAA-PM-TU-03) Rev. 00 dated August 01, 2015 has regulated that the marks of RSPO Mass Balance and certificate number on certified material receipt documentation only stated and informed on delivery notes or weighbridge slip from supplier, however during simulation process on March 19, 2015 and May 04, 2015 has been found that internal weighbridge slip from PT PAA has been given a description with CPO RSPO/MB and PK RSPO/MB. 5.5. Outsourcing activities Findings: The company has outsourcing activities for transportation and bulking. The transport activity divided in two types by truck and by tankers. Outsource activity by truck and by tankers is for transport of raw material and also finished product, during period January to November 2015, the listed outsourcing company are: 1. By truck:

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 10 of 26 Name of transporter Aman Abadi, CV Andalan Cahaya Sejahtera, PT Andalas Dinamika Anugerah Multitrans Sumatra Bumi Abadi Sejahtera Garuda Mas Gloria Harapenta Jaya Pertama Lima Adil Makmur Maju Jaya Abadi Maju Terus Mestika Jaya Mitra Jasa Transport Pelita Jaya Rahim Setia Jaya Sinar Kayangan Sinar Maju Teman Setia Wahyu Mas 2. By tankers: Name of transporter PT Citra Armada Nusantara PT Bintang Samudra Utama PT Pancaran Maritim Transportindo

Address Medan Pekanbaru Medan Medan Medan Medan Padang Sidempuan Dumai Medan Medan Dumai Medan Dumai Medan Medan Dumai Dumai Medan Medan Kisaran Medan

Contact person Ms. Widya Ms. Cindy Ms. Defi Ms. Joni Ms. Joni Toni

Telphone number +62 61 685 0294 +62 761 789 2096 +62 61 4142 377 +62 61 8448 347 +62 61 6623 812 +62 821 62555077

Ridwan

+62 821 67753991

Penta Rudy Dewie Juni Karim Rudy Suwandi Caroline Rahim Lina Ayong Maria Aing April

+62 813 65451133 +62 61 4553 388 +62 61 8003 288 +62 765 438877 +62 853 60888999 +62 812 75881888 +62 852 28989898 +62 61 4514 134 +62 813 65012233 +62 852 78332030 +62 811 618995 +62 61 7880 489 +62 61 2344 947 +62 61 76388153

Address Jl. Raya Kumpai KM 9 RT2 RW 8, Kapur sungai Raya, Kubu Raya 78391, Pontianak Kalimantan Barat Ruko Mega Grosir Cempaka Mas Blok B No. 27-29, Letjend Soeprapto Jakarta Pusat 10640 Menara Satu Sentra Kepala Gading Lantai 6 Suite 0607, Jl. Bulevar Kepala Gading LA 3 No.1 Summarecon Kelapa Gading, Jakarta 14240

Contact person

Telphone number

Agustinus Barry

Tel. +62561 7079976 Fax +622129339375

P. Dedy S

Tel. +62214269261 Fax +62214269262

Susanto

Tel. +622129385781 Fax +622129385782

To ensure the RSPO SCCS system will be implemented well, the company has prepared the form of Self Declaration in each agreement or contract signed by company and contractor. The statement in self declaration mentioned about “the transporter will provide data related their activity of transporting raw material and product certified RSPO SCCS MB to the certification body designated by RSPO”. During audit process, document check and discussion about the outsourcing process, in procedure of Mass Balance and Traceability (PAA-PSU-TU-01) Rev. 02 issued March 16, 2015 point 6.2.2 stated that beside transportation, the company also use storage (bulking) for material and finished good from third parties which is sister company PT Nagamas Palmoil Lestari (PT NPO). The controlling of material receipt and finished goods delivery will be handled by PT NPO. In the procedure related with outsourcing process still not inform about the procedure of storage (bulking facility) that will be handled by third parties and how the company ensure that third parties comply with all requirements of RSPO SCC. There is no contract between organization and subcontractor/third parties for bulking. So, there is no article of contract explained that all document related outsourced activity managed by the facility. This is non compliance with RSPO SCCS principle and criteria 5.5.1. Because the document related outsourced activity not available in the facility Compliance status: Non-compliance NCR 2015 – 02 of 04

