Enough is enoughTime for the palm oil market to start the real work to stop driving deforestation]

Investigative Report
Eyes on the Forest
Published in June 2018
Eyes on the Forest (EoF) was founded in 2004 by 3 NGOs in Riau, Sumatra:
Walhi Riau, Jikalahari "Riau Forest Rescue Network" and WWF-Indonesia Central Sumatra Program.
Its network members include KKI Warsi in Sumatra and Enviromental Law Clinic, Lembaga Gemawan,
Jari Indonesia Borneo Barat, Kontak Rakyat Borneo, POINT, Swandiri Institute, Yayasan Titian,Gapeta Borneo and WWF-Indonesia West Kalimantan Program in Kalimantan.
EoF investigates those who clear natural forests and grab land they do not own in Indonesia.
The coalition also informs those who buy products made from commodities grown on these lands andthose who regulate the use of these lands.
EoF website: http://www.eyesontheforest.or.id
EoF interactive map: http://maps.eyesontheforest.or.id
Email: editor(at)eyesontheforest.or.id

Front cover photo: Aerial view of illegal oil palm plantations and a stretch ofremnant forest in Tesso Nilo National Park. Photo taken by Eyes on the Forest at
S0°5'59.59" and E101°36'44.94" on 21 November 2013 - almost five years ago.
Quote: EoF (2018) Enough is enough - time for the palm oil market to start the real
work to stop driving deforestation. Investigative report.
Online: Check for this report and many related documents at
www.eyesontheforest.or.id. Follow the tracks of illegal FFB and tainted CPO at
maps.eyesontheforest.or.id.

Contents
EXECUTIVE SUMMARY - Eyes on the Forest “Enough is Enough”, 2018 .......................... 1
INTRODUCTION ..................................................................................................... 4
INVESTIGATION FINDINGS ..................................................................................... 8
1. Tracking illegally grown FFB from protected areas to CPO mills ............................... 8
2. Tracking CPO tainted with illegally grown FFB..................................................... 12
3. Exposure of the Big 4 to tainted CPO – company commitments versus reality ......... 13
4. Exposure of other major global palm oil traders/users to tainted CPO .................... 16
5. Can RSPO certified products offer a solution? ..................................................... 25
6. FFB agents - the weakest points in supply chains: the case of Tesso Nilo ............... 27
CONCLUSIONS & RECOMMENDATIONS ................................................................... 29
Appendix 1. Supply chains of illegal FFB to surrounding CPO mills. .............................. 33
Appendix 2. Supply chains of CPO from mills who purchased illegal FFB. ...................... 40
Appendix 3. Definition of traceability by RGE and Wilmar. .......................................... 44
Appendix 4. Corporate responses to this report ........................................................ 45
References .......................................................................................................... 46

EXECUTIVE SUMMARY - Eyes on the Forest “Enough is Enough”, 2018
In May 2016, the Indonesian Ministry of Environment and Forestry (MoEF) set up a multistakeholder task force to revitalize Tesso Nilo National Park (TNNP) and the larger Tesso
Nilo ecosystem. One of main objectives of the task force is to remove illegal oil palm
plantations which occupy 75% of the national park, to ensure that CPO mills surrounding
Tesso Nilo do not source FFB from illegal plantations, and to convince implicated companies
to support rehabilitation and reforestation in Tesso Nilo. In support of the task force, Eyeson the Forest (EoF) investigated the flow of illegal FFB from TNNP in June, July and August
2017 to determine whether Indonesia’s “Big 4” - Wilmar, Musim Mas, Golden Agri-Resources
and Royal Golden Eagle - followed the MoEF Secretary General’s order to stop buying FFB
grown illegally in TNNP. All had been implicated in previous investigations and have been
fully aware of the risks.
Indonesia’s palm oil industry has been at the center of the storm of the dramatic
deforestation of the country. EoF satellite image analysis found that Sumatra's 44 million
hectares mainland, covered by 25 million ha (57%) of natural forests in 1985, lost 56% of
this forest over 31 years and by 2016 had only 11 million ha (25%) remaining.
Sumatra has been the main production hub for palm oil’s “Big 4”. They have almost half ofthe total refining capacity of Indonesia and Malaysia and are involved in more than 75% of
global palm oil trade. Since 2013, the groups have published corporate zero deforestation
policies and signed joint zero deforestation pledges, including in 2014 the United Nations
Climate Summit “New York Declaration on Forests”, the Indonesian Palm Oil Pledge(disbanded after Government pressure in June 2016), and the Sustainable Palm Oil
Manifesto. Today, 74% of the total refining capacity in the world’s two prime palm countries
is operated by corporate groups with “No Deforestation No Peat No Exploitation” policies.
However, despite these impressive paper commitments, the region’s remaining ever smaller
and ever more precious forest blocks continue to be converted to oil palm plantations. Many
were some of the last remaining habitats of critically endangered species like tigers,
elephants and orangutan, and on the easily flammable, carbon rich peatlands of Sumatra
and Borneo. The fruit (FFB) of the mostly illegally developed oil palm plantations is bought
by an ever-increasing number of CPO mills.
The palm oil industry’s continuous expansion of refining capacity keeps increasing thedemand for CPO and ultimately, FFB. EoF investigative results and the presence ofindependent mills in their supply chains are indications that the Big 4 do not control enough
FFB of known legal and sustainable origin and have to rely heavily on unproven supplies
from third party producers and agents. Interestingly, when EoF contacted the Big 4 about
the percentage of third party supplies entering their processing facilities and overall FFB
traceability, they either did not provide data (Wilmar) or stated these data were not yet
available. Combined with the widespread illegality of oil palm plantation development in
Riau and the Big 4’s and others’ lack of systems to trace FFB, the forests keep falling andthe world’s palm oil products continue to be vulnerable to being tainted by illegal FFB.
Agents and third-party CPO mills are the weakest points in the system. EoF findings showthat agents delivering FFB to CPO mills know about the illegality of the FFB they trade andtry to hide its true origin by for example claiming that they come from a legal oil palm
plantation, by driving longer routes before delivering it, or changing license plates on theirtrucks. The findings highlight how critically important it is for CPO mills to trace the real

1 | EoF (June 2018) Enough is Enough.

origins of the FFB delivered to their mills by agents so that illegally and unsustainably
produced/harvested FFB can be identified, separated and rejected.
Current efforts are not enough. FFB tracing data required from agents by companies like
Apical and Wilmar are not sufficient. Wilmar’s current approach to tracing its supplies backto the plantation does not require agents to report “GPS” or “planted area” for the FFB they
supply. The likelihood of agents delivering illegal and/or unsustainable FFB gets higher withmore and more illegal FFB coming online as illegally established plantations become mature,with illegal growers unable to easily sell their product directly at market prices, with agentstrying to find as much and as cheap FFB as possible to increase their margins, and withmills reluctant to reject illegal FFB or even put strong measures into place to identify it
because they need to fill their FFB supply gaps.
Without the Big 4 truly committing to no longer buy and sell illegal product and establish
fool proof systems to achieve 100% FFB traceability, and without the Big 4 committing to
only expand their capacities according to the availability of legal FFB and CPO they cancontrol, rather than the vast quantities of illegal FFB and CPO floating in the market, they
will continue to deliver illegal and tainted product to the world. Their commitments toconservation and zero deforestation policies will sound ever hollower as their CEOs battle
for position in Forbes’ list of palm oil billionaires. The companies have to seriously invest
into ensuring the legality of their supplies and they are clearly not doing enough.
How easily tainted CPO from just a few mills in one area can pollute the world’s palm oil
supplies became clear in EoF’s random investigations. Since 2011, EoF identified 22 CPO
mills purchasing illegal FFB harvested inside the Tesso Nilo and the Bukit Tigapuluh
landscapes. EoF found the Big 4 to continue to be implicated in the trade of illegal FFB andtainted CPO from the two areas in 2017.

In its 2016 report, EoF wrote that “No One is Safe” from purchasing tainted palm oil
products. This year, in addition to the Big 4, EoF found the 21 of the 22 implicated mills
to be among the direct or indirect suppliers of many of the world’s key traders and users
with zero deforestation commitments: AAK, ADM, Bunge, Cargill, Colgate-Palmolive,
General Mills, Kellogg’s, Mars, Mondelēz, Neste, Nestlé, Olam, PepsiCo, Proctor &Gamble, Reckitt Benckiser and Unilever. Some of these buyers were found to buy palm
oil from the implicated mills via their direct suppliers including AAK, ADM, RGE (as Apical),Cargill, Bunge Loders Crocklaan, Fuji Oil, GAR, Musim Mas (as ICOF), IOI, Louis Dreyfus,
Sime Darby Plantation and Wilmar. Through the tainted products they buy, they are alllinked to the deforestation of central Sumatra. EoF believes that its investigations just show
the tip of the iceberg. In the absence of purchasing filters at the CPO mill level similar useof illegally grown FFB likely occurs throughout the country, contaminating many more global
supply chains. EoF appreciates the new supply chain transparency of the companies namedin this report – but what’s next? EoF hopes that the connections identified by ourinvestigation will help companies develop legal supply chains by eliminating FFB produced
illegally or in violation of zero deforestation commitments at plantation level from their
supply chains.
After years of commitments, markets are still encouraging the conversion of forests to oil.
Buzzwords like “risk mapping” and “jurisdictional approach” are the current fashion. But“Enough is enough”, the real work to stop driving deforestation has to start. In the eighthyear since the industry’s first zero deforestation policy, there is a clear need for industry
and civil society to review all the supply chain work and its real achievements on the ground;to redirect efforts to achieve the purpose why zero deforestation commitments were ever
2 | EoF (June 2018) Enough is Enough.

“created”: to stop the loss of the remaining High Conservation Value and High Carbon Stockareas, like Sumatra’s lowland forests in Tesso Nilo and Bukit Tigapuluh; and to address palm
oil’s legacy and begin restoring some of the most precious conservation areas. EoF has
compiled specific recommendations in the “Conclusions & Recommendations” section.

3 | EoF (June 2018) Enough is Enough.

INTRODUCTION
Indonesia’s palm oil industry has been at the center of the storm of the dramatic
deforestation of the country. EoF satellite image analysis found that Sumatra's 44 million
hectares mainland, covered by 25 million ha (57%) of natural forests in 1985, lost 56% of
this forest over 31 years and by 2016 had only 11 million ha (25%) remaining.
Sumatra has been the main production hub for palm oil’s “Big 4” – Wilmar, Musim Mas,
Golden-Agri-Resources (GAR) and Royal Golden Eagle (Asian Agri and Apical) - with a
combined refining capacity of 33.2 million MT/year, almost half (46%) of Indonesia andMalaysia’s total refining capacity1. According to 2016 data, Wilmar, Musim Mas and GAR
controlled 75% of global palm oil trade2. Since 2011, the groups have published corporate
zero deforestation policies3, 4, 5, 6, 7 and signed joint zero deforestation pledges with manyother companies, including in 2014 the United Nations Climate Summit “New York
Declaration on Forests”8, the Indonesian Palm Oil Pledge (disbanded due to Governmentpressure in June 2016)9, and the Sustainable Palm Oil Manifesto10, 11. Today, 74% of thetotal refining capacity in the world’s two prime palm countries is operated by corporategroups with “No Deforestation No Peat No Exploitation” policies12.
However, despite these impressive paper commitments, the region’s remaining ever smaller
and ever more precious forest blocks continue to be converted to oil palm plantations andtheir fruit (FFB) are bought by crude palm oil (CPO) mills - whether the areas were protectedby government or not.
Riau, Indonesia’s top palm oil producing and exporting province has been plagued with
deforestation for development of often illegal oil palm plantations for years. Between 2011
and 2015, WWF-Indonesia and the Eyes on the Forest (EoF) coalition conducted random
investigations of the supply chains of illegally grown oil palm fruit (FFB) from Tesso Nilo
National Park (TNNP) (Map 1) and “Bukit Batabuh Tiger Corridor (BBTC)” and theirsurrounding “Forest Estates” (Box 1). These investigations have shown many companies,
including the Big 4, to be involved in the trade of illegal FFB from these areas and/or oftainted CPO or other palm oil products which may have been “contaminated” when illegallygrown FFB were milled and the oil was bulked with other supplies for shipment and/or
further processing13, 14 , 15. WWF and EoF have alerted the Big 4 many times to these facts.
EoF found that the Big 4 do not know the origin of the FFB for the majority of the CPO theyrefine. Without that knowledge, the implementation of their respective zero-deforestation
policies is not possible. During many conferences and in replies to EoF’s 2016 “No one issafe” report, all groups commented on the complexity of achieving 100% FFB traceability
and filtering illegal FFB supplies out of their supply chains16. The Big 4 thus know they are
directly or indirectly responsible for destruction of Indonesia’s last remaining High
Conservation Value, High Carbon Stock forest blocks. Palm oil is big business, having easily
generated places among Forbes’ lists of top billionaires for group owners. But to avoid
reputational and legal risks companies also have to make the investments necessary tosafeguard their supply chains and exclude illegal FFB and tainted CPO.
The history of oil palm plantation development in Riau Province, still the main production
province for the industry, has been plagued with illegality and corruption. In 2009, Riau’sprovincial and district plantation agencies recorded 2.6 million ha of oil palm plantation area.
In 2010, the Riau Governor at the time (Rusli Zainal, later jailed for pulp & paper industry
related corruption) proposed 3.5 million hectares of Forest Estate to become Non-Forest
Estate, a lot of it supposedly already planted with illegal palm oil plantations at the time.

