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Indicator

Comment (English)

1

Introduction

2

Preamble

Retailers in Europe are concerned that the P&Cs as currently implemented will not provide the compliance required under the
EUDR legislation. This is particularly problematic for mass balance volumes, as well as derivatives and fractions. We would likethe current review to take note of the EUDR implementation timescale (Dec 2024) and to ensure that any required changes tobring it in line with EUDR are brought to the General Assembly in 2023.
"add all the reference that appears in the requirements (this will help new joiner having a more exhaustive view ofrequirements):- RaCP- GHG assessment for new developments- GHG calculator- Metric template- FPIC guidance- CSDSF complaint system- Chile labour remediation guidance- BMP for rehabilitation of riperian"#

Indicator

Comment (English)

1
2
3

Definition
Definition
Definition

4
5
6
7

Definition
Definition
Definition
Definition

better source than Wikipedia ?
The bribe/bribery should be defined in the oil palm context and do not use general Wikipedia definitions.
"...there should be restrictions on hours of work and overtime..." This is another global but vague definition. Why is it not
related to working conditions in the oil palm context and the labor situation in the oil palm industry?
Most agreements are enforceable by law. RSPO needs to redefine or be more specific to the agreements referred to.
Definition of Bribery and Corruption ?
the assessmentS and FPIC"[HRSS] The definition of Child Labour should follow ILO standards on minimum age as reflected in this definition.
Please note that under Draft 2 Indicator 6.4.2 and 6.4.3, RSPO has raised the age limit on prohibition of child labor to 18 years,
which may be considered to be beyond ILO's requirements on Child labour. If draft 2 indicator 6.4.2 and 6.4.3 is accepted, thenthis definition has be amended to make it aligned.
Raising of age to 18 years may bring unintended consequences for young workers who are already engaged by the UoC such as
depriving them livelihood opportunities and that the UoC will now have to terminate their employment despite the fact thatILO requirements permit them.

8

Definition

9

Definition

10

Definition

Propose to retain the current definition of child labour as set out in the definition section and that Indicator 6.4.2 and 6.4.3 tobe aligned with this definition."
The stress on reduction is premature in this definition as it is directly copy-pasted from the Waste4Change website. RSPO as anorganization should be mature enough to define the 3R concept based on conditions in estates, especially rural areas where theuse of plastic is rampant especially when drinking water is unavailable through the estate infrastructure and needs to bepurchased. In most rural estates, there is no recycling support, and RSPO must be cognizant of this factor. Thus, a more realistic
definition of 3R should be coined.
This is a convoluted attempt to be all-inclusive. Please simplify the definition. The standard should be readable, especially for
individuals and organizations having a poor command of English. Translations could become messier.
Suggest to add a definition of 'child-sensitive' (reference 2.4.1)

#Indicator

Comment (English)

11

Definition"The latest version of Accountability Framework's definition was issued in 2020. No major difference in the text, however. The
full definition is as follow:
Deforestation""Loss of natural forest as a result of: i) conversion to agriculture or other non-forest land use; ii) conversion to a tree
plantation; or iii) severe and sustained degradation.""This definition pertains to no-deforestation supply chain commitments, which generally focus on preventing the conversion ofnatural forests.
Severe degradation (scenario iii in the definition) constitutes deforestation even if the land is not subsequently used for a nonforest land use.
Loss of natural forest that meets this definition is considered to be deforestation regardless of whether or not it is legal.
The Accountability Framework’s definition of deforestation signifies ‘gross deforestation’ of natural forest where ‘gross’ is usedin the sense of ‘total; aggregate; without deduction for reforestation or other offset.

12

Definition

13

Definition

See: https://accountability-framework.org/use-the-accountability-framework/definitions/""Several definitions from 2018 P+C have been removed - suggest either reinstate these or ensure these are adequately
explained in relevant indicators? e.g.:
due diligence, extensive replanting on steep terrain, facilitation payment, family farm, food security, gender equal, independent
smallholder, in good faith, integrated pest management, ISO standards, landscape, landscape level, outgrowers, site,transmigrant, undue influence, water security""Expand the defenitions in this list. Especially those terms that you refer to in existing defenitions.
For example how is natural forest defined? Plantation forest, agricultural use?
Try to match with existing defenitions. Consider EUDR because this can help make RSPO relevant for members needing tocomply with EUDR."#

Indicator

Comment (English)

14

Definition"Adding suggestions for definitions used throughout the document:
1. Conservation Area: An area with the main purpose to conserve environmental and social values.
2. Free, Prior and Informed Consent: The right of Indigenous Peoples, Local Communities, and other users to give or to withhold
their consent to any project affecting their lands, livelihoods and environment. (Source: RSPO FREE, PRIOR AND INFORMEDCONSENT (FPIC) GUIDE (2022))
3. High Carbon Stock Approach (HCSA): A methodology that distinguishes forest areas for protection from degraded lands withlow carbon and biodiversity values, that may be developed. The methodology was developed with the aim to ensure a practical,
transparent, robust, and scientifically credible approach that is widely accepted to implement commitments to halt
deforestation in the tropics, while ensuring the rights and livelihoods of local people are respected (Source: HCSA Membership
Requirements)

15

Definition

16
17
18
19
20

Definition
Definition
Definition
Definition
Definition

21

Definition

4. High Carbon Stock Social Requirements: Social requirements that are outlined in Module 2 of the HCSA Toolkit""To consider defining the scope of 'environmental HRD'. A suggested reference from the Accountability Framework's
definitions: water, air, land, flora, and fauna.
Full definitions of ""environmental and human rights defenders"" for reference: Individuals or groups who, in their personal or
professional capacity and in a peaceful manner, act to protect and promote human rights, eliminate human rights violations, orprotect the environment, including water, air, land, flora, and fauna. "consider changing into: ".. area identified as.."Definition of Land Clearing- Parameters need to be established. 10 ha per year? 10 ha per Unit of Certification since 2018? etc.
Labour recruiter / Labour contractor (2.1.2)
Add a definition for "Management review" (3.1.3)
Instead of saying "other conservation areas," this should explicitly call out currently protected areas as defined by local, state,regional, national, and international agreements or legislation.
this definition on limited replanting does not make sense, seems to be using the wording from when this was framed as
extensive replanting? Currently sates limited planting means planting on contiguous area more than 25 ha, needs to becorrected. Also not clear with current wording how the 25 ha limit and 1% relate - is it 'up to 25 ha, and only up to 1% if that 1%
is lower than 25 ha'?

#

Indicator

Comment (English)

22

Definition

23

Definition

concerned that this new definition will allow for more planting on fragile and marginal soils. Especially as timeframe not defined- e.g. is it allowed to replant 100ha on fragile soils one year, and 3 years later replant a different 100ha on fragile soils as well? It
would be stronger, clearer, more auditable to take a clear position that no planting on fragile and marginal soils is allowed.
Focus should then be on how to support small growers not to do this. See also comments on indicators 7.3.3 and 7.3.4"Consider adopting Accountability Framework's definition:
Natural ecosystem
An ecosystem that substantially resembles — in terms of species composition, structure, and ecological function — one that isor would be found in a given area in the absence of major human impacts. This includes human-managed ecosystems wheremuch of the natural species composition, structure, and ecological function are present.
Natural ecosystems include:24
25

Definition
Definition

26
27
28
29

Definition
Definition
Definition
Definition-Largely ‘pristine’ natural ecosystems that have not been subject to major human impacts in recent history-Regenerated natural ecosystems that were subject to major impacts in the past (for instance by agriculture, livestock raising,tree plantations, or intensive logging) but where the main causes of impact have ceased or greatly diminished and theecosystem has attained species composition, structure, and ecological function similar to prior or other contemporary natural
ecosystems-Managed natural ecosystems (including many ecosystems that could be referred to as ‘semi-natural’) where much of theecosystem’s composition, structure, and ecological function are present; this includes managed natural forests as well as
native grasslands or rangelands that are, or have historically been, grazed by livestock-Natural ecosystems that have been partially degraded by anthropogenic or natural causes (e.g., harvesting, fire, climatechange, invasive species, or others) but where the land has not been converted to another use and where much of theecosystem’s composition, structure, and ecological function remain present or are expected to regenerate naturally or bymanagement for ecological restoration"
Suggest to add the definition of 'New development', so that we understand what is 'new planting' vs. 'new development'
Consider making jurisdictional laws more explicit based on the Accountability Framework's definition: "National laws include
the laws and regulations of all jurisdictions within a nation (local, regional, and national)." --> under the definition of 'Applicable
Law'
What when land is being replanted to create primary forest again?
confusing because above you say without human activity
make specific link to what fao defention you mean
Confusing wording. naturally regenerating can also occure when land is deforested and left alone#Indicator

Comment (English)

30

Definition"Consider adding a definition of natural forest (but not replacing the primary forest definition) based on the Accountability
Framework's definition:
Natural forest
A forest that is a natural ecosystem.
- Natural forests possess many or most of the characteristics of a forest native to the given site, including species composition,
structure, and ecological function.
Natural forests include:- Primary forests that have not been subject to major human impacts in recent history- Regenerated (second-growth) forests that were subject to major impacts in the past (for instance by agriculture, livestockraising, tree plantations, or intensive logging) but where the main causes of impact have ceased or greatly diminished and theecosystem has attained much of the species composition, structure, and ecological function of prior or other contemporary
natural ecosystems

Managed natural forests where much of the ecosystem’s composition, structure, and ecological function exist in the presenceof activities such as:- Harvesting of timber or other forest products, including management to promote high-value species- Low intensity, small-scale cultivation within the forest, such as less-intensive forms of swidden agriculture in a forest mosaic
Forests that have been partially degraded by anthropogenic or natural causes (e.g., harvesting, fire, climate change, invasive
species, or others) but where the land has not been converted to another use and where degradation does not result in thesustained reduction of tree cover below the thresholds that define a forest or sustained loss of other main elements ofecosystem composition, structure, and ecological function

The categories ‘natural forest’ and ‘tree plantation’ are mutually exclusive, though in some cases the distinction may be
nuanced. Please see the Operational Guidance on Applying the Definitions Related to Deforestation, Conversion, and Protectionof Ecosystems for further discussion of boundary cases.

31

Definition

For the purpose of corporate no-deforestation commitments, the focus is on preventing the conversion of natural forests."
define also other types of forest relevant for RSPO#

Indicator

Comment (English)

32

Definition

33

Definition

34
35

Definition
Definition

This definition should be changed to, or adapted to reflect definition from the United Nations Convention to Combat
Desertification: "The ecological process to restore a natural and safe landscape for humans, wildlife, and plant communities."
depending on what has been lost. should the aim also include natural state.. or better to the state before degradation and orconversion to be able to recover lost ecological and social functions
within the plantation or management unit?
[HRSS] To delete the first sentence as this is not aligned with ILO's definition of recruitment fees. Revert to draft 1 definition:""The terms ‘recruitment fees’ or ‘related costs’ refer to any fees or costs incurred in the recruitment process in order for
workers to secure employment or placement, regardless of the manner, timing or location of their imposition or collection.
Recruitment fees include:a. payments for recruitment services offered by labour recruiters, whether public or private, in matching offers of andapplications for employment;b. payments made in the case of recruitment of workers with a view to employing them to perform work for a third party;c. payments made in the case of direct recruitment by the employer; ord. payments required to recover recruitment fees from workers.

36

37

38

Definition

Definition

Definition

These fees may be one-time or recurring and cover recruiting, referral and placement services which could include advertising,disseminating information, arranging interviews, submitting documents for government clearances, confirming credentials,
organizing travel and transportation, and placement into employment."""doesnt work grammatically. the verb is defined as a location (the oil palm plantation where replanting takes place)should refer to the action""Consider referring to the Accountability Framework's definition on the environmental restoration and human rights harm
contexts:
Restoration
The process of assisting the recovery of an ecosystem, and its associated conservation values, that has been degraded,
damaged, or destroyed.
The term ‘restoration’ is also used in the context of remediation of human rights harms, for which restoration may come inmany forms (e.g., restoration of benefits, employment, or access to lands). See the Operational Guidance on Remediation andAccess to Remedy."
Should be changed to "areas with a slope greater than 25 degrees..."#

Indicator

Comment (English)

39
40
41
42
43

Definition
Definition
Definition
Definition
Definition

spell out abbreviation in first time word is used. Not here
oil palm
oil palm
3.4.1 mention "Outgrower scheme" add a definition or remove outgrowers from 3.4.1"Consider expanding the definition, referring to Accountability Framework's:
Risk assessment
A systematic process of evaluating potential risk in a company’s current or future operations, supply chains, and investments.

44
45

Definition
Definition

46

Definition

47

Definition

48

Definition

49

Definition

In the context of the Accountability Framework, this term refers to the assessment of risk of non-compliance with the company
commitments or applicable law related to the Accountability Framework’s scope, as well as adverse impacts to internationallyrecognised human rights. This is different from the use of the term in a general business context, where it refers to theassessment of financial risks and the drivers of such risk (e.g., legal risk, credit risk, reputation risk, and others). Risk of adverse
social and environmental impacts, including non-compliance with company commitments, can be an important element ofbroader business risk."
Suggest to add a definition and guidance for 'geo-location' (reference 2.3)
"I believe that the definition of communities could be more generic (not to exclude those who are not mentioned there); For
example:Communities: people living near palm plantations, extractors or new developments that may be positively or negatively
impacted by agricultural exploitation or industrial operation. It includes indigenous peoples and other interested parties,
according to the context of the UDC."
It should be understood as affectation to positive impacts in an inclusive way, the connotation of the term is associated withnegative aspects. The term "impacts" in exchange for "effects" should be used
It must be established in the definition that the definition of force majeure established by the national legislation of eachcountry may be adopted in case
The scope of this definition is impossible to comply with any company, precisely what is unforeseen and that are not because of
any of the parties, is the justification for not forcing a salary payment that as defined can be medium and up to long term.
The concept associated with extreme weather conditions is not peat, it can be from heavy rains, the phenomenon of the girl or
the boy to a strong drought.

#Indicator

Comment (English)

50

Definition

51

Definition

52

Definition

53

Definition

54

Definition

55
56
57

Definition
Definition
Definition

Essential agricultural work are the activities that are not interrupted? How the harvest? or includes those that are carried out
less frequently such as health, fertilization and maintenance work?
"Essential works are directly related to the production process, they are part of the agricultural activity or the industrial process
and affect the final result.
Example: Surveillance is not an essential process."
I think that clarification on "new development" that is in the indicators must be included. In addition, when a "newdevelopment" requires or not CLPI.
It does not give clarity to the concept, it refers to another document. It must refer to the amount of carbon captured and thenegative effect of freeing it to the environment through the process associated with deforestation and negative footprint when
it is replaced by crops that will not compensate for capture volumes in a reasonable period of time.
Formed by representatives of the employer and the workers, not directly by the employer, and its function is not to study theelaboration of standards, its function must be to define and implement these standards.
Include right to transit by servitude (customary rights)
Examples on light work could be placed, just as there are in dangerous work.
"It would be appropriate to expand the definition A:
Due environmental diligenceDue social diligence

58
59
60

Definition
Definition
Definition

61

Definition

There is talk of ""due diligence"" but it is not said what does it contain?"
Incomplete definition in Spanish tradduction.
Add the definition of new developments"It is already a vital salary
It is very important that Malaysia knows that in Latin America the current minimum legal wage has contemplated many
variables that are mentioned in this definition; But, it is impossible (and unsustainable) to comply with such salary being free ofdeductions because the law allows tax deductions, for social security contributions, for food demands, loans or others ..."As I mentioned before, in Latam there is the small independent producer who does make decisions about his land and wishes tobe part of the nucleus (extractor supply base and certify with it).

#

Indicator

Comment (English)

62

Definition"It is necessary and priority to improve and clarify the definitions of:-Associate producer;-Small system producer;-Small independent producer and,-Independent producer associated with an extractor plant.
In Latin America there is the small independent producer who does not want to be certified individually or in the standard that
corresponds to small independent producers and that, he prefers, to associate with an extractor plant (under the certificate of
it).

63

Definition

64

Definition

65

Definition

66

Definition

It is ""independent"" because it makes decisions about its plantation (the extractor does not take them for it); And it is""associated"" because the plant provides contract, technical assistance and some additional benefits. For the resources you
have, you should meet only the indicators of the standard of children and not those of full PyC."
Important to clarify whether the definition corresponds specifically to indigenous peoples or on the contrary to any communitythat voluntarily isolates. In that order of ideas, it is important that if a community is voluntarily isolated without being
considered an indigenous people, it has a valid legal document that certifies the presence in the territory, otherwise we would
open the door to link any community that is considered to be isolated voluntarily.
"According to Latinomaérica countries there is generally an entity that legitimizes indigenous people or populations; If theclarification is not made, this can be provided to ""legalize"" invasions of people outside the plantations that settle without
legitimacy in them ..."The type of contract with the worker depends on what the legislation of each country allows. A temporal worker, for example,
can have a definite term contract.
Hasto: It needs to be clarified again for the definition of core workers / core jobs for in gardens and factories, not all types ofwork enter the core worker / core work.

#Indicator

Comment (English)

1

1"Compared to the 2018 P&C, is the structure of the standard better, the same or worse?
Difficult to comment as no table of contents was included in draft 2. We note that in section 3 scope, reference is made to mills,
medium growers and scheme smallholders stating that there are specific indicators for them, but this is not obvious in draft 2 –seems only the standard indicators are listed with no visual differentiation if indeed there are any that are only applicable to a
specific type of grower.
Include clear visual marking of indicators that are only applicable to specific groups of growers.
We note many indicators have been merged again, after 2018 P&C separated them out following comments from auditors thatraising CARs is clearer when a single indicator does not cover multiple aspects. We would urge seeking confirmation from CBs retheir preference as ultimately it’s in everyone’s interest to have CARs clearly communicated and resolved.

2

1

3

1

4
5

1
1.1

6

1.1

We miss the guidance and other annexes, so again, difficult to comment whether this is overall better, the same or worse as the
document is incomplete.""Any other general comments and observations about the P&C that can be added : normative and informative text (guidance),
definitions, resources etc.
> Ensure that the NIWGs have balanced representation and technical know-how to look at these various topics [The following
criteria are addressed through national Interpretation: 2.1 (Legal compliance), 3.4 (Social and Environmental Impact Assessment),
3.5 (Soil fertility), 6.4 (Child labour), 6.7 (Forced Labour), 7.1 (Integrated Pest Management), 7.2 (3R Reduce-Reuse-Recycle
Concept), 7.3 (Soil erosion and degradation), 7.4 (Land clearing on peat), 7.5 (Surface and groundwater), 7.7 (GHG emissions)]""Compared to the 2018 P&C, is the clarity of language in the new draft better, the same or worse?
>Wording needs to be checked to avoid confusion (e.g. Criteria e.g. 4.2 and 4.4)
>Make the language a bit more straightforward when you break it up into a few sentences> Specific check and confirmation of use of ‘shall’ with NIWGs where translated texts are used[>Sentence: even longer than it used to be> Reverted to use of ‘shall’ – this had been removed in 2018 P&C and active language used for easier translation into otherlanguages following feedback on issues with translations]."
they are not in italic in the current draft
Consult and confirm with CBs re this renewed merging of indicators as otherwise next P&C review you have to take them apartagain [Proposed C1 is exemplary for merging indicators throughout the draft. In the past, CB comments about single issue indicators
had led to separating out the individual elements to make auditing and raising of CARs clearer. This now seems to have been
reversed].
What is meant by adequate? Especially for auditors.

#Indicator

Comment (English)

7

1.1

8

1.1

9

1.1

10

1.1

11
12
13
14
15
16

1.1.1
1.1.1
1.1.1
1.1.1
1.1.1
1.1.1

17

1.1.1

18
19
20

1.1.1
1.1.1
1.1.1

21
22
23
24

1.1.1
1.1.1
1.1.1
1.1.1

1.1 The Unit of Certification provides adequate information via a transparent process to relevant stakeholders on environmental,social and legal issues relevant to RSPO Principles & Criteria, in appropriate languages and forms to allow for effective participationin decision-making - according to relevant standards agreed by said stakeholders"1.1 The Unit of Certification provides adequate information via a transparent process to relevant stakeholders on environmental,social and legal issues relevant to RSPO Principles & Criteria, in appropriate languages and forms to allow for effective participationin decision-making - according to relevant standards agreed by said stakeholders"
1.1 The Unit of Certification provides adequate information via a transparent process to relevant stakeholders on environmental,social and legal issues relevant to RSPO Principles & Criteria, in appropriate languages and forms to allow for effective participationin decision-making - according to relevant standards agreed by said stakeholders
The Unit of Certification provides adequate information via a transparent process to relevant stakeholders on environmental, social
and legal issues relevant to RSPO Principles & Criteria, in appropriate languages and forms to allow for effective participation indecision-making - according to relevant standards agreed by said stakeholders
There should be specific guidance or further explanation on what is meant by "confidential information".
"speficied" - spelling error.
In all the standard it is important that the differentiation between what it should apply for a medium and large producer is made.
1.1.1 Continue to take the same structure of guide 1.1.1. 2018, without incurring the confidentiality of the company
Eliminate "FREE" - Not synchronous with the English version
Proposed Indicator 1.1.1: Representing the word "for free" because there will be perception that there are documents provided in
paid.
1.1 Certification Unit never implements payments if stakeholders want to access information/management documents related to
PNC RSPO, so this indicator regarding the provision of documents for free is not necessary
Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid
Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid
In indicator 1.1.1 there is the word "free". The word should be deleted so as not to cause new perceptions in the form of documents
provided paid.
1.1.1 - Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid
1.1.1: The word "free" is deleted because if it is said for free, the perception arises that there are documents provided in paid
Proposed: Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid
Proposed: Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid#Indicator

Comment (English)

25

1.1.1

"Comment:
Deleted the word ""for free"" because if it is said for free, the perception arises that there are documents provided in paid

26

1.1.1

27

1.1.1

28
29

1.1.1
1.1.1

30

1.1.1

31

1.1.1

32

1.1.1

33

1.1.1

34
35

1.1.1
1.1.2

36

1.1.2

Proposed changes:
1.1.1 (c) Except for confidential information, management documents specified in the RSPO P&C are provided for the public and in
the language as they should."
Proposed Indicator 1.1.1: Deleted the word "for free" because if it is said for free, the perception arises that there are documents
provided in paid
Indicator 1.1.1 (c) Proposed to: The word "for free" is deleted because if you use the word "for free", the perception arises that
there are documents provided in paid.
Propose on indicator 1.1.1 Deleted the word "for free" so that there is no perception of documents provided accessed in paid
"1.1.1: The word ""free"" is deleted because it is said for free, the perception arises that there is a document
which is provided in paid.""Proposed 1.1.1:
Deleted the word in indicator 1.1.1 ""for free"" because if it is said for free, it shows that in the provisions of the RSPO there are
documents provided in paid"
Indicator 1.1.1 - Proposed: Deleted the word "for free" because if it is said for free, the perception arises that there are documents
provided in paid
"Proposed 1.1.1
The word ""free"" is deleted because if it is said for free, the perception arises that there are documents provided in paid"
Proposed: Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid.
So that the sentence becomes "1.1.1 (c) Except for confidential information, the management documents specified in the P&C RSPO
are provided for the public in the language as it should".
Deleted the word "for free" because if it is said for free, the perception arises that there are documents provided in paid
1.1.2. Records of identified stakeholders with their nominated representatives; requests for information by stakeholders andresponses to requests shall be maintained and made available by the Unit of Certification with the prior agreement, informationand consent of these stakeholders
1.1.2. Records of identified stakeholders with their nominated representatives; requests for information by stakeholders andresponses to requests shall be maintained and made available by the Unit of Certification with the prior agreement, informationand consent of these stakeholders#Indicator

Comment (English)

37

1.1.2

38

1.1.2

39
40

1.1.2
1.1.2

41
42

1.1.2
1.1.2

43

1.1.2

44

1.1.2

45
46

1.1.2
1.1.2

47
48

1.1.2
1.1.2

49
50

1.1.2
1.1.2

"1.1.2. Records of identified stakeholders with their nominated representatives; requests for information by stakeholders andresponses to requests shall be maintained and made available by the Unit of Certification with the prior agreement, informationand consent of these stakeholders"
1.1.2. Records of identified stakeholders with their nominated representatives; requests for information by stakeholders andresponses to requests shall be maintained and made available by the Unit of Certification with the prior agreement, informationand consent of these stakeholders
proposed to change "....nominated representatives" to "nominated representatives (if any)", as not all stakeholders have this"1.1.2: After the sentence ""along with its representatives appointed ""added"" if there is ""because not all Stakeholders pointed totheir representatives."
The word "along with" changed to "or""Indicator 1.1.2 Proposed:
The word ""along with"" changed to ""or""""Proposal:
The word ""along with"" changed to ""or""""Proposal:
The word ""along with"" changed to ""or"""
Proposed Indicator 1.1.2: Changing the word "along with" to "or"1.1.2: After the phrase "along with the appointed representative" added "if there is" because not all stakeholders pointed to theirrepresentatives.
1.1.2 - the word "along with" changed to "or"Indicator 1.1.2 (c) proposed to: the word "along with" changed to "or" so that the sentence becomes "notes about identified
stakeholders or appointed representatives; requests for information by stakeholders; and responses to the request must be
managed."
Proposed improvement in indicators 1.1.2 Words along with replaced "or", because not all revolutions with their representatives.
"Comment:
The word ""along with"" changed to ""or""Proposed changes:
1.1.2 (c) Note about identified stakeholders or designated representatives; request for information by stakeholders; and responses
to these requests must be managed."#Indicator

Comment (English)

51

1.1.2

"The word ""along with"" changed to ""or""

52

1.1.2

53
54

1.1.2
1.1.2

55
56
57

1.1.2
1.1.3
1.1.3

58

1.2

59

1.2

60

1.2

61

1.2

62

1.2

Note about identified stakeholders or designated representatives; request for information by stakeholders; and responses to theserequests must be managed."
Indicator 1.1.2 (c) needs to replace the word "along with" to "or" so that the sentence reads "notes about identified stakeholders or
appointed representatives; requests for information by stakeholders; and responses to the request must be managed".
Propose on indicator 1.1.2 The word "along with" changed to "or"The word "along with" being "or" so that the indicator 1.1.2 (c) The sentence becomes: Note about the identified stakeholders or
appointed representatives; request for information by stakeholders; and responses to these requests must be managed.
Proposed Indicator 1.1.2: Changing the word "along with" to "or"Communication - wrong spelling.
"A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited."
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
"Working Animal Rights - Comments
The rights of working animals such as buffalo, donkey, horse etc.is an issue that has not been raised yet by the RSPO standards
though working animals play an important role in the production of palm oil.
Any animal is subject to rights under the regulations in the different countries, evidence from palm oil producers showed that theseanimals do not have neither an adequate medical record, nor identity [age, history, origin etc.], nor are they subject to standard
operating procedures that reflect the animals complete life history.
What is the RSPO position/requirements on animal protection as these animals are workers of the companies that produce oil palm.
>Suggest RSPO to take into account the working animals and its associated procedures/requirements, its related topics such asanimal health, smallholder support etc."
This is a 'feel-good' criterion. The indicator focuses on just policy and procedure and not implementation or actual commitment. Be
realistic, it should be framed in a way that certificate holders, and members, recognise the magnitude of this problem especially in
Asia.
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.

#Indicator

Comment (English)

63

1.2

64

1.2

65

1.2

66

1.2

67

1.2

68

1.2

69

1.2

70

1.2

71

1.2

72

1.2.1

"1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria."
The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
1.2. The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
The certification unit undertakes to respect ethical practices in all its operations and business transactions, based on objective,
verifiable criteria.
"(C) -> (c)

73

1.2.1

please note that the system of dote point should remain consistent.
e.g.
6.2.9 use "" a. ""6.2.1 use "" a) ""6.7.1 use "" (a) ""6.7.3 use (i) while there is no ""a) after the (i)"A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.

#

Indicator

Comment (English)

74

1.2.1

75

1.2.1

76

1.2.1

77

1.2.1

78

1.2.1

79
80

1.2.1
1.2.1

81

1.2.1

A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.
A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area. A system is in place to monitor compliance with and implementation of thepolicy and ethical business practices in general - based on guidelines published by the RSPO, the result of a multi-stakeholder effort
to agree on the criteria to be audited.
"A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area."
A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.
A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.
add definition of "corruption, bribery"A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.
A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.

#

Indicator

Comment (English)

82

1.2.1

83

1.2.1

A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area. A system is in place to monitor compliance with and implementation of thepolicy and ethical business practices in general - based on guidelines published by the RSPO, the result of a multi-stakeholder effort
to agree on the criteria to be audited.
"A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.

84
85

1.2.1
1.2.1

86

1.2.1

87

1.2.1

88

1.2.1

A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
"
1.2.1 (c) this is not clear what is expected"Proposed Indicator 1.2.1:
1. When compared to the English version of the translation is not right, usual in point A becomes a fair business policy
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify information in point C""1. When compared to the English version of the translation is not right, usual in point A becomes a fair business policy
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify information in point C""Comment:
1. When compared to the English version of the translation is not right.
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal.
Proposal to point (a): Respect a fair business policy
3. Point C is unclear, especially the information in question. Should be deleted"
Proposed 1.2.1 Improvement of appreciation translation is "respect" because the English version respect.

#Indicator

Comment (English)

89

1.2.1

"Proposed changes:

90
91
92

1.2.1
1.2.1
1.2.1

93

1.2.1

94
95

1.2.1
1.2.1

96

1.2.1

1. When compared to the English version, the translation is not right, the proposal to the ""Point A"" translation is changed to""Respect Fair Business Policy""
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify what is meant by information in point C"
1.2.1 Details regarding the contents of the Code of Ethics policy should not be raised in the indicator but described in the guide1.2.1 - When compared to the English version of the translation, the proposal in point a.) Becomes respect for a fair business policy"Proposal:
1. When compared to the English version of the translation is not right, the proposal on point A becomes a fair business policy
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify information in point C""Indicator 1.2.1 is proposed to:
1. When compared to the English version of the translation is not right, usual in point A becomes a fair business policy.
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify information in point C"
1.2.1 - Need to clarify information on point C"1.2.1: Words in points (b) ""abuse of resources"" deleted because in addition to opening different interpretations it is also
subjective. P&C should not make milli-interpretation and subjective things. When The company allows the community to use land
For non -palm oil plants, part of the comdev, whether it is 'abuse'? If there are big activities in the district, Then the local
government asks to be supported by an ambulance or bus School of company, is that 'abuse'?""1.2.1: Check the translation again about the fragrant.
(b) a prohibition of all forms of corruption, bribery andFragitant Use of Funds and Resources;(b) Prohibition of all forms of corruption, bribery, andembezzlement of money and abuse of resources"

#

Indicator

Comment (English)

97

1.2.1

98

1.2.1

99
100

1.2.1
1.2.1

101

1.2.1

102

1.2.1

103

1.2.1

104

1.2.1

105
106

1.2.1
1.2.1

"Proposal:
1. When compared to the English version of the translation is not right, usual in point A becomes a fair business policy
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify information on points""Proposed changes:
1. There is a difference in scent when compared to the English version, its proposal to the ""point A"" translation is changed to""Respect Fair Business Policy""
2. What is meant by reasonable business behavior? A reasonable business behavior should be removed because it is something thathas been running properly.
3. It is necessary to describe in more detail what is meant by information in point C""1. When compared to the English version of the translation is not right, usual in point A becomes a fair business policy""Proposed Indicator 1.2.1:
1. When compared to the English version of the translation is not right, usual in point A becomes a fair business policy
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normal3. It is necessary to clarify information in point C""1.2.1: The word in point (b) ""abuse of resources"" is deleted because in addition to opening different interpretations is also
subjective. P&C should not make a muilti-interpretation and things that are subjective. If the company allows people to use land fornon -palm oil plants, part of Comdev, is that 'abuse'? If there are major activities in the district, then the local government asks to
be supported by the company's ambulance or school buses, is that 'abuse'?"
Propose on indicator 1.2.1, namely improving language translation in the word appreciation to "respect" because in the English
version in the form of the word "respect".
2. What is meant by reasonable business behavior? In our opinion this does not need to be included because this is something
normalComments: 1. When compared to the English version of the translation is not right. 2. What is meant by reasonable businessbehavior? In our opinion this does not need to be included because this is something normal. Proposal on point (a): Respect fairbusiness policy 3. Point C is unclear, especially the information in question. Should be deleted
point A is changed to respect the fair business policy"1.2.1: Check the translation again about the fragrant.
(b) a prohibition of all forms of corruption, bribery and fragitenit use of funds and resources;(b) prohibition of all forms of corruption, bribery, and embezzlement of money and abuse of resources;"#Indicator

Comment (English)

107

1.2.2

108

1.2.2

109

1.2.2

110

1.2.2

111

1.2.2

112

1.2.2

113

1.2.2

114

1.2.2

115

1.2.2

116

1.2.2

A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
A policy of ethical conduct is in place and implemented in all business operations and transactions, including recruitment andcontracts - in accordance with objective international and/or national benchmarks, in agreement with external civil society
stakeholders. The RSPO can set up upstream multi-stakeholder workshops to agree on the criteria and thresholds to be followed,
depending on the type of player and geographical area.
A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
A system is in place to monitor compliance with and implementation of the policy and ethical business practices in general - basedon guidelines published by the RSPO, the result of a multi-stakeholder effort to agree on the criteria to be audited.
"1.2.2: The indicator is changed to; ""1.2.2 Procedure
Risk Prevention and Management of Code of Ethics Violationmust be arranged and implemented. There must be evidenceshows that workers know the existence of the code of ethics """"1.2.2 This indicator is proposed to change to:
The certification unit must show that the implementation of the code of ethics policy is going well based on evidence of theimplementation of work procedures in the related operational department
Consideration: If work procedures are implemented properly, it can be ascertained that the application of the code of ethics has
also been running, including the implementation of internal audit procedures that also control the implementation of the work
procedures. So there is no need for procedures regarding the violation of the code of ethics"

#

Indicator

Comment (English)

117

1.2.2

118

1.2.2

119

1.2.2

"Proposal:
Delete the word ""all potential"" because it cannot be said to be a violation"
1.2.2: The word "all potential" is removed because the potential for violations is very multi-interpretation and cannot be said to be a
violation.
"Delete the word ""all potential"" because it cannot be said to be a violation

120
121

1.2.2
1.2.2

122

1.2.2

123

1.2.2

124

1.2.2

125

1.2.2

126

1.2.2

127
128
129

1.2.2
1.2.2
1.2.2

Procedure for managing the violation of the Code of Ethics must be prepared and implemented. There must be evidence thatindicates that workers know the code of ethics."
Indicator 1.2.2 is proposed to: The word "all potential" is removed because it cannot be said as a violation.
Proposal 1.2.2 Improvement to remove the word all potential because it creates a broad interpretation of not being able toauditability and cannot be said to be a violation"Comment:
Delete the word potential because it cannot be said as a violation
Proposed changes:
1.2.2 Procedure for Management of Violations of the Code of Ethics must be prepared and implemented. There must be evidence
that indicates that workers know the code of ethics.""Proposed Indicator 1.2.2:
Delete the word ""all potential"" because it cannot be said to be a violation""1.2.2: The word ""all potential"" is removed because of potential
Violations are very multi-interpretation and cannot be said
as a violation."
In indicators 1.2.2 The word "all potential" has a broad meaning and diverse interpretation, this can cause something that is biased
and vague and tends to be subjective because the potential cannot be said as a violation so that we propose to be removed.
Proposed: removing the word '' all potential "because the potential cannot be said as a violation, so the sentence becomes: 1.2.2
Procedure for Management of Violations Code of Ethics must be prepared and implemented. There must be evidence that showsthat workers know the existence of the code of ethics.
1.2.2 - Remove the word '' all potential "because it cannot be said as a violation
Proposed 1.2.2 The word "all potential" should be removed because it causes broad interpretation"Proposal:
Delete the word ""all potential"" because it cannot be said to be a violation"

#Indicator

Comment (English)

130

1.2.2

131
132

1.2.2
1.2.2

"Proposed Indicator 1.2.2:
Delete the word ""all potential"" because it cannot be said to be a violation"
Proposed 1.2.2: Remove the word "all potential" because it cannot be said as a violation
Proposed Indicator 1.2.2: Removing the word "all potential" because it cannot be said as a violation

#

Indicator

Comment (English)

1

2.1

2

2.1

3

2.1

4

2.1

5

2.1

6

2.1

7

2.1.1

8

2.1.1

9
10

2.1.1
2.1.1

11
12

2.1.1
2.1.1

13

2.1.1

2.1 There is compliance with all applicable local, national, and ratified international laws and regulations.by always referring to
the most demanding laws in terms of respect for human rights.
There is compliance with all applicable local, national, and ratified international laws and regulations.by always referring to themost demanding laws in terms of respect for human rights.
"2.1 There is compliance with all applicable local, national, and ratified international laws and regulations.by always referring to
the most demanding laws in terms of respect for human rights."
2.1 There is compliance with all applicable local, national, and ratified international laws and regulations.by always referring to
the most demanding laws in terms of respect for human rights.
Correction of translation in criteria 2.1 points (a) all laws and regulations, including but not limited to: regulations governing
land rights and land use rights, customary law, labor, agricultural practices (for example, the use of chemicals), theenvironment (for example, Law on Protection of Wildlife, Pollution), Storage, Transportation, and Processing Practices.
"This note section to be deleted because:• Indonesia has many regulations according to its level (Law to Ministerial Regulation). National interpretation will havedifficulty identifying it.
• There are different regional regulations according to each location• The dynamics of laws and regulations in Indonesia are very high (especially the addition of legislation)• All certification units have identified related legislation requirements in their respective locations.
"
Isn't this a bit vague? Could an auditor construe "legal requirements" to only refer to domestic laws and inadvertently fail torecognise the need to comply with ratified international obligations? There is a danger here unless it is spelt out.
"2.1.1: At the end of the sentence the word ""applies"" is added
The English version is 2.1.1 (c) The Unit of Certification
Complies with Applicable Legal Requirements."
Proposal to add words that "apply"
2.1.1: At the end of the sentence the word "applies" according to the English version is 2.1.1 (c) The Unit of Certification
Complies with Applicable Legal Requirements.
incomplete verse - add "applies" to the verse to match the English version
Define whether the scope of "ratified international regulations" includes compliance with international directives such as the
new deforestation regulation of the European Union.
Define whether the scope of "ratified international regulations" includes compliance with international directives such as the
new deforestation regulation of the European Union.

#Indicator

Comment (English)

14

2.1.2

15

2.1.2

16

2.1.2

17
18

2.1.2
2.1.2

A documented system for ensuring legal compliance is in place. This system has a means to track changes to the law and also
includes listing and evidence of legal due diligence of all contracted third parties, recruitment agencies, service providers andlabour contractors. This documentation shall remain available for consultation upon request by defined and relevant
stakeholders for ensuring legal compliance is in place.
A documented system for ensuring legal compliance is in place. This system has a means to track changes to the law and also
includes listing and evidence of legal due diligence of all contracted third parties, recruitment agencies, service providers andlabour contractors. This documentation shall remain available for consultation upon request by defined and relevant
stakeholders for ensuring legal compliance is in place.
A documented system for ensuring legal compliance is in place. This system has a means to track changes to the law and also
includes listing and evidence of legal due diligence of all contracted third parties, recruitment agencies, service providers andlabour contractors. This documentation shall remain available for consultation upon request by defined and relevant
stakeholders for ensuring legal compliance is in place.
add a definition or change "labour contractor" into "labour recruiters" ?
"table of definitions includes- contractor- labour contractor

19

2.1.2

20
21

2.1.2
2.1.2

22

2.1.2

23
24

2.1.2
2.1.2

consider using terms in the definitions throughout and consistently""A documented system for ensuring legal compliance is in place. This system has a means to track changes to the law and also
includes listing and evidence of legal due diligence of all contracted third parties, recruitment agencies, service providers andlabour contractors. This documentation shall remain available for consultation upon request by defined and relevant
stakeholders for ensuring legal compliance is in place."
There is no change with P&C 2018
The scope of due diligence at the legal level should be established, both in the front related to the issues of hiring, safety andhealth at work, environment, accounting and including at the money laundering level. The scope must be defined by the UDC,
and that must be established in the standard to facilitate the audit.
In this requirement, there is currently subjectivity in audits, because although companies have defined their scope of due
diligence, auditors from their experience ask that more requirements be controlled.
OK. It is necessary to be specific about what you want to prioritize.
Include that the scope of due diligence will be established by the UDC in accordance with the nature of the hired third party
and the services provided to the UDC, since the due diligence made to the Internet service provider is not the same as the
supplier than the supplier tank maintenance#Indicator

Comment (English)

25

2.1.3

26

2.1.3

27
28

2.1.3
2.1.3

29

2.1.3

30

2.1.3

31

2.1.3

32

2.1.3

Legal status, including occupancy and use rights, is clearly documented. Spatial boundaries are visibly delineated andmaintained. Legal registration or written authorization from governmental authority(ies) must be available. This legal status
must be validated by a third party, in agreement with the local population.
Legal status, including occupancy and use rights, is clearly documented. Spatial boundaries are visibly delineated andmaintained. Legal registration or written authorization from governmental authority(ies) must be available. This legal status
must be validated by a third party, in agreement with the local population.
Amend to "Legal boundaries should be demarcated on the ground and visibly maintained..."Legal boundaries are much clearer term rather than spatial boundaries. Propose to stick with current term of "legal
boundaries" that holds valid approval from the authority.
"Legal status, including occupancy and use rights, is clearly documented. Spatial boundaries are visibly delineated andmaintained. Legal registration or written authorization from governmental authority(ies) must be available. This legal status
must be validated by a third party, in agreement with the local population.""2.1.3: The word ""spatial limit"" is changed to ""legal limit""
because the legal limit is declared by government agencies
Clearly in the field such as a HGU stake."
Indicator 2.1.3 (c) Proposed to: The sentence "Legal registration document or written authorization of the authorized
government institution must be available" deleted because it has been included in the initial sentence.
"For the phrase ""legal registration document or written authorization from the authorized government institution must be
available"" to be removed because it has been covered in the initial sentence
Become

33

2.1.3

34

2.1.3

2.1.3 (c) Documenting legal status clearly, including user control and rights. The spatial limit is determined and maintained sothat it remains clearly visible."
For indicators 2.1.3 In the sentence "Legal registration document or written authorization from the authorized government
institution must be available" proposed to be deleted because the sentence has been included in the beginning so that it canbe said to be repetition of meaning.
"Proposal:
For the phrase ""legal registration document or written authorization from the authorized government institution must be
available"" to be removed because it has been covered in the initial sentence"#

Indicator

Comment (English)

35

2.1.3

36

2.1.3

37

2.1.3

38

2.1.3

39

2.1.3

40

2.1.3

41

2.1.3

42

2.1.3

"Proposed Indicator 2.1.3:
For spatial boundary sentences corrected into boundary sentences according to the law.
The phrase ""Legal registration documents or written authorization from the authorized government institution must be
available"" only deleted because the documentation of legal status and its mastery have been included."
Proposed: For the phrase "Legal registration documents or written authorization from the authorized government institution
must be available" to be deleted because it has been covered in the initial sentence.
"Proposed Indicator 2.1.3:
For the phrase ""legal registration document or written authorization from the authorized government institution must be
available"" to be removed because it has been covered in the initial sentence""Proposal:
For the phrase ""legal registration document or written authorization from the authorized government institution must be
available"" to be removed because it has been covered in the initial sentence"
Proposed indicator 2.1.3: There is a repetition of sentences in this indicator. For the phrase "legal registration document or
written authorization from the authorized government institution must be available" it is recommended to be deleted because
it has been covered in the initial sentence
2.1.3: The word "spatial limit" is changed to "legal limit" because the legal limit is clearly declared by government institutions in
the field such as HGU stakes.
the sentence "legal registration documents or written authorization from the authorized government institution must be
available" just deleted because it has been covered in the initial sentence"Comment:
For the phrase ""legal registration document or written authorization from the authorized government institution must be
available"" to be removed because it has been covered in the initial sentence

43

2.1.3

Proposed changes:
2.1.3 (c) Documenting legal status clearly, including user control and rights. The spatial limit is determined and maintained sothat it remains clearly visible.""1. Replace the ""spatial limit"" with the ""legal limit"" that is the boundary stated by the government in the field is the HGU
stake
2. The last sentence ""Legal registration document or written authorization from an authorized government institution must be
available"" is redundant because it has been stated in the first sentence"#

Indicator

Comment (English)

44

2.1.3

45

2.1.3

46

2.1.3

47

2.1.3

48

2.1.3

49

2.1.3

50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66

2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2.1
2.2.1
2.2.1

"Indicator 2.1.3 Proposed:
For the phrase ""legal registration document or written authorization from the authorized government institution must be
available"" to be removed because it has been covered in the initial sentence""Proposal:
For the phrase ""Legal registration documents or written authorization from the authorized government institution must be
available"" to be deleted because it has been covered in the initial sentence."
2.1.3 - For the phrase "Legal registration document or written authorization from the authorized government institution must
be available" to be removed because it has been covered in the initial sentence"2.1.3 The sentence ""legal registration document or Written authorization of authorized government institutions
must be available ""to be deleted because it has been covered at the initial sentence so that it is reduced."
2.1.3 Sentence "Legal registration document or written authorization from the authorized government institution must be
available" to be removed because it has been covered in the initial sentence so that it is reduced.
2.1.3 Need further explanation, what is meant by "legal registration documents or written authorization from the authorized
government institution must be available"
2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
Please define what is meant by legal contractors in the Definition Section.
2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers"2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers""2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers""2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers"
2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers
2.2 The Unit of Certification commits to contract or engage ONLY legal contractors and FFB suppliers[Accra WS] 2.2 NI process should define what is legal based on national regulation. How to include 'legitimacy' land use rights.
"The list of contracted parties should cover all growers, MB certified or not"The list of contracted parties should cover all growers, MB certified or not
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents

#

Indicator

Comment (English)

67
68
69
70
71
72
73

2.2.1
2.2.1
2.2.1
2.2.1
2.2.1
2.2.1
2.2.1

74

2.2.1

75
76
77
78
79
80
81
82

2.2.2
2.2.2
2.2.2
2.2.2
2.2.2
2.2.2
2.2.2
2.2.3

83
84
85

2.2.3
2.2.3
2.2.3

86
87
88
89

2.2.3
2.2.3
2.2.3
2.2.3

90

2.2.3

MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
The list of contracted parties should cover all growers, MB certified or not
The list of contracted parties should cover all growers, MB certified or not
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
This should be specific to say "...legal contracted parties..."The list of contracted parties should cover all growers, MB certified or not"2.2.1: At the end of the sentence added ""if needed""because the involvement of the contractor is not mandatory and only if needed.
2.2.1: The Unit of Certification Shall Engage Legal Contractors (IF Needed)."2.2.1: At the end of the sentence added "if needed" because the involvement of the contractor is not mandatory and only ifneeded. 2.2.1: The Unit of Certification Shall Engage Legal Contractors (IF Needed).
The verification of legality of contracted parties should be updated regularly"MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents""MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents."
The verification of legality of contracted parties should be updated regularly
What is meant by legal requirements?
The verification of legality of contracted parties should be updated regularly"The verification of legality of contracted parties should be updated regularly"
How is this indicator auditable, especially for FFB suppliers and transport contractors? Are the auditors now expected to visit
these FFB supplier sites?
"MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents"
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
the recruitment fees should only based on the statutory fees. Others non-documented cost should not bare by the company as
is only from verbally by workers and unable to verify the source.
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
Legal status, including occupancy and use rights, is clearly documented. Spatial boundaries are visibly delineated andmaintained. Legal registration or written authorization from governmental authority(ies) must be available. This legal status
must be validated by a third party, in agreement with the local population.
MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents

#

Indicator

Comment (English)

91
92
93
94

2.2.3
2.2.3
2.2.3
2.2.3

95
96
97
98
99
100

2.3
2.3
2.3
2.3
2.3
2.3

101

2.3

MB mills should ensure legality of contracted parties through ISPO and MSPO certification documents
No worker below 18 years - stating it is a young worker below 18 years would be redundant
young worker is defined to min under 18 in defentions already. why make explicit here?
2.2.3 The part stating "payment of recruitment costs and other related costs" to be removed because it raises various
interpretations of what is meant by other related costs. Please also consider that third parties also have their own mechanisms
in the recruitment of their employees as needed and cannot be intervened by the certification unit. Even if there are otherrelated costs that violate the laws and regulations, it has been regulated in a contract where one of the requirements clauses isthat the third party must comply with laws and regulations
2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
"2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s)."The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
"This whole principle would benefit from being more linked with EUDR requirements and consideration should be given to therecommendations from the EUDR gap analysis report RSPO commissioned, including these:""● Geo-location requirements of polygon should be added to bring it in line with the EUDR for plots above 4 hectares;● Definition of “FFB origin” should be added and aligned with EUDR definitions of “plot of land”;● Special attention should be given to “an extension of land within a single real-estate property”;● The transition period for mills going for the first year of certification to collect smallholder geolocations should be deleted."""2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).

#Indicator

Comment (English)

102

2.3

"Criteria 2.3:
EUDR: Suggest to include a separate add-on module for RSPO CSPO volumes for sale to the EU:>Integration of the EUDR traceability requirements: geolocation (plots over 4 ha, definition of FFB origin to be added & alignedwith EUDR definition of plot of land etc.), legality according to the laws of producer country inc. env. human and labour rights
and FPIC (to be transferred through supply chain), requirements for the non-certified source for MB supply (Due diligence on
no deforestation, legality and geolocation)>>Extend the RSPO's IT traceability system i.e. Palmtrace to include EUDR requirements (geo-location, deforestation, legality)
to be uploaded by mills and transferred through supply chain.
>>Develop an EUDR information system for all material, certified and conventional, within the mass balance supply>>Support independent smallholders to gather the geolocation data
>Suggest to have a clear ToR and timeline for the taskforce for developing this procedure involving CBs and producers invarious countries (SEA, Latam, Africa): guidance for certificate holder, guidance for auditors.
For RSPO P&C (i.e. not for the EUDR add-on module) and specifically for indirect FFB origins:
Develop a risk-based approach for traceability, with (more generous) timebound plan to map indirect suppliers, andrecognition of engagement in JA initiatives.
[Traceability:>Implementation procedure for 2.3.2: mills have 3 years to get this data from their third party suppliers, namely their collection
centres, agents and everybody else to get the geolocation of the FFB origins. This is very challenging for mills.
>Buying indirect FFB volumes from collection centres or any intermediaries adds another layer of complexity and risk i.e. risk of
mixing products deriving from areas with various env. and soc. Issues. The collaboration with the collection centres remains
challenging because of the typical existence of multiple layers of traders involved.
>There are competition amongst the mills, the plantations (certified and non-certified), agents which impacts the behaviour of
the indirect suppliers. Therefore, they would not want to disclose the location of FFB origins to the mills because they fear thecompany would buy directly from the smallholders.
>Regarding the 3-year timeframe. where companies have to collect this information, the issue is that indirect suppliers are notbound by long term contract with the company depending on their supplies. Therefore, having the static 3 -year period to get
information may not be realistic Company would probably look at having a time frame of 1-year after onboarding anagent/middle/ 3rd party to collect the information of their supplies.
> There are challenges for companies/RSPO members to gather the geolocation data because company may require moreresources such as hiring dedicated staff to focus on this task.
>How does the current RSPO system (Palmtrace) for traceability relate to EUDR?
>Dropped from Draft1 is the PROCEDURAL NOTE ‘A Task Force is to be established to propose a solution that can be audited
and would require growers to gradually progress towards full implementation of this indicator’.]"#

Indicator

Comment (English)

103
104
105
106
107
108

2.3
2.3
2.3
2.3
2.3
2.3

2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
"EU Deforestation Regulation (EUDR) requirements – Comments
In addition to continued engagement efforts with the EU to aid the recognition of RSPO’s solid deforestation approach that
includes use of HCV/HCS assessments, we strongly urge RSPO to develop a modular approach for the P&C that will retain thestrong RSPO base certification, but allows for those growers who wish to sell EUDR-compliant volumes to the EU, to obtain an
additional compliance check via a separate module. This will ensure continued relevance of RSPO certification as it will aide
implementation of a legal requirement applicable to RSPO’s SC members (retailers, CGMs, traders).
This module could be classified as ‘interim’ until more clarity is provided by EU or their own revision process further finetunes
the EUDR.

109
110
111

2.3
2.3
2.3

Sourcing RSPO CSPO as part of a downstream companies due diligence approach to demonstrate compliance with EUDR will
require the following:> geo-location data needs to be defined in line with EUDR
>Deforestation (cut-off date, definition of forest as per FAO, exemption for High Forest Cover Landscapes Countries (RSPO) vsnon exemption (EUDR), check RaCP cut-off dates and align> check coverage of all legality aspects listed under EUDR and develop indicators where needed (e.g. on tax compliance)"
2.3 The Unit of Certification shall source fresh fruit bunch (FFB) ONLY from legal supplier (s).
[Jakarta WS] 2.3 a proposal for UoC to conduct 'risk assessment' of all direct and indirect FFB supplier - with mitigation plan?
"[Abidjan WS] 2.3 Criteria and indicator level - concerns over the interpretation of 'legal status' - as being the land titles andthere is lack of recognition of 'legitimate land rights'.
Proposed to indicate for National Interpretation to clearly provide guidance on how legitimate land rights or user rights arerecognised - not just land titles. "#Indicator

Comment (English)

112

2.3.1

"For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/trading license, or is part of a cooperative which allows the buying and selling of
FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"#Indicator

Comment (English)

113

2.3.1

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board

114

2.3.1

115

2.3.1

116

2.3.1

Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""
Suggest to line this up more with new EUDR geolocation requirements for plots above 4 ha. Definition of FFB origin should be
added and aligned with EUDR definitions of "plot of land."[Accra WS] 2.3.1. and 2.3.2 - Ni should define the acceptable proof of ownership - to include some legitimate use rights, where
there is no land title (official documentation).
"define what and how geo location parameters: polygon, 1 coordinate, above how much ha?.
suggest to be in line with 4ha of EUDR. Keep in mind that this 4ha might be up for review in 5 years"

#Indicator

Comment (English)

117

2.3.1

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""#Indicator

Comment (English)

118

2.3.1

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""#Indicator

Comment (English)

119

2.3.1

"For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"#Indicator

Comment (English)

120

2.3.1

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board

121

2.3.1

122

2.3.1

123

2.3.1

Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""
how do you define origin? a physically connected area owned by the supplier? What is one supplier has multiple scattered plotsof land? Should he supply all specific geo location information?
[Accra WS] 2.3.1 for all directly sourced FFB - there should be a clear scope defined - what about those seasonal supplier (thoseSH only send once in a year) - does it mean geolocation and ownership documents required too? Also to provide a progressing
collection of such information - to avoid a complete cut-off of FFB suppliers that information is not able to be collected within
the timeframe, especially for a large database of suppliers.
"Is this part applicable here? Because when you buy FFB from 'a cooperative which allows the buying and selling of FFB' - so a
trader, not somebody that produces FFB - you are not sourcing directly, but indirectly. Correct?"#Indicator

Comment (English)

124

2.3.1

125

2.3.1

Suggest to highlight the context of current developments of EU deforestation legislation or various national due diligencelegislation where legality may be defined more broadly [What FFB from legal suppliers entails in this indicator are
origin/geolocation, ownership and license to operate. The indicator does not include the full legal compliance e.g. as requiredby criterion 2.1 on compliance with all applicable legal requirements such as regulations on labour, agricultural practices andthe environment for the unit of certification].
"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/trading license, or is part of a cooperative which allows the buying and selling of
FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""#Indicator

Comment (English)

126

2.3.1

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""#Indicator

Comment (English)

127

2.3.1

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""#Indicator

Comment (English)

128

2.3.1

129

2.3.1

"RSPO requirements will be more difficult to be aligned with global traceability standards that is increasingly becoming a global
trend as evident from EU Deforestation Regulation, UK Environment Act, US Forest Act, and interests from other major palm oil
consumer countries such as China. Although RSPO is indeed a different sets of standard, but this will make it more impracticalfor producer members to follow different sets of standards. It was observed that the EUDR-RSPO Gap analysis report concludes
that RSPO is in a good position to provide information on the EUDR geolocation requirement. Especially, Criterion 2.3.1
provides a basis under which geo-location information can be made available for all Fresh Fruit Bunches (FFB) (certified andnon-certified).
However, for full alignment with EUDR requirements the following gaps needs to be covered on new RSPO P&C Standard:
1. Geo-location requirements of polygon should be added to bring it in line with the EUDR for plots above 4 hectares;
2. Definition on ‘FFB origin’ should be added and aligned with EUDR definitions of ‘plot of land’; Special attention should begiven to the ‘an extension of land within a single real-estate property’;
Therefore, we recommend that RSPO should add more the clarity on “Geolocation” and “FFB origin” definition or
requirement.""2.3.1 Task Clusters need to consider the situation in the field where many direct TBS suppliers (direct suppliers) refuse toprovide information about the land legality document because this is something personal and confidential

130

2.3.1

131

2.3.1

132

2.3.2

133

2.3.2

134

2.3.2

It also makes it difficult for the existence of a certification unit among other surrounding companies that are not certified RSPOin terms of competition to get the supply of FFB from external suppliers because of this requirement.""2.3.1 I suggest modifying item 3 of this indicator:
When applied, legal compliance referring to exploitation and/or crop marketing permits."
Geographical information must be clarified about the term, if this includes coordinates and/or polyigonos of the lots where thecrop develops. Aligned with the new European regulation if polygons and not only coordinates should be included
Agents who sourced FFB from farmers and supply to mills as indirect supply are not resourced enough to carry out activities
such as mapping,etc
Due to the nature of distribution of agent relationship , it is practically not feasible at all to get credible information about thegeo location and proof of ownership
The difference between direct and indirect FFB suppliers creates biases and FFB suppliers would rather become indirect
suppliers as the requirements are lenient.

#Indicator

Comment (English)

135

2.3.2

"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/ trading license, or is part of a cooperative which allows the buying and sellingof FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board

136

2.3.2

Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""This will increase the reputational risk for RSPO.
Previously, the indicator include requirements to have the same traceability evidence as directly sourced FFB (indicator 2.3.1)
that are geo-location, proof of land rights/ownership, and where applicable, valid planting/operating/trading license orcooperative membership allowing it to bu/sell FFB.
Removing some of them, will make it more difficult for RSPO to be aligned with national laws/regulation in Indonesia especiallyISPO.
For example, as RSPO is piloting an alignment with ISPO in Jambi, this change to the criteria will also put that project to morerisk. Eliminating those requirements does not support Government of Indonesia’s (GOI) effort to develop database on
smallholder farmers through the Cultivation Registry Letter (Surat Tanda Daftar Budidaya - STDB) that is also a requirement for
ISPO. This will estrange the relationship of RSPO with GOI and sub-national governments that already have targets and allocate
resources toward STDB and ISPO."#

Indicator

Comment (English)

137

2.3.2

138
139

2.3.2
2.3.2

Agreed with the other comments here - wording on including the other requirements under 2.3.1 needs to be reinstated here.
Not clear why it has been removed
Define what is indirect sourcing and direct sourcing"Recommendation for Indicator 2.3.2:
To keep “the evidence as listed in Indicator 2.3.1”.
Rationale:
To strengthen the message on legal compliance and proper business licensing of the mills as mentioned in Indicator 2.3.1.

140
141

2.3.2
2.3.2

Additional comments for indicator 2.3.2: We support the improvement of this indicator which seems to ensure compliancewith the EU Deforestation Regulation. "[Accra WS] 2.3.2 should include requirement of legality - as this will risk FFB coming from indirect supplier are not legal.
"""For all Fresh Fruit Bunch (FFB), the Unit of Certification sourced through traders (dealers, collection centers), information
listed below shall be obtained:i) Geolocation of FFB origins;ii) Proof of the ownership, customary rights or other land user rights to the land by the farmers;iii) Where applicable, valid planting/ operating/trading license, or is part of a cooperative which allows the buying and selling of
FFB.
Procedural note: A Task Force is to be established to propose a solution that can be audited and would require growers togradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process“And would require growers” > And would require growers and mills
Geolocation:> Using the GeoRSPO platform> Using national traceability initiatives, such as the Malaysia Palm Oil Board
Legality:> RSPO MB mills should ensure all suppliers, certified or not, are certified with national standards (ISPO, MSPO, etc.) which
would guarantee a minimum verification on legal compliance"""#Indicator

Comment (English)

142

2.3.2

"we need to get the clarity about this indicator, whether this new indicator means the mill doesn’t need to prove the legality
and operational license of indirect supplier (including License for Collection centres, agents, cooperative and so on) ?

143

2.3.2

144

2.3.2

Suggest to add: “...as well as other evidence listed in indicator 2.3.1”"
Should also require proof of legality and a valid operational license. In absence of this being required, suggest adding "as well asother evidence listed in indicator 2.3.1.""Suggest to keep the criteria: ""...evidence as listed in 2.3.1"" in.
Now the legality requirement is excluded for indirect FFB. This coudl cause problems if RSPO wants to assist members
complying with EUDR and other mandatory due dilligence that have legality as a basis like the UK Env. Act and upcoming d.d. in
the USA. Most downstream members or RSPO are in these markets and need to show compliance.

145

2.3.2

146

2.3.2

147

2.3.2

Besides, it is watering down the standards compared to 2018. What are the arguments for this?""Suggest RSPO to define geolocation and related requirements from companies i.e. upstream and downstream. What type of
information should company keep/collect and manage?
[What is RSPO definition of geo-location of FFB origins. Is it just a GPS point and hectarage or is it an actual polygon?]""This new indicator means the company doesn’t need to prove the legality and operational license (including License forCollection centres, agents, cooperative and so on).
Suggest to add: “...as well as other evidence listed in indicator 2.3.1”
as for 2.3.1 indicator, It is required to provide a Trader/business operation license for FFB Supplier.
Previously, the indicator include requirements to have the same traceability evidence as directly sourced FFB (indicator 2.3.1)
that are geo-location, proof of land rights/ownership, and where applicable, valid planting/operating/trading license orcooperative membership allowing it to bu/sell FFB. Removing some of those element, will increase the reputational risk for
RSPO and make it more difficult for RSPO to be aligned with national laws/regulation in Indonesia especially ISPO.
Proposed indicator:
2.3.2 For all indirectly sourced FFB, the Unit of Certification shall obtain from the collection centres, agents or otherintermediates, the information on geo-location of FFB origins and other evidence listed in indicator 2.3.1."[Jakarta WS] 2.3.2 Call for maintaining just the geolocation – not to include requirements on legality of indirectly FFB suppliers as legality for indirect suppliers is hard to get.