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 11 of 26 The company still not describes and regulates the outsourcing process of storage (bulking) for material and finished good that will be handled by sister company PT Nagamas Palmoil Lestari (PT NPO) including the documentation required for outsourcing company. 5.6. Sales and goods out Findings: During surveillance audit, the company still not purchased and sold certified product RSPO SCCS MB. But the facility has procedure to control and manage the implementation of product delivery RSPO SCCS MB, which is set in: Mass balance procedure and traceability procedure No.PAA-PSU-TU-01, in part of procedure mentioned for sustainable product delivery: Delivery of certified product should be IN written order from trading division in Medan On sales contract should be RSPO SCCS system applied will available Sales document delivery RSPO SCCS product such as DO, weightbrigde, BL for tankers should be information about: Name and buyer address Name and sales address Delivery date Name of product Amount of product Information of RSPO SCCS model Certificate number Certified product and non-certified product delivery procedure No.PAA-PM-TU-02. The procedure mentioned about certified and non certified delivery product such as (CPO, CPKO, PME, RBDPO, RBDPKO, PFAD, PKFAD, Fatty Matter, and Glycerine). On the procedure mentioned that the security division should be report of permit letter to the production clerk to adjust the DO number, self declaration of transporter, entrance into weightbridge, and give the RSPO SCCS MB stamp with certificate number on wightbridge slip. Based on record of simulation process, conducted in March and May 2015, when the raw material received, production clerk ensure that the weightbridge slip from supplier has informed RSPO SCCS model, certificate number. After that, raw material obtained permission to the facility for process in refinery. The simulation process, has been equipped with: Purchase contract (has informed about name and address of buyer, name and address of seller, commodity, quantity, price, payment terms, deliver to/port discharge, delivery date, quality product). Self declaration After production process, production clerk recorded sustainable product in to mass balance table. After finished process, if any transaction sales sustainable product, trading division Medan will inform to facility to prepare the sustainable product based on sales contract. If the quality requirement meet the buyer standard, person in charged will open storage tank and flowed the product in to the truck, then production clerk will inform to weighbridge clerk that will deliver sustainable product, and will complete with RSPO SCCS stamp in weighbridge slip and allowed to deliver. 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 Self Declaration, and others Container or ISO Tank: Packing list, Bill of Lading (B/L), Certificate of Analysis, Manifest, Statement of Fact, Self Declaration, and others. Truck: Sales contract, delivery order, weighing slip, Self Declaration, Self declaration, and others In every document will stamp with SCCS MB. Where the person responsible for this have been getting training and simulation on the purchase and sale of the product certified MB, also the facility will distinguish the stamp. Trading departement issue invoice to customer after product loaded, the information on the invoice are: Contract number Invoice number Delivery order Buyer address

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 12 of 26 Description of product Statement/or information about RSPO SCCS selection model with stamp All information stated above can be verified during onsite audit through RSPO SCCS product simulation process. Compliance status: Compliance 5.7. Registration of transactions Findings: PT Pelita Agung Agrindustri is producing Edible and Non Edible Oil from supplied CPO and PK, the company has established SOP for registration every transaction to RSPO IT System as required by RSPO-SCC standard and the control of IT system in point 6.9.8 of procedure of Mass Balance and Traceability (PAA-PSU-TU-01) Rev. 02 issued March 16, 2015. During surveillance audit, the organization still not purchased certified material and sold certified products, so the transaction still not registered in RSPO IT system. Compliance status: Not applicable 5.8. Training Findings: The training program has regulated in training procedure (PAA-PI-TU-01) and set on training program (FPM-TU-01-02). The training programs have been set for all employees involved in RSPO SCC system. Refreshment training for RSPO SCCS planned to be conducted on May 15, 2015 for KCP and May 27, 2015 for Refinery. However until the last surveillance audit conducted, there is no evidence that the training program for RSPO SCC has been carried out in 2015. The last training for RSPO SCC conducted on October 2014 with using the old standard as reference. There is also no evidence that the RSPO SCC team which has been appointed based on KDP letter issued on November 02, 2014 and all employees involved in RSPO SCC systems have gained socialization or training related to the new standard of RSPO SCC specific and relevant to the task(s) performed. Compliance status: Non-compliance NCR 2015 – 03 of 04 The training programs have been set for all employees involved in RSPO SCC system. Refreshment training for RSPO SCCS planned to be conducted on April 2015. However until the last surveillance audit conducted, there is no evidence that the training program for RSPO SCC has been carried out in 2015. The last training for RSPO SCC conducted on August and September 2014 with using the old standard as reference. NCR 2015 – 04 of 04 No evidence that the RSPO SCC team which has been appointed based on the Decision Letter of KDP Head No. KDP/DSI-PHG/164/X/15 issued on October 15, 2015 and all employees involved in RSPO SCC systems have gained socialization or training related to the new standard of RSPO SCC specific and relevant to the task(s) performed. 5.9. Record keeping Findings: The facility has established a mechanism for control and maintenance of the data and document used in production process as stated on the document control procedure and records control procedure, the retention time for all records and reports for certified material and product has been defined for at least for ten (10) years. The storage and maintainance of documents is the responsibility of the Management Representative.