4 | EoF (June 2018) Enough is Enough.

Then Minister of Forestry (Zulkifli Hasan) launched an investigation of the proposal and in2012 agreed to less than half of the proposed zoning change, 1,638,249 hectares. Only two
years later, in 2014, the same Minister admitted that 50%, or two million hectares, of all oilpalm plantations in Riau were “illegal or had no permit”17 and issued a Decree (Number
673/Menhut-II/2014 dated August 8, 200418) to legalize the 1,638,249 hectares of illegal
oil plantations by changing their zoning from Forest Estate19 to Non-Forest Estate. Four days
before the same Minister issued a related Decree (Number 878/Menhut-II/2014 dated 29
September 2014)20 , then Governor of Riau (Anas Maamun) was caught red-handed byIndonesia’s KPK (Corruption Eradication Commission) for allegedly receiving bribes frompalm oil plantation businessmen and companies in favor of his effort to lobby the thenMinister of Forestry for accepting their proposal to change the zoning of Forest Estates. He
was sentenced to 7 years in prison for the alleged corruption.
A 2016 EoF investigation21 of 26 oil palm plantations including some by Wilmar and GAR
covering in total around 100,000 ha of the above mentioned 1,638,249 found manyillegalities and irregularities. EoF recommended that the Ministry of Environment andForestry (MoEF) revokes the two 2014 Decrees mentioned above and take enforcement
actions against palm oil companies which had illegally occupied Forest Estates anddeveloped oil palm plantations therein before the issuance of the two Minister of Forestry
Decrees.
The industry’s over capacity of refining facilities without assured sources of known origin
CPO and its resulting heavy reliance on unknown third party supplies, combined with thewidespread illegality of oil palm plantation development in Riau and the lack of systems totrace FFB by the Big 4 and others, have made the majority of the world’s palm oil supplies
vulnerable to palm products tainted with illegally grown FFB, produced in some of the lastremaining habitats of critically endangered species like tigers, elephants and orangutan,
and on the easily flammable, carbon rich peatlands of Sumatra and Borneo.
Shortly after EoF’s 2016 “No one is safe” report highlighted again the trade of illegal FFB
and tainted CPO from TNNP and its surrounding Forest Estates, the MoEF ramped up its
efforts by setting up a multi-stakeholder task force for Tesso Nilo Ecosystem Revitalization(Revitalisasi Ekosistem Tesso Nilo, RETN), composed of MoEF, Riau Provincial Government
and NGOs including EoF members and Mitra Insani. The main objectives of the RETN task
force are to:● revitalize the “Tesso Nilo ecosystem”, including TNNP and the adjacent Forest Estatesby removing illegal oil palm plantations which occupy more than 75% of TNNP alone(RETN task force’s survey in 2017) (Map 1),● ensure that CPO mills surrounding the Tesso Nilo ecosystem do not source FFB fromillegal plantations in the ecosystem, and● convince nearby and implicated companies to support rehabilitation and reforestation in
the ecosystem.
Several actions were taken by the RETN task force related to sourcing of illegal FFB fromthe ecosystem:● 15 July 2016: The Directorate General of MoEF’s Law Enforcement submitted a letter toIndonesian Palm Oil Association (GAPKI) and Roundtable on Sustainable Palm Oil(RSPO), urging both groups to require their members not to purchase illegal FFB and/or
tainted CPO.
● 16 November 2016: MoEF and RETN task force representatives had a meeting with the
Big 4: Wilmar, RGE, GAR and Musim Mas. The Secretary General of MoEF ordered thefour companies not to purchase FFB from illegal palm oil plantations grown in the Tesso

5 | EoF (June 2018) Enough is Enough.

●Nilo ecosystem and/or tainted CPO, and informed them that there will be sanctions if
they are found to source them;
17 February 2017: The Chief of Riau Police issued a letter calling on the 58 CPO mills
surrounding the Tesso Nilo ecosystem not to transport and/or source FFB sourced fromplantations inside Forest Areas including TNNP22.

To support the RETN task force’s objectives, EoF investigated traceability of illegal FFB fromTNNP between June and August 2017. Today, the 82,471 hectares national park is coveredby around 36,000 hectares (44%) of oil palm plantations, some of them still growing tobecome harvestable, and 27,000 ha (33%) of “cleared area with some vegetation” which
are often planted with oil palm (Map 1). Have the Big 4 followed the MoEF Secretary
General’s order? Are they still receiving TNNP FFP and/or tainted CPO? And what about otherprotected forests? Where does the illegal FFB from Riau’s Bukit Batabuh Protection Forestgo?
In 2017, EoF also conducted investigations into chains of custody originating in illegal oilpalm plantations in two areas in another conservation hotspot in central Sumatra, Bukit
Tigapuluh landscape23 (Map 2):
 Bukit Batabuh Tiger Corridor and nearby Forest Areas24, and Expired selective logging concession area of PT. Hatma Hutani.

Map 1.—Land covers identified by RETN in Tesso Nilo National Park in 2017. Some of the“Cleared area with some vegetation” zones also have some young oil palms though not wellmanaged. Harvestable age is considered higher than normal (5 instead of 3) because growthof palms in many areas is not uniform and some farmers wait until all trees are ready to be
harvested.

6 | EoF (June 2018) Enough is Enough.

Tesso Nilo
ecosystem

Bukit
Tigapuluh
landscapeMap 2.—Deforestation history in and around the study areas where EoF conductedinvestigations in 2017 (with names in red text) or previous years (names in black text).
Box 1. All oil palm plantations inside protected areas like TNNP and the Government’s“Forest Estate”, are considered illegal. Transactions of FFB originating from them areconsidered illegal and anyone involved in the transaction process could face criminal
charges in Indonesia. Relevant letters of Law No. 18/2013 “The Prevention and Eradicationof Forest Destruction” 25 on development of oil palm plantations in Forest Areas andtransaction of products from such plantations26 state:
Chapter IV Eradication of Forest Destruction,
Part Two Provisions on Forest Destruction Acts,
Article 17(2) Anybody is banned from:b. conducting plantation activities in forest area without a permit from the Minister;e. buying, marketing and/or processing plantation products from plantation activities inforest area without a permit.
Chapter X Crime Provisions,
Article 92(1) Anybody who knowingly:
a. conducts plantation activities without a permit from the Minister in forest area asreferred to in Article 17 paragraph (2) letter b; and/or
b. brings heavy duty equipment and/or other equipment commonly used or believed to
be used to conduct plantation activities and/or transport plantation products in forest area
without a permit from the Minister as referred to in Article 17 paragraph (2) letter a shallbe sentenced to a minimum of 3 (three) years and a maximum of 10 (ten) years in jailand be fined a minimum of Rp1,500,000,000.00 (one billion, five hundred million rupiah)
and a maximum of Rp5,000,000,000.00 (five billion rupiah).
Article 93(3) Any corporation:c. buys, markets and/or processes plantation products from plantation activities in forest
area without a permit as referred to in Article 17 paragraph (2) letter e shall be sentenced
to a minimum of 5 (five) years and a maximum of 15 (fifteen) years in jail and be fined aminimum of Rp5,000,000,000.00 (five billion rupiah) and a maximum of
Rp15,000,000,000.00 (fifteen billion rupiah).

7 | EoF (June 2018) Enough is Enough.

INVESTIGATION FINDINGS
1. Tracking illegally grown FFB from protected areas to CPO mills
Between January and June 2017, EoF tracked illegal FFB from production to processing.
Investigators picked up the trails of loads of FFB at their first collection points inside Tesso
Nilo National Park, Bukit Batabuh Protection Forest and its adjacent Forest Area in Riau
Province and ex PT. Hatma Hutani selective logging concession in Jambi Province andcontinuously documented their routes until they entered CPO mill gates. Illegally grown FFB
was bought by (Appendix 1 and Table 1, Table 2):● PT. Citra Riau Sarana 2 mill. The company is a repeat offender. Its three mills had
been found to purchase illegal FFB from TNNP in 2011, 201227 and 201528. In 2017, thecompany’s 2 mill was found to receive three separate supplies of illegal FFB from TNNP
between 11-13 June. Wilmar Plantation Limited, a direct wholly-owned subsidiary of
RSPO member Wilmar International Limited, disposed of its entire 95% equity interestin PT. Citra Riau Sarana to "Team Ventures Investments Limited" in December 201429
after EoF (2013) revealed that the company bought illegal FFB.
● PT. Inti Indosawit Subur (RGE/Asian Agri) Ukui 1 mill. The company is a repeat
offender. Its Ukui 1 and Ukui 2 mills had already been found to purchase illegal FFB
from TNNP in 2011, 201230 and 201531.
● PT. Makmur Andalan Sawit and PT. Gemilang Sawit Lestari mills. They are repeat
offenders, found to buy illegal FFB from Tesso Nilo National Park in 201532. They are
non-branded, so-called independent mills without their own plantations.
● PT. Sawit Mas Nusantara is a non-branded independent mill which started to operate
in 2016. It was found to receive three separate supplies of illegal FFB from TNNP
between 15 and 17 June.
● PT. Fortius Wajo Perkebunan and PT. Persada Alam Jaya in Jambi Province are
non-branded independent mills.
Interestingly, RGE reports that its implicated PT. Inti Indosawit Subur Ukui 1 mill had 100%
traceability for FFB supplies between January 2014 and September 2015 while random
investigations by EoF found the mill to purchase illegal FFB from TNNP twice, between 2223 January and 14 April 201533. This points to a serious flaw in RGE’s traceability work andits definition of “FFB traceable”: RGE requires such very limited data on the actual plantation
areas (Appendix 3) that they cannot possibly verify legality or environmental and otherimpacts of the actual FFB production sources.
Wilmar requires even less data than RGE for a supply to be considered source traceable.
For agents, they don’t even ask GPS locations of FFB sources (Appendix 3). In 2013, Wilmar
wrote that “Wilmar will create transparent sourcing networks with full traceability. […] These
commitments will apply to all subsidiaries, refineries, mills that Wilmar owns, manages orinvests in, regardless of stake and all third-party suppliers we purchase from or with whom
we have a trading relationship […] we expect suppliers to be fully compliant with allprovisions of this policy by December 31, 2015.”34 However, Wilmar has missed the deadline
by a wide margin and still does not know FFB sources for most of the CPO processed bytheir downstream facilities35. The company also failed to answer EoF’s request for data on
the percentage of third party supplies they receive. The group has not published a new
deadline for achieving full FFB traceability and seems to be moving away from the FFB
traceability objective, saying: “Obtaining traceability information to farm or plantation level
can therefore be highly resource intensive in terms of man-hours and cost. Traceability
information, by itself, does not address environmental and social issues. Moreover, thedefinition of 'traceable to plantation', or 'fresh fruit bunch (FFB) traceability', is also a subject

8 | EoF (June 2018) Enough is Enough.

of considerable debate. We believe resources are more effectively utilised in supporting thetransformation of mills and their supply bases towards responsible practices36”.
Clearly, that is not working. In response to the EoF report (2016), Wilmar wrote that it
continued to guide and monitor PT. Citra Riau Sarana sourcing after disposing of thecompany and its consultant TFT had found that the company enforced Wilmar’s sourcing
guidelines37. However, Wilmar’s sourcing guidelines clearly do not detect the illegally grown
FFB the company buys.
Table 1.—Supply chains of FFB, illegally grown by distinct groups of encroachers operating
inside Tesso Nilo National Park, Bukit Batabuh Tiger Corridor or its adjacent Forest Area,
and to surrounding CPO mills (see Appendix 1 for maps with the chains of custody).
CoC #FFB Seller

1
2
3
4
5
6
7
8

9
10
11

12
13
14

Encroacher
group / area /cooperative /company

Latitude

FFB Buyer

Longitude

CPO mill

Corporate
Group

Operates ownplantation?