#Indicator

Comment (English)

148

2.3.2

149
150
151

2.3.2
2.3.2
2.3.2

152
153
154
155

2.4
2.4
2.4
2.4

[Jakarta WS] 2.3.2 Potential risk of watering – where the requirement of ensuring legality from indirect FFB suppliers isremoved. The requirement should be maintained – implementation can be done through guidance or tool provided. –reputation risk to RSPO – also the alignment with ISPO – this is crucial when touching on legality (legality should be the key)
This geolocation information should also include if it corresponds to coordinates and/or polygons
2.3.2 I think I should say that intermediaries must comply with indicator 2.3.1 (if that is the meaning)[Abidjan WS] 2.3.2 only required geolocation but not legality - may leads to un intended consequences of which UoC start
shifting to use indirect suppliers. - Concerns raisedThis system must be accessible to all stakeholders - and the process must be communicated to them in advance.
This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
"Recommendation for Criteria 2.4: After the last sentence, consider adding: “The grievance system shall follow the
Effectiveness Criteria of the UN Guiding Principles on Business and Human Rights”.

156

2.4

157
158

2.4
2.4

159
160
161
162

2.4
2.4
2.4
2.4

Rationale:1)To align with the existing global principles so that we can enhance the use of common language on the effectiveness of thegrievance system.
2)To express a more explicit goal to create and implement an ‘effective’ grievance system.
"
The certification unit, in consultation with communities and workers, develops and implements a system for handlingcomplaints and grievances, and provides for their resolution. This system must be accessible to all stakeholders - and theprocess must be communicated to them in advance.
This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
The certification unit, in consultation with communities and workers, develops and implements a system for handlingcomplaints and grievances, and provides for their resolution. This system must be accessible to all stakeholders - and theprocess must be communicated to them in advance.
This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
The certification unit, in consultation with communities and workers, develops and implements a system for handlingcomplaints and grievances, and provides for their resolution. This system must be accessible to all stakeholders - and theprocess must be communicated to them in advance.

#Indicator

Comment (English)

163
164
165

2.4
2.4
2.4

166

2.4

167
168

2.4
2.4

This system must be accessible to all stakeholders - and the process must be communicated to them in advance.
[2.4] It would be ideal to group all grievance mechanism requirements under one criterion (2.4, 4.5, 5.1.9).
"The certification unit, in consultation with communities and workers, develops and implements a system for handlingcomplaints and grievances, and provides for their resolution. This system must be accessible to all stakeholders - and theprocess must be communicated to them in advance."
Proposal: Continue to use the criteria 4.2 P&C 2018: The existence of a system agreed upon and documented to handle
complaints and complaints, which are implemented and accepted by all affected parties.
Proposed Criteria 2.4: Keep using the sentences in P&C 2018
"Criteria 2.4. In order to be relevant to indicators 2.4.1 and 2.4.2, the sound criterion 2.4 is proposed to be: The certification
unit communicates with the community and workers to implement a system of handling complaints ....

169

2.4.1

170

2.4.1

171

2.4.1

172

2.4.1

173

2.4.1

Considerations: because indicators 2.4.1 and 2.4.2 indicate that the complaint handling system must be made by thecertification unit and then communicated to the community and workers""This is a wooly indicator, packing so many requirements in a single indicator to the point that it is not auditable.
RSPO should be cognizant of the fact that there already exists a common/potential list of grievances in certification units. Thisshould be used as guidance to frame indicator 2.4.1. The indicator has been made very complex and packed with so manyrequirements that it would be difficult to gather objective evidence at the time of audit.
Gender-related grievances or other sensitive grievances should be addressed in a separate indicator. ""A complaint to the grievance mechanism"... It is not possible to complain to a mechanism. An individual can raise a complaint
through the grievance mechanism. This part of the indicator should be reworded.
"[HRWG] Recommendation: To use the phrase ‘known to affected communities etc’ instead? Or another way to express this.
Auditors can ask community members etc whether they know the existence of the grievance mechanism.
Recommendation: To use ‘In consultation’ instead of ‘mutually agreed’ - use ‘in consultation’ in Principle 2 and 4. We can leaveit to the company how to conduct their consultation."
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures
2.4.1 Inconsistent use of '.' and ',' in listing the elements in this indicator. Punctuation should be addressed.

#Indicator

Comment (English)

174

2.4.1

175

2.4.1

176

2.4.1

177

2.4.1

178

2.4.1

179

2.4.1

180
181

2.4.1
2.4.1

182

2.4.1

2.4.1 From audit experience, a grievance mechanism in most UoC is restricted to infrastructure maintenance and housing
facilities. Indicator 2.4.1 takes a whole different dimension where the grievance mechanism is concerned. The framing of thisindicator needs a sound understanding of situations and detailed discussion amongst relevant stakeholders before being placedin the standard. The requirements do not take into consideration nor recognize rural situations and workers' psyches.
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures
The category "spouse of workers" and "their representatives" requires more clarification within this list. If it is suggested thefor those living on the plantation, or within plantation housing, then possibly it could be changed to "dependents of theworkers"? Otherwise they may fall under other relevant stakeholders. It needs to be clear what relation the "spouses" and"representatives" have to the company BESIDES their relationship to the worker.
Recognizing the gravity of the complaint is important. In some cases, the UoC would not have the mechanism to solve complex
complaints, and thus, should also incorporate in its mechanism a point of decision, allowing the complainant to raise it throughthe legal process.
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures[Accra WS] 2.4.1 (iii) To remain just confidentiality - remove 'anonymity' as it will make it difficult for the process"Independent technical advice should be omitted.
justification
1)Leads to conflict of interest2)Undue influence""Grievance mechanisms should include mutal agreement between parties and equal participation of stakeholders.

183

2.4.1

184

2.4.1

185
186

2.4.1
2.4.1

Should also be open for review within certain periods (see how this is arranged in other schemes or guidelines)"
Who determines the "appropriate remediates"? The auditors or the unit of certification? What is considered appropriate? This
is non-auditable.
[Accra WS] 2.4.1 remove the specific mentioning of 'spouses of workers' as this will create different interpretation - where
spouses of workers residing outside of UoC will be needed to be included.
line break
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures#

Indicator

Comment (English)

187

2.4.1

188

2.4.1

189

2.4.1

190

2.4.1

191
192
193

2.4.1
2.4.1
2.4.1

194

2.4.1

195

2.4.1

196

2.4.1

197

2.4.1

198

2.4.1

"Suggest to align the grievance mechanism with the 8 UNGP criteria: legitimate, accessible, predictable, equitable, transparent,
rights compatible, a source of continuous learning, based on engagement and dialogue for operational level grievancemechanisms.
[Is this grievance mechanism aligned with the 8 UNGP criteria based on engagement and dialogue?]"
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures"This procedure may be amended from time to time as the need arises: new regulations (national or international), newgrievances revealed, cases of conflict, etc."
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures
These details make the indicator too lengthy and suggest to move to guidance. The indicator shall keep it precise and auditable.
How to ensure the procedure is child and gender sensitive from CB's auditors perspective?
[Accra WS] 2.4.1 (iv) provide access to ... information and advice - should not be a responsibility of UoC. Define how much andhow to avoid potential conflict of interest?
"This now refers to 'stakeholders' instead of 'all affected parties' - need to be clear if there is any difference in intention here,
and whether changing this wording is likely to exclude any affected parties?
Additionally, explicit reference to HRDs seems to have been removed, not clear why? Need to ensure wording changes do not
reduce the scope of who is included""all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops
to create and implement these procedures"
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures
All relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures#

Indicator

Comment (English)

199

2.4.1

"To remove the sentence of ‘which is gender and child-sensitive' in the indicator.
The purpose of this indicator is to safeguard the complainant's anonymity and prevent any intimidation towards them. To
ensure compliance with this indicator, specific components have been outlined in the grievance mechanism. These
components address the protection of the complainant's identity and aim to mitigate any potential threats or harassment they
may face. Putting the wording of gender and child-sensitive in the indicator would create confusion and repetitive if the intent
of the indicator has been outlined in the elements that shall be follow by the UoC.

200

2.4.1

201

2.4.1

If it is the context, RSPO shall clarify more on what are the condition for UoC to achieve a grievance mechanism that is genderand child-sensitive in order to comply with this indicator."
all relevant stakeholders must be freely informed of grievance resolution mechanisms, or even be involved in the workshops tocreate and implement these procedures"“resolves disputes in an effective manner” is missing now.
The evaluation of effectiveness grievance mechanism still are not covered yet by this indicator.
The evaluation of the effectiveness is very important to promote better management of grievance mechanism and hence
minimise the risk of grievance turning into complaint.
The grievance mechanism system of UoC also shall follow “the Effectiveness Criteria of the UN Guiding Principles on Businessand Human Rights”.
The rationale of this suggestion also to be more aligned with the existing global principles so that we can enhance the use ofcommon language on the effectiveness of the grievance system, and also express a more explicit goal to create and implementan ‘effective’ grievance system.
Therefore,
Suggest to add one indicator :The effectiveness of grievance mechanism shall be evaluated in consultation with stakeholders every xxx years. The evaluations
shall be documented."#Indicator

Comment (English)

202

2.4.1

203

2.4.1

204

2.4.1

"2.4: The criteria are returned according to P&C 2018, namely: 4.2
the system agreed upon and documented forhandling complaints and complaints, which are carried out andreceived by all affected parties. Sentence""Consulting with the community and workers"" is different
with the ""agreed upon system""."
Proposed Indicator 2.4.1: Sentences Criteria should use the sentences contained in P&C 2018 so that it is easier to understand.
Proposed for indicator sentences: - Remove the sentence "(which is gender and child sensitive)" - Remove the word
"husband/wife", because it is included in the category of other stakeholders"2.4.1 Gender and Child Sensitive to be replaced into gender sensitive only to be consistent with the following sentence below
itHandling complaints is something dynamic and cannot be predicted the need for time to reach its resolution. Therefore,
determining the estimated time for each stage of handling complaints in the SOP will make it difficult for the certification unit

205

2.4.1

206

2.4.1

207

2.4.1

208

2.4.1

- Details of the mechanism for handling complaints do not need to be conveyed in detail in the indicator description. Simply
written on the guide""2.4: This indicator should be combined with indicatorsin principle 4 related to
Principle 4: Respect for affected communities and human rights,
and provide benefits and ensure it is
Remediation, if necessary""Proposed Indicator 2.4.1
Delete (gender sensitive and child) ""- Removing the word ""husband/wife"", because it has been included in the category of other stakeholders""- Sentences Criteria Using P&C 2018 sentences- Sentence ""(which is gender and child sensitive)"" deleted- Remove the word ""husband/wife"", because it is included in the category of other stakeholders""2.4.1: The phrase ""gender sensitive and child"" is deleted because of multi-interpretation and is very subjective to assess thelevel of ""sensitivity""
2.4.1: The phrase ""husband/wife of workers"" is deleted because it is included in the category of other stakeholders."#Indicator

Comment (English)

209

2.4.1

210
211

2.4.1
2.4.1

212

2.4.1

"Indicator 2.4.1 Proposed:- Sentences Criteria Using P&C 2018 sentences- Sentence ""(which is gender and child sensitive)"" deleted- Remove the word ""husband/wife"", because it is included in the category of other stakeholders""2.4.1: The phrase ""husband/wife of workers"" is deleted because it has been included in the category of other stakeholders""2.4.1: The phrase ""gender sensitive and child"" is deleted because
multi-interpretation and very subjectively assessing the level""Sensitivity""""Comment:- Sentences Criteria Using P&C 2018 sentences- Sentence ""(which is gender and child sensitive)"" deleted- Remove the word ""husband/wife"", because it is included in the category of other stakeholders
Proposed changes:
2.4.1 (c) The mechanism for handling complaints and complaints can be accessed by related parties, including the community,
planters, workers, workers' representatives, and other related stakeholders, must be developed and applied. Procedures thatare confidential and sensitive to report acts of sexual harassment and gender -based discrimination must also be prepared andimplemented
This mechanism must include the following elements:i) Procedure for accessing the mechanism for handling complaints and complaints;ii) estimated time to receive, acknowledge, process, investigate, respond, and resolve complaints and complaints;iii) Procedure for maintaining the identity (anonymity) of the complainant and guarantees confidentiality;IV) Procedure for the Certification Unit to allow the complainant to access relevant sources of information, independent legal
and technical considerations, and independent dispute resolution mechanisms;v) Providing effective access to appropriate recovery measures;
VI) There is no intervention of efforts to achieve appropriate recovery actions (law/non -law);vii) Protection of acts of reply or intimidation as a consequence of using the mechanism for handling complaints andcomplaints.
Complaints to the complaint mechanism must not prevent the complainant to report the same issue through legal processes, if
it applies"#

Indicator

Comment (English)

213

2.4.1

214

2.4.1

215

2.4.1

"Proposed Indicator 2.4.1:- Sentence ""(which is gender and child sensitive)"" deleted- Remove the word ""husband/wife"", because it is included in the category of other stakeholders"
In indicators 2.4.1 sentences "(which are gender and children) are" deleted because this indicator is not only fixated on genderand child limits. Delete the word "husband/wife", because it has been accommodated in the category of other stakeholders"There is a guide note for criteria 2.4:
Criteria for complaints handling mechanisms need to refer to the Principle 31 UNGPS:""To ensure the effectiveness of non-judicial mechanisms, non-judicial complaints mechanisms, both state-based and not statebased must:
SAH: Give the trust of the intended stakeholder group, and is responsible for providing fair behavior for the complaint process;Accessibility: known its existence by all the intended stakeholder groups, and provides sufficient assistance for those who facespecial obstacles to access;Special obstacles to access can include a lack of knowledge of the mechanism, language, literacy, cost, place of domicile, andfear of the threat of retaliation.
Can be predicted: provide a clear and known procedure with a certain period of time for each stage, and clarity about the typesof processes and results available and ways to oversee the implementation:
Justice: Ensuring that the disadvantaged party has sufficient access to the source of information, advice, and expertise needed
to be involved in a complaint process in a fair, informed and respected form;
Transparent: Make the parties who complain to get information about the progress of complaints, and provide adequate
information about the performance of the mechanism to build trust in its effectiveness and meet the public interests that are
in question;
In accordance with the rights: ensuring that the results and recovery are in accordance with internationally recognized humanrights;
Sources for the learning process: use relevant efforts to identify lessons for improving mechanisms and preventing loss andviolations in the future;
The operational level mechanism must also be:
Based on involvement and dialogue: consult with the intended stakeholder group on performance and design, and focus on
dialogue as a way to overcome and resolve complaints;"#

Indicator

Comment (English)

216

2.4.1

"2.4: Criteria are returned according to P&C 2018, namely: 4.2 The existence of a mutually agreed and documented system tohandle complaints and complaints, which are implemented and accepted by all affected parties. The phrase ""consulting withthe community and workers"" is different from ""the agreed system"".

217

2.4.1

218

2.4.1

219

2.4.1

220

2.4.1

221

2.4.1

222

2.4.1

223

2.4.1

2.4: This indicator should be combined with indicators on principle 4 related to respecting affected communities and humanrights, as well as providing benefits and ensuring remediation, if needed.""Proposal:- Sentences Criteria Using P&C 2018 sentences- Sentence ""(which is gender and child sensitive)"" deleted- Remove the word ""husband/wife"", because it is included in the category of other stakeholders"- Sentences Criteria Using P&C 2018 sentences; The sentence "(gender and child sensitive)" is deleted. ; Remove the word
"husband/wife", because it is included in the category of other stakeholders.
2.4: Criteria are returned according to P&C 2018, namely: 4.2 The existence of a mutually agreed and documented system tohandle complaints and complaints, which are implemented and accepted by all affected parties. The phrase "consulting withthe community and workers" is different from "the agreed system".
"Proposed Indicator 2.4.1: Sentences Criteria should refer to the sentence P&C 2018 is easier to understand. Proposed forindicator sentences:- Remove the sentence ""(which is gender and child sensitive)""- Remove the word ""husband/wife"", because it is included in the category of other stakeholders""Indicator 2.4.1 (c) is proposed in order to:
1. Sentences Criteria Using P&C 2018 sentences.
2. Sentence ""(which is gender sensitive and child)"" deleted.
3. The word ""husband/wife"" is deleted because it is included in the category of other stakeholders.""2.4.1: The phrase ""gender sensitive and child"" is deleted because of multi-interpretation and is very subjective to assess thelevel of ""sensitivity""
2.4.1: The phrase ""husband/wife of workers"" is deleted because it is included in the category of other stakeholders.""- Sentences Criteria Using P&C 2018 sentences.
; The sentence ""(gender and child sensitive)"" is deleted.
; Remove the word ""husband/wife"", because it is included in the category of other stakeholders."#Indicator

Comment (English)

224

2.4.1

225

2.4.1

226

2.4.1

227

2.4.1

228

2.4.1

"Proposed 2.4.1:
1. Delete sentences in brackets (gender and children)
2. Remove the word ""husband/wife"", because it has been included in the category of other stakeholders.""Proposed: (a). Sentences Criteria Using P&C 2018 sentences, (b). The sentence ""(which is gender and children) is"" deleted,(c). Delete the word ""husband/wife"", because it is included in the category of other stakeholders"iv) clarify that guide routes for legal and technical advice that seeks impartiality, identifying the interested parties that canrepresent them and facilitate the resolution of the conflict, but not that it is a position for the palm or producer company (thisif it would be impartiality) . It is suggested to include: a mechanism of requests, complaints, claims and suggestions (PQRS) will
be developed and implemented that has a gender approach and social inclusion (GESI), accessible to interested parties: local
and social communities, ethnically differentiated groups, small, small producers, workers and their family nuclei (according tonational regulations). Confidential and conscious procedures will be developed and applied with gender issues to denouncecases of sexual harassment and gender discrimination.
"Eliminate the word childhood and spouse from the description of the indicator, it is suggested only to indicate that thecomplaint mechanism must be accessible to anyone. For audit purposes, as shown that the infant has knowledge about themechanism.
""iv) The certification unit should not be responsible for legal advice to the demanding parties in conflict resolution processes,
the principle of impartiality is lost.

229

2.4.1

It is suggested: a mechanism of requests, complaints, claims and suggestions (PQRS) will be developed and implemented thathas a social gender and inclusion approach (GESI), accessible to interested parties: local and social communities, differentiatedethnic groups, small, small producers, workers and their family nuclei (according to national regulations). Confidential andconscious procedures will be developed and used with gender issues to denounce cases of sexual harassment and gender
discrimination."
2.4.1 Item IV: No responsibility for the certification unit will not be able to give legal advice.

#Indicator

Comment (English)

230

2.4.1

231

2.4.1

232

2.4.1

"I suggest for 2.4.1 (c): a mechanism of complaints that is accessible to the pertinent stakeholders (workers, contractors,
suppliers, clients, members of the communities of the area of influence, government entities and non -governmental entities
will be developed and implemented ). Procedures will be developed and applied to discuss issues related to gender, cases ofsexual harassment, labor abuse or discrimination.
Will include the following elements:i) Procedures to access the complaint mechanismi) estimated deadlines to receive, accuse receipt, process,investigate, respond and solve claimsiii) Procedure to maintain the anonymity of the complainant and guarantee confidentialityiv) procedures for the UDC to easier toplaintiffs on access to relevant sources of information or which agency to go to conflict resolution.
v) Appropriate forms of remediation.
vi) No interference with efforts to obtain other appropriate forms of remediation (judicial/non -judicial).
VII) Protection against retaliation or intimidation asconsequence of the use of the complaint mechanism.
----It is not clear the sense of naming childhood and spouses. The UDC has no resources to address family complaints, which are
not available to the labor issue. Nor is it objective that assumes the cost of an advisor to the complainant (this can be provided
for abuses from any of the parties)."
The certification unit should not be responsible for legal advice to the demanding parties in conflict resolution processes, theprinciple of impartiality is lost.
"Modify item IV indicating that the UDC may supply a guide for legal and technical advice that seeks impartiality, identifying theinterested parties that can represent them and facilitate the resolution of the conflict. (but not that the obligation to give andpay that advice by the UDC) is understood
The following indicator writing is suggested: a mechanism of requests, complaints, claims and suggestions (PQRS) will be
developed and implemented that has a gender approach and social inclusion (GESI), accessible to interested parties: local andsocial communities, groups Ethnically differentiated, small producers, workers and their family nuclei (according to national
regulations).
Confidential and conscious procedures will be developed and applied with gender issues to denounce cases of sexual
harassment and gender discrimination."#Indicator

Comment (English)

233

2.4.1

"iv) Clarify that guide routes for legal and technical advice that seeks impartiality, identifying the interested parties that canrepresent them and facilitate the resolution of the conflict, but not that it is a position for the palm company or the producer.
It is suggested to include: a mechanism of requests, complaints, claims and suggestions (PQRS) will be developed andimplemented that has a gender approach and social inclusion (GESI), accessible to interested parties: local and social
communities, ethnically differentiated groups, small, small producers, workers and their family nuclei (according to national
regulations).

234

2.4.1

235

2.4.2

236

2.4.2

Confidential and conscious procedures will be developed and applied with gender issues to denounce cases of sexual
harassment and gender discrimination."[Abidjan WS] 2.4.1(C) to delete 'spouses of workers' - this is not implementable and open for different interpretations - which
include all spouse of workers even not residing within Unit of Certification
2.4.2 Construct this indicator in a logical manner rather than cramping the whole list of stakeholders in a sentence. It should be
kept in mind that indicators require objective evidence to be auditable. This would then come across as another indicator thatis just glanced at and ticked unless it is systematically listed.
"[HRWG] In favour of using the term “an agreed time frame” instead of a “timely manner” as this is very vague.
The important thing is having a clear process with timeframes.
Concern of what is meant by “timely manner”: Timeliness should depend on the complexity of a grievance e.g.:

237
238

2.4.2
2.4.2

“I don’t understand my payslip”. This may require 3 days because it’s simple. Compare this to whistleblowing matter which
requires investigation and may take 1 month.
Companies have specified timeframes to address specific types of grievances. If you say UoC can set the timeframethemselves, it may raise the issue that some UoCs don’t have resources and may have to take longer.
Recommendation: The language should be: ‘a clear and reasonable timeframe’ and not ‘agreed timeframe’ or ‘timely manner’.
There should also be a language within this indicator to say that the timeframes should be established based on what theprocess for each type of grievance. The requirement for the UoC to establish a ‘clear and reasonable timeframe’ should be inPrinciple 2 and 4."[Sandakan, 21 June 2023] ...make accessible (e.g. website, social media, notice board, "apps" etc.)...
2.4.2 Confusing and inconsistent usage of capitalization in this indicator... such as "Worker" and "Smallholder".

#

Indicator

Comment (English)

239

2.4.2

240

2.4.2

Proposed Indicator 2.4.2: the word "and" on the "complainant indicator and its representatives continue to be informed about
the development of complaints submitted" should be changed to "or" so that it gives space for complaints to directly obtain
information on the development of complaints"Proposal 2.4.2
The word ""women and children are deleted, because they are included in the category of other stakeholders (vulnerable
groups)

241

2.4.2

242

2.4.2

243

2.4.2

244

2.4.2

Proposed improvement: 2.4.2 Certification units must socialize and facilitate access (for example, websites, social media,
announcement boards, etc.) on procedures relating to the mechanism for handling complaints and complaints to thecommunity, planters, workers, representatives, and other stakeholders, As well as all levels of labor, activities, suppliers, andworkforce recruiters with the language they understand. Provided assistance to related parties who face obstacles in accessing
the mechanism for handling complaints and complaints.""Proposed 2.4.2:
Remove the word ""women and children"", because it is included in the category of other stakeholders (vulnerable groups)"
In indicators 2.4.2 it is proposed to delete the word "women and children", because it has been included in the category ofother stakeholders (vulnerable groups)"Comment:
Remove the word ""women and children"", because it is included in the category of other stakeholders (vulnerable groups)
Proposed improvement:
2.4.2 Certification Units must socialize and facilitate access (for example, websites, social media, announcement boards, etc.)
on procedures relating to the mechanism for handling complaints and complaints to the community, planters, workers,
representatives, and other stakeholders, as well as all levels labor, activities, suppliers, and recruiters of labor in the language
they understand. Provided assistance to related parties who face obstacles in accessing the mechanism for handling complaints
and complaints."
Proposal 2.4.2 The word "women and children are deleted, because it is included in the category of other stakeholders(vulnerable groups) Proposed improvement: 2.4.2 Certification units must socialize and facilitate access (for example, websites,
social media, notice boards, etc.) on procedures In connection with the mechanism for handling complaints and complaints tothe community, planters, workers, their representatives, and other stakeholders, as well as all levels of labor, activities,
suppliers, and recruiters of labor in the language they understand. mechanism for handling complaints and complaints.

#

Indicator

Comment (English)

245

2.4.2

246
247

2.4.2
2.4.2

248

2.4.2

249

2.4.2

250

2.4.2

251
252

2.4.2
2.4.2

253

2.4.2

254
255

2.4.2
2.4.2

256
257
258
259

2.4.2
2.4.2
2.4.2
2.4.2

"Proposed 2.4.2:
Remove the word ""women and children"", because women and children are included in the category of other stakeholders(vulnerable groups). So as not to repetition."
2.4.2. Remove the word "women and children", because it is included in the category of other stakeholders (vulnerable groups)
2.4.2: The sentence "women and children" is removed because it is included in the category of other stakeholders (vulnerable
groups).
"Proposal:
Remove the word ""women and children"", because it is included in the category of other stakeholders (vulnerable groups)"
Indicator 2.4.2 is proposed to: The word "female and child" is removed because it is included in the category of otherstakeholders (vulnerable groups).
"2.4.2: The word ""female and child"" is removed because it has been included in the category of other stakeholders(vulnerable group)."
Remove the word "women and children", because it is included in the category of other stakeholders (vulnerable groups)
Proposal 2.4.2 The word "women and children are removed, because they are included in the category of other stakeholders(vulnerable groups)
Proposed: delete the word "women and children", because it is included in the category of other stakeholders (vulnerable
groups), so the sentence becomes: 2.4.2 Certification Unit must socialize and facilitate access (for example, websites, social
media, announcement boards, etc.) The procedures relating to the mechanism for handling complaints and complaints to thecommunity, planters, workers, representatives, and other stakeholders, as well as all levels of labor, activities, suppliers, andrecruiters of the workforce with the language they understand, including the Tunaaksara and the vulnerable group. Provided
assistance to related parties who face obstacles in accessing the mechanism for handling complaints and complaints.
2.4.2: The word "female and child" is deleted because it is included in the category of other stakeholders (vulnerable groups).
"Proposal:
the word ""and"" in the sentence ""the complainant and representatives continue to be informed about the development ofcomplaints submitted"" proposed to be changed to ""or"""Clarify the scope or eliminate the description of this indicator to women and children.
Eliminate, delimit or clarify "childhood and spouses" scope "2.4.2 Eliminate children, and define the scope, or leave only interested parties"2.4.2. To say clearly that the answers to the interested party must be disseminated to protect confidentiality.
Quitr to children as an interested part or explain why they are included."#

Indicator

Comment (English)

260

2.4.2

261

2.4.2

262

2.4.2

263
264
265
266

2.4.2
2.4.2
2.4.2
2.4.3

"I suggest for indicator 2.4.2 The certification unit will disclose, through the internal and external media with which you have,the procedures related to the mechanism of complaints to their interested parties (workers, contractors, suppliers, clients,
entities governmental and non -governmental and members of the communities in their area of influence). Said socialization
will be done in local languages, giving reach people
illiterate."
Important to define the scope of the support that the UDC will provide to the interested party. Being the UDC who provides
support can be lost objectivity in the management of the objective, it is better that the UDC provides spaces to communicate
the mechanisms to resolve obstacles.
"Eliminate, delimit or clarify childhood scope and spouses.
"
Eliminate children from scope and leave only interested parties
Eliminate, delimit or clarify "childhood and spouses" scope "[Abidjan WS] 2.4.2 to revert back to P&C 2018 wordings - as it is much more clearer on implementation and more auditable" 2.4.3 It is noticed that the indicators in this standard are not to the point, and there is a convoluted way that these have been
framed. Indicators are meant to be straight to the point and concise, allowing conformity to be addressed by ensuring that
objective evidence is detectable.

267

2.4.3

268

2.4.3

269

2.4.3

270
271
272

2.4.4
2.4.4
2.4.4

""Grievance(s) raised are responded to and are either resolved or are in the process of resolution."" - Convoluted style ofwriting. "[Accra WS] 2.4.3 (c) replaced ' how they will be resolved' to 'a progressing plan to resolving it'. It will be difficult to also predetermine how it can be resolved.
A plantation cannot always be in the position to state HOW the grievance will be resolved. It may state how they are addressing
the grievance, and provide a status update of the ongoing process. However, the resolution itself may still need to be found.
[Abidjan WS] 2.4.3 Grievance(s) raised are responded to and are either resolved 'and/or' are in the process of resolution - add'and/or.
2.4.4. The 2018 version of this indicator is better phrased. Consider using that one. You could add the language factor to 2.4.4.
[Sandakan, 21 June 2023] The records should be kept for 24 months or 36 months.
the word "and" in the sentence "the complainant and representatives continue to be informed about the development ofcomplaints submitted" changed to "or"#

Indicator

Comment (English)

273

2.4.4

274

2.4.4

275

2.4.4

276

2.4.4

277

2.4.4

278

2.4.4

279

2.4.4

"Proposed indicator 2.4.4
the word ""and"" in the sentence ""the complainant and representatives continue to be informed about the development ofcomplaints submitted"" changed to ""or"""In indicators 2.4.4 words "and" on "the complainants and representatives continue to be informed about the development ofcomplaints submitted" changed to "or"Proposed indicator 2.4.4 words "and" in the sentence "the complainant and representatives continue to be informed about thedevelopment of complaints submitted" changed to "or""2.4.4: the word ""and"" changed to ""or"" because not all
The complainant pointed to his representative, and if any
representatives, communication is carried out throughthe representative, and if there are no representatives
then communication is carried out directly to the complainant."
Indicator 2.4.4 is proposed to: The word "and" in the sentence "the complainant and representatives continue to be informed
about the development of complaints submitted" changed to "or".
"Proposed improvement: change the word ""and"" to ""or"" on indicators 2.4.4 which states that ""the complainants andrepresentatives continue to be informed about the development of the proposed complaints. The results must be presented
and communicated in the language they understand"" to ""the complainant or representative. .. """"Comment:
the word ""and"" changed to ""or""

280

2.4.4

281

2.4.4

Proposed improvement:
2.4.4 The complainant or representative continues to be informed about the development of the complaints submitted. The
results must be presented and communicated in the language they understand."
2.4.4: Kata "dan" diganti menjadi "atau" karena tidak semua pengadu menunjuk perwakilannya, dan jika ada perwakilannya
maka komunikasi dilakukan melalui perwakilannya tersebut, dan jika tidak ada perwakilannya maka komunikasi dilakukan
langsung kepada pihak pengadu.
"Indicator 2.4.4 Proposed:
the word ""and"" in the sentence ""the complainant and representatives continue to be informed about the development ofcomplaints submitted"" changed to ""or"""#

Indicator

Comment (English)

282

2.4.4

283
284

2.4.4
2.4.4

285

2.4.4

286

2.4.4

"Proposal:
the word ""and"" in the sentence ""the complainant and representatives continue to be informed about the development ofcomplaints submitted"" changed to ""or"""
Change "and" to "or" because not all complainants have representatives"Proposed indicator 2.4.4:
Change the word ""and"" to ""or"" in the sentence ""the complainant and representatives continue to be informed about thedevelopment of complaints submitted"""
Proposed indicator 2.4.4: the word "and" in the sentence "the complainant and representatives continue to be informed about
the development of complaints submitted" changed to "or""Here does not appear indicator 2.4.5 in which there are objections.
2.4.5 The effectiveness of the complaint mechanism will be evaluated in consultation with the interested parties every three
years. Evaluations will be documented.
Objection (producers):
1. The effectiveness of the complaint mechanism has been evaluated by the Auditor (a) of the RSPO during the certification
process and the annual surveillance audit. The PYCs of the RSPO have defined how the mechanism of complaints effectively by
the certification unit should be developed and implemented.
2. The same scenario is also applied to other procedures required by the PyC of the RSPO, such as contracting, management
and monitoring procedures of AVC, etc. Through the audit process, we can guarantee the effectiveness of such procedures thathave been developed and implemented by the certification unit.
3. Not all interested parties are relevant, so measuring effectiveness is difficult. Instead of focusing on point 2.4.5, we must
continue using the indicators of points 2.4.3 and 2.4.4, which already have several steps whose efficiency can be verified.
4. This is very complex. Companies cannot be ""at the mercy"" of the satisfaction of the plaintiffs."

#Indicator

Comment (English)

287

2.4.4

288

2.4.4

The process methodology must be evaluated because an interested party that does not receive a satisfactory response but thatis correct, fair and legal can poorly qualify the evaluation of the mechanism. The objection is supported: objection (producers):
1. The effectiveness of the complaint mechanism has been evaluated by the auditor (a) of the RSPO during the certification
process and the annual surveillance audit. The PYCs of the RSPO have defined how the mechanism of complaints effectively by
the certification unit should be developed and implemented. 2. The same scenario is also applied to other procedures requiredby the PyC of the RSPO, such as contracting, management and monitoring procedures of AVC, etc. Through the audit process,we can guarantee the effectiveness of such procedures that have been developed and implemented by the certification unit. 3.
Not all interested parties are relevant, so measuring effectiveness is difficult. Instead of focusing on point 2.4.5, we must
continue using the indicators of points 2.4.3 and 2.4.4, which already have several steps whose efficiency can be verified. 4.
This is very complex. Companies cannot be "at the mercy" of the satisfaction of the plaintiffs.
For indicator 2.4.5 the objections (producers) are supported- it is requested to eliminate it, since: 1. The effectiveness of thecomplaint mechanism has been evaluated by the auditor (a) of the RSPO during the certification process and the audit ofAnnual surveillance. The PYCs of the RSPO have defined how the mechanism of complaints effectively by the certification unit
should be developed and implemented. 2. The same scenario is also applied to other procedures required by the PyC of the
RSPO, such as contracting, management and monitoring procedures of AVC, etc. Through the audit process, we can guarantee
the effectiveness of the procedures that have been developed and implemented by the certification unit. 3. Not all interested
parties are relevant, so measuring effectiveness is difficult. Instead of focusing on point 2.4.5, we must continue using theindicators of points 2.4.3 and 2.4.4, which already have several steps whose efficiency can be verified. 4. This is very complex.
Companies cannot be "at the mercy" of the satisfaction of the plaintiffs. This is very complex. Companies cannot be "at themercy" of the satisfaction of the plaintiffs. This is very complex. Companies cannot be "at the mercy" of the satisfaction of theplaintiffs.

#Indicator

Comment (English)

289

2.4.4

290

2.4.4

"The public consultation work document appears indicator 2.4.5 without resolving ""2.4.5 The effectiveness of the complaint
mechanism will be evaluated in consultation with the interested parties every three years. The evaluations will be
documented."" As a producer we agree to eliminate The indicator supporting the comments of the producers:
1. The effectiveness of the complaint mechanism has been evaluated by the Auditor (a) of the RSPO during the certification
process and the annual surveillance audit. The PYCs of the RSPO have defined how the mechanism of complaints effectively by
the certification unit should be developed and implemented.
2. The same scenario is also applied to other procedures required by the PyC of the RSPO, such as contracting, management
and monitoring procedures of AVC, etc. Through the audit process, we can guarantee the effectiveness of such procedures thathave been developed and implemented by the certification unit.
3. Not all interested parties are relevant, so measuring effectiveness is difficult. Instead of focusing on point 2.4.5, we must
continue using the indicators of points 2.4.3 and 2.4.4, which already have several steps whose efficiency can be verified.
4. This is very complex. Companies cannot be ""at the mercy"" of the satisfaction of the plaintiffs. """"The process methodology must be evaluated because an interested party that does not receive a satisfactory response butthat is correct, fair and legal can poorly qualify the evaluation of the mechanism. The objection is supported:

291
292
293
294

2.5
2.5
2.5
2.5

Objection (producers):
1. The effectiveness of the complaint mechanism has been evaluated by the Auditor (a) of the RSPO during the certification
process and the annual surveillance audit. The PYCs of the RSPO have defined how the mechanism of complaints effectively by
the certification unit should be developed and implemented.
2. The same scenario is also applied to other procedures required by the PyC of the RSPO, such as contracting, management
and monitoring procedures of AVC, etc. Through the audit process, we can guarantee the effectiveness of such procedures thathave been developed and implemented by the certification unit.
3. Not all interested parties are relevant, so measuring effectiveness is difficult. Instead of focusing on point 2.4.5, we must
continue using the indicators of points 2.4.3 and 2.4.4, which already have several steps whose efficiency can be verified.
4. This is very complex. Companies cannot be ""at the mercy"" of the satisfaction of the plaintiffs."
This procedure will be co-written with the relevant external stakeholders to ensure their agreement and understanding.
This procedure will be co-written with the relevant external stakeholders to ensure their agreement and understanding.
This procedure will be co-written with the relevant external stakeholders to ensure their agreement and understanding.
This procedure will be co-written with the relevant external stakeholders to ensure their agreement and understanding.

#Indicator

Comment (English)

295

2.5

"[HRSS] Propose to consolidate the prevention against retaliation in P2 and P4 as follows:
Criteria 2.5
The Unit of Certification upholds human rights and is prohibited from retaliating against Human Rights Defenders,
Whistleblowers and Community spokespersons.
Indicator 2.5.1 (C)
2.5.1(C) A policy to respect the human rights of Communities, Workers, Workforce, Smallholders, Suppliers, Human Rights
Defenders and Stakeholders shall be established and implemented by the Unit of Certification and its contracted security
services (including private military and security companies). This policy shall follow RSPO’s policy on Human Rights Defenders
and include the prohibition of:(a) Retaliation(b) Intimidation, harassment and threats(c) Violence (physical, sexual and gender-based) and torture(d) Exploitation(e) Discrimination (access to employment, education and training)(f) Detention, disappearance and killing.

296

2.5.1

This policy shall also outline access to the established grievance mechanism and remediation. It shall be made publicly available
and socialised to all Stakeholders (including Affected Communities, Smallholders, Workers) in a language understood by them.
""2.5.1 Is there an indication that RSPO is allowing private military forces to be hired? We are aware that this is a global
standard and if you have to hire private military forces, then the situation is probably unacceptable for plantation
development. We would assume that the implementation of sustainability in oil palm plantations is to create a harmonious
situation where RSPO subscribes to the Triple Bottom Line concept. This badly framed indicator presents a scenario wherecertificate holders are facing situations listed in the indicator. This is another wooly attempt of requiring a policy that
addresses: Retaliation;(b) Intimidation, harassment, and threats;(c) Violence (physical, sexual, and gender-based) and torture;(d) Exploitation;(e) Discrimination - access to employment, education, and training; and(f) Detention, disappearance and killing.
All of these have legal implications and then the solution if it ever were to happen is through a grievance mechanism, andshould be made publically available. The indicator is weak and should and needs to be rephrased to make it practical. "#Indicator

Comment (English)

297

2.5.1

298

2.5.1

299

2.5.1

300

2.5.1

301
302

2.5.1
2.5.1

303

2.5.1

304

2.5.1

305

2.5.1

306
307

2.5.1
2.5.1

This procedure may be amended from time to time as the need arises: new regulations (national or international), newgrievances revealed, cases of conflict, etc.
This procedure may be amended from time to time as the need arises: new regulations (national or international), newgrievances revealed, cases of conflict, etc.
This procedure may be amended from time to time as the need arises: new regulations (national or international), newgrievances revealed, cases of conflict, etc.
"2.5.1: Sentences on (a)-(f) are removed because of the policy
respect for human rights is clear and refers to the rules
or applicable guidelines."
Indicator 2.5.1 A: proposed to be revised into acts of reply (except for the act of violation of law that can be proven)
2.5.1: Sentences on (a)-(f) are removed because the policy of respecting human rights is clear and refers to the applicable rules
or guidelines.
2.5.1: Sentences on (a)-(f) are removed because the policy of respecting human rights is clear and refers to the applicable rules
or guidelines.
Drafting proposal: 2.5.1 (c) The certification unit establishes and applies a policy of respect for the human rights of
subcontracted personnel and workers, subcontracted services (including private security and military companies) suppliers,
communities, defenders of the human rights and other interested parties. This policy will include the prohibition of: (a)reprisals; (b) intimidation, harassment and threats; (c) violence (physical, sexual and gender) and torture; (d) exploitation; (e)Discrimination - Access to employment, education and training; and (f) detention, disappearance and murder. This policy will
also describe access to the complaint mechanism and established remediation. This policy will be publicly available and will be
disclosed at all levels of the workforce and operations in a language they understand.
Conclusion: 2.5.1. and 2.5.2. Prioritize the part of subcontractors for being a very broad issue, it is requested that the company
can be allowed to carry out a risk assessment matrix, in order to determine which subcontracted companies can violate humanrights and thus be able to demand compliance.
2.5.1 Priorize the subcontracted parts with more vulnerability creating a matrix to measure the risks to choose them ..
Drafting proposal: 2.5.1 (c) The certification unit establishes and applies a policy of respect for the human rights of
subcontracted personnel and workers, subcontracted services (including private security and military companies) suppliers,
communities, defenders of the human rights and other interested parties. This policy will fulfill the prohibition of: (a) reprisals;(b) intimidation, harassment and threats; (c) violence (physical, sexual and gender) and torture; (d) exploitation; (e)Discrimination - Access to employment, education and training; and (f) detention, disappearance and murder. This policy will
also describe access to the complaint mechanism and established remediation.

#Indicator

Comment (English)

308

2.5.1

"Writing proposal:
2.5.1 (c) The Certification Unit establishes and applies a policy of respect for human rights of subcontract personnel andworkers, subcontracted services (including private security and military companies) suppliers, communities, defenders ofhuman rights and other other rights and other concerned parties. This policy will include the prohibition of:(a) reprisals;(b) intimidation, harassment and threats;(c) violence (physical, sexual and gender) and torture;(d) exploitation;(e) Discrimination - Access to employment, education and training; and(f) detention, disappearance and murder.

309

2.5.1

310

2.5.1

This policy will also describe access to the complaint mechanism and established remediation. This policy will be publicly
available and will be disclosed at all levels of the workforce and operations in a language they understand.
""1. Specify that the policy must be generated by the UDC and communicate it to interested parties including subcontractors. It is
not viable to require a policy with each subcontractor, the writing does not seem clear in this aspect.""Improve the writing to clarify that the UDC policy must be adopted by contractors:
2.5.1 (c) The Certification Unit will establish and apply a policy of respect for the human rights of subcontracted personnel andworkers, and their subcontracted services (including security and private military companies) suppliers, communities,
defenders of human rights and other interested parties. This policy will include the prohibition of:(a) reprisals;(b) intimidation, harassment and threats;(c) violence (physical, sexual and gender) and torture;(d) exploitation;(e) Discrimination - Access to employment, education and training; and(f) detention, disappearance and murder.
This policy will also describe access to the complaint mechanism and established remediation. This policy will be publicly
available and will be disclosed at all levels of the workforce and operations in a language they understand.
"#Indicator

Comment (English)

311

2.5.1

"Improve the writing to clarify that the UDC policy must be adopted by contractors:
2.5.1 (c) The Certification Unit will establish and apply a policy of respect for the human rights of subcontracted personnel andworkers, and their subcontracted services (including security and private military companies) suppliers, communities,
defenders of human rights and other interested parties. This policy will include the prohibition of:(a) reprisals;(b) intimidation, harassment and threats;(c) violence (physical, sexual and gender) and torture;(d) exploitation;(e) Discrimination - Access to employment, education and training; and(f) detention, disappearance and murder.
This policy will also describe access to the complaint mechanism and established remediation. This policy will be publicly
available and will be disclosed at all levels of the workforce and operations in a language they understand."#

Indicator Comment (English)

1

3.1

2
3
4
5

3.1.1
3.1.1
3.1.1
3.1.1

This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
3.1.1 There should be guidance on the minimum content of the business plan to make it auditable.
A guide to good farming practices should be available to all smallholders, in their own language, to help them find information.
A guide to good farming practices should be available to all smallholders, in their own language, to help them find information.
"A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.

6
7

3.1.1
3.1.2

8

3.1.2

9

3.1.2

10

3.1.2

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers"
A guide to good farming practices should be available to all smallholders, in their own language, to help them find information.
3.1.2 This requirement should only be for estates and for smallholders, something else needs to be considered through a stakeholder
consultative exercise.
"""3.1.2. How does this expectation apply to SH?
Guidance should be given, maybe a taskforce should be established to bring solutions to SH notably under 2 to 3 ha SH.
A mapping of existing approaches to small scale replanting are already on-going, building on such studies could be a first step""""3.1.2. How does this expectation apply to SH?
Guidance should be given, maybe a taskforce should be established to bring solutions to SH notably under 2 to 3 ha SH.
A mapping of existing approaches to small scale replanting are already on-going, building on such studies could be a first step""How does this expectation apply to SH?
Guidance should be given, maybe a taskforce should be established to bring solutions to SH notably under 2 to 3 ha SH.
A mapping of existing approaches to small scale replanting are already on-going, building on such studies could be a first step"#Indicator Comment (English)

11

3.1.2

12
13

3.1.3
3.1.3

14

3.1.3

15

3.1.3

16

3.1.3

17
18

3.1.3
3.1.3

19

3.2.1

20

3.2.1

21

3.2.1

22

3.2.1

23

3.2.1

24
25

3.2.1
3.2.1

26
27
28

3.2.1
3.2.1
3.2.1

"3.1.2. How does this expectation apply to SH?
Guidance should be given, maybe a taskforce should be established to bring solutions to SH notably under 2 to 3 ha SH.
A mapping of existing approaches to small scale replanting are already on-going, building on such studies could be a first step"
Planned intervals? Appropriate to scale of operations? Open to interpretation. Make it an annual audit and keep it simnple.
"3.1.3 What should be the frame of the management review and what should be the minimum content of the review for auditing
purposes?""A guide should be published to identify the various cases and provide overall planning assistance - depending on the scale and natureof the activities."
A guide should be published to identify the various cases and provide overall planning assistance - depending on the scale and natureof the activities.
A guide should be published to identify the various cases and provide overall planning assistance - depending on the scale and natureof the activities.
definition of "management review"
A guide should be published to identify the various cases and provide overall planning assistance - depending on the scale and natureof the activities.
"Proposal for multi-stakeholder co-construction, in particular with smallholders, of KPIs to objectively assess progress and, if necessary,
provide operational assistance on plantations."
Proposal for multi-stakeholder co-construction, in particular with smallholders, of KPIs to objectively assess progress and, if necessary,
provide operational assistance on plantations.
Proposal for multi-stakeholder co-construction, in particular with smallholders, of KPIs to objectively assess progress and, if necessary,
provide operational assistance on plantations.
Proposal for multi-stakeholder co-construction, in particular with smallholders, of KPIs to objectively assess progress and, if necessary,
provide operational assistance on plantations.
3.2.1 This indicator is not in accordance with the requirements of the criteria. The spirit of continuous improvement in key elements ofsustainability is not being promoted through this indicator. The focus of only impacts is misleading.
The translation of "continuous improvement" was proposed to be changed to "ongoing improvement""Proposal:
Indicator 3.2.1 (c) is proposed that the translation ""continuous improvement"" is changed to ""ongoing improvement""."Proposed Indicator 3.2.1: Translation of "Continuous Improvement" Proposed to be changed to "Sustainable Improvement"
Indicator 3.2.1 (c) is proposed that the translation "continuous improvement" is changed to "ongoing improvement".
The translation of "continuous improvement" was proposed to be changed to "ongoing improvement"#

Indicator Comment (English)

29
30
31
32
33

3.2.1
3.2.1
3.2.1
3.2.1
3.2.1

34
35

3.2.1
3.2.1

36
37
38
39

3.2.1
3.2.1
3.2.1
3.2.1

40

3.2.1

41

3.2.1

42

3.2.1

43

3.2.1

44
45

3.2.2
3.2.2

46

3.2.2

Proposed on indicators 3.2.1: The sentence translation "Continuous Improvement" should be changed to "ongoing improvement"
Proposal 3.2.1: The translation sentence "Continuous Improvement" is proposed to be changed to "Sustainable Improvement"
Proposed 3.2.1: Translation "Continuous Improvement" proposed to be changed to "Sustainable Improvement"
In indicator 3.2.1 for the translation "Continuous Improvement" proposes to be changed to "Sustainable Improvement""Proposed Indicator 3.2.1:
The translation of ""continuous improvement"" was proposed to be changed to ""ongoing improvement"""
Proposal for 3.2.1 (c): the translation of "continuous improvement" proposed to be changed to "ongoing improvement""Proposed Indicator 3.2.1:
The translation of ""continuous improvement"" was proposed to be changed to ""ongoing improvement"""
The translation of "continuous improvement" was proposed to be changed to "ongoing improvement"
3.2.1-Translation of "Continuous Improvement" is proposed to be converted into "Sustainable Improvement"
3.2.1 Translation "Continuous Improvement" Proposed to be changed to "Sustainable Improvement""Comment:
The translation of ""continuous improvement"" was proposed to be changed to ""ongoing improvement""
Proposed changes:
3.2.1 (c) The action plan for continuous improvement is carried out based on consideration of various social and main environmental
impacts as well as various opportunities from the certification unit.""Proposed for indicators 3.2.1:
The translation of ""continuous improvement"" was converted into ""ongoing improvement""""3.2.1.
The translation of ""continuous improvement"" was proposed to be changed to ""ongoing improvement""""Proposal:
The translation of ""continuous improvement"" was proposed to be changed to ""ongoing improvement""""Indicator 3.2.1 Proposed:
The translation of ""continuous improvement"" was proposed to be changed to ""ongoing improvement"""
3.2.2 The RSPO metrics are weak and do not support the important key elements in sustainability.
The template should be regularly re-evaluated with a panel of expers relevant to the geographical area under consideration and the
local social situation.
The template should be regularly re-evaluated with a panel of expers relevant to the geographical area under consideration and the
local social situation.

#Indicator Comment (English)

47

3.2.2

48

3.2.2

49

3.2.2

50

3.2.2

51
52

3.2.2
3.2.2

53

3.2.2

54

3.2.2

55

3.2.2

56

3.2.2

57

3.2.2

The template should be regularly re-evaluated with a panel of expers relevant to the geographical area under consideration and the
local social situation.
"Proposed indicator 3.2.2: so that the indicator is deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute"
Proposal: Proposing Indicators 3.2.2 Deleted, because: 1. Filling Matric Template is a duplication of the Documentation of Fulfillment of
P&C RSPO 2. Actual, the matric template contents are not sent to the RSPO Secretariat, but submitted to the Auditor of theCertification InstitutePropose indicators to be deleted, because: 1. Filling Matric Template is a duplication of the Documentation of Fulfillment"Proposal 3.2.2 Elimination of Indicators due to:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""3.2.2: The indicator is deleted because based on RSPOInterpretation Forum at KL, 15-16 May 2023 willdeveloped into a metric monitoring dashboard.""3.2.2: The indicator is deleted because based on RSPOInterpretation Forum at KL, 15-16 May 2023 willdeveloped into a metric monitoring dashboard."
This indicator is recommended to be abolished. In accordance with the RSPO Interpretation Forum in KL, 15-16 May 2023 will be
developed into a Metric Monitoring Dashboard.
"Proposed 3.2.2: Indicators are deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""3.2.2 - Proposed so that the indicator is deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute"#Indicator Comment (English)

58

3.2.2

59

3.2.2

60

3.2.2

61

3.2.2

62

3.2.2

63

3.2.2

64

3.2.2

65

3.2.2

66

3.2.2

"Proposed Indicator 3.2.2:
Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""Proposed for indicators 3.2.2:
Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute"
In indicator 3.2.2 it is proposed to be deleted because the matric template is a duplication of the documentation of the fulfillment of
the RSPO P&C in addition to the Matric Template is not sent to the RSPO Secretariat, but was conveyed to the Auditor of theCertification Institute
3.2.2: The indicator is deleted because based on RSPO Interpretation Forum in KL, May 15-16 2023 will be developed into a metricmonitoring dashboard.
"Indicator 3.2.2 is proposed to: abolished because:
1. Filling Matric Template is a duplication of the Documentation of Fulfillment of P&C RSPO.
2. Actually, the matric template is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute."[Jakarta WS] 3.2.2 to be removed - metrication data needed should be captured through audit report. Auditor should make these data
available to RSPO Secretariat.
"Proposed Indicator 3.2.2:
Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""Proposal:
Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""Indicator 3.2.2 Proposed:
Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute"#Indicator Comment (English)

67

3.2.2

68

3.2.2

69

3.2.2

70
71
72

3.2.2
3.2.2
3.2.2

73
74
75
76
77
78

3.2.2
3.3
3.3
3.3
3.3
3.3.1

79

3.3.1

80
81

3.3.1
3.3.1

82

3.3.1

Indicator 3.2.2 is proposed to be deleted because: 1. Filling Matric Template is a duplication of the documentation of Fulfillment of P&C
RSPO. 2. Actually, the matric template is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute.
"This indicator should be removed, because:
1. Filling Matric Template is a duplication of the documentation of fulfilling P&C RSPO;
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute"
3.2.2 RSPO Metric Templates to be deleted because all information regarding the performance unit of certification already exists in the
Annual RSPO audit report and initial data information (Basic Info) that is always requested by the Certification Agency to theCertification Unit every before the annual audit implementation. This is also to avoid the substance of data that may be different
between Basic Info and RSPO Metric Templates.
Clarify who is responsible for submitting these annual reports to RSPO.
3.2.2 Describe what temporality should be presented to the Secretariat, prior to the audit or as part of the COP
It is a minor indicator, but in practice it is a larger indicator since RSPO requires the certification entities that to request the license of
the certification unit in Palm Trace, the metric template is uploaded and clarify who is responsible for submitting these reports annual
to the secretariat of the RSPO.
Clarify who is responsible for submitting these annual reports to the secretariat of the RSPO.
"We need to ensure that smallholders have access to information, to ensure that procedures are properly followed."
We need to ensure that smallholders have access to information, to ensure that procedures are properly followed.
We need to ensure that smallholders have access to information, to ensure that procedures are properly followed.
We need to ensure that smallholders have access to information, to ensure that procedures are properly followed.
3.3.1 There should be a statement addressing the spread of SOPs required. The minimum requirement should be SOPs for all activities
required for promoting sustainability.
"1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit"
3.3.1 -The word "enactment" is not quite right, it should be "available" -> SOP available in the certification unit
"Proposed 3.3.1:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit"
Proposed Indicator 3.3.1: 1. It is necessary to change the word "valid" to "available"#

Indicator Comment (English)

83

3.3.1

84

3.3.1

85

3.3.1

86

3.3.1

87

3.3.1

"Proposed 3.3.1:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit""Indicator 3.3.1 (c) Proposed for:1. The word ""enactment"" SOP in the certification unit is changed to ""available"" because of the wrong translation.
So that the sentence becomes ""available Standard Operating Procedures (SOP) for the Certification Unit"".""In indicators 3.3.1
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit""Proposed 3.3.1 (c):1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit""Comment:
Translation in the language version needs to be improved

88

3.3.1

89

3.3.1

90
91

3.3.1
3.3.1

92

3.3.1

Proposed changes:
3.3.1 (c) Available Standard Operating Procedures (SOP) for the Certification Unit."
Indicator 3.3.1 (c) Proposed in order to: 1. The word "validy" SOP in the certification unit is changed to "available" because of thewrong translation. So that the sentence becomes "available Standard Operating Procedures (SOP) for the Certification Unit".
Proposal 3.3.1: The word "validity" is wrong with the translation, it should be "available", so that the indicator sentence changes to"3.3.1 (c) Available Standard Operating Procedures (SOP) for the Certification Unit""The entry into force" was changed to "the availability".
"Indicator proposal 3.3.1:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. SOP is available in the certification unit.""Comment: Translation in the language version needs to be improved.

3.3.1

Proposed changes: 3.3.1 (c) Available Standard Operating Procedures (SOP) in the Certification Unit.""The entry into force" was changed to "the availability".

93

#

Indicator Comment (English)

94

3.3.1

95

3.3.1

96

3.3.2

97

3.3.2

98

3.3.2

99

3.3.2

100 3.3.2

101 3.3.2
102 3.3.2

103 3.3.2

104 3.3.2"Indicator proposal 3.3.1:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit""Indicator 3.3.1 Proposed:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. Available SOPs in the Certification Unit"
3.3.2 How is this auditable? What would be the mechanism to check consistency? And what is the assurance that the SOP isappropriate?
"Comment: Translation in the language version needs to be improved
Proposed changes: 3.3.2 There is a mechanism to ensure the implementation of the procedure consistently."
Indicator 3.3.2 is proposed to: The word "enactment" is changed "because of the wrong translation. So that the sentence becomes"There is a mechanism to check the implementation of the procedure consistently".
3.3.2 -The word "validity" is not quite right, it should be "available" -> There is a mechanism to check the implementation of theprocedure consistently"Indicator 3.3.2 Proposed:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently""1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently""In indicator 3.3.2
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently""Indicator proposal 3.3.2:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently""Comment:
Translation in the language version needs to be improved
Proposed changes:
3.3.2 There is a mechanism to ensure the implementation of procedures consistently."

#Indicator Comment (English)

105 3.3.2

106 3.3.2

107 3.3.2

108 3.3.2
109 3.3.2
110 3.3.2

111 3.3.2

112 3.3.3
113 3.3.3
114 3.3.3

115 3.3.3

116 3.3.3"Proposed 3.3.2:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently""Proposed and comments:
Propose indicators to be deleted, because:
1. Filling Matric Template is a duplication of documentation of fulfilling P&C RSPO
2. Actually, the matric template filling is not sent to the RSPO Secretariat, but is delivered to the Auditor of the Certification Institute""Indicator 3.3.2 is proposed to:
The word ""entry into force"" replaced ""is available"" because of the wrong translation. So that the sentence becomes ""There is amechanism to check the implementation of the procedure consistently"".""The entry into force" was changed to "the availability".
Proposed Indicator 3.3.2: 1. The word "enactment" is wrong with the translation, it should be "available" 2. A mechanism is available tocheck the implementation of the procedure consistently"Indicator proposal 3.3.2:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently""Indicator proposal 3.3.2:
1. The word ""validity"" is mistaken for the translation, it should be ""available""
2. A mechanism is available to check the implementation of procedures consistently"
3.3.3 What is the minimum period of monitoring? Should the monitoring be done annually?
Proposed changes in indicators 3.3.1: 1. It should be the sentence "provided and managed" changed to the phrase "maintained andavailable" so that the sentence becomes "recording of monitoring and actions taken and available".
"Comment: Translation in the language version needs to be improved
Proposed changes: 3.3.3 Records of monitoring and actions taken are maintained and available.""Indicator proposal 3.3.1:
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available."
3.3.3 -Incorrect translation, the phrase "provided and managed" changed to "maintained and available" -> Records of monitoring andactions taken are maintained and available.

#

Indicator Comment (English)

117 3.3.3

118 3.3.3

119 3.3.3
120 3.3.3

121 3.3.3

122 3.3.3

123 3.3.3

124 3.3.3
125 3.3.3
126 3.3.3"Comment:
Translation in the language version needs to be improved
Proposed changes:
3.3.3 Records of monitoring and actions taken are maintained and available.""Indicator 3.3.3 Proposed:
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available.""1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available.""Proposed Indicator 3.3.3:
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available.""Indicator 3.3.3 Proposed for:1. The sentence ""is provided and managed"" changed to ""maintained and available"".
2. Records of monitoring and actions taken are maintained and available.""Indicator 3.3.3.
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available.""In indicator 3.3.3
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available."
Indicator 3.3.3 Proposed in order to: 1. The sentence "is provided and managed" changed to "maintained and available". 2. Records ofmonitoring and actions taken are maintained and available.
Comment: Translation in the language version needs to be improved proposed changes: 3.3.3 Records of monitoring and actions taken
are maintained and available.
"Proposed Indicator 3.3.3:
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available."#Indicator Comment (English)

127 3.3.3

128 3.4

129 3.4

130 3.4

131 3.4

132 3.4

133 3.4

134 3.4

135 3.4

136 3.4"Proposed 3.3.3:
1. Wrong translation, the phrase ""provided and managed"" changed to ""maintained and available""
2. Records of monitoring and actions taken are maintained and available.""This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues."
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.

#Indicator Comment (English)

137 3.4

138 3.4

139 3.4

140 3.4
141 3.4.1

142 3.4.1

143 3.4.1

This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
This assessment must be undertaken with the help of external stakeholders, notably representatives of civil society and local
smallholders or villagers - but also representatives of environmental and social rights. A basic template should be made available withthe same threshold requirements - this template will be adapted according to local environmental and social issues.
"3.4 The note section to be deleted because:• Indonesia has many regulations according to its level (Law to Ministerial Regulation). National interpretation will have difficulty
identifying it.
• There are different regional regulations according to each location• The dynamics of laws and regulations in Indonesia are very high (especially the addition of legislation)• All certification units have identified related laws and requirements in their respective locations• Important environmental and social impacts will be identified during the assessment process so that it does not need to be
determined by the national interpretation"[Abidjan WS] Criteria 3.4 - missing the word 'conducted' 'creation' before the wordings of before new plantings - translation issue
3.4.1 First of all, experience dictates, the social and environmental impacts should not be grouped together in 1 document, in the oilpalm context. For established concessions, it is the social component that would probably change. From an environmental perspective,
impacts are either mitigated or remediated and unless there are new additions to the concessions, these impacts would stabilize. So,
requiring the generic SEIA document in most oil palm countries actually dilutes the social component which we believe is very crucial
for sustainability.
3.4.1 First of all, experience dictates, the social and environmental impacts should not be grouped together in 1 document, in the oilpalm context. For established concessions, it is the social component that would probably change. From an environmental perspective,
impacts are either mitigated or remediated and unless there are new additions to the concessions, these impacts would stabilize. So,
requiring the generic SEIA document in most oil palm countries actually dilutes the social component which we believe is very crucial
for sustainability.
"3.4.1 We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers"#Indicator Comment (English)

144 3.4.1"A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.

145 3.4.1
146 3.4.1

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers""The template should be regularly re-evaluated with a panel of expers relevant to the geographical area under consideration and the
local social situation.""A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.
We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers"

#Indicator Comment (English)

147 3.4.1"A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.

148 3.4.1

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers""A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.