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 13 of 26 Record keeping activity for all process for MB SCCS system from incoming raw material until finished product and delivery product will record in mass balance table. The facility has prepared the mass balance calcultion form with consist information such as: Opening stock; CPO incoming; CPO process refinery, product refine, tank farm, refinery, fractination and biodiesel plant. During surveillance audit, the company still not purchased raw material and delivered certified product, but the facility has been done conducted the simulation for SCCS implementation. On the simulation record for the facility used form for : 1. Purchase contract with contained information: Buyer and seller name Buyer and seller adress Product type/name Quantity and quality product Price product Payment terms Desrination Delivery date 2. Weighing slip Vehicle ID Quantity product Quality spesification Product type/name Wheighing result before and after loading 3. Entry permits/unloading, with contained information: Commodity Date Vehicle ID Sample analysis Seal check 4. Delivery order, with contained information: Name of transporter DO number Dated DO Quantity Destinantion Addrasse Origin Commodity 5. Self declaration, inform about statement of outsourcing activity to fulfill of RSPO SCCS system requirement especially for transport and following the facility mechanism for sustainable product handling. The marks of RSPO MB during simulation production process from material receipt until finished goods delivery can be found in a. Contract Purchasing from PT PAA to supplier: in the commodity section informed the status of material CPO or CPKO RSPO/MB b. On the weighing slip from supplier should inform the status of certified material in accordance with purchase contract issued. c. On receipt weighing slip of PT PAA will be stamped with RSPO/MB and RSPO Cert. No. d. All certified material will be recorded in mass balance table and registered in e-trace. e. Sales contract from PT PAA to costumer, in the commodity section informed the status of material CPO or CPKO RSPO/MB f. On delivery weighing slip of PT PAA will be stamped with RSPO/MB and RSPO Cert. No. g. Delivery order PT PAA h. Proforma Shipping Instruction i. All certified product will be recorded in RSPO products monthly record, in mass balance table and registered in e-trace. Compliance status: Compliance

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 14 of 26 5.10. Conversion factors

Findings: The conversion factor calculation regulated in work instruction of inputting table of mass balance records (PAA-IK-TU-05) Rev. 01 issued on March 16, 2015. In point 5.1.3 of the work instruction described the Refinery and Fractionation process, from processed CPKO become CPKOL (65%) and CPKS (35%). Until the last surveillance audit, the company still not purchased raw material and delivered certified product and not produce certified products. Compliance status: Compliance

5.11. Claims

Findings: The company still not purchased raw material, produce certified products, and delivered certified product. So the company still not do the claimed for sustainable products. However the sustainable product claimed process has regulated and informed in procedure of Mass Balance and Traceability (PAA-PSU-TU-01) Rev. 02 issued March 16, 2015 point 6.10. Compliance status: Not applicable