Total
traveldistance

Chains of custody originating inside Tesso Nilo National Park
PT. Citra Riau
Toro
S0°16'19.80" E101°51'3.60"
Ex Wilmar Yes
56 km
Sarana 2
PT. Citra Riau
Toro
S0°14'35.27" E101°47'15.02"
Ex Wilmar Yes
51 km
Sarana 2
PT. Citra Riau
Toro
S0°14'27.73" E101°45'42.81"
Ex Wilmar Yes
46 km
Sarana 2
PT. Sawit Mas
Bukit Kusuma S0°7'24.70"
E101°47'21.30"
No infoNo
60 km
Nusantara
PT. Sawit Mas
Bukit Kusuma S0°7'30.80"
E101°45'35.30"
No infoNo
61 km
Nusantara
PT. Inti Indosawit RGE/Asia
Simpang Silau S0°12'46.03" E102°2'36.81"
Yes
21 km
Subur Ukui 1
n AgriPT. Makmur
Simpang Silau S0°12'40.80" E102°2'26.46"
No infoNo
54 km
Andalan Sawit
PT. Sawit Mas
Simpang Silau S0°13'42.22" E102°2'25.14"
No infoNo
145 kmNusantara
Chains of custody originating inside Bukit Batabuh Tiger Corridor or the nearby Forest Area
PT. Bagas
PT. Gemilang
S0°45'14.99" E102°3'33.46"
No infoNo
71 km
Indah Perkasa
Sawit Lestari
PT. Bagas
PT. Gemilang
S0°45'9.51"
E102°3'36.64"
No infoNo
71 km
Indah Perkasa
Sawit Lestari
PT. Runggu
PT. Gemilang
S0°51'42.77" E101°57'49.96"
No infoNo
76 km
Prima Jaya
Sawit Lestari
Chains of custody originating inside ex PT. Hatma Hutani selective logging concession
KPMMB,
PT. Fortius Wajo
Lubuk
S1°13'42.46" E102°50'46.36"
No infoNo
82 km
Perkebunan
Kambing
Sungai Ari,
PT. Persada Alam
S1°5'1.27"
E102°50'53.17"
No infoNo
13 Km
Suban Village
Jaya
PT. Alkausar
PT. Fortius Wajo
S1°15'8.31"
E102°50'44.90"
No infoNo
83 km
Afdeling VII
Perkebunan

9 | EoF (June 2018) Enough is Enough.

Dates ofinvestigation

11-12 Jun
2017
12 Jun 201712-13 Jun
2017
15-16 Jun
2017
16-17 Jun
2017
17 Jun 201718-19 Jun
2017
15-16 Jun
2017
12 Jun 201714 Jun 201713 Jun 201712-13 Jan2017
22 Feb 201725-26 Feb
2017

Photo 1.—A board and a banner at PT. Sawit Mas
Nusantara gate say: “Attention...!!! PT. Sawit Mas
Nusantara does not receive FFB from protected forest
areas, TNTN, & illegal FFB. Anyone who ignores theabove, then all the consequences of legal risk that occurs
is not the responsibility of PT. Sawit Mas Nusantara.”
Still, the company was found to buy illegal FFB fromTNTN (Tesso Nilo National Park) 3 times in June 2017.
Photos taken by Eyes on the Forest on 3 August 2017.

In summary, EoF investigations since 2011 found 22 CPO mills to receive illegal FFB fromprotected areas in Central Sumatra (Table 2). Please note that when a mill in Table 2 does
not show sourcing of illegal FFB received during a particular year, it does not mean that themill did not buy any illegal FFB that year. Nor does it mean that CPO mills who are not listed
in Table 2 have not bought any illegal FFB. Given the small scale of the investigations, EoF
believes its study identified only the tip of the iceberg. Given the widespread illegality,
combined with over capacity for refining, a general lack of FFB tracing by the industry, andthe apparent unwillingness to do so by major players like Wilmar, the majority of the world’s
palm oil supplies may be tainted with FFB illegally grown in some of the last remaining
habitats of critically endangered species like tigers, elephants, and orangutan (also see
Chapters 3 and 4).

10 | EoF (June 2018) Enough is Enough.

Table 2.—22 CPO mills found by EoF to receive illegal FFB from the Tesso Nilo complex and
the Bukit Tigapuluh landscape between 2011 and 2017. CPO mills with * are independent
mills without own plantations.
CPO mills which received illegal FFB
CPO Mill (company and mill name)Group
1 PT. Berlian Inti Mekar Rengat*
Mahkota

Year and source of illegal FFB received
ISPO
certified?
2011-201238 2012-201439 2014-201540
2017
BBTC
No
Ex PT. Hutani
No
2 PT. Citra Riau Sarana 1 (Teso Satu)
Ex Wilmar Sola Lestari
HPH
3 PT. Citra Riau Sarana 2 (Teso Dua)
Ex Wilmar TNNP
TNNP
No
4 PT. Citra Riau Sarana 3 (Teso Tiga)
Ex Wilmar TNNPTNNPNoEx PT.
No
5 PT. Fortius Wajo Perkebunan*
No info
Hatma
Hutani HPH
TNNP,
No
6 PT. Gemilang Sawit Lestari*
Anugrah
TNNP
Forest Area
near BBTC
7 PT. Inti Indosawit Subur Ukui 1
RGE
TNNP
TNNP
TNNP
Yes41
8 PT. Inti Indosawit Subur Ukui 2
RGE
TNNP
Yes42
9 PT. Makmur Andalan Sawit*
No info
TNNP
TNNP
No
Ex PT. Siak
Yes43
10 PT. Mitra Unggul Pusaka Segati
RGE
Raya Timber
HPH
11 PT. Peputra Supra Jaya
No info
TNNP
NoEx PT.
No
12 PT. Persada Alam Jaya*
Hatma
Hutani HPH
13 PT. Putera Keritang Sawit*
No info
BBTC
No
14 PT. Rigunas Agri Utama Bungo TeboRGE
Ex Dalek
Yes44
15 PT. Rigunas Agri Utama Peranap
RGE
BBTC
Yes45
16 PT. Sawit Mas Nusantara*
TNNP
No
17 PT. Sugih Riesta Jaya*
No info
BBTC
No
18 PT. Sumbar Andalas Kencana Muara Timpeh Incasi Raya
BBTC
No
19 PT. Swakarsa Sawit Raya
No info
TNNP
No
20 PT. Tri Bakti Sarimas 1 (Bukit Bayung)SarimasBBTC
Yes46
21 PT. Tri Bakti Sarimas 2 (Ibul)
SarimasBBTC
Yes47
22 PT. Wana Jingga Timur
Darmex
BBTC
Yes48
#

11 | EoF (June 2018) Enough is Enough.

2. Tracking CPO tainted with illegally grown FFB
Between March and August 2017, EoF also tracked CPO trucks from the 7 mills identified ashaving received illegal FFB between January and June (Table 1) and documented theirroutes continuously to their destinations (Appendix 2 and Table 3). Tainted CPO wastransported to three repeat offenders and one additional facility:● RSPO member49 Wilmar International Limited’s integrated manufacturing Kawasan
Industri Dumai complex in Pelintung in Riau, where PT. Wilmar Nabati Indonesia
Pelintung and PT. Wilmar Bioenergi Indonesia are based. Trucks with tainted CPO
were found to enter this complex in 2011 50 and 2015 51 . This year, tainted CPO
originating from PT. Citra Riau Sarana 2 mill was found to enter the complex.
● Another RSPO member52 of RGE53, Apical’s AAA Oil & Fats Pte. Ltd. facility in Riau,
where PT. Sari Dumai Sejati and PT. Cemerlang Energi Perkasa are based. Trucks
with tainted CPO were found to enter this complex in 201554. This year, the facility was
found to receive tainted CPO originating from two non-branded mills, PT. Makmur
Andalan Sawit and PT. Sawit Mas Nusantara.
● A bulking station of Sumber Kencana (SK) Group. Trucks with tainted CPO were
found to enter this complex in 201355 and 201556. This year, the facility was found again
to receive tainted CPO originating from RGE’s PT. Inti Indosawit Subur Ukui 1 mill andtwo non-branded mills, PT. Gemilang Sawit Lestari and PT. Fortius Wajo Perkebunan(Jambi Province). SK Group’s website which was active until October 2017 claimed
companies like Astra, Cargill, Darmex, Musim Mas, RGE, Salim, Sarimas and GAR groups
as its customers57. Unless SK diligently segregated all the CPO its trucks and barges
transported by plantation source, it may have shipped CPO contaminated by illegallygrown FFB to its customers. GAR was found to use this company in the past and wrote
to EoF (18 January 2016): “SK Group provides storage services for two of GAR’s mills
under terms that GAR oil has to be segregated from oils owned by other parties. Thisrequirement was established in response to the findings in the EoF “Tiger in the Tank”
report in 2014”.
● A refinery of CV. Perintis Lintas Talang Duku, Pelita Group in Jambi Province.
Table 3.—Supply chains of CPO tainted with FFB illegally grown inside the two investigatedareas.
CoC#

CPO mills confirmed tohave received illegallygrown FFB

CorporateGroup

Final destination: refinery / port

Corporate
Group

1

PT. Citra Riau Sarana 2

Ex Wilmar

PT. Wilmar Nabati Indonesia
Pelintung & PT. Wilmar
Bioenergi Indonesia

Wilmar

PT. Inti Indosawit Subur
Ukui 1
PT. Makmur Andalan
Sawit

RGE/AsianAgri

PT. Sumber Kencana

SK

PT. Sawit Mas Nusantara

No info

2
3
4
5
6
7

PT. Gemilang Sawit
Lestari
PT. Fortius Wajo
Perkebunan
PT. Persada Alam Jaya

No info

PT. Sari Dumai Sejati & PT.
Cemerlang Energi Perkasa
PT. Sari Dumai Sejati & PT.
Cemerlang Energi Perkasa

RGE/Apical
RGE/ApicalNo info

PT. Sumber Kencana

SK

No info

PT. Sumber Kencana

SK

No info

CV. Perintis Lintas Talang
Duku

Pelita12 | EoF (June 2018) Enough is Enough.

District /Province

Dates ofinvestigation

Kotamadya
Dumai / Riau

29-30 July
2017

Indragiri Hilir,
Riau
Kotamadya
Dumai / Riau
Kotamadya
Dumai / Riau
Indragiri Hilir,
Riau
Indragiri Hilir,
Riau / Jambi
Muaro Jambi /Jambi

4 August
2017
31 July – 1
August 2017
7-8 August
2017
28 July 201716 Mar 201717-18 Mar2017

3. Exposure of the Big 4 to tainted CPO – company commitments versus
reality
The Big 4 have been trying to reach 100% traceability of CPO for their downstream facilities(refineries, bulking stations, etc.) and publish regularly updated supply chain data, including
lists of CPO suppliers per facility, on their web pages:● Wilmar: http://www.wilmar-international.com/sustainability/supply-chain-map/● GAR: https://goldenagri.com.sg/sustainability-dashboard/supply-chain-map● RGE/Apical: http://www.sustainability.apicalgroup.com/supply-chain-map/● Musim Mas: http://www.musimmas.com/sustainability/traceable-supply-chain/supplychain-map
EoF appreciates the transparency of the companies who published some of their supply
chains and hopes that its investigation will help them to eliminate FFB produced illegally orin violation of zero deforestation commitments at plantation level from their supply chains.
EoF checked the CPO tracing data of the Big 4’s Indonesian downstream facilities andcompared it to its own findings of illegal FFB supply chains between January and June 2017
(Table 1) and tainted CPO supply chains between March and August 2017 (Table 3). The
results (Table 4) show that:● The seven mills identified by EoF to purchase illegal FFB between January and June 2017supplied CPO to 7 facilities of the Big 4 for the data periods up to June 2017.
● In the subsequent months July-August 2017, Wilmar and RGE/Apical facilities were
found by EoF to buy CPO from three out of the seven mills.
● RGE/Apical’s own CPO tracing data up to June 2017 show it purchased tainted CPO from
6 out of the 7 mills, including two implicated mills in Jambi Province.
● None of the CPO trucks that EoF investigators followed entered GAR and Musim Mas
facilities, however, their own mill traceability data show that three of their facilities
purchased CPO from three mills combined.
Table 4.—Downstream facilities of the Big 4 which purchased CPO from the seven CPO mills
identified by EoF to purchase illegal FFB in January - June 2017 (Table 1).
#

CPO mill

Source of illegal
FFB

CompanyGroup

PT Citra Riau
Sarana 2
PT Gemilang
Sawit LestariEx
WilmarNo info

PT Inti Indosawit
Subur Ukui 1 mill
PT Makmur
Andalan Sawit

Asian
Agri
No info

5

PT Sawit Mas
Nusantara

No info

Tesso Nilo NP

6

PT. Fortius Wajo
Perkebunan
PT. Persada AlamJaya

No info

Ex. PT. Hatma
Hutani HPH
Ex. PT. Hatma
Hutani HPH

1
2

3
4

7

No info

Tesso Nilo NP
Tesso Nilo NP,
Bukit BatabuhProtection Forest
Tesso Nilo NP

Refineries or bulking stations of the four groups which buy CPO fromthe mills which were found to purchase FFB from Tesso Nilo National
Park
Wilmar58 (data GAR59 (data period:
Apical60
Musim Mas61
period: Jul
Apr-Jun 2017)(data(Jan-Jun
2016 – Junperiod: Apr2017)2017)
Jun 2017)
WNI Dumai,
WNI Pelintung
Sari Dumai
IBP Lubuk
Sejati, CET Gaung62

Tesso Nilo NP

Dumai Bulking
Station, Lubuk
Gaung Refinery
WNI Dumai,
WNI Pelintung

13 | EoF (June 2018) Enough is Enough.