149 3.4.1
150 3.4.1

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers"
We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers
3.4.1 We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers

#Indicator Comment (English)

151 3.4.1
152 3.4.1
153 3.4.1
154
155
156
157
158

3.4.1
3.4.1
3.4.1
3.4.1
3.4.1

159 3.4.1

160 3.4.1

161 3.4.1
162 3.4.1
163
164
165
166
167

3.4.1
3.4.1
3.4.1
3.4.1
3.4.1

168 3.4.1
169 3.4.1

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers
Proposed Indicator 3.4.1: The phrase "The Planning/Supplier Scheme Outside Fruit" is changed to "Plasma/Partnership Garden""Proposed Indicator 3.4.1:
The phrase ""Fruit Planning/Supplier Scheme"" is changed to ""Plasma/Partnership Garden"""
Proposal: The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden".
Indicator 3.4.1 (c) Proposed in order to: The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden"
Proposed Indicator 3.4.1 (c) Proposed to: The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden"
3.4.1: The term "Fruit Expert/Supplier Scheme" is changed to "Plasma/Partnership Garden"
3.4.1. Documented the Seia which was carried out through participatory methodologies and involved affected stakeholders along with
the impact on schemes of the planters/suppliers outside the fruit on new operations or planting, including PKS.
"Comment:
The phrase ""Fruit Planning/Supplier Scheme"" is changed to ""Plasma/Partnership Garden""
Proposed changes:
3.4.1 (c) Documented the Seia which is carried out through participatory methodologies and involves affected stakeholders along with
the impact on plasma/partnership gardens on new operations or planting, including PKS."
Comment: The phrase "" Fruit Expert/Supplier Scheme "was changed to" Plasma/Partnership Garden "Proposed Change: 3.4.1 (c) It
was documented through a participatory methodology and involved affected stakeholders along with the impact on theplasma/partnership garden on the operation/partnership on the operation or new planting, including PKS.
Proposed 3.4.1: The phrase "The Planning/Suppliers Scheme Outside the Fruit" is changed to "Plasma/Partnership Garden""Proposed 3.4.1 (c):The phrase ""Fruit Planning/Supplier Scheme"" is changed to ""Plasma/Partnership Garden"""
The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden"
In indicators 3.4.1 The sentence "Expert Scheme/Outside Fruit Supplier" is changed to "Plasma/Partnership Garden"
3.4.1 - Sentence "The Fruit Planning/Supplier Scheme" was changed to "Plasma/Partnership Garden"
The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden""3.4.1: The term ""Fruit Expert/Supplier Scheme"" replaced
Become a ""Plasma Garden/Partnership"""
The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden"
Indicator 3.4.1 (c) Proposed in order to: The phrase "Fruit Planning/Supplier Scheme" is changed to "Plasma/Partnership Garden"#Indicator Comment (English)

170 3.4.1
171 3.4.1

172 3.4.1

173 3.4.1
174 3.4.1
175 3.4.1
176 3.4.1

177 3.4.2"Indicator 3.4.1 Proposed:
The phrase ""Fruit Planning/Supplier Scheme"" is changed to ""Plasma/Partnership Garden"""Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the impact(positive or negative) because it diverts the term used and in the principle 4 that in some cases is spoken of affected as affected as
Negative is not coincident.
"I suggest: 3.4.1 (c) In new plantations or operations (including extractor plants and system producers) an EISA is documented
independent, performed through a methodology
Participatory that involves relevant interested parties.
"
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the term
impacted.
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the term
impacted.
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the term
impacted because it diverts the term used to the error.
"[Abidjan WS] Criteria 3.4 - There is a need to provide Clear Clarity on the requirement of this impact assessment. There is different
Between Seia and Esia (L'Eise versus i'eies) - In Cote d'Ivoire that is regulated under national regulation.
Perhaps National Interpretation Can Address?"
3.4.2 It follows the above comment in 3.4.1. The social and environmental impacts should be considered separately for management
purposes.

#

Indicator Comment (English)

178 3.4.2"A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.

179 3.4.2

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers.
""A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.
We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers"

#Indicator Comment (English)

180 3.4.2"A guide to good farming practices should be made available to all smallholders (2-3 ha), in their own language, to help them findinformation.
These guidelines should result from the work of a panel of relevant players.
A mapping of existing approaches to small-scale replanting is already underway; building on these studies could be a first step.
Overall planning support should be provided - depending on the scale and nature of the activities.
Representatives of smallholders and schemes should be included in these discussions to validate the relevance of key performanceindicators.
The model should be regularly re-evaluated with a panel of exporters, depending on the geographical area under consideration andthe local social situation.

181 3.4.2

182 3.4.2

183 3.4.2

184 3.4.2

We acknowledge the fact training programs should be made accessible to all workers, we suggest to specify it includes migrant
workers, or illiterate workers""3.4.2: Add the word ""social"" to monitoring
environment, to match the sentence in the English version, namely; 3.4.2 for the unit of certification, a seia is available and social andenvironmental management andMonitoring Plans have been developed with participation of
Affected Stakeholders.""Proposed for indicators 3.4.2:
The sentence revision becomes ""for the certification unit, the seia is carried out and the planned management and monitoring ofsocial and environmental compiled through the participation of affected stakeholders.""""Proposed Indicator 3.4.2: Changing the phrase ""for the certification unit, the seia is carried out and the planned management andenvironmental monitoring is prepared through the participation of the stakeholders affected"" to be ""to be""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""Proposed for indicators 3.4.2:
Change the phrase ""for the certification unit, the seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected"" to become""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders."""#

Indicator Comment (English)

185 3.4.2

186 3.4.2
187 3.4.2

188 3.4.2

189 3.4.2

190 3.4.2

191 3.4.2"3.4.2 For the Certification Unit, the Seia is carried out and the planned management and environmental monitoring is preparedthrough the participation of affected stakeholders.
Proposal:
Changing the phrase ""For the Certification Unit, the Seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected""
become""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders."""3.4.2. For the Certification Unit, the SEA is carried out and the planned management and environmental monitoring is preparedthrough the participation of affected stakeholders.
3.4.2: Add the word "social" to environmental monitoring, to match the sentence in the English version, namely; 3.4.2 for the unit ofcertification, a seia is available and social and environmental management and monitoring plans have been developed withparticipation of affected stakeholders.
Proposal for 3.4.2: Changing the phrase "for the certification unit, the seia is carried out and the planned management andenvironmental monitoring is prepared through the participation of the affected stakeholders" to "for the certification unit, as well as
the management and social and environmental monitoring plans are prepared through the participation of the stakeholders affectedinterests. ""Indicator 3.4.2 is proposed to:
The sentence ""for the certification unit, the seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected"" into""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""Change the phrase ""for the certification unit, the seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected"" to become""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""Indicator 3.4.2 Proposed:
Change the phrase ""for the certification unit, the seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected"" to become""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders."""#

Indicator Comment (English)

192 3.4.2

193 3.4.2

194 3.4.2
195 3.4.2

196 3.4.2

197 3.4.2

198 3.4.2

199 3.4.2"In indicators 3.4.2 Changing the phrase ""for the certification unit, the seia is carried out and the planned management andenvironmental monitoring is prepared through the participation of the stakeholders affected"" to be ""to be""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""3.4.2 Changing the phrase ""For the Certification Unit, the Seia is carried out and the planned management and environmental
monitoring is prepared through the participation of the stakeholders.
""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders."""
Improve sentences so that "Management and Monitoring Plans" also embellish "social" aspects and not environmental sajes"Proposed 3.4.2:
Change the phrase ""for the certification unit, the seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected"" to become""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""Comment:
Changing the sentence of environmental monitoring into ""social and environmental monitoring""
Proposed change
For the Certification Unit, the Seia is carried out and the planned management and monitoring of social and environment]"
Changing the phrase "For the Certification Unit, the Seia is carried out and the planned management and environmental monitoring is
prepared through the participation of affected stakeholders" to "for the certification unit, the seia is carried out as well as the
management and environmental and environmental monitoring plans are prepared through the participation of affectedstakeholders.""Proposed 3.4.2:
Changing the phrase ""For the Certification Unit, SEA is carried out and the planned management and environmental monitoring is
prepared through the participation of affected stakeholders"" to: ""for the certification unit, the seia is carried out and the planned
management and social and environmental monitoring of the environmental stakeholders.""""3.4.2 - Changing the phrase ""for the certification unit, the seia is carried out and the planned management and environmental
monitoring is prepared through the participation of the stakeholders.
""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders."""#

Indicator Comment (English)

200 3.4.2

201 3.4.2

202 3.4.2

203 3.4.2
204 3.4.2

205 3.4.2
206 3.4.2
207 3.4.3
208 3.4.3
209
210
211
212

3.4.3
3.4.3
3.4.3
3.4.3

"3.4.2: Changing the phrase ""for the certification unit, the seia is carried out and the planned management and environmental
monitoring is prepared through the participation of the stakeholders.
""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""Proposed Indicator 3.4.2:
Change the phrase ""for the certification unit, the seia is carried out and the planned management and environmental monitoring is
prepared through the participation of the stakeholders affected"" to become""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders.""""3.4.2. Replace the phrase ""for the certification unit, the seia is carried out and the planned management and environmental
monitoring is prepared through the participation of the stakeholders affected"" into""For the Certification Unit, the SEA is carried out and the planned management and social and environmental monitoring is preparedthrough the participation of affected stakeholders."""Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the term
impacted.
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the impact(positive or negative) because it diverts the term used and in the principle 4 that in some cases is spoken of affected as affected as
Negative is not coincident.
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the term
impacted
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the term
impacted.
3.4.3 Please define regularly? 6 months, 1 year, or 2 years etc. As mentioned earlier, these the environmental and social plan should be
separated.
[Accra WS] Defined what is regulated updated - should state updated every 5 years or in accordance to national regulation. (NI to also
defined clearly the update frequency as per national regulation).
Include that the periodicity of monitoring is every two years.
Define that the periodicity of monitoring is every two years
3.4.3 Define that period is considered
Clarify the revision and update times of EISA management plans include a suggested time.

#Indicator Comment (English)

213 3.4.3

214
215
216
217

3.4.3
3.4.3
3.4.3
3.4.3

218 3.4.3
219 3.4.4

220 3.4.4
221 3.4.4
222 3.4.4
223 3.4.4
224 3.4.4"3.4.3 and 3.4.4. They are related and I think the other way around: the social and environmental impact assessment is carried out
once and their plans are updated every two years. In the event that there is a change in the EISA findings (impacts), such evaluation is
updated.
These independent evaluations are expensive and it would be unsustainable to do them periodically."
3.4.3. Define that the period must be every 2 years.
Include that the periodicity of monitoring is every two years.
Define that the periodicity of monitoring is every two years"[Abidjan WS] 3.4.3 (c) To include requirement on communication - Remove the requirement from 3.4.4 on 'this seia
shall be provided to all affected communities in a form andLanguage Understood by all parts included vulnerable andIlliterate Groups. ' To 3.4.3 (C)"
[Abidjan WS] 3.4.3(C) To define 'update regularly' - propose to state review to be done every 3-years and/or based on National
Interpretation.
3.4.4 Need to rethink this. In most cases, especially for established estates, the impacts would remain the same. An SEIA would only benecessary if there are significant changes in the project. The 2-year reassessment requirement is based on ignorance and a lack ofunderstanding the palm oil industry.
[Accra WS] 3.4.4 removed the first sentence - as it is captured under 3.4.3 - redundant. And it should stated a summary of the SEIA andits monitoring and management plan shall be provided.... groups. SEIA often is a long documents (more than 200 pages)"This review will be carried out with the participation of relevant external stakeholders.
"
These documents are usually 200+ pages, and providing them in full to stakeholders may not be practicable. A summary, or the SEIA
Management Plan would be more logical.
This review will be carried out with the participation of relevant external stakeholders.
Instead of "SEIA shall be provided", the SEIA management plan to be shared during any stakeholders consultation session would sufficeand more practical. We must not create bureaucracy by distributing the SEIA or management plan. Let UoC decide the channel tocascade the information.

#Indicator Comment (English)

225 3.4.4

226
227
228
229

3.4.4
3.4.4
3.4.4
3.4.4

230 3.4.4

231 3.4.4"Suggest to take off this indicator as it should be managed through the management and monitoring plan as opposed to reviewing theentire SEIA.
[>Having SEIA conducted, reviewed every two years is not practical. SEIA is a legal requirement in many countries and companies must
follow regulations to implement it. SEIA is done prior to a project (not at a time when a project is already in operation) and during theimplementation of the project, the management and monitoring plan is reviewed periodically (in Ghana every 3 years, in Nigeria every
5 years) as we already have in the standard (3.4.3C). Therefore any new risk identified, will be addressed by the management andmonitoring plan. The 2-year review of SEIA would not be consistent with the legal requirements in these countries.
> In Malaysia, there is no legal requirement to review and revise EIA. as it is managed through the management plan. Company will
update the EIA only for specific requirements for e.g. when there is a new planting or replanting [more than 500 hectares for Sabah
and Sarawak], , or the case of displacement of a community of more than 100 people. The monitoring plan of the EIA requires regularreview]."
This review will be carried out with the participation of relevant external stakeholders.
Suggest to do NPP SEIA review whenever necessary instead of once every two years.
This review will be carried out with the participation of relevant external stakeholders.
"Proposed indicator 3.4.4- Disagreeing to review documents seia is carried out every 2 years but adjusted if there is a change in the capacity of activities, thearea of activity or additional activities of the certification unit or changes in the SEA studies scope that can potentially on
environmental impacts and in accordance with applicable national regulations.""Proposed Indicator 3.4.4: 1. Disagreeing EIA Document Review (AMDAL) is carried out every 2 years, adjusted if there is a change incapacity, activity, scope, etc.
2. Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations""""Indicator 3.4.4:- Disagree if the EIA document review (AMDAL) is carried out every 2 years, it should be adjusted if there is a change in capacity,
activity, scope, etc.
- Proposed sentence revision: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on theenvironment in accordance with national regulations"""#Indicator Comment (English)

232 3.4.4

233 3.4.4

234 3.4.4

235 3.4.4

236 3.4.4

237 3.4.4"- Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations""""Indicator 3.4.4: The English version, namely: ""Provided"" should be interpreted in Indonesian which is ""available"".
Consideration: This is to be consistent with indicators 1.1.1
Indicator 3.4.4: It is necessary to clarify that the product identification of environmental and social impacts required based on laws andregulations is not included in the review requirements per 2 years because it already has its own review mechanism (cth: for Indonesia
is RKL-RPL). It also needs an explanation regarding the basis for determining the 2 years of the review period because actually thereview is more effective if there are changes related to field operations that are likely to have an impact on the environment andsocial."Proposed changes in indicators 3.4.4: - It is necessary to change the phrase "Review of the EIA document (AMDAL) is carried out every
2 years, adjusted if there is a change in capacity, activity, scope, etc." - Use the sentence: "Seia will be reviewed if there is a change incapacity, activity , scope that has an impact on the environment in accordance with national regulations ""Proposal:- Disagree with the EIA document review (AMDAL) is carried out every 2 years, adjusted to if there is a change in capacity, activity,
scope,- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations""""Proposed Indicator 3.4.4:- Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations""""Indicator 3.4.4 is proposed to:
1. Disagree with the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
2. Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations."""#

Indicator Comment (English)

238 3.4.4

239 3.4.4

240 3.4.4

241 3.4.4

242 3.4.4

243 3.4.4"Proposed 3.4.4:- Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations""""3.4.4 -Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity,
scope, etc. -> Proposed Sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact to theenvironment in accordance with national regulations """3.4.4: The phrase "every two (2) years" is changed to "if there is a change in capacity, activity, scope that has an impact on theenvironment in accordance with applicable national regulations". Explanation: Review of Documents Seia or AMDAL in Indonesia isregulated by national regulations. The SIA document can be reviewed every 2 years according to the previous RSPO P&C provisions.
Comment: - There is no basis/reference that regulates the review provisions carried out every 2 years - Disagreeing EIA Document
Review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope, etc. Proposed changes: 3.4.4 Seia
must Reviewed if there is a change in capacity, activity, scope that has an impact on the environment in accordance with national
regulations. Seia must be done on all people affected in the form and language understood by all parties.
"Indicator 3.4.4 Proposed:- Disagrees to the SEA (AMDAL) document review is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations""""3.4.4: The sentence ""every two (2) years"" is changed to ""ifthere are changes in capacity, activity, scope
impact on the environment in accordance with national regulations
applicable"". Explanation: SEA Document Review
or AMDAL in Indonesia is regulated by national regulations.
SIA documents in addition can be reviewed
Every 2 years according to the previous RSPO P&C provisions.
"#

Indicator Comment (English)

244 3.4.4

245 3.4.4

246 3.4.4

247 3.4.4

248 3.4.4

249 3.4.4
250 3.4.4

3.4.4- Disagree with the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity,
scope, etc. - Use the sentence: "Seia will be reviewed if there is a change in capacity, activity, scope that affects the environment
accordingly National Regulation"Comment:- There is no basis/reference governing the review provisions are carried out every 2 years- Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
Proposed changes:
3.4.4 Seia must be reviewed if there is a change in capacity, activity, scope that has an impact on the environment in accordance withnational regulations. Seia must be done on all people affected in the form and language understood by all parties.
""Proposed Indicator 3.4.4:- Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations"""[Jakarta WS] 3.4.4 review done every three years not two years - as it is regulated under law. Also remove 'including vulnerable andilliterate groups.' it is covered under all parties - because it will create audit issues - where to find them and make sure to find themand interview them.
"In indicators 3.4.4- Disagrees to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope,etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations"""
Proposed changing sentences to: "Seia will be reviewed if there are changes in capacity, activity, scops that have an impact on theenvironment in accordance with the applicable national regulations""Disagreeing EIA Document Review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity, scope, etc.
Proposed change: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations"""#Indicator Comment (English)

251 3.4.4

252 3.4.4

253 3.4.4

254 3.4.4

255 3.4.4
256 3.4.4
257 3.4.4

258 3.4.4
259 3.5"3.4.4: - Disagree with the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is a change in capacity, activity,
scope, etc.
- Use the sentence: ""Seia will be reviewed if there is a change in capacity, activity, scope that has an impact on the environment inaccordance with national regulations"""
Indicator 3.4.4 Proposed in order to: 1. Disagree to the EIA document review (AMDAL) is carried out every 2 years, adjusted if there is achange in capacity, activity, scope, etc. 2. Use the sentence: "Seia will be reviewed if there is a change in capacity, activity, Scope which
has an impact on the environment in accordance with national regulations. "Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the impact(positive or negative) because it diverts the term used and in the principle 4 that in some cases is spoken of affected as affected as
Negative is not coincident.
Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the impact(positive or negative) because it diverts the term used and in the principle 4 that in some cases is spoken of affected as affected as
Negative is not coincident.
It makes no sense to review the EISA every two years unless there is a new operation or new planting, it is suggested to include that
EISA will be reviewed (new planting and/or new operation)
It is suggested to include that EISA will be reviewed when it is carried out: (new planting and/or new operation) and the management
plans will be reviewed and/or updated every (2) two years.
"I suggest:
3.4.4 The EISA action plans will be checked every two (2) years. In the event that there are changes in the findings of the EISA, it will be
updated to have the new impacts on their interested parties."[Abidjan WS] 3.4.4 propose to merge under 3.4.3 as proposed above.
"We need to ensure that smallholders have access to information, particularly on good agricultural practices and on which molecules
to use or avoid, to ensure that procedures are properly followed."#

Indicator Comment (English)

260 3.5

261 3.5
262 3.5
263 3.5
264 3.5

265 3.5.1
266 3.5.1

267 3.5.1"Regenerative Agriculture - Comments>Reg Ag is a means to deliver on various elements of the RSPO standard (e.g. water quality, safe use of pesticides and herbicides, GHGetc.) - No need to write it in a separate element in the standard. But it would probably be useful to mention it in any supporting
guidance.
The RSPO standard could recognize the adoption of certain Reg.Ag. practices, in certain contexts as indicators of good practice, for e.g.
integration of grazing livestock within palm plantations, where this is an economically viable option, to reduce or avoid use ofherbicides and promote nutrient cycling to reduce dependency on inorganic N fertilizer.
>Suggest RSPO to widen the 'RSPO best practices on agricultural practices' to all types of palm oil plantations.
>Some of the Reg Ag principles i.e. good agricultural practices are embedded in the standards (P&C and ISH), suggest RSPO to do aninternal study/a gap analysis of Reg. Ag. practices principles against RSPO standards and determine what are the additional > alignment"
We need to ensure that smallholders have access to information, particularly on good agricultural practices and on which molecules touse or avoid, to ensure that procedures are properly followed.
We need to ensure that smallholders have access to information, particularly on good agricultural practices and on which molecules touse or avoid, to ensure that procedures are properly followed.
We need to ensure that smallholders have access to information, particularly on good agricultural practices and on which molecules touse or avoid, to ensure that procedures are properly followed.
"3.5 Note section to be deleted because:• Indonesia has many regulations according to its level (Law to Ministerial Regulation). National interpretation will have difficulty
identifying it.
• There are different regional regulations according to each location• The dynamics of laws and regulations in Indonesia are very high (especially the addition of legislation)• All certification units have identified related laws and requirements in their respective locations• Important environmental and social impacts will be identified during the assessment process so that it does not need to be
determined by the national interpretation"
3.5.1 This is an indicator based on ignorance as any functional estate or unit of certification undertakes this exercise annually. The
indicator is also not time specific.
"3.5.1 + 3.5.2 This estimate must be carried out with external experts, in collaboration with all stakeholders - potentially including theuse of satellite tools and/or field photos to attest land use and tree maturity/health. This is to avoid any drifting of the system inplace."
also for indirectly sourced FFB?

#

Indicator Comment (English)

268 3.5.1
269 3.5.1
270 3.5.1
271
272
273
274

3.5.1
3.5.1
3.5.1
3.5.1

275 3.5.1
276 3.5.1
277 3.5.1
278 3.5.1

279
280
281
282
283
284

3.5.1
3.5.1
3.5.1
3.5.1
3.5.1
3.5.1

285 3.5.1

This estimate must be carried out with external experts, in collaboration with all stakeholders - potentially including the use of satellite
tools and/or field photos to attest land use and tree maturity/health. This is to avoid any drifting of the system in place.
3.5.1 + 3.5.2 This estimate must be carried out with external experts, in collaboration with all stakeholders - potentially including theuse of satellite tools and/or field photos to attest land use and tree maturity/health. This is to avoid any drifting of the system in place.
This estimate must be carried out with external experts, in collaboration with all stakeholders - potentially including the use of satellite
tools and/or field photos to attest land use and tree maturity/health. This is to avoid any drifting of the system in place.
Suggest to add “optimum while sustainable FFB yield”
3.5.1: The word "potential" is removed because there is already a word "estimating"
the word potential is removed because there is a repetition of words (estimates and potential of the same meaning)[Jakarta WS] 3.5.1 proposed to reword to 'The Unit of Certification shall document annual projected yield potential of its own
plantation (excluding direct and indirect FFB supplier)'. This is avoid mis-interpretation where CB raise NC when actual yield is lower
then projected.
Indicator 3.5.1 is proposed in order to: The word "potential" is removed because there is a repetition of words (estimates and the same
meaning).
"Proposed Indicator 3.5.1:
the word potential is removed because there is a repetition of words (estimates and potential of the same meaning)""Proposed Indicator 3.5.1:
The word potential is removed because there is a repetition of words (estimates and the same meaning).""Comment:
The word potential is removed because there is a repetition of words (estimates and potential of the same meaning)
Proposed changes:
3.5.1 Certification Unit must estimate the potential of the Fresh Fruit Bunches (FFB) harvest to optimize the crop of FFB."
abolish the phrase "potential" - already estimated
Proposal 3.5.1: Potential words are removed due to repetition of words (estimates and potential of the same meaning)
In indicators 3.5.1 Potential words are removed due to repetition of words (estimates and potential of the same meaning)
3.5.1 Please detail the projection of TBS potential for how many years the data needs to be provided?
"3.5.1: The word ""potential"" is removed because there is already a word ""Estimating""""Proposed 3.5.1:
The word potential is removed because there is a repetition of words (estimates and potential of the same meaning)"
3.5.1 - Potential words are removed due to repetition of words ("estimates" and "potential" has the same meaning)#Indicator Comment (English)

286 3.5.1
287 3.5.1
288 3.5.1
289
290
291
292

3.5.1
3.5.1
3.5.1
3.5.1

293 3.5.2
294 3.5.2

295 3.5.3
296 3.5.3

297 3.5.3

298 3.5.3

299 3.5.3

300 3.5.3
301 3.5.3

Indicator 3.5.1 is proposed in order to: The word "potential" is removed because there is a repetition of words (estimates and the same
meaning).
Proposal: Potential words are removed due to repetition of words (estimates and potential of the same meaning)
Indicator 3.5.1 is proposed in order to: The word "potential" is removed because there is a repetition of words (estimates and the same
meaning).
Indicator 3.5.1 Proposed: Potential words are removed due to repetition of words (estimates and potentials are equal)
Important specify the performance of performance, either by production or productivity in production/hectares.
"Include performance scope, either production /hectares or production /t rff"
In the annexes of the standard, some suggested methodologies could be included for the estimation of the RFFs that allow facilitating
the auditability of the new indicator.
3.5.2 This is such a wide topic for a specific indicator. Proper consultation is required and reframing is necessary.
"Proposed Indicator 3.5.2:
The sentence is changed to: ""There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment"""
Indicator 3.5.3 should precede 3.5.2. Please flip it.
"Guidelines to be published to certify what is and what is not good farming practiceWith a basic guide, available in all relevant languages, and effective local relays, to ensure messages are disseminated andunderstood.""Guidelines to be published to certify what is and what is not good farming practiceWith a basic guide, available in all relevant languages, and effective local relays, to ensure messages are disseminated andunderstood.""Proposed 3.5.3:
The sentence is changed to: ""There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment"""
Comment: Language Indicator is unclear and difficult to understand proposed changes: 3.5.3 Available recording of parking
implementation - good cultivation practices as stipulated in SOPs to manage soil fertility so that the yields are optimal and have aminimum impact on the environment
Proposed 3.5.3: Improvement of sentence indicators to: "A recorded PARKTIC Implementation Records - Good Aquaculture Practices
As stipulated in SOPs to manage soil fertility so that the yields are optimal and have a minimum impact on the environment"
Proposed changes in Indkator 3.5.3 to be available recording of parking implementation - good cultivation practices as stipulated in
SOPs to manage soil fertility so that the harvest is optimal and has a minimum impact on the environment#Indicator Comment (English)

302 3.5.3

303 3.5.3

304 3.5.3

305 3.5.3

306 3.5.3

307 3.5.3
308 3.5.3

309 3.5.3

310 3.5.3
311 3.5.3"Comment:
Indicator language is unclear and difficult to understand
Proposed changes:
3.5.3 Records of Parktic Implementation Available - good cultivation practices as stipulated in SOPs to manage soil fertility so that theyields are optimal and have a minimum impact on the environment""Proposed 3.5.3: Improvement of sentence indicators to:""Available Records of Parktic Implementation - Good Cultivation Practices as stipulated in SOPs to manage soil fertility so that theyields are optimal and have a minimum impact on the environment""""Indicator 3.5.3 Proposed In order to: Sentences are changed to ""Records of the implementation of good cultivation practices asregulated in SOPs to manage soil fertility so that the yields are optimal and have a minimum impact on the environment.""""3.5.3. - The sentence is changed to: ""Available recording of parking implementation - good cultivation practices as stipulated in SOPs
to manage soil fertility so that the yields are optimal and have a minimum impact on the environment"""
Language Indicator is difficult to understand, so that the language proposal is as follows: 3.5.3 Records are available in parking
implementation - good cultivation practices as stipulated in SOPs to manage soil fertility so that the yields are optimal and have aminimum impact on the environment
3.5.3. The sentence is changed to: "There is a record of parking implementation - good cultivation practices as stipulated in SOPs tomanage soil fertility so that the yields are optimal and have a minimum impact on the environment""Proposed Indicator 3.5.3:
The sentence is changed to: ""There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment""""Proposal:
The sentence is changed to: ""There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment"""
The sentence is changed to: "There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment"
Indicator 3.5.3 Sentences are changed to: "PARKTIC IMPLEMENTATION RECORDING - Good Cultivation Practices As stipulated in SOPs
to manage soil fertility so that the yields are optimal and have a minimum impact on the environment"#

Indicator Comment (English)

312 3.5.3
313 3.5.3

314 3.6
315 3.6

316 3.6

317 3.6

318 3.6

The sentence is changed to: "There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment""Indicator 3.5.3 Proposed:
The sentence is changed to: ""There is a record of parking implementation - good cultivation practices as stipulated in SOPs to manage
soil fertility so that the yields are optimal and have a minimum impact on the environment"""
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process"3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to be establishedto propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""""3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""#Indicator Comment (English)

319 3.6

320 3.6

321 3.6

322 3.6

323 3.6"provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to be establishedto propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to be establishedto propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to be establishedto propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process"#Indicator Comment (English)

324 3.6

325 3.6

326 3.6

327 3.6.1
328 3.6.1
329 3.6.1

330 3.6.1

331 3.6.1

332 3.6.1"provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to be establishedto propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator""3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator
A timeline should be specified for the establishment of the taskforce and the development of a solution and audit process""3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator"
3.6.1 This is a mouthful indicator. Again, another badly written indicator. RSPO should get a language expert to reframe the indicator inthis standard.
online platform or secure system to make this information available
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.

#Indicator Comment (English)

333 3.6.1

334 3.6.1

335 3.6.1

336 3.6.1
337
338
339
340
341
342

3.6.2
3.6.2
3.6.2
3.6.2
3.6.2
3.6.2

343 3.6.2
344 3.6.3
345 3.6.3

346 3.6.4
347 3.6.4
348 3.6.4

Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
[Abidjan WS] 3.6.1 and 3.6.2 - annual production - proposed change to production over the last 12 months. As they will be different
understanding on annual - calendar year or fiscal year etc.
3.6.2 Again, please reframe this indicator as the language is long-winded.
online platform or secure system to make this information available.
online platform or secure system to make this information available"online platform or secure system to make this information available"
online platform or secure system to make this information available"""Guidelines to be published to certify what is and what is not good farming practiceWith a basic guide, available in all relevant languages, and effective local relays, to ensure messages are disseminated andunderstood.""""online platform or secure system to make this information available"
3.6.3 All indicators retained from the previous P&Cs seem to be well-structured. RSPO might need to reconsider a language consultant
for this P&C"3.6.3 d). Contamination? Please define. Does this mean contamination with mineral oils? If it means contamination of IP productswith MB and no-certified, then this is covered later.
It seems to be a useless comment as any mill will soon have its product rejected if the oil or PK is contaminated! The clarification line so
there to clean the mucky oil that comes out of the presses!"
3.6.4 In the RSPO SCC standard, the person conducting the annual internal audit cannot be the person in charge as the audit must be
independent. Why not here?
[Accra WS] 3.6.4 - to include the scope of the internal audit to cover for 'any other outsourcing activities'[Accra WS] 3.6.4 RSPO to provide guidance on internal audit procedure? What are the critical elements?

#

Indicator Comment (English)

349 3.6.5

350 3.6.5

351 3.6.5
352 3.6.6

353 3.6.6

354 3.6.6
355 3.6.6

356 3.6.6"When certified independent smallholders (ISH) chose to sell their certified volume via Credits, suggest to give exemption for the mill
to maintain status as Identity Preserved (IP) when they process these FFBs physically (certified volume has become uncertified volume
after ISH traded in PalmTrace).
This is to encourage a certified mill to continue receiving FFBs from certified ISH who sells their volume via Credits.""The data mills collect on purchasing in 3.6.5 (traded volumes both certified and non-certified) needs to be linked with the data
gathered in 2.3.
[3.6.5 Purchasing and Goods in
RSPO MB study undertaken by Proforest highlighted the link between 2.3 and 3.6.5 regarding the legality of source/supplier andvolumes. Mills are required to verify and document the tonnage and sources of certified and the tonnage of non-certified FFB received(P&C 3.6.5 i). For non-certified FFB, mills are not required to verify and document the sources, only the tonnage. It also does not
specify the types of information to keep for the purchasing (e.g. supplier’s origin/location, proof of legality). So even though P&C 2.3
requires non-certified FFB to be from legal supplier [provision of geolocation, ownership, license to operate] the standard does not ask
explicitly to link this information through to the volumes in/out as stipulated under 3.6.5]."[Abidjan WS] 3.6.5 iii) Provide definition and/or guidance on what are nonconforming FFB - example the FFB delivered by using a dirty
truck - is it not conforming?
"Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too."
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
including geo info and land ownership info? Could be relevant to expand information system for those members needing to show
evidence and information for due dilligence
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
"3.6 provide operational assistance to mills to implement these requirements: tools, training, support… A Task Force is to beestablished to propose asolution that can be audited and would require
growers to gradually progress towards full implementation of this indicator"#Indicator Comment (English)

357 3.6.6

358 3.6.6

359 3.6.7

360 3.6.7
361 3.6.7

362 3.6.7

363 3.6.7

364
365
366
367
368

3.6.7
3.6.7
3.6.7
3.6.7
3.6.7

369 3.6.7

370 3.6.7
371 3.6.7

Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
"Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.""Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too."[Accra WS] this indicator should be elevated to critical indicator"Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too."
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Support is definitely needed from the RSPO and the market as a whole to help mills implement this tracking system. The MB model isstill very unclear to most non-certified FFB suppliers. We need to help mills get organized and raise smallholders' awareness of theneed to trace their harvests too.
Proposed improvement for indicators 3.6.7: Translation to "PKS may not convert its factory activities".
"The proposed translation improvement to ""PKS may not convert to its factory activities""."
Proposed improvement for indicators 3.6.7: Translation to "PKS may not convert its factory activities".
The proposed translation improvement to "PKS may not convert to its factory activities".
"Proposed Indicator 3.6.7:
The proposed translation improvement to ""PKS may not convert to its factory activities"".
""Proposed improvement for point 3.6.7:
The translation to ""PKS may not convert its factory activities"".
"
Indicator 3.6.7 Proposed translation improvement to "PKS may not convert its factory activities".
3.6.7 - Proposed translation improvement to "PKS may not switch to its factory activities".

#Indicator Comment (English)

372 3.6.7
373 3.6.7
374 3.6.7

375 3.6.7
376 3.6.9

377 3.6.9

378 3.6.9
379 3.6.9
380 3.6.9

Proposed Indicator 3.6.7: Improvement of the translation to "PKS may not convert to its factory activities".
Indicator 3.6.7 is proposed in order to: Point (i) the translation to "PKS may not convert to its factory activities".
"Proposed Indicator 3.6.7:
The proposed translation improvement to ""PKS may not convert to its factory activities"".
""Indicator 3.6.7 Proposed:
The proposed translation improvement to ""PKS may not convert to its factory activities"".""Let us be very, very clear: If any mill receives and processes ANY quantity of non-certified FFB or FFB with an MB claim, then it isdeemed to be a Mass Balance Mill. See also comments for 3.6.9 C and 3.6.10.
There is NO way that a mill can produce 100% separated IP through a clarification line of they have processed any non certfified crop,
without stripping the complete line and steam cleaning every single pipe, valve, machuine and tank. ""3.6.9 c). The credibility of the mass balance supply chain model is in serious doubt as it is effectively the ISO definition of book andclaim. There is no guarantee of even one molecule of certified CPO and PKO in any product that carries an MB claim and an MB claim
can be created throughout the supply chain on products from TOTALLY UN-KNOWN ORIGINS! (An MB claim can even be created on
Glycerine derived from cocoa nut oil, olive oil etc.,!!).
Allowing selling short further undermines the credibility of the RSPO and must NOT be allowed. MB must ONLY be claimed frompositive physical and matching paper MB stock records and so the MB account must ALWAYS be equal to or greater than the physicalstock. It must NEVER be allowed that the paper record for MB ever exceeds any physical stock. It is almost 100% certain that the SCC
review will ensure that the MB supply chain model reflects the true ISO definition of MB and does not continue as nothing more andnothing less than Book and Claim. The RSPO book and claim supply chain model is quite simply the trading of credits! "[Accra WS] 3.6.9 iv b) add '...according to mill-specific conversion ratios. In the absence of mill-specific conversation ratios, material
account system shall be in accordance with RSPO guidance on conversation ratios.'[Accra WS] 3.6.9 iv a) 'three-monthly basis'?
"3.6.9 Points IV a. Writing mistake.
(1) It says ""Thrice-Monthly"" should be ""Three-Monthly"".
(2) In the Indonesian version the word balance is interpreted to ""calculate"" should ""balance"""#Indicator Comment (English)

381 3.6.10

382 3.6.10

383 3.6.11
384 3.6.11
385 3.6.11

386 3.6.11"Identity Preserved must mean just that. IP claim must ONLY be applicable to a mill that is processing 100% RSPO certified FFB.
The standard requires 100% separation. This means that the certified FFB must be kept separate from non-certified (and MB FFB - that
may result from an FFB trader or collector mixing certified FFB with non-certified FFB and then selling non-certified FFB with an MB
claim!!).
Through the nature of the sterilizers, threshers, digesters and presses, and their effectively self cleaning, it is possible to batch processcertified FFB and then non certified FFB and still claim IP and 100% separation at that point.
However, the clarification line comprises significant lengths of small diameter pipes, machines with very large surface areas comparedto the volume of oil (Centrifuges, Filters, vibrating screens etc.,) as well as small and intermediate storage tanks, that without actual
stripping the mill to pieces and steam cleaning every element of the clarification line that it is possible to claim 100% separation.
""Striving for 100% separation"" without a clear definition of what is meant by this, has already resulted in subjective auditing anddecisions made by auditors that may conflict with the ASI auditors. The RSPO MUST encourage all growers to become RSPO P&C
certified and stop allowing growers and mills to avoid full compliance. An IP claim on CPO and PK must ONLY be allowed if 100% of all
FFB is from RSPO P&C or ISHS certified sources. The credibility of the RSPO is further under-mined if this is not the case,"
To add on with a scenario : if the certified ISHs sell their volume via Credits, a mill will not be able to claim IP status (certified volume
has become uncertified after traded in PalmTrace). In order to encourage a certified mill to continue receiving FFBs from certified ISHs
who sell their volume via Credits, suggest to give exemption for the mill to maintain as IP status, with condition the CPO produced fromthat portion cannot be claimed as certified product in their bookkeeping.
Indicator 3.6.11 (c) proposed to be repaired and the sentence is changed to "the volume of the RSPO IT platform must be abolished, if:
1. Sold through other schemes or conventionally 2. lost or damaged volume.
Proposed Indicator 3.6.11: Changes in sentences to "the volume of the RSPO IT platform must be abolished if": 1. Sold through otherschemes or by conventional means 2. Volume is lost or damaged"Proposed 3.6.11 (c):The sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged""Indicator 3.6.11 (c) Proposed for:The sentence is changed to ""the volume of the RSPO IT platform must be abolished, if:
1. For sale through other schemes or in a conventional way
2. lost or damaged volume."

#Indicator Comment (English)

387 3.6.11

388 3.6.11

389 3.6.11
390 3.6.11

391 3.6.11

392 3.6.11

393 3.6.11
394 3.6.11"Indicator 3.6.11
The sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged""3.6.11: The proposed sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged"
3.6.11: The sentence proposal is changed to "the volume of the RSPO IT platform must be abolished if": 1. Sold through other schemes
or by conventional means 2. Volume is lost or damaged"Proposed Indicator 3.6.11:
The sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged""Proposal:
The sentence is changed to ""the volume of the RSPO IT platform must be abolished if:
1.) For sale through other schemes or in a conventional way.
2.) Lost or damaged volume. """"Indicator 3.6.11 Proposed:
The sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged"
Indicator 3.6.11 (c) proposed to be repaired and the sentence is changed to "the volume of the RSPO IT platform must be abolished, if:
1. Sold through other schemes or conventionally 2. lost or damaged volume.
"Comment:
The sentence is too long and unclear
Proposed changes: (Indicator 3.6.11 Points (II)The volume of the RSPO IT platform must be abolished if:
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged"#Indicator Comment (English)

395 3.6.11

396 3.6.11

397 3.6.12

398 3.6.12"Proposal:
The sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged""The sentence is changed to ""the volume of the RSPO IT platform must be abolished if"":
1. For sale through other schemes or in a conventional way
2. The volume that is lost or damaged"This is fairly irrelevant to a mill as they are only producing IP or MB products when in compliance with this standard and making an IP
or SG claim! The min 95% rule is not applicable and the only time the RSPO Trademark maybe used for General Corporate
communication. Irrelevant requriement.
From indicators 3.6.3 to 3.6.12, very minor changes have been introduced. This is either because the 2018 indicators are effective or
the review of these indicators has been weak.

#Indicator

Comment (English)

1

4

2
3

4
4.1

"Organisation of Principle 4: Please check the wording of 4.2 and 4.4 which are different cases. One should look at new planting/new
development (FPIC guidance and support for implementation is available) and the other should look at existing plantations.
[4.2 might be read as contradicting 4.4 which covers the case where plantation has not had an FPIC agreement in place when it wasestablished. 4.2 is not clear and leads us to think that it applies to every case which is not true. We have to read up to 4.4. to find out
there is the case of land conflict where there was not FPIC in place and thus should be resolved through a mutually agreed process].
"remove "and" after "rights,...""On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.

4

4.1

Information should be disseminated in a culturally appropriate manner.""On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.

5

4.1

Information should be disseminated in a culturally appropriate manner.""On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.

6

4.1

7

4.1

8

4.1

9

4.1

Information should be disseminated in a culturally appropriate manner."On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new use ofland for oil basket plantations be regulated in order to respect the rights of local populations.
On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new use ofland for oil basket plantations be regulated in order to respect the rights of local populations.
"On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.
Information should be disseminated in a culturally appropriate manner.""On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.

Information should be disseminated in a culturally appropriate manner."#Indicator

Comment (English)

10

4.1

11

4.1

"On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.""On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.

12

4.1

13

4.1

14

4.1

15

4.1

16

4.1

17

4.1.1

18

4.1.1

19

4.1.1

Information should be disseminated in a culturally appropriate manner."On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new use ofland for oil basket plantations be regulated in order to respect the rights of local populations.
"On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.""On the contrary, in view of the environmental problems and, above all, the cases of social grievances, it is essential that any new useof land for oil basket plantations be regulated in order to respect the rights of local populations.

Information should be disseminated in a culturally appropriate manner."
Sentence 4.1 was changed to "land use for oil palm does not reduce legal rights, customary rights recognized by the government inaccordance with applicable national law, or the rights of utilization owned by other parties, except by obtaining the KBDD." so that theintended customary rights are more class
4.1: Sentences Criteria added, "customary rights recognized by the government in accordance with the applicable national law" to"criteria 4.1 Land utilization for palm oil does not reduce legal rights, customary rights recognized by the government in accordancewith applicable national law, or the rights of utilization owned by the party Others, except by obtaining KBDD.
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
"[HRWG] Recommendation: A compensation process or procedure may be more appropriate for cases where Communities are foundon existing plantations. Align this with the RaCP process for HCV. In the RaCP, there are different dates between 2005 and now. It
establishes the consequences of a clearance (including compensation) based on when a clearance of a HCV area was conducted. We
need to look at when FPIC was first introduced (i.e. after 2005) and determine the consequences based on when a clearing without
FPIC happened.
Retrospective application of FPIC may cause legal uncertainty and therefore access to compensation processes may be the best way
forward. For compensation, the start date should not pre-date when FPIC was first introduced to RSPO i.e. from 2005."
4.1.1 Please define new planting and new development. Specify the difference between the two and in which context, FPIC is required.

#

Indicator

Comment (English)

20
21

4.1.1
4.1.1

22

4.1.1

23

4.1.1

What is new development - definition to be provided
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
"4.1.1 (C) - To add: ""c) Existing Operations.""

24

4.1.1

25

4.1.1

26
27
28

4.1.1
4.1.1
4.1.1

29
30
31

4.1.1
4.1.1
4.1.1

32

4.1.1

33

4.1.1

34

4.1.1

There are existing operations without FPIC or incomplete FPICs that require compliance. "Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
no need to specify as all indicators appply[Sandakan, 21 June 2023] New Development definition should be provided in the standard.
In indicators 4.1.1 for both Pont (a and b) it is proposed to be combined into "new planting including the development of supporting
infrastructure"
Proposal 4.1.4: Point A and B are combined into "new planting including the development of supporting infrastructure"
Proposed indicator 4.1.1. Points A and B are combined into "new planting including the development of supporting infrastructure".
4.1.1: There is no definition of "new development" in the definition section. It is recommended that there is a definition of "newdevelopment".
"Indicator 4.1.1
Proposed changes:
Merging points A and B becomes ""new planting including the development of supporting infrastructure"""Indicator 4.1.1 (c) is proposed to: points A and B are combined into "new planting including the development of supporting
infrastructure".
4.1.1. Points A and B are combined into "new planting including the development of supporting infrastructure".

#Indicator

Comment (English)

35

4.1.1

36

4.1.1

Comments: - Points A and B are combined into "new planting including the development of supporting infrastructure" - Definition and
Limitation of New Development There is no proposal for change: 4.1.1 (c) KBDD must be obtained from people who are legal rights,
customary rights, and other utilization rights (including access to forest resources, food, water, roads/channels, etc.) directly affectedby new planting including the development of supporting infrastructure. The KBDD process specified in the indicator 4.2.1-4.2.11 isvalid.
"Comment:- Points A and B are combined into ""new planting including the development of supporting infrastructure""- The definition and limitations of new development do not exist

37
38
39
40
41

4.1.1
4.1.1
4.1.1
4.1.1
4.1.1

42

4.1.1

Proposed changes:
4.1.1 (c) KBDD must be obtained from legal rights, customary rights, and other utilization rights (including access to forest resources,
food, water, roads/channels, etc.) directly affected by new planting including the development of supporting infrastructure .
The KBDD process specified in the indicator 4.2.1-4.2.11 is valid."
Proposal 4.1.1 (c): points a and b are combined into "new planting including the development of supporting infrastructure"
Indicator 4.1.1 Proposed: points A and B are combined into "new planting including the development of supporting infrastructure"
Points A and B are combined into "New Planting including the Development of Supporting Infrastructure"
Deletion of subsection b. new developments and leave the application of the CLPI only for new plantations"4.1.1 (c) Free consent, prior and will be obtained
Informed (CLPI) of communities whose rights
legal, customary or other rights of use (such as
Access to forest resources, food, water, incidentally,etc.), they are directly impacted by:
to. New plantations
b. New developments""4.1.1 (c) The free, prior and informed consent (CLPI) of communities whose legal, customary and other user rights will be obtained,
such as access to forest resources, food, water, passing through, etc., etc., etc. They are directly affected by:
to. New plantations
b. New developmentsc. The existing operations and the areas withdrawn from the production for being AVC management areas [accepted objection] A
producer suggests eliminating 4.1.1 (c) C; and determine a borderline date for the application of the CLPIThe CLPI processes established in indicators 4.2.1 to 4.2.11 will be applied."#

Indicator

Comment (English)

43
44
45
46

4.1.1
4.1.1
4.1.1
4.1.1

47

4.1.1

48

4.1.1

49
50

4.1.1
4.1.1

Remove from subsection b. new developments and leave the application of the CLPI only for new plantations
Clarify if the clip applies to existing plantations.
Define in a better way for the standards which are new developments. The scope is not clear.
"Accept the objection: existing operations and the areas withdrawn from production for being AVC management areas [acceptedobjection] A producer suggests eliminating 4.1.1 (c) C; and determine a borderline date for the application of the CLPI"
Define the term "new developments", since this process should not include infrastructure developments or processes changes inalready certified units.
4.1.1 (c) The free, prior and informed consent (CLPI) of communities whose legal, customary and other user rights will be obtained,
such as access to forest resources, food, water, passing through, etc., etc., etc. They are directly affected by: a. New plantations b. New
developments c. The existing operations and the areas withdrawn from the production for being AVC management areas [acceptedobjection] A producer suggests eliminating 4.1.1 (c) C; and determine a borderline date for the application of the CLPI will apply the
CLPI processes established in indicators 4.2.1 to 4.2.11.
The 4.1.1 indicator is not clear when defining the scope.
"4.1.1. Eliminate subsection ""B"" that says new developments, since subsection ""A"" refers to new plantations.

51

4.1.2

52

4.1.2

53

4.1.2

54

4.1.2

55
56

4.1.2
4.1.2

57

4.1.2

58

4.1.2

Or define what refers to new developments."
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
"Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their lands."
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
4.1.2 Specify if this indicator is referring to the RSPO-specific guidance.
Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.
"Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land."Partnerships with local governments, businesses and smallholders must be set up to help customary owners complete and accelerate
administrative procedures and recognize their right to own their land.

#

Indicator

Comment (English)

59
60
61

4.1.3
4.1.3
4.1.3

62

4.1.3

63

4.1.3

64

4.1.3

65
66
67
68

4.1.3
4.1.3
4.1.4
4.1.4

69

4.1.4

4.1.3 This indicator needs to be reviewed under national interpretation as it does not apply to the major oil palm countries.
4.1.3 Specify the objective by which already certified plantations that were sown before 2005 must have a CLPI.
Clarifying the meaning and scope of the criteria taking into account that "as a result of recent expropriations for reasons of national
interest" is not a clear concept.
"Clarifying the meaning and scope of the criteria taking into account that ""as a result of recent expropriations for reasons of national
interest"" is not a clear concept.
""4.1.3 (c) New land will not be acquired for plantations andextractor plants after November 15, 2018,
As a result of expropriations, except in cases of small producers that benefit from agrarian reform or drug -fight programs.
--This point is not clear and it is not clear why it is retroactive (2005) ..."
Clarifying the meaning and scope of the criteria taking into account that "as a result of recent expropriations for reasons of national
interest" is not a clear concept.
Clarify the meaning and scope of the criteria, since it is not understood[Abidjan WS] 4.1.3(C) remove 'anti-' should just be programme antidrogue.
4.1.4 The recognition of voluntary isolation should be proven and legally accepted by the government.
In indicator 4.1.4 The sentence "Planting and/or New Development" is proposed to be replaced by "new planting including thedevelopment of supporting infrastructure""Proposal 4.1.4:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""

70

4.1.4

This is because it is in one unity of the process .."Indicator 4.1.4 Proposal: the phrase "planting and/or new development" was changed to "new planting including the development of
supporting infrastructure"#Indicator

Comment (English)

71

4.1.4

72

4.1.4

73

4.1.4

74

4.1.4

75

4.1.4

76

4.1.4

77

4.1.4

78

4.1.4

79
80

4.1.4
4.1.4

81
82

4.1.4
4.1.4

"Comment:- Using new planting sentences including the development of supporting infrastructure ""- The definition and limitations of new development do not exist
Proposed changes:
4.1.4 (c) New land obtained for new planting including the development of supporting infrastructure is not on the land inhabited bypeople who areolated themselves voluntarily.
"
The phrase "Planting and/or New Development" was changed to "new planting including the development of supporting
infrastructure"
Indicator 4.1.4 (c) proposed to: The phrase "planting and/or new development" is changed to "new planting including thedevelopment of supporting infrastructure".
Proposed 4.1.4: The phrase "Planting and/or New Development" was changed to "New Planting Includes in the development of
supporting infrastructure". This is because it is already in a unity of the process.
"Indicator 4.1.4:
Changing the phrase ""Planting and/or New Development"" to ""New Planting including the Development of Supporting
Infrastructure"""4.1.4. The phrase "Planting and/or New Development" was changed to "new planting including the development of supporting
infrastructure"
Indicator 4.1.4 (c) proposed to: The phrase "planting and/or new development" is changed to "new planting including thedevelopment of supporting infrastructure".
"Indicator 4.1.4 Proposed:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""4.1.4 Voluntary isolation must have a legal form to demonstrate,"4.1.4 (c) The new land acquired for new
Plantations and/or new developments will not be on land
inhabited by communities in voluntary isolation, which have legitimacy to be.
--I think the clarification is necessary because otherwise in Latam it can be provided to ""lagalize"" invasions (common practice ofpeople outside the UDC)"
4.1.4 Voluntary isolation must be legitimately demonstrated, clarify within the indicate, for any invasion that plantations can have
Voluntary isolation must be legally recognized.

#Indicator

Comment (English)

83
84

4.1.4
4.1.4

85
86

4.1.4
4.1.4

The legitimacy of the isolation should be demonstrated under some legal mechanism.
The legitimacy of the isolation should be demonstrated under some legal mechanism while it should be made clear that it applies only
for indigenous communities, since in the definition of voluntary isolation it is open for other types of populations
4.1.4 Define what refers to "voluntary isolation" and or let it refer to indigenous peoples.
"It is suggested to add ""... inhabited by communities in legitimately recognized voluntary isolation.""

87
88

4.1.4
4.1.5

89

4.1.5

90

4.1.5

91

4.1.5

92

4.1.5

93

4.1.5

94

4.1.5

95

4.1.5

96

4.1.5

The legitimacy of the isolation must be demonstrated under some legal mechanism that formally recognizes it."
Add or clarify: land inhabited by indigenous communities in voluntary isolation under some legal mechanism.
4.1.5 Establish the link between this general indicator and FPIC. Otherwise, it should be relocated to the NPP indicator. And there are
instances where NPP is not required.
4.1.5. The proposal to be abolished because it has been included in the NPP procedure which has also been verified by the certification
institution.
For new indicators 4.1.5 it is proposed to be eliminated because it has been included in the NPP procedure carried out by theverification of the Certification Institute (can potentially double audit)
The indicator proposal was abolished because it was included in the NPP procedure carried out by the verification of the Certification
Institute (can potentially double audit)"[I] 4.1.5
The indicator proposal was abolished because it was included in the NPP procedure carried out by the verification of the Certification
Institute (can potentially double audit)""Proposal:
Indicator 4.1.5 is abolished because it has been included in the NPP procedure which has also been carried out by RSPO auditors by the
Certification Institute (can potentially double audit). In addition, NPP requirements have been included in each indiakator related to
new planting procedures starting from SEIA, Land Legality, HCV, HCS, Social Survey etc.) Double Counting Audit."
Indicator 4.1.5 is proposed to: Eliminated because it has been included in the NPP procedure carried out by the verification of theCertification Institute (can potentially double audit).
"Indicator 4.1.5 Proposed:
The indicator proposal was abolished because it was included in the NPP procedure carried out by the verification of the Certification
Institute (can potentially double audit)"
4.1.5. The indicator is abolished because it is included in the NPP procedure carried out by the verification itself by the Certification
Institute (can potentially double audit).

#Indicator

Comment (English)

97

4.1.5

98

4.1.5

99

4.1.5

100

4.1.5

101

4.2

102
103
104

4.2
4.2
4.2

105
106
107
108

4.2
4.2
4.2
4.2

Indicator 4.1.5 is proposed to: Eliminated because it has been included in the NPP procedure carried out by the verification of theCertification Institute (can potentially double audit).
"Proposal:
Delete indicators because it has been included in the NPP procedure carried out by the verification of the Certification Institute (canpotentially double audit)"
Indicator 4.1.5 is proposed to: Eliminated because it has been included in the NPP procedure carried out by the verification of theCertification Institute (can potentially double audit).
"Indicator 4.1.5:
The indicators are included in the NPP procedure carried out by the verification itself by the certification institution so that it is
proposed to be deleted"
Revise wording of 4.2 to clarify that this is for new planting/new development [This is specific to 'new plantings' (old 4.5) and why it
was taken out?]
Information should be disseminated in a culturally appropriate manner.
Information should be disseminated in a culturally appropriate manner.
The update in FPIC requirements is understood and welcome for future developments. However, it is unclear how this applies to past
FPIC’s. FPICs done in the past for development purposes may have followed the 2018 P&C, but due to the updates, may notcompletely comply to the 2023 P&C. Past FPICs cannot be redone, but an auditor may interpret that it must comply 100% to the 2023
P&C. It is unclear how the revised FPIC requirements apply to past FPICs.
"Information should be disseminated in a culturally appropriate manner."[4.2] This criteria should only apply to new plantings as it is the case in the 2018 P&C.
Information should be disseminated in a culturally appropriate manner.
"suggest adding (IN UPPER CASE):

109

4.2

110
111

4.2
4.2.1

...and FPIC has not been obtained FROM THE RIGHT HOLDERS."
4.2 need to be given notes in indicators 4.2.2, 4.2.3 (c), 4.2.4 (c), 4.2.5, 4.2.6, 4.2.7, 4.2.8, 4.2.9, 4.2.10 that for the unit for the unit
Certification or old plantations that have been operating long before the implementation of the RSPO FPIC Guide (ie 2015) has norecord for decision making in the past that meets the FPIC rules
4.5 This criterion to be removed because it is included in the criteria 2.4 regarding handling complaints
4.2.1 The list of affected communities should be identified through the FPIC process and not the SEIA. As stated earlier, the SEIA is awatered-down approach. A separate SIA is required. Moreover, FPIC should be a standalone process and provides stronger
identification of affected parties, and not be extracted from the SEIA#

Indicator

Comment (English)

112
113

4.2.1
4.2.1

114

4.2.1

4.2.1 This indicator is missing the FPIC point. A mere list does not prove anything,
4.2.1 "Any proposed New Plantings and/or Development in existing operations" - new plantings do not necessarily have to be inexisting operations. They could be in areas where new operations are being established. Rewording is required.
"Reference to SEIA as the means to identify affected communities seems to be a mistake. Change for reference to Land Tenure and
Use Study instead.
As clearly stated in the RSPO FPIC Guide page 28 (assessment stage), identification of affected communities should be done through a
Land Tenure and Use Study :

115

4.2.1

116

4.2.1

117

4.2.1

118

4.2.1

119
120

4.2.1
4.2.1

121

4.2.1

The fundamental purpose of this stage is to:• Identify land ownership, boundaries and use (Land tenure and use assessment and participatory mapping)• Assess impacts of the potential development (SEIA)• Identify areas of conservation and forests (HCV assessment, HCS assessment, integrated HCV-HCSA
assessment)"
Sustained objection: Identification of affected parties have been covered under Principle 3 (SEIA). FPIC shall be confined to newplantings/new developments only as per 4.1.1. SEIA would suffice if there is any conflicts/grievance from affected parties. This entire
principles are in a mess after revamp. All in all, remain FPIC concept in P&C 2018 and revert back to the original text for P4 in P&C
2018.
"Proposal:- Specifying SEA documents (including the list of affected communities) available and cover the entire area
- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure""""Proposed 4.2.1: The sentence ""planting and/or new development"" was changed to ""new planting including the development of
supporting infrastructure"""
Proposed sentence changes in indicators 4.2.1. Changing the phrase "Planting and/or New Development" to "New Planting including
the development of supporting infrastructure".
Changing the phrase "Planting and/or New Development" to "New Planting including the Development of Supporting Infrastructure"
4.2.1. Changing the phrase "Planting and/or New Development" to "New Planting including the development of supporting
infrastructure".
Indicator 4.2.1 is proposed to: The phrase "planting and/or new development" is changed to "new planting including the developmentof supporting infrastructure".

#Indicator

Comment (English)

122

4.2.1

123

4.2.1

124

4.2.1

125
126

4.2.1
4.2.1

127

4.2.1

128
129

4.2.1
4.2.1

Indicator 4.2.1 is proposed to: The phrase "planting and/or new development" is changed to "new planting including the developmentof supporting infrastructure".
"Comment:- Using new planting sentences including the development of supporting infrastructure ""- The definition and limitations of new development do not exist
Proposed changes:
4.2.1 (c) Identifying the list of affected communities in the area of the proposed new planting including the development of
supporting infrastructure in the operation that is being carried out, through the SEIA or a review of the management plan andutilization of the latest SEA certification unit.
To identify affected communities, see the KBDD RSPO 2022 guide.""Term translation affected to impacted is suggested. It must be explained that:
The documents related to the CLPI, including maps and compensation procedure, only apply if there is any pending genuine dispute
over any land in existing operations."
Translation to impacted communities is suggested, the word affected in Spanish is understood that it is something negative"4.2.1 (c) A list of communities will be identified
impacted (positive or negatively) that exist within the proposed area for any new plantation or new development in existing
operations, through the EISA or a review of the current management and monitoring plan of the EISA of the certification unit.
To identify the impacted communities, see the guide
RSPO on free, prior and informed consent (CLPI)
of 2022.""It is suggested to change the translation of the terms affected to impacted.
Define the scope of new developments, since at the meeting they established that the term did not apply for existing plantations oroperations."
Translation to impacted communities is suggested given to negative connotation of affected.
"It is suggested to change term translation affected to impacted.
According to the accepted objection:

130

4.2.2

Accepted objection of the producers: the documents related to the CLPI, including the maps and the compensation procedure, only
apply if there is any case pending genuine dispute over any land in existing operations."
4.2.2 What if the affected parties have none of this? How would the "affected parties" then proceed?

#Indicator

Comment (English)

131

4.2.2

132

4.2.2

133

4.2.2

134

4.2.2

135

4.2.2

"The Unit of Certification must also prove that all the information communicated has been understood by the local population, in theirnative language, following the FPIC process.""The Unit of Certification must also prove that all the information communicated has been understood by the local population, in theirnative language, following the FPIC process."[Accra WS] 4.2.2 a)The issue with 'history' - how to get the history of land tenure? It is not possible to get a list of historical land tenureas they may not available.
"a) History of land tenure may not be always be availableb) legal ownership or lease should already dealt under 2.1.3 ""How should we define Vulnerable Groups and any example for this group of people?

136

4.2.2

137

4.2.2

138

4.2.2

139

4.2.2

To elaborate more on the Vulnerable Group. ""Suggest to correct the wording ' provide the following documents: a) History of land tenure;' to 'a) Information on land tenure' [4.2.2
deals with the units of certification (UoC) conducting land tenure and user assessments through engagement with identified affectedgroups and then requires the UoC to provide 3 documents. And if we look at the documents that have been listed there, the first one is
the history of the land tenure, the second one is the legal ownership or lease and then the third one is authorization to use the land.
But on the history of the land tenure, you don't necessarily have documents that will show the history of the land tenure. Usuallyduring the study of land tenure the process is described in the report i.e. information on land tenure rather than the history of land
tenure].
""4.2.2 a and 4.2.2.b should be moved up to 4.2.1, as these are about the evidence collected through Land tenure and Use study thatallows to identify which are the affected communities.
But it is missing a third point to cover the required evidence of customaryusers which could be covered by the text currently presented for the indicator 4.2.3)
Indicator 4.2.2 should instead focus on the evidence of autorisation to use the land by the right holders. Something like:
4.2.2. The Unit of Certification has documented authorisation to use the land, received from the legal or customary owners or users,
and/or their freely self-chosen representatives. "The Unit of Certification must also prove that all the information communicated has been understood by the local population, in theirnative language, following the FPIC process.
[Accra WS] 4,2,2 C) it may not be available e.g. land leased from state.