5.12. Complaints

Findings: To handling the customer complaints the company has regulated in the procedure of costumer satisfaction survey and handling complaint (PAA-PM-MR-03) Rev. 01 issued on December 04, 2012. During surveillance audit, there are no complaints from stakeholders related to RSPO SCC systems. The complaint process are 1. Complaint received through Formal letter, email or by phone will be recorded in Form corrective and preventive action request (FPI-MR-04-01) 2. MR is the responsible person to follow up the complaints 3. If needed MR can command to conduct internal audit 4. Complaints handling result will be reported by MR to Top Management Records complaints will be discussed more detail in the Management Review Meeting. Compliance status: Compliance

5.13. Management review

Findings: The organization has conducted management review meeting on August 28, 2015. The meeting agenda are 1. Audit result 2. Feedback from stakeholders 3. Company policies and quality objectives 4. Performance of process, OHS, Environment and suitability of product 5. Corrective and preventive action status 6. Report and investigation of accident/incident QMF: RSPO-007c-13 rev.2

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 15 of 26 7. 8. 9. 10. 11. 12.

Follow up last management review meeting Changes that can impact quality objectives Evaluation result of compliance with laws and regulation Communication, participation and consultation result Recommendation of improvement Etc.

Detail description for each agenda has beed discussed and described in Management Review Minutes Meeting. The Management Review meeting attended by 25 participants from all section led by Mr. Dapot SH Hutabarat as Mill Manager. Compliance status: Compliance

Section 6: Supply chain models - Modular Requirements: Module C – Mass Balance C.1. Definition Findings: The company has applied Mass Balance system ( Module C) due to the nature of incoming material from company’s supplier are Mass Balance and company’s production facilities are not sufficient to implement others supply chain model. During the 1st surveillance audit, the organization still implemented of RSPO SCCS MB. The organization still not purchased raw material and delivered certified product and not produce certified products. In mass balance record has showed the information of incoming raw material, refined and fractionation, conversion ratio (yield shceme), 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 mentioned “all document related sustainable product will keep in 10 years and deliverd to Management Representative. Compliance status: Compliance C.2. Supply chain reqiurements Findings: Following the nature of company’s material purchased availability for production facilities. PT PAA management decided to implement Mass Balance supply chain model (Module 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. The company did not separate the storing or controls in the production process, however in the documentation for product received and product delivery the company will use RSPO-Mass Balance stamp to distinguish between certified and non-certified products. The organization has established a mechanism for control and maintenance of the data and document used in production process following PT PAA integrated Manual System (PAA-MI-TM-01), including all procedures and work instruction to support the implementation of RSPO SCC standard. Operation Manual, in which the retention time for all records and reports already defined for at least for ten (10) years. The storage and maintainance of documents is the responsibility of the respective departments.

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 16 of 26 The refinery has record and balance all receipts of RSPO certified material and non certified material and deliveries of RSPO certified product on daily basis; All volumes of product that are delivered are deducted from the material accounting system according to actual daily conversion ratios. Compliance status: Compliance