Dumai Bulking
Station, Lubuk
Gaung Refinery

Sari Dumai
Sejati, CET
Sari Dumai
Sejati, CET
Sari Dumai
Sejati
Sari Dumai
Sejati
Sari Dumai
Sejati

IBP Lubuk
Gaung

For the Big 4’s seven downstream facilities who were supplied by the seven implicated CPO
mills in 2017 (Table 4), the latest CPO and FFB tracing data published by the Big 4 let EoF
conclude that all except GAR’s Dumai bulking station (Table 5):● Receive the majority (45% to 88.77%) of their CPO supplies from third party mills,
apparently because of over-capacities in their refining operations.
● Trace FFB only with low intensity. They do not properly verify compliance with theirlegality and zero deforestation policy for their “FFB traceable” third party supplies, as
the companies clearly do not ask the right questions about the sources of FFB (Chapter
1, Appendix 3).
● Have only a minority of their CPO supplying mills RSPO certified.
Table 5.—Status quo of CPO and FFB traceability of the seven downstream facilities of the
Big 4 which purchased CPO from the seven CPO mills who were identified by EoF to purchaseillegal FFB between January and June 2017 (Data sources: the same supply chain maps
quoted in Table 4).
# of suppliers (% total supply)Group

Facility

WilmarWilmarGARGAR
RGE

WNI Dumai
WNI Pelintung
Dumai
Lubuk Gaung
Sari Dumai
SejatiCET
IBP Lubuk
Gaung

RGE
Musim
Mas

% CPO
traceable
to mill% CPO
traceable toplantation

95.7%
98.2%
100%
100%

# of
RSPO
CertifiedMills

Own mill

3rd party millOwn
refineries

20.0%
18.2%
55%
23%

8 (18.8%)
18 (15.1%)
6 (55%)
18 (24%)86 (63.6%)
147 (63.4%)
44 (45%)70 (76%)5 (17.5%)5 (21.2%)
0 (0%)
0 (0%)

Others(refiners/
traders/
bulkers)
0 (0%)
2 (0.3%)0 (0%)
0 (0%)

97.51%

No info.

20 (11.23%)

160 (88.77%)

0 (0%)

0 (0%)

23

98.88%

No info.

20 (46.99%)

108 (53.01%)

0 (0%)

0 (0%)

22

100.00%41.1%

6 (18.00%)

116 (81.00%)

1 (2.00%)

0 (0%)

21

6
19
7
28

The implications for global buyers of palm oil from companies who do not identify and rejectillegal FFB at the CPO mill gate and indiscriminately continue to feed CPO from such mills
into refineries become clear once the flows of CPO and refined products are mapped (Figure1). EoF compiled:
A. all illegal FFB and tainted CPO chains of custody WWF and EoF verified on the groundsince the first investigation in July 2011, andB. additional flows of CPO from the 22 implicated CPO mills (Table 2) to Big 4’s downstream
facilities based on the lists of supplier mills published by the Big 4.
The data (Figure 1) show that Big 4 palm oil supplies are much more contaminated by thetrade of CPO tainted by illegal FFB than the few random EoF investigations suggest.
Considering the deeply penetrating contamination of Big 4 supplies just from EoF’s
investigation of two small conservation areas in Sumatra suggests how huge the problem
really may be if FFB and CPO flows from more conservation areas in the country were
investigated63.
The data on CPO flows collected by the Big 4 could easily be used by them to identify theirfacilities’ exposure to illegal and deforestation linked products - if the companies would
evaluate the legality and sustainability of the FFB supplied to each CPO mill that they source
from. Unfortunately, companies appear reluctant to do so.

14 | EoF (June 2018) Enough is Enough.

Figure 1.—Chains of custody (CoC) of illegal fresh fruit bunches (FFB) and tainted palm oil (PO) identified since 2011 in WWF and EoF
field investigations originating in Tesso Nilo ecosystem and Bukit Tigapuluh landscape (solid lines) and additional PO CoC based on
published data on CPO suppliers to the Big 4’s downstream facilities (dotted lines).
15 | EoF (June 2018) Enough is Enough.

4. Exposure of other major global palm oil traders/users to tainted CPO

Table 6.—Global palm oil traders/users who published their palm oil supplying mills.
Company
who
Direct PO suppliers disclosed by the
Period and coverage of the PO supplier mill data
publishedcompany
checked by EoF to produce Figures 2 - 8
PO suppliermill list
AAK
No data
Unspecified time/period64.
ADM /No data
July 2016 – September 2017 supplier list for ADM
OlenexGlobal, Europe, North America and Olenexfacilities65
Bunge &
There is no information on direct suppliers 2017 Q3 supplier list for Bunge68 and the 2017
Bunge
for Bunge66. Direct suppliers for Bunge
Q1-Q4 supplier list for Bunge Loders Croklaan69.
LodersLoders Croklaan include Apical, Cargill,
The lists for Bunge Loders Croklaan include data
Croklaan
GAR, ICOF of Musim Mas and Wilmar67.
on direct suppliers who sourced from them, but
the list for Bunge does not.
Cargill
No data“List of mills in Cargill’s supply chain of the pastquarter”70, but not dated.
ColgateIt’s largest suppliers for PO and PKO are2017 list72. The list includes data on direct
Palmolive
Wilmar, Sime-Darby/Morakot, Cargill andsuppliers who sourced from them.
ADM71.
General
As of December 31, 2017, it’s direct PO
The “most recent list of mills supplying our directMills
suppliers include AAK, ADM, Bunge,
suppliers”74, 75, but not dated. The list includes
73
Cargill, Fuji Oil and Loders Croklaan .
data on direct suppliers who sourced from them.
Kellogg’s
No data
Full year of 201776
Mars
It’s top 6 suppliers covering 80% of palm
2016 suppliers list79. The list does not include data
volume are Cargill, IOI77, AAK, Fuji, Olenex on direct suppliers.
and Wilmar78.
Mondelēz
It’s “continuing suppliers” include AAK,
Suppliers list of unspecified time81. The list
Apical, Bunge, Cargill, IOI, Fuji Oil, Sime
includes data on direct suppliers who sourced
Darby and Wilmar80.
from them.
Neste
No data
Suppliers during part or all of 201682
Nestlé
It’s direct suppliers include AAK, ADM,
November 2017 snapshot of direct (Tier 1)
Bunge Loders Croklaan, Cargill, Fuji Oil,suppliers and their palm oil supplier mills84. The
PT. Smart Tbk Marunda, Sime Darby andlist includes data on direct suppliers who sourced
Wilmar83.
from them.
Olam
Direct suppliers include Apical, GAR, Sime 2016 & 2017 list86. The list includes data on direct
Darby and Wilmar85.
suppliers who sourced from them.
87
PepsiCo
It’s 39 direct suppliers include Wilmar .
2017 list does not include direct suppliers info88.

FigureEoF greatly appreciates that an increasing number of major global companies have begun
publishing some of their supply chain data. EoF evaluated the lists of palm oil supplying
mills recently published by some of the major palm oil traders / users with zero deforestationcommitments (Table 6) to check whether the 22 CPO mills which have received illegal FFB(Table 2, Figure 1) are among their suppliers.

2a
2a

2b

2a
2c

2d

2a
2a

2e

2a
2f

2g
2a

Proctor &Gamble6 direct suppliers of PO and PKO are AAA,
FGV, GAR, KLK, Musim Mas and Wilmar89.

2017 palm and palm kernel oil supplier mill list90.
The list does not include data on direct suppliers.

2a

Reckitt
Benckiser

In 2017 it’s direct suppliers of palm oilderived soap noodles included IOI
Oleo, Musim Mas, Unilever and Wilmar
International (includes Wilmar China
and Adani Wilmar)91.

2007 supplier list92. The list does not include dataon direct suppliers.

2aUnileverMore than 300 direct suppliers aredisclosed93.

2017 supplier list94. The list does not include dataon direct suppliers.

2a

16 | EoF (June 2018) Enough is Enough.

EoF found that (Figures 2a – 2g):
● All companies bought directly or indirectly from at least some of the 22 implicatedmills. None appear to have bought from PT. Wana Jingga Timur’s CPO mill. This new
analysis shows more than ever what EoF predicted in 2016: “No one is safe” fromsupplies tainted by illegal product (Figures 2a-2g).
● Bunge Loders Crocklaan, Colgate-Palmolive, General Mills, Mondelēz, Nestléand Olam published direct suppliers and supplying CPO mills together (Figures 2b-2g).
They bought from the implicated mills via their direct suppliers including: AAK, ADM,
Apical of RGE, Cargill, Bunge Loders Crocklaan, Fuji Oil, GAR, ICOF of Musim
Mas, IOI, Louis Dreyfus, Sime Darby Plantation and Wilmar.
● Supply chain transparency varied greatly between companies. Some miss-spelledcompany and mill names. Some mills were only identified by location without company
names (e.g. only “Ukui I” instead of “PT. Inti Indosawit Subur Ukui I mill”). As a result,
we listed some “likely CPO supply chains” shown as red dotted lines in some Figures.
They, as all the data in this analysis need to be verified by the companies and EoF will
be happy to update the information.
EoF hopes that this analysis will help untangle the complex web of palm oil supplies acrossthe globe, identify policy and legal compliance issues, and encourage companies to work
together to solve the issue of continuing deforestation and pumping of illegal, unsustainablepalm oil into the global economy once and for all. EoF also hopes that more companies will
publish their supply chain data.

Natural forest in the Bukit Tigapuluh landscape. Can we save the last remaining lowland
forest in central Sumatra? © Neil Ever Osborne / WWF-US.

17 | EoF (June 2018) Enough is Enough.

Figure 2a.—Direct or indirect palm oil supplies to AAK, ADM, Cargill, Kellogg’s, Mars, Neste, PepsiCo, P&G, RB and Unilever fromsome of the 22 CPO mills which WWF and EoF field investigations since 2011 found to have purchased, sometimes repeatedly, illegal fresh
fruit bunches (FFB) originating in the Tesso Nilo ecosystem and Bukit Tigapuluh landscape (Table 2, Figure 1).
18 | EoF (June 2018) Enough is Enough.

Figure 2b.—Palm oil supplies to Bunge and Bunge Loders Croklaan from some of the 22 CPO mills which WWF and EoF field
investigations since 2011 found to have purchased, sometimes repeatedly, illegal fresh fruit bunches (FFB) originating in the Tesso Nilo
ecosystem and Bukit Tigapuluh landscape (Table 2, Figure 1).
19 | EoF (June 2018) Enough is Enough.

Figure 2c.—Palm oil supplies to Colgate-Palmolive from some of the 22 CPO mills which WWF and EoF field investigations since 2011
found to have purchased, sometimes repeatedly, illegal fresh fruit bunches (FFB) originating in the Tesso Nilo ecosystem and Bukit
Tigapuluh landscape (Table 2, Figure 1).
20 | EoF (June 2018) Enough is Enough.

Figure 2d.—Palm oil supplies to General Mills from some of the 22 CPO mills which WWF and EoF field investigations since 2011 foundto have purchased, sometimes repeatedly, illegal fresh fruit bunches (FFB) originating in the Tesso Nilo ecosystem and Bukit Tigapuluh
landscape (Table 2, Figure 1).
21 | EoF (June 2018) Enough is Enough.

Figure 2e.—Palm oil supplies to Mondelēz from some of the 22 CPO mills which WWF and EoF field investigations since 2011 found tohave purchased, sometimes repeatedly, illegal fresh fruit bunches (FFB) originating in the Tesso Nilo ecosystem and Bukit Tigapuluh
landscape (Table 2, Figure 1).
22 | EoF (June 2018) Enough is Enough.

Figure 2f.—Palm oil supplies to Nestlé from some of the 22 CPO mills which WWF and EoF field investigations since 2011 found to havepurchased, sometimes repeatedly, illegal fresh fruit bunches (FFB) originating in the Tesso Nilo ecosystem and Bukit Tigapuluh landscape(Table 2, Figure 1).
23 | EoF (June 2018) Enough is Enough.

Figure 2g.—Palm oil supplies to Olam from some of the 22 CPO mills which WWF and EoF field investigations since 2011 found to havepurchased, sometimes repeatedly, illegal fresh fruit bunches (FFB) originating in the Tesso Nilo ecosystem and Bukit Tigapuluh landscape(Table 2, Figure 1).
24 | EoF (June 2018) Enough is Enough.