#Indicator

Comment (English)

140

4.2.2

141

4.2.2

142

4.2.2

143

4.2.2

144

4.2.2

145

4.2.2

146

4.2.2

147

4.2.2

148

4.2.2

149

4.2.2

150

4.2.2

The Unit of Certification must also prove that all the information communicated has been understood by the local population, in theirnative language, following the FPIC process.
Anything to do affected parties in existing operations, let SEIA in P3 take care of it and do not mix up with FPIC for new plantings/new
developments as per 4.1.1. SEIA would suffice if there is any conflicts/grievance from affected parties. This entire principles are in amess after revamp. All in all, remain FPIC concept in P&C 2018 and revert back to the original text for P4 in P&C 2018.
For indicators 4.2.2 can be combined with indicators 4.1.2 because the fulfillment is the same (both implementation anddocumentation)
Proposed: Indicator 4.2.2 is combined with indicators 4.1.2 because the fulfillment is the same (both implementation anddocumentation). So that there will be repetition.
Proposed: Indicator 4.2.2 is combined with indicators 4.1.2 because the fulfillment is the same (both implementation anddocumentation). So that there will be repetition.
"Proposal:
Indicator 4.2.2 is combined with indicators 4.1.2 because the fulfillment is the same (both implementation and documentation). So
that there will be repetition.
"
Proposed: preferably indicators 4.2.2 combined with indicators 4.1.2 because the substance and fulfillment are the same (bothimplementation and documentation)"4.2.2: It is necessary to clarify that the ""C"" point regarding the permit to utilize the land from the previous owner of the owner anduser of the previous customary land, or representatives chosen by the law or customary owner only applies to new plantations / newland.
The consideration is not to practice asking permission / approval for an established / existing area, where land owners or customs thathave received compensation from the company have given permission to use their land, so this is irrelevant if done for existing
plantations .""Proposal:
Indicator 4.2.2 is combined with indicators 4.1.2 because the fulfillment is the same (both implementation and documentation)""
Proposal:
Combining indicators 4.2.2 with indicators 4.1.2 because the fulfillment of both implementation and documentation is similar.
"
Indicator 4.2.2 is put forward to: combined with indicators 4.1.2 because the fulfillment is the same (both implementation anddocumentation).

#Indicator

Comment (English)

151

4.2.2

152

4.2.2

153

4.2.2

154

4.2.2

155

4.2.2

156

4.2.2

Indicator 4.2.2 is put forward to: combined with indicators 4.1.2 because the fulfillment is the same (both implementation anddocumentation).
"[I] 4.2.2
Indicator 4.2.2 combined with indicators 4.1.2 Because the fulfillment is the same (both implementing and documentation), theindicator has the same substance and fulfillment""Proposed changes:
Indicator 4.2.2 is combined with indicators 4.1.2 because the fulfillment is the same (both implementation and documentation)"
For 4.2.2 translation of terms affected to impacted is suggested. It must be explicit that: the documents related to the CLPI, including
maps and compensation procedure, only apply if there is any pending genuine dispute over some land in existing ones.
4.2.2 For new plantations, the certification unit will show the possession and use of the land, through dialogue with the identified
communities and applicable legal requirements.
"Term translation of affected parties to impacted parts is suggested.

157

4.2.3

158
159
160
161

4.2.3
4.2.3
4.2.3
4.2.3

162
163

4.2.3
4.2.3

164

4.2.3

It is suggested that the scope based on official listings or groups that demonstrate legitimate interest and that is supported in themethodology established by the UDC be delimited to identify these parties."
4.2.3 If the affected parties have no legal tenure and only historical occupation without legal documentation, how would the FPIC
process proceed?
Photos and satellite images can also be supplied - to make documents more comprehensible to all stakeholders.
"Photos and satellite images can also be supplied - to make documents more comprehensible to all stakeholders.""Photos and satellite images can also be supplied - to make documents more comprehensible to all stakeholders."" no necessity to follow the scale stated where it might distort or limit the UoC aerial view since there is a different ha of UoC.
Suggested the scale “(1:5000 or 1:10000)” to be removed. "[Sandakan, 21 June 2023] Participatory mapping would be sensitive to some Affected Communities.
"Indicator 4.2.3: Determination of map scale 1: 5000 or 1: 10000 needs to be given an explanation for the reasons for the selection of
the scale.
It is recommended that this scale is only included in the guide for indicators 4.2.3"
In indicators 4.2.3 the sentence should be returned as indicators 4.4.3 in 2018, namely "a map with a scale that should be" becausesome locations or regions require a more detailed scale for clarity.

#Indicator

Comment (English)

165

4.2.3

166

4.2.3

167

4.2.3

168

4.2.3

"Indicator 4.2.3 Proposed:
The sentence proposal is returned to the indicator 4.4.3 of 2018, ""Map with a scale should""""[I] 4.2.3
The sentence proposal is returned to the indicator 4.4.3 in 2018, ""Map with a scale should"". The map scale should be adjusted sothat the map can be used"
The need for sentence changes in indicators 4.2.3: The sentence proposal is returned to the indicator 4.4.3 in 2018, "Map with a scale
should""Proposal 4.2.3:
Proposed sentences related to the map scale are returned to the indicator 4.4.3 in 2018, namely ""maps with a scale that should be""

169

4.2.3

170
171

4.2.3
4.2.3

172

4.2.3

173
174
175
176

4.2.3
4.2.3
4.2.3
4.2.3

"
Proposed 4.2.3: Proposed sentences related to the scale of the map are returned to the indicator 4.4.3 in 2018 namely "Map with ascale should"
Indicator 4.2.3 (c) Proposed to: The sentence is returned to the indicator 4.4.3 in 2018 namely "map with a scale should".
"Comment:
The sentence proposal is returned to the indicator 4.4.3 of 2018, ""Map with a scale should""
Proposed improvement:
4.2.3 (c) Maps with a proper scale, which indicates the extent to which legal rights, customary rights, or other recognized land use
rights, must be available and arranged through participatory mapping with affected communities (including vulnerable groups,
communities in adjacent areas , and the authorities).
""Proposed indicator 4.2.3
The sentence proposal is returned to the indicator 4.4.3 of 2018, ""Map with a scale should"""
The sentence proposal is returned to the indicator 4.4.3 of 2018, "Map with a scale should"
The indicator sentence is returned to the indicator 4.4.3 in 2018, "Map with a scale that should be"
Proposed Indicator 4.2.3 The sentence proposal is returned to the indicator 4.4.3 in 2018 namely "Map with a scale should"
Check the definition of the term "vulnerable groups", is broad and a methodology has not been included to identify them.

#

Indicator

Comment (English)

177

4.2.3

"4.2.3 (c) Maps will be prepared and made available adequate scale (1: 5000 or 1: 10000) that show the Extension of recognized land
use rights of legal, customary or other type.}

178
179

4.2.3
4.2.3

180

4.2.3

181

4.2.3

182

4.2.4

183

4.2.4

184
185

4.2.4
4.2.4

When there is conflict, a participatory mapping will be made that involves the affected communities and relevant authorities, if
applied."This evaluation should be carried out only when there are conflicts, as part of the resolution this evaluation must be carried out.
Term translation of affected parties to impacted parts is suggested. It is suggested that the scope based on official listings or groups
that demonstrate legitimate interest and that is supported in the methodology established by the UDC be delimited to identify theseparties.
Participatory mapping should be limited to involving only the group, community or directly impacted authority that has beenpreviously selected with the methodology defined by the UDC
It is suggested that the scope based on official listings or groups that demonstrate legitimate interest and that is supported in themethodology established by the UDC be delimited to identify these parties.
4.2.4 This indicator has never been effectively tested. It attempts to secure food and water resources for the 'affected community
through the SEIA process and land use planning. In addition, to this, there is also the land allocation process. This is a long-drawn,complex indicator and it is not auditable. What is the objective evidence required to seek conformance? The art of standard
development and indicator framing is lost in this document. The logical flow is missing.
4.2.4 (c) As part of the CLPI, food supply and water supply options will be considered, in order to locally guarantee food safety andwater resource.
For 4.2.4 according to the objection of the producers. It is suggested to change the term affected by directly impacted.
"Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the impact(positive or negative) because it diverts the term used and in the principle 4 that in some cases is spoken of affected as affected as
Negative is not coincident.
"#

Indicator

Comment (English)

186

4.2.4

"Incomplete indicator in translation, although we suggest that the concept of impacted communities is addressed instead of affected
communities. The term ""affected"" in Spanish according to the SAR defines it
Of the part. to affect.
1. adj. That suffers from affectation. Speaker, affected style.
2. adj. Aquejo, disturbed.

187

4.2.4

While the term ""impacted"" or ""linked"" to refer to those communities that are within the area of influence of the operation of thecrop or extractor plant.""It is suggested to change the term affected by directly impacted.
According to the objection of the producers:

188

4.2.5

189

4.2.5

190
191
192
193
194

4.2.5
4.2.5
4.2.5
4.2.5
4.2.5

195
196

4.2.5
4.2.5

197

4.2.5

Objection of the producers accepted: eliminate this indicator, since it is covered by criteria 3.4."
4.2.5 Packing 4 previous indicators into 1 defies logic, how is this auditable? There should be a separate report detailing theserequirements for the auditor to assess.
The RSPO must support growers and mills in understanding the FPIC process and its implementation in order to increase efficiency inthe field and mitigate the future risk of grievances.
A taskforce should be set up to jointly define the objective, quantifiable and/or qualifiable criteria to be audited eventually.
A taskforce should be set up to jointly define the objective, quantifiable and/or qualifiable criteria to be audited eventually.
line break
A taskforce should be set up to jointly define the objective, quantifiable and/or qualifiable criteria to be audited eventually.
"A taskforce should be set up to jointly define the objective, quantifiable and/or qualifiable criteria to be audited eventually.
"
remove "in a form and language understood by affected communities (...)" it is already stated at the end ot the indicator.
The RSPO must support growers and mills in understanding the FPIC process and its implementation in order to increase efficiency inthe field and mitigate the future risk of grievances.
[Sandakan, 21 June 2023] FPIC should be law-abiding, subjected to the rules of national regulation.

#Indicator

Comment (English)

198

4.2.5

199

4.2.5

200

4.2.5

201

4.2.5

202

4.2.5

"Indicator 4.2.5
The contents of this indicator are very detailed in explaining the requirements. This indicator should only mention the need for KBDD
as a requirement for new planting. The contents of the KBDD documentation include the agreed agreement that will automaticallyadjust to the RSPO KBDD guide, plus adjustments that will see cases after case of the KBDD process. Even if you want to write down indetail the expected content of a KBDD results document, it is enough to be described in the guide section of the indicator 4.2.5""Proposed changes:
4.2.5 The KBDD process carried out must include documented evidence as follows:a) Important Information - All important information related to the proposed development must be available and explained in theform and language understood by the affected community (including vulnerable groups). This includes information related to theimpact assessment, the distribution of proposed benefits, and legal agreements.
b) Independent Access to Information - The existence of evidence that the affected community and the right holder have an option toaccess information and suggestions related to the consequences of the legal, economic, environmental, and social implications of the
proposed operations on their land, and the evidence is not influenced by the project initiator.
c) Consultation and Negotiations Joint - A process must be mutually agreed upon through consultation and negotiations carried out ingood faith with affected communities in indicators 4.2.1 to achieve decisions related to the proposed development. Various steps aretaken to involve and consult with vulnerable groups. People who were directly affected were given information about their rights toreject the development during the KBDD process.
d) Approval - negotiations must be carried out without coercion and voluntarily, as well as considering the form of consultation andapproval according to custom as the user's request or rights holder. There is evidence that the certification unit respects the affected
community's decision to give or suspend its agreement to the operation when the decision was taken.
e) Implications of approval - Communities that are directly affected must be given an explanation by the Certification Unit related tothe implications of the development licensing, and the legal status of land when the right to use, concession, or lease the land unit isexpired. All communication must be carried out in the form and language understood by people who are directly affected (includinggroups that are vulnerable and cannot read and write).
"
4.2.5: The word "repeated" is deleted. It takes a clear definition because if the MoU and the garden have been built, then it is notpossible for the KBDD process to be repeated.
For 4.2.5 according to objection but it is suggested to expand to having clear mechanisms to demonstrate the legitimate interest ofparticipation in CLPI procedures.
4.2.5 According to the objection but it is suggested to expand to having clear mechanisms to demonstrate the legitimate interest ofparticipation in CLPI procedures.

#Indicator

Comment (English)

203

4.2.5

204
205

4.2.5
4.2.6

206
207
208

4.2.6
4.2.6
4.2.6

209

4.2.6

210
211

4.2.6
4.2.6

"4.2.5 The CLPI process will include documented evidence of:a) Key information: Information related to decision making on the proposed development (impact evaluations and proposed
agreements).
b) Remove this itemc) Mutual consultation and negotiation: Mutually agreed
and in good faith a process of consultation and negotiation with theidentified communities. The directly affected communities will be informed about their right to say ‘no’ to development throughout
the CLPI process.
d) Consent: negotiations will happen without
coercion and voluntarily and will take into account thecustomary forms of consultation and consent if
They request users or rights holders. Exists
evidence that the UDC has respected the decisions of the affected communities of giving or denying their consent to operations at thetime these decisions were made.
e) Implications of the Agreement: When applying, the UDC will explain to the communities directly affected the implications ofallowing the development and legal status of the lands when the title, concession or lease of the UDC takes. All communications will
be made in a form and language that they understand by those involved."[Abidjan WS] 4.2.5 b - it is not the responsibility of the UoC - no action is needed - need to make clear.
The RSPO must take into account and even make available the means to defend local populations affected by a case of grievance at alower cost.
The latter do not always have the financial or human resources to represent their interests themselves.
The latter do not always have the financial or human resources to represent their interests themselves.
"4.2.6. The RSPO must take into account and even make available the means to defend local populations affected by a case ofgrievance at a lower cost.
The latter do not always have the financial or human resources to represent their interests themselves."
The RSPO must take into account and even make available the means to defend local populations affected by a case of grievance at alower cost. The latter do not always have the financial or human resources to represent their interests themselves.
[Accra WS] 4.2.6 How to audit 'option of resourced access'? What is the responsibility of UoC and how much is consider enough?
4.2.6.Quite that the company must provide legal advice or aid, because it becomes a conflict of interest.

#

Indicator

Comment (English)

212

4.2.6

"4.2.6 There will be evidence available to demonstrate that directly affected communities are represented by institutions or
representatives chosen by them same.

213
214

4.2.6
4.2.6

---It is not objective that the UDC must pay for some legal process. The maximum that can be done is to inform (guide) about institutions
that can support the affected people or communities."
Incomplete indicator in translation"Cutted text appears but having Excel could see complete.

215
216

4.2.6
4.2.6

217

4.2.6

218
219
220

4.2.6
4.2.6
4.2.6

221
222
223
224
225
226
227

4.2.7
4.2.7
4.2.7
4.2.7
4.2.7
4.2.7
4.2.7

I suggest: facilitate access to the roadmap of the parts in which they can be supported to be represented without having the UDEC
who assumes the costs of that representation."
Incomplete indicator in translation
According to the objection but it is suggested to expand to having clear mechanisms to demonstrate the legitimate interest ofparticipation in CLPI procedures.
In order to prevent the indicator from being used for other purposes, the company cannot be responsible for legal or technical advice,rather the company may facilitate access to the roadmap of the parties in which they can be supported to be represented without
being the UdeC who assumes the costs of that representation.
4.2.6. Companies should not provide legal advice or aid, because it becomes a conflict of interest.
It is suggested to change the term affected by impacted
4.2.6 Remove from the writing the option of resources to access legal advisors, this goes against the principle of impartiality at thetime of these disputes.
4.2.7 The essence of indicator 4.4.2 (2018 P&C) is lost.
4.2.7.Nor do they always have access to clear information on their rights and their means of action.
Nor do they always have access to clear information on their rights and their means of action.
Nor do they always have access to clear information on their rights and their means of action.
Nor do they always have access to clear information on their rights and their means of action.
not applicable to existing plantations"The text of the indicator is cut, so Excel was requested.

4.2.8

It is suggested to change the term affected by impacted"
4.2.8 Too many requirements in an indicator. Not auditable.

228

#

Indicator

Comment (English)

229
230
231
232
233
234

4.2.8
4.2.8
4.2.8
4.2.8
4.2.8
4.2.8

235

4.2.8

236
237

4.2.8
4.2.8

238

4.2.8

239

4.2.8

access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities"access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities""negociated FPIC agreement"
4.2.8. access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities
access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities"In indicator 4.2.8 there are several proposals, namely:- In point a the word ""and"" changed to ""or""- In point a the word ""representative"" added ""representative of landowners""- At the point F sentence ""re-negotiations, renewal and termination"" should be examined and confirmed in accordance withapplicable regulations and laws""Proposed indicator 4.2.8:- The word ""and"" in point A should be changed to ""or""- The word ""representative"" in point A is clarified as ""Representative of the Land Owner""- The sentence ""re-negotiating, renewing and terminating"" in point F needs to be ascertained in accordance with applicableregulations and laws"a) changed to "party or representative ....." because not all landowners appoint their representatives"Proposed improvement 4.2.8:- The word ""and"" in point A should be changed to ""or""- The word ""representative"" in point A was added to ""Representative of the Land Owner""- The sentence ""re -negotiating, renewing and terminating"" in point F is added in accordance with applicable national regulations andlaws""4.2.8: the word ""and"" changed to ""or"" because not all
The landowner appoints his representative, and if any
representatives, communication is carried out throughthe representative, and if there are no representatives
then communication is carried out directly to the ownerland."
Proposed Indicator 4.2.8: - The word "and" in point A should be changed to "or" - the word "representative" in point A is clarified to"representative of landowners" in accordance with applicable regulations and laws#

Indicator

Comment (English)

240

4.2.8

241

4.2.8

242

4.2.8

243

4.2.8

Comments: - The word "and" in points A should be changed to "or" - the word "representative" in point A is clarified to "representativeof the landowner" - the phrase "re -negotiating, renewal and stopping" in point F needs to be observed and confirmed there is a basis/references include in accordance with the applicable regulations and legislation proposed changes: 4.2.8 Agreement on the results ofnegotiations includes: a) the party or representative of the landowner from the agreement; b) duration or duration of development
and other implications of the agreement; c) compensation and benefits; d) the mechanism for handling complaints and complaints; e)conflict resolution mechanism; and f) Provisions for monitoring agreements in accordance with applicable national law.
"[I] 4.2.8- The word ""and"" in point A should be changed to ""or""- The word ""representative"" in point A is clarified as ""Representative of the Land Owner""- The sentence ""re-negotiating, renewing and terminating"" in point F needs to be examined and confirmed in accordance withapplicable regulations and regulations""4.2.8: The sentence ""re -negotiating, renewal andtermination ""added"" in accordance with regulations andcurrent regulation""""Indicator 4.2.8 is proposed to:

244

4.2.8

245

4.2.8

1. The word ""and"" in point A should be changed to ""or"".
2. The word ""representative"" in point A is clarified as ""representative of landowners"".
3. The sentence ""re-negotiating, renewing and terminating"" in point F needs to be examined and confirmed in accordance withapplicable regulations and regulations."
4.2.8: the word "and" changed to "or" because not all landowners appoint their representatives, and if there are representatives,
communication is carried out through these representatives, and if there are no representatives, communication is carried out directly
to the landowners.
Proposed improvement 4.2.8: (a). The word "and" in point A should be changed to "or", (B). The word "representative" in point A wasadded to "representative of landowners", (c). The sentence "re -negotiating, renewing and terminating" in point F is added inaccordance with applicable national regulations and laws#

Indicator

Comment (English)

246

4.2.8

"Comment:- The word ""and"" in point A should be changed to ""or""- The word ""representative"" in point A is clarified as ""Representative of the Land Owner""- The sentence ""re-negotiating, renewing and terminating"" in point F needs to be observed and confirmed there is a basis/reference
including in accordance with applicable regulations and regulations

247

4.2.8

248
249

4.2.8
4.2.8

250
251

4.2.8
4.2.8

Proposed changes:
4.2.8 Agreement on the results of negotiations includes:a) Party or representative of landowners from the agreement;b) duration or duration of development and other implications of the agreement;c) compensation and benefits;d) the mechanism for handling complaints and complaints;e) conflict resolution mechanism; Andf) Provisions for monitoring agreements in accordance with applicable national law.
"
"Indicator 4.2.8 Proposed:- The word ""and"" in point A should be changed to ""or""- The word ""representative"" in point A is clarified as ""Representative of the Land Owner""- The sentence ""re-negotiating, renewing and terminating"" in point F needs to be examined and confirmed in accordance withapplicable regulations and regulations"
4.2.8: The sentence "re-negotiating, renewal and termination" added "in accordance with applicable regulations and laws".
"- The word ""and"" in point A should be changed to ""or""- The word ""representative"" in point A is clarified as ""Representative of the Land Owner""- The sentence ""re-negotiating, renewing and terminating"" in point F needs to be examined and confirmed in accordance withapplicable regulations and regulations"Compensation refers to "compensation"
Define "compensation"

#Indicator

Comment (English)

252

4.2.8

253
254
255
256
257
258
259
260
261
262

4.2.8
4.2.8
4.2.8
4.2.9
4.2.9
4.2.9
4.2.9
4.2.9
4.2.9
4.2.9

263

4.2.9

264

4.2.9

"4.2.8 If there is a negotiated agreement, it will include:a) Parties and representatives in the agreement;b) Development duration and any other aspect that
imply the agreement;c) Type of negotiation (compensation or agreement)d) claims and complaint mechanism;e) Conflict resolution mechanism, andf) Provisions for monitoring, renegotiation,
renewal and termination of compliance with legislation
applicable national"
Eliminate this indicator, since it is covered by criterion 3.4.
Compensation refers to "compensation"?
Delete indicator, it is already covered.
4.2.9 The negotiated agreement should be signed by the legal representative of the UoC.
access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities"negociated FPIC agreement"
4.2.9. access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities"access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities"
access to a legal representative - free or at a reduced cost - would be the first thing to be offered to local communities"In indicator 4.2.9- The word ""and/or"" just use the word ""or""- ""Representative Institution"" was changed to ""Representative of Land Owners""""Indicator 4.2.9 Proposed:- The sentence ""and"" eliminated, just use the word ""or""- ""Representative Institution"" was changed to ""Representative of Land Owners"""
4.2.9: The word "and" replaced with "or" "because not all landowners appoint their representatives, and if there are representatives,
communication is carried out through these representatives, and if there are no representatives, communication is carried out directly
to the landowner.

#

Indicator

Comment (English)

265

4.2.9

"Proposed improvement 4.2.9

266

4.2.9

267
268

4.2.9
4.2.9

269

4.2.9

270

4.2.9

271
272

4.2.9
4.2.9

273

4.2.9

274

4.2.9

275

4.2.9

' - The sentence ""and"" eliminated, only using the word ""or"" - ""Representative Institution"" was changed to ""Representative ofLand Owners""""[I] 4.2.9
The sentence ""and"" eliminated, just use the word ""or"" ""representative institution"" was changed to ""representative oflandowners"""
4.2.9: Definition added that the "representative institution" in question is a representative institution from the landowner.
"'Comment:- The word ""and"" eliminated, just use the word ""or""- ""Representative Institution"" was changed to ""Representative of Land Owners""
Proposed changes:
4.2.9 Agreement on the results of negotiations must be signed by the Certification Unit, directly affected communities orrepresentatives of landowners. A copy must be given to all parties who signed an agreement,
In the form and language understood by all parties in the agreement.""4.2.9: the words ""and"" replaced with ""or"" ""because it is not all landowners appoint their representatives, and if any
representatives, communication is carried out through the representative, and if there are no representatives then communication iscarried out directly to the owner land.""Proposed indicator 4.2.9:'- The sentence ""and"" eliminated, just use the word ""or""- ""Representative Institution"" was changed to ""Representative of Land Owners""""4.2.9: Definition is added that ""Representative Institution"" What is meant is a representative institution from the owner land."Indicator 4.2.9 is proposed in order to: 1. the word "and" eliminated, just use the word "or". 2. The word "representative institution"
was changed to "representative of landowners".
Indicator 4.2.9 is proposed in order to: (a). The word "and" eliminated, just use the word "or". (b). The word "representative
institution" was changed to "representative of landowners".
"'- The sentence ""and"" eliminated, just use the word ""or""- ""Representative Institution"" was changed to ""Representative of Land Owners""""Indicator 4.2.9 is proposed to:
1. The word ""and"" eliminated, just use the word ""or"".
2. The word ""representative institution"" was changed to ""representative of landowners""."#

Indicator

Comment (English)

276

4.2.9

277
278
279

4.2.9
4.2.104.2.10280

4.2.10Keep in mind that the Spanish translation of the affected term, in Spanish has a negative connotation, we suggest using the impact(positive or negative) because it diverts the term used and in the principle 4 that in some cases is spoken of affected as affected as
Negative is not coincident.
"Impacted" or "linked" communities instead of "affected"
4.2.10 This should be a critical indicator.
"Examples of corrective measures are already to be presented by the RSPO.
The same applies to fines or penalties - or even suspension of certification - in the event of wilful non-compliance by a stakeholder.
To avoid any suspicion, the RSPO should help all growers and mills to familiarize themselves with the FPIC processes and assist themwith their operational implementation.
By communicating a global framework that can be plugged into different geographical areas and types of players""4.2.10. Examples of corrective measures are already to be presented by the RSPO.
The same applies to fines or penalties - or even suspension of certification - in the event of wilful non-compliance by a stakeholder.
To avoid any suspicion, the RSPO should help all growers and mills to familiarize themselves with the FPIC processes and assist themwith their operational implementation.
By communicating a global framework that can be plugged into different geographical areas and types of players

281

4.2.10282

4.2.10283

4.2.10""Examples of corrective measures are already to be presented by the RSPO.
The same applies to fines or penalties - or even suspension of certification - in the event of wilful non-compliance by a stakeholder.
To avoid any suspicion, the RSPO should help all growers and mills to familiarize themselves with the FPIC processes and assist themwith their operational implementation.
By communicating a global framework that can be plugged into different geographical areas and types of players"
Examples of corrective measures are already to be presented by the RSPO. The same applies to fines or penalties - or even suspensionof certification - in the event of wilful non-compliance by a stakeholder. To avoid any suspicion, the RSPO should help all growers andmills to familiarize themselves with the FPIC processes and assist them with their operational implementation. By communicating a
global framework that can be plugged into different geographical areas and types of players"In indicator 4.2.10
1. Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement
2. The KBDD review process is carried out until the agreed time."#

Indicator

Comment (English)284

4.2.10"Indicator 4.2.10 Proposed:
1. Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement285

4.2.10286

4.2.10287

4.2.10288

4.2.10289

4.2.10290

4.2.102. The KBDD review process is carried out until the agreed time.""Proposed indicator 4.2.10
Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement
2. The KBDD review process is carried out until the agreed time."
Proposed, preferably on indicators 4.2.10: 1. Added Annual Review Guide should only include: a. Implementation of the initialagreement points for the approval of plantation development b. The period of fulfilling the initial agreement 2. The KBDD review
process is carried out until the mutual agreed time.
"Proposal 4.2.10:
1. Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement
2. The KBDD review process is carried out until the agreed time.""4.2.10: added the phrase ""up to the process
Garden development ends ""because of the review process
Every year there must be an end time."
Comments: 1. Add Annual Review Guide should only include: a. Implementation of the initial agreement points for the approval ofplantation development b. The period of fulfilling the initial agreement 2. The KBDD review process is carried out until the mutual
agreed time.
The sentence is changed to "....... up to the garden development process ends" because the review process every year must have an
end.

#

Indicator

Comment (English)291

4.2.10"1. Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement292

4.2.10293

4.2.10294

4.2.10295

4.2.10

296
297
298

4.2.104.2.104.2.11299

4.2.11300
301

4.2.114.2.11

2. The KBDD review process is carried out until the agreed time."
Proposal 4.2.10: (1). Added Annual Review Guide should only include: a. Implementation of the initial agreement points for theapproval of plantation development b. The period of fulfilling the initial agreement. (2). The KBDD review process is carried out until
the agreed time.
"[I] 4.2.10
1. Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement
2. The KBDD review process is carried out until the agreed time."
Indicator 4.2.10 is proposed in order to: 1. Added Annual Review Guide should only include: a. Implementation of the initial agreement
points for the approval of plantation development b. The period of fulfilling the initial agreement 2. The KBDD review process is carriedout until the mutual agreed time.
"Comment:
1. Add an annual review guide should only include:
a. Implementation of Points Preliminary Agreement Agreement on Plantation Development
b. The period of fulfilling the initial agreement
2. The KBDD review process is carried out until the agreed time."
4.2.10: The phrase added "until the garden development process ends" because the review process every year must be ended.
Incomplete indicator in translation"not clear at all. Indicators are applicable no need to specify it...
except 4.2.7 which is not applicable to existing plantations"4.2.11 This is a retrospective FPIC requirement that predates the establishment of RSPO. This is unacceptable, irrespective of whatcertain parties think. There is always a cut-off line otherwise the indicator will become non-sensical.
How is an FPIC done retroactively? How relevant would that be?
[Accra WS] 4.2.11 - removed. Not practical to do retrospective FPIC - area is cleared. This should be dealt under SEIA - where newcommunity identify and management needed.

#Indicator

Comment (English)

302

4.2.11303

4.2.11304

4.2.11

Please review this new indicator 4.2.11 and correct the mistake as there is no indicators 4.6.2-4.6.6. ["Indicators 4.5.1 to 4.5.4 and4.6.1- 4.6.6 shall apply where relevant.". There is a mistake here only 4.6.1 exists, there is no 4.6.2 - 4.6.6. What indicators are youreferring here?]
Sustained objection. Anything to do affected parties in existing operations, let SEIA in P3 take care of it and do not mix up with FPIC for
new plantings/new developments as per 4.1.1. SEIA would suffice if there is any conflicts/grievance from affected parties. This entire
principles are in a mess after revamp. All in all, remain FPIC concept in P&C 2018 and revert back to the original text for P4 in P&C
2018.
"[HRSS] There is a gap in this indicator - it only addresses the applicability of FPIC to existing operations set up before 2005. There is aneed to incorporate an indicator on the applicability of FPIC to a UoC's existing operations which was set up after 2005 as thepreceding Indicator 4.1.1 also do not address this and only touches on new plantings and developments.

305
306

4.2.114.2.11

The references to Indicators on FPIC processes have been stated incrorrectly. The FPIC processes are set out in Indicators 4.2.1 to
4.2.10 and 4.2.12. The current text has missed out the applicable Indicators 4.2.8 to 4.2.10 and 4.2.12 (negotiations, review of FPIC
agreement and compensation for dispossessed communities). It is important to include them as they are part of the FPIC processes.
Similarly, Indicators 4.3.1 to 4.3.4 (compensation) and 4.4.1 to 4.4.5 (conflict resolution) are also excluded.
Indicators 4.6.2 to 4.6.6 do not exist in Draft 2.
Therefore, the 2nd sentence should read ""....the FPIC processes set out in Indicators 4.2.1 to 4.2.10 and 4.2.12 shall apply. Indicators
4.3.1 to 4.3.4 and 4.4.1 to 4.4.5 shall apply where relevant."""4.2.11 What do you mean by "where relevant"? Who determines the relevancy in this matter?
"[HRWG] Recommendation: A compensation process or procedure may be more appropriate for cases where Communities are foundon existing plantations. Align this with the RaCP process for HCV. In the RaCP, there are different dates between 2005 and now. It
establishes the consequences of a clearance (including compensation) based on when a clearance of a HCV area was conducted. We
need to look at when FPIC was first introduced (i.e. after 2005) and determine the consequences based on when a clearing without
FPIC happened.
Retrospective application of FPIC may cause legal uncertainty and therefore access to compensation processes may be the best way
forward. For compensation, the start date should not pre-date when FPIC was first introduced to RSPO i.e. from 2005.
"

#Indicator

Comment (English)

307

4.2.11308

4.2.11309

4.2.11310

4.2.11"In this 4.2.11 indicator - it is proposed to be deleted, because the KBDD only applies to the new planting, following the 2015 guide
2. Historical FPIC has been arranged as follows:- FPIC has emerged in 2005, but there is no guide- In 2008, RSPO asked FPP to compile guidelines, but has not been approved by RSPO- Approved Guide in 2015"
4.2.11 This indicator should be removed because it is not consistent with indicator 4.2.1 where affected people need to be considered
if there are new planting plans or new development in existing operational areas. So for operations that have been running, things
about FPIC are not needed.
4.2.11: The indicator is deleted, because KBDD only applies to new planting with a cut-off date implementation of FPIC according to
the 2015 FPIC RSPO guide.
"Proposal:
1. Proposed indicator 4.2.11 is deleted, because the KBDD UK is irrelevant, KBDD should only be for gardens for new planting,following the 2015 FPIC guide
2. It is specifically determined by the KBDD only applies to gardens planted after November 2015 after the issuance of the November
2015 FPIC Revision Guide

311

4.2.11312

4.2.11313

4.2.11""Proposed indicator 4.2.11
Indicator was deleted because KBDD only applies to new plants, following the 2015 guidelines."
Proposal: This indicator is proposed to be deleted, because the KBDD guide is more relevant for the new planting (after the FPIC guide
published), following the 2015 guide *Historical FPIC - FPIC has appeared in 2005, but there has been no guide - in 2008, RSPO asked
FPP to compile Guide, but not yet approved RSPO - Approved Guide in 2015"[I] 4.2.11
Proposal
1. The proposal of this indicator to be deleted, because the KBDD only applies to the new planting, following the 2015 guide
2. Historical FPIC has been arranged as follows:- FPIC has emerged in 2005, but there is no guide- In 2008, RSPO asked FPP to compile guidelines, but has not been approved by RSPO- Approved Guide in 2015"

#

Indicator

Comment (English)314

4.2.11315

4.2.11316

4.2.11"Indicator 4.2.11 Proposed:
1. The proposal of this indicator to be deleted, because the KBDD only applies to the new planting, following the 2015 guide
2. Historical FPIC has been arranged as follows:- FPIC has emerged in 2005, but there is no guide- In 2008, RSPO asked FPP to compile guidelines, but has not been approved by RSPO- Approved Guide in 2015""4.2.11: The indicator is deleted, because KBDD only applies to
New Planting With Cut-off Date Implementation of FPIC
according to the 2015 FPIC RSPO guide.
*Historical FPIC• FPIC has emerged in 2005, but not yet
guide• In 2008, RSPO asked FPP to compile
guide.
• In 2015, the RSPO was on the FPIC guidebased on the results of public consultation and compiled
by involving the Multi-Stakeholder Forum.""This indicator is proposed to be deleted, because the KBDD only applies to the new planting, following the 2015 guide*Historical FPIC- FPIC has emerged in 2005, but there is no guide- In 2008, RSPO asked FPP to compile guidelines, but has not been approved by RSPO- Approved Guide in 2015"

#

Indicator

Comment (English)317

4.2.11"Proposal:
This indicator is proposed to be deleted, because the KBDD guide is more relevant for new planting (after the FPIC guide published),
following the 2015 guide318

4.2.11319

4.2.11320

4.2.11321
322

4.2.114.2.11323

4.2.12324
325

4.2.124.2.12*Historical FPIC- FPIC has emerged in 2005, but there is no guide- In 2008, RSPO asked FPP to compile guidelines, but has not been approved by RSPO- Approved Guide in 2015"
Proposed: (1). Indicator 4.2.11 was proposed to be deleted, because the KBDD UK Old Garden Garden was irrelevant, KBDD should
only be for new gardens for new handling, following the 2015 FPIC guidelines. (2). Revision Guide November 2015"1.) This indicator to be deleted, because the KBDD only applies to the new planting, following the 2015 guide;2.) Historical FPIC has been regulated as follows: FPIC has appeared in 2005, but there has been no guide.
- In 2008, RSPO asked FPP to compile guidelines, but has not been approved by RSPO.
- Approved Guide in 2015.""Indicator 4.2.11 is proposed to:
1. This indicator is deleted, because the KBDD only applies to the new planting, following the 2015 guide.
2. Historical FPIC has been arranged as follows:- FPIC has emerged in 2005, but there has been no guide.
- In 2008, RSPO asked FPP to compile guidance, but has not been approved by RSPO.
- Approved Guide in 2015."
4.2.11 What is the point of doing CLPI of established plantations before 2005?
[Abidjan WS] 4.2.11 should be removed - retrospective FPIC is not possible. This is not implementable. Any new community identified
will be captured by SEIA assessment, under Criteria 3.4.
"Communication of a clear timeline for handling identified grievances,
This framework must be communicated and adhered to by all players, on pain of sanctions or even suspension.
A scale of damages must also be published - after a multi-stakeholder taskforce has been set up to define them.
"
4.2.12 Again this is difficult to audit. What is meant by "time-bound manner"?
"Communication of a clear timeline for handling identified grievancesThis framework must be communicated and adhered to by all players, on pain of sanctions or even suspension.
A scale of damages must also be published - after a multi-stakeholder taskforce has been set up to define them."#Indicator

Comment (English)

326

4.2.12327

4.2.12

328
329
330
331

4.2.124.2.124.2.124.2.12332

4.2.12333

4.2.12

334
335
336

4.2.124.2.124.2.12337

4.2.12"4.2.12. Communication of a clear timeline for handling identified grievances. This framework must be communicated and adhered toby all players, on pain of sanctions or even suspension.
A scale of damages must also be published - after a multi-stakeholder taskforce has been set up to define them."
Communication of a clear timeline for handling identified grievances This framework must be communicated and adhered to by all
players, on pain of sanctions or even suspension. A scale of damages must also be published - after a multi-stakeholder taskforce has
been set up to define them.
Indicator 4.2.12 is proposed so that the phrase "scheduled" changed to "in accordance with the agreement"
In indicator 4.2.12 the sentence "scheduled" is proposed to be changed to "according to the agreement"
Proposed 4.2.12: Improvement of the phrase "scheduled" to "in accordance with the agreement"
Comment: Changing the phrase "scheduled" to "in accordance with the agreement" proposed change: 4.2.12 Claims of compensationor agreement achieved through the process of resolving conflicts with the affected community or those who have been deprived of
their land through acquisition or forced neglect of customary rights holders and rights Use the land before the operation carried out at
this time must be carried out in accordance with the agreement.
"Proposed indicator 4.2.12
Changing the phrase ""scheduled"" to ""according to the agreement""""Indicator 4.2.12 Proposed:
Changing the phrase ""scheduled"" to ""according to the agreement"""
4.2.12: The word "scheduled" was changed to "according to the agreement"
The word "scheduled" was changed to "in accordance with the agreement""[I] 4.2.12
Changing the phrase ""scheduled"" to ""according to the agreement""""Comment:
Changing the phrase ""scheduled"" to ""according to the agreement""

338

4.2.12339

4.2.12

Proposed changes:
4.2.12 Claims of compensation or agreement achieved through the process of resolving conflicts with affected communities or those
who have been deprived of their land through acquisition or forced neglect of customary rights holders and land use rights before
operations carried out at this time must be carried out in accordance with the agreement.""4.2.12: The word ""scheduled"" was changed to ""appropriate
with an agreement """Changing the phrase "scheduled" to "according to the agreement"#

Indicator

Comment (English)

340
341
342
343
344

4.2.124.2.124.2.124.2.12
4.3

345

4.3

346

4.3

347

4.3

348

4.3

349

4.3

350

4.3

351

4.3

352

4.3

353

4.3

354

4.3

355

4.3

356
357

4.3.1
4.3.1

Changing the phrase "scheduled" to "according to the agreement"
Indicator 4.2.12 is proposed to: The sentence "scheduled" is changed to "according to the agreement".
No 4.6.5 and 4.6.6
No indicator 4.6.5 and 4.6.6
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defence for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defence for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defense for local populations who aresometimes poorly informed or have few financial means.
Institutions and representatives must be facilitated by the RSPO to facilitate access to a fair defence for local populations who aresometimes poorly informed or have few financial means.
A timeline of standard procedures to be published on the RSPO guidelines"A timeline of standard procedures to be published on the RSPO guidelines"#Indicator

Comment (English)

358

4.3.1

359
360

4.3.1
4.3.1

4.3.1 There should be a reference made to the appropriate language. There should be a systematic review made to insert documentsin the appropriate languages.
A timeline of standard procedures to be published on the RSPO guidelines"A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

361
362
363

4.3.1
4.3.1
4.3.1

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable."
A timeline of standard procedures to be published on the RSPO guidelines
A timeline of standard procedures to be published on the RSPO guidelines"A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

364

4.3.1

365

4.3.1

366

4.3.1

367

4.3.1

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable.""on indicators 4.3.1 Proposed Editor in the sentence is ""a procedure must be available agreed upon by the relevant parties to identify
legal rights, rights
customs or rights to use, and procedures for identifying people who are entitled to compensation ""."
"Indicator 4.3.1 Proposed:
Proposed sentences in indicators 4.3.1 were changed to: ""The procedure must be available agreed upon by the relevant parties to
identify legal rights, customary rights or use rights, and procedures for identifying people who are entitled to compensation""."
Proposal of Pernaikan 4.3.1 (c) to become a certification unit must determine the procedures agreed upon by related parties to
identify legal rights, customary rights or use rights, and procedures for identifying people who are entitled to compensation. This
procedure must be carried out, monitored. This procedure must be documented and available for all stakeholders and affected
communities.
"Indicator 4.3.1
Proposal:
The sentence was changed to ""the procedure must be available agreed upon by the relevant parties to identify legal rights, rights
customs or rights to use, and procedures for identifying people who are entitled to compensation ""."

#

Indicator

Comment (English)

368

4.3.1

369

4.3.1

370

4.3.1

371

4.3.1

372

4.3.1

373

4.3.1

374

4.3.1

375
376
377

4.3.1
4.3.1
4.3.2

"Proposed changes:
4.3.1 (c) The certification unit must determine the procedures agreed upon by related parties to identify legal rights, rights
customs or rights to use, and procedures for identifying people who are entitled to compensation. This procedure must be carried out,
monitored. This procedure must be documented and available for all stakeholders and affected communities."
Indicator sentences 4.3.1 should be changed to "the procedure must be agreed upon by the relevant parties to identify the legal rights,
customary rights or rights of use, and procedures for identifying people who are entitled to compensation".
Proposed changes: 4.3.1 (c) The certification unit must determine the procedures agreed upon by related parties to identify legal
rights, customary rights or use rights, and procedures for identifying people who are entitled to compensation. This procedure must be
carried out, monitored. This procedure must be documented and available for all stakeholders and affected communities.
"[I] 4.3.1
Proposed sentences in indicators 4.3.1 were changed to: ""The procedure must be available agreed upon by the relevant parties to
identify legal rights, rights
customs or rights to use, and procedures for identifying people who are entitled to compensation ""."
Indicator 4.3.1 (c) It is proposed that the sentences in indicators 4.3.1 will be changed to: "The procedure must be agreed upon by therelevant parties to identify legal rights, customary rights or use rights, and procedures for identifying people who are entitled tocompensation ".
"Indicator 4.3.1 (c) It is proposed that the sentence in indicator 4.3.1 is replaced to: ""The procedure must be available agreed upon by
the relevant parties to identify legal rights, rights
customs or rights to use, and procedures for identifying people who are entitled to compensation ""."
"Proposed sentences in indicators 4.3.1 were changed to: ""The procedure must be available agreed upon by the relevant parties to
identify legal rights, rights
customs or rights to use, and procedures for identifying people who are entitled to compensation ""."
It is requested to maintain 4.6.1 and 4.7.1 of the previous version. Demonstrate legitimate affectation.
It is requested to maintain 4.6.1 and 4.7.1 of the previous version. Demonstrate legitimate affectation.
4.3.2 What if the UoC is dealing with a patriarchal customary system? How would the UoC prove an equal gender opportunity for theaffected communities who themselves do not believe in gender equality? For example, land inheritance in Muslim communities isusually passed down through males. And this is the case in most rural communities, especially oil palm countries in Asia.

#

Indicator

Comment (English)

378

4.3.2

"A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

379

4.3.2

380

4.3.2

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable."
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.
"A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

381

4.3.2

382

4.3.2

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable.""The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.""A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

383

4.3.2

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable.""A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

384

4.3.2

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable."
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

#Indicator

Comment (English)

385

4.3.2

"A schedule of standard procedures should be published on the RSPO guidelines.
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.

386

4.3.3

387
388
389
390
391
392

4.3.3
4.3.3
4.3.3
4.3.3
4.3.3
4.3.3

393

4.3.3

394

4.3.3

395

4.3.3

396

4.3.3

397

4.3.3

In all cases, the RSPO complaints resolution mechanism must provide a clear and public timetable."
The basis for calculating compensation or even the procedures should not mention the gender of the landowner, which is irrelevant
information.
4.3.3. This should also be made publicly available for monitoring wider stakeholder groups.
In indicator 4.3.3 The phrase "representative chosen" was proposed to be changed to "representative of landowners"
Changing the phrase "representative he chose" was changed to "representative of landowners"
Indicator 4.3.3 (c) Proposed to: The phrase "the representative he chose" was changed to "Representative of the Land Owner".
Proposed Indicator 4.3.3: Changing the phrase "the representative he chose" was changed to "Representative of the Land Owner""Indicator 4.3.3 Proposed:
Changing the phrase ""representative he chose"" was changed to ""representative of landowners""""Proposed indicator 4.3.3:
Changing the phrase ""representative he chose"" was changed to ""representative of landowners"""
Proposed changes in indicators 4.3.3: Changing the phrase "the representative he chose" was changed to "Representative of the Land
Owner""Comment:
Changing the phrase ""representative he chose"" was changed to ""representative of landowners""
Proposed changes:
4.3.3 (c) Documenting the process and results of all agreements, compensation, and payments resulting from negotiations, completewith proof of the participation of the affected parties, and the documents referred to are available to the parties and representativesof landowners.""[I] 4.3.3
Changing the phrase ""representative he chose"" was changed to ""representative of landowners"""
Indicator 4.3.3 (c) Proposed to: The phrase "the representative he chose" was changed to "Representative of the Land Owner".

#Indicator

Comment (English)

398
399
400

4.3.3
4.3.3
4.3.4

401
402
403
404
405
406

4.3.4
4.3.4
4.3.4
4.3.4
4.3.4
4.3.4

407

4.3.4

408

4.3.4

409

4.3.4

410

4.3.4

411

4.3.4

Indicator 4.3.3 (c) Proposed to: The phrase "the representative he chose" was changed to "Representative of the Land Owner".
The indicator 4.3.3. It is already included in 4.2.8
4.3.4 What would be the appropriate compensation or opportunity? And who should determine whether it is enough? How do we
audit something like this?
"in a language they understand"
Propose to reword : evidence is documented
in a language they understandin a language they understandin a language they understand"In indicators 4.3.4 - the sentence changes are proposed to be ""available evidence that people who lose access and land rights to
expand plantations are given the opportunity to benefit from plantation development"".
- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure"""Proposal 4.3.4 The sentence "planting and/or new development" was changed to "new planting including the development of
supporting infrastructure" so that changes: 4.3.4 to: available evidence that people who lose access and rights to land that exist newplanting including the development of supporting infrastructure given the opportunity to benefit from the development of plantations". Evidence of this process is documented and available for all people and stakeholders that are affected.
"- It is proposed to change sentences to ""available evidence that people who lose access and land rights for plantation expansion are
given the opportunity to benefit from the development of plantations"".
- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure"""Need to change indicators 4.3.4: Changes in sentences to "available evidence that people who lose access and land rights forplantation expansion are given the opportunity to benefit from plantation development". While the phrase "Planting and/or New
Development" was changed to "new planting including the development of supporting infrastructure""[I] 4.3.4- It is proposed to change sentences to ""available evidence that people who lose access and land rights for plantation expansion are
given the opportunity to benefit from the development of plantations"".
- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure"""4.3.4: Replacing the word "proof of the process" to "evidence of the results" because it is not auditable to document all the processes.

#Indicator

Comment (English)

412

4.3.4

413

4.3.4

414

4.3.4

"Proposed indicator 4.3.4:- Changing sentences to ""available evidence that people who lose access and land rights to expand plantations are given theopportunity to benefit from plantation development"".
- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure""""Indicator 4.3.4 is proposed to:
1. The sentence is changed to ""available evidence that people who lose access and rights to land for plantation expansion are given
the opportunity to benefit from plantation development"".
2. The phrase ""Planting and/or New Development"" was changed to ""New Planting including the development of supporting
infrastructure"".""Comment:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""

415

4.3.4

416

4.3.4

417

4.3.4

Proposed changes:
4.3.4 Evidence is available that people who lose access and rights to existing land including the development of supporting
infrastructure are given the opportunity to benefit from the development of plantations "". Evidence of this process is documented
and available to all communities and stakeholders
affected.
""Indicator 4.3.4 Proposed:- It is proposed to change sentences to ""available evidence that people who lose access and land rights for plantation expansion are
given the opportunity to benefit from the development of plantations"".
- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure"""Comment: The sentence "planting and/or new development" was changed to "new planting including the development of supporting
infrastructure" proposed changes: 4.3.4 Available evidence that people who lose access and rights to existing land including thedevelopment of supporting infrastructure are given the opportunity to get Benefits of Plantation Development ". Evidence of thisprocess is documented and available to all people and stakeholders affected.
Indicator 4.3.4 is proposed to: (1). The sentence was changed to "available evidence that people who lose access and land rights to
expand plantations are given the opportunity to benefit from plantation development". (2). The phrase "Planting and/or New
Development" was changed to "new planting including the development of supporting infrastructure".

#Indicator

Comment (English)

418
419
420

4.4
4.4
4.4

421
422
423
424

4.4
4.4
4.4.1
4.4.1

425
426
427
428

4.4.1
4.4.1
4.4.1
4.4.1

429

4.4.1

430

4.4.1

431

4.4.1

432

4.4.1

Consultation and negotiation should be conducted in a culturally appropriate manner.
Consultation and negotiation should be conducted in a culturally appropriate manner.
Revise wording of 4.4 to clarify that this is the case of existing plantations. [There is confusion here. Why are they putting 'newplantings' here? Is there a reason?]Consultation and negotiation should be conducted in a culturally appropriate manner.
"Consultation and negotiation should be conducted in a culturally appropriate manner. "in all cases, the RSPO complaints resolution mechanism must provide a clear and public timeline.
4.4.1 Guidance should also be given if other processes are used. If other processes are used, what would be the minimum
requirements by RSPO?
"in all cases, the RSPO complaints resolution mechanism must provide a clear and public timeline."
in all cases, the RSPO complaints resolution mechanism must provide a clear and public timeline.
4.4.1.in all cases, the RSPO complaints resolution mechanism must provide a clear and public timeline.
In indicators 4.4.1 can be: If there is a land conflict, then the process of resolving conflicts that can be received together as stipulated
in the RSPO complaint system or dispute resolution facility
4.4.1 This indicator to focus on making a system/mechanism in the certification unit in handling land conflicts, so there is no need toinclude a complaint system or dispute resolution facility owned by RSPO.
"Proposal:
Spending Indicator 4.4.1 Becomes: If there is a land conflict, then the process of resolving conflicts that can be received together as
stipulated in the RSPO complaint system or dispute resolution facility"
Proposed changes: 4.4.1 (c) If there is a land conflict can be resolved through a mutually agreed process. This process is compiled,documented, and implemented in order to overcome disagreement with and between affected communities (including people whose
land is seized or forced to leave their customary land or other utilization rights holders). Documented, provided, and understood steps
to resolve conflicts for all stakeholders, affected communities, and their representatives.
"[I] 4.4.1

433

4.4.1

434

4.4.1

Spending Indicator 4.4.1 Becomes: If there is a land conflict, then the process of resolving conflicts that can be received together as
stipulated in the RSPO complaint system or dispute resolution facility"
Proposed 4.4.1: Indicator Supporting 4.4.1 becomes: "If there is a land conflict, then the process of resolving conflicts that can bereceived together as stipulated in the RSPO complaint system or dispute resolution facility"
4.4.1: Indicator 4.4.1 is simplified to: "If there is a land conflict, then the process of resolving conflicts that can be received together as
stipulated in the RSPO complaint system or dispute resolution facility"#

Indicator

Comment (English)

435

4.4.1

436

4.4.1

437

4.4.1

438

4.4.1

439

4.4.1

440

4.4.1

441
442

4.4.2
4.4.2

443

4.4.2

444

4.4.2

Indicator 4.4.1 (c) Proposed in order to: Support Indicator 4.4.1 becomes "if there is land conflict, then the process of resolving
conflicts that can be received together as regulated in the RSPO complaint system or dispute resolution facility".
"Proposed changes:
4.4.1 (c) If there is a land conflict can be resolved through a mutually agreed process. This process is compiled, documented, andimplemented in order to overcome disagreement with and between affected communities (including people whose land is seized orforced to leave their customary land or other utilization rights holders). Documented, provided, and understood steps to resolve
conflicts for all stakeholders, affected communities, and their representatives.
""Proposal:
Spending Indicator 4.4.1 Becomes: If there is a land conflict, then the process of resolving conflicts that can be received together as
stipulated in the RSPO complaint system or dispute resolution facility"
Simplification of indicators 4.4.1 becomes: If there is a land conflict, then the process of resolving conflicts that can be received
together as stipulated in the RSPO complaint system or dispute resolution facility
Supporting Indicator 4.4.1 Becomes: If there is a land conflict, the conflict resolution is carried out with a jointly acceptable process as
stipulated in the RSPO complaint system or dispute resolution facility
Spending Indicator 4.4.1 Becomes: If there is a land conflict, then the process of resolving conflicts that can be received together as
stipulated in the RSPO complaint system or dispute resolution facility
4.4.2 Information should be provided in the appropriate language.
"4.4.2. For any grievance resolution mechanism chosen, the RSPO must define a timeline according to the seriousness of the situation.
All players must ensure that the grievance is resolved before the deadline."
Directly affected communities shall be represented through institutions or representatives of their own choosing. Vulnerable Groups
shall be considered in the selection of representatives. This includes the option of access and provision of independent advice andlegal counsel. For any grievance resolution mechanism chosen, the RSPO must define a timeline according to the seriousness of thesituation All players must ensure that the grievance is resolved before the deadline.
"Directly affected communities shall be represented through institutions or representatives of their own choosing. Vulnerable Groups
shall be considered in the selection of representatives. This includes the option of access and provision of independent advice andlegal counsel.

445

4.4.2

For any grievance resolution mechanism chosen, the RSPO must define a timeline according to the seriousness of the situation
All players must ensure that the grievance is resolved before the deadline.""For any grievance resolution mechanism chosen, the RSPO must define a timeline according to the seriousness of the situation
All players must ensure that the grievance is resolved before the deadline."#Indicator

Comment (English)

446

4.4.2

447

4.4.2

448

4.4.2

449

4.4.2

450

4.4.2

451

4.4.2

452

4.4.2

453

4.4.2

454

4.4.2

455

4.4.2

Directly affected communities shall be represented through institutions or representatives of their own choosing. Vulnerable Groups
shall be considered in the selection of representatives. This includes the option of access and provision of independent advice andlegal counsel
4.4.2.Directly affected communities shall be represented through institutions or representatives of their own choosing. Vulnerable
Groups shall be considered in the selection of representatives. This includes the option of access and provision of independent advice
and legal counsel.
In indicators 4.4.2 it is proposed to be combined with 4.4.1 to "if there is a land conflict, then the process of resolving conflicts that canbe received together as stipulated in the RSPO complaint system or dispute resolution facility""Indicator 4.4.2
Proposed change
Indicator 4.4.2 combined with 4.4.1 becomes ""if there is a land conflict, then the process of resolving conflicts that can be received
together as stipulated in the RSPO complaint system or dispute resolution facility"""
Indicator is proposed 4.4.2 combined with 4.4.1 to "if there is a land conflict, then the process of resolving conflicts that can bereceived together as regulated in the RSPO complaint system or dispute resolution facility"
Indicator is proposed 4.4.2 combined with 4.4.1 to "if there is a land conflict, then the process of resolving conflicts that can bereceived together as regulated in the RSPO complaint system or dispute resolution facility"
Indicator is proposed 4.4.2 combined with 4.4.1 to "if there is a land conflict, then the process of resolving conflicts that can bereceived together as regulated in the RSPO complaint system or dispute resolution facility""Comment:
Indicator is proposed 4.4.2 combined with 4.4.1 because the repetition of sentence information about the conflict resolution system isunderstood by all related parties"
Indicator 4.4.2 should be combined with 4.4.1 With the sentence "If there is a land conflict, then the process of resolving conflicts thatcan be received together as stipulated in the RSPO complaint system or dispute resolution facility""[I] 4.2.2

456

4.4.2

457

4.4.2

Indicator is proposed 4.4.2 combined with 4.4.1 to ""if there is a land conflict, then the process of resolving conflicts that can bereceived together as regulated in the RSPO complaint system or dispute resolution facility"""
Proposed 4.4.2: Proposed indicators 4.4.2 combined with 4.4.1 to "if there is a land conflict, then the process of resolving conflicts thatcan be received together as regulated in the RSPO complaint system or dispute resolution facility"
Indicator is proposed 4.4.2 combined with 4.4.1 to "if there is a land conflict, then the process of resolving conflicts that can bereceived together as regulated in the RSPO complaint system or dispute resolution facility"#

Indicator

Comment (English)

458

4.4.2

459

4.4.2

460
461
462
463
464
465

4.4.2
4.4.3
4.4.3
4.4.3
4.4.3
4.4.3

466
467
468
469
470

4.4.3
4.4.3
4.4.3
4.4.3
4.4.3

471
472

4.4.3
4.4.3

473

4.4.3

Indicator 4.4.2 (c) proposed so that the indicator 4.4.2 combined with 4.4.1 becomes "if there is land conflict, then the process ofresolving conflicts that can be received together as regulated in the RSPO complaint system or dispute resolution facility"
4.4.2: The word "and" replaced with "or" "because not all people affected appoint their representatives, and if there arerepresentatives, communication is carried out through these representatives, and if there are no representatives, communication iscarried out directly to the affected community, namely the landowner.
"And the representative." replaced with "or representative" tap is not all representativesb) The RSPO can also set up an assistance unit for populations affected by a case of grievance.
the system must also include a financial aid envelope to provide assistance to local populations.
the system must also include a financial aid envelope to provide assistance to local populations.
The RSPO can also set up an assistance unit for populations affected by a case of grievance.
"4.4.3.the system must also include a financial aid envelope to provide assistance to local populations.
b) The RSPO can also set up an assistance unit for populations affected by a case of grievance."... ; and... -> and/or
The RSPO can also set up an assistance unit for populations affected by a case of grievance.
the system must also include a financial aid envelope to provide assistance to local populations.
In indicator 4.4.3 for points c is removed because it is covered in points A and B"Indicator 4.4.3 Proposed points C is removed because it has been covered in points A and B"
Indicator 4.4.3 Proposal: Points C is removed because it is covered in points A and B"Indicator 4.4.3
Proposal: Points C is removed because it has been covered in points A and B""[I] 4.4.3

474
475

4.4.3
4.4.3

476
477
478

4.4.3
4.4.3
4.4.3

Proposed point C was removed because it was included in points A and B"
There needs to be a summary of indicators 4.4.3 by eliminating points C because it has been covered in points A and b.
"Proposal:
Point C is removed because it has been covered in points A and B"
Indicator 4.4.3 is proposed in order to: Points C is removed because it has been covered in points A and b.
Proposed point C was removed because it was included in points A and B
Indicator 4.4.3 is proposed in order to: Points C is removed because it has been covered in points A and b.

#Indicator

Comment (English)

479
480

4.4.3
4.4.3

481

4.4.4

482

4.4.4

483

4.4.4

484

4.4.4

485
486

4.4.4
4.4.4

487

4.4.4

488

4.4.4

489

4.4.4

490
491

4.4.4
4.4.4

492
493
494
495
496
497

4.4.4
4.4.4
4.4.4
4.4.4
4.4.4
4.4.4

Indicator 4.4.3 is proposed in order to: Points C is removed because it has been covered in points A and b.
4.4.3 Does not specify the way in which communities will have access to legal advice, who provides it? It should be as part of the
management of the community and should not be given the company to preserve the principle of impartiality in the process.
4.4.4. (C). Photos taken in the field or by satellite should be preferred to leave no room for doubt and ensure that all stakeholders arein agreement.
Photos taken in the field or by satellite should be preferred to leave no room for doubt and ensure that all stakeholders are inagreement.
"Photos taken in the field or by satellite should be preferred to leave no room for doubt and ensure that all stakeholders are inagreement."
Photos taken in the field or by satellite should be preferred to leave no room for doubt and ensure that all stakeholders are inagreement.
In indicators 4.4.4 add sentences to "authorities according to the applicable national regulations""Indicator 4.4.4 Proposed:
Add sentences to ""authorities according to the applicable national regulations"""
Proposed changes: 4.4.4 (c) For all conflicts or land disputes, participatory mapping must be carried out on the disputed area with theaffected parties and the authorities according to the applicable national regulations, if any. See indicator 4.2.3 (c).
Proposed indicator 4.4.4 (c) Proposed to: There are additional sentences to "the authorities according to the applicable national
regulations".
"[I] 4.4.4
Add sentences to ""authorities according to the applicable national regulations"""
Indicator 4.4.4 (c) Proposed to: There are additional sentences to "the authorities according to the applicable national regulations".
"Proposed changes:
4.4.4 (c) For all conflicts or land disputes, participatory mapping must be carried out on the area that is disputed with the affectedparties and the authorities in accordance with the applicable national regulations, if any. See indicator 4.2.3 (c)."Proposed to: There are additional sentences to "the authorities according to the applicable national regulations".
4.4.4: Need the definition of "who is the authorities" in participatory mapping.
Indicator 4.4.4 (c) Proposed to: There are additional sentences to "the authorities according to the applicable national regulations".
Indicator 4.4.4 (c) Proposed to: There are additional sentences to "the authorities according to the applicable national regulations".
Add sentences to "authorities according to the applicable national regulations"
Proposed indicator 4.4.4 (c): It is proposed that there is an additional sentence to "the authorities according to the applicable national
regulations".