C.3. Processing Findings: The facility will be implemented of RSPO SCCS MB. Mechanism processing for SCCS MB system to ensure that all standard operation procedure can implemented in PT Pelita Agung Agrindustri, the facility conduct RSPO production process simulation from incoming material until product dispatch on March and May 2015 as observed on RSPO SCCS production simulation. Incoming material in PT Pelita Agung Agrindustri more by truck. Incoming material using truck will directly to the facility and still do cheked slip delivery, RSPO SCCS model, stamp, and if confirm, raw material will be loaded in to tank farm. Raw material in PT Pelita Agung Agrindustri such as CPO and CPKO is come from supplier. PT Pelita Agung Agrindustri has storage tanks for raw material and for each product in facility location, i.e.: A. For raw material: - Tank number 304 for CPKO - Tank number 305 and 306 for CPO from own Mill - Tank number 3012 for CPO - Tank number 301 for CPO - And there are 2 new tanks number 3010 and 3011 unfilled B. For product: - Tank number 19007 for PFAD - Tank number 302, 303, 19003 for RBDPO - Tank number 307, 308, 309 for PME - Tank number 19002 for RBDPKO - Tank number 19010 for PKFAD - Tank number 19001, 19006 for Fatty matter - Tank number 19008, 19008 for Glycerine Refine - Tank number 19004, 19005 for PME - Tank number 19011 for Water Glycerine - Tank number 19012 for Crude Glycerine Pipe line for raw material and product transfer using: - Pipe lines yellow colour for CPO also for CPKO with flushing first - Pipe lines cream colour for PME As described above in outsourcing activities, PT PAA has storage tank located in bonded zone (Kawasan Berikat) where the location in sister company PT Nagamas Palmoil Lestari. Storage tank number appointed for PT PAA is number T224, T225, T305, T306, T502, T503, T627, T628, T629, T631 accorndace to Customs Permit number Kep-1524/WBC.03/KPP.02/2010 dated April 20, 2010. This storage tank used for product before deliver to buyer, if any buyer used tanker to transport. But some times this storage tank also used for stored raw material if any supplier deliver use tanker to seaport, but this is a rare. Most of supplier delivered their raw material to facility used tuck. Mass Balance and Traceability procedure number No.PAA-PSU-TU-01, on this procedure, has explained about receiving material with Mass Balance Model, should be include information about: - Contract number/Delivery Order - Self declaration - RSPO SCCS model stamp and certificate number - Origin of material - Quantity All of activity for mass balance since received raw material and processing until to finish product will be control by facility through the mass balance input system. This is arranged in work instruction number No.PAA-IK-TU-05 about work instruction for mass balance input RSPO SCCS. On mass balance table

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 17 of 26 input has been separated between raw material and product certificate and non certificate. For control of raw material quantity and certified product available in facility, has been control by work instruction about Mass Balance Table Input Data number No.PAA-IK-TU-05. When person incharge to input data is production clerk in each plant. In mass balance table has been describe information such as: Opening stock for certified raw material Opening stock for non certified raw material Total certified and non certified raw material Total quantity of certified and non certified product Total quantity delivered product certified and non certified And others. All of information about mass balance system has been described and will applie when the facility has run their certified production. 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 number No.PAA-PSU-TU-01, mentioned “all document related sustainable product will keep in 10 years and deliverd to Management Representative”. Compliance status: Compliance C.4. Continous accounting system Findings: PT Pelita Agung Agrindustri has established a meachism to ensure that the quantity of physical CSPO, CSPK, Fractionation mass balance material inputs and outputs (volume or weight) at the physical site are monitored on a real-time basis and recorded on facility work instruction about Mass Balance Table Input Data number No.PAA-IK-TU-05 Rev. 01 dated March 16, 2015. All palm oil volumes that are delivered are deducted from the material accounting system according to actual daily conversion ratios. On the procedure also mentioned every certified product from refinery shall be recorded in mass balance report and the information on mass balance report consist of: Own of product Name of product Origin of product Quantity Opening stock Receiving Dispatch Production Final stock Furthermore, in procedure number No.PAA-PSU-TU-01 Rev 02 dated March 16, 2015 about mass balance and traceability procedure mentioned that mass balance report for supply chain logistics shall be consistent with first/initial stock, incoming, delivery and end/final stock. Also, make sure that stock is always positive. The company will inform CB if facing condition to make sell short. The implementation of certified product accounting system will be started after PT PAA getting approval as certified company from RSPO CB Compliance status: Compliance C.5. Fixed inventory perionds Findings: In the procedure of Mass Balance and Traceability the company decided to use continous accounting system and the material balance records will be check each three month by MR to ensure the stock always positive.