5. Can RSPO certified products offer a solution?
Currently, RSPO is considered the most credible certification available for sustainable palm
oil95. However, we need to keep in mind that RSPO certification is not a proof of compliancewith individual corporate zero deforestation pledges as RSPO’s Principles and Criteria in theircurrent form do not assure total avoidance of deforestation.
RSPO writes: “To ensure the credibility of the sustainability claim at the end of the supply
chain, all organizations that take legal ownership and physically handle RSPO certified
sustainable oil palm products need to be supply chain certified. Transparency and credibility
are assured through RSPO Supply Chain Certification [SCC] and RPSO Principles and Criteria
Certification”96. However, EoF (2016) highlighted that RSPO’s Supply Chain Standard only
covers operations downstream from the CPO mill but not upstream from the mill toplantations or to independent producers97. The RSPO Principles and Criteria for Growers
only cover the supply-shed controlled by the company, but not third-party sources.
Our 2017 investigation found that: Of the 22 CPO mills who were found to purchase illegal FFB since 2011 (Table 2), PT.
Inti Indosawit Subur and PT. Tri Bakti Sarimas are RSPO members.
 Only four of the 22 implicated CPO mills are certified against the RSPO P&C and RSPO
Supply Chain Certification November 2014 for CPO Mills and all are RGE/Asian Agri mills:
PT. Inti Indosawit Subur’s Ukui I mill (Mass Balance) 98 and Ukui II mill (Identity
Preserved) 99 and PT. Rigunas Agri Utama’s Peranap mill (Mass Balance) 100 and Bungo
Tebo mill (Mass Balance)101.
 Some of the implicated downstream facilities (Tables 3 and 4 and Figure 1) hold RSPO
Supply Chain Certificates (Table 7).
In purchasing palm oil from these facilities, EoF recommends buyers, who do not want tobe exposed to the legal risks of knowingly dealing with tainted CPO, to: Purchase only palm oil certified by RSPO’s “Identity Preserved (IP)” or “Segregated(SG)” Supply Chain Models for which only CPO made from FFB from known and certified
sources qualifies. However, buyers may want to take this a step further and verify
compliance against their own zero deforestation commitments as current RSPO P&C do
not fully ensure that.
 Alternatively, purchase POIG verified oil, which precludes RSPO certified palm oil that
may be linked to deforestation.
Currently, RSPO does not have a standard and certification system to verify the origins,
legality and sustainability of any FFB used to produce the non-certified oil which is mixed
with RSPO Certified Sustainable Palm Oil (CSPO) in Mass Balance certified products and“Book & Claim”. The latter does not ensure the presence of CSPO in addition, so theoretically“Book & Claim” oil could be based on 100% illegal/unsustainable FFB as RSPO’s systems
currently do not detect it. Until RSPO inserts checks and balances on the uncertified oil
within both “Mass Balance” and “Book & Claim” products, buyers of these products arerecommended to verify themselves the legality and compliance with their own zerodeforestation commitments of the uncertified oil.
Our analysis of supplier lists published by global traders and users (Chapter 4) found that: Neste writes: “All crude palm oil used by Neste has been fully traceable all the way tothe plantation level since 2007, and 100% certified since 2013.102 ” In 2016, Nestebought CPO from three RGE/Asian Agri mills (PT. Inti Indosawit Subur’s Ukui I and Ukui
II mills and PT. Rigunas Agri Utama Peranap mill, Figure 2a)103. The non-certified portion

25 | EoF (June 2018) Enough is Enough.



of the RSPO Mass Balance oil purchased from PT. Inti Indosawit Subur Ukui I and PT.
Rigunas Agri Utama Peranap mill is not fully traceable and could be tainted with
deforestation.
Bunge Loders Croklaan data shows that it’s Rexdale, Rotterdam and Wormerveer
facilities purchased RSPO “Identify Preserved” palm oil from PT. Inti Indosawit Subur
Ukui I mill via Apical and Wilmar in 2017, however, Ukui I mill is only certified withRSPO Mass Balance. Given that its sister mill Ukui II is certified with “Identity Preserved”
this may have been a data glitch.

Considering the above and that RGE’s FFB traceability is seriously flawed and the PT. Inti
Indosawit Subur is a repeat offender (Chapter 1), we recommend Neste and Bunge to work
closely with RGE/Asian Agri to make necessary improvements of their mills’ sourcing
practices and traceability work.
Table 7.—RSPO SCS holders involved in the trade of tainted CPO (see Tables 3 and 4,
Figure 1).
Group
Company
Certificate validity period
Supply chain
model
Wilmar
PT. Wilmar Nabati Indonesia, Pelintung refinery
19/08/2014 – 18/08/2019104
SG, MBWilmar
PT. Wilmar Bioenergi Indonesia
19/08/2014 – 18/08/2019105
SG, MBWilmar
PT. Wilmar Nabati Indonesia, Rengat bulking station
No certificate
Wilmar
PT. Wilmar Nabati Indonesia, Dumai refinery
08/12/2016 – 07/12/2021106
SG, MBWilmar
PT. Wilmar Nabati Indonesia, Padang refinery
29/05/2015 – 28/05/2020107
MB
108
RGE/Apical PT. Sari Dumai Sejati refinery
30/08/2017 – 29/08/2022
IP, SG, MB
RGE/Apical PT. Cemerlang Energi Perkasa
No certificate109
RGE/Apical PT. Asianagro Agungiaya, Marunda refinery
16/05/2017 – 15/05/2022110
MB
GAR
Incasi Raya bulking station in West Sumatra, rented
No certificate
by PT. Leidong West Indonesia
GAR
PT. Ivo Mas Tunggal, Dumai bulking station
06/06/2014 – 05/06/2019111
SG, MBGAR
PT. Ivo Mas Tunggal, Lubuk Gaung refinery
30/03/2016 – 29/03/2021112
SG, MBGAR
PT. SMART Tbk. Belawan refinery
08/10/2013 – 07/10/2018113
SG, MB
114
Musim Mas PT. Inti Benoa Perkasatama Lubuk Gaung refinery
08/07/2014 – 07/07/2019
IP, SG, MB
SarimasPT. Agro Sarimas Indonesia harbour
No certificate
DarmexPT. Duta Palma
No certificate
SK
PT. Sumber Kencana
No certificate
SIPEF
PT. Agro Muko Tank Terminal
No certificate
Pacific Inter- PT. Pacific Indopalm Industries refinery
19/06/2014 – 18/06/2019115
MB
Link
PelitaPT. Perintis Lintas Talang Duku
No certificate

26 | EoF (June 2018) Enough is Enough.

6. FFB agents - the weakest points in supply chains: the case of Tesso Nilo
In June 2017, EoF identified 21 small agents and 13 big agents distributing (buying andselling) FFB in and around TNNP (Map 2). In principal, agents collect FFB from plantationsof various sizes, ages, owners and legality and sell it to CPO mills. Agents can be divided
into two types:● Small agents, who usually are residents living in areas near FFB collection points which
receive the FFB from plantations inside TNNP. They collect 7-10 tons of FFB per day andsell it either directly to CPO mills or to big agents.
● Big agents, who usually come from locations outside TNNP, have a lot of capital invested
in their operations, operate trucks for FFB transport, have a security apparatus to protect
their business, and operate FFB collection points with their own truck scales (weight
bridges) that are quite far from the actual plantations. They may collect 40 tons of FFB
per day and sell it directly to CPO mills.

Map 2.—Locations of FFB distributors identified by EoF’s June 2017 survey inside andaround Tesso Nilo National Park.

EoF observed that nearly all FFB harvested in TNNP were brought to FFB collection points ofsmall or big agents, mixed with other FFB there, and then sent to CPO mills. The furthest
distance EoF found trucks with illegal FFB to drive was 145 km. EoF observed that agentsuse different routes, drivers and vehicles to reach CPO mills. The findings show that agentsknow about the illegality of the FFB they trade and try to obscure its origin before delivering
it to the mills.
These observations highlight the critical importance for CPO mills to trace the real origins
of FFB delivered by agents so that illegally and unsustainably produced/harvested FFB can

27 | EoF (June 2018) Enough is Enough.

be identified and rejected. Current efforts do not seem to make a difference. FFB traceability
data required from “Dealers” (agents) by Apical and Wilmar are not sufficient (Chapter 1,
Appendix 3). Wilmar’s current approach to tracing its supplies back to the plantation level
does not even require agents to report “GPS” or “planted area” of the FFB they supply.
Anything is possible. And with more and more illegal FFB coming online, with illegal growers
unable to easily sell their product at market prices, with agents trying to find as much andas cheap FFB as possible to increase their margins and employing simple tricks to hide theorigin of their illegal FFB, and with mills reluctant to reject illegal FFB or even put strong
measures into place to identify it because they need to fill their FFB supply gaps, thelikelihood of agents delivering illegal and/or unsustainable FFB is high.
EoF investigations and the rapid increase in the number of so-called independent mills areindications that the industry’s over capacity for refining CPO has increased operators’
reliance on third party producers and agents to fulfill both FFB and CPO demands. Agentsand third-party suppliers are the weakest points in the system and the Big 4 state they are
not even aware of the percentage of third supplies in their systems (Table 8). Without the
Big 4 truly committing to no longer buy and sell illegal product and establish fool proof
systems to achieve 100% FFB traceability for all their supply chains to ensure that, without
the Big 4 committing to expand their capacities according to the availability of legal FFB andCPO they can control, rather than the vast quantities of illegal FFB and CPO floating in themarket, they will continue to deliver illegal product to the world, and their commitments toconservation and zero deforestation policies will sound ever more hollow as their CEOs battle
for position in Forbes’ list of palm oil billionaires. The companies have to invest into legality
and they are clearly not doing enough.
Table 8.—CPO refined by Big 4 produced with FFB from third party plantations, based on
responses to a request by EoF to provide data and references listed.
Overall FFB
Total CPO refined by own
traceability
downstream facilities in# of own
achieved for theIndonesia and Malaysia,
downstream
Total CPO refined by own
total CPO refined
which is produced by own orGroupfacilities refining
downstream facilities inby ownthird party CPO mills from
CPO in Indonesia Indonesia and Malaysia in 2017
downstream
FFB from third party
and Malaysia.
facilities inplantations in 2017
Indonesia and(MT/year)
Malaysia in 2017
GAR
answered
that
it
does
GAR
6 in Indonesia116 4.7 million MT (capacity)117
39%118
not have this figure yet.
18.2 million MT (capacity)120.
Wilmar data on supplies andshipments for 2017 writes that
11 in Indonesia, 8.54 million MT and 5.69 million
WilmarNo response
No response
10 in Malaysia119 MT from its Indonesian and
Malaysian refineries,
respectively, “are traceable atleast to mills”121.
Musim
11 in Indonesia,
7.1 million MT (capacity)123
No response
53%124Mas
1 in Malaysia122
Apical responded:“Incomplete data. Not
Apical3 in Indonesia125 3.27 million MT
available as we have not
No response
achieved full traceability toplantation.”

28 | EoF (June 2018) Enough is Enough.

CONCLUSIONS & RECOMMENDATIONS
EoF’s conclusions from its 2017 investigation echo the key conclusions of is 2016 report126:● EoF’s random chains of custody investigations since 2011 found 22 CPO mills to purchaseillegal FFB harvested in the High Conservation Value areas Tesso Nilo ecosystem andBukit Tigapuluh landscape. EoF found the Big 4 - GAR, Musim Mas, RGE and Wilmar - topurchase from these mills – often repeatedly, knowing that they were implicated fromearlier EoF reports. The mills are also among the many direct or indirect suppliers ofsome of the world’s key traders/users with zero deforestation commitments, ADM,
Bunge, Cargill, Colgate-Palmolive, General Mills, Kellogg’s, Mars, Mondelēz, Neste,
Nestlé, PepsiCo, Proctor & Gamble, Rockitt Benckiser and Unilever. Some of these buyers
were found to buy palm oil from these implicated mills via their direct suppliers including
AAK, Apical, ADM, Bunge/Loders, Cargill, Fuji Oil, IOI, Sime Darby Plantation andWilmar.
● The majority of the world’s palm oil supplies may thus be tainted by FFB illegally grownin some of the last remaining habitats of critically endangered species like tigers,
elephants, and orangutan and on flammable, carbon rich peatlands in Sumatra.
● At the root of this problem is the heavy reliance by the Big 4 and many other companies
on external suppliers to fill the demands of their processing and trading facilities, withcurrent refining capacities much larger than the FFB and CPO volumes that comply withgovernment regulations and with the companies’ own zero deforestation policies.
● Lack of traceability and the common practice among the Big 4 and others to buy and sellpalm oil products to each other led to widespread contamination of the global supply
chain. Only strict identification and segregation at the source of FFB from unknown third
parties, often traded by agents, can reduce the contamination.
● The scale of the legal issues global buyers and sellers of the tainted product potentiallyface is huge, as mills and refineries that feed the tainted products into the global
economy have known about the systemic legality issues for a long time. Knowingly, they
have failed to tackle the issue trying to avoid the investments needed to clean up thesystem.
● Even today, and despite the proliferation of dashboards and annual sustainability
reports, the majority of mills and refineries do not trace the origin of their products tothird party plantations, although they know this is the only way to identify and rejectillegal FFB and tainted products. Some of the Big 4 even seem reluctant to make thistask a priority, likely because it would expose the vastness of the issue of their pumpingof illegal product into the global palm economy.
● Agents (distributors, dealers) use different ways (e.g. mixing FFB from different sources,using different vehicles, license plates or drivers) to hide the real origin, legality andsustainability issues of the FFB that they sell to CPO mills. Without a robust traceability
system, mills will continue to knowingly purchase illegal FFB.
● The risk for any CPO mill in Sumatra to purchase illegal FFB is extremely high as trucks
with illegal FFB followed by EoF travelled up to 145 km and up to 5 days until CPO millsbought their FFB. Illegal FFB followed by EoF often travelled for more than a day, morethan enough time to reach most of Riau’s almost 200 CPO mills and way beyond district
and provincial boundaries127. Considering that EoF only investigated occasionally andrandomly, these data likely show only the tip of the iceberg and seriously put into doubt
the big data based risk assessments and risk radius approaches promoted by mills andtheir consultants, and many iterations of the so-called “jurisdictional approach”. We have
known which areas are risky for a very long time, its time for the real work to stop
driving deforestation! Only tedious purchasing filters installed at the initial entry points
into the global palm economy, the CPO mills, and designed to identify FFB from illegal

29 | EoF (June 2018) Enough is Enough.