#

Indicator

Comment (English)

498
499

4.4.4
4.4.5

500

4.4.5

501

4.4.5

502

4.4.5

503

4.4.5

504

4.4.5

505

4.4.5

506

4.4.5

Add sentences to "authorities according to the applicable national regulations""In the case of grievances, the RSPO must accelerate administrative procedures for access to ownership rights.
The RSPO must also propose a simplified administrative procedure for obtaining proof of land ownership.""In the case of grievances, the RSPO must accelerate administrative procedures for access to ownership rights.
The RSPO must also propose a simplified administrative procedure for obtaining proof of land ownership."In the case of grievances, the RSPO must accelerate administrative procedures for access to ownership rights. The RSPO must also
propose a simplified administrative procedure for obtaining proof of land ownership.
"4.4.5. In the case of grievances, the RSPO must accelerate administrative procedures for access to ownership rights.
The RSPO must also propose a simplified administrative procedure for obtaining proof of land ownership.
""In indicators 4.4.5 the sentence changes are proposed to: ""If there has been or a dispute has occurred, proof of land acquisition
legally and proof of compensation as agreed by the parties have been given to all people
who have legal rights, customary rights, or use rights when the land acquisition is carried out.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."
Indicator 4.4.5 is proposed to: The sentence is changed to "if there has been or a dispute has occurred, proof of land acquisition legallyand proof of compensation as agreed by the parties has been given to all people who have legal rights, customary rights, or use rights
at When the land acquisition is carried out. The evidence is available and given to the parties involved in the dispute and thatcompensation has been received through the documented KBDD process ".
"Indicator 4.4.5 Proposed:
The sentence changes will be proposed to: ""If there has been or a dispute, proof of land acquisition is legally and proof ofcompensation as agreed by the parties has been granted to all people who have legal rights, customary rights, or use rights at the timeof land acquisition.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."
"Indicator 4.4.5
Proposed changes: ""If there have been or disputes, proof of land acquisition legally and proof of compensation as agreed by parties
have been given to all people who have legal rights, customary rights, or use rights at the time of land acquisition. Evidence- The
evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process """#Indicator

Comment (English)

507

4.4.5

508

4.4.5

509

4.4.5

510

4.4.5

511

4.4.5

"The sentence changes are proposed to be: ""If there has been a dispute or a dispute, proof of land acquisition legally and proof ofcompensation as agreed by the parties has been given to everyone
who have legal rights, customary rights, or use rights when the land acquisition is carried out.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."
In indicators 4.4.5 it is necessary to change sentences to: "If there has been or a dispute has occurred, proof of land acquisition legallyand proof of compensation as agreed by parties have been given to all people who have legal rights, customary rights, or use rights At
the time of land acquisition. The evidence is available and given to those involved in the dispute and that compensation has been
received through the documented KBDD process ".
"Proposal 4.4.5:
The sentence changes are proposed to be: ""If there has been a dispute or a dispute, proof of land acquisition legally and proof ofcompensation as agreed by the parties has been given to everyone
who have legal rights, customary rights, or use rights when the land acquisition is carried out.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."In order to: the sentence is changed to "if there has been or a dispute has occurred, proof of land acquisition legally and proof ofcompensation as agreed by parties have been given to all people who have legal rights, customary rights, or use rights at the time ofland acquisition . The evidence is available and given to the parties involved in the dispute and that compensation has been received
through the documented KBDD process ".
"[I] 4.4.5

512

4.4.5

The sentence changes are proposed to be: ""If there has been a dispute or a dispute, proof of land acquisition legally and proof ofcompensation as agreed by the parties has been given to everyone
who have legal rights, customary rights, or use rights when the land acquisition is carried out.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."
"Indicator 4.4.5 Proposed to: The sentence is changed to ""if there has been or a dispute has occurred, proof of land acquisition legallyand proof of giving compensation as agreed by the parties have been given to all people
who have legal rights, customary rights, or use rights when the land acquisition is carried out.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."

#

Indicator

Comment (English)

513

4.4.5

514

4.4.5

515

4.4.5

516

4.4.5

517
518
519

4.5
4.5
4.5.1

520
521
522
523
524
525

4.5.1
4.5.1
4.5.1
4.5.1
4.5.1
4.5.1

526
527

4.5.1
4.5.1

Change the sentence to: "If there is or a dispute has occurred, proof of land acquisition legally and proof of compensation as agreed by
the parties has been given to all people who have legal rights, customary rights, or use rights at the time of land acquisition. -The
evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ".
"4.4.5: The indicator sentence becomes,""If there have been or disputes, proof of land acquisition legally and proof of compensation as agreed by the parties have been given
to all people who have legal rights, customary rights, or use rights at the time of land acquisition.
The evidence is available and given to the parties involved in the dispute and that compensation has been received through the
documented KBDD process ""."
"Change the sentence to: ""If there is or a dispute has occurred, proof of land acquisition legally and proof of compensation as agreed
by the parties has been given to all people
who have legal rights, customary rights, or use rights when the land acquisition is carried out. The evidence is available and given to
the parties involved in the dispute and that compensation has been received through the documented KBDD process ""."
Define the terms to be able to carry out a CLPI in established operations before 2005, the term affected communities does not clearly
determine the beginning of this process.
What is the difference with criteria 2.4? They both discuss the Grievance mechanism is similar ways.
All indicators contained in criteria 4.5 are already in indicator 2.4.1 (c), is it necessary to repeat them? ...
[HRSS] Propose to consolidate this with P2 - see HRSS proposed wordings in P2 on grievance mechanism which is to apply to p4, p5
and p6.
For indicators 4.5.1 it is proposed to add the phrase "as long as the report is supported by sufficient initial evidence"
The phrase added "as long as the report is supported by sufficient initial evidence"
Indicator 4.5.1 is proposed to: added the phrase "as long as the report is supported by sufficient initial evidence".
Indicator 4.5.1 is proposed to: added the phrase "as long as the report is supported by sufficient initial evidence".
The phrase added "as long as the report is supported by sufficient initial evidence""Indicator 4.5.1 Proposed:
The phrase added ""as long as the report is supported by sufficient initial evidence"""
Proposed indicator 4.5.1 needs to be added by the phrase "as long as the report is supported by sufficient initial evidence""[I] 4.5.1

4.5.1

The phrase added ""as long as the report is supported by sufficient initial evidence"""
Indicator 4.5.1 is proposed to: added the phrase "as long as the report is supported by sufficient initial evidence".

528

#

Indicator

Comment (English)

529
530

4.5.1
4.5.2

531
532
533

4.5.2
4.5.4
4.5.4

534

4.5.4

535

4.5.4

536

4.5.4

537

4.5.4

538

4.5.4

539

4.5.4

540

4.5.4

541

4.5.4

542

4.5.4

543

4.5.4

It is suggested to change the term affected by impact.
"The RSPO must support growers and mills in understanding the FPIC process and its implementation in order to increase efficiency inthe field and mitigate the future risk of grievances."
It is suggested to change the term affected by impact.
"Including an agreed time frame "In indicators 4.5.4 it is proposed that the change to "the certification unit informs the development of complaints to the parties,
including the agreed time frame, and the results are available and communicated to relevant stakeholders".
"Indicator 4.5.4 Proposed:
It was proposed to change to ""The Certification Unit informed the development of complaints handling to the parties, including theagreed time frame, and the results were available and communicated to relevant stakeholders"".""Indicator 4..5.4
Proposed change
The certification unit informs the development of complaints handling to the parties, including the agreed time frame, and the results
are available and communicated to relevant stakeholders ""."
Proposed Indicator 4.5.4: It should be changed to "The Certification Unit informs the development of complaints to the parties,
including the agreed time frame, and the results are available and communicated to relevant stakeholders".
Proposed 4.5.4, Improvement of Indicators to "Certification Unit informs the development of complaints handling to the parties,
including the agreed time frame, and the results are available and communicated to relevant stakeholders"Proposed changes:
4.5.4 The certification unit informs the development of complaints handling to the parties, including the agreed time frame, and theresults are available and communicated to relevant stakeholders ""."
Proposed change: 4.5.4 Certification Unit informs the development of complaints handling to the parties, including the agreed timeframe, and the results are available and communicated to relevant stakeholders ".
It was proposed to change to "The Certification Unit informed the development of complaints handling to the parties, including theagreed time frame, and the results were available and communicated to relevant stakeholders".
Indicator 4.5.4 is proposed to: Change to "the certification unit informs the development of complaints to the parties, including theagreed time frame, and the results are available and communicated to relevant stakeholders".
Indicator 4.5.4 is proposed to: Change to "the certification unit informs the development of complaints to the parties, including theagreed time frame, and the results are available and communicated to relevant stakeholders".
It was proposed to change to "The Certification Unit informed the development of complaints handling to the parties, including theagreed time frame, and the results were available and communicated to relevant stakeholders".

#Indicator

Comment (English)

544
545

4.5.4
4.5.4

546
547
548

4.5.4
4.6.1
4.6.1

549

4.6.1

550

4.6.1

551

4.6.1

552

4.6.1

This indicator is doubled in accordance with the provisions of indicator 2.4.1, 2.4.2
It must be focused on impacted or linked communities, and not to relevant interested parties since this indicator is addressed inprinciple 2 in the indicators of 2.4
This indicator is doubled in accordance with the provisions of indicator 2.4.1, 2.4.2, it is suggested to eliminate.
4.6.1 Is community development equal to sustainable development? There seems to a be disjunct between the criteria and indicator
4.6.1. A taskforce could be formed by the RSPO with a number of relevant stakeholders to try to identify and quantify contributions tocommunity development.
"A taskforce could be formed by the RSPO with a number of relevant stakeholders to try to identify and quantify contributions tocommunity development."
A taskforce could be formed by the RSPO with a number of relevant stakeholders to try to identify and quantify contributions tocommunity development.
A taskforce could be formed by the RSPO with a number of relevant stakeholders to try to identify and quantify contributions tocommunity development.
"Here is a confusion, these contributions are agreements as part of a CLPI? or in general, project support requests agreed with thecommunities.
The auditors audit it as something general but not because it is associated with an agreement in a clip."#Indicator

Comment (English)

1

5.1

2

5.1

3

5.1

4

5.1

5

5.1

6

5.1

7

5.1

8

5.1

9

5.1

10

5.1

The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.

#Indicator

Comment (English)

11

5.1

12

5.1

13

5.1.1

The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
The notion of "fair" needs to be very clearly defined, with a panel of several relevant stakeholders, guidelines or even, precise criteria
to ensure that smallholders and schemes not only receive genuine fairness in prices but also have a voice in negotiations with players and to avoid random interpretation among mills.
"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.

14

5.1.1

While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.""The price information in question in question is that
determined by the government and can be accessed by all
Planning (Swadaya and Plasma) TBS suppliers."#Indicator

Comment (English)

15

5.1.1

16

5.1.2

17

5.1.3

5.1.1: FFB price information in question is determined by the government and can be accessed by all planters (self -help and plasma)
TBS suppliers.
Proposed Indicator Improvement 5.1.2 Becomes: The availability of evidence that the certification unit gives an explanation of thedetermination of TBS prices regularly to farmers.
"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."#Indicator

Comment (English)

18

5.1.3

19

5.1.3

RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
"Welcome that the NI will develop a procedure to calculate a fair price for FFB in the absence of government floor pricing [For National
Interpretation:
National Interpretation will include information on national pricing mechanism. In the absence of government floor pricing, theNational Interpretation will develop a procedure to calculate a fair price for FFB].
"#

Indicator

Comment (English)

20

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.

21

5.1.3

The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency.""5.1.3.(C) In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for
FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023."

#Indicator

Comment (English)

22

5.1.3

"5.1.3 (C) For National Interpretation : While waiting for Living Wages benchmark,the National Interpretation shall use the production
costs approach to calculate what is a fair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
"

#

Indicator

Comment (English)

23

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,etc.)"

#

Indicator

Comment (English)

24

5.1.3

25

5.1.3

n the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB". RSPO
will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate. Oncethe appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify living
wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall be done by
the end of 2023. While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to
calculate what is a fair price for FFB. ● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation andcover, at a minimum, the costs of production - including labour, materials, overheads, and a margin ● Fair Price calculation methods
should consider the costs associated to the production itself (when applicable: seedling, agricultural inputs, specific authorisations,fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance, cost of transportation for goods orworkforce, etc.) but also costs for implementing good agricultural practices, measures for conserving/restoring biodiversity; costs oftraining and awareness raising events; costs of technical support and internal audits. ● Cost calculations consider the average timespent by smallholders or medium growers, on cultivation related to the raw material, at a rate proportional at least to the national
minimum wage. ● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase ofminimum wages, etc.)
In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB". RSPO
will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate. Oncethe appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify living
wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall be done by
the end of 2023. While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to
calculate what is a fair price for FFB. ● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation andcover, at a minimum, the costs of production - including labour, materials, overheads, and a margin ● Fair Price calculation methods
should consider the costs associated to the production itself (when applicable: seedling, agricultural inputs, specific authorisations,fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance, cost of transportation for goods orworkforce, etc.) but also costs for implementing good agricultural practices, measures for conserving/restoring biodiversity; costs oftraining and awareness raising events; costs of technical support and internal audits. ● Cost calculations consider the average timespent by smallholders or medium growers, on cultivation related to the raw material, at a rate proportional at least to the national
minimum wage. ● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase ofminimum wages, etc.)#Indicator

Comment (English)

26

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.

27

5.1.3

The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."
In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB".

#

Indicator

Comment (English)

28

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."#Indicator

Comment (English)

29

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."#Indicator

Comment (English)

30

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."#Indicator

Comment (English)

31

5.1.3

"While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
"

#

Indicator

Comment (English)

32

5.1.3

"In the absence of government floor pricing, the National Interpretation will develop a procedure to calculate a fair price for FFB"".
RSPO will endeavour to ascertain the appropriate living wage benchmarks for palm oil-producing areas in which its members operate.
Once the appropriate living wage benchmarks are available, the Unit of Certification (UoC) shall update their prevailing wage, identify
living wage gap, develop a time-bound wage improvement plan and take measures to close the gap (if any). These studies shall bedone by the end of 2023.
While waiting for Living Wages benchmark,the National Interpretation shall use the production costs approach to calculate what is afair price for FFB.
● Fair Price paid to smallholders or medium growers of FFB are based on cost-calculation and cover, at a minimum, the costs ofproduction - including labour, materials, overheads, and a margin● Fair Price calculation methods should consider the costs associated to the production itself (when applicable: seedling,
agricultural inputs, specific authorisations, fields rental, employed workforce, machinery costs - rental, new acquisition, maintenance,
cost of transportation for goods or workforce, etc.) but also costs for implementing good agricultural practices, measures forconserving/restoring biodiversity; costs of training and awareness raising events; costs of technical support and internal audits.
● Cost calculations consider the average time spent by smallholders or medium growers, on cultivation related to the raw material,at a rate proportional at least to the national minimum wage.
● Cost calculations are periodically reviewed to reflect changes in cost of living (inflation, deflation, increase of minimum wages,
etc.)
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.

33

5.1.3

34

5.1.3

The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."
Why is 'Fair pricing' changed to 'the fair or competitive pricing'? Dealing fairly and transparently with all smallholders requires that afair price is paid. The wording 'fair OR competitive pricing' could give the impression that it is ok to not pay a fair price.
"5.1.3 In order to add the words ""if any"" to the sentence ""Determine the Fair or Competitive Prices (including Premium Prices ifany)""The pricing mechanism owned by the company is already something standard."#Indicator

Comment (English)

35

5.1.3

36

5.1.3

37

5.1.3

38

5.1.3

39

5.1.3

40

5.1.3

41

5.1.3

42

5.1.3

43

5.1.3

44

5.1.3

45

5.1.3

"On indicators 5.1.3 Fair pricing, including determining the value of premiums, if any, agreed with farmers
suppliers, and documented (the same as indicator 5.1.3 RSPO P&C 2018)""Indicator 5.1.3 Proposed:
Determination of fair prices, including determining the value of premiums, if any, agreed upon with supplier farmers, and documented(the same as the indicator 5.1.3 RSPO P&C 2018)""The phrase ""including premium prices"" was deleted because
The definition of premium prices has not been established, and there is no premium price benchmark that can be used as a reference.
In addition, the provision of incentives for suppliers
FFB can be in the form of other forms besides the price of FFB for example
Technical assistance, fertilizer supply assistance, and others.""For the current FFB price based on
for the authority of Disbun and representatives of oil palm companies
In each province, and is not regulated nationally."
Proposed Improvement of Indicators 5.1.3 Returns to the 2018 RSPO PNC Indicator, "Fair price determination, including determining
the value of premiums, if any, agreed upon with supplier farmers, and documented" "Indicator 5.1.3 (c) is proposed to: For national interpretation, the current TBS prices are based on the authority of Disbun andrepresentatives of oil palm companies in each province is not regulated nationally.
Proposed Indicator 5.1.3 (c): For national interpretation, the current FFB price is based on the authority of Disbun and representativesof oil palm companies in each province is not regulated nationally.
"Proposed Indicator 5.1.3 Returns to the 2018 RSPO PNC indicator, fair price determination, including determining the value ofpremiums, if any, agreed with the farmers
supplier, and documented""Indicator 5.1.3 (c) Proposed for:Fair price determination, including determining the value of premiums, if any, agreed with farmers
suppliers, and documented (the same as the indicator 5.1.3 RSPO P&C 2018)."
For the current FFB price based on the authority of Disbun and representatives of oil palm companies in each province is not regulated
nationally5.1.3: The phrase "including premium prices" is removed because the definition of premium prices has not been determined, andthere is no benchmark for premium prices that can be used as a reference. In addition, the provision of incentives for FFB suppliers canbe in the form of other forms besides the price of FFB such as technical assistance, fertilizer supply assistance, and others.

#Indicator

Comment (English)

46

5.1.3

47

5.1.3

48

5.1.3

49

5.1.3

50

5.1.3

51

5.1.3

52

5.1.3

53

5.1.4

54

5.1.4

55

5.1.4

56

5.1.4

57
58
59

5.1.4
5.1.4
5.1.5

Indicator 5.1.3 (c) is proposed to: For national interpretation, the current TBS prices are based on the authority of Disbun andrepresentatives of oil palm companies in each province is not regulated nationally.
"Proposed changes:
5.1.3 (c) The certification unit must determine the fair price including premium prices if there is, through an agreement with the
supplier of FFB. The agreed price must be documented."
Proposed 5.1.3: Indicators are changed to "Fair Prices, including determining the value of premiums, if any, agreed with suppliers, anddocumented" (equal to indicators 5.1.3 RSPO P&C 2018)
The indicators are changed to "Fair Prices, including determining the value of premiums, if any, agreed upon with supplier farmers, anddocumented" (the same as the indicator 5.1.3 RSPO P&C 2018)"Proposed Indicator 5.1.3:
Fair price determination, including determining the value of premiums, if any, agreed with farmers
suppliers, and documented (the same as indicator 5.1.3 RSPO P&C 2018)""Fair price determination, including determining the value of premiums, if any, agreed with farmers
suppliers, and documented (the same as indicator 5.1.3 RSPO P&C 2018)"
5.1.3: For the current price of FFB based on the authority of Disbun and representatives of oil palm companies in each province, and is
not regulated nationally.
5.1.4. Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
"Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members."
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
Guidelines should be proposed to provide simplified negotiation processes that are fair for the mills, but above all safe andunderstandable for smallholders and scheme members.
This indicator is related to plasma/partnership cooperation.
5.1.4: This indicator is related to plasma/partnership cooperation.
"The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable toall smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."#Indicator

Comment (English)

60

5.1.5

61

5.1.5

62

5.1.5

63

5.2

64

5.2

65

5.2

66

5.2

67

5.2

68

5.2

69

5.2

"5.1.5. The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair andunderstandable to all smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency.""The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable toall smallholders.
Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its transparency."
The process must be proposed by the RSPO and a panel of relevant stakeholders to ensure that it is both fair and understandable to all
smallholders. Audits could be set up, with public disclosure of FFB prices, to guarantee compliance with the process and its
transparency.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.

#Indicator

Comment (English)

70

5.2

71

5.2

72

5.2

73

5.2

74

5.2

75

5.2.1

76

5.2.1

77

5.2.1

Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
Mills must be required to meet the % of certified FFB, which they must purchase, at the right price, and which is made available bysmallholders or scheme. If necessary, the certification unit must prove its inability to purchase certified volumes from smallholders at
the premium price.
"In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction."
Guidelines need to be put in place to provide smallholders with a legal framework and/or support to establish this dialogue with mills.
These guidelines should consider the type of player, the economic situation of the area, the geographical location and the volumes
involved (non-exhaustive list). This will also help the mill to see how it can provide operational support to smallholders.

#

Indicator

Comment (English)

78

5.2.1

79

5.2.1

80

5.2.1

81

5.2.1

82

5.2.1

83

5.2.1

84

5.2.1

"In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction.""Guidelines need to be put in place to provide smallholders with a legal framework and/or support to establish this dialogue with mills.
These guidelines should consider the type of player, the economic situation of the area, the geographical location and the volumes
involved (non-exhaustive list).
This will also help the mill to see how it can provide operational support to smallholders.""5.2.1. Guidelines need to be put in place to provide smallholders with a legal framework and/or support to establish this dialogue
with mills.
These guidelines should consider the type of player, the economic situation of the area, the geographical location and the volumes
involved (non-exhaustive list).
This will also help the mill to see how it can provide operational support to smallholders.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction.""Guidelines need to be put in place to provide smallholders with a legal framework and/or support to establish this dialogue with mills.
These guidelines should consider the type of player, the economic situation of the area, the geographical location and the volumes
involved (non-exhaustive list)."What is the reason for no longer explicitly referring to 'including women' in indicator 5.2.1? As a marginalized group, it is important tomake explicit that female smallholders should be supported. This is also important if RSPO is benchmarked on the inclusion of
women's rights in the standard.

#Indicator

Comment (English)

85

5.2.1

"5.2.1 Changing the word planner to an independent farmer (independent smallholder)

86

5.2.1

87

5.2.2

88

5.2.2

89

5.2.2

90

5.2.2

91

5.2.2

92

5.2.2

93

5.2.2

94

5.2.2

Consideration: This indicator is more relevant for planters with the status of independent farmers (independent smallholder), whileplanters with plasma status (Schemed Smallholder) have been included in the certification unit obligation for the certification process.
""To encourage harmonization with EUDR related to traceability at the Self -Help Petanis level, I propose there are additional sentences
in indicators 5.2.1: ......... and UC prioritizes the partnership of buying and selling FFB with RSPO certified self -help farmers.
""These documents and training courses must be produced in a language and format that can be understood by all stakeholders.
Assessments must be guaranteed to be free from conflicts of interest with external stakeholders, and to meet objective audit criteria.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction.""These documents and training courses must be produced in a language and format that can be understood by all stakeholders.
Assessments must be guaranteed to be free from conflicts of interest with external stakeholders, and to meet objective audit criteria.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction."
These documents and training courses must be produced in a language and format that can be understood by all stakeholders.
Assessments must be guaranteed to be free from conflicts of interest with external stakeholders, and to meet objective audit criteria.
The documented training list along with the list of participants, based on the findings of the assessment of the needs of plasma
planters which includes aspects that apply from P&C RSPO and, if possible for interested independent planters must be available.
"Indicator 5.2.2 Proposed:
The documented training list along with the list of participants, based on the findings of the assessment of the needs of plasma
planters which includes aspects that apply from P&C RSPO and, if possible for interested independent planters must be available."
In indicators 5.2.2 List of documented training along with a list of participants, based on the findings of the assessment of the needs ofplasma planters that include aspects that apply from P&C RSPO and, if possible for interested independent planters must be available.

#

Indicator

Comment (English)

95

5.2.2

96

5.2.2

97

5.2.2

98

5.2.2

99

5.2.2

Indicator 5.2.2 Proposal: Documented training list along with a list of participants, based on the findings of the assessment of theneeds of plasma planters that include aspects that apply from P&C RSPO and, if possible for interested independent planters must be
available.
"Indicator 5.2.2
Proposal:
The documented training list along with the list of participants, based on the findings of the assessment of the needs of plasma
planters which includes aspects that apply from P&C RSPO and, if possible for interested independent planters must be available.""Proposed indicator improvement 5.2.2 to:
The list of documented training along with the list of participants, based on the results of the assessment of the needs of plasma
planters which includes aspects that apply from P&C RSPO and, if possible for interested independent planters must be available."
Indicator 5.2.2 (c) Proposed in order to: Documented Training List along with a list of participants, based on the findings of theassessment of the needs of plasma planters which include aspects that apply from P&C RSPO and, if possible for interested
independent planters must be available.
Indicator 5.2.2 (c) Proposed in order to: Documented Training List along with a list of participants, based on the findings of theassessment of the needs of plasma planters which include aspects that apply from P&C RSPO and, if possible for interested
independent planters must be available.
"Indicator proposal 5.2.2:
The documented training list along with the list of participants, based on the findings of the assessment of the needs of plasma
planters which includes aspects that apply from P&C RSPO and, if possible for interested independent planters must be available.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.
Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction.""In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C.""5.2.3. In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders.
RSPO must work with governments to facilitate these procedures and help mills operationally to be compliant with P&C."
In localities, mills must set up mechanisms with local governments to accelerate or assist smallholders. RSPO must work withgovernments to facilitate these procedures and help mills operationally to be compliant with P&C.

100 5.2.2

101 5.2.3

102 5.2.3
103 5.2.3
104 5.2.3

#Indicator

105 5.2.3
106 5.2.3

107 5.2.3

108 5.2.3
109 5.2.3

110 5.2.3
111 5.2.3

112 5.2.3
113 5.2.3
114 5.2.3

Comment (English)"In indicator 5.2.3 If it can be done, the certification unit provides support to Farmers to support the legality of FFB production(according to indicators 5.2.3 P&C 2018)""5.2.3 Changing the word ""must (shall)"" to ""if it can be done""
Consideration: Implementation of this indicator in planters with the status of independent farmers will be very dependent on their
desires regarding the land legislation process.
""Indicator 5.2.3 Proposed:
If it can be done, the Certification Unit provides support to farmers to support the legality of FFB production (according to indicators
5.2.3 P&C 2018)"
Proposed Improvement of Indicators 5.2.3 to "if the Certification Unit can be carried out provides support to farmers to support thelegality of FFB production (according to indicators 5.2.3 P&C 2018)"Proposed indicator 5.2.3
add ""if it can be done"" at the beginning of the sentence the certification unit provided support to Farmers to support the legality of
FFB production (according to indicators 5.2.3 P&C 2018)""Indicator 5.2.3 is proposed in order to: If it can be done, the certification unit provides support toFarmers to support the legality of FFB production (according to indicators 5.2.3 P&C 2018)""If it can be done, the certification unit provides support toFarmers to support the legality of FFB production (according to indicators 5.2.3 P&C 2018)"
Indicator 5.2.3 is proposed in order to: If it can be done, the Certification Unit provides support to farmers to support the legality of
FFB production (according to indicators 5.2.3 P&C 2018)
Indicator 5.2.3 should be returned according to indicators 5.2.3 P&C 2018: If it can be done, the certification unit provides support tofarmers to support the legality of TBS production"Proposed indicator 5.2.3:
If it can be done, the certification unit provides support toFarmers to support the legality of FFB production (according to indicators 5.2.3 P&C 2018)"

#Indicator

115 5.2.4
116 5.2.4
117 5.2.4
118 5.2.4

119 5.2.4

120 5.2.4

121 5.2.4

122 5.2.4

123 5.2.4

Comment (English)
These additional activities must be documented in guidelines made available to them. These guidelines must be the result ofconsultations with relevant stakeholders.
"These additional activities must be documented in guidelines made available to them.
These guidelines must be the result of consultations with relevant stakeholders.""These additional activities must be documented in guidelines made available to them.
These guidelines must be the result of consultations with relevant stakeholders.""1. Propose to delete ""Considering the results of participatory consultations conducted with them""
2. The Certification Unit develops and implements the livelihood improvement programs, including at least an increase in capacity toincrease productivity, quality, ability organized and managerial, as well as certain elements in RSPO certification (including RSPOStandards for Independent Farmers).""For indicators 5.2.4 - propose to delete ""consider the results of participatory consultations conducted with them""- The certification unit develops and implements life-ranking programs,
including at least an increase in capacity to increase productivity, quality, ability
organized and managerial, as well as certain elements in RSPO certification (including
RSPO Standards for Independent Farmers).""5.2.4 Changing the word Farmer to an Independent Farmer
Consideration: This indicator is more relevant for planters with independent smallholder (independent smallholder) status, while
matters regarding the improvement of welfare for planters with the status of plasma planters (Schemed Smallholder) have been
covered in the cooperation document of the Plasma Development Partnership.
""Indicator 5.2.4 is proposed to:
1. Propose to delete ""Considering the results of participatory consultations conducted with them"".
2. The Certification Unit develops and implements the livelihood improvement programs,
including at least an increase in capacity to increase productivity, quality, ability
organized and managerial, as well as certain elements in RSPO certification (including
RSPO Standards for Independent Farmers)."
Proposed Improvement of Indicators 5.2.4 Becomes: Certification Unit develops and implements life-improvement programs,
including at least an increase in capacity to increase productivity, quality, organizational and managerial skills, as well as certain
elements in RSPO certification (including RSPO standards for Independent farmers)
1. Propose "Considering the results of participatory consultations conducted with them" 2. The certification unit develops andimplements life-improve program RSPO (including RSPO standard for independent farmers).

#Indicator

124 5.2.4
125 5.2.4

126 5.2.4

127 5.2.4

128 5.2.4

129 5.2.4

130 5.2.5

131 5.2.5

Comment (English)
Indicator 5.2.3 is proposed so that the sentence becomes: If it can be done, the Certification Unit provides support to farmers to
support the legality of FFB production (according to indicators 5.2.3 P&C 2018)"Indicator 5.2.4
1. Propose ""Considering the results of participatory consultations conducted with them"" 2. The certification unit develops andimplements life-improve program RSPO (including RSPO Standards for Independent Farmers)""Indicator 5.2.4 Proposed:
1. Propose to delete ""Considering the results of participatory consultations conducted with them""
2. The Certification Unit develops and implements the livelihood improvement programs,
including at least an increase in capacity to increase productivity, quality, ability
organized and managerial, as well as certain elements in RSPO certification (including RSPO standards for independent farmers).""Proposal:
1. Propose to delete ""Considering the results of participatory consultations conducted with them""
2. The Certification Unit develops and implements the livelihood improvement programs,
including at least an increase in capacity to increase productivity, quality, ability
organized and managerial, as well as certain elements in RSPO certification (including
RSPO Standards for Independent Farmers)."
Indicator 5.2.4 is proposed in order to: (1). Propose to delete "Considering the results of participatory consultations conducted withthem". (2). The Certification Unit develops and implements life-ranking programs, including at least an increase in capacity to increase
productivity, quality, ability to organize and managerial, as well as certain elements in RSPO certification (including RSPO standards forindependent farmers).
"Proposed indicator 5.2.4:
1. Propose to delete ""Considering the results of participatory consultations conducted with them""
2. The Certification Unit develops and implements the livelihood improvement programs,
including at least an increase in capacity to increase productivity, quality, ability
organized and managerial, as well as certain elements in RSPO certification (including
RSPO Standards for Independent Farmers).""Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction."
Thresholds should be published to compare the progress reported by mills. Quantitative and qualitative targets, with an associatedtimeline, should be published to ensure that actions are progressing in the right direction.

#Indicator

132 5.2.5

Comment (English)"Thresholds should be published to compare the progress reported by mills.
Quantitative and qualitative targets, with an associated timeline, should be published to ensure that actions are progressing in theright direction."#Indicator

Comment (English)

1

6.1

2

6.1.1

3
4
5

6.1.1
6.1.1
6.1.1

6

6.1.1

7

6.1.1

8

6.1.1

6.1 Part of the indicator 6.1.3 From the 2018 RSPO P&C it needs to be adopted to the draft 2023 P&C where therequirements/qualifications/abilities/expertise/expertise are determined by the certification unit for recruitment, training, certain
promotions are not considered as a form of discrimination
6.1.1 Again, this indicator defies logic. Compressing the requirements of 4 previous indicators into 1 and merely listing requirements
is an audit disaster.
RSPO could include discrimination based on any medical tests such as HIV/AIDS , pregnancy or other similar tests.
To provide clearer guidance on the procedure about publishing and socializing the policy to labour recruiters.
In indicators 6.1.1 there are editors' proposals namely "(c) Nondiscrimination policies that apply to recruitment, giving work and wages
as well as access to training must be prepared and implemented. This nondiscrimination policy must include a prohibition on
discrimination based on ethnic, caste, nationality, religion, disability, gender, marital status, pregnancy, sexual orientation, gender
identity, migrant type, migrant worker status, membership in trade unions, political affiliation, and/or age. This policy is available forthe public and is socialized to the workforce, operation and suppliers, and worker recruiters and implemented ""Proposed Sentences Indicator:
6.1.1 (c) Nondiscrimination policies that apply to recruitment, giving work and wages and access to obtain training must be preparedand implemented. This nondiscrimination policy must include a prohibition on discrimination based on ethnic origin, caste, nationality,
religion, disability, gender, marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker status,
membership in trade unions, political affiliation, and//// or age. This policy is available to the public and is socialized to labor,
operations and suppliers, as well as worker recruiters and implemented""- ""work equipment"" work is changed to ""work equipment""- The word allowance is eliminated, because the definition of wages includes allowances"
The need for changes in the sentence indicator 6.1.1, namely the word "work", "allowance", "promotion", "facility", and "workequipment" are proposed to be deleted, because it will be difficult in implementing and causing multi interpretations during the audit.
- The company has the right to regulate compensation in accordance with the status of workers in accordance with the work
agreement, PP or PKB.

#

Indicator

Comment (English)

9

6.1.1

"1. Giving wages including benefits based on
Types of work and worker status are not included
discrimination. This has been spoken in the work agreement,
Company regulations and collective work agreements.
2. The word ""work equipment"" is changed to ""equipment
Work""
3. The word ""allowance"" is eliminated, because of the definition of wages
already includes allowances.

10

6.1.1

11

6.1.1

4. Sentence, ""This policy must be available to the public andsocialized to labor, operations and suppliers,
and worker recruiters. "" added ""... andimplemented and monitored ""."
"6.1.1 ""Work Equipment"" Work is changed to ""work equipment""
6.1.1 The word allowance is eliminated, because the definition of wages includes allowances""Proposed Improvement of Indicators: 6.1.1 (c) to:Nondiscrimination policies that apply to recruitment, giving work and wages and access to obtain training must be prepared andimplemented. This nondiscrimination policy must include a prohibition on discrimination based on ethnic origin, caste, nationality,
religion, disability, gender, marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker status,
membership in trade unions, political affiliation, and//// or age. This policy is available to the public and is socialized to labor,
operations and suppliers, as well as worker recruiters and implemented.
The word allowance is deleted because it has been covered in wages.
The word ""work equipment"" work is changed to ""work equipment"" The company has the right to regulate the compensation of each worker status in accordance with work agreements, company
regulations or PKB which refer to national regulations.
"#

Indicator

Comment (English)

12

6.1.1

13

6.1.1

14

6.1.1

15

6.1.1

16

6.1.1

17

6.1.1

Indicator 6.1.1 (c) Proposed in order to: 1. The word "work equipment" is changed to "work equipment" 2. The word allowance iseliminated, because the definition of wages already includes allowances. So that the sentence indicator 6.1.1 (c) becomes a"nondiscrimination policy that applies to recruitment, giving work and wages and access to obtain training must be prepared andapplied. This nondiscrimination policy must include a prohibition on discrimination based on ethnic, caste, national, religious, religious
Disability, gender, marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker status, membership intrade unions, political affiliation, and/or age. This policy is available for the public and is socialized to labor, operations and suppliers,
and worker recruiters and implemented ".
"6.1.1 ""Work Equipment"" Work is changed to ""work equipment""
6.1.1 The word allowance is eliminated, because the definition of wages includes allowances""- ""work equipment"" work is changed to ""work equipment""- The word allowance is eliminated, because the definition of wages includes allowances"
Indicator 6.1.1 (c) Proposed in order to: 1. The word "work equipment" is changed to "work equipment" 2. The word allowance iseliminated, because the definition of wages already includes allowances. So that the sentence indicator 6.1.1 (c) becomes a"nondiscrimination policy that applies to recruitment, giving work and wages and access to obtain training must be prepared andapplied. This nondiscrimination policy must include a prohibition on discrimination based on ethnic, caste, national, religious, religious
Disability, gender, marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker status, membership intrade unions, political affiliation, and/or age. This policy is available for the public and is socialized to labor, operations and suppliers,
and worker recruiters and implemented ".
"- The words ""giving work"", ""benefits"", ""promotion"", ""facilities"", and ""work equipment"" are proposed to be deleted, because
it will be difficult in implementing and causing multi interpretations during the audit.
- The company has the right to regulate compensation in accordance with the status of workers in accordance with the work
agreement, PP or PKB.""Indicator 6.1.1 (c) is proposed to:
1. The word ""work equipment"" is changed to ""work equipment""
2. The word allowance is eliminated, because the definition of wages already includes allowances.
So the indicator sentence
6.1.1 (c) becomes a ""nondiscrimination policy that applies to recruitment, giving work and wages and access to obtain training must
be prepared and implemented. This nondiscrimination policy must include a prohibition on discrimination based on ethnic, caste,national, religious, disability, gender , marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker
status, membership in trade unions, political affiliation, and/or age. This policy is available to the public and is socialized to theworkforce, operations and suppliers, and worker recruitment and implemented ""."

#

Indicator

Comment (English)

18

6.1.1

"Proposal:- ""work equipment"" work is changed to ""work equipment""- The word allowance is eliminated, because the definition of wages includes allowances

HR Note:- The words ""giving work"", ""benefits"", ""promotion"", ""facilities"", and ""work equipment"" are proposed to be deleted, because
it will be difficult in implementing and causing multi interpretations during the audit.
- The company has the right to regulate compensation in accordance with the status of workers in accordance with the work
agreement, PP or PKB.

19

6.1.1

20

6.1.1

Proposed Sentences Indicator:
6.1.1 (c) Nondiscrimination policies that apply to recruitment, giving work and wages and access to obtain training must be preparedand implemented. This nondiscrimination policy must include a prohibition on discrimination based on ethnic origin, caste, nationality,
religion, disability, gender, marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker status,
membership in trade unions, political affiliation, and//// or age. This policy is available to the public and is socialized to labor,
operations and suppliers, as well as worker recruiters and implemented"
The word "work equipment" is changed to "work equipment"; The word allowance is eliminated because the definition of wages
includes allowances.
"6.1.1: Giving wages including benefits based on the type of work and the status of workers is not discriminatory. This has been spoken
in the employment agreement, company regulations and collective labor agreements.
6.1.1: The word ""work equipment"" is changed to ""work equipment""
6.1.1: The word ""allowance"" is eliminated, because the definition of wages includes allowances.
6.1.1: Sentence, ""This policy must be available to the public and socialized to the workforce, operations and suppliers, as well as
worker recruiters."" added ""... and implemented and monitored""."#Indicator

Comment (English)

21

6.1.1

22

6.1.1

23

6.1.1

"Proposed Sentences Indicator 6.1.1
Indicator sentence becomes:
6.1.1 (c) Nondiscrimination policies that apply to recruitment, giving work and wages and access to obtain training must be preparedand implemented. This nondiscrimination policy must include a prohibition on discrimination based on ethnic origin, caste, nationality,
religion, disability, gender, marital status, pregnancy, sexual orientation, gender identity, migrant type, migrant worker status,
membership in trade unions, political affiliation, and//// or age. This policy is available to the public and is socialized to labor,
operations and suppliers, as well as worker recruiters and implemented""- ""work equipment"" work is changed to ""work equipment""- The word allowance is eliminated, because the definition of wages includes allowances""Comment:- ""work equipment"" work is changed to ""work equipment""- The word allowance is eliminated, because the definition of wages includes allowances

24
25
26

6.1.2
6.1.2
6.1.2

27
28

6.1.2
6.1.2

29

6.1.2

Proposed changes:
6.1.1 (c) Nondiscrimination policies that apply to recruitment, giving work, wages, and access to obtaining training, promotion,
facilities, and work equipment must be prepared and implemented. This nondiscrimination policy must include a prohibition on
discrimination based on ethnic origin, caste, nationality, religion, disability, gender, marital status, pregnancy, sexual orientation,
gender identity, migrant type, migrant worker status, membership in trade unions, political affiliation, and//// or age. This policy must
be available to the public and socialized to workers, operations and suppliers, as well as worker recruiters."
6.1.2 This indicator has too many requirements and it is not auditable.
propose to add : implemented and monitored"- The word allowance is eliminated, because the definition of wages includes allowances- This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1"
In indicator 6.1.2 it is proposed to be deleted because the substance is the same and has been included in the proposed indicator 6.1.1"Indicator 6.1.2. deleted because it has been covered by indicators
6.1.1. by adding ""and implemented and monitored"".""Proposed Indicator 6.1.2:- The indicator is deleted because the substance is the same and has been covered in the proposed indicator 6.1.1 so that it isreduced."#

Indicator

Comment (English)

30

6.1.2

31

6.1.2

32

6.1.2

"Proposed indicator 6.1.2
Eliminating the word allowance, because the definition of wages includes allowances"
Proposed indicator 6.1.2 by changing the word "allowance", because the definition of wages already includes benefits. This indicator
should be removed because the substance is the same and has been included in the proposed indicator 6.1.1"The word allowance is eliminated, because the definition of wages includes allowances

33

6.1.2

34

6.1.2

35

6.1.2

36

6.1.2

37

6.1.2

38

6.1.2

39

6.1.2

This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1""Proposal:
This 6.1.2 indicator is removed because the substance is the same and has been covered in the proposed indicator 6.1.1.
Comment:- The definition of wages includes allowances""- The word allowance is eliminated, because the definition of wages includes allowances- This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1""Indicator 6.1.2 Proposed:- The word allowance is eliminated, because the definition of wages includes allowances- This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1""[I] 6.1.2- The word allowance is eliminated, because the definition of wages includes allowances- This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1""6.1.2 The word allowance is eliminated, because the definition of wages includes allowances
6.1.2 This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1""Indicator 6.1.2 (c) is proposed for:
- The word ""allowance"" is eliminated, because the definition of wages includes allowances- Indicator 6.1.2 (c) is removed because the substance is the same and has been included in the proposed indicator 6.1.1."
Proposed: Indicator 6.1.2 is removed because the substance is the same and has been included in the proposed indicator 6.1.1.
Comment: - The definition of wages includes allowances#

Indicator

Comment (English)

40

6.1.2

41
42

6.1.2
6.1.3

43

6.1.3

"Proposal:- The word allowance is eliminated, because the definition of wages includes allowances- This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1"
6.1.2: The indicator is removed because it has been covered by indicator 6.1.1.
6.1.3 This is difficult to achieve especially when much of the work and oil palm estates is piece rated especially in Indonesia andMalaysia. More thought needs to go into this"redundant with 6.1.2 for ""pay and benefit""

44

6.1.3

45
46

6.1.3
6.1.3

47
48
49

6.1.3
6.1.3
6.1.3

50

6.1.3

51

6.1.3

52

6.1.3

53
54
55

6.1.3
6.1.3
6.1.3

Remuneration is the total amount paid to an employee. It may include a salary or hourly rate, bonuses, commissions, or any otherpayment. In the view of the IRS, remuneration is the sum total of earnings and other taxable benefits and allowances."
I don't think that receiving equal remuneration (6.1.3) follows automatically from equal opportunities, incl. for pay and benefit (6.1.2).
One looks into the process, the other into the results of an equal opportunity policy. Both are important. In the P&C 2018 there was anindicator calling for evidence of equal remuneration.
This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1
In this 6.1.3 indicator it is proposed to be deleted because the substance is the same and has been included in the proposed indicator
6.1.1
Indicator 6.1.3. deleted because it has been covered by indicator 6.1.1. by adding "and implemented and monitored".
Indicator 6.1.3. deleted because it has been covered by indicator 6.1.1. by adding "and implemented and monitored".
"Proposal 6.1.3
This indicator is deleted because the substance is the same and has been included in the requirements in the indicator 6.1.1""Proposed Indicator 6.1.3:
This indicator is deleted because the substance is the same as the indicator 6.1.1""Indicator 6.1.3 Proposed:This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1""[I] 6.1.3
This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1"
Proposed: Indicator 6.1.3 is removed because the substance is the same and has been covered in the proposed indicator 6.1.1.
This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1
Indicator 6.1.3 proposed in order to: This indicator is removed, because the substance is the same and has been included in the
proposed indicator 6.1.1.

#Indicator

Comment (English)

56

6.1.3

57

6.1.3

Indicator 6.1.3 proposed in order to: This indicator is removed, because the substance is the same and has been included in the
proposed indicator 6.1.1.
"Notes :Remuneration is regulated based on work agreements, PP or PKB.

58
59

6.1.3
6.1.3

60

6.2

61

6.2

62

6.2

63

6.2

64

6.2

65

6.2

Proposal:This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1"
This indicator is removed because the substance is the same and has been included in the proposed indicator 6.1.1"6.1.3: The indicator is deleted because it has been covered by indicator 6.1.1.
6.1.1. added ""and implemented and monitored""."not clear why it is specified "until" does it means that after the benchmark is established there will be no need to calculate theprevailing wage ? I doubt.
"We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. "We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new
deadline should be set no later than the end of 2023 and a working group identified as accountable.
"We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. ""We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. "We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new
deadline should be set no later than the end of 2023 and a working group identified as accountable.

#

Indicator

Comment (English)

66

6.2

67

6.2

68

6.2

69

6.2

70

6.2

"We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. ""> Suggest RSPO: 6.2.2/6.2.3/6.2.4 about recruitment process would sit better under 6.7> LW should be retained as overarching concept from P&C 2018: this should be reflected in the indicators, not just the minimum wage.
It seems RSPO are taking a big step back on this topic.
>LW should be the top indicator and an interim measure clearly outlined whilst the wage calculation procedure is being finalised.
>Suggest RSPO to consult the NIWGs to address the LW issue and ensure balanced representation of NIWG members to look at the LW
topic.
>Ensure that LW concept is not hollowed out and implementation is not further delayed[Criteria 6.2: Pay and working and living conditions>There are 3 indicators 6.2.2/6.2.3/6.2.4 talk about recruitment process>Regarding prevailing wages, nothing to comment until RSPO releases the new guidance on prevailing wage calculation & procedure
which will be made available by end of 2024.
>The living wage problem depends on national regulations, context of the country, economic position of the country, position of thepalm oil sector in each country etc. and this should be addressed within the national interpretations>The shift of responsibility to NIWGs – concern about weak representation of SNGOs in the NIWGs]""We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. ""We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. """"We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. """#Indicator

Comment (English)

71

6.2

72

6.2

73

6.2

74

6.2

75

6.2

76

6.2

"We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. ""We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. "Achieving a living wage for all workers is essential. Please take into account the recommendations of the HRWG to explicitly refer toachieving a living wage in due time.
"We suggest the addition of a criteria related to working hours with specific instructions based on ILO recommendations or the local
legal context
A timeline for 2019 was set for this objective and the RSPO Labor task force was mentioned as responsible for it. A new deadline
should be set no later than the end of 2023 and a working group identified as accountable. "[HRSS] It is important to include LW at the criteria level to avoid a perceived lowering of the standards. Proposed wordings: "Criteria
6.2: Living Wage shall be paid to all workers, progressively. Working and living conditions for all Workers shall meet legal or industry
minimum standards""Addition of Editor in Criteria 6.2:
6.2: Wages and working conditions and life for all workers must meet the minimum legal or industrial standards without a reduction inwages if workers have worked in the specified work time.

77

6.2.1

Input to the use of the term Living Wage (LW), must be changed again to a decent Living Wage (DLW)""[HRSS] Propose to add ""d) Applicable labour laws, union and/or other collective agreements and documentation of pay andconditions are available to the workers in national languages and explained to them in a language they understand.""This is to ensure that the UoC explains applicable labour laws and makes copies of these laws available to them in a language they
understand. This is to ensure there is no perceived reduction in the standards as it was already included in indicator 6.2.1.(C) of the2018 P&C."

#

Indicator

Comment (English)

78

6.2.1

79
80

6.2.1
6.2.1

"[HRWG] Recommendation: Put the 2018 indicator back in. There should be no dilution of RSPO Standards in 2023.
It is important that the UoC explain applicable laws to workers and make copies available to them in the worker’s local languages sothat they understand. This should apply to all workers, be it migrant or transmigrant. Not all workers know about the applicable laws in
the country they are working. kers’ local language."
6.2.1 Wrong spelling.
"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.

81

6.2.1

We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations""Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.

82

6.2.1

83

6.2.1

We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations"the "evidence" that a copy of contract has been given to the worker is important. The evidence could help when the worker
interviewed by the auditor during the audit and they said didnt receive the copy of contract.
"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.

84

85

6.2.1

6.2.1

We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations""6.2.1. b. 'Explain' is one matter but the indicator should require objective evidence that the workers understand the content of theirwork contracts.
c. Employment contracts for workers should be duly signed by employer and employee and 1 copy should be retained by theemployee. ""6.2.1 - While the text has provisions in place to ensure that payments and conditions of employment are understood by theworkers, it does not require that the information is provided to workers before they enter employment"#

Indicator

Comment (English)

86

6.2.1

87

6.2.1

88

6.2.1

6.2.1 - While the text has provisions in place to ensure that payments and conditions of employment are understood by the workers,
it does not require that the information is provided to workers before they enter employment
While the text has provisions in place to ensure that payments and conditions of employment are understood by the workers, it does
not require that the information is provided to workers before they enter employment"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.

89

6.2.1

We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations""Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.

90

6.2.1

We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations""Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.

91

6.2.1

We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations.""The below could be important to add:
- prohibit zero hour contracts.
•If workers work away from their base location they should be compensated for any additional living costs.
•Workers should be provided with safe places to eat and rest.
•Workers should have access during working hours to hygienic toilets which are free of charge.
•Workers should have access to unlimited, clean drinking water within a reasonable distance of the work area which is available free ofcharge.
"#

Indicator

Comment (English)

92

6.2.1

"Indicator 6.2.1 A: Add to the "".... In accordance with national legal requirements, existing together work agreements (if applicable) orother agreements in accordance with laws and regulations ..... etc.).

93

6.2.1

94

6.2.1

95

6.2.1

96

6.2.1

97

6.2.1

98

6.2.1

99

6.2.1

Consideration:
In Indonesia, in addition to the Collective Labor Agreement there are also company regulations governing aspects of work order,
workers' rights and obligations, and other employment matters. Company regulations are also recognized as its existence based onIndonesian laws and regulations."
In indicator 6.2.1 For the phrase "These terms and conditions must include wages, regular working hours, discounts, overtime, pain
leave, the right to get a holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before
layoffs" proposed to be deleted . Because it is contradictory to the previous sentence
The sentence "These terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right to geta holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs" proposed to bedeleted. Because it is contradictory to the previous sentence"Indicator 6.2.1 (c) Proposed:
The sentence ""These terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right toget a holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs"" proposed to
be deleted. Because it is contradictory to the previous sentence""Proposal 6.2.1
It is proposed to be deleted the phrase ""These terms and conditions must include wages, regular working hours, discounts, overtime,sick leave, the right to get a holiday, pregnancy leave, reasons for termination of employment (layoffs), and notification period before
layoffs"". Because this requirement is contradictory to the previous sentence"
The sentence "These terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right to geta holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs" proposed to bedeleted. Because it is contradictory to the previous sentence"Proposed Indicator 6.2.1:
Delete ""these terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right to get aholiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs"" with reasons ofcontradictory with the previous sentence"
The need for changes to the indicator 6.2.1: Removing the phrase "These terms and conditions must include wages, regular working
hours, discounts, overtime, sick leave, the right to get a holiday, maternity leave, reasons for termination of employment (layoffs), andnotification period before layoffs "For reasons of contradictory to the previous sentence#Indicator

100 6.2.1

101 6.2.1

102 6.2.1

103 6.2.1

104 6.2.1

105 6.2.1

106 6.2.1

107 6.2.1

108 6.2.1

Comment (English)
Indicator 6.2.1 (c) Proposed to: Deleted the phrase "These terms and conditions must include wages, regular working hours, discounts,
overtime, pain leave, the right to get a holiday, pregnancy leave, reasons for termination of employment (layoffs), and notification
period Before layoffs ", because it is contradictory to the previous sentence.
"[I] 6.2.1
The sentence ""These terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right toget a holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs"" proposed to
be deleted. Because it is contradictory to the previous sentence""The phrase ""These terms and conditions must include
wages, regular working hours, discounts, overtime, sick leave, rights
get a holiday, maternity leave, reasons for termination of relationships
work (layoffs), and notification period before layoffs. ""deleted, because it was included in the previous sentence."
6.2 .1 The sentence "These terms and conditions must include wages, regular working hours, discounts, overtime, sick leave, the rightto get a holiday, pregnancy leave, reasons for termination of employment (layoffs), and notification period before layoffs" proposed to
be deleted. Because it is contradictory to the previous sentence
The sentence "These terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right to geta holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs" proposed to bedeleted. Because it is contradictory to the previous sentence
6.2.1 The sentence "these terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the rightto get a holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs" proposed to
be deleted. Because it is contradictory to the previous sentence"Proposal:
The sentence ""These terms and conditions must include wages, regular working hours, discounts, overtime, pain leave, the right toget a holiday, maternity leave, reasons for termination of employment (layoffs), and notification period before layoffs"" proposed to
be deleted. Because it is contradictory to the previous sentence"
Proposal 6.2.1 is proposed to be deleted the phrase "These terms and conditions must include wages, regular working hours,
discounts, overtime, sick leave, the right to get a holiday, maternity leave, reasons for termination of employment (layoffs), andnotification period before layoffs". Because this requirement is contradictory to the previous sentence
6.2.1: The phrase "These terms and conditions must include wages, regular working hours, discounts, overtime, sick leave, the right toget a holiday, pregnancy leave, reasons for termination of employment (layoffs), and notification period before layoffs." deleted,because it was included in the previous sentence.

#

Indicator

Comment (English)

109
110
111
112
113
114

6.2.1
6.2.1
6.2.1
6.2.1
6.2.1
6.2.2

6.2.1 Improve writing in casualties due to diseases and maternity.
It can be specified as "disability" and not "low"6.2.1. (C) This is not necessarily stipulated in the contract, it is usually in the rit or mention that the labor law guidelines are met.
Changing the word "casualties" makes it known that there is a decoupling and it is not so.
[Abidjan WS] 6.2.1 c. Removed 'all workers' to specified to 'permanent and full time worker'"[HRSS] To adopt Indicator 6.6.2(C) of the 2018 P&C which requires the UoC to introduce a specific labour policy and procedures are
established and implemented where temporary or migrant workers are employed. This is to ensure that there are precautionary
mechanisms in place to prevent any of the ILO Forced Labour Indicators.

115 6.2.2
116 6.2.2
117 6.2.2
118 6.2.2
119 6.2.2
120 6.2.2
121 6.2.3

Propose to add, ""Where temporary or migrant workers are employed, a specific labour policy and procedures are established andimplemented."""6.2.2 This indicator merely requires a procedure. It does not support ethical hiring or the promotion of fairness. It is an ineffective
indicator.
6.2.2 Not made available upon request. The procedures should be socialized and a summary of procedures (in a form of a handbook)should be provided to all workers in appropriate languages.
"Valid and substantiated reasons must be given for any dismissal.
A notice period must be respected, in accordance with national labor law.""Valid and substantiated reasons must be given for any dismissal.
A notice period must be respected, in accordance with national labor law."
Valid and substantiated reasons must be given for any dismissal. A notice period must be respected, in accordance with national labor
law.
"There is a guide note for indicators 6.2.2: Severance payment after layoffs must be paid in a maximum period of 30 days"
"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.
We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations"#

Indicator

122 6.2.3

123 6.2.3
124 6.2.3

125 6.2.3
126 6.2.3

127 6.2.3
128 6.2.3
129 6.2.3
130 6.2.3
131 6.2.3
132 6.2.3

133 6.2.3

134 6.2.3

Comment (English)"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them.
We need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations"
RSPO shall provide more clarification/guidance on the amendments to the employment contract that are mandated by law (e.g.,
minimum wages, etc.) and/or subjected to changes in the CBA shall be exempted from this indicator.
"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them."
Propose to move to 6.2.1 as 6.2.3 same topic regarding employment contract"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them."[Accra WS] 6.2.3 defined the extend and scope of amendment that need agreement. The agreement will need to be documented?
Documents must be written in a language that can be understood by all stakeholders. A taskforce could be mobilized to help
smallholders better understand their contracts and legal obligations, as well as their rights - and above all how to assert them.
6.2.3 The indicator does not provide the opportunity for a collective agreement to amendments. In most labor situations,representatives are recognized.
[Sandakan, 21 June 2023] Propose to have this indicator to be absorbed into 6.2.1 as another key point"Indicators are deleted and combined to indicators 6.2.1.
Because it is still in one topic related to work contracts.""Addition of editors to indicators 6.2.3:
6.2.3 (c) Changes in work contracts must be negotiated transparently and agreed by workers voluntarily, without pressure andcoercion.""Proposed 6.2.3:
Combining indicators 6.2.3 with 6.2.1 because it is still in one unit related to work contracts in indicators 6.2.1 (Repetition ofIndicators)"
6.2.3. Indicators are deleted and combined to indicators 6.2.1. Because it is still in one topic related to work contracts.

#Indicator

Comment (English)

135
136
137
138

6.2.3
6.2.3
6.2.3
6.2.3

[Jakarta WS] 6.2.3 should be consolidated into 6.2.1
Improve the writing, "6.2.3 (c) The modifications of the employment contract must be agreed with the worker."
Improve the writing, "6.2.3 (c) The modifications of the employment contract must be agreed with the worker."
In Colombia it is not viable that the signing of the contract is made in the country of origin of the worker despite exercising his work inanother country, the signing of the contract must be made according to the legislation of each country
change the writing, for - with
Improve the writing, "6.2.3 (c) The modifications of the employment contract must be agreed with the worker."
6.2.4 The migrant worker must understand the content of the contract, and their scope of work with no contract substitution and be
provided a copy contract in their language. Illiterate migrant workers would have to be treated as special cases.
"This indicator requires more guidance on the intents of this indicator or otherwise this indicator shall be rephrased to a more
auditable statement. Suggest clearer guidance to comply with this indicator. Following items/questions to be considered in theguidance documents:

139 6.2.3
140 6.2.3
141 6.2.4
142 6.2.4

1. What is the cut–off date for the international migrant workers?
2. Should auditor travels to the home country just to ensure the UoC comply with this indicator?
3. What are the documentation required for UoC to prove the migrant workers sign the contract in their home country?

143 6.2.4

144 6.2.4
145 6.2.4

146 6.2.4

4. Verification solely from interview by the auditor would be doubtful and can be influenced by various factors (e.g., language barriers,
fear of vulnerability, etc.).""Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them."
Documents must be written in a language that can be understood by all stakeholders. A taskforce could be mobilized to help
smallholders better understand their contracts and legal obligations, as well as their rights - and above all how to assert them.
"Documents must be written in a language that can be understood by all stakeholders.
A taskforce could be mobilized to help smallholders better understand their contracts and legal obligations, as well as their rights - andabove all how to assert them."[Accra WS] 6.2.4 define 'source country' the country that sourcing of workers?

#Indicator

Comment (English)

147 6.2.4"Addition of Editor in Indicator 6.2.4:

148 6.2.4

6.2.4 International migrant workers recruited in their home country must sign a certification unit work contract in their home country.
The work contract may not reduce the rights of local workers.""I don't know if it is applicable in all cases since each country has its own regulation.

149 6.2.4
150 6.2.4
151 6.2.4
152 6.2.4

153 6.2.4
154 6.2.4

155 6.2.4
156 6.2.4

157 6.2.5

Writing proposal to avoid confusion in case of the legal framework, 6.2.4 International migrant workers who are hired in the country oforigin will sign the contract in the country of the certification unit where they will carry out their activities."
6.2.4 International migrant workers who are hired in the country of origin will sign the contract in the country of the certification unit
where they will carry out their activities. (This must be so that the UDC has no implications and legal)
6.2.4 It is not viable that a employment contract be signed in the country of origin of the person working in another country, thewriting must be changed, the legislation of each country must be based.
Indicator does not apply, it has no legal basis that supports different conditions to the country where it will work.
"6.2.4 This can be illegal in some countries.
The writing should change for:If the UDC hires migrant workers, it must comply with the applicable legislation as well as with the migratory processes required in the
country where working will work."
In Colombia it is not viable that the signing of the contract is made in the country of origin of the worker despite exercising his work inanother country, the signing of the contract must be made according to the legislation of each country"Writing proposal to avoid confusion in case of the legal framework,
6.2.4 International migrant workers who are hired in the country of origin will sign the contract in the country of the certification unit
where they will carry out their activities."
Check the writing, the indicator is not understandable,"[Abidjan WS] 6.2.4 - to rewords - to provide clear definition of 'source country' . It should be reworded as 'Employment contract ofInternational Migrant Workers hired shall be signed at the country or origin.'source country can refer to the UoC country - as sourcing party"
6.2.5. A revision is needed because there is an assumption that non-certified units would have lower-grade infrastructure thancertified units. There is an element of bias here. Based on our experience of visiting certified units, there are instances where workers'
housing in the certified unit is below the acceptable living standard.

#Indicator

158 6.2.5
159 6.2.5
160 6.2.5
161 6.2.5
162 6.2.5
163 6.2.5
164 6.2.5
165 6.2.5
166 6.2.5
167 6.2.5

168 6.2.5

Comment (English)
6.2.5 Spelling error. There are many spelling errors. This is unacceptable for an international standard. RSPO should at least do a spell
check before releasing this document for public comments.
we need to define "adequate" and amend the ILO recommendations dating from 1961 with more up-to-date considerations"we need to define ""adequate"" and amend the ILO recommendations dating from 1961 with more up-to-date considerations"
propose to add"electricity supply" as it is also a basic need of a household and from financing perspective, it must be clear whether thefacilities for worker, especially water and electricity supply, are free of charge or must be subsidized by the company.
6.2.5 Single bracket without closure.
we need to define "adequate" and amend the ILO recommendations dating from 1961 with more up-to-date considerations
6.2.5 C Adequately housing under international law means having secure tenure, in the future they are not worry about being evicted
or if the home and lands taken away .Then add... to have access to appropriate services, to schools , and employment
Suggest to reinforce the requirement i.e. to make sanitation facilities available and sufficient in the plantation fields [Issue: There areinsufficient sanitation facilities in the plantation fields]
Propose to rewording the TBP in the bracket into: (a reasonable timeline of 5 years). Reason being is every unit of certification havedifferent size of plantation, some unit can achieve it in 5 years, and some larger plantation might need more time to achieve it.
"Please consider below inputs:•There could be controls if national standards are present but weak. The standard could require as a minimum that theaccommodation should be safe, of solid construction and have natural and artificial light, an uninterrupted power supply, watersupply, protection against weather conditions, ventilation and, when necessary, heating. Accommodation should be located in abuilding where high-risk operations do not take place and away from loud sources of noise. Amenities should also include designatedcooking areas.
•This criteria could also state that if accommodation is provided for men and women in the same building, separate rooms must be
provided for each gender, unless residents choose to share a double room.
•Need to have controls over the cost of accommodation – this should not exceed market rates.
•Residents must also have the right to leave the accommodation at any time and must not be required to live in the designatedaccommodation.
""We need more clarity... does the text mean.. Where accommodation is provided?
Currently, it is open for interpretation as it may read that the company MUST provide accommodation"

#Indicator

169 6.2.5

170 6.2.5

Comment (English)"In this 6.2.5 indicator there are several proposals, namely: - The sentence ""storage that can be locked"" is deleted, because theworker has received a locked house facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law.""6.2.5 Points a. In the ""safe drinking water supply"" to be changed to ""the affordability of drinking water"".
Consideration :171 6.2.5

172 6.2.5
173 6.2.5

174 6.2.5

175 6.2.5

In a large plantation work area, it is not possible to supply drinking water to the field, but can provide a source of clean water or refill
water depot in residential areas.
""Proposed indicator 6.2.5:- The sentence ""storage that can be locked"" is deleted, because workers have gotten home facilities that can be locked by the dooretc.
- sentence ""(including safe drinking water supply)"" removed and revised into water supply- Proposed to be deleted the sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961
if there is no related law that applies"" deleted. Enough to refer to national law."
What is meant by retired time? better call: workers with a fixed work status"- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law.""The word ""locked storage"" deleted, because workers have gotten home facilities can be locked and safe, including if this indicator isrelated with an indicator of 6.7.2 (c) identity documents, passports, andThe work permit issued by the government must be stored by worker.""- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law."#

Indicator

176 6.2.5

177 6.2.5

178 6.2.5

179 6.2.5

180 6.2.5

181 6.2.5

182 6.2.5

Comment (English)
Indicator 6.2.5 - The sentence "storage that can be locked" is deleted, because the worker has received a locked home facility sentence "(including safe drinking water supply)" deleted - sentence "and/or international. See ILO Guide on Housing
Recommendations Worker No. 115 of 1961 if there is no related law that applies "deleted. Enough to refer to national law.
"Indicator 6.2.5 (c) Proposed:- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law.""- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law.""6.2.5 Sentence ""Locking storage"" deleted, because workers have gotten home facilities that can be locked.
6.2.5 sentences ""(including safe drinking water supply)"" deleted
6.2.5 sentences ""and/or international. See ILO Guide on Worker Housing Recommendations No. 115 of 1961 if there is no related lawthat is applicable"" deleted. Enough to refer to national law.
""[I] 6.2.5- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law.""6.2.5 Sentence ""Locking storage"" is deleted, because workers have got a locked house facility- Sentence ""(including safe drinking water supply)"" deleted
6.2.5 sentences ""and/or international. See ILO Guide on Worker Housing Recommendations No. 115 of 1961 if there is no related lawthat is applicable"" deleted. Enough to refer to national law.""Addition of editors to indicators 6.2.5:
6.2.5 (c). . . . . . . . . . The facilities and equipment provided must be gender and child -friendly and meet national and/or international
legal requirements."