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 18 of 26 Compliance status: Non-compliance C.6. Conversion ratios Findings: The conversion factor calculation regulated in work instruction of inputting table of mass balance records (PAA-IK-TU-05) Rev. 01 issued on March 16, 2015. In point 5.1.3 of the work instruction described the Refinery and Fractionation process, from processed CPKO become CPKOL (65%) and CPKS (35%). Until the last surveillance audit, the company still not purchased raw material and delivered certified product and not produce certified products. Compliance status: Compliance C.7. Yield Schemes Findings: Until the last surveillance audit, the company still not purchased raw material and delivered certified product and not produce certified products. The yield scheme regulated in work instruction of inputting table of mass balance records (PAA-IK-TU-05) Rev. 01 issued on March 16, 2015. In point 5.1.3 of the work instruction described the Refinery and Fractionation process, from processed CPKO become CPKOL (65%) and CPKS (35%). Compliance status: Compliance

3.2 Previously Status Identified of RSPO SCCS Requirement Non-conformities Not applicable (no non-conformities found during certification assessment)

3.3. Identified Non-conformances against RSPO SCCS Requirements, Corrective Actions Taken and Auditors Conclusions The company has provided sufficient evidences of corrective action for all Non-conformances issued.

SCCS Non-conformance 2015 - 01 of 04: In administration of palm kernel receipt procedure (PAA-PM-TU-02) and administration of liqud commodities receipt procedure (PAA-PM-TU-03) Rev. 00 dated August 01, 2015 has regulated that the marks of RSPO Mass Balance and certificate number on certified material receipt documentation only stated and informed on delivery notes or weighbridge slip from supplier, however during simulation process on March 19, 2015 and May 04, 2015 has been found that internal weighbridge slip from PT PAA has been given a description with CPO RSPO/MB and PK RSPO/MB. Correction: The head of production has revised internal weighbridge slip and evaluate the RSPO M/B marking process in weighbridge to ensure that all receipt documentation is in accordance with the procedure. Corrective Action: The company has conducted the refreshment and socialization of the procedure and documentation for certified and non-certified material receipt on November 25, 2015 to all employees involved in material receipt. MR will reviewed documentation simulation that will be conducted annually due to the rill process of certified material receipt and certified products delivery. Auditor Conclusions: Closed

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 19 of 26 Date of closure: February 05, 2016 Verification Result: The simulation documentation has been revised to fulfil the requirements of the raw material receipt procedure. MR has conducted evaluation with weighbridge section to ensure the process is in accordance with the procedure. The company has conducted refreshment and socialization of the procedure and documentation for certified and non-certified material receipt on November 25, 2015 to all employees involved in material receipt and during simulation process that will be held every year as long as the rill process of certified material receipt and certified products delivery still not running, MR will reviewed simulation documentation to ensure all documents are comply with procedure.

SCCS Non-conformance 2015 - 02 of 04: The company still not describes and regulates the outsourcing process of storage (bulking) for material and finished good that will be handled by sister company PT Nagamas Palmoil Lestari (PT NPO) including the documentation required for outsourcing company. Correction: The company has revised and added the mechanism for outsourcing process of storage (bulking) that will be handled by sister company PT Nagamas Palmoil Lestari (PT NPO) including the documentation required to fulfil all requirements for outsourcing. The organization has appointed personil to conducted socialization about the mechanism for storage and delivery in Bulking. Corrective Action: The company has created agreement between PT PAA and PT NPO to ensure that all requirements for RSPO SCC have been fulfilled. Auditor Conclusions: Closed Date of closure: February 05, 2016 Verification Result: In mass balance and traceability procedure has added information about outsourcing process of storage (bulking) in point 6.2.2, 6.2.4. The agremeent has created between PT PAA and PT NPO, long term lease agreement No. 002/NPL-PAA/TT/XII/2015 dated December 18, 2015 in clause 14 has regulated about the RSPO SCCS. The supporting documentation has created to support the implementation of the agremeent, such as a. Minutes of meeting for transfer/delivery products. The revised procedure has socialized on November 12, 2015.

SCCS Non-conformance 2015 - 03 of 04: The training programs have been set for all employees involved in RSPO SCC system. Refreshment training for RSPO SCCS planned to be conducted on April 2015. However until the last surveillance audit conducted, there is no evidence that the training program for RSPO SCC has been carried out in 2015. The last training for RSPO SCC conducted on August and September 2014 with using the old standard as reference. Correction: The sustainability of head office has been provided training of the new standard RSPO SCC on November 12, 2015 trained by internal trainer Mr. Hendra Hosea and attended by 15 participants (Batch I) and 15 participants (Batch II). Corrective Action:

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 20 of 26 MR will monitor each changes of standard that could impact the knowledge of employess. If there are changes MR will coordinate with training department of head office to provide the training. If MR already gets the training of the new standard, MR will give directly training or socialization to all employees involved in RSPO SCC systems. Auditor Conclusions: Closed Date of closure: February 05, 2016 Verification Result: The organization will do the coordination with head office to provide the training needed especially for RSPO SCC at least once in a year.