●

sources or in violation of zero deforestation commitments at plantation level can solve
this problem.
In the eighth year since Unilever made the industry’s first zero deforestationcommitment128, there is a clear need for industry and civil society to review all the supply
chain work and its real achievements on the ground and to redirect future efforts toachieve the purpose why zero deforestation commitments were ever “created”: to stop
the loss of the remaining High Conservation Value and High Carbon Stock areas, like
Sumatra’s lowland forests in Tesso Nilo and Bukit Tigapuluh.

Considering the above, EoF recommends:
To the Big 4 - Wilmar, RGE, GAR and Musim Mas:
● Prioritize “FFB traceability” (plantation to mill) and actually begin identifying andeliminating the illegal suppliers that are contaminating your whole global supply chain(agents and third-party mills) unless they change their practices.
● Improve your traceability systems to actually evaluate the legality and sustainability ofthe plantations that produce for your facilities and go beyond collecting just the minimum
information you currently do.
● Require supplier CPO mills including the 22 implicated mills highlighted by this report totrace and report their FFB sources, disclose and verify the percentages of FFB received
from owned plantations, plasma and scheme small-holders, agents and independent
growers, and engage them to evaluate the legality and sustainability of their FFB
supplies.
● Exclude suppliers that fail to make necessary improvements and continue to rely onillegal/unsustainable FFB sources, but stay engaged and work towards a solution. Restartpurchasing only when there is an independently verified proof that illegal/unsustainable
FFB sources are excluded.
● Especially Wilmar must stop buying from mills which continue to be identified by EoF as
repeat offenders even if your consultants tell you they are clean.
● Have a clear deadline, after which no supplies from agents and third parties will be
accepted following a “leave it out if in doubt” approach unless they can prove and verify
location, legality and sustainability of all their FFB sources.
● Share your supply chain data and work together as an industry to identify, reject andblacklist questionable agents and suppliers, so that illegal growers no longer have amarket for their products and cannot simply divert their products to less concerned mills,
allowing their tainted products to eventually incriminate everybody with a tainted
downstream supply chain.
● Use extra caution when considering so-called independent mills – mills without their own
plantation base – as suppliers as there will be a high potential they receive FFB fromillegally grown plantations.
● Require companies specializing in the transportation of CPO, such as SK Group, to join
your efforts by segregating supplies from different mills to prevent tainted CPO fromcontaminating supplies around the world.
● Support legally operating smallholders and independent suppliers to improve practices
and achieve RSPO certification so that they can differentiate themselves from rogue
operators.
● Address your legacy of deforestation and contribute to the restoration of protected
and/or High Conservation Value and High Carbon Stock areas you helped destroy,
including the Tesso Nilo ecosystem and Bukit Tigapuluh landscape.
● Do not divest of “toxic assets”, like Wilmar did with PT. Citra Riau Sarana and PT. Asiatic
Persada129, and invest in cleaning up such facilities so that they no longer facilitate illegal
deforestation and contaminate global supply streams. Should you have divested do not

30 | EoF (June 2018) Enough is Enough.

buy from them again but stay engaged, work towards a solution, and restart purchasing
only when there is an independently verified proof that illegal/unsustainable FFB sources
are excluded.
To global palm oil buyers downstream:● Do not ‘turn away’ but put pressure the Big 4 and other suppliers to meet the above
recommendations and collaborate with peers and WWF and key local stakeholders(NGOs, government) to find a common approach and solutions.
● Prioritize “FFB to end user” traceability through independent, accredited auditing experts
and work with WWF and key local stakeholders (NGOs, government) to ensure a legal
and sustainable palm oil supply:➢ through segregated certified palm oil based on RSPO “Identity Preserved (IP)” or“Segregated (SG)” Supply Chain Models and strengthened P&C (seerecommendations to RSPO below) or POIG, and➢ by only buying mixed oil based on RSPO “Mass Balance (MB)” or “Book & Claim”
Supply Chain Models if all uncertified oil has been independently verified byaccredited auditors for legality and compliance with your own zero deforestationcommitments.
● Support conservation and restoration of High Conservation Value and High Carbon Stockareas lost or degraded by oil palm production, including Tesso Nilo and Bukit Tigapuluh.
● Publish a comprehensive list of your CPO and FFB suppliers. Full transparency will help
clean up the sector.
To Indonesian government authorities:● Stop issuing, and revoke licenses to CPO mills that cannot prove a legal supply base.
● Stop allowing conversion of natural forest to develop new oil palm plantations.
● Enforce existing legislation and regulations and save protected areas and Forest Estatesfrom oil palm plantation development and restore natural forests and peatlands.
● Punish CPO mills and downstream facilities who purchase illegal FFB or tainted CPO
products.
● Strengthen ISPO standard and certification so the ISPO is used as a robust proof of
legality.
● Stop procurement of CPO with subsidies for biofuels by State-owned companies unlessplantation sources are verified legal and sustainable.
To RSPO and its members including companies mentioned in this report:● Strengthen RSPO Principles and Criteria (P&C) and Supply Chain Certification Systems
to ensure that:➢ RSPO certified products are legal and compliant with the most ambitious corporate
zero deforestation policies in the industry.
➢ RSPO members – including the ‘Big 4’ – are held accountable for their whole
corporate group of companies and all their supply chains including all third party
FFB and CPO suppliers to the group’s refineries, in line with RSPO’s vision to“transform markets to make sustainable palm oil the norm” and the Code of
Conduct.
➢ RSPO members progress in implementing the whole group and supply chain timebound plans towards certification and the progress is regularly audited by RSPO to
confirm this and lack of progress results in revoking of RSPO membership. Have theinformation on progress published on the RSPO website.
➢ RSPO takes strong action including revoking of membership against violations by
RSPO members of the country’s laws and regulations, RSPO P&C and Code of
Conduct, for example in cases where associated facilities accept illegal FFB and

31 | EoF (June 2018) Enough is Enough.

●●

supplies from CPO mills who are involved in the trade of FFB produced illegally andunsustainably.
➢ RSPO Mass Balance oil is not tainted by illegal palm oil by introducing a system ofcontrols and checks for non-certified oil in the supply chain.
RSPO members rapidly move towards 100% CSPO based on strengthened RSPO P&C(as above) and/or POIG, and require all of their suppliers to become RSPO memberswith the appropriate certification (P&C or Supply Chain for IP and SG).
RSPO Secretariat publishes a response to MoEF’s letter on how RSPO is working to end
sourcing by RSPO members from national parks such as TNNP.

To the CSO community:● Increase monitoring of field implementation of the much-publicized global sustainability
and zero deforestation commitments of the palm oil sector.
● Do not take paper commitments as face value, and inform companies and the public
about the mills and refineries that are buying products that are illegal and/or noncompliant with the companies’ policies.
● Monitor supply chain operations of RSPO members and SCC certified mills and inform
RSPO about purchases of illegal and/or non-compliant products.
● Support the supply chain transparency process of end users who published palm oil
supplier lists as an important contribution towards improving the situation as an industry
through providing information on FFB sources for these mills and urge other companies
to publish their suppliers list.
#END

32 | EoF (June 2018) Enough is Enough.

Appendix 1. Supply chains of illegal FFB to surrounding CPO mills.
CoC 1 – Toro group to PT. Citra Riau Sarana 2 mill.

CoC 2 – Toro group to PT. Citra Riau Sarana 2 mill.

33 | EoF (June 2018) Enough is Enough.

CoC 3 – Toro group to PT. Citra Riau Sarana 2 mill.

CoC 4 – Bukit Kusuma group to PT. Sawit Mas Nusantara mill.

34 | EoF (June 2018) Enough is Enough.

CoC 5 – Bukit Kusuma group to PT. Sawit Mas Nusantara mill.

CoC 6 – Simpang Silau group to PT. Inti Indosawit Subur Ukui 1 mill.

35 | EoF (June 2018) Enough is Enough.

CoC 7 – Simpang Silau group to PT. Makmur Andalan Sawit mill.

CoC 8 – Simpang Silau group to PT. Sawit Mas Nusantara mill.

36 | EoF (June 2018) Enough is Enough.

CoC 9 – PT. Bagas Indah Perkasa to PT. Gemilang Sawit Lestari mill.

CoC 10 – PT. Bagas Indah Perkasa to PT. Gemilang Sawit Lestari mill.

37 | EoF (June 2018) Enough is Enough.

CoC 11 – PT. Runggu Prima Jaya to PT. Gemilang Sawit Lestari mill.

CoC 12 – KPMMB to PT. Fortius Wajo Perkebunan mill.

38 | EoF (June 2018) Enough is Enough.

CoC 13 – Sungai Ari to PT. Persada Alam Jaya mill.

CoC 14 – PT. Alkausar Afdeling VII to PT. Fortius Wajo Perkebunan mill.

39 | EoF (June 2018) Enough is Enough.

Appendix 2. Supply chains of CPO from mills who purchased illegal
FFB.
CoC 1 – PT. Citra Riau Sarana 2 mill to PT. Wilmar Nabati Indonesia Pelintung.

CoC 2 – PT. Inti Indosawit Subur Ukui 1 mill to PT. Sumber Kencana (SK).

40 | EoF (June 2018) Enough is Enough.

CoC 3 – PT. Makmur Andalan Sawit to PT. Sari Dumai Sejati & PT. Cemerlang Energi
Perkasa (RGE).

CoC 4 – PT. Sawit Mas Nusantara to PT. Sari Dumai Sejati & PT. Cemerlang Energi
Perkasa (RGE).

41 | EoF (June 2018) Enough is Enough.

CoC 5 – PT. Gemilang Sawit Lestari mill to PT. Sumber Kencana (SK).

CoC 6 – PT. Fortius Wajo Perkebunan mill to PT. Sumber Kencana (SK).

42 | EoF (June 2018) Enough is Enough.

CoC 7 – PT. Persada Alam Jaya mill to CV. Perintis Lintas Talang Duku (Pelita).

43 | EoF (June 2018) Enough is Enough.

Appendix 3. Definition of traceability by RGE and Wilmar.
Table 1.—Apical subscribes to Traceability Working Group (TWG) definition of traceability
which
requireonly
limiteddata(Source:“Traceability”
pageofApicalhttp://www.sustainability.apicalgroup.com/traceability/).

Table 2.—Wilmar’s definition of traceability require even less data than RGE on all growers(Source: “Traceability back to plantation” page of Wilmar http://www.wilmarinternational.com/sustainability/progress/traceability/traceability-back-to-plantation/).

44 | EoF (June 2018) Enough is Enough.

Appendix 4. Corporate responses to this report
Prior to publication, EoF requested the Big 4 and 20 global traders and brands
mentioned in the report to check the draft report and inform EoF of factual errors withsupporting evidence.
Overall, the responses from the companies were positive. Many agreed with EoF
recommendation to work together towards a solution, whether their links to the problems
in the two landscapes are direct or indirect.
Some informed about their engagement with specific direct or indirect suppliers and/or the
Sumber Kencana group highlighted in the report. One company explained that a ‘Delivery
Order’ holder was identified and suspended. Some explained that they had stopped sourcing
from mills highlighted in the report.
Many companies informed on their supply chain transparency efforts including publicationof CPO supplier lists through their dashboards and use of grievance mechanisms.
Some of the Big 4 requested EoF to disclose the names of actors that are linked to illegal
plantations in Tesso Nilo. That information is treated as evidence for law enforcement bygovernment, thus formal engagement with the Tesso Nilo Task Force would be a first stepfor the companies to take. However, we think that the responsibility for legal supplies lies
with buyers like the Big 4 and cannot be transferred to sporadic voluntary efforts like thoseby EoF. Corporate traceability systems have to be robust enough to ensure not only legality
but also full implementation of NDPE commitments for direct and third party purchases.
Overall, we are encouraged by the responses we received and feel that the companies aretaking actions. We hope that this report can trigger a more organized and intensive
framework for stakeholders at all levels in the palm oil supply chain to work together andspeed up the process to achieve the common goal of zero deforestation and legal supply
chains. Before it is too late!