#

Indicator

183 6.2.5

184 6.2.5

185 6.2.5

186 6.2.5

187 6.2.5

188 6.2.5

189 6.2.5

Comment (English)"Indicator 6.2.5 (c) is proposed for:1. The phrase ""Locking Storage"" is deleted, because workers have gotten home facilities that can be locked.
2. sentence ""(including safe drinking water supply)"" deleted.
3. sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" is deleted. Enough to refer to national law.""Word ""(including safe drinking water supply)""
deleted, because there are certain natural conditions
Having difficulty getting water quality for safe drinking. The provisions of the Indonesian government are providing clean water
facilities.
"
Proposed Indicator 6.2.5 - The sentence "storage that can be locked" is deleted, because the worker has received a locked homefacility - sentence "(including safe drinking water supply)" deleted - sentence "and/or international. See ILO Guide on
Recommendations Workers' Housing No. 115 of 1961 if there is no applicable related law is "deleted. Enough to refer to national law.
"Point b ""(a maximum scheduled plan of 5 years)""
revised to ""a fair schedule plan for 5 year"".
This is because each certification unit has a size different plantations, some units canachieved it before 5 years, and several plantations The bigger one may require more time to achieve it."
"Proposal:- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law.""Proposed indicator 6.2.5- The sentence ""storage that can be locked"" is deleted, because the worker has got a locked home facility- Sentence ""(including safe drinking water supply)"" deleted- sentence ""and/or international. See ILO Guide on Workers' Housing Recommendations No. 115 of 1961 if there is no applicablelaw"" deleted. Enough to refer to national law."
Note Guidelines: Accommodation and gender-friendly facilities and children such as examples of sanitation facilities that haveadequate lighting, separating female and male booths in order to minimize the potential for sexual violence.

#

Indicator

190 6.2.5

191 6.2.5
192 6.2.5
193 6.2.5

194
195
196
197

6.2.5
6.2.5
6.2.6
6.2.6

198 6.2.6
199 6.2.6
200 6.2.6
201 6.2.6

Comment (English)"6.2.5: The word ""locking storage"" is deleted, because workers have obtained housing facilities that can be locked and safe, including
if this indicator is related to indicator 6.7.2 (c) Identity documents, passports, and work permits issued by the government must be
stored by workers.
6.2.5: word ""(including safe drinking water supply)"" removed, because there are certain natural conditions that cause difficulty
getting water quality for safe drinking. The provisions of the Indonesian government are providing clean water facilities.
6.2.5: point B ""(a maximum scheduled plan of 5 years)"" Revised to ""a fair schedule plan for 5 years"".
This is because each certification unit has a different plantation size, some units can achieve it before 5 years, and some larger
plantations may require more time to achieve it."
6.2.5 Define the plan of the plan, as is in the 2018 version
6.2.5 Define the plan of the plan, as is in the 2018 version
In the case in which a producer aspires to receive his first certification that the auditor, numeral a) or numeral b) must apply,
understanding that when new acquisitions are established, producers who are entering the certification scheme could be referenced
and could Present to audit with a "plan" that demonstrates management and advances in infrastructure improvements.
6.2.5 Place in Spanish version temporary at Item B[Abidjan WS] 6.2.5 a) Provide clarity on what is consider 'adequate'
6.2.6 This is a vague indicator. What is meant by "access to adequate, sufficient, and affordable food"? Who determines this?
The terms "adequate" and "affordable" need to be defined and set against the wage conditions of workers in different geographicalareas and players.
"The terms ""adequate"" and ""affordable"" need to be defined and set against the wage conditions of workers in different
geographical areas and players."
The terms "adequate" and "affordable" need to be defined and set against the wage conditions of workers in different geographicalareas and players.
[Accra WS] 6.2.6 define 'make effort' how to audit? How to audit adequate, sufficient and affordable?
[Sandakan, 21 June 2023] Repetitive use of adequate and sufficient.

#Indicator

202 6.2.6

Comment (English)"6.2.6 This indicator should be clarified.
There are you who provide food due to the remoteness of its facilities or because it has camps; There are other UDCs that have thefood service and, there are others, that only have a space so that their workers can eat there ... the conditions can be very different.

203 6.2.6
204 6.2.6
205 6.2.7
206 6.2.7
207 6.2.7

208 6.2.7
209 6.2.7
210 6.2.7

211 6.2.7

212 6.2.7

It happened to me in a UDC that we wanted to remove the soda, we hired a nutritionist and we changed the menu (for a healthy one)and the workers were dissatisfied because they wanted to consume the black soda to which they were accustomed as well as the large
and poorly balanced portions .. ."This has generated many interpretations during audits is not clear how it can be demonstrated.
[Abidjan WS] 6.2.6 what is the definition or clear requirement on 'adequate, sufficient, and affordable'. Affordable and sufficient foodis beyond the control of UoC. What is the exact expectation?
"Documents must be written in a language that can be understood by all stakeholders."
Documents must be written in a language that can be understood by all stakeholders[Accra WS] 6.2.7 Some tasks are meant to be on seasonal (e.g. FFB harvesting), turning this seasonal tasks into permanent hiring - maylead to workers hired with no other tasks for them. This may also lead to unintended consequences that the same worker cannot be
hired after three round of hiring.
Documents must be written in a language that can be understood by all stakeholders
The term & condition of the three sucessive times shall be clarified and explained in the guidance for UoC to comply. Without clear
direction, auditors can manipulate and interpret this term differently.
Suggest to frame around the jobs, i.e. if a work task is filled by temporary or casual workers, but is an ongoing task needed, then it
constitutes core work and should be filled permanently. Suggest that the taskforce clearly describes the exceptions where
temporary/casual work might be allowed and provides a clear timeframe for those jobs. Jobs that are continuously needed to be filled
by default should not be done by temps. [It’s now effectively allowing keeping workers in temporary roles for a series of appointments– if a job needs filling continuously it’s part of core work and should be filled with a permanent staff member].
6.2.7 This will force employees not to hire any workers for casual work after the 3rd time because of the need to provide permanent
employment opportunities. It creates a situation where seasonal job opportunities will be given to newcomers and locals depending on
this will lose the opportunity to earn consistent casual income. Rethinking this indicator is suggested.
In West and Central Africa, casual and temporary workers are usually hired to support the oil palm plantations requirements during
peak production seasons. It would be difficult to sustain this workforce, or provide them alternate work, during non-peak productionseasons. Further, the term “successive time” needs to be clarified. 3 over a 3-year period?

#Indicator

213 6.2.7

214 6.2.7
215 6.2.7
216 6.2.7

Comment (English)[Accra WS] 6.2.7 - should not use 'successive time' unless it is clearly defined the engagement duration and what about is there is a gap
between hiring (eg. a worker is hired for a month to harvest fruit, second rehired after three months and third rehired only after ayear)?
Every country will have different ruling to protect the temporary workers and suggest not to specify the frequency of contract renewal.
[Sandakan, 21 June 2023] The definition for Casual Workers and Temporary Workers are available in the standard. To make it clearer,the definition for Casual Job and Temporary Job should be provided along with the list of activities.
"In this 6.2.7 indicator there are several proposals, namely:- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.

217 6.2.7

218 6.2.7- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented""""- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.
- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented"""6.2.7 In the sentence "Freelance workers and temporary workers who have been employed for the same job 3 times in a row, to beoffered to become permanent workers at the same job on the fourth occasion" to add the words "unless it has been stipulateddifferently in national laws and regulations"
Consideration :Matters regarding freelance workers or workers with certain time work agreements (PKWT) for the context of Indonesia already havetheir own requirements in accordance with the laws and regulations.

#

Indicator

219 6.2.7

Comment (English)"Proposed indicator 6.2.7:- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.

220 6.2.7- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented""""Proposed 6.2.7:- Definition of Core Workers in Draft 2 for gardens and factories must be clarified more thoroughly. The definition mentioned by thedraft 2 includes all activities or types of work in the factory and oil palm plantations. In the reality of field practice, not all types of work
enter the core worker category- Indicator improvement 6.2.7 becomes""The granting of permanent and retail work (freelance workers and temporary workers) is carried out for all core work in thecertification unit in accordance with applicable laws and regulations"".
This is because the applicable laws and regulations in Indonesia allow PKWT for core work under certain conditions (peak crops)

221 6.2.7- It is proposed to be deleted the phrase ""freelance workers and temporary workers who are re-employed for the same job more than
three times in a row given the opportunity to become a fixed retail worker at the time of giving the fourth time. This offer must be
documented""""Indicator 6.2.7 is proposed to:
1. Claimed again for the definition of core workers for gardens and factories, not all types of work enter the core worker.
2. Addition to the first sentence, to be: ""Giving permanent and retail work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.
3. The sentence ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row
given the opportunity to become a fixed retail worker when giving the fourth time. This offer must be documented"""#

Indicator

222 6.2.7

223 6.2.7

224 6.2.7

225 6.2.7

Comment (English)
Indicator 6.2.7 - It is necessary to clarify again for the definition of core worker for gardens and factories, not all types of work enter
the core worker - the addition of the first sentence, to: "the provision of permanent and reticine work (freelance workers andtemporary workers) is done for all Core work in the certification unit in accordance with applicable laws and regulations ". Because theapplicable laws and regulations allow PKWT for core work under certain conditions. - The phrase "freelance workers and temporary
workers who are re-employed for the same job more than three times in a row given the opportunity to become a fixed time worker at
the time of giving the fourth time. This offer must be documented""Need to be clarified again for the definition of core worker(Core work) for gardens and factories, because they are not
All types of work enter the core worker.
Core work in a certain period of time is possible
requires seasonal workers (for example harvesters
peak harvest).
""This sentence is deleted, ""freelance workers and workers
While those who are re-employed for the same job more than three times in a row are given the opportunity to become a fixed time
worker when giving the fourth time. This offer must be documented """"6.2.7 It is necessary to be clarified again for the definition of core workers for gardens and factories, not all types of work enter thecore worker
6.2.7 Addition to the first sentence, to: ""Giving permanent and retail work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.
6.2.7 The sentence ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row
given the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented"""#

Indicator

226 6.2.7

Comment (English)"[I] 6.2.7- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.

227 6.2.7- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented""""Indicator 6.2.7 Proposed:- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.

228 6.2.7- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented""""- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.
- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented"""#

Indicator

229 6.2.7

230 6.2.7

231 6.2.7

232 6.2.7

233 6.2.7

Comment (English)"6.2.7 It is necessary to be clarified again for the definition of core workers for gardens and factories, not all types of work enter thecore worker
6.2.7 Addition to the first sentence, to: ""Giving permanent and retail work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.
6.2.""The phrase ""Giving permanent and retaining work
done for all core work in the certification unit ""added ""In accordance with national regulations
valid ""."
"Additional Definition: Enter the type of core work such as the Definition of PNC RSPO 2018 - All Agricultural and Milling Activities are
Considered Core Work, E.G. Planting, Harvesting, Fertilizing, Maintenance; FFB Sorting and Grading; Machine-Technical Maintenance;and machine operation""6.2.7: The sentence "Permanent and full-time employment is carried out for all core work in the unit of certification" is added "inaccordance with applicable national regulations".
6.2.7: It needs to be clarified again for the definition of core workers (core work) for gardens and factories, because not all types ofwork enter the core worker. Core work in a certain period of time is possible to require seasonal workers (for example harvesters at
the peak harvest).
6.2.7: This sentence is deleted, ""loose workers and temporary workers who are re-employed for the same job more than three times
in a row given the opportunity to become a fixed retail worker when giving the fourth time. This offer must be documented """"- It needs to be clarified again for the definition of core worker for gardens and factories, not all types of work enter the core worker- Addition to the first sentence, to be: ""Giving permanent and retired work (freelance workers and temporary workers) is carried out
for all core work in the certification unit in accordance with applicable laws and regulations"". Because the applicable laws andregulations allow PKWT for core work under certain conditions.
- The phrase ""freelance workers and temporary workers who are re-employed for the same job more than three times in a row given
the opportunity to become a fixed time worker at the time of giving the fourth time. This offer must be documented"""#

Indicator

234 6.2.7

235 6.2.7
236 6.2.7

237 6.2.7

Comment (English)"Proposed changes:
6.2.7 Provision of permanent and retail work (freelance workers and temporary workers) is carried out for all core work in thecertification unit in accordance with applicable laws and regulations.
Comment:
Definition of Core Work/Core Work.
The last sentence is deleted."
It needs to be clarified again for the definition of core workers for gardens and factories, not all types of work enter the core worker.
"Proposed 6.2.7:(1). It needs to be clarified again for the definition of core workers for gardens and factories, not all types of work enter the core
worker, (2). The addition in the first sentence, becomes: ""Provision of permanent and retail work (freelance workers and temporary
workers) is carried out for all core work in the certification unit in accordance with applicable laws and regulations"". Because theapplicable laws and regulations allow PKWT for core work under certain conditions, (3). The sentence ""freelance workers andtemporary workers who are re-employed for the same job more than three times in a row given the opportunity to become a fixed
time worker at the time of giving the fourth time. This offer must be documented""""There is a guide note for indicators 6.2.7:
Note the guide in this indicator that workers should not be employed repeatedly for temporary contracts. Then, the referral used is areferral in regulations at the national level if there is a national law in force. Coalition records, in adopting national regulations orapplicable national law, what needs to be ascertained is the regulation of the requirements fulfilled is the same as the prevailingstandards in 2018 or the regulation is better. So. This discussion refers to national regulations if there is a national law that applies with
the note that the regulated requirements must apply equally and/or better.

238 6.2.7

239 6.2.7

Note: Calculation of Living Wage, Shall Refer to ILO Convention Number 26, 1928 on the Minimum Wage-Fixing Machinery and ILO
Convention Number 131, 1970 on Minimum Wage Fixing.
Facilities include but not limited to schools, clinics, housing, school bus, childcare, etc.
"
"notes:
1. Replace ""given the opportunity to"" become ""automatically changed""
2. Urge RSPO to make a list/ criteria for determining the types of core work, non -core that apply in various fields in accordance withthe characteristics of land and planting years."
6.2.5 Leave in the 2018 version

#Indicator

240 6.2.7

241 6.2.7
242 6.2.7

243 6.2.7
244 6.2.7

245 6.2.7
246 6.2.7
247 6.2.7

248 6.2.7

249 6.2.7

Comment (English)
It should not be explained that the UDC is the one who must offer the possibility of becoming full -time workers, the subject of the
fixed should be reviewed, or if it is considered permanent since it is seasonal work the advisable mechanism for hiring is hiring
Temporary since it makes it easier for them to go to the place where their work is required. I suggest that the indicator is how it was in
the 2018 version.
6.2.7 The temporality and approach of national legislation, elimination of direct fixed contraction and the national legislation of eachcountry is complied with
It can be an error in translation, and instead of talking about fixed jobs you must talk about permanent jobs as referenced in thedefinition of "work" of the English version. It is important to make these revisions in the translations because it can generateincongruities when validating the indicator.
6.2.7 Establishing fixed positions after recurring rectation is not viable, since within the production cycle of the palm there areproductive peaks, temporary hiring is complied with the National Law of Guatemala.
"Establishing fixed positions after a recurring rectation is not viable, since within the productive cycle of La Palma there are productive
peaks, temporary hiring is complied with the Colombian national law, as in other countries.
It can be an error in translation, and instead of talking about fixed jobs you must talk about permanent jobs as referenced in thedefinition of ""work"" of the English version. It is important to make these revisions in the translations because it can generateincongruities when validating the indicator."
I think this indicator for auditors is not clear, creates confusion and interpretations.
It is suggested that the indicator is as the 2018 version was. Not in all countries can be applied and it should be taken into account that
palm cultivation is due to production peaks cycles, production is not constant.
"This indicator is not applicable as written.
Work contracts must comply with the labor legislation of each country and must be consistent with the seasonality of the work (forexample, production peaks).
If it is left as it will cause many non -conformities because the auditors will take it literally."
What is the definition of a fixed contract vs. indefinite? It is not clear that you want in the indicator. The working conditions they
demand refers to the certification unit must hire? or if the law allows essential field activities through contractors? as long as it is a
fixed contract?
It should not be explained that the UDC is the one who must offer the possibility of becoming full -time workers, the subject of the
fixed should be reviewed, or if it is considered permanent since it is seasonal work the advisable mechanism for hiring is hiring
Temporary since it makes it easier for them to go to the place where their work is required. I suggest that the indicator is how it was in
the 2018 version.

#Indicator

250 6.2.7
251 6.2.7

252 6.2.8
253 6.2.8
254 6.2.8
255 6.2.8

256 6.2.8
257 6.2.8
258 6.2.8

259 6.2.8
260 6.2.8

Comment (English)
It is suggested that the indicator is as the 2018 version was. Not in all countries can be applied and it should be taken into account that
palm cultivation is due to production peaks cycles, production is not constant.
[Abidjan WS] Define what is core work, what is the timeframe for the contract and what is the period defined as 'successive time'. Thismay create unintended outcome - where casual worker 'fruit collector or harvester' who will be hired on daily basis - may not now beable to hire to do the job after three contracts timeframe. Does it mean if the worker is hired on daily basis - it can only be limited tohire for three days?
6.2.8 c. There is a possibility that an agreed deduction for loan repayment could cause the wage to be below the minimum. This needs
to be addressed.
6.2.8.f For how long should this commitment last?
[Accra WS] 6.2.8 f) define day wage - and the duration where this need to be pay. e.g. continuous storm for 1 week - should the UoC
pay the whole week? What about for seasonal workers/ or workers on hourly?
Sustained objection: This is contradict with the Employment Act of Malaysia. The workers who turned up for full days work offered in amonth are eligible for national minimum wage. However, if the workers are earning less than national minimum wage due to low
productivity, there will still be some statutory deductions (electricity/water, insurance, EPF) which brings their take home salary below
the legal/CBA minimum wage.
Suggest to change "explained" to "made available".
[Accra WS] 6.2.8(C) minimum wages - is gross/net? Removed or other from (Statutory or other) - as this will create different
interpretation that UoC need to bear workers' taxes and/or loan.
We have comments on 6.2.8 (c) F. We disagree with this point since not all companies have sufficient reserves to deal with mid or
long-term emergencies, and the consequences can be dramatic. An example could be the covid emergency, natural disasters such as
hurricanes in Central America where plantations have been partially or totally lost, during which thousands of companies wentbankrupt. This is a very complex issue that must be addressed in conjunction with each country's government. We propose to maintainthe payment of health services and a percentage of the salary to be agreed upon at the country level (for cases of force majeure in the
mid or long term).
Please define a day wage
"In the 6.2.8 indicator there are several proposals, namely:- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance with applicablelaws and regulations""- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure).
"#Indicator

261 6.2.8

Comment (English)"6.2.8 points c. Please explain what is included as a type of piece.
What if the worker does make mistakes based on the rules agreed upon in a joint work agreement should be given a fine?
What about the deductions that are in accordance with the laws and regulations such as employment insurance, health insurance, oldage insurance insurance in Indonesia known as BPJS. Is this included the intended discount? What about monthly discounts because
workers take staple goods in the cooperative?
As long as the intended type of discount is clear, based on an agreement between workers and the certification unit, or based on laws
and regulations, it should not be seen as a violation of the 6.2.8 indicator of this C.
6.2.8 points D and f.
Point D to be deleted because the certification unit does not recognize workers who are family members. All workers are known as one
particular individual.

262 6.2.8

263 6.2.8

264 6.2.8

Point F to be explained again as Kahar's conditions are relevant for points F because of many Kahar conditions where the certification
unit will be difficult to operate so that businesses cannot run for a long time, for example: war conditions, political upheaval, large
natural disasters, etc. In conditions cannot operate it will be difficult to pay workers' wages.""- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance withapplicable laws and regulations"".
- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure).""- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance withapplicable laws and regulations""- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure)."Proposed on indicators 6.2.8: - Points C, the sentence "may not cause reduction in wages to below the minimum wage" changed to "inaccordance with applicable laws and regulations" - Poin F, the certification unit must be committed to paying wages according to thelaws and regulations -The applicable army if there is a state of kahar (force majeure).

#Indicator

265 6.2.8

266 6.2.8

267 6.2.8

268 6.2.8

269 6.2.8

270 6.2.8

Comment (English)"Point a) sd f): added ""according to the rules
valid ""
Notes:In accordance with PP 36 of 2021 Article 65: The total amount Cutting wages at most 50% of each payment of wages received byworkers.""'Proposed Indicator Improvement 6.2.8:- Points C, the phrase ""may not cause reduced wages to below the minimum wage"" revised to ""in accordance with applicable laws
and regulations""- Improvement of points F, becoming a certification unit must be committed to paying wages in accordance with the applicable laws
and regulations in the event of a state majeure.
""Indicator 6.2.8 (c) Proposed:- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance with applicablelaws and regulations""- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure).""[I] 6.2.8- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance with applicablelaws and regulations""- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure).
""'Proposed Indicator 6.2.8:- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance with applicablelaws and regulations""- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure).
"
6.2.8 Points a) SD f): added "according to applicable regulations"#

Indicator

271 6.2.8

272 6.2.8

273 6.2.8

274 6.2.8
275 6.2.8
276 6.2.8

277 6.2.8

278 6.2.8
279 6.2.8
280 6.2.8

Comment (English)"Indicator 6.2.8 (c) is proposed for:
1. Points C, the phrase ""may not cause reduced wages to below the minimum wage"" changed to ""in accordance with applicable laws
and regulations"".
2. Point F is changed to ""the certification unit must be committed to paying wages in accordance with the applicable laws andregulations in the event of a state majeure""."Indicator 6.2.8 (c) is proposed for: (1). Points C, the phrase "must not cause a reduction in wages to below the minimum wage"changed to "in accordance with applicable laws and regulations". (2). Point F was changed to "the certification unit must be committed
to paying wages in accordance with the applicable laws and regulations in the event of a state majeure".
"Proposed changes in indicators 6.2.8 points c and f:c. All workers must receive a salary slip that shows all payment details and cuts. Deductions (compulsory or other) in accordance withapplicable laws and regulations.
f. The Certification Unit must be committed to paying wages in accordance with the applicable laws and regulations in the event of astate of kahar (force majeure)"[Jakarta WS] 6.2.8 c. remove the word 'all' - just '.... payslip showing details...' as it will create challenges in auditing - what constitute'all details'.
6.2.8: This sentence is deleted "pieces (mandatory or other) may not cause reduced wages to below the minimum wage""This sentence is deleted ""pieces (mandatory or other)
may not cause a reduction in wages to under the minimum wage """"Proposal:- Points C, the phrase ""may not cause a reduction in wages to below the minimum wage"" changed to ""in accordance with applicablelaws and regulations""- Points F, the certification unit must be committed to paying wages in accordance with the applicable laws and regulations in theevent of a kahar (force majeure)."Improve the definition "Force Mayor", in the list of definitions the concept of force majeure is left very wide, the scope should be
limited.
Item F: Define “Force majeure case”, or leave it at the discretion of the company according to its criteria and its analysis, both legal orinternal criteria.
Define the concept of "force majeure", a mechanism must be determined to validate the absence for various reasons, it isrecommended that it be subject to national legislation.

#Indicator

281 6.2.8
282 6.2.8

283 6.2.8
284 6.2.8

285 6.2.8
286 6.2.8
287 6.2.8
288 6.2.8

289 6.2.8
290 6.2.8

Comment (English)"6.2.8 (C)Subsection f) The scope to which the term ""force majeure"" should be defined must be defined""6.2.8 Comment in item c. Respect the national legislation of each country and the “legal” dynamics, since in each country there arelegal deductions, which are applied to the minimum wage, define the dynamics of this item
Item F: Define “Force majeure case”, or leave it at the discretion of the company according to its criteria and its analysis, both legal orinternal criteria.
"
Really due to the scope of the definition, it is better to eliminate this indicator, since what companies can do is follow government
guidelines to try to guarantee job stability.
This indicator is not sustainable. Even the agreement on the protection of salary #95, art. 8 (ILO) says that: "Salary discounts should
only be allowed in accordance with the conditions and within the limits set by national legislation, a collective contract or an arbitralaward. The workers should be indicated, in the way in which the competent authority deems most appropriate, the conditions andlimits to be observed to be able to make such discounts. "It is recommended that this be subject to national legislation, it is unfeasible to pay the minimum wage and subsidize law discounts fora producer.
Literal C, of indicator 6.2.8 (c) is not clear. Clarify that the minimum wage only deduces the concepts established by law, it seems thatit says that the minimum wage will be paid without deductions of law and that is unfeasible in any country.
Legally the deductions of law are made using as a base the minimum wage therefore it is barely natural that the worker receives afigure below the minimum wage
"6.2.8 (c):Point C ""no deduction (legal or anothertype) may reduce payments below the minimum wage ""can be illegal (and cause of fines) in many countries because labor legislation
allows tax deductions, labor security, loans, paternity food pension, etc. which must be respected the ""top"" of deductions that thelaw says.
Also, point f. ""The UDC will commit to paying a day of wages in case of force majeure,"" can be interpreted in different ways,
therefore, it must be specified to what force majeure refers."
The translation does not correspond to what is in the version in English, for example: f. The reach of force majeure is totally different in
the scope.
"Literal C, of indicator 6.2.8 (c) is not clear. Clarify that the minimum wage only deduces the concepts established by law, it seems
that it says that the minimum wage will be paid without deductions of law and that is unfeasible in any country."#Indicator

291 6.2.8
292 6.2.9

293
294
295
296

6.2.9
6.2.9
6.2.9
6.2.9

297 6.2.9
298 6.2.9

299 6.2.9
300 6.2.9

301 6.2.9

Comment (English)[Abidjan WS] 6.2.8 c - replace 'all workers' to 'permanent and full time workers'.
6.2.9 b. This indicator needs to be revised as it should reflect the payment systems in plantations. The minimum wage is compulsory
but in most situations, workers who have been working in non-piece rated tasks have only been paid minimum wage. These plantation
workers will only see a pay increase when the minimum wage is increased by the government irrespective of the number of years
worked for the UoC. Not all piece-rated work is calculated on the proportion of the legal minimum wage. There are other contributing
factors, and this should be taken into consideration.
Here for clarity it should only say deduct the legal requirements.
Objectives must be defined in a way that is consistent with human feasibility over the course of a working day.
Performance bonuses to avoid undeclared workers on plantations"Objectives must be defined in a way that is consistent with human feasibility over the course of a working day.
a) Performance bonuses to avoid undeclared workers on plantations"6.2.9 (a) Performance bonuses to avoid undeclared workers on plantations
Sustained objection: This is contradict with the Employment Act of Malaysia. The workers who turned up for full days work offered in amonth are eligible for national minimum wage. However, if the workers are earning less than national minimum wage due to low
productivity, there will still be some statutory deductions (electricity/water, insurance, EPF) which brings their take home salary below
the legal/CBA minimum wage.
Objectives must be defined in a way that is consistent with human feasibility over the course of a working day.
"The sentence is not quite right and confusing""c. Deductions shall not be made from a Worker’s pay which reduces the Worker’s pay to below the legal or CBA minimum wage.""
If any legal deductions being made from a worker's salary, and if that particular month's earning is the same as legal/CBA wage, theworker's take home salary will be lower than legal/ CBA minimum wage. ""In the 6.2.9 indicator there are several proposals, namely:- Changes in sentences in point C: ""Cutting workers' wages can be done in accordance with the agreement and refer to the applicablelaws and regulations""- All points, a to E, also added the phrase ""refer to the applicable laws and regulations""- Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or PKB""- Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to a work accident, then the full
day's wages are paid to any type of worker"""#

Indicator

302 6.2.9

303 6.2.9

304 6.2.9

305 6.2.9

306 6.2.9

Comment (English)"The sentence in point c is removed to be changed to""Cutting wages can be done according toagreement and refer to regulations andapplicable laws ""."
"Sentence in point d. changed to ""d. Work overtime
must be paid according to national legal tariffs or based on
work agreements, company regulations or employment agreements
Together"".
""The sentence in point E is changed to ""e. If it is working day
shortened due to work accidents then a day's wage
Full paid to any type of worker "".""- Changes in sentences in point C: ""Cutting workers' wages can be done in accordance with the agreement and refer to the applicablelaws and regulations""- All points, a to E, also added the phrase ""refer to the applicable laws and regulations""- Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or PKB""- Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to a work accident, then the full
day's wages are paid to any type of worker""""6.2.9 points c. Please explain what is included as a type of piece.
What if the worker does make mistakes based on the rules agreed upon in a joint work agreement should be given a fine?
What about the deductions that are in accordance with the laws and regulations such as employment insurance, health insurance, oldage insurance insurance in Indonesia known as BPJS. Is this included the intended discount? What about monthly discounts because
workers take staple goods in the cooperative?
As long as the intended type of discount is clear, based on an agreement between workers and the certification unit, or based on laws
and regulations, it should not be seen as a violation of the 6.2.9 indicator of this C.
"#Indicator

307 6.2.9

Comment (English)"Indicator 6.2.9 (c) Proposed:- Changes in sentences in point C: ""Cutting workers' wages can be done in accordance with the agreement and refer to the applicablelaws and regulations""- All points, a to E, also added the phrase ""refer to the applicable laws and regulations""- Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or PKB""

308 6.2.9- Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to a work accident, then the full
day's wages are paid to any type of worker""""Proposed 6.2.9 Improvement of Indicators:- Improvement of points c to: ""Workers' wages can be done in accordance with the agreement and refer to the applicable laws andregulations""- Dibalization of points A to E, added the phrase ""Referring to the laws and regulations that apply to each country""- Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or collective labor agreements (PKB)""

309 6.2.9
310 6.2.9

311 6.2.9- Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to a work accident, then the full
day's wages are paid to any type of worker""""6.2.9 Points a) SD e): added ""according to the regulations
valid""notes:1. The sentence ""must be paid according to the legal minimum wage"" replace with ""every worker with a work period of under 1
year must be paid at least a legal minimum wage"".
2. General Note: Every PKB word must be preceded by an explanation of ""PKB negotiated"": Negotiated CBA.
3. Afterwards adding a definition of ""PKB negotiations according to procedures"" in particular this needs to be elaborated at 6.3.1."
Proposed indicator 6.2.9 (c): - Changes in sentences in point C: "Cutting workers' wages can be done in accordance with the agreement
and refer to the applicable laws and regulations" - All points, a to e, also added the sentence "refer to applicable laws and regulations "- Changes in sentences in point d:" Overtime work must be paid according to national legal tariffs or based on employment
agreements, company regulations or PKB " - Changes in sentences in point E:" If the working day is shortened due to incidents/injury
due to work accidents, then full a day wages are paid to any type of worker "#Indicator

312 6.2.9

Comment (English)"Proposed Indicator 6.2.9] Proposed:- Changes in sentences in point C: ""Cutting workers' wages can be done in accordance with the agreement and refer to the applicablelaws and regulations""- All points, a to E, also added the phrase ""refer to the applicable laws and regulations""- Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or PKB""

313 6.2.9

314 6.2.9- Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to a work accident, then the full
day's wages are paid to any type of worker""""6.2.9 Changes in sentences in point c: ""The work of workers' wages can be done in accordance with the agreement and refer to theapplicable laws and regulations""- All points, a to E, also added the phrase ""refer to the applicable laws and regulations""
6.2.9 Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on employment
agreements, company regulations or PKB""
6.2.9 Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to work accidents, then full a
day wages are paid to any type of worker""""Proposed changes in indicators 6.2.9:
All workers must be paid according to the legal minimum wage or minimum wage negotiated in the Collective Labor Agreement (PKB),
which is higher. The following are things that need to be considered in giving wages:
a. Performance bonus and overtime wage are not calculated as part of the legal minimum wage or PKB minimum wage refer to theapplicable laws and regulations
b. For wholesale work, proportional wages must be calculated based on legal minimum wages or tariffs in PKB refer to applicable laws
and regulations
c. Cutting workers' wages can be done in accordance with the agreement and refer to the applicable laws and regulations
d. Overtime work must be paid according to national legal tariffs or based on employment agreements, company regulations or PKB
e. If the working day is shortened due to incidents/injuries due to work accidents, then full a day wages are paid to any type of worker"#Indicator

315 6.2.9

316 6.2.9

Comment (English)
Indicator 6.2.9 (c) is proposed in order to: (1). Changes in sentences in point C to "Cutting workers' wages can be done in accordancewith the agreement and refer to the applicable laws and regulations". (2). All points A to E added the phrase "refer to the applicablelaws and regulations". (3). Changes in sentences in point d: "Overtime work must be paid according to national legal tariffs or based on
work agreements, company regulations or PKB", (4). Changes in sentences in point E: "If the working day is shortened due toincidents/injuries due to work accidents, then full a day wages are paid to any type of worker".
"Indicator 6.2.9 (c) Proposed for:1. Changes in sentences in point C to ""Cutting workers' wages can be done in accordance with the agreement and refer to theapplicable laws and regulations"".
2. All points A to E added the phrase ""refer to the applicable laws and regulations"".
3. Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or PKB""

317 6.2.9

4. Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to work accidents, then full a day
wages are paid to any type of worker"".""Proposal:- Changes in sentences in point C: ""Cutting workers' wages can be done in accordance with the agreement and refer to the applicablelaws and regulations""- All points, a to E, also added the phrase ""refer to the applicable laws and regulations""- Changes in sentences in point d: ""Overtime work must be paid according to national legal tariffs or based on work agreements,
company regulations or PKB""

318 6.2.9- Changes in sentences in point E: ""If the working day is shortened due to the incident/injury due to a work accident, then the full
day's wages are paid to any type of worker""""6.2.9 Points a) SD e): added ""according to applicable regulations""
6.2.9: The sentence in point c is deleted to be changed to""Cutting wages can be done in accordance with the agreement and refer to applicable regulations and regulations"".
6.2.9: Sentences in point d. changed to ""d. Overtime work must be paid according to national legal tariffs or based on employment
agreements, company regulations or collective labor agreements "".
6.2.9: The sentence in point E is changed to ""e. If the working day is shortened due to work accidents, the full day wages are paid to
any type of worker ""."

#

Indicator

319 6.2.9

320 6.2.9
321 6.2.9
322 6.2.9
323 6.2.9
324 6.2.9
325 6.2.9
326 6.2.9
327 6.2.9
328 6.2.10
329 6.2.10
330 6.2.10
331 6.2.10

Comment (English)"6.2.9 points c. Please explain what is included as a type of piece.
What if the worker does make mistakes based on the rules agreed upon in a joint work agreement should be given a fine?
What about the deductions that are in accordance with the laws and regulations such as employment insurance, health insurance, oldage insurance insurance in Indonesia known as BPJS. Is this included the intended discount? What about monthly discounts because
workers take staple goods in the cooperative?
As long as the intended type of discount is clear, based on an agreement between workers and the certification unit, or based on laws
and regulations, it should not be seen as a violation of the 6.2.9 indicator of this C.
"
Literal E, is not clear in its reach, subjectivity for auditors, must specify that in countries where this is regulated, it will apply.
I consider not to include in the indicator that the measurement is on the salary negotiated by collective bargaining agreement (ANC).
The indicator must be measured on the minimum and not on the salary agreed with the workers and their representatives.
I consider not to include in the indicator that the measurement is on the salary negotiated by collective bargaining agreement (ANC).
The indicator must be measured on the minimum and not on the salary agreed with the workers and their representatives.
I do not agree clearly in literal C, of indicator 6.2.9 (c). Clarify that the minimum wage only deduces the concepts established by law, it
seems that it says that the minimum wage will be paid without deductions of law and that is unfeasible in any country.
There are deductions of law that are allowed in each country, it is suggested that this be subject to national legislation or eliminate thisindicator.
It must be subject to national legislation.
In Latam, the work codes are clear in what can and that cannot be deduced from a salary. Not fulfilling the country's law is not viable,
as well as thinking that a UDC will be sustainable if the minimum wage is "free" of deductions ... This is unfeasible and unsustainable.
Take into account the law of each country regarding deductions on the minimum wage, in many countries the deductions are allowed
under certain conditions and up to a maximum percentage
Suggest to split into several indicators for ease of raising CARs as frequently underlined by auditors in previous revision processes. [Toomany elements in one single indicator]
A taskforce can be set up by the RSPO and relevant players to define guidelines to be followed by the Unit of Certifications - to define
and implement this policy"All means made available to employees can be easily audited to ensure non-intervention by the unit of certification.""A taskforce can be set up by the RSPO and relevant players to define guidelines to be followed by the Unit of Certifications - to define
and implement this policy "#Indicator

332 6.2.10
333 6.2.10

334 6.2.10

335 6.2.10
336 6.2.10

337 6.2.10
338 6.2.10
339 6.2.10
340 6.2.10
341 6.2.10

342 6.2.10

Comment (English)[Sandakan, 21 June 2023] Leniency to MG. The Prevailing Wage Calculation Procedure implementation by the UoC (MG) should begiven within 12 months of its issuance.
6.2.10 Prevailing wage calculation. There should be proper interim guidance as this gap has existed for many years. It is suggested thatthe living wage be calculated for each work category rather than averaging out. An example would be, piece rated harvesters would
earn twice the amount of maintenance workers, and if it is done collectively as one living wage calculation, it will skew the living wage
determination.
[HRSS] It is important to include LW at the indicator level to avoid a perceived lowering of the standards. Proposed to add "6.2.10(C)Living Wages shall be paid to all workers. As the first step towards paying Living Wage, the Unit of Certification shall calculate theirprevailing wages annually in accordance to RSPO Prevailing Wage Calculation Procedure....... "[6.2.10] What is the objective of calculating the prevailing wage? Could auditor expect additional information on top of thecalculation?
"The Indonesian government has a policy
Wages that must be obeyed by the Certification Unit.
RSPO Procedure Regarding Applicable Wage Calculationmust be in accordance with the provisions of the Indonesian government."
6.2.10. The Indonesian government has a wage policy that must be obeyed by the certification unit. The RSPO procedure regarding theapplicable wage calculation must be in accordance with the provisions of the Indonesian government.
Salaries must be subject to minimum wages established in each country,
The prevailing salary guide must be put to a public consultation that will be removed in 2024, since it must take into account all thebenefits that each country is currently granted to the worker beyond the payment of the minimum wage
6.2.10 It is requested to respect the national legislation of each country, according to its salary established by the Government.
"There should be a consultation in this regard to validate the applicability and clarity of the prevailing salary guide that will be issued in
2024 and give a greater term to its implementation. In addition, it must be explicit that the prevailing salary is a calculation of eachcertification unit and should not be compared with other companies or an average industry.
What is the purpose of calculating the prevailing salary if you can talk about minimum wage. It is not clear about the need to calculate
the prevailing salary and what is the final purpose of presenting it before a certification audit, since it does not take into account theindividuals that exist in each country, state or department, area, type of UDC and even the Influence of the sector. It is a risk to
calculate the prevailing salary if the peculiarity of each UDC is not recognized and that in the end all must be fulfilling the payment of
the minimum wage."
According to this comment.

#

Indicator

343 6.2.10

344 6.2.10
345 6.3

346 6.3

347 6.3

348 6.3

349 6.3

350 6.3.1
351 6.3.1
352 6.3.1

Comment (English)
What is the purpose of calculating the prevailing salary if you can talk about minimum salt. It is not clear about the need to calculate
the prevailing salary and what is the final purpose of presenting it before a certification audit, since it does not take into account theindividuals that exist in each country, state or department, area, type of UDC and even the Influence of the sector. It is a risk to
calculate the prevailing salary if the peculiarity of each UDC is not recognized and that in the end all must be fulfilling the payment of
the minimum wage.
It should not be reviewed with the GT-SD, it is a guide that must be built with all representatives of the different sectors and even takeit to public consultation.
6.3 "Employer facilitates a parallel means of independent and free association and bargaining for all Workers through representativesof their choice." How is this translated into an indicator? When in most cases, wages and piece rates are predetermined based onother factors.
"""No repression of any kind will be tolerated by the unit of certification towards the workers.
Discussion forums must be set up between employee representatives and the company to promote conflict management, improvecompany life or simply comply with the law.""""No repression of any kind will be tolerated by the unit of certification towards the workers.
Discussion forums must be set up between employee representatives and the company to promote conflict management, improvecompany life or simply comply with the law."
6.3.2 This is not an auditable indicator, it is a wishlist and requires in-depth investigation to determine conformity. This indicator calls
for a UoC report providing the information required in indicators 6.3.1 - 6.3.4. It should be referred to as a report supporting workers'
rights.
"Input:Addition of indicators to criteria 6.3:
Add ""Unit Certification Assures a Safe Environment for Workers and Their Representative to Encourage Constructive Social
Dialogue.""
Add ""Collective Bargaining Agreement"" as Indicator of Social Dialogue in Unit Certification.
""to anybody or to stakeholders ?
then it could be added in the guidance of 1.1.1"
All means made available to employees can be easily audited to ensure non-intervention by the unit of certification.
a taskforce must be set up by the RSPO to occasionally review or even audit grievances related to these subjects in the plantations orMills with the workers, without restriction of the unit of certifications

#Indicator

353 6.3.2
354 6.3.2

355 6.3.2
356 6.3.2
357 6.3.2

358 6.3.2

359 6.3.3
360 6.3.3

361 6.3.3
362 6.3.3
363 6.3.3

Comment (English)
6.3.1 The collective construct is not included. It is assumed that there will always be CBAs. How the CBAs are developed should be
guided by the indicator requirements.
"Propose the sentences stop on : .....shall be provided free of charge...
This because every company has its own policy regarding the facilities provided to its workers. The term ""monitored"" is too broad tobe audited by the CB and it would be difficult for the CB to check its implementation."
A taskforce can be set up by the RSPO and relevant players to define guidelines to be followed by the Unit of Certifications - to define
and implement this policy"If necessary, workers' anonymity must be guaranteed."
6.3.2: The phrase "and not monitored by the Certification Unit" is deleted so that it becomes "facilities for workers to be able tointeract with each other and with their representatives must be given free of charge" because each company has their respective
policies for the facilities provided to their workers. The term "monitored" is too broad to be audited by CB and will be difficult to checkits implementation by CB.
"The phrase ""and not monitored by the Certification Unit""
deleted so that it becomes a ""facility for workers in agar
can interact with each other and with its representatives must be given free of charge ""because each company has their respective
policies for the facilities provided to their workers. The term ""monitored"" is too broad to be audited by CB and will be difficult tocheck its implementation by CB."a taskforce must be set up by the RSPO to occasionally review or even audit grievances related to these subjects in the plantations orMills with the workers, without restriction of the unit of certifications"a taskforce must be set up by the RSPO to occasionally review or even audit grievances related to these subjects in the plantations orMills with the workers, without restriction of the unit of certifications"
I propose the implementation time from 6 months into 1 year after the prevailing wage calculation procedure is issued. We need time
to socialize the procedure well and clearly to all of unit operations before it is implemented.
If necessary, workers' anonymity must be guaranteed.
In this 6.3.3 indicator it is proposed that there is no need for monitoring every year because the timeline is already in the minutes ofthe meeting held routinely#Indicator

364 6.3.3

365 6.3.3
366 6.3.3
367 6.3.3

368 6.3.3

369 6.3.3

Comment (English)"Indicator 6.3.3 Proposed for:1. There is no need for monitoring every year because there is already an minutes of the meeting held routinely.
2. It is proposed that the phrase is proposed ""All actions agreed upon in this meeting are held and monitored every year""."
Proposed 6.3.3: Monitoring every annual is abolished ... because there is a meeting held routinely and all the results of the meeting
agreed upon in the meeting held and monitored every year.
"There is no need for monitoring every year because there is already an minutes of the meeting held routinely.
Proposed deleted: All actions agreed upon in this meeting are carried out and monitored every year.""Indicator 6.3.3 Proposed:
There is no need for monitoring every year because there is already an minutes of the meeting held routinely.
Proposed deleted: All actions agreed upon in this meeting are carried out and monitored every year.""The word ""monitored every year"" is deleted. Frequency
Monitoring is established jointly between the Certification Unit
with registered trade unions/unions.""[I] 6.3.3
There is no need for monitoring every year because there is already an minutes of the meeting held routinely

370 6.3.3
371 6.3.3
372 6.3.3

373 6.3.3

Proposed deleted: All actions agreed upon in this meeting are carried out and monitored every year."
Proposed changes in indicators in 6.3.3: The note of meetings between the certification unit and the registered trade union and theregistered union must be documented and provided according to request.
Proposed changes in indicators 6.3.3: The notula of the meeting between the certification unit and the registered worker organizationand the registered union must be documented and provided according to request.
"There is no need for monitoring every year because there is already an minutes of the meeting held routinely
All actions agreed upon in this meeting are held and monitored every year."
Indicator 6.3.3 is proposed in order to: (1). There is no need for monitoring every year because there is already an minutes of themeeting held routinely. (2). It was proposed that the phrase was proposed "All actions agreed upon in this meeting were held andmonitored every year".

#

Indicator

Comment (English)

374 6.3.3"There is no need for monitoring every year because there is already an minutes of the meeting held routinely

375 6.3.3

Proposed deleted: All actions agreed upon in this meeting are carried out and monitored every year.""Proposal:
There is no need for monitoring every year because there is already an minutes of the meeting held routinely

376 6.3.3
377 6.3.3
378 6.3.4
379 6.3.4
380 6.3.4
381 6.3.4
382 6.3.4
383 6.3.4
384 6.3.4
385 6.3.4
386 6.3.4

387 6.3.4
388 6.3.4
389 6.3.4

Proposed deleted: All actions agreed upon in this meeting are carried out and monitored every year.""Indicator 6.3.3
Proposed deleted: All actions agreed upon in this meeting are carried out and monitored every year."
6.3.3: The word "monitored every year" is deleted. The frequency of monitoring is determined between the certification unit and theregistered trade union/union.
All means made available to employees can be easily audited to ensure non-intervention by the unit of certification.
If necessary, workers' anonymity must be guaranteed.
"Suggest to ensure that any use of biological control agents complies with national legislation.
[The use of a Biological Control Agent (BCA) is the preferred option for the management of pests]."
Deleted due to redundant with 6.1.1. related to discrimination"Proposal:
Indicator 6.3.4 is deleted due to redundant with 6.1.1. related to discrimination."
For indicators 6.3.4 it is proposed to be deleted due to redundant with 6.1.1. related to discrimination
Proposed Indicator 6.3.4: Interesting this indicator due to repetition related to 6.1.1 regarding discrimination"Proposal:
Deleted due to redundant with 6.1.1. related to discrimination""[I] 6.3.3
Deleted due to redundant with 6.1.1. related to discrimination""Indicator 6.3.4 Proposed:
Deleted due to redundant with 6.1.1. related to discrimination"
Indicator 6.3.4 is proposed to: deleted due to redundant with 6.1.1. related to discrimination.
"Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations."#

Indicator

390 6.3.4
391 6.3.4
392 6.3.4
393 6.3.4
394 6.4

395 6.4

Comment (English)"Proposal:
Indicator 6.3.4 is deleted due to redundant with 6.1.1. related to discrimination""Proposed indicator 6.3.4:
This indicator is due to repetition related to 6.1.1 regarding discrimination"
Deleted due to redundant with 6.1.1. related to discrimination
6.3.4: The indicator is deleted because it has been covered by indicators 6.1.1. related to discrimination"Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.

396 6.4

397 6.4

The company should have a governance and reporting structure in place to ensure proper implementation of the policy.""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member"
No repression of any kind will be tolerated by the unit of certification towards the workers or among workers

#Indicator

398 6.4

399 6.4
400 6.4

401 6.4

Comment (English)"Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""No repression of any kind will be tolerated by the unit of certification towards the workers or among workers""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
""In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.

402 6.4

The company should have a governance and reporting structure in place to ensure proper implementation of the policy. """"""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member"""#

Indicator

403 6.4

Comment (English)"The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.

404 6.4
405 6.4

The company should have a governance and reporting structure in place to ensure proper implementation of the policy."
No repression of any kind will be tolerated by the unit of certification towards the workers or among workers"Input:Addition of indicators to criteria 6.4:
Add ""Unit Certification Shall Prevent Child Labor by Setting Fair Working Target for the Workers and to Implement Dent Wage."""#Indicator

406 6.4.1

407 6.4.1

408 6.4.1
409 6.4.1
410 6.4.1
411 6.4.1

Comment (English)"[HRWG] Concern:- Contradiction with national laws - Malaysia allows children to work at 16. Concern - this new threshold of no one below 18 years old
may contradict local laws.
- Apprenticeship’ may be problematic - you can be an apprentice but due to lack of clarity, you may be undertaking similar work as
those below 18 years old who have worked at the UoC previously. It may also be open to abuse and can lead to situations of forced
labour.
- Apprenticeship would mean that they are required to show some connection to education. This may be difficult to audit if
apprenticeship is linked to education- How practical is this need for connection to education? How would this be monitored practically on the ground? Hazardous work
should also consider work that is done in mills and upkeep work. Some may not be hazardous. Indonesia is just one country whichclassifies palm oil as hazardous work. This would not be a problem for the big Malaysian plantations due to the reliance on migrant
workers. However, caution to not forget about the supply chain as we have to consider the smallholders as well.
Recommendation: Follow the ILO standard age in general because it is accepted by most countries. Clarify that UoC can adopt nationallaw or international, depending on which is higher. Concern should be given to the children currently working because the higher
requirement imposed will have repercussions on the many young workers already employed in the field. ""Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities."
Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements.
"A taskforce is to be set up to define guidelines to help mills define and implement this policy – regarding national laws"
Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements.
"A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.
Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements."

#

Indicator

412 6.4.1

413 6.4.1

Comment (English)"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
""A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.

414 6.4.1

Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements.""Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.

415 6.4.1

Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met.""The indicator is deleted because it has been covered by
Indicator 6.1.1. related to discrimination"

#Indicator

416 6.4.1

Comment (English)"Enter/addition:
1. In the definition of RSPO (source) ILO Conventions Convention C184 2001 Concerning Safety and Health in Agriculture Convention
2001 - Types of work that are endangering K3, may not be under 18 years, unless determined different from by national regulations
and regulations or competent authority, and Consultation with worker representatives, can employ young workers aged 16 years by
first getting training.
2. Children's Schools, the company should provide school facilities and participate in supervising and ensuring that workers' children
are required to attend schools from elementary to high school, so there are no more child labor or providing transportation or
children's facilities to attend school

417 6.4.2

418 6.4.2
419 6.4.2

420 6.4.2

3. The company has a definition of which area is dangerous and not, so that the company does not exploit internship workers""[HRSS] Proposal"" 6.4.2(C) The Unit of Certification shall not employ workers below the age of 15. An age screening verification
procedure shall be documented.""To align the indicator with ILO's requirements which allow those under 15 to be able to conduct non-hazardous work."
6.4.2 What about the verification procedure for contractors' workers?
"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.
Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met."
and made available for verification

#

Indicator

421 6.4.2

Comment (English)"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.

Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.

422 6.4.2

Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met.""""A taskforce is to be set up to define guidelines to help mills define and implement this policy.

423 6.4.2

Ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.""""A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.

424 6.4.2
425 6.4.2
426 6.4.2
427 6.4.2
428 6.4.2

Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements."
A taskforce is to be set up to define guidelines to help mills define and implement this policy – regarding national laws
It is suggested that, if national laws allow to hire young workers, complying with the legal framework and protecting theirdevelopment, it is possible to do so.
It could be done as long as the national regulation of each country is fulfilled.
Proposal "The UDC will use workers complying with the minimum age required by the legal framework of each country." Review
writing
6.2.4 If not used under 18; Why a Poe to verify age?; That is, it is already a "rule" not to hire them, since in order to make a contract,the identification document is requested that accredits it as of legal age ...

#Indicator

429 6.4.2
430 6.4.3
431 6.4.3

432 6.4.3
433 6.4.3

434 6.4.3
435 6.4.3
436 6.4.3

Comment (English)
There are cases in which minors can be hired; for example, "interns or practitioners"; So, it could be that its hiring is made withadherence to national legislation.
reword punishment to sanction.
"and made available for verification"
Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
"A taskforce is to be set up to define guidelines to help mills define and implement this policy.
Ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government."
6.4.3 C It shall not become an apprentice until that child has completed compulsory school years (under 18 year old)
"In indicator 6.4.3 it is proposed to delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations.""6.4.3 To be consistent using the term ""Young People"", not ""Young Worker""
For the context of Indonesia, the internship does not get payments like regular workers because this is part of the process or
educational requirements, not in the context of working. They are likely to get an allowance/transportation money which isdetermined by the company.

437 6.4.3
438 6.4.3
439 6.4.3

That way the indicator requirements section 6.4.3 related to the payment of apprenticeship activities should be abolished""Indicator 6.4.3 (c) Proposed:
Removing the phrase ""Internship participants must get paid and given a salary slip."" refer to national regulations.""Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations.""Indicator 6.4.3 (c) Proposed to: The sentence ""Internship Participants
must get paid and given a salary slip ""deleted referring to national regulations."#

Indicator

440 6.4.3

441 6.4.3
442 6.4.3

443 6.4.3

444 6.4.3

445 6.4.3
446 6.4.3

447 6.4.3
448 6.4.3
449 6.4.3
450 6.4.3

Comment (English)"[I] 6.4.3
Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations.""Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations.""
Proposed Indicator 6.4.3: Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations.""Proposed changes in indicators 6.4.3 (c) Internship opportunities for young workers over the age of 15 years and under the age of 18
for educational and training purposes are permitted under supervision. Internship activities for young workers should not interferewith school activities and should not endanger their health or development.
Comment: Payment of wages to apprentice workers is not based and there is no reference. It is better if it is enough with theprovisions in the company""Proposed Improvement of Indicators 6.4.3: Removing the phrase ""Internship Participants must get paid and given a salary slip."".
The arrangement of internship workers refers to national regulations.""Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations.""The phrase ""Internship Participants must get paid
and given a salary slip. "" added ""according to regulations
National Yenag applies.
"
6.4.3: The phrase "Internship participants must get paid and given a salary slip." added "In accordance with the national regulation inforce.
"Ussulan 6.4.3: Delete the phrase ""Internship Participants
must get paid and given a salary slip. ""Referring to national regulations."
Removing the phrase "Internship participants must get paid and given a salary slip."
Refer to detable of payrolls "and not" payroll "based on the fact that they are not own of the personnel plant but enter a learning
phase and the payment corresponds to support and not with a salary payment.

#

Indicator

451 6.4.3
452 6.4.4
453 6.4.4

454 6.4.4

Comment (English)
Complement, according to the national regulations of each country.
6.4.4 If child labor is found, the unit should be suspended and remediation monitored. Legal repercussion should also be explored.
6.4.3 How would this indicator handle individuals between the ages of 16 and 18 who are not schooling, but require an income tosustain themselves? There should be evidence provided that these young workers are being trained specifically for certain
employment and a certain plan should be made available, if relevant.
"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.

Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.

455 6.4.4

456 6.4.4
457 6.4.4
458 6.5

Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met.""Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities."
Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
and made available for verification"Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member"#Indicator

459 6.5

460 6.5

461 6.5

Comment (English)"The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.
The company should have a governance and reporting structure in place to ensure proper implementation of the policy.""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""Input:Addition of indicators to criteria 6.5:
Add ""If Domestic Violence Towards Workers is found in the unit certification, unit Certification shall provide adequate discretion for
the workers to settle the domestic violence.

462 6.5.1
463 6.5.1

Note: Example of Discretion: to Provide Permits for the Workers/Victims to Go To Hospital, Police Department, Legal Aid Office,Therapy Session, etc.
"
6.5.1 This should also include contractors.
"A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.
Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements."

#

Indicator

464 6.5.1

Comment (English)"A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.

465 6.5.1

466 6.5.1

467 6.5.1

Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements.""A taskforce is to be set up to define guidelines to help mills define and implement this policy.
Ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government."
Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender. A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any
opportunities.
"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.

Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.

468 6.5.1

469 6.5.1
470 6.5.1

Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met.""No repression of any kind will be tolerated by the unit of certification towards the workers.
Discussion forums must be set up between employee representatives and the company to promote conflict management, improvecompany life or simply comply with the law."
6.5.1 C There is a Guidelines for Preventing and Handling Sexual Violence in the Workplace, kindly refer to that
"Proposal 6.5.1
The word sentence is corrected into sanctions. This is because the company has no right to punish individuals"

#Indicator

471 6.5.1
472 6.5.1
473 6.5.1

474 6.5.1
475 6.5.1
476 6.5.1

477 6.5.1
478 6.5.1
479 6.5.1
480 6.5.1
481 6.5.1

Comment (English)"OSDV: Using the term sanctions not punishment because the company has no right to punish individuals"
In indicators 6.5.1 The term "punishment" is proposed to be "sanctions" because the company has no right to punish individuals"Indicator 6.5.1 (c) Proposed:
use the term sanctions not punishment because the company has no right to punish individuals"
use the term sanctions not punishment because the company has no right to punish individuals
Indicator 6.5.1 (c) is proposed to: Using the term "sanctions" not "punishment" because the company has no right to punish
individuals.
"The word ""punishment"" is changed to ""sanctions"" because
the company has no right to punish individuals, andWhat will determine the penalty is a court."
use the term sanctions not punishment because the company has no right to punish individuals
Indicator 6.5.1 (c) is proposed to: Using the term "sanctions" not "punishment" because the company has no right to punish
individuals.
Indicator 6.5.1 (c) is proposed to: Using the term "sanctions" not "punishment" because the company has no right to punish
individuals.
"RSPO 6.5.1
The term used is sanction not punishment because the company has no right to punish individuals""Notes:1. Procedure for resolving sexual violence that has been running so far is still wrong, so it needs to be improved, it may be assistedfrom external parties to resolve sensitive cases (not resolved by management), so that victims do not become victims
2. explained and prepared the mechanism for handling and also recovery
3. The existence of a good handling system and the perspective of victims

482 6.5.1

4. When determining the independent team that helps the settlement is not directly appointed by the company directly to theauthorities, but also communicates with labor unions to determine who will help complete"
The word "punishment" is changed to "sanctions" because the company has no right to punish individuals.

#Indicator

483 6.5.1
484 6.6

Comment (English)
6.5.1: The word "punishment" is changed to "sanctions" because the company has no right to punish individuals, and those who will
determine the sentence are courts.
"The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.

485 6.6

The company should have a governance and reporting structure in place to ensure proper implementation of the policy.""The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
""In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.
The company should have a governance and reporting structure in place to ensure proper implementation of the policy. """#Indicator

486 6.6

Comment (English)"The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.
The company should have a governance and reporting structure in place to ensure proper implementation of the policy."#Indicator

487 6.6

Comment (English)"""The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
""""In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.
The company should have a governance and reporting structure in place to ensure proper implementation of the policy. """""""

#

Indicator

488 6.6

Comment (English)"The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.

489 6.6

490 6.6

The company should have a governance and reporting structure in place to ensure proper implementation of the policy.""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.
The company should have a governance and reporting structure in place to ensure proper implementation of the policy."#Indicator

491 6.6

492 6.6

Comment (English)"Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""The unit of certification must be able to prove the identity and age of each worker - but without confiscating or withholding identity
papers.
In the event of non-possession of identity papers, the unit of certification must help the worker to obtain them.
Acknowledging that the P&C requires socialization of the child protection policy to everyone, consider conducting in-depth training,
especially to those who are in contact with children (including workers and contractors). Ensure that all who are in contact withchildren are subjected to background checks.
Consider conducting a child protection risk assessment to identify salient child protection issues.

493 6.6

494 6.6

The company should have a governance and reporting structure in place to ensure proper implementation of the policy.""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member""Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.
Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met."#

Indicator

495 6.6

Comment (English)"Input:Addition of indicators to criteria 6.6:
Add ""Unit Certification Fulfills Specific Rights of Women Workers, as Stipulated in the National Regulation or Above"".
Note: Example of the Rights: Menstruation Leave, Maternity Leave, Caregivers Leave.

496 6.6.1

497 6.6.1
498 6.6.1

Add ""women workers who are a breadwinner, due to any cause, shall receive equal wages and benefits with"
"6.6.1.C add the issues of women worker rights such as 1. to end any discrimination, including stereotypes, that undermine access to""decent work"" , 2. Equality, end of low pay and to end the absence of equal pay , 3. Need recognition, equal distribution and value ofcare work and 4. a policy to end
violence and harassment against women"
propose to combine this indicator to 6.1.2 as this same topics for training and development"[HRWG] Negative effects of child labour should be communicated but this raises questions on what this would practically look like.
There is no harm in ensuring this communication and other community outreach on these issues. But it should be included in thecommunication with the surrounding communities.
However, how will auditors verify this?

499 6.6.1

500 6.6.1

Recommendation: Add the word ‘education’ or ‘facilitating education for the community on the issues of child labour’""A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.
Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements.""A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.
Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements."

