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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
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 2 OF 22 PAGES
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
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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.
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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).
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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).
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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.
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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.
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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
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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.
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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).
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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.
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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.
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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.
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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.
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 15 OF 22 PAGES
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."
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 16 OF 22 PAGES
• 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
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 17 OF 22 PAGES
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
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 18 OF 22 PAGES
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).
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 19 OF 22 PAGES
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
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 20 OF 22 PAGES
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.
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 21 OF 22 PAGES
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.
NPL-D18I14 SUSTAINABILITY INFORMATION DOCUMENT NOBLE PLANTATIONS 2018 PAGE 22 OF 22 PAGES
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