45 | EoF (June 2018) Enough is Enough.

References
1
Chain Reaction Research (1 November 2017) Unsustainable Palm Oil Faces Increasing Market Access
Risks: NDPE Sourcing Policies Cover 74 Percent of Southeast Asia’s Refining Capacity.
https://chainreactionresearch.files.wordpress.com/2017/10/unsustainable-palm-oil-faces-increasingmarket-access-risks-final-1.pdf
2Financial Times (13 June 2016) Cargill and Bunge refuse to cut ties with palm oil trader.
https://www.ft.com/content/aac0151e-2f13-11e6-a18d-a96ab29e3c95
3Wilmar (5 December 2013) No Deforestation, No Peat, No Exploitation Policy.

4

Musim
Mas
Sustainability
Policy.
http://www.musimmas.com/qws/slot/u50045/style/Sustainability/2.%20Sustainability%20Policy/MM%20
sustainability%20policy_final.pdf
5 Golden

Agri-Resources (9 February 2011) Golden Agri-Resources Initiates Industry Engagement for
ForestConservation.
http://www.goldenagri.com.sg/pdfs/News%20Releases/2011/110209%20Golden%20AgriResources%20Initiates%20Industry%20Engagement%20for%20Forest%20Conservation.pdf
6 AsianAgri (September 2014) Sustainability Policy. http://www.asianagri.com/images/pdf/2016/asianagri-sustainability-policy-2014.pdf
7 Apical (September 2014) Sustainability Policy. http://www.apicalgroup.com/sustainability
8 United Nations Headquarters (23 September 2014) Governments, Business, Civil Society and Indigenous

Leaders
PledgetoEnd
Lossredd.org/portals/15/documents/ForestsPressRelease.pdf

ofForests.

http://www.un-

9

Oil

Pledge disbands

http://www.eco-

Eco-Business.com (1 July 2016) Indonesian Palm
business.com/news/indonesian-palm-oil-pledge-disbands/
10

Sime
Darby
website,Sustainable
Palm
Oil
Manifesto
http://www.simedarbyplantation.com/sustainability/practices-key-initiatives/sustainable-palm-oilmanifesto, checked on 15 October 2017.
11 Greenpeace (19 September 2014) Palm Oil Manifesto Companies Urged to Apply Strong HCS Standards.

http://www.greenpeace.org/seasia/Press-Centre/Press-Releases/Palm-Oil-Manifesto-Companies-Urgedto-Apply-Strong-HCS-Standards/
12 Chain Reaction Research (1 November 2017)
13

WWF-Indonesia(2013)
PalmingOffaNational
http://awsassets.wwf.or.id/downloads/wwf_indonesia_palming_off_a_national_park_final.pdf

Park.

14

Eyes
on
the
Forest(4
September
2014)
Tiger
in
your
tank?
http://www.eyesontheforest.or.id/uploads/default/report/Eyes-on-the-Forest-Investigative-Report-Tigerin-your-tank-September-2014.pdf
15

Eyes
on
the
Forest(2016)
No
One
is
Safe.
http://www.eyesontheforest.or.id/uploads/default/report/Eyes-on-the-Forest-Investigative-Report-NoOne-is-Safe-April-20161.pdf
16 Eyes on the Forest (2016), Appendix 3. Responses to this report.
17

Antara News (6 August 2014) Riau’s two million hectares of oil palm plantation illegal.
http://www.antaranews.com/en/news/95203/riaus-two-million-hectares-of-oil-palm-plantation-illegalminister
18

Keputusan Menteri Kehutanan Republic Indonesia Nomor: SK.673/Menhut-II/2014 tentang Perubahan
Peruntukan Kawasan Hutan Menjadi Bukan Kawasan Hutan Seluas ± 1.638.249 (Satu Juta Enam Ratus
Tiga Puluh Delapan Ribu Dua Ratus Empat Puluh Sembilan) Hektar, Perubahan Fungsi Kawasan Hutan
Seluas ± 717.543 (Tujuh Ratus Tujuh Belas Ribu Lima Ratus Empat Puluh Tiga) Hektar dan Penunjukan
Bukan Kawasan Hutan Menjadi Kawasan Hutan Seluas ± 11.552 (Sebelas Ribu Lima Ratus Lima Puluh Dua)
Hektar di Provinsi Riau.

19 The Forest Estate classifies land managed by the Ministry of Forestry based on the 1986 “Consensus ofForest Land Use” (TGHK, Ministry of Forestry Decree No 173/Kpts-II/1986) and 1994 “Riau Spatial
Planning” (RTRWP 1994) documents. The “Forest Estate” does not allow development of agricultural

46 | EoF (June 2018) Enough is Enough.

commodities, such as oil palm plantations. The designation “Forest Estate” does not necessarily mean thatthe land is covered by natural forest.
20 Keputusan

Menteri Kehutanan Republic Indonesia Nomor: SK.878/Menhut-II/2014 tentang Kawasan
Hutan Provinsi Riau.

21 Eyes on the Forest (2016b) ‘Legalization’ of palm oil plantation companies by changing the designationof Forest Estate to Non-Forest Estate in Riau Province. Investigative analysis of Remote Sensing analysis
against26
palm
oilplantations.
https://www.eyesontheforest.or.id/uploads/default/report/Legalization_of_palm_oil_çompanies_(Dec_2016).pdf
22 Utusanriau.com (8 March 2017) Kapolda Himbau PKS Tak Terima TBS TNTN, Sejumlah Warga Mengadu
ke
DPRD
Pelalawan.
http://utusanriau.co/?/det/29441/kapolda-himbau-pks-tak-terima-tbs-tntnsejumlah-warga-mengadu-ke-dprd/2017-03-08,
http://m.riaupos.co/156442-berita-sawit-terusmerajalela-di-hutan-lindung.html
23 KKI Warsi, Frankfurt

Zoological Society, Eyes on the Forest & WWF-Indonesia (2010) Last Chance to
Save Bukit Tigapuluh. Sumatran tigers, elephants, orangutans and indigenous tribes face local extinction,
along
with
forest.
http://assets.wwfid.panda.org/downloads/last_chance_for_bukit_tigapuluh__warsi_fzs_eof_wwf_14dec2
010_.pdf
24 Eyes on the Forest (4 September 2014)
25 Undang-Undang

Republik Indonesia Nomor 18 Tahun 2013 tentang Pencegahan Dan Pemberantasan
Perusakan Hutan. http://www.dpr.go.id/dokjdih/document/uu/UU_2013_18.pdf English translation “ThePrevention and Eradication of Forest Destruction (Law No. 18/2013 dated August 6, 2013) is available at:
http://faolex.fao.org/docs/pdf/ins137703.pdf
26 English translation published by FAO: http://faolex.fao.org/docs/pdf/ins137703.pdf
27 WWF-Indonesia (2013)
28 Eyes on the Forest (2016)
29 Wilmar

International Limited (29 December 2014) Asset Acquisitions and Disposals :: Notification on
Wilmarsubsidiaries
andassociatedcompanies.
http://media.corporateir.net/media_files/IROL/16/164878/SGX/2014/SGX_Announcement_Notification_on_WIL_subs_and_asso_cos_dd_29Dec2014.pdf
30 WWF-Indonesia (2013)
31 Eyes on the Forest (2016)
32 Eyes on the Forest (2016)33

Eyes on the Forest (2016)34

Wilmar (5 December 2013) No Deforestation, No Peat, No Exploitation Policy writes: “All provisions inthis policy, with no exception, apply to: All Wilmar operations worldwide, including those of its subsidiaries,
any refinery, mill or plantation that we own, manage, or invest in, regardless of stake. All third party
suppliers from whom we purchase or with whom we have a trading relationship.” It also writes “In addition
to immediately shifting development activities away from HCS, HCV, and peatland areas uponannouncement of this policy, we expect suppliers to be fully compliant with all provisions of this policy by
December 31, 2015”35

WilmarCountry
Statistics
Q2
2017
on
Traceability.
http://www.wilmarinternational.com/sustainability/wp-content/uploads/2017/07/Country-Statistics_Q2-2017-_Link-toClick.pdf, checked on 13 October 2017.
36

Wilmar International Limited (2017) Sustainability Report 2016. Chapter on Supply Chain andTraceability,P.
31-35.
http://www.wilmar-international.com/sustainability/wpcontent/uploads/2017/08/Wilmar-SR-2016-Final.pdf
37 Eyes on the Forest (2016), Appendix 3. Responses to this report.
38

WWF-Indonesia (2013)39

Eyes on the Forest (2014)

40 Eyes on the Forest (2016)47 | EoF (June 2018) Enough is Enough.

41 Asian Agri (2017) Sustainability Report 2015-2016.
www.asianagri.com/images/pdf/2016/sustainability_report_2015_2016.pdf
42 Asian Agri (2017) Sustainability Report 2015-2016.
www.asianagri.com/images/pdf/2016/sustainability_report_2015_2016.pdf
43 http://www.ispo-org.or.id/index.php?option=com_content&view=article&id=114:sertifikasi&catid=10&Itemid=279&showal
l=&limitstart=9&lang=ina
44

http://www.ispoorg.or.id/index.php?option=com_content&view=article&id=114:sertifikasi&catid=10&Itemid=279&showal
l=&limitstart=9&lang=ina
45 http://www.ispo-org.or.id/index.php?option=com_content&view=article&id=114:sertifikasi&catid=10&Itemid=279&showal
l=&limitstart=5&lang=ina
46

http://mutucertification.com/wp-content/uploads/2015/09/SPO-4019-Jurnal-ISPO-DESEMBER2016.pdf
47

http://mutucertification.com/wp-content/uploads/2015/09/SPO-4019-Jurnal-ISPO-DESEMBER2016.pdf
48 http://www.ispo-org.or.id/index.php?option=com_content&view=article&id=114:sertifikasi&catid=10&Itemid=279&showal
l=&limitstart=10&lang=ina
49 http://www.rspo.org/members/88/Wilmar-International-Limited
50 WWF-Indonesia (2013)
51 Eyes on the Forest (2016)52 http://www.rspo.org/members/836/AAA-Oils-Fats-Pte.-Ltd
53 http://www.apicalgroup.com/
54 Eyes on the Forest (2016)
55 Eyes on the Forest (2014)
56 Eyes on the Forest (2016)
57

SK
Group
website,Our
ValuedCustomers:
http://www.skgroup.co.id/customers.php?customers&language=en_US, checked on 12 October 2017. Asof 2 June 2018, the website is not active.
58

http://www.wilmar-international.com/sustainability/supply-chain-map/ (all 14 facilities in Indonesia
were checked on 16 November 2017. WNI = PT Wilmar Nabati Indonesia)
59 https://goldenagri.com.sg/sustainability-dashboard/supply-chain-map (all 8 facilities in Indonesia werechecked on 11 October 2017)60

http://www.sustainability.apicalgroup.com/supply-chain-map/ (all 4 facilities in Indonesia were checkedon 11 October 2017)61 http://www.musimmas.com/sustainability/traceable-supply-chain/supply-chain-map (all 16 facilities inIndonesia were checked on 11 October 2017. IBP = Inti Benua Perkasatama)
62 Musim Mas (4 June 2018) explained to EoF that PT. Gemilang Sawit Lestari was listed as a supplier forthe period as the delivery of a 2016 contract was done on early January 2017 and that since then, there
was no new contract and delivery.
63 See for example Rainforest Action Network (2014) The Last Place on Earth – Exposing the Threats to the

LeuserEcosystem
https://d3n8a8pro7vhmx.cloudfront.net/rainforestactionnetwork/pages/2782/attachments/original/14157
27823/Last_Place_On_Earth_Report_Nov2014_Low.pdf?1415727823 and Rainforest Action Network(2017) Leuser Watch. PT. Agra Bumi Niaga: Destroying elephant habitat while breaching the Indonesian
Government
Moratoriumon
ForestClearance
for
Palm
Oil.
https://d3n8a8pro7vhmx.cloudfront.net/rainforestactionnetwork/pages/17392/attachments/original/1486
495650/RAN_Leuser_Watch_PT_Agra_Bumi_Niaga_20170207.pdf?1486495650

48 | EoF (June 2018) Enough is Enough.

64

AAK (No date) AAK mill list. https://aak.com/siteassets/sustainable-growth/aak-public-mill-list.pdf,
checked on 21 March 2018.
65

ADM (No date) Supply Chain Map (https://www.adm.com/sustainability/sustainability-progresstracker/palm-oil/supply-chain-map), checked on 10 March 2018
66

Bunge
(No
date)
Supplychain
duringQ3(https://www.bunge.com/sites/default/files/mill_list.q32017.pdf posted at its Palm oil
https://www.bunge.com/sustainability/palm-oil-dashboard), checked on 10 March 2018.

2017.
dashboard

67

Bunge Loders Croklaan (No date) List of Mills (http://europe.bungeloders.com/taking-responsibility/listof-mills/), checked on 10 March 2018.
68

Bunge
(No
date)
Supplychain
duringQ3(https://www.bunge.com/sites/default/files/mill_list.q32017.pdf posted at its Palm oil
https://www.bunge.com/sustainability/palm-oil-dashboard), checked on 10 March 2018.