#

Indicator

501 6.6.1
502 6.6.1

Comment (English)
Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
"A taskforce is to be set up to define guidelines to help mills define and implement this policy - and made it available for verification
Need to ensure access to education to workers’ children from early childhood until mandatory minimum school age set by national
government.

503 6.6.1
504 6.6.1
505 6.6.1
506 6.6.1
507 6.6.1

508 6.6.1
509 6.6.1
510 6.6.2
511 6.6.2

Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements."
Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.
A taskforce is to be set up to define guidelines to help mills define and implement this policy – regarding national laws
"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance."
Need to pay attention to Sexual and Reproductive Health and Rights (SRHR) and ILO Convention 183.
"The involvement of women in the assessment of the risk of their work, not only involves men (6.6 and 6.7)
Additional for definitions: Recruitment costs cover internal recruitment (in countries) and external (between countries). For travel
costs, the company is borne after the candidate passes the selection"
Add: menstrual leave rights
It is suggested to leave only a gender committee in which the women's well -being issues are discussed, and not that there is a well being committee
A taskforce is to be set up to define guidelines to help mills define and implement this policy – regarding national laws
The correct document reference is "RSPO Guidance on Child Right". Suggest aligning the document name to avoid misperception inreferencing document.

#

Indicator

512 6.6.2

Comment (English)"Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.

Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.

513 6.6.2
514 6.6.2

Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met.""Penalties must also be clearly defined by the RSPO in the event of failure to meet these criteria - including temporary or permanentsuspension of membership in the case of serious infringements.""Multi-stakeholder guidelines should be issued to mills to help them mitigate problems in the workplace - as well as sanctions for noncompliance.

Opportunities for workers (training, promotion, raises, etc.) should be linked only to individual performance, and should not be
conditioned by origin or gender.
A policy must be defined in this respect, with clear, auditable indicators and criteria to justify any opportunities.

515 6.6.2
516 6.6.2
517 6.6.2

518 6.6.2

Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met."
In the 6.6.2 indicator it is proposed to be deleted, because it is redundant with 6.1.2 related to the same opportunity for workers
Proposed 6.6.2: This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers.
"Welfare Welfare and Empowerment Committee
consisting of women only and is in the shade
Gender Committee.""The indicator is deleted because it has been covered by
Indicator 6.1.1. related to discrimination."#Indicator

519 6.6.2
520 6.6.2
521 6.6.2
522 6.6.2
523 6.6.2
524 6.6.2
525
526
527
528
529
530

6.6.2
6.6.2
6.6.2
6.6.2
6.6.2
6.6.2

531 6.6.2

532 6.6.3

Comment (English)"Indicator 6.6.2 Proposed:This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers"
Indicator 6.6.2 This indicator is removed, because it is redundant with 6.1.2 related to the same opportunity for workers"Proposal:
This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers""[I] 6.6.2
This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers"
Indicator 6.6.2 is proposed in order to: This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity forworkers.
"Proposal:
Indicator 6.6.2 is deleted, due to redundant with 6.1.2 related to the same opportunity for workers"
6.6.2: The indicator is deleted because it has been covered by indicators 6.1.1. related to discrimination.
This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers
This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers
Delete indicators 6.6.2 due to repetition with 6.1.2 related to the same opportunity for workers
This indicator is deleted, because it is redundant with 6.1.2 related to the same opportunity for workers
Indicator 6.6.2 Proposed: This indicator is proposed to be deleted, because it is redundant with 6.1.2 related to the same opportunity
for workers.
"Proposed 6.6.2:
The sentence in the indicator needs to be clarified the relationship of the gender committee with the Welfare Committee. andrelations with the female committee ... it can be ambiguous."
Guidelines resulting from multi-stakeholder collaborative work are to be produced within the RSPO to help companies express andimplement their particular needs for pregnant women and new mothers.

#Indicator

533 6.6.3

Comment (English)"[HRSS] Propose to add ""The Unit of Certification shall develop and implement policies and procedures on the prevention andremediation of:(a) forced labour as stated in ILO's 11 Indicators of Forced Labour (2012) and traficking in persons.
(b) Any payment made by workers related to the recruitment process as defined in the ILO General principles and operationalguidelines for fair recruitment and definition of recruitment fees and related costs (2019);(c) Debt Bondage and wage withholding.
These policies and procedures shall be made Publicly Available and socialised to all levels of the Workforce, suppliers and labour
recruiters in languages understood by them.""

534 6.6.3

535 6.6.3
536 6.6.3
537 6.6.3

538 6.6.3
539 6.6.3
540 6.6.3

It is necessary to add the ILO forced labour indicators to address any potential gaps in RSPO's standards. This is also to avoid tradebarriers from EU and US."
Does this mean 2 committees are needed, the 'Gender Committee' and the 'Women's welfare and Empowerment Committee'? What is
the role of the Gender Committee in this case? If the Gender Committee fulfills all the requirements of the 'Women's welfare andEmpowerment Committee', do we then still need both? More clarity is needed on the difference of both committees?
Recruitment processes must be clear and objective"Recruitment processes must be clear and objective""Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met."
Guidance for this indicator, "needs of employees who are pregnant" shall clarify and provide in details the needs that can be supported
by UoC.
[Sandakan, 21 June 2023] What does it mean by legally mandated? Which rule are we referring to?
6.6.3 A women committee should focus on women rights issues , provide a safe environment for women to discuss current workplace,community & personal issues, otherwise it will be overwhelmed#Indicator

541 6.6.3

Comment (English)"Input1. In order not to be confusing, it is necessary to improve the term ""Welfare Committee and Women's Empowerment"" because it ispart of the Gender Committee. So that both are not considered different committees.
2. The Welfare and Empowerment of Women's Empowerment Sub Committee indeed prioritizes female members, but also needs
members other than women as a form of education for men. This can expand the prevention of sexual violence because all workers
have a good understanding of gender.
3. The management of the Gender Committee is not dominated by management and there must be representatives of theunion/representative of workers + people who have an influence in decision making

542 6.6.3

543 6.6.3

544 6.6.3
545 6.6.3
546 6.6.3
547 6.6.3

4. The period of the gender committee for meetings is every 3 months, not 4 months.
""notes:1. Add: Sanitation facilities are available ""in every radius of 3 km"".
2. Add Description: Sanitation facilities ""especially clean water flow"" things need to be written explicit and irreplaceable by 7.5.1.""Proposed Indicator 6.6.3:
Revision of Translation: A Gender Committee Shall Be Established, which includes a
Women's Welfare and Empowerment Committee. -> Gender Committee must be formed, which includes the Women's Empowerment
Committee
There is no need for a review because the gender committee consists of employees and female workers"
The Welfare and Empowerment Committee for Women consists of women and is in the auspices of the Gender Committee.
It is complex to indicate that the Gender Committee is only made up of women, if they only want women to be called the Womenletting participate in the committee where in theory I could participate
6.6.3 Define whether it is necessary to have a subcommitte of women, how working with the 2018 version"A committee within another committee, it is not better to indicate that the Gender Committee will address within its issues:a) Welfareb) Empowerment of women"#Indicator

548 6.6.3

549 6.6.3

550 6.6.3
551 6.6.3
552 6.6.3

553 6.6.3
554 6.6.4

555 6.6.4

Comment (English)"6.6.3 About this indicator:
1. If we talk about non -discrimination, why are other genres excluded in the Gender Committee?
2. Make too many committees not only hinders its implementation but also socialization towards interested parties (different
representatives because we can have, for example: Ethics Committee, Coexistence Committee, Gender Committee and, now well being committee for women) . This is confusing and there are objectives and functions that can be repetitive.
3. Why a well -being committee composed only of women?, Could be used to include men and other genres, to facilitate training,
information and understanding, which reduces better coexistence.
"
Suggestion: a single committee, formed by different genres, who may have representatives of the UDEC and workers and treat
sensitive issues that violate Human Rights ... One of their functions can be to promote these rights and train (train) to the different
CONCERNED PARTIES.
It is suggested to leave only a gender committee in which the women's well -being issues are discussed, and not that there is a well being committee
Only a gender committee such as the 2018 version should be left, for producers it is no longer viable to have too many committees,
you should seek to be practical.
"Eliminate the word ""committee"" for the well -being and empowerment of women,
The following wording is suggested ""a gender committee will be established that includes content and thematic for the well -being
and empowerment of women""
Keep in mind that in national laws there are already the committees as in Colombia Labor Coexistence Committee where a group of
workers in which it is sought to recognize and control the psychosocial risk or situations of workplace harassment in an organization is
being worked on"
6.6.3 Define whether it is necessary to have a subcommitte of women, as working with the 2018 version. This change is reallydiscrimination, rather the UDC must have cultural sensitivity to deal with complex issues in some realities"Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests.
Any request not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if theconditions requested by the company are met.""Gender discrimination must not be tolerated in the workplace.
Labor law must be applied irrespective of an employee's origin or gender - or at least aim for this independence.
The women welfare committee should include representatives from all positions/work type
The committee member should allow the committee to be safe place for discussion with no discrimination related to the position of
the participating member"#Indicator

556 6.6.4
557 6.6.5

558 6.6.5
559 6.6.5

560 6.6.5

561 6.6.5

562 6.6.5

563 6.6.5

564 6.6.5

565 6.6.5

Comment (English)
6.6.4. What about situations where there is no legal mandate and consent is given by the worker as a health and safety precautionary
measure? How is this handle? Would this be treated as a non-conformity?
Committee requests are taken into account by the company - with a clear timeline for implementation of validated requests. Anyrequest not validated must be clearly and explicitly justified - with a clear timeline for implementation of the request if the conditions
requested by the company are met.
Recruitment processes must be clear and objective"In indicators 6.6.5 there are several proposals, namely:- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""Indicator 6.65 Proposed:- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""Indicator 6.6.5 is proposed to:
1. Claimed the definition of the needs of female workers who are pregnant/new, adjusted to national regulations.
2. The sentence ""period six months before"" was abolished.
3. Add the phrase ""in the scope of work"".""- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work"""
Proposed 6.6.5: (1). Clarify the definition of the needs of pregnant/new female workers, adjusted to national regulations, (2). The
sentence "period six months before" was abolished, (3). Add the phrase "in the scope of work"#Indicator

566 6.6.5

567 6.6.5

568 6.6.5
569 6.6.5

570 6.6.5

571 6.6.5

572 6.6.5

573 6.6.5

Comment (English)"Proposed 6.5.5
Changes in indicators are the needs of female workers who are pregnant/new, adjusted to the regulations and the applicable national
law.
""The phrase ""in the previous six months""
to be clarified. Maternity leave in Indonesia according to the provisions
The Indonesian government was given for 3 months.
"
Indicator 6.65 Proposal: - Clarify the definition of the needs of pregnant/new female workers, adjusted to the National Regulation - thesentence "the previous six months" is abolished - adding the phrase "within the scope of the work""Proposal:- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""[I] 6.6.5- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""The definition of ""the needs of the middle female worker
pregnant / new giving birth ""to be clarified and still deepin the scope of the work.
""Proposed indicator 6.6.5:- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work""""6.6.5: Definition ""The need for female workers who are pregnant / new giving birth"" to be clarified and still in the scope of work.
6..6.5: The phrase ""in the previous six months"" to be clarified. Pregnant leave in Indonesia in accordance with the provisions of theIndonesian government is given for 3 months."#

Indicator

574 6.6.5

Comment (English)

579 6.7"- Clarify the definition of the needs of pregnant/new female workers, adapted to national regulations- The sentence ""period six months before"" was abolished- Add the phrase ""in the scope of work"""
Gender Committee or Women's Welfare Committee, if the scope is with the woman I suggest that the indicator approach is "Women's
Welfare Committee" and not "Gender Committee".
What is the scope of this attention? I suggest the wording of the 2018 version indicator. I consider that it is an issue to analyze inparticular with each mother and that the process is not so long in case this new scope of the gender committee will be approved.
It is suggested to leave only a gender committee in which the women's well -being issues are discussed, and not that there is a well being committee
Check the scope of the attention that should be given to the person, there are other means by which this support is given, such asSocial Security for example.
"""Guidelines resulting from multi-stakeholder collaborative work are to be produced within the RSPO

580 6.7

Sanctions for any breaches must be provided for by the RSPO, up to and including suspension of the unit of certification and evencompensation for individuals.""""Guidelines resulting from multi-stakeholder collaborative work are to be produced within the RSPO

581 6.7

Sanctions for any breaches must be provided for by the RSPO, up to and including suspension of the unit of certification and evencompensation for individuals.""Guidelines resulting from multi-stakeholder collaborative work are to be produced within the RSPO

575 6.6.5
576 6.6.5
577 6.6.5
578 6.6.5

582 6.7
583 6.7
584 6.7

Sanctions for any breaches must be provided for by the RSPO, up to and including suspension of the unit of certification and evencompensation for individuals."
Remove the word "Any" and the payment as defined in ILO guidance.
Criteria 6.7 In general, indicators - indicators in the criteria 6.7 are too detailed. It is recommended to make the indicator to be more
simple, where other detailed things are included in the guide only
Input in the form of adding editors to criteria 6.7 There is no tolerance for the practice of forced labor and human trafficking.
Prevention, monitoring and remediation procedures are available.

#

Indicator

585 6.7.1

586 6.7.1
587 6.7.1
588 6.7.1
589 6.7.1
590 6.7.1
591 6.7.1

Comment (English)"Suggest to revise the indicator to clarify the role and responsibilities of the gender committee, and how the gender welfare andempowerment committee fits in the overall structure. The indicator could be re-worded: ‘ A gender committee, comprising of women’s welfare and empowerment committee, shall be established specifically to raise awareness, identify and address issues of concern, as
well as identify training opportunities and support for the women to fulfil their work’.
[In the old indicator (6.1.5) A gender committee is in place, although in the draft2. A Gender Committee shall be established, which
includes a women's
welfare and empowerment committee. And the women's welfare and empowerment committee shall comprise women workers only.
There is a confusion in this indicator because the indicator goes on to talk about the roles and responsibilities of the Women's Welfare
and Empowerment Committee which responsibility is solely to look at women's welfare. The indicator no longer describes the role andresponsibility of a gender community. What is a gender committee supposed to do?
>There is no provision to provide any training or support to this new women's welfare and empowerment committee to do their job].
"
Guidelines resulting from multi-stakeholder collaborative work are to be produced within the RSPO to help companies express andimplement their particular needs for pregnant women and new mothers.
"Guidelines resulting from multi-stakeholder collaborative work are to be produced within the RSPO to help companies express andimplement their particular needs for pregnant women and new mothers."
No need to state "provide opportunity at least quarterly to discuss" but UoC provide opportunity for the women committee toorganise meeting and the women committee decides the frequency of meeting. This is clearer from audit perspective.
[Sandakan, 21 June 2023] Leniency to MG. Propose to put a minimum number of women workers in the committee. Make thisindicator applicable only to the UoC (MG) with significant number of women workers.
Proposed indicator 6.7.1 point B is removed because it is not relevant to the policy of forced labor.
"Addition of editors to indicators 6.7.1 (c) into, the certification unit must prepare and implement policies and procedures regarding
prevention, monitoring, and remediation to:(c) Ijon work and wage detention. There should be no work practices, wages, and wage cuts. These policies and procedures must be
available to the public and socialized to all levels of labor, suppliers, and recruiters of workers in the language that they understand or
use."

#

Indicator

592 6.7.1

Comment (English)"Input:1. (c) There are conditions that have not been conditioned about wages (deduction of wages from companies to other parties toworkers, because the company does not provide salaries directly to laborers)
2. The definition of forced labor and human trafficking is how (including the detention of documents and debt payments)
3. Subjective companies determine work targets, including the planting period, which requires workers to work exceeding the time
limit to meet their targets. Because if the target is not achieved there will be a wage deduction and does not get their rights well.

593 6.7.1
594 6.7.1
595 6.7.1
596 6.7.1
597 6.7.1
598 6.7.2

599
600
601
602
603
604

6.7.2
6.7.2
6.7.2
6.7.2
6.7.2
6.7.3

605 6.7.3
606 6.7.3

4. Provision of work facilities that are suitable for needs"
6.7.1 Define the scope of suppliers, the scope is very extensive or define that the company sees its important or vulnerable suppliers.
6.7.1 Define the scope of suppliers, the scope is very extensive or define that the company sees its important or vulnerable suppliers.
The remediation process must have a clear methodology to investigate the existence or not of a payment, this is only subject to theworker's version.
Define the scope of the type of suppliers, if it is a supplier of FF, inputs, services etc.
[Abidjan WS] 6.7.1 'Debt bondage' should be based on national regulation. NI to provide guidance.
The addition of redkation in 6.7.2 (c), becomes, identity documents, passports, and work permits issued by the government must be
stored by workers. If it is considered unsafe in independent storage, then this document can be given to the certification unit or its
representatives appointed for legal or immigration purposes that are mandatory and must be returned as soon as possible. The
certification unit must provide a safe document storage area for workers and must be accessible freely by workers.
6.7.2 (c) The word (safe place) does not context with the action that is being proposed.
6.7.2 The responsibility of the UDC increases for providing a place to save the documents
6.7.2 The responsibility of the UDC increases for counting a space to protect the documents.
The UDC is not due to the UDC to provide a safe place to save documents, they must carry or save each worker.
Remove the word safe place to save documents, although the rule is clear that the identification documents should not be retained.
The indicator should be removed as it seems like overlap/repetitive of indicator 6.5.1. or it can be replaced with ‘Worker's freedom of
movement and access to transport and communication should not be denied.’[Accra WS] 6.7.3 define 'unfair work target' - this is hard to audit - what is considered unfair - benchmark needed on local level? The
indicator should be There shall be no debt bondage and withholding of wages. These include the following: ...
iii) requires workers to pay a deposit or security deposit to the certification unit;#Indicator

607 6.7.3
608 6.7.3
609 6.7.3
610 6.7.3
611 6.7.4
612 6.7.4

613 6.7.4

614 6.7.4

615 6.7.4

616 6.7.4

Comment (English)
6.7.3 Change the word date for a period, since it is consistent with the contract, thus not having double interpretations, taking into
account national legislationiii) Define the word deposit better, since there are different ways of payment or accreditation of wages for the work carried out.
"Numeral I: change the word date for period, and include the note according to the national norm.
Numeral II: clarify the concept referred to in the concept of ""deposit"""[Abidjan WS] 6.7.3 - defined 'unfair work target' - this will create interpretation issue .
The implementation of objectives consistent with technical and human feasibility, within an acceptable timeframe, must be
guaranteed by the unit of certification. Additional objectives must also be integrated into this process, to avoid disguised forced labor.
"The 6.2.2/6.2.3/6.2.4 are about recruitment process and would sit better under 6.7. [> Some clarities are needed regarding
remediation of fees whether or not there will be a cutoff date when fees (payment made by workers related to recruitment process)need to be remediated>Nothing to comment yet as RSPO Secretariat will issue a procedure for the repayment of costs incurred by workers in recruitment
only December 2024].
"
In indicator 6.7.4 For the phrase "Total working hours must include rest and break time on working days, as determined in local law
and/or national law, including a break time of at least 24 hours in a row every 7 days", because in the criteria This talks about overtime
work. because it has been included in national law"Proposal:
The phrase ""Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days"", because in this criterion it talks about overtime work.
because it has been included in national law"
The phrase "Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days", because in this criterion it talks about overtime work.
because it has been included in national law"Proposed 6.7.4:
Changes in indicators to: Overtime work must be carried out voluntarily and in accordance with local law and/or national law. Total
working hours must include rest and break time on weekdays, as specified in local law and/or national law
The phrase ""Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days"" is abolished ... because it has been included in thesentence in the law national."#Indicator

617 6.7.4

618 6.7.4

619 6.7.4

620 6.7.4

621 6.7.4

622 6.7.4

623 6.7.4

624 6.7.4

625 6.7.4

626 6.7.4

Comment (English)"Indicator 6.7.4 (c) Proposed:
The phrase ""Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days"", because in this criterion it talks about overtime work.
because it has been included in national law"
Indicator 6.7.4 (c) Proposed to: The phrase "Total working hours must include rest and break time on working days, as determined inlocal law and/or national law, including a break time of at least 24 consecutive hours every 7 days" , because in this criterion it talks
about overtime work. Because it has been included in national law.
"[I] 6.7.4
The phrase ""Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days"", because in this criterion it talks about overtime work.
because it has been included in national law"
6.7.4: The phrase "Total working hours must include rest and break time on working days, as determined in local law and/or nationallaw, including a break time of at least 24 hours in a row every 7-day period" was removed because the provisions of overtime work
have been determined by the Indonesian government.
Proposed changes in indicators 6.7.4: Overtime work must be carried out voluntarily and in accordance with local law and/or nationallaw. Total working hours must include rest and break time on working days, as specified in local law and/or national law, including a
break time of at least 24 hours in a row
The phrase "Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days", because in this criterion it talks about overtime work.
because it has been included in national law"The phrase ""Total working hours must include rest andThe break time on weekdays, as determined in local law and/or national law, including a break time of at least 24 hours in a row every
7-day period ""was removed because the provisions of overtime work had been determined by the Indonesian government.""Proposed Indicator 6.7.4:
The phrase ""Total working hours must include rest and break time on working days, as determined in local law and/or national law,
including a break time of at least 24 hours in a row every period of 7 days"", because in this criterion it talks about overtime work.
because it has been included in national law"
Proposed 6.7.4: The phrase "Total working hours must include rest and break time on working days, as determined in local law and/or
national law, including a break time of at least 24 consecutive hours every 7-day period", because in this criterion Talking about
overtime work. because it has been included in national law
6.7.4 To adhere to the national legislation of each country, with the working day.

#Indicator

627 6.7.4
628 6.7.4
629 6.7.4

630 6.7.4
631 6.7.5

632 6.7.5
633 6.7.5
634 6.7.6
635 6.7.6

636 6.7.7
637 6.7.7

638 6.7.7

639 6.7.7
640 6.7.7

Comment (English)
6.7.4 To adhere to the national legislation of each country, with the working day.
6.7.4 Change the word arrangement or verify the English version, the legislation of each country is different with the work schedules
according to the position that is defined.
"Check the word ""arrangement"" if it is because of Spanish translation, since it is misunderstood.
The wording of the indicator should remain until the word ""working day"" and add that it is according to national legislation."[Abidjan WS] 6.7.4 It should put specific requirement - it should be based on national regulation. Plus to remove the last two
sentences.
6.7.5 How would the rights of international migrant workers be guaranteed here? There are situations where they cannot terminate
their employment freely because of the employment permit issued by the government. Premature termination to work for otherparties should also be considered.
6.7.5 Application of sanctions for certain things in the resignation process that has been agreed between workers and companies
should be applied in this indicator[Abidjan WS] 6.7.5 Removed the entire sentence of 'Penalty for not complying with notice period can only be enforced if it has been
agreed in the employment contract.' - no need to specify this matter. How to audit?
6.7.6. This might not be possible for international migrant labor as this is not the normal practice in certain countries.
"The implementation of objectives consistent with technical and human feasibility, within an acceptable timeframe, must be
guaranteed by the unit of certification. Additional objectives must also be integrated into this process, to avoid disguised forced labor.
"
6.7.7. There should be guidelines on this because it has been made a critical indicator.
[Abidjan WS] 6.7.7 please clarity the role of UoC - is this for all workers or just workers residing in UoC? This will create multiple
interpretation that UoC need to provide telephones, sim cards and even credits) to all workers. Access to transportation - does it mean
the UoC need to provide all transports for local workers do not stay inside the plantation?
"Suggest to re-word the sentence: Overtime work shall be voluntary and shall be paid in accordance with local and/or national laws or
sector agreements including with the trade union. Overtime shall be monitored.
[Overtime work shall be voluntary and in accordance with local and/or National Laws].""and/or" -> "and" no need of "or"The implementation of objectives consistent with technical and human feasibility, within an acceptable timeframe, must be
guaranteed by the unit of certification. Additional objectives must also be integrated into this process, to avoid disguised forced labor.

#

Indicator

641 6.7.7

642 6.7.7

643 6.7.7

644 6.7.7

645 6.7.7
646 6.7.7

647 6.7.7
648 6.7.7

Comment (English)"In indicator 6.7.7 the phrase ""transportation and/or communication restrictions should not be used as an action to enforce
discipline"" to be removed because it causes multi interpretation.
Whether the prohibition of using a cellphone in a particular station that can endanger the safety of workers and colleagues, includingin the sense of restrictions""The phrase ""restrictions on transportation and/or communication should not be used as an action to enforce discipline"" to be
removed because it causes multi interpretation.
Whether the prohibition of using a cellphone in a particular station that can endanger the safety of workers and colleagues, includingin the sense of restrictions""Proposal:
The phrase ""restrictions on transportation and/or communication should not be used as an action to enforce discipline"" to be
removed because it causes multi interpretation.
Whether the prohibition of using a cellphone in a particular station that can endanger the safety of workers and colleagues, includingin the sense of restrictions"
Proposed indicator 6.7.7 The sentence "transportation restrictions and/or communication should not be used as an action to enforce
discipline" to be removed because it causes multi interpretation. Whether the prohibition of using a cellphone in a particular stationthat can endanger the safety of workers and colleagues, including in the sense of restrictions
Proposed Indicator 6.7.7: The phrase "Limitation of transportation and/or communication should not be used as an action to enforce
discipline" is removed because it causes unclear and multi -interpretation in the application and audit.
"Cause multiple interpretations, whether by providing parking space and prohibition using cellphones in certain stations that can
endanger the safety of workers and their colleagues, including in the sense of restrictions
This sentence is deleted: Transportation and/or communication restrictions should not be used as an action to enforce discipline."
Indicator 6.7.7 (c) is proposed in order to: The phrase "restrictions on transportation and/or communication should not be used as anaction to enforce discipline" to be removed because it causes multi interpretation.
"Indicator 6.7.7 (c) Proposed:
The phrase ""restrictions on transportation and/or communication should not be used as an action to enforce discipline"" to be
removed because it causes multi interpretation."#Indicator

649 6.7.7

650 6.7.7

651 6.7.7

652 6.7.7
653 6.7.7

654
655
656
657
658

6.7.7
6.7.7
6.7.7
6.7.7
6.7.7

659 6.7.7

Comment (English)"[I] 6.7.7
The phrase ""restrictions on transportation and/or communication should not be used as an action to enforce discipline"" to be
removed because it causes multi interpretation.
Whether the prohibition of using a cellphone in a particular station that can endanger the safety of workers and colleagues, includingin the sense of restrictions""The phrase ""restrictions on transportation and/or communication should not be used as an action to enforce discipline"" to be
removed because it causes multi interpretation.
Whether the prohibition of using a cellphone in a particular station that can endanger the safety of workers and colleagues, includingin the sense of restrictions""Proposed indicator 6.7.7:
The phrase ""restrictions on transportation and/or communication should not be used as an action to enforce discipline"" to be
removed because it causes multi interpretation.
"
Proposed Indicator Improvement 6.7.7: Workers have access to transportation and/or communication (cellphones, SIM cards, pulses).
"Proposed 6.7.7: Proposal: The phrase ""Limitation of transportation and/or communication should not be used as an action to
enforce discipline"" to be removed because it causes multi interpretation.
Whether the prohibition of using a cellphone in a particular station that can endanger the safety of workers and colleagues, includingin the sense of restrictions"
It is not clear the scope of this indicator, subjectivity in its implementation and auditability.
6.7.7 Clarify the indicator since it is not viable with the accesses that are requested (phones, SIM cards, credits)
Define the scope in terms of transport and communications.
It is suggested to clarify the scope, referred to with access to communication and transportation
Define the scope of the indicator, since it is provided for multiple interpretations, (which is the obligation of the company to provide
the worker).
[Abidjan WS] 6.7.7 Access to transportation and communication - requirement is too wide and leads to multiple interpretation. Suggest
to delete the first sentence - make clear that workers's access to transportation and communication are not taken away as punishment
due to weak performance. There should be recognised some rules where such restriction is to be imposed due to safety issue and/or
confidentiality issues. Example, where there is restriction of taking picture due to confidential matters, and or mobile phone is notallowed in certain working condition.

#Indicator

660 6.7.8

661 6.7.8
662 6.7.8
663 6.7.8

664 6.7.8
665 6.7.8
666 6.7.8
667 6.7.9

668 6.7.9

669
670
671
672
673

6.7.9
6.7.9
6.7.9
6.7.9
6.7.9

674 6.7.9

Comment (English)"Should refer to 6.7.1B,
6.8.1 B is health and safety indicators.
"
wrong ref.
Suggest to correct the reference [(ref. 6.8.1 B) irrelevant - 6.8.1 B refers to prevent work-related injuries and ill health]
HRDD is mentioned in 6.7.9 particularly in the context of an assessment and focusing on recruitment process only. HRDD should be
implemented and assessed to cover the entire scope of human rights. It is not clear what are the practical implications or how it's
going to be applied for mills. We note that continued relevance of RSPO certification will depend also in how far it can support theimplementation of HRDD related legal requirements such as the CSDDD.
It is only fair for growers to see the framework of reimbursement and to be agreed upon the before growers can decide whether toaccept the guidance.
This wording is not clear, does it refers to hiring fees?
6.8.1 B is not related to the issue of the indicator, it must be explicit that the payment of contracting quotas is not allowed.
"To define the clearly on the term of the access to transport and/or communication in the list of definition.
To provide what are the conditions that can be assumed that the restriction of transport and/or communication has occurred / takeplace in the UoC.. "HRDD is a very broad scope and child labour, discrimination, overtime have been covered under other indicators. This assessment shallconfine to implementation of recruitment practices as per 6.7.1 and to remove the word "third party". Let the UoC decides the internalteam who is capable to conduct the assessment.
[Accra WS] 6.7.12 reference to 6.8.1 b should be 6.7.1B
Remove the word "Any" and the payment as defined in ILO guidance.
6.7.9 The assessment should always be conducted by a 3rd party, recognised by RSPO.
wrong ref.
"RSPO Principles & Criteria 2023 shall be reimbursed for any payments (ref: 6.8.1 b) this should ref to 6.7.1.
6.8.1 B is for health and safety indicators. "Suggest to correct the reference [(ref. 6.8.1 B) irrelevant - 6.8.1 B refers to prevent work-related injuries and ill health]#Indicator

675 6.7.9

676 6.7.9

677 6.7.9

678 6.7.9

Comment (English)"In this 6.7.9 indicator there are several proposals, namely:- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator.""Indicator 6.7.9 (c) Proposed:- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The phrase ""The assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the recruitment process"" removed from the indicator.""6.7.9 Please explain about the definition and purpose of the completion of the Human Rights Completion, and how to carry out thecomplete test
What is the connection between the Human Rights Completion Test with Indicator 6.8.1 B?
""- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator."#Indicator

679 6.7.9

680 6.7.9

681 6.7.9

Comment (English)"This indicator is removed, because of the recruitment process
Internal and third parties refer to regulations
the applicable national and several indccathers havecover the requirements that must be carried out related to the process
recruitment and is quite comprehensive.
2.1.2, 2.2.3, 2.4.2, 2.5.1, 6.1.1, 6.1.2, 6.2.2, 6.2.4, 6.4.1, 6.4.2, 6.5.1, 6.7.1, 6.7. 3 6.7.8, 6.7.10, 6.7.11, and 6.7.12.
For example 2.1.2: ""... legal due diligence of all
Contracted third parties, recruitment agencies, service
Providers and Labor Contractors.""- Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process and Third Party must be carried out acertification unit to identify and overcome the potential impact of human rights on workers. This assessment must be carried out byinternal staff who are not involved in the recruitment process or by third parties in accordance with applicable national regulations.
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator.""Proposed 6.7.9:
1. Changes in sentence indicators 6.7.9 to""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process and Third Party must be carried out acertification unit to identify and overcome the potential impact of human rights on workers. This assessment must be carried out byinternal staff who are not involved in the recruitment process or by third parties in accordance with the applicable national
regulations"" .
2. The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator."#Indicator

682 6.7.9

683 6.7.9

684 6.7.9

685 6.7.9

Comment (English)"Proposal:- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator."
Indicator 6.7.9 (c) Proposed: - Changes in sentences Indicators to "Assessment of Annual Human Rights Complete Test on the Internal
Recruitment and Third Party Process must be carried out to identify and overcome the potential impact of human rights on workers.
This assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties in accordancewith applicable national regulations ". - The phrase "The assessment must include the process of identification and remediation of all
payments (ref. 6.8.1 b) conducted by workers during the recruitment process" removed from the indicator.
"Indicator 6.7.9 (c) is proposed for:1. Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties according to theapplicable national regulations "".
2. The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the recruitment process"" is removed from the indicator.""[I] 6.7.9- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator."#Indicator

686 6.7.9

687 6.7.9

688 6.7.9

Comment (English)"Proposal:
Indicator 6.7.9 is deleted, due to the recruitment process
Internal and third parties refer to regulations
the applicable national and several indccathers havecover the requirements that must be carried out related to the process
recruitment and is quite comprehensive.
2.1.2, 2.2.3, 2.4.2, 2.5.1,
6.1.1, 6.1.2, 6.2.2, 6.2.4, 6.4.1, 6.4.2, 6.5.1, 6.7.1, 6.7.3
6.7.8, 6.7.10, 6.7.11, and 6.7.12.
For example 2.1.2: ""... legal due diligence of all
Contracted third parties, recruitment agencies, service
Providers and Labor Contractors.""6.7.9: This indicator is deleted, because the process of internal recruitment and third party refers to the applicable national
regulations and several indccatures have covered the requirements that must be carried out related to the recruitment process andare quite comprehensive.
2.1.2, 2.2.3, 2.4.2, 2.5.1,
6.1.1, 6.1.2, 6.2.2, 6.2.4, 6.4.1, 6.4.2, 6.5.1, 6.7.1, 6.7.3
6.7.8, 6.7.10, 6.7.11, and 6.7.12.
For example 2.1.2: ""... legal due diligence of all
Contracted Third Parties, Recruitment Agencies, Service Providers and Labor Contractors.""- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator."#Indicator

689 6.7.9

690 6.7.9

691 6.7.9
692 6.7.9

693 6.7.9
694 6.7.11
695 6.7.12
696
697
698
699

6.7.12
6.7.12
6.7.12
6.7.12

Comment (English)"Proposed indicator 6.7.9:- Changes in the sentence indicator to ""Assessment of Annual Human Rights Complete Test on the Internal Recruitment Process andThird Party must be carried out a certification unit to identify and overcome the potential impact of human rights on workers. This
assessment must be carried out by internal staff who are not involved in the recruitment process or by third parties accordingly
applicable national regulations "".
- The sentence ""Assessment must include the process of identification and remediation of all payments (ref. 6.8.1 b) conducted byworkers during the process
Recruitment ""removed from the indicator."
Proposed 6.7.9: (1). Changes in the sentence indicator to "Assessment of Annual Human Rights Complete Test on the Internal
Recruitment Process and Third Party must be carried out a certification unit to identify and overcome the potential impact of humanrights on workers. This assessment must be carried out by internal staff who are not involved in the recruitment process or by third
parties according to the regulations applicable national ". (2). The phrase "Assessment must include the process of identification andremediation of all payments (ref. 6.8.1 b) conducted by workers during the recruitment process" removed from the indicator.
The 6.8.1 is not related to the item, it is suggested to eliminate taking into account that there are internal audit procedures that
support legal compliance as the standard requirements, including Human rights.
The 6.8.1 is not related to the item, it is suggested to eliminate-teaching that there is already a due diligence in principle 2 thisrequirement is repeated and that it would be the minimum that should be evaluated in Human Rights to be clear in an audit in an audit.
The 6.8.1 is not related to the issue discussed in this indicator, it is suggested to eliminate taking into account that there is an indicatorin principle 2 that includes the evaluation of legal compliance and compliance with human rights[Abidjan WS] 6.7.11 to add (if applicable) - where there is no reimbursement needed - this is not needed. As this is not applicable in
Africa.
The clause has provided clear timeline and guidance regarding reimbursement. A detail procedure should be ruled further by each UoC
following their policy and SOPs. The P&C should focus more on how auditor can check that UoC has implement it within the timeline.
[Accra WS] 6.7.8 (reference to 6.8.1B is wrong), should be 6.7.1B[Accra WS] 6.7.9 - RSPO guidance on due diligence (checklist) needed.
[Accra WS] 6.7.9 (reference to 6.8.1 is wrong) should be 6.7.1"Should refer to 6.7.1B,
6.8.1 B is health and safety indicators.
"#Indicator

700 6.7.12

Comment (English)

704 6.7.12
705 6.8"> Suggest to correct the reference> Suggest HRDD component to be more holistic: at mill level, UoC needs to make sure they have the HRDD process/system
implemented for the non-certified portion of their supply base i.e. for example assessment of human rights would involve field workand consultation with potentially affected stakeholders about risk and ways to address those risks.
[>(ref. 6.8.1 B) irrelevant - 6.8.1 B refers to prevent work-related injuries and ill health>HRDD is only appearing once through an assessment of internal and 3rd party recruitment processes though the implementation of
HRDD is relevant to the entire mill level].
"
6.7.12 What about contractors' workers? How does this apply to them?
6.7.12: should refer to "6.7.1" not "6.8.1 B" related to SOP and POD K3"Should refer to ""6.7.1"" not ""6.8.1 B""
related to SOP and POD K3"
It is suggested to clarify the scope of the reimbursement of the hiring costs, otherwise eliminate the indicator.
"Training and compliance must be ensured by the unit of certification.

706 6.8

Following multi-stakeholder consultations, the RSPO must issue clear guidelines on respect for workers' health and the prevention of
workplace accidents, whether on plantations or in mills.
These guidelines must be applied through various channels: displays, signage, training, awareness-raising, incentives, etc.""Training and compliance must be ensured by the unit of certification.

701 6.7.12
702 6.7.12
703 6.7.12

Following multi-stakeholder consultations, the RSPO must issue clear guidelines on respect for workers' health and the prevention of
workplace accidents, whether on plantations or in mills.
These guidelines must be applied through various channels: displays, signage, training, awareness-raising, incentives, etc."#Indicator

707 6.8

708 6.8
709 6.8.1
710 6.8.1
711 6.8.1

712 6.8.1
713 6.8.1
714 6.8.1
715
716
717
718

6.8.1
6.8.1
6.8.1
6.8.2

Comment (English)"[HRSS] To include an indicator on worker accident insurance - this was previously covered under Indicator 6.7.4 of the 2018 P&C.
Excluding this risks diluting the standards.
Proposal, ""6.8.11 All workers are provided with medical care and covered by accident insurance. Costs incurred from work-related
incidents leading to injury or sickness are covered in accordance with national law or by the unit of certification where national law
does not offer protection. Occupational injuries and illnesses shall be recorded using Lost Time Accident (LTA) metrics. Processes toinvestigate work-related incidents shall be developed and implemented. Reports of the investigation shall be documented. Findings
from the investigations are forwarded to the Health and Safety Committee for the purposes of updating the Health and Safety Plan.
Costs incurred from work-related incidents leading to injury or illness, shall be covered by the Unit of Certification in accordance with
National Laws."""6.8 In general, indicators - indicators in the criteria 6.8 are too detailed. It is recommended to make the indicator to be more simple,
where other detailed things are included in the guide only
These policies must be applied through various channels: displays, signage, training, awareness-raising, incentives, etc.
"These policies must be applied through various channels: displays, signage, training, awareness-raising, incentives, etc."">Suggest to ensure that a safe and healthy working place is provided to all workers and this includes at least access to safe drinking
water, basic sanitation facilities, REST AREAS, and protective equipment free of any cost.
>Suggest to ensure that there is regular maintenance of machinery, equipment and work materials/devices in order to ensure theirsafe and efficient functioning[Occupational Health and Safety policies and procedures shall be established and implemented. The policies and procedures shall
include the following:a) Assure a safe and healthy working place]"
These policies must be applied through various channels: displays, signage, training, awareness-raising, incentives, etc.
6.8.1 Change the word bad health, for occupational diseases established by the environment of each company, fulfilling the national
legislation of each country.
6.8.1 Change the word poor health, for occupational diseases established by the environment of each company, complying with thenational legislation of each country
injuries and diseases, it should be the writing
How the ANC intervenes in these requirements.
It is suggested to change the bad health for occupational diseases.
[HRSS] Propose to add "The H&S Plan shall be communicated and made available to all workers." to align with Criteria 3.6 of 2018 P&C#Indicator

719 6.8.2

720 6.8.2

721 6.8.2

722 6.8.2
723 6.8.2
724 6.8.2
725 6.8.2
726 6.8.2

727 6.8.2
728 6.8.2
729 6.8.2

Comment (English)"Please consider the below comments:•Chemical risks should be assessed as per the UN Global Harmonising System and identified and labelled accordingly.
•H&S Committee and assessments should include assessments to ensure the structural integrity of buildings and the proper and safe
installation of electrical wiring, lighting and gas fixtures.
•H&S plans should ensure warning signs and safety information for dangerous equipment is provided and visible to workers.
""""Training and compliance must be ensured by the unit of certification.
Following multi-stakeholder consultations, the RSPO must issue clear guidelines on respect for workers' health and the prevention of
workplace accidents, whether on plantations or in mills.
These guidelines must be applied through various channels: displays, signage, training, awareness-raising, incentives, etc."""
6.8.2 There is confusion here. There are certain things that the H&S committee can do and certain things that have to be done
independently by the UoC either through professional or management staff. What is required of the H&S committee is awareness ofwhat is going on. Thus, parking so much under a single H&S committee management has created an indicator that will be difficult toaudit and implement. Some revision is needed. The H&S committee should meet monthly.
In indicators 6.8.2 Points f The term Welfare Committee is proposed to be changed to a gender committee (relevant to indicator 6.6.3)
Proposed 6.8.2 Points F: Terms of the Welfare Committee for Welfare Revised into Gender Committee (to be relevant to indicators
6.6.3)
Point F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant to indicators 6.6.3)
Point F The term Women's Welfare Committee is changed to the Gender Committee (relevant to indicators 6.6.3)"Proposal:
Point F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant to indicators 6.6.3)"
Indicator 6.8.2 (c) Proposed to: Points F The term "female welfare committee" is changed to "gender committee" (relevant toindicators 6.6.3).
6.8.2 Points F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant to indicators
6.6.3)
6.8.2 Points F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant to indicators
6.6.3)

#

Indicator

730 6.8.2

731 6.8.2

732 6.8.2
733 6.8.2

734 6.8.2
735 6.8.2
736 6.8.2

737 6.8.3
738 6.8.3
739 6.8.3

740 6.8.3
741 6.8.3

Comment (English)"[I] 6.8.2
Point F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant to indicators 6.6.3)""Indicator 6.8.2 (c) Proposed:
Point F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant to indicators 6.6.3)"
Proposed changes 6.8.2, namely point f The term Women's Welfare Committee is changed to the Gender Committee (relevant toindicators 6.6.3)"Proposed 6.8.2: Points F The term Women's Welfare Committee is proposed to be changed to the Gender Committee (relevant toindicators 6.6.3)"
6.8.2 Change the Welfare Committee of Women for Gender Committee, in the same way as it is in indicator 6.6.3
6.8.2 Change the Welfare Committee of Women for Gender Committee, in the same way as it is in indicator 6.6.4"It is suggested that the committee is composed of management representative and not by a member of the management.
In item c) it is suggested to change the word ""eliminate"" by ""mitigate or control threats in the workplace.""
In item f) it is suggested to change ""Women's Welfare Committee"" for ""Gender Committee"".
"This indicator is too lengthy and it dilutes the actual purpose. Indicator shall be precise and auditable. The sub-points shall be moved to
guidance.
6.8.3 The healthy and safety component for young workers and workers with disabilities is excluded here. Only emphasizing women(gender-related).
"In indicator 6.8.3- The phrase ""Identifying Occupational Safety and Health Problems"" was changed to ""Identify Occupational Safety and Health
Issues"" (translation is not appropriate)"
6.8.3 Hirarc can be done by certain personnel as long as they have received AK3 training (there is no 3 -year time requirement).
"The phrase ""identify safety problems andOccupational health ""was changed to"" identify issues
Safety and Occupational Health "". Lack of translationin accordance."#Indicator

742 6.8.3
743 6.8.3
744 6.8.3

745 6.8.3
746 6.8.3

747 6.8.3

748 6.8.3
749 6.8.3
750 6.8.3
751 6.8.3

752 6.8.3

753 6.8.3

Comment (English)
Proposed 6.8.3: The phrase "Identifying Occupational Safety and Health Issues" was changed to "Identifying Occupational Safety and
Health Issues". The word problem is corrected by issues (translation inappropriate)
The phrase "Identifying Occupational Safety and Health Issues" was changed to "Identifying Occupational Safety and Health Issues"(translation is not appropriate)"Indicator 6.8.3 (c) Proposed:- The phrase ""Identifying Occupational Safety and Health Problems"" was changed to ""Identify Occupational Safety and Health
Issues"" (translation is not appropriate)"
Proposed changes 6.8.3 Namely, the phrase "Identifying Occupational Safety and Health Problems" was changed to "Identifying
Occupational Safety and Health Issues". (translation is not appropriate)"Proposal:- The phrase ""Identifying Occupational Safety and Health Problems"" was changed to ""Identify Occupational Safety and Health
Issues"" (translation is not appropriate)""Indicator 6.8.3 (c) is proposed for:The phrase ""Identifying Occupational Safety and Health Problems"" was changed to ""Identifying Occupational Safety and Health
Issues"". Because the translation is not appropriate."
Indicator 6.8.3 - The sentence "Identifying Occupational Safety and Health Problems" was changed to "Identify Occupational Safety and
Health Issues" (translation is not appropriate)- The phrase "Identifying Occupational Safety and Health Problems" was changed to "Identify Occupational Safety and Health Issues".
(translation is not appropriate)- The phrase "Identifying Occupational Safety and Health Problems" was changed to "Identify Occupational Safety and Health Issues"(translation is not appropriate)"Proposal 6.8.3: The phrase ""Identifying Occupational Safety and Health Issues"" was changed to ""Identifying Occupational Safety
and Health Issues"" (translation is not appropriate)""[I] 6.8.3- The phrase ""Identifying Occupational Safety and Health Problems"" was changed to ""Identify Occupational Safety and Health
Issues"" (translation is not appropriate)"
Indicator 6.8.3 - The sentence "Identifying Occupational Safety and Health Problems" was changed to "Identify Occupational Safety and
Health Issues" (translation is not appropriate)#Indicator

754 6.8.3
755 6.8.3

756 6.8.3

757 6.8.3
758 6.8.4
759
760
761
762

6.8.4
6.8.4
6.8.5
6.8.5

763 6.8.5
764 6.8.5
765
766
767
768
769
770
771

6.8.5
6.8.5
6.8.6
6.8.7
6.8.7
6.8.7
6.8.7

Comment (English)
6.8.3: The phrase "Identifying Occupational Safety and Health Problems" was changed to "Identifying Occupational Safety and Health
Issues". The translation is not appropriate.
"Proposed indicator 6.8.3: The phrase ""identify safety problems andOccupational health ""was changed to"" identify issues
Safety and Occupational Health "". Lack of translationin accordance."
The legislation determines the profile that the person responsible for the IAECR evaluation must have and does not follow theguidelines contemplated by the indicator, for this reason it must be established that for those countries that legislate on the subject, it
must follow what indicates the legislation
It is suggested to eliminate "every three years" and leave the scope "according to applicable national legislation."[HRWG] Recommendation: The 2018 requirement should be reinstated. It is important that the H&S Plan should be communicated andmade clear to the workers in their local languages with the maps/drawings/diagrams made available to them.
6.8.4 This requirement can be deleted because risk mitigation and repair action are part of the manufacture of hierarc (indicator 6.8.3).
Indicator with incomplete information
Sufficient water and sanitation facilities, including toilets, should be provided in the field which are well maintained.
6.8.5 to add regarding safety culture. Also to add ..."the prevention of injury, illness, and death of workers.Also a provision of safe
systems of work, the provision of safety equipment/tools, a safe working conditions, risk assessment, management planning &information for workers
6.8.5 Respect the national legislation of each country with the scope of first aid, having emergency brigades, define the scope within
the indicator
6.8.5 Respect the national legislation of each country with the scope of first aid, having emergency brigades, define the scope within
the indicator.
Keep in mind that training the entire workforce in first aid is difficult to comply, each country must comply with its legislation
Defining the scope of "basic first aid" to workers, taking into account that training the entire workforce may not be attainable in reality.
Sufficient water and sanitation facilities, including toilets, should be provided in the field which are well maintained.
Sufficient water and sanitation facilities, including toilets, should be provided in the field which are well maintained.
PPE should be comfortable.
Expiration dates WHERE APPLICABLE. Not all first aid equipment has expiration dates.
To provide guidance and explanation on how the evaluation to the accessibility of sanitation facilities shall be done by UoC.

#

Indicator

772 6.8.7

773 6.8.7
774
775
776
777
778
779

6.8.7
6.8.7
6.8.7
6.8.7
6.8.7
6.8.7

780 6.8.7
781 6.8.7
782 6.8.7

783 6.8.7

Comment (English)"Indicator 6.8.7 Points D should be changed to: The life life of the APD provided must be recorded and the PPE that has expired should
not be used.
There is a certification unit that applies the APD replacement system for each PPE is damaged. That way, even though there is an
estimated life life, it is no longer a sole reference. So there are conditions where the life life has been exceeded but the PPE is still
suitable for use and will not be replaced. Will this be considered a violation of indicators 6.8.7 points d? For the record, not all PPE
producers include information about the service life so that generally the service life is determined by the certification unit based on
the field experience. This could be different from the reality of each worker who uses the PPE.""Indicators become more detailed. Proposed tousing the P&C 2018 indicator sentence."
Keep using the old indicator sentence (P&C 2018)
In indicator 6.8.7 you should continue to use the old indicator sentence (P & C 2018 Indicator 6.7.3)
6.8.7 Keep using the old indicator sentence (P&C 2018)
Proposed 6.8.7 still use the old indicator sentence (P&C 2018)
Keep using the old indicator sentence (P&C 2018)"Proposed Improvement of Indicators 6.8.7 to become workers using appropriate personal protective equipment (PPE), and isprovided without being collected payment
to all workers at work, as protection in all operations that havePotential hazards, such as pesticide applications, machine operations, land preparation, and harvest. Facility
Sanitation is available for workers who use pesticides so that workers can release PPE,
clean himself and wear his personal clothes."
Keep using the old indicator sentence (P&C 2018, 6.7.3)
Indicator 6.8.7 (c) is proposed to: keep using the old indicator sentence (P&C 2018).
"[I] 6.8.7
Keep using the old indicator sentence (P&C 2018)""Indicator 6.8.7 (c) Proposed:
Keep using the old indicator sentence (P&C 2018)"

#Indicator

784 6.8.7

785 6.8.7
786 6.8.7
787 6.8.7
788 6.8.7
789 6.8.7
790 6.8.7
791 6.8.7
792 6.8.7
793 6.8.8
794 6.8.8
795 6.8.8
796 6.8.8
797 6.8.8

798 6.8.8
799 6.8.8
800 6.8.8

Comment (English)"Proposed indicator 6.8.7: Proposed forusing the P&C 2018 indicator sentence.
The indicator is too more detailed to be an indicator."
6.8.7The uses the old indicator sentence (P&C 2018)
Indicator 6.8.7 Keep using the old indicator sentence (P&C 2018)"Proposal:
Keep using the old indicator sentence (P&C 2018)"
Proposed 6.8.7 (c): Keep using old indicator sentences at P&C RSPO 2018, namely Indicator 6.7.3 (C)"Proposal 6..8.7
Proposed indicators continue to use old indicator sentences (P&C 2018)"
6.8.7: The indicator becomes more detailed. Proposed to use the P&C 2018 indicator sentence.
6.8.7. A more simplicated indicator for small associated or system producers should be defined, as they do for PPIs. Small producers
must identify and know the risks to health and safety, have safe facilities, make use of appropriate EPP and receive training.
6.8.7. A more simplicated indicator for small associated or system producers should be defined, as they do for PPIs. Small producers
must identify and know the risks to health and safety, have safe facilities, make use of appropriate EPP and receive training.
PPE should be comfortable.
[6.8.8] Does not sound realistic in the case of the field workers.
Suggest to reinforce the requirement i.e. to make sanitation facilities available and in sufficient number in the plantation fields [Issue:
There are insufficient sanitation facilities in the plantation fields.].
Suggest to reinforce the requirement i.e. to make sanitation facilities available and sufficient in the plantation fields [Issue: There areinsufficient sanitation facilities in the plantation fields].
Sustained objection from Growers: This is not practical and we must not raise the ceiling without raising the bar. Such commitments onaccessibility of sanitary facilities lead to financial impact therefore shared responsibility on the uptake of CSPO shall be taken into
considerations before growers can commit to this. The commitments on shared responsibility is relatively poor at this point of time.
Please drop this indicator.
"PPE should be comfortable. "It is suggested that national legislation be paid in the field.
It is suggested that national legislation be paid in the field.

#Indicator

801 6.8.9

802 6.8.9

803 6.8.9
804 6.8.9

805 6.8.9

806 6.8.9
807 6.8.9

808 6.8.9

Comment (English)"[HRSS] To include an indicator on worker accident insurance - this was previously covered under Indicator 6.7.4 of the 2018 P&C.
Excluding this risks diluting the standards.
Proposal, ""6.8.11 All workers are provided with medical care and covered by accident insurance. Costs incurred from work-related
incidents leading to injury or sickness are covered in accordance with national law or by the unit of certification where national law
does not offer protection. Occupational injuries and illnesses shall be recorded using Lost Time Accident (LTA) metrics. Processes toinvestigate work-related incidents shall be developed and implemented. Reports of the investigation shall be documented. Findings
from the investigations are forwarded to the Health and Safety Committee for the purposes of updating the Health and Safety Plan.
Costs incurred from work-related incidents leading to injury or illness, shall be covered by the Unit of Certification in accordance with
National Laws.""""In indicator 6.8.9 there are several proposals namely- Emergency response team related to wildlife refers to national regulations- Proposal of the phrase ""Emergency Response Team Wildlife Problem"" was changed to ""Emergency Response Team related towildlife"""
Proposed 6.8.9: (1). Emergency Response Team related to wildlife refers to national regulations, (2). Proposed phrase "Emergency
Response Team Wildlife Problem" was changed to "Emergency Response Team related to wildlife""Emergency Wildlife Response refers to the regulations
national that applies with the aim of protecting
Workers and protected animals.""- Emergency response team related to wildlife refers to national regulations- Proposal of the phrase ""Emergency Response Team Wildlife Problem"" was changed to ""Emergency Response Team related towildlife"""Emergency Wildlife Response refers to the National Regulation"Indicator 6.8.9 is proposed to:
1. Emergency Response Team related to wildlife refers to national regulations.
2. Proposal of the phrase ""Emergency Response Team Wildlife Problem"" was changed to ""Emergency Response Team related towildlife"".""Indicator 6.8.9 Proposed:- Emergency response team related to wildlife refers to national regulations- Proposal of the phrase ""Emergency Response Team Wildlife Problem"" was changed to ""Emergency Response Team related towildlife"""#

Indicator

809 6.8.9
810 6.8.9

811 6.8.9

812 6.8.9
813 6.8.9
814 6.8.9
815 6.8.9
816
817
818
819

6.8.9
6.8.9
6.8.9
6.8.10820 6.8.10
821
822
823
824

6.8.106.8.106.8.11
6.8.11

Comment (English)
Indicators 6.8.9 Proposed improvements to indicators: 1. Emergency response team related to wildlife refers to national regulations. 2.
Proposal of the phrase "Emergency Response Team Wildlife Problem" was changed to "Emergency Response Team related to wildlife".
"Proposal:
The formation of a wildlife emergency response team was revised into the formation of a wildlife emergency response team referring
to national regulations""Proposal:- Emergency response team related to wildlife refers to national regulations- Proposal of the phrase ""Emergency Response Team Wildlife Problem"" was changed to ""Emergency Response Team related towildlife"""
Proposed Amendment 6.8.9 namely, Emergency Wildlife Response refers to national regulations
Proposed Indicator 6.8.9: Emergency Wildlife Response refers to the national regulation that applies with the aim of protecting
workers and protected animals.
"- Emergency response team related to wildlife refers to national regulations- Proposed sentence ""Emergency Response Team"6.8.9: Emergency Wildlife Response refers to the national regulation that applies with the aim of protecting workers and protectedanimals.
Make it clearer to which it refers to wildlife so that any producer and auditor understands it.
Clarify what refers to emergencies for wildlife
Clarify Wildlife Emergencies
6.8.10 Maintain the term pesticides, since pesticides is a very broad according to the country or legislation. Similarly, the average exam
must be according to the product used.
"6.8.10 Maintain the term pesticides, since pesticides is a very broad according to the country or legislation.
Similarly, the average exam must be according to the product used."
6.8.10. The term pesticide must be maintained, since pesticide has a different definition in some LATAM countries.
Annual medical exams are performed according to the pesticide product used.
wildlife response, when applicable[HRSS] Proposal: "The accessibility of sanitation facilities for workers shall be evaluated by the Unit of Certification, in consultation with
Workers’ representatives. Provision of any sanitation facilities following the consultation shall be maintained and ensure safe accessfor Workers especially women."#

Indicator

825 6.8.11

826 6.8.11

827 6.8.11
828 6.8.11

829 6.8.11

830 6.8.11
831 6.8.11

832 6.8.11

833 6.8.11

Comment (English)"[HRWG] Recommendation: Please reinstate the 2018 requirement.
Worker accident insurance needs to be covered and this requirement should be restored as an indicator as per the 2018 P&C.
CNV studies show there are often misunderstandings on who is responsible for paying insurances which may differ in context andnational laws. Restore indicator.
"
In indicator 6.8.11 The sentence "records injuries and diseases due to work accidents using metrics of loss of work time (Lost
Accident/LTA)" returned the sentences such as old indicators 6.7.5 "recorded work accidents using the size of the accident that caused
the loss of work time (lost time Accident/LTA) ""Recorded injuries and diseases due to work accidents using metrics of loss of work time (Lost Accident/LTA)" returned to 6.7.5 "Herecorded a work accident using the size of an accident that caused a loss of work time (Lost Time Accident/LTA)"
The proposed change of 6.8.11 is, "He recorded injuries and diseases caused by work accidents using metrics to lose work time (Lost
Time Accident/LTA)". returned to 6.7.5 "The recorded work accident using the size of an accident that caused a loss of work time (Lost
Accident/LTA)""Proposal:""Recorded injuries and diseases due to work accidents using metrics of loss of work time (Lost Accident/LTA)"" returned to 6.7.5 ""Herecorded a work accident using the size of an accident that caused a loss of work time (Lost Time Accident/LTA)"""
Proposal: "Recorded injuries and diseases caused by work accidents using metrics of loss of work time (LTA)" Returned to 6.7.5"Recorded work accidents using the size of an accident that caused a loss of work time (Lost Time Accident/LTA)""Indicator 6.8.11 is proposed to: sentence""Recorded injuries and diseases due to work accidents using metrics of loss of work time (Lost Accident/LTA)"" returned to 6.7.5 ""Herecorded a work accident using the size of an accident that caused a loss of work time (Lost Time Accident/LTA)""""Proposed Indicator Improvement 6.8.11 Becomes:
Work accidents are recorded using Lost Time Accident (LTA). The process of investigating incidents related to work accidents must be
prepared and implemented. The investigation report must be documented. The findings of the investigation were then forwarded to
the K3 Committee to update the K3 plan. Costs arising from incidents related to work accidents that cause injury or
Disease is borne by the certification unit in accordance with national law.""Indicator 6.8.11 Proposed:""Recorded injuries and diseases due to work accidents using metrics of loss of work time (Lost Accident/LTA)"" returned to 6.7.5 ""Herecorded a work accident using the size of an accident that caused a loss of work time (Lost Time Accident/LTA)"""#

Indicator

834 6.8.11

835 6.8.11

836 6.8.11

837 6.8.11
838 6.8.12
839 6.8.12
840 6.8.12

Comment (English)"Proposal:""Recorded injuries and diseases due to work accidents using metrics of loss of work time (Lost Accident/LTA)"" returned to 6.7.5 ""Herecorded a work accident using the size of an accident that caused a loss of work time (Lost Time Accident/LTA)""""Recorded injuries and diseases due to work accidents using metrics to lose work time (Lost Time Accident/LTA)" changed to "recorded
work accidents using the size of the accident that caused the loss of work time (Lost Time Accident/LTA)" - returned to indicator 6.7. 5
P&C 2018"Proposed 6.8.11:""Recorded injuries and diseases due to work accidents using the Metric Metric Loss of Working Time (LTA)"" Returned to P&C 2028
Indicators 6.7.5 namely ""recorded work accidents using the size of the accident that causes lost time accident/LTA"" """"Noted injuries and diseases due to work accidents using metrics to lose work time (Lost Accident/LTA)". returned to 6.7.5 "Therecorded work accident using the size of an accident that caused a loss of work time (Lost Accident/LTA)"
6.8.12. Do not change the pesticide term for pesticide, since pesticide has a different definition in some LATAM countries.
6.8.12. Do not change the pesticide term for pesticide, since pesticide has a different definition in some LATAM countries. At the
beginning of the indicator they speak of pesticide but then refer to pesticide, which generates confusion
6.8.12. Do not change the pesticide term for pesticide, since pesticide has a different definition in some LATAM countries.

#

Indicator

Comment (English)

1

7

2

7

3

7.1

We would strongly urge that throughout Principle 7 (and throughout the document), attention is paid to the substantial scientificevidence base and existing recommendations on improving effectiveness of RSPO P+C already created by the scientificcommunity, including the Sensor project commissioned by the RSPO: http://www.sensorproject.net/reports/ This is a valuable
body of research and practical recommendations, and incorporating it better into reviews of the Standards would make theprocess more efficient and effective"Organic palm oil producers prove that production works without using chemical-synthetic pesticides if prevention is well done.
RSPO should commit to the renunciation of extremly hazardous pesticides.
Furthermore, define a broad minimum buffer zone to local communities, where application of sanitary products is not allowed.""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

4

7.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.
New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."#Indicator

Comment (English)

57.1"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

6

7.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

7

7.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""The use of BCA can sometimes have greater negative effects on the environment than pesticides.
This must be determined on a case by case basis, predetermined by a study.
How it currently reads, auditors may want companies to FIRST try out all possible BCA options, before any pesticides are applied,even though a BCA option may not the best option. We must be very careful about this.
"#

Indicator

Comment (English)

87.1"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

9

10

7.1

7.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""Recommendation for Criteria 7.9:1)Consider updating the text to “The Unit of Certification shall not cause deforestation or damage ………, peatlands, and othernatural ecosystems. HCV areas, ….”
2)Consider adding a definition of “natural ecosystems”. A suggested definition is the Accountability Frameworks’ definition ofnatural ecosystem (see Definitions | Accountability Framework initiative - Accountability Framework (accountability-framework.
org))3)If the term “conservation area” is also used, a scoping of “conservation area” is required.
4)We support the statement on RTE species protection. We suggest that indicators related to RTE management are included aswell.
Rationale:1)To align with the existing responsible supply chain framework so that we can enhance the use of common language on theeffectiveness of the grievance system.
2)To make the term ‘natural ecosystem’ consistent with indicator 7.9.8.
""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
"#

Indicator

Comment (English)

11

7.1

"""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, dependingon the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

12

7.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.
New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."#Indicator

Comment (English)

13

7.1

"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

14

7.1

15

7.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.
New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.
New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."#Indicator

Comment (English)

16

7.1

17

7.1

18

7.1

a taskforce must be set up by the RSPO to occasionally review or even audit grievances related to these subjects in the plantations
or Mills with the workers, without restriction of the unit of certifications"Suggest to ensure that any use of biological control agents complies with national legislation.
[The use of a Biological Control Agent (BCA) is the preferred option for the management of pests].""Also consider including criteria on human wildlife conflict. This is now only in the annex. For example by:

19

7.1.1

20

7.1.1

Human wildlife conflict, (indirectly) driven by the cultivation of oil palm, is minimized by developing
responsible management measures and damage is compensated to local communities if applicable."
7.1.1 "An integrated pest management PLAN". Please include the work plan. For years, this has been one of the weakest
indicators. RSPO has not made an attempt to stipulate the minimum content of the plan. The development of a detailed planshould now be promoted.
"This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.