SCCS Non-conformance 2015 - 04 of 04: No evidence that the RSPO SCC team which has been appointed based on the Decision Letter of KDP Head No. KDP/DSI-PHG/164/X/15 issued on October 15, 2015 and all employees involved in RSPO SCC systems have gained socialization or training related to the new standard of RSPO SCC specific and relevant to the task(s) performed. Correction: The team has joined training of the new standard RSPO SCC on November 12, 2015 trained by internal trainer Mr. Hendra Hosea (sustainability department head office) and attended by 30 participants. The company has provided training documentation and training material kit. Corrective Action: HR department will allocate for all employees involved in RSPO SCC systems who have not followed training, to participate in the training program 2016. Auditor Conclusions: Closed Date of closure: February 05, 2016 Verification Result: The team has joined training of the new standard RSPO SCC on November 12, 2015 and all employees involved in RSPO SCC systems that have not followed training, to participate in the training program 2016.

3.4 Conclusion and Recommendation for RSPO Supply Chain Certification The audit team has confirmed through the audit process that PT Pelita Agung Agrindustri has established and maintains an effective system to ensure compliance with the RSPO Supply Chain Certification requirements (dated November 2014). PT TUV Rheinland Indonesia recommends that PT Pelita Agung Agrindustri still continue their certification of compliance to the RSPO Supply Chain Certification requirements.

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 21 of 26

4.0 CERTIFIED ORGANISATION’S ACKNOWLEDGEMENT OF INTERNAL RESPONSIBILITY

4.1 Date of Next Surveillance Visit The next surveillance visit is planned for November 2016

4.2 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 Pelita Agung Agrindustri

Signed on behalf of PT TUV Rheinland Indonesia

Hardi Harmen Management Representative Date: February 05, 2016

Riki Harpan Auditor Date: February 05, 2016

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 22 of 26

APPENDICES Appendix 1: Details of Supply Chain Certification Certificate

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 24 of 26 Appendix 2: List of Abbreviations CPO P&C PKO SCC KCP PME RBDPO RBDPKO PFAD PKFAD

Crude Palm Oil Principles & Criteria Palm Kernel Oil Supply Chain Certification Kernel Crushing Plant Palm Methyl Ester Refine Bleached Deodorized Palm Oil Refine Bleached Deodorized Palm Kernel Oil Palm Fatty Acid Distillate Palm Kernel Fatty Acid Distillate

Appendix 3: Observations and Opportunities for Improvement Not applicable

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 25 of 26 Appendix 4: Supply Chain Certification Audit Closing Meeting Summary Accordance audit result, the facility has prepared very well for SCCS implementation, such as procedure, person trained, and also manajemen support. But, there is 4 finding not fullfill for SCCS requirement and has closed by correction and corrective action submitted by facility.

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RSPO SCC 1 Surveillance Audit Report PT. Pelita Agung Agrindustri Duri, Riau Province Page 26 of 26 Appendix 5: List of Certified Product and Projection for year 2016 No.

Product

Output (tones)

1.

CPKO

295,358

2.

PFAD

12,694

3.

PKFAD

4.

Methanol

5.

Palm Methyl Ester

207,441

Glycerine Crud Glycerine Refined

28,431 20,893.9

7.

RBDPO

210,600

8.

RBDPKO

9.

Biodiesel, Fatty Matter

6.

918,773 21,587

32,915 2,527

Appendix 6: List of Certified Suplier and Buyer Volume incoming material*

1

-

-

Date of Incoming material* -

2

-

-

-

Name of certified Supplier

No.

Supply chain model

Certificate No.

Expiry Date

remarks

-

-

-

-

-

-

-

-

*) still not applicable because the facility has not made a purchase the certified product

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