2017.
dashboard

69 Bunge Loders Croklaan (No date) List of Mills (http://europe.bungeloders.com/taking-responsibility/list-of-mills/), checked on 10 March 2018.
70
Cargill
(No
date)
Full
list
of
the
mills
in
Cargill’s
supplychain(https://secure1.foodreg.net/ksportal/web/cargill/mill-list) and Cargill (No date) Supply Chain Map(https://secure1.foodreg.net/ksportal/web/cargill/supply-chain-map), checked on 10 March 2018.
71 Colgate-Palmolive (February 2018) Colgate-Palmolive’s largest suppliers for palm oil and palm kernel oil
andmills.
https://www.colgatepalmolive.com/content/dam/cpsites/corporate/corporate/en_us/corp/localeassets/pdf/Statement_Palm_Oil_Mills_Disclosure_Feb_12_2018.pdf, checked on 20 March 2018.
72

ColgatePalmolive(No
date)
ColgatePalmolive
List
of
Mills
as
of
https://www.colgatepalmolive.com/content/dam/cp-sites/corporate/corporate/en_us/corp/localeassets/pdf/ColgatePalmolive-List-of-Mills.pdf, checked on 20 March 2018.

2017

73 General

Mills (No date) General Mills global direct palm oil suppliers (as of December 31, 2017).
https://www.generalmills.com/en/News/Issues/palm-oil-statement/current-direct-suppliers, checked on
20 March 2018.
74

https://www.generalmills.com/~/media/Files/Issues/aak-public-mill-list.pdf?la=en,
March 2018.

checked

on

20

75

https://www.generalmills.com/~/media/Files/Issues/PalmOil%20MasterList%20318.pdf?la=en,
checked on 20 March 2018.
76 Kellogg (2018) Kellogg Extended Supply Chain Mill List.

http://www.kelloggcompany.com/content/dam/kelloggcompanyus/corporate_responsibility/pdf/2018/Kell
oggExtendedSupplyChainMill_List.pdf, checked on 17 May 2018.
77 Mars

writes “*Please note we have withheld allocation to IOI until end January, depending on thedevelopment of the IOI Pelita case.”

78

Mars (January 2018) Mars, Incorporated. Update on Sustainable Palm Oil Sourcing.
http://www.mars.com/docs/default-source/Policies-and-Practices/mars-palm-update-(january2018).pdf?sfvrsn=2
79

Mars (February 2018) Mars’ Suppliers – 2016 Full Mill List. http://www.mars.com/global/aboutus/policies-and-practices/palm-oil-policy, checked on 20 March 2018.
80

Mondelēz(February
2018)
MondelēzInternational
Palm
Oil
Supplier
List.
http://www.mondelezinternational.com/~/media/mondelezcorporate/uploads/downloads/supplier_list.pdf?la=en, checked on 20 March 2018.
81

Mondelēz (March 2018) Mills Data. http://www.mondelezinternational.com/impact/sustainableresources-and-agriculture/~/media/mondelezcorporate/uploads/downloads/Mills_Data.pdf?la=en,
checked on 20 March 2018.
82 Neste (no date) Neste Supply Chain Map, at http://nestepalmoildashboard.com/, checked on 21 March

2018.
83

Nestlé (No date) Palm oil (https://www.nestle.com/csv/communities/responsible-sourcing/palm-oil),
Nestlé
(February
2018)
SnapshotNovember
2017(https://www.nestle.com/assetlibrary/documents/creating-shared-value/responsible-sourcing/list-mills-february-2018.pdf), checked on
10 March 2018.

49 | EoF (June 2018) Enough is Enough.

84

Nestlé (No date) Palm oil (https://www.nestle.com/csv/communities/responsible-sourcing/palm-oil),
Nestlé
(February
2018)
SnapshotNovember
2017(https://www.nestle.com/assetlibrary/documents/creating-shared-value/responsible-sourcing/list-mills-february-2018.pdf), checked on
10 March 2018.
85

Olam
(No
date)
Olam’slistofsupplying
mills
(2016
&
2017).
http://49tmko49h46b4e0czy3rlqaye1b.wpengine.netdna-cdn.com/wp-content/uploads/2018/01/ThirdParty-Supplier-Mill-List-12-Jan-2018.pdf, checked on 21 March 2018.
86

Olam
(No
date)
Olam’slistofsupplying
mills
(2016
&
2017).
http://49tmko49h46b4e0czy3rlqaye1b.wpengine.netdna-cdn.com/wp-content/uploads/2018/01/ThirdParty-Supplier-Mill-List-12-Jan-2018.pdf, checked on 21 March 2018. After drafting of the report, Olampublished a new list of suppliers.
87 PepsiCo (March 2018) PepsiCo Global Palm Oil Supplier List, 2018.

http://www.pepsico.com/docs/album/policies-doc/pepsico-2018-direct-palm-oil-supplierlist_vf.pdf?sfvrsn=b1bad141_4
88

PepsiCo (no date) PepsiCo Palm Oil Mill List 2017. http://www.pepsico.com/docs/album/policiesdoc/pepsico-2017-palm-oil-mill-list.pdf?sfvrsn=ca59d041_6
89Procter&Gamble
(No
date)
P&G’s
DirectPalm
Suppliers-2017.
https://us.pg.com/sustainability/environmental-sustainability/policies-practices/palm-oil/pandg-directpalm-suppliers-2017, checked on 20 March 2018.
90
Procter&Gamble
(No
date)
2017
Palm
Oil
Mills.
https://us.pg.com//media/PGCOMUS/Documents/PDF/PG%202017%20Palm%20Oil%20Mills.pdf?la=en-US&v=1201802280708&hash=A585AD28988F160AB4AE854EFFA7F75195F73C3F, checked on 20 March 2018.
91

RB
(No
date)
RB’s
next
steps
on
responsible
palm
oil
-2018
and
https://www.rb.com/media/3322/rb-s-plans-for-responsible-palm-oil-sourcing-2018_final_allsuppliers.pdf

beyond.

92 RB (no date) RB 2017 Palm Oil Mills. www.rb.com/media/3314/rb-palm-oil-mill-list_2017.pdf, checkedon 20 March 2018.
93

Unilever (No date) 2017 Palm Oil Suppliers. https://www.unilever.com/Images/unilever-palm-oilsupplier-list_tcm244-515896_en.pdf
94

Unilever (No date) Sustainable palm oil - our progress (https://www.unilever.com/sustainableliving/reducing-environmental-impact/sustainable-sourcing/transforming-the-palm-oil-industry/palm-oilprogress/) and Unilever (No date) 2017 Palm Oil Mills (https://www.unilever.com/Images/unilever-palmoil-mill-list_tcm244-515895_en.pdf), checked on 10 March 2018.
95

WWF
Global,Promotingcertifiedsustainablepalm
http://wwf.panda.org/what_we_do/footprint/agriculture/palm_oil/solutions/responsible_purchasing/oil.

96 RSPO website, How RSPO Certification Works. http://www.rspo.org/certification/how-rspo-certification-

works, accessed on 10 June 2015.
97 Eyes on the Forest (2016)
98

Certification of Registration for PT. Inti Indosawit Subur Ukui I Palm Oil Mill.
https://www.rspo.org/uploads/default/pnc/Ukui_I_POM_certificate_RSPO_PC_PT_Inti_Indosawit_Subur.p
df
99

Certification of Registration for PT. Inti Indosawit Subur Ukui II Palm Oil Mill.
https://www.rspo.org/uploads/default/pnc/Ukui_II_POM_certificate_RSPO_PC_PT_Inti_Indosawit_Subur_
-.pdf
100

CertificationofRegistration
for
PT.
RigunasAgri
Utama
Peranaphttps://www.rspo.org/uploads/default/pnc/PT_Rigunas_Agri_Peranap_POM_certificate.pdf

Mill.

101

CertificationofRegistration
for
PT.
Rigunas
Agri
Utama
Bungo
Tebo
Mill.
https://www.rspo.org/uploads/default/pnc/PT_Rigunas_Agri_Utama_Bungo_Tebo_POM_Certificate.pdf
102 Neste (No date) Traceability, at http://nestepalmoildashboard.com/. Checked on 21 March 2018.
103

Neste (no date) Neste Supply Chain Map, at http://nestepalmoildashboard.com/, checked on 21 March
2018.

50 | EoF (June 2018) Enough is Enough.

104

http://www.rspo.org/uploads/default/scc/PT_WILMAR_NABATI_INDONESIA_Certificate_C833301CU_RSP
O_SCC_01_2016.pdf
105

http://www.rspo.org/uploads/default/scc/PT_Wilmar_Bioenergi_Indonesia_Certificate_C833302CU_RSPO_SCC_01_2015.pdf
106

http://www.rspo.org/uploads/default/scc/PT._Wilmar_Nabati_Indonesia_(Dumai)_Certificate_C847234CU_RSPO_SCC_01_2016_.pdf
107

https://rspo.org/uploads/default/scc/PT_Wilmar_Nabati_Indonesia_RSPO_SCCS_Certificate_PT_WNI_201
7.pdf
108 http://www.rspo.org/uploads/default/scc/PT._SARI_DUMAI_SEJATI_CERT_RSPO_2017_.pdf
109

The previous certificate (CU-RSPO SCCS-821959) based on RSPO Supply Chain Certification Systems,
versionNovember
2011
expiredon
29/08/2017
http://www.rspo.org/.../PT_Cemerlang_Energi_certificate_2_C821959CU_RSPO_ SCCS_02_2014-34.pdf
110https://www.rspo.org/uploads/default/scc/PT_ASIANAGRO_AGUNGJAYA_Certificate_RSPO_2017.pdf

111 http://www.rspo.org/uploads/default/scc/Dumai_Bulking_Station_Certificate_RSPO_2017.pdf
112 http://www.rspo.org/uploads/default/scc/Lubuk_Gaung_Refinery_Certificate_RSPO_2016.pdf
113 https://rspo.org/uploads/default/scc/PT_SMART_Tbk_Belawan_Certificate.pdf
114 https://www.rspo.org/uploads/default/scc/LUBUK_GAUNG_CERT_RSPO_2017.pdf
115

https://www.rspo.org/uploads/default/scc/Pacific_Indopalm_Industries_Certificate_SQUAL40055_201602
22_Upgrade.pdf
116 Golden Agri-Resources Supply Chain Map, GAR Downstream Facilities

https://goldenagri.com.sg/sustainability-dashboard/supply-chain-map, checked on 2 June 2018.
117 Golden Agri-Resources (2018) Annual Report 2017. https://goldenagri.com.sg/wp-

content/uploads/2018/03/GAR-AR2017.pdf
118 Golden Agri-Resources (2018) Annual Report 2017. https://goldenagri.com.sg/wp-

content/uploads/2018/03/GAR-AR2017.pdf Page 54: "In 2017, we reached a significant milestone when
we achieved 100 percent Traceability to the Plantation (“TTP”) for all GAR mills. This means 39 percent ofour palm supply chain is now fully traceable".
119

Wilmar (no date) Country Statistics January – Dececmber 2017. http://www.wilmarinternational.com/sustainability/progress/traceability/country-statistics/, checked on 4 June 2018.
120 Chain Reaction Research (1 November 2017)
121

Wilmar (no date) Country Statistics January – Dececmber 2017.

122 Musim Mas (no date) Operational Presence. http://www.musimmas.com/about-us/operational-

presence#_ptoh_3012739, checked on 4 June 2018.
123 Chain Reaction Research (1 November 2017)124

Musim Mas (2018) Sustainability Policy Progress Report January – December 2017.
http://www.musimmas.com/qws/slot/u50045/style/Sustainability/3.%20Progress%20on%20Policy/Progr
ess%20Report/5th%20Progress%20Report%20-%20Jan%20to%20Nov%202017/2017%20Progress%20
report%20-%20Jan%20to%20Dec%202017.pdf

125 Apical (no date) Operations. http://www.apicalgroup.com/operations, checked on 4 June 2018.
126 http://www.eyesontheforest.or.id/uploads/default/report/Eyes-on-the-Forest-Investigative-Report-No-

One-is-Safe-April-20161.pdf
127

CPO mills in Central Sumatra,
http://maps.eyesontheforest.or.id

published

51 | EoF (June 2018) Enough is Enough.

at

the

Eyes

on

the

Forestinteractivemap128 Unilever (No date) Eliminating deforestationin our supply chain. https://www.unilever.com/sustainable-

living/reducing-environmental-impact/greenhouse-gases/eliminating-deforestation-in-our-supply-chain/
Unilever made its NDPE commitment in 2010.
129

CAO (December 2013) Dispute Resolution Conclusion Report – Wilmar 3. http://www.caoombudsman.org/cases/document-links/documents/Wilmar3ConclusionReportDec2013.pdf

52 | EoF (June 2018) Enough is Enough.