21

7.1.1

Precautions towards the environment and the health of workers/local populations must be taken into account""This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.
Precautions towards the environment and the health of workers/local populations must be taken into account"#Indicator

Comment (English)

22

7.1.1

23
24

7.1.1
7.1.1

"This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.
Precautions towards the environment and the health of workers/local populations must be taken into account""This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.""Contradict with below statement: pesticide can be used where pest outbreaks are validated with strong evidence andjustification, and no alternative which can be used for major threat.

25

7.1.1

Propose the following revision, to combine both sentences: ........shall not be used or stored in the managed area unless validatedwith strong evidence and justification. ""This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.

26

7.1.1

Precautions towards the environment and the health of workers/local populations must be taken into account""This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.
Precautions towards the environment and the health of workers/local populations must be taken into account"#Indicator

Comment (English)

27

7.1.1

28

7.1.1

29

7.1.1

30
31

7.1.1
7.1.1

32

7.1.1

33

7.1.1

34

7.1.1

"[Sandakan, 21 June 2023] The Integrated Pest Management should be made applicable to the UoC only when there is any
significant pest problems.
Improve wording - ""If there is any significant pest issues within the UoC"""", an Integrated Pest Management shall be
developed..."""
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines"In the control and management of pests and diseases, reaching zero use is not realistic. The auditor must validate the efficiencyof the MIPE; On the other hand, the use of biological agents is a clean alternative regarding the use of agrochemicals, so it issuggested to withdraw from the indicator's writing, what is mentioned with respect to environmental risks. In this context, we
propose a writing that does not necessarily lead to the total elimination of the use of the alternative. So:""Integrated pest management will be developed and applied to avoid, or reduce the frequency, scope and amount of pesticide
applications, and which will lead to gradual reductions in applications.""
Likewise, it is proposed that the definitions of agrochemical, pesticide, biological control agent, herbicide, pesticide and growth
regulators be clearly included in the glossary."
This indicator for auditors is complex as written, I think that if the environmental risk analysis that each plantation should
generate subjectivity is left, no palm founder is able to develop this activity.
"In the control and management of pests and diseases, reaching zero use is not realistic. The auditor must validate the efficiencyof the MIPE; On the other hand, the use of biological agents is a clean alternative regarding the use of agrochemical They will take
into account the environmental risks indicating the technical sheets of the supplier and/or producers of biological controllers.
In this context, we propose a writing that does not necessarily lead to the total elimination of the use of the alternative. So:""Integrated pest management will be developed and applied to avoid, or reduce the frequency, scope and amount of pesticide
applications, and which will lead to gradual reductions in applications.""
Likewise, it is proposed that the definitions of agrochemical, pesticide, biological control agent, herbicide, pesticide and growth
regulators be clearly included in the glossary.""The following is suggested: ""Integrated pest management will be developed and applied to avoid, or reduce the frequency,
scope and amount of pesticide applications, and which will lead to gradual reductions in applications."""#Indicator

Comment (English)

35

7.1.2

"This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.

36

7.1.2

Precautions towards the environment and the health of workers/local populations must be taken into account""This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.

37

7.1.2

38

7.1.2

39

7.1.2

Precautions towards the environment and the health of workers/local populations must be taken into account""Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers."– RSPO could look to control the use of other highly hazardous pesticides such as those meeting the criteria for category 1
carcinogens, mutagens and reproductive toxicity of the Globally Harmonised System of Classification and Labelling of Chemicals(GHS).
This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.

#Indicator

Comment (English)

40

7.1.2

"This policy must be modelled on the recommendations of the RSPO or any other relevant stakeholder certification/guidelines.
Penalties must be clearly published and applied in the event of the use of unauthorized molecules and/or the spreading ofproducts without appropriate protection of workers.
There are agricultural practices to be put in place to prevent pest or disease attacks: these sustainable agricultural practices must
be integrated into the guidelines provided by the RSPO to companies.

41

42

43

7.1.2

7.1.2

7.1.2

Precautions towards the environment and the health of workers/local populations must be taken into account""7.1.2 Proposed to return to the first draft, namely that the use of chemicals classified as 1A 1B WHO or the Rotterdam andStockholm conventions can be done with a strong justification and validation or through permission from the government.
That way it is enough to fulfill one of these requirements.
""It is proposed to eliminate the requirement of the burden of proof and that only the authorization of government entities issufficient.
The following wording is suggested in the second paragraph: ""When there is a justification (that is, there is no other alternative)of the use for pest and/or disease outbreaks, government authorization will be obtained according to national regulations and will
be developed and implemented A detailed application and management plan to avoid and mitigate negative impacts for theenvironment and human health. """"It is proposed to eliminate the requirement of the burden of proof and that only the authorization of government entities issufficient.
The following wording is suggested in the second paragraph: ""When there is a justification (that is, there is no other alternative)of the use for pest and/or disease outbreaks, government authorization will be obtained according to national regulations and will
be developed and implemented A detailed application and management plan to avoid and mitigate negative impacts for theenvironment and human health. """#Indicator

Comment (English)

44

7.1.3

45

7.1.4

" The bones of contaminated foliar material for the PC case are included in the use of fire? If so, we propose the following writing:Burns for pest control will be prohibited.
In exceptional cases in which the fire has to be used for the control of pests and diseases, the certification unit will provide
evidence of prior approval by government authorities when required.
In the case that the practice of burning as part of the sanitary management protocol this must be clearly supported technically andscientifically as a sanitary measure. So you must mitigate and/or repair damage to the environment. """"On the other hand, there are agricultural practices to be put in place to prevent pest or disease attacks: these sustainableagricultural practices must be integrated into the guidelines provided by the RSPO to companies.

46

7.1.4

47

7.1.4

48

7.1.4

49

7.1.4

50

7.1.5

51

7.1.5

52

7.1.5

"
"Precautions towards the environment and the health of workers/local populations must be taken into account""Aerial spraying poses great risks to humans and the environment and the risks are difficult to keep under control.
RSPO should commit to a clear ban on aerial spraying.""The writing proposed in the draft standard clarifies that the prophylactic use of pesticides refers to preventive use and this typeof products are used only for pest control. We consider it important to remove the loading of the producer, suggesting thefollowing writing as follows:""Prophylactic pesticides will not be used. When the use is allowed by national regulations, its use and management, it will be
carried out as identified in national regulations and/or in the guide on best practices.""""The writing proposed in the draft of the standard, clarifies that the prophylactic use of pesticides refers to preventive use and thistype of products are used only for pest control. We consider it important to remove the loading of the producer, suggesting thefollowing writing as follows:""Prophylactic pesticides will not be used. When the use is allowed by national regulations, its use and management, it will be
carried out as identified in national regulations and/or in the guide on best practices."""Precautions towards the environment and the health of workers/local populations must be taken into accountOn the other hand, there are agricultural practices to be put in place to prevent pest or disease attacks: these sustainableagricultural practices must be integrated into the guidelines provided by the RSPO to companies.
propose to add : and/or CABI.org

#

Indicator

Comment (English)

53

7.1.5

"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

54
55

7.1.5
7.1.5

56

7.1.5

57

7.1.5

58

7.1.5

59

7.1.5

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."
On indicators 7.1.5 Definition Aerial spraying should be made clearer
Proposed for 7.1.5: Definition of aerial spraying is made clearer so that there is no multi-interpretation. In our opinion spraying
with drones, does not belong to the aerial spraying category because the scope and focus are limited. RSPO also needs to open
space for innovations that support fertilizer or herbisisa applications with high precision so that environmental impacts can be
minimized.
"The definition of aerial spraying is made clearer, andThe use of drones is not included in the aerial spraying category
which is prohibited.""Proposal:- The definition of aerial spraying is made clearer"
7.1.5 - Definition of aerial spraying / spraying pesticides through air to be detailed more clearly. In our opinion, spraying pesticides
with drone technology is not included in the aerial spraying category because it has a higher accuracy and minimal exposure toworkers/ environment so that RSPO should be able to accommodate the use of this technology as a form of innovation forcontinuous improvement.
Proposed 7.1.5: Definition of aerial spraying is made clearer. It is necessary to accommodate the use of drones for spraying
pesticides that can be more environmentally friendly, and not included in the category of air spraying. Because the use of drones
for spraying is more appropriate dosage and targeted in spraying on each tree affected by pest attacks. So that environmental
impacts can be avoided.

#Indicator

Comment (English)

60

7.1.5

61

7.1.5

62

7.1.5

63

7.1.5

64

7.1.5

65

7.1.5

66

7.1.5

Proposed 7.1.5 - Definition of aerial spraying / spraying pesticides through air so that it is detailed more clearly. RSPO needs toaccommodate the use of drone technology to spray pesticides that can be more environmentally friendly, and do not enter the
category of air spraying. Because the use of drones for spraying is more precise and precise dosage and is right on target inspraying on each tree affected by pest attacks. So that environmental impacts can be avoided.
"Proposed Indicator 7.1.5:- Definition of aerial spraying needs to be clarified.
""Proposed for 7.1.5: Definition of aerial spraying is made clearer so that there is no multi-interpretation. In our opinion spraying
with drones, does not belong to the aerial spraying category because the scope and focus are limited. RSPO also needs to open
space for innovations that support fertilizer or herbisisa applications with high precision so that environmental impacts can be
minimized.
"
Proposed for 7.1.5: Definition of aerial spraying is made clearer so that there is no multi-interpretation. In our opinion spraying
with drones, does not belong to the aerial spraying category because the scope and focus are limited. RSPO also needs to open
space for innovations that support fertilizer or herbisisa applications with high precision so that environmental impacts can be
minimized.
"Indicator 7.1.5
Proposal:- The definition of aerial spraying is made clearer"
Indicator 7.1.5. The definition of aerial spraying is defined as more clearly so that there is no multi-interpretation. In our opinion
spraying with drones, does not belong to the aerial spraying category because the scope and focus are limited. RSPO also needs toopen space for innovations that support fertilizer or herbisisa applications with high precision so that environmental impacts canbe minimized.
7.1.5: Definition of aerial spraying is made clearer, and the use of drones does not belong to the prohibited aerial spraying
category.

#Indicator

Comment (English)

67

7.1.5

68
69

7.1.5
7.1.5

70
71

7.1.5
7.1.5

"Proposal:
Definition of aerial spraying / spraying pesticides through air needs to be detailed more clearly. In our opinion, spraying pesticides
with drone technology is not included in the aerial spraying category because it has a higher accuracy and minimal exposure toworkers/ environment so that RSPO should be able to accommodate the use of this technology as a form of innovation forcontinuous improvement"
Proposed indicator 7.15: Definition of aerial spraying to be made clearer"7.1.5The definition of aerial spraying is made clearer"
Clarify the definition of aerial spraying, especially related to the use of drones.
"Proposed changes in indicators 7.1.5 to:
7.1.5 (c) The certification unit is prohibited from using the method of spraying pesticides by air except in extraordinary
circumstances when there are no other alternatives that are worth doing. Practices and innovations such as the use of drones bypaying attention to environmental and social aspects are possible and are not included in the category of spraying areas. If
spraying by air cannot be avoided, there must be previous approval from the government authority, and the application of themethod must be informed in detail to the local community affected by at least 48 hours before the action is carried out.

72
73

7.1.5
7.1.5

74
75

7.1.5
7.1.5

Comment: The definition and limitations of aerial spraying are made clearer. There are exceptions to the use of drones not belong
to the aerial spraying category
which is prohibited by paying attention to environmental and social aspects."
7.1.5 Definition Aerial spraying is made clearer
Indicator 7.1.5. The definition of aerial spraying is defined as more clearly so that there is no multi-interpretation. Spraying withdrones, does not belong to the aerial spraying category because the scope and focus are limited and this is for innovations that
support the application of fertilizer or herbicide with high precision so that environmental impacts can be minimized.
Clarify the definition of aerial spraying, especially related to the use of drones.
"Proposed Indicator 7.1.5:- It is necessary to clarify the definition of aerial spraying- Proposing a drone is not included in the aerial spraying category"#Indicator

Comment (English)

76

7.1.5

77

7.1.5

78

7.1.6

Proposed 7.1.5 - Definition of aerial spraying / spraying pesticides through air so that it is detailed more clearly. RSPO needs toaccommodate the use of drone technology to spray pesticides that can be more environmentally friendly, and do not enter the
category of air spraying. Because the use of drones for spraying is more precise and precise dosage and is right on target inspraying on each tree affected by pest attacks. So that environmental impacts can be avoided.
The obligation of prior approval of the government authorities must be modified by: the existing national regulation in eachcountry will be fulfilled to carry out an air fumigation.
"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
The use of molecules must be regulated and properly monitored.
But it is above all farming practices that need to be guided to help the unit of certification in an operational way.

79

7.1.6

80

7.1.7

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."
7.1.6 Proposed to return to the first draft, namely that if there is a species use listed in the Global Invasive and/or Cabi Database
Species, the certification unit makes plans to control and prevent its spread.
" The bones of contaminated foliar material for the PC case are included in the use of fire? If so, we propose the following writing:Burns for pest control will be prohibited.
In exceptional cases in which the fire has to be used for the control of pests and diseases, the certification unit will provide
evidence of prior approval by government authorities when required.
In the case that the practice of burning as part of the sanitary management protocol this must be clearly supported technically andscientifically as a sanitary measure. So you must mitigate and/or repair damage to the environment. """#Indicator

Comment (English)

81

7.1.7

82

7.1.7

83

7.2

"The bones of contaminated foliar material for the PC case are included in the use of fire? If so, we propose the following writing:Burns for pest control will be prohibited.
In exceptional cases in which the fire has to be used for the control of pests and diseases, the certification unit will provide
evidence of prior approval by government authorities when required.
In the case that the practice of burning as part of the sanitary management protocol this must be clearly supported technically andscientifically as a sanitary measure. So you must mitigate and/or repair damage to the environment. """It is recommended that they are established within the international standard. Does the slopes for steep terrain to what % do theyrefer to? Include a specific inclination percentage.
"Waste must be monitored in quantity and quality
A waste reduction plan with a precise timeline must be put in place, made public and accessible to external stakeholders uponrequest.
A prioritization of waste management must be carried out by the mill, with regard to the risk of pollution by type of waste but also
by possibility of mitigation

84

7.2.1

85
86
87
88
89

7.2.1
7.2.1
7.2.1
7.2.1
7.2.2

90
91

7.2.2
7.2.2

We can also add a 4th R: ReThink the use to avoid the generation of any new waste."7.2.1 related to the prohibition of waste disposal to the water body according to this indicator, what about the disposal of liquid
waste to a water body that has received licensing from the government as applies in Indonesia (Waste Disposal Permit, IPLC)?
Proposed 7.2.1 Word of Destruction of Waste Revised to "Waste Disposal
7.2.1. The waste of waste turns into "waste disposal and removes waste directly into the flow of water"
7.2.1. The waste of waste turns into "waste disposal and removes waste directly into the flow of water"
7.2.1 Destruction of Waste turns into "waste disposal and removes waste directly into the flow of water"
On the other hand, there are agricultural practices to be put in place to prevent pest or disease attacks: these sustainableagricultural practices must be integrated into the guidelines provided by the RSPO to companies.
7.2.2 Minimum content of the waste management plan must be determined by RSPO.
"7.2.2 made in more detail, with additional:- Waste management for operational and non-operational activities- Identify waste"#Indicator

Comment (English)

92

7.2.2

93
94
95

7.2.3
7.2.3
7.2.3

96

7.2.3

97

7.2.3

98

7.2.3

99

7.2.3

100

7.2.3

101

7.2.3

102

7.2.3

103

7.2.3

104

7.2.3

"7.2.2. Made in more detail, with the addition:- Waste management for operational and non-operational activities- Identify waste"
Precautions towards the environment and the health of workers/local populations must be taken into account
7.2.3 Component of the monitoring system must also be predetermined.
"Proposed 7.2.3:
The indicator sentence only mentions ""Identifying and developing opportunities for reducing waste (especially plastic) is carriedout in accordance with the provisions of the National Regulation"""In indicators 7.2.3, the indicator sentence should only mention "Identifying and developing opportunities for reducing waste(especially plastic) is carried out in accordance with the provisions of the National Regulation""Indicator 7.2.3 Proposed:
The indicator sentence only mentions ""Identifying and developing opportunities for reducing waste (especially plastic) is carriedout in accordance with the provisions of the National Regulation""""Proposed changes in indicator sentences to,""Identifying and developing opportunities
Reduction of waste (especially plastic) is run accordingly
National Regulation Provisions """7.2.3 The application of this indicator will be difficult to talk about domestic waste because the type of waste that is very varied
and the certification unit does not have the infrastructure to measure its quantity. This indicator 7.2.3 is also actually able to becovered by indicator 7.2.2
Proposed: The sentence indicator only mentions "Identifying and developing opportunities for reducing waste (especially plastic)is carried out in accordance with the provisions of the National Regulation"
Indicator 7.2.3. It is proposed that at this stage it is sufficient to be limited to "identify and develop opportunities for reducing
waste (especially plastic) is carried out in accordance with the provisions of the National Regulation". Tracking and monitoring
activities are currently focused on CPO products and their derivatives (Certified & Non-Cerated)
Proposed Improvement of Indicators 7.2.3 becomes a "system to identify and develop opportunities for reducing waste (especiallyplastic) is carried out in accordance with the provisions of the National Regulation"
7.2.3 - Sentences Indicators to only mention "Identifying and developing opportunities for reducing waste (especially plastic) are
carried out in accordance with the provisions of the National Regulation"
Proposed Sentences Indicators: "Identifying and developing opportunities for reducing waste (especially plastic) are carried out inaccordance with the provisions of the National Regulation".

#Indicator

Comment (English)

105

7.2.3

106

7.2.3

107

7.2.3

108

7.2.3

109

7.2.3

110

7.2.3

111

7.2.3

112

7.2.3

113

7.2.3

114

7.2.3

115

7.2.3

Proposed Sentences Indicators: "Identifying and developing opportunities for reducing waste (especially plastic) are carried out inaccordance with the provisions of the National Regulation".
The indicator sentence only mentions "Identifying and developing opportunities for reducing waste (especially plastic) is carriedout in accordance with the provisions of the National Regulation""Indicator 7.2.3
Proposal:
The indicator sentence only mentions ""Identifying and developing opportunities for reducing waste (especially plastic) is carriedout in accordance with the provisions of the National Regulation"""Indicator 7.2.3. It is proposed that at this stage it is sufficient to be limited to "identify and develop opportunities for reducing
waste (especially plastic) is carried out in accordance with the provisions of the National Regulation". Tracking and monitoring
activities are currently focused on CPO products and their derivatives (Certified & Non-Cerated)"Proposed changes in sentence indicator 7.2.3:""Identifying and developing opportunities
Reduction of waste (especially plastic) is run accordingly
National Regulation Provisions """"Proposed indicator 7.2.3:- The sentence indicator only mentions ""Identifying and developing opportunities for reducing waste (especially plastic) is carriedout according to the provisions of the National Regulation""."
Proposed Sentences Indicators: "Identifying and developing opportunities for reducing waste (especially plastic) are carried out inaccordance with the provisions of the National Regulation".
Proposed Indicator 7.2.3: Sentences Indicators only mention "Identifying and developing opportunities for reducing waste(especially plastic) are carried out in accordance with the provisions of the National Regulation"
7.2.3: The sentence indicator only mentions "Identifying and developing opportunities for reducing waste (especially plastic) is
carried out in accordance with the provisions of the National Regulation""7.2.3 Proposed:
The indicator sentence only mentions ""Identifying and developing opportunities for reducing waste (especially plastic) is carriedout in accordance with the provisions of the National Regulation"""
7.2.3: Proposed changes in sentence indicators to, "Identifying and developing opportunities for reducing waste (especially plastic)is carried out in accordance with the provisions of the National Regulation"

#Indicator

Comment (English)

116

7.2.4

117

7.2.4

Suggest to do away with the term 'avoid' and aim for stronger indicators to stop planting and start restoration on these areas. This
could be part of a biodiveristy strategy to create 'islands of forest' in the plantation for species connectivity and future resilienceof the landscape.
"""Waste must be monitored in quantity and quality
A waste reduction plan with a precise timeline must be put in place, made public and accessible to external stakeholders uponrequest.
A prioritization of waste management must be carried out by the mill, with regard to the risk of pollution by type of waste but also
by possibility of mitigation

118

7.2.4

119
120

7.2.4
7.2.4

121
122

7.2.5
7.2.5

We can also add a 4th R: ReThink the use to avoid the generation of any new waste.""""Waste must be monitored in quantity and quality
A waste reduction plan with a precise timeline must be put in place, made public and accessible to external stakeholders uponrequest.
A prioritization of waste management must be carried out by the mill, with regard to the risk of pollution by type of waste but also
by possibility of mitigation
We can also add a 4th R: ReThink the use to avoid the generation of any new waste."
7.2.4 How do we determine the optimal use of fertilizer? How is the word "optimal" auditable?
Proposed Indicator Improvement 7.2.4 Becomes: There is a recycling strategy of nutrients, can include empty recycling, PKS liquid
waste (POME), oil palm residues, and optimizing non-organic fertilizer.
7.2.5 Training content and schedule must be made available by RSPO.
"7.2.5In more detail, workers must have attended special training"#Indicator

Comment (English)

123

7.3

"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
Farming practices need to be guided to help the unit of certification in an operational way.

124

7.3

125
126

7.3.1
7.3.1

127

7.3.1

128
129
130

7.3.1
7.3.2
7.3.2

131

7.3.2

132

7.3.2

133

7.3.2

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""Delete this indicator. Do not dilute the criterion.
New plantings and/or development on marginal and/or fragile soil is prohibited."
7.3.1 This indicator should list the types of fragile soils and slope limits
A clear and public monitoring system must be put in place to clearly indicate steep terrain and other risk areas, including GPS
coordinates"A clear and public monitoring system must be put in place to clearly indicate steep terrain and other risk areas, including GPS
coordinates"
which includes for example:
7.3.2. This is arbitrary, what if certain countries legally allow planting in steep terrain?
A clear and public monitoring system must be put in place to clearly indicate steep terrain and other risk areas, including GPS
coordinates"Indicator 7.3.2 Proposed:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
In indicators 7.3.2 The phrase "Planting and/or New Development" is proposed to be changed to "new planting including thedevelopment of supporting infrastructure"
Proposed Indicator 7.3.2: The phrase "Planting and/or New Development" was changed to "New Planting including theDevelopment of Supporting Infrastructure"#Indicator

Comment (English)

134

7.3.2

135

7.3.2

136

7.3.2

137

7.3.2

138

7.3.2

139

7.3.2

140

7.3.2

141

7.3.2

142

7.3.2

143

7.3.2

"Proposed Indicator 7.3.2:- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure"".
""Proposed 7.3.2:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
Proposed Indicator 7.3.2: Sentence "Planting and/or New Development" Corrected into "New Planting Including the Developmentof Supporting Infrastructure""Indicator 7.3.2
Proposal:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""""Proposed Indicator 7.3.2:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""""7.3.2 - The sentence ""planting and/or new development"" was changed to ""new planting including the development of
supporting infrastructure"""
The phrase "Planting and/or New Development" was changed to "new planting including the development of supporting
infrastructure"
The phrase "Planting and/or New Development" was changed to "new planting including the development of supporting
infrastructure""The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
Proposed Indicator 7.3.2: Sentence "Planting and/or New Development" Corrected into "New Planting Including the Developmentof Supporting Infrastructure"#Indicator

Comment (English)

144

7.3.2

145

7.3.2

146
147
148

7.3.2
7.3.2
7.3.3

149

7.3.3

150

7.3.3

151

7.3.3

152

7.3.3

153

7.3.3

154

7.3.3

155

7.3.3

Indicator 7.3.2 (c) Proposed to: The phrase "planting and/or new development" was changed to "new planting including thedevelopment of supporting infrastructure".
Indicator 7.3.2 Proposal: The phrase "Planting and/or New Development" was changed to "New Planting including theDevelopment of Supporting Infrastructure"
Specify the definition of steep.
Specify until the steep boundary, so that the palm grower is clear, as well as the auditor
we're concerned that the wording of these indicators 7.3.3 and 7.3.4 has been weakened, and that this combined with the new
definition of marginal and fragile soils and specified allowed hectarage for clearance that the P+C may allow more leniency forplanting on fragile and marginal soils. Suggest keeping previous wording of 'no' planting rather than 'avoid'. Also this keepreference to 'planting' rather than only 'replanting'. Not clear under which circumstances it is acceptable that limited replanting 'isoccurring' - this indicator seems both to say that it should not happen, and accept that it does happen anyway, which makes theintention unclear. Would be clearer and more auditable to have strong position that this clearing is not allowed.
7.3.3 What is the definition of limited planting? This indicator should be very specific so that it deters plantings on wetlands, acidsulfate soils, karst basement areas, sandstone basements, podzolised siliceous sand (spodosols), and ultramafic soils are someexamples. Over applications of inorganic fertilizers should be deterred.
"Indicator 7.3.3 Proposed:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
Proposed Indicator 7.3.3: Sentence "Planting and/or New Development" was changed to "New Planting including theDevelopment of Supporting Infrastructure"
7.3.3 It is necessary to determine the limitations of the area that is more standard and has the right reference basis to be called alimited new planting.
In indicator 7.3.3 for the phrase "planting and/or new development" was changed to "new planting including the development of
supporting infrastructure""Proposed indicator 7.3.3:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
Proposed Indicator 7.3.3: Sentence "Planting and/or New Development" Corrected into "New Planting Including the Developmentof Supporting Infrastructure"#Indicator

Comment (English)

156

7.3.3

157

7.3.3

158

7.3.3

159

7.3.3

160

7.3.3

161

7.3.3

162

7.3.3

163

7.3.3

164

7.3.3

165

7.3.4

"Proposed indicator 7.3.3:- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure"".
""Proposed 7.3.3:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
Indicator 7.3.3 Proposed to: The phrase "Planting and/or New Development" was changed to "New Planting including theDevelopment of Supporting Infrastructure""Indicator 7.3.3
Proposal:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""""The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""
Indicator 7.3.3 Proposed to: The phrase "Planting and/or New Development" was changed to "New Planting including theDevelopment of Supporting Infrastructure""7.3.3 - The sentence ""planting and/or new development"" was changed to ""new planting including the development of
supporting infrastructure"""
The phrase "Planting and/or New Development" was changed to "new planting including the development of supporting
infrastructure"
Indicator 7.3.3 Proposed to: The phrase "Planting and/or New Development" was changed to "New Planting including theDevelopment of Supporting Infrastructure"
7.3.4 Are definitions in this document, such as limited replanting, considered normative?

#

Indicator

Comment (English)

166

7.3.4

167

7.3.4

Organic matter when possible must be compostable to generate material that can be used on plantations (EFB) Methane fromPOME must be captured to prevent release into the atmosphere - and potentially create energy from it The RSPO should provide
clear guidelines of the technical possibilities for the mills with an idea of timeline and budget so that the unit of certification canbe better supported on these sites - and know which actions are prioritized"Organic matter when possible must be compostable to generate material that can be used on plantations (EFB)
Methane from POME must be captured to prevent release into the atmosphere - and potentially create energy from it

168

7.3.4

169

7.3.4

170

7.3.4

171

7.3.4

172

7.3.4

173
174

7.3.5
7.3.5

The RSPO should provide clear guidelines of the technical possibilities for the mills with an idea of timeline and budget so that theunit of certification can be better supported on these sites - and know which actions are prioritized""Organic matter when possible must be compostable to generate material that can be used on plantations (EFB)
Methane from POME must be captured to prevent release into the atmosphere - and potentially create energy from it.
The RSPO should provide clear guidelines of the technical possibilities for the mills with an idea of timeline and budget so that theunit of certification can be better supported on these sites - and know which actions are prioritized""Indicators are replaced with indicators at RSPO P&C2018 namely ""7.5.2 Recipping Palm Oil
carried out extensively on steep sloped land
according to applicable regulations """7.3.4 It is necessary to determine the limitations of the area that is more standard and has the right reference basis to be called alimited replanting.
7.3.4: The indicator is replaced with indicators at the 2018 RSPO P&C namely "7.5.2 Re -planting oil palm is not carried out
extensively on steep sloped land according to applicable regulations""Proposed changes in indicators 7.3.4: Palm oil replanting is not carried out extensively on steep sloped land according toapplicable regulations ""Proposed indicators are returned and equated with indicators at RSPO P&C 2018 which is 7.5.2"
A clear and public monitoring system must be put in place to clearly indicate peat terrain, including GPS coordinates
7.3.5 How is this going to be demonstrated in terms of auditability?

#

Indicator

Comment (English)

175

7.4

"""A system of verification audits and sanctions must be put in place as a priority to avoid any breach of this criterion.

7.4

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""""A system of verification audits and sanctions must be put in place as a priority to avoid any breach of this criterion.

176

177

7.4.1

178

7.4.1

179
180

7.4.1
7.4.1

181

7.4.1

182

7.4.1

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."
Make a stronger case to stop replanting after harvest cycle is over. Replanting in peatland is undesireble for climate, environment
and also plantation productivity. These could be good areas for rewetting and restoration. We would like to suggest to RSPO tostart working on restoration on those places where it has less impact on yield, in the long term, like the steep terrain andpeatland.
"Indicator 7.4.1 Proposed:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""In order to clarify the definition of new planting, new development and supporting supporting infrastructure.
In indicators 7.4.1 The sentence "planting and/or new development" was changed to "new planting including the development of
supporting infrastructure"
Indicator 7.4.1 (c) is proposed to: The phrase "planting and/or new development" is changed to "new planting including thedevelopment of supporting infrastructure".
"Proposed 7.4.1 (c):The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""#

Indicator

Comment (English)

183

7.4.1

184

7.4.1

185

7.4.1

186

7.4.1

187

7.4.1

188

7.4.1

189

7.4.1

190

7.4.1

191

7.4.1

192
193

7.4.1
7.4.2

194

7.4.2

"Indicator 7.4.1 (c) is proposed for:The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""."Indicator 7.4.1 (c) is proposed to: The phrase "planting and/or new development" is changed to "new planting including thedevelopment of supporting infrastructure".
"Proposed Indicator 7.4.1:- The phrase ""Planting and/or New Development"" was changed to ""New Planting including the Development of Supporting
Infrastructure""."Indicator 7.4.1 (c) is proposed to: The phrase "planting and/or new development" is changed to "new planting including thedevelopment of supporting infrastructure".
"Indicator 7.4.1
Proposal:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure""""Proposed 7.4.1. In order to clarify the definition of new planting,new development and and infrastructure development
supporters.""Proposed Indicator 7.4.1:
The phrase ""Planting and/or New Development"" was changed to ""new planting including the development of supporting
infrastructure"""The phrase "Planting and/or New Development" was changed to "new planting including the development of supporting
infrastructure"
Indicator 7.4.1 (c) is proposed to: The phrase "planting and/or new development" is changed to "new planting including thedevelopment of supporting infrastructure".
7.4.1. In order to clarify the definition of new planting, new development and supporting supporting infrastructure.
"Why was “shall” added?
The older version is stronger: “There is no new planting (...)”""A clear and public monitoring system must be put in place to clearly indicate peat terrain, including GPS coordinates"#

Indicator

Comment (English)

195

7.4.2

"""The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, dependingon the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
Farming practices need to be guided to help the unit of certification in an operational way.

196
197

7.4.2
7.4.2

198
199

7.4.2
7.4.3

200

7.4.3

201

7.4.3

202
203

7.4.3
7.4.3

204
205

7.4.3
7.4.3

New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."""The deadline for re-submitting peat inventory to RSPO Secretariat on November 5, 2023.
7.4.2 The results of the mapping and inventory of peat have and will continue to be reported to the RSPO regularly, so thecertification unit does not need to report it through the Certification Agency.
The deadline for re-submitting peat inventory to RSPO Secretariat on November 5, 2023.
In indicators 7.4.3 there should be an exception to accommodate interests other than companies (for example government) in theconstruction of waterways, roads, dams, dikes, embankments, and/or electric lines.
Indicator 7.4.3 (c) is proposed to: The construction of waterways, roads, dams, dikes, embankments, and/or electric paths otherthan company interests (government interests) are allowed.
Proposed Indicator 7.4.3: Construction of waterways, roads, dams, dikes, embankments, and/or electric lines other than company
interests (government interests) are allowed
Exceptions at 7.4.5.
"7.4.3 Proposed to add sentences to this indicator, as follows:
Every infrastructure development in the work area of the certification unit that is not related to the operational activities of thecertification unit (for example: government projects, public facilities, etc.) is not seen as a violation of this indicator ---->
adaptation from RSPO P&C 2020 Interpretation Indonesia.
"
Development is not for the benefit of corporations (non-corporate land clearance) can be re-entered"Proposal:
for development not for the interests of corporations (non-corporate land clearance) can be re-entered"#

Indicator

Comment (English)

206

7.4.3

207

7.4.3

208

7.4.3

209

7.4.3

210

7.4.3

211

7.4.3

212
213

7.4.3
7.4.3

214
215

7.4.3
7.4.3

216
217

7.4.3
7.4.3

218

7.4.3

219
220

7.4.4
7.4.4

"Proposed Indicator 7.4.3:- Development of waterways, roads, dams, embankments, embankments, and/or electric lines in addition to the interests ofcompanies (government interests) are allowed."
Indicator 7.4.3 (c) is proposed to: The construction of waterways, roads, dams, dikes, embankments, and/or electric paths otherthan company interests (government interests) are allowed.
Indicator 7.4.3 Proposed: construction of waterways, roads, dams, dikes, embankments, and/or electric lines other than company
interests (government interests) are allowed
7.4.3 - The construction of waterways, roads, dams, embankments, embankments, and/or electric paths other than company
interests (government interests) are allowed
Indicator 7.4.3 (c) is proposed to: The construction of waterways, roads, dams, dikes, embankments, and/or electric paths otherthan company interests (government interests) are allowed.
Proposed Indicator 7.4.3: Construction of waterways, roads, dams, dikes, embankments, and/or electric lines other than company
interests (government interests) are allowed
Proposed for indicators 7.4.3: Exceptions in the conditions mentioned in the indicator 7.4.5.
"Indicator 7.4.3
Proposal:
Construction of waterways, roads, dams, dikes, embankments, and/or electric lines in addition to the interests of the company(government interests) are allowed"
for development not for the interests of corporations (non-corporate land clearance) can be re-entered"Proposed Indicator 7.4.3:
Construction of waterways, roads, dams, dikes, embankments, and/or electric lines in addition to the interests of the company(government interests) are allowed"
7.4.3: Exception at 7.4.5.
"Proposed 7.4.3:
Construction of waterways, roads, dams, dikes, embankments, and/or electric lines in addition to the interests of the company(government interests) are allowed""Indicator 7.4.3 (c) Proposed:
Construction of waterways, roads, dams, dikes, embankments, and/or electric lines in addition to the interests of the company(government interests) are allowed"
7.4.4. Undeveloped is a better alternative to 'unplanted'.
A clear and public monitoring system must be put in place to clearly indicate peat terrain, including GPS coordinates#

Indicator

Comment (English)

221
222

7.4.6
7.4.6

223

7.4.6

7.4.6. This entire indicator is confusing. The timeline for drainability assessment is confusing please reword this.
"The RSPO must carry out studies and convene panels of experts every year to define clear and relevant guidelines, depending on
the type of plantation and geographical area, on the best agricultural practices for workers' health and the environment.
Farming practices need to be guided to help the unit of certification in an operational way.
New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers.""7.4.6 • Drainability assessment can actually conflict with conditions in the field, where the certification unit still has a legal permit
to land use (HGU) in a long period of time but becomes unable to reinstate in peat because based on the results of drainability
assessment it is not possible for Re -planting.
• Please consideration to impose drainability assessment procedures version 2, where this procedure is very scientific, requires
time allocation, human resources and costs to conduct field surveys related to the height and thickness of peatland to get primarydata• Cultivation on peatlands that do not damage the environment can be done by applying the best cultivation practices on
peatlands according to the RSPO guide. Even if there is a desire from the certification unit to carry out drainage assessment
activities, the results should be intended for recommendations for BMP improvement in the replanting area, not to stop planting

224

225

7.4.7

7.4.7

With the above consideration, it is proposed to delete the drainability assessment requirements from the indicator.
""A system of verification audits and sanctions must be put in place as a priority to avoid any breach of this criterion.
New agricultural systems less oriented towards monoculture and more towards the diversification of plant species must be
favored.
The RSPO must help the plantations to turn to its new agricultural practices more in line with global warming, the preservation of
the environment and with the mitigation of the risk of pest / disease - while maintaining high yields and therefore ensuringincome to producers."
7.4.7. This is wishful thinking, most companies would just abandon the site. The effectiveness of this indicator needs to bereviewed.

#

Indicator

Comment (English)

226
227
228

7.4.8
7.4.9
7.4.9

229

7.4.9

230
231

7.4.9
7.5

232
233

7.5
7.5

7.4.8 This is another vague indicator with audit difficulties. What should we focus on?
7.4.9. What is the accepted peat subsidence? It should be stated clearly rather than making a reference to the BMP.
The wording of the older version has been stronger and more clear “No new planting on peat, regardless of depth after 15
November 2018 and all peatlands are managed responsibly.”
The first phrase in 7.4 can be made stronger as follows: The UoC shall not conduct land clearing or new planting on peat
regardless of depths, after November 2018.
7.4.9. What is meant by ground cover management?
"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy"
We should be indeed doing our best to prevent ground water contamination or pollution"""The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.

234

7.5

235
236
237
238
239

7.5.1
7.5.1
7.5.1
7.5.1
7.5.1

The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy""""Suggest to revise the wording of the indicator on management of waste water. For e.g. The water management plan should
avoid contamination of surface and ground water through…including the treatment of wastewater such as POME, sewage andother wastewater, in accordance with national legislation.
[Issue: there is a lack of management of wastewater in the fields, such as POME, sewage and other wastewater that may impact
on surface and groundwater quality]."
7.5.1 Guidance on the structure of the water management plan should be provided.
wrong linkshould refer to 7.5.2. There is no indicator 7.6.2
Past activities after November 2018 or any other timeline?
Riparian#

Indicator

Comment (English)

240

7.5.1

241

7.5.1

242

7.5.1

243

7.5.1

244

7.5.2

245

7.5.2

246

7.5.2

247

7.5.2

248

7.5.2

249

7.5.2

"Protect natural water flow, river border, andOther buffer zones* (see 7.6.2); Should refer
at 7.5.2. Because there is no indicator 7.6.2."
7.5.1 This indicator is too detailed. It is recommended to make the indicator to be more simple, where other detailed things areincluded in the guide only
7.5.1: Protects natural water flow, river borders, and other buffer zones* (see 7.6.2); Should refer at 7.5.2. Because there is no
indicator 7.6.2.
"Proposed 7.5.1: Protecting natural water flow, river borders, and other supporting zones* (see 7.6.2); Should refer
at 7.5.2. Because there is no indicator 7.6.2."
Indicator 7.5.2 (c) Proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes"if there are no national regulations/guidelines, then the RSPO guide on the best management practices for management andrehabilitation of Riparian Nature Reserve and river border management in Indonesian oil palm plantations "In indicators 7.5.2 it is proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence
becomes "if there are no national regulations/guidelines, then the RSPO guide on the best management practices for the
management and rehabilitation of Riparian Nature Reserve and river border management in coconut plantations Indonesian palm"
The latest guide can adopt the issued of the RSPO Secretariat July 2022 concerning the Management of River Borders in Palm Oil
Plantation in Indonesia
Proposed Indicator 7.5.2: In order to adopt the latest guidelines that had previously been issued by the RSPO Secretariat in July
2022, so that the sentence became "if there are no national regulations/guidelines, then the RSPO guide about the best
management practices for management and rehabilitation of Riparian Nature Reserve and river border management inIndonesian oil palm plantations "In order to add a reference to the latest guidelines issued by the RSPO Secretariat July 2022 concerning the Management of River
Borders in Palm Oil Plantation in Indonesia.
"Proposed Indicator 7.5.2:
It is proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes ""if there areno national regulations/guidelines, then the RSPO guide on the best management practices for the management andrehabilitation of Riparian Nature Reserve and river border management in Indonesian oil palm plantations"""#Indicator

Comment (English)

250

7.5.2

251

7.5.2

252

7.5.2

253

7.5.2

254

7.5.2

255

7.5.2

256

7.5.2

257

7.5.2

258

7.5.2

"Indicator proposal 7.5.2 is proposed to adopt the latest guidelines for managing riparian that are not determined by government
in palm oil plantation in Indonesia issued For the management and rehabilitation of the Riparian Nature Reserve and river bordermanagement in the Indonesian Palm Oil Plantation Managing Riparian that are not determined by government in palm oil
plantation in Indonesia 2022.
"
Indicator 7.5.2 (c) Proposed to: Adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes"if there are no national regulations/guidelines, then the RSPO guide about the best management practices for management andrehabilitation of Riparian Nature Reserve and river border management in Indonesian oil palm plantations ".
Ndicator 7.5.2 (c) Proposed to: Adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes"if there are no national regulations/guidelines, then the RSPO guide about the best management practices for the management
and rehabilitation of the Riparian Nature Reserve and river border management in Indonesian oil palm plantations ".
"Proposed Indicator 7.5.2:- It is proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes ""if there areno national regulations/guidelines, then the RSPO guide on the best management practices for the management andrehabilitation of the Riparian Nature Reserve and river border management in Indonesian oil palm plantations""."Indicator 7.5.2 (c) Proposed to: Adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes"if there are no national regulations/guidelines, then the RSPO guide about the best management practices for management andrehabilitation of Riparian Nature Reserve and river border management in Indonesian oil palm plantations ".
7.5.2 - Proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes "if there
are no national regulations/guidelines, then the RSPO guide on the best management practices for the management andrehabilitation of the Riparian Nature Reserve and river border management in the coconut plantation Indonesian palm ""Proposed Indicator 7.5.2:
To be able to adopt the latest guidelines issued by the Secretariat of the RSPO July 2022 regarding the management of riverborders in oil palm plantations in Indonesia"
7.5.2: In order to add a reference for the latest guidelines issued by the RSPO Secretariat July 2022 concerning the Management ofRiver Borders in Palm Oil Plantation in Indonesia.
"Indicator 7.5.2
Proposal:
It is proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes ""if there areno national regulations/guidelines, then the RSPO guide on the best management practices for the management andrehabilitation of Riparian Nature Reserve and river border management in Indonesian oil palm plantations"""#Indicator

Comment (English)

259

7.5.2

260

7.5.2

261

7.5.2

262

7.5.3

263
264
265

7.5.3
7.5.3
7.5.3

266
267
268

7.5.3
7.5.3
7.5.3

269
270

7.5.3
7.5.3

"Proposed for 7.5.2 (c):It is proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence becomes ""if there areno national regulations/guidelines, then the RSPO guide on the best management practices for the management andrehabilitation of Riparian Nature Reserve and river border management in Indonesian oil palm plantations"""
Indicator 7.5.2 Proposed: Proposed to adopt the latest guidelines issued by the RSPO Secretariat July 2022, so that the sentence
becomes "if there are no national regulations/guidelines, then the RSPO guide on the best management practices for the
management and rehabilitation of the Riparian Nature Reserve and river border management in the plantation Indonesian palmoil ""Proposal:
To be able to adopt the latest guidelines issued by the Secretariat of the RSPO July 2022 regarding the management of riverborders in oil palm plantations in Indonesia""Suggest to broaden the scope in ensuring no negative impacts on users AND natural environment; particularly in the context of
future higher demand for irrigation which may impact HCVs negatively; e.g., Increase of water pumping for irrigation purposes
could result in biodiversity loss, unfair distribution of water across ecosystems, etc.).
Note: When irrigation is used, the relevant legislation is being complied with.
[It is currently stated that a water management plan shall be developed and implemented to avoid negative impacts on otherusers in the catchment. The water management plan aims to ensure efficiency of use, continued availability of water sources ,only on human use of water but not on the natural environment. As climate warms up, there will be more interest in using
irrigation in existing oil palm plantations (used extensively in India, in parts of Thailand) and that is not touched at all in thiscriterion]"
7.5.3 What is the definition of restoration here? What do you mean by "semi-natural state"? Can oil palm be maintained?
Proposed Indicator 7.5.3: Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 Refer)"Proposed indicator 7.5.3:
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 referral)"Indicator 7.5.3: This indicator is no longer necessary, because it has been covered in indicator 7.5.2 (management program)Indicator 7.5.3: This indicator is no longer necessary, because it has been covered in indicator 7.5.2 (management program)"Indicator proposal 7.5.3 is removed due to the mechanism
Restoration/Remediation has been regulated in RACP (Annex Refer 5
P&C 2018) with Cut Off Date 2005."
Proposed: Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 Refer)
For indicators 7.5.3 Disagree and proposed to be deleted because it has been arranged in RACP (Annex 5 P&C 2018 Refer)#Indicator

Comment (English)

271

7.5.3

272

7.5.3

273

7.5.3

274

7.5.3

275

7.5.3

276
277

7.5.3
7.5.3

278
279
280
281

7.5.3
7.5.3
7.5.3
7.5.3

282

7.5.3

283

7.5.4

284

7.5.4

285

7.5.4

"Proposed indicator 7.5.3: - Proposed indicator is deleted, because it has been arranged in RACP (Annex 5 RSPO P&C 2018 Refer).
Annex 5 RSPO P&C 2018 proposal is still adopted in P&C 2023""Proposed indicator 7.5.3:- Disagree with the new indicator because it has been arranged in RACP (Annex 5 RSPO P&C 2018 refer.""Indicator 7.5.3 Proposed:
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 referral)""Indicator 7.5.3 is proposed to:
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 refer.""Indicator 7.5.3
Proposal:
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 referral)"
7.5.3 - Disagree with the new indicator because it has been regulated in RACP (Annex 5 P&C 2018 Refer)"Proposed 7.5.3:
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 referral)"Indicator 7.5.3 Proposal: Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 Refer)
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 referral)
Proposed indicator 7.5.3: Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 refer).
"Proposal:
Disagree with the new indicator because it has been arranged in RACP (Annex 5 P&C 2018 referral)"
7.5.3: The indicator is removed because the mechanism of restoration/remediation has been regulated in the RACP (Annex 5 P&C2018 refer) with a 2005 cut off date.
The indicator is replaced with the 2018 P&C indicator, namely, "7.8.3 PKS liquid waste is managed according to applicableregulations. The quality of the PKS liquid waste that is discarded, especially BOD (Biochemical Oxygen Demand) is monitored
regularly according to applicable regulations "The indicator proposal 7.5.3 is removed because the mechanism of restoration/remediation has been regulated in the RACP
(Annex 5 P&C 2018 Refer) with Cut Off Date 2005.
"7.5.4: Indikator diganti dengan Indikator P&C 2028 yaitu,“7.8.3 Limbah cair PKS dikelola sesuai peraturan yangberlaku. Kualitas limbah cair PKS yang dibuang, khususnya
BOD (Biochemical Oxygen Demand) dipantau secara berkala
sesuai peraturan yang berlaku”"

#Indicator

Comment (English)

286

7.5.4

287

7.5.5

"7.5.4: The indicator is replaced with the P&C 2028 indicator, namely,""7.8.3 PKS liquid waste is managed according to applicable regulations. The quality of the PKS liquid waste that is discarded,
especially BOD (Biochemical Oxygen Demand) is monitored regularly according to applicable regulations """"The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.

288

7.5.5

289

7.5.5

290

7.5.5

291

7.5.5

292
293

7.5.5
7.5.5

294

7.5.5

295

7.5.5

296
297

7.5.5
7.5.5

298

7.5.5

The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy"
In indicators 7.5.5 the editor of the sentence should continue to use P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS ismonitored and recorded""Indicator 7.5.5 Proposed:
The sentence still uses P&C 2018 Indicator 7.8.4 ""PKS water use per ton TBS is monitored and recorded""""Proposed 7.5.5:
The sentence still uses P&C 2018 Indicator 7.8.4 ""PKS water use per ton TBS is monitored and recorded""""Indicators are replaced with the 2018 P&C indicator, namely,""7.8.4 The use of PKS water per ton of FFB is monitored and recorded"""The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored and recorded"
Indicator 7.5.5 is proposed to: The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored andrecorded".
Indicator 7.5.5 is proposed to: The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored andrecorded". (INA NI 2020)"7.5.5: The indicator is replaced with the P&C 2028 indicator, namely,""7.8.4 The use of PKS water per ton of FFB is monitored and recorded"""The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored and recorded""Proposed indicator 7.5.5:- The sentence still uses P&C 2018 Indicator 7.8.4 ""PKS water use per ton TBS is monitored and recorded"".
"7.5.5 - The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored and recorded"#Indicator

Comment (English)

299

7.5.5

300

7.5.5

301

7.5.5

302

7.5.5

303

7.5.5

304

7.5.5

305
306

7.5.5
7.6

"Indicator 7.5.5
Proposal:
The sentence still uses P&C 2018 Indicator 7.8.4 ""PKS water use per ton TBS is monitored and recorded"""
Indicator 7.5.5 is proposed so that the sentence still uses P&C 2018 Indicator 7.8.4, namely "PKS water use per ton TBS ismonitored and recorded"
Indicator 7.5.5 is proposed to: The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored andrecorded".
Proposed Indicator 7.5.4: In order to keep using the sentence P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored
and recorded""Proposed indicator 7.5.5:
The sentence still uses P&C 2018 Indicator 7.8.4 ""PKS water use per ton TBS is monitored and recorded""""7.5.5: The indicator is replaced with the 2018 P&C indicator, namely,""7.8.4 The use of PKS water per ton of FFB is monitored and recorded"""7.5.5: The sentence still uses P&C 2018 Indicator 7.8.4 "PKS water use per ton TBS is monitored and recorded""The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

307

7.6

The reduction plan must be made public with objective figures that can be verified by third parties""These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.
The reduction plan must be made public with objective figures that can be verified by third parties"#

Indicator

Comment (English)

308

7.6

"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

309

7.6

The reduction plan must be made public with objective figures that can be verified by third parties""The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

310
311

7.6
7.6

The reduction plan must be made public with objective figures that can be verified by third parties"
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.
"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.
The reduction plan must be made public with objective figures that can be verified by third parties"#

Indicator

Comment (English)

312

7.6

"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

313

7.6

The reduction plan must be made public with objective figures that can be verified by third parties""The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy

314

7.6

GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes.""The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes."#Indicator

Comment (English)

315

7.6.1

"The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy

316

7.6.1

317

7.6.1

GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes.""Suggest to review GhG calculator and align with SBTi and GhG protocol, so that carbon claims can be generated. This also
requires revision of the RSPO claims procedure.
[The GHG calculator includes data of the entire company operations as well as the plantations that supply them including 3rdparty FFB suppliers. The problem is that data from these 3rd party FFB suppliers are often either insufficient or poor then thecompany will therefore use defaults values or default estimates. The company can only get accurate data from their own
estates].""The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

318

7.6.1

The reduction plan must be made public with objective figures that can be verified by third parties""The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes."#Indicator

Comment (English)

319

7.6.1

320

7.6.1

We suggest to not suggest continuing to ingrain fossil fuels into the industry. Instead, a plan to "phase out fossil fuels" should be
made.
"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy

321

7.6.1

"
"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.

322

7.6.1

323
324

7.6.1
7.6.1

325

7.6.1

326

7.6.1

327

7.6.1

328
329

7.6.1
7.6.1

The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy"
For indicators 7.6.1 the editorial of the sentence should continue to use P&C 2018 Indicator 7.9.1 "Plan to increase the efficiency
of fossil fuel use and to optimize renewable energy available, monitored and documented"
Using the P&C 2018 indicator 7.9.1
Indicator 7.6.1 is proposed to: The sentence still uses P&C 2018 Indicator 7.9.1 "Plan to increase the efficiency of fossil fuel use
and to optimize renewable energy available, monitored and documented".
"Proposed indicator 7.6.1: Sentence improvement into ""Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented"". (INA NI 2018)"
Proposed Indicator 7.6.1: In order to continue using P&C 2018 sentence Indicator 7.9.1 "Plan to improve the efficiency of fossil
fuel use and to optimize renewable energy available, monitored and documented" ""Proposed Indicator 7.6.1:- The sentence still uses P&C 2018 Indicator 7.9.1 ""Plan to improve the efficiency of fossil fuel use and to optimize renewableenergy available, monitored and documented""."7.6.1: The word "and reported" is deleted because it has been reported in the RSPO audit report every year.
Indicator 7.6.1: The word "and reported" is deleted because it has been reported in the RSPO audit report every year.

#Indicator

Comment (English)

330

7.6.1

331

7.6.1

332

7.6.1

333

7.6.1

334

7.6.1

335

7.6.1

336

7.6.1

337

7.6.1

338

7.6.1

339

7.6.1

"Indicator 7.6.1
Proposal:
The sentence still uses P&C 2018 Indicator 7.9.1 ""Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented""""Proposed 7.6.1:
The sentence still uses P&C 2018 Indicator 7.9.1 ""Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented"""7.6.1 - The sentence still uses P&C 2018 Indicator 7.9.1 "Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented" "7.6.1: The sentence still uses P&C 2018 Indicator 7.9.1 "Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented""The word ""and reported"" was deleted because it had
reported in the RSPO audit report every year.""7.6.1 Proposed:
The sentence still uses P&C 2018 Indicator 7.9.1 ""Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented"""Indicator 7.6.1 is proposed to: The sentence still uses P&C 2018 Indicator 7.9.1 "Plan to increase the efficiency of fossil fuel use
and to optimize renewable energy available, monitored and documented".
"Indicator 7.6.1: The word ""and reported"" is deleted because it has beenreported in the RSPO audit report every year.
"
7.6.1: The sentence still uses P&C 2018 Indicator 7.9.1 "Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented""Indicator 7.6.1 Proposed:
The sentence still uses P&C 2018 Indicator 7.9.1 ""Plan to increase the efficiency of the use of fossil fuels and to optimize
renewable energy available, monitored and documented"""#

Indicator

Comment (English)

340

7.7

"The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

341

7.7

342

7.7

The reduction plan must be made public with objective figures that can be verified by third parties""Suggest to replace ‘minimise and reduce GHG emissions’ by accounting approach: ‘estimate GHG emissions, set a target, plan
actions and monitor toward a low GHG emissions target’ OR if RSPO does not want to use the accounting approach , we would
suggest ‘identify the activities and resources used that are the main sources of GHG emissions and implement a plan to reduce
emissions from these sources’.
[>Distinguish between emissions from processing and emissions from growing plantations i.e. land use change>Clarify what does it mean MINIMIZE, as that could be interpreted in many different ways by an auditor and by a producer].""The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

343

7.7

The reduction plan must be made public with objective figures that can be verified by third parties""""These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.
The reduction plan must be made public with objective figures that can be verified by third parties"""#Indicator

Comment (English)

344

7.7

"""These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

345

7.7.1

346

7.7.1

The reduction plan must be made public with objective figures that can be verified by third parties""""The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy
GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes.""The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy

347

7.7.1

348

7.7.1

349

7.7.1

350

7.7.1

GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes.""The mill must be encouraged to create retention basins for its POME.
All POME must be treated with return to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy"
RSPO could require the monitoring and recording of water use for the activities that require the biggest volume of water – not justwater use in palm oil processing. On-farm irrigation can be a large consumer of water and can have a detrimental effect on thesurrounding environment. By monitoring, farmers develop a better understanding of their water use and can adjust practices tobe more efficient and sustainable.
The mill must be encouraged to create retention basins for its POME. All POME must be treated with return to nature. The RSPO
must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of this POME and thegeneration of carbon-free energy[Sandakan, 21 June 2023] The use of fuel on genset in Sandakan estates are significant due to no electricity supply provided. Plans
to minimise GHG emission would be difficult to these groups.

#Indicator

Comment (English)

351

7.7.1

"the current Language less strong than before,“7.8 Practices maintain the quality and availability of surface and groundwater.”

352

7.7.1

353

7.7.1

354

7.7.1

355

7.7.1

Demonstrate efforts vs. maintain quality ??
""In this 7.7.1 indicator there are several proposals, namely:- The sentence ""with the target of reducing the group"" was abolished- Editors of sentences as well as to protect the indicator version 7.10.1 P&C 2018, ""GHG emissions for the certification unit are
identified and assessed. Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator,
and reported publicly."""7.7.1 - Sentence "with the target of reducing the group" was abolished, and then to continue to use the indicator sentence 7.10.1
P&C 2018, "GHG emissions for the certification unit are identified and assessed. Plans to reduce or minimize GHG emissions arecarried out, monitored through the PalmGHG Calculator , and reported publicly. ""7.7.1 What is meant by the GHG reduction target in the group? This should be removed because the entity that is thecertification unit is not a company group.
GRK reduction in groups can be obtained by RSPO through reporting GHK for each member in each audit period.""The indicator is replaced with an indicator of 7.10.1 (P&C 2018) because P&C 2018 is quite clear and both include therequirements requested.
P&C 2018, 7.10.1 (c) GHG Emissions are identified and assessed for the unit of certification. PLANS to Reduce or Minimise Them
are implemented, monitored through the Palm GHG Calculator and Publicly Reported.

356

7.7.1

357

7.7.1

Reporting and reducing GHG emission targets should not be applied exclusively using the Palm GHG Calculator RSPO. There areinternational methods that are recognized as GHG Protocol.""Proposed Indicator 7.7.1: 1. sentence ""with a group reduction target"" abolished
2. Continue to use the sentence indicator 7.10.1 P&C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly.""""Proposed 7.7.1:- The sentence ""with the target of reducing the group"" was abolished- Propose indicator sentences to ""GHG emissions for certification units identified and assessed. Plans to reduce or minimize GHG
emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly."""#

Indicator

Comment (English)

358

7.7.1

359

7.7.1

360

7.7.1

361

7.7.1

362

7.7.1

363

7.7.1

364

7.7.1

365

7.7.1

"Proposed Indicator 7.7.1:- The sentence ""with the target of reducing the group"" was abolished- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly.""""Proposed Indicator 7.7.1:- The sentence ""with the target of reducing the group"" was abolished.
- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly""."Proposed 7.7.1: - Sentence "with a group reduction target" abolished - Propose indicator sentences to "GHG emissions forcertification units identified and assessed. Plans to reduce or minimize GHG emissions are carried out, monitored through the
PalmGHG Calculator, and reported publicly.""Indicator 7.7.1 (c) is proposed for:1. The sentence ""with a group reduction target"" was abolished. 2. Continue to use the sentence indicator 7.10.1 P&C 2018,""GHG emissions for the certification unit are identified and assessed. Plans to reduce or minimize GHG emissions are carried out,
monitored through the PalmGHG Calculator, and reported publicly.""""Indicator 7.7.1
Proposal:- The sentence ""with the target of reducing the group"" was abolished- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly."""Indicator 7.7.1 Proposal: - Sentence "with a group reduction target" abolished - Keep using the sentence Indicator 7.10.1 P&C
2018, "GHG emissions for the certification unit are identified and assessed. Plans to reduce or minimize GHG emissions are carriedout, monitored through the PalmGHG Calculator, and reported publicly. "7.7.1 - Sentence "with the target of reducing the group" was abolished, and then to continue to use the indicator sentence 7.10.1
P&C 2018, "GHG emissions for the certification unit are identified and assessed. Plans to reduce or minimize GHG emissions arecarried out, monitored through the PalmGHG Calculator , and reported publicly. ""Proposed 7.7.1 (c):- The sentence ""with the target of reducing the group"" was abolished- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly."""#

Indicator

Comment (English)

366

7.7.1

367

7.7.1

"7.7.1: The indicator is replaced with indicators 7.10.1 (P&C 2018) because P&C 2018 is quite clear and both have included therequested requirements.
P&C 2018, 7.10.1 (c) GHG Emissions are identified and assessed for the unit of certification. PLANS to Reduce or Minimise Them
are implemented, monitored through the Palm GHG Calculator and Publicly Reported.
Reporting and reducing GHG emission targets so that it is not exclusively applied using the Palm GHG Calculator RSPO. There areinternational methods that are recognized as GHG Protocol.""7.7.1: The indicator is replaced with an indicator 7.10.1 (P&C 2018)
Because P&C 2018 is quite clear and both haveincludes the requested requirements.

368

7.7.1

369

7.7.1

370

7.7.1

371

7.7.1

P&C 2018, 7.10.1 (C) GHG Emissions are identified andAssessed for the unit of certification. Plans to Reduce or
minimise them are implemented, monitored through thePalm GHG Calculator and Publicly Reported.
Reporting and Reduction of GHK Emission Targets as Serinya
Not enforced exclusively using the Palm GHG Calculator RSPO. There are international methods that are recognized as GHG
Protocol.""Indicator 7.7.1 (c) Proposed:- The sentence ""with the target of reducing the group"" was abolished- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly.""""- The sentence ""with the target of reducing the group"" was abolished- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly.""""7.7.1: - Sentence ""with a group reduction target"" abolished- Continue to use the sentence indicator 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified and assessed.
Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported publicly.""""1.) The sentence ""with the target of reducing the group"" was abolished.
2.) Continue to use the indicator sentence 7.10.1 P & C 2018, ""GHG emissions for the certification unit are identified andassessed. Plans to reduce or minimize GHG emissions are carried out, monitored through the PalmGHG Calculator, and reported
publicly."""#

Indicator

Comment (English)

372

7.7.3

"The mill must be encouraged to create retention basins for its POME.
All POME must be treated before returning to nature.
The RSPO must facilitate technical and financial access to the mill to a methane capture facility to guarantee treatment of thisPOME and the generation of carbon-free energy

373
374
375
376
377
378
379

7.7.3
7.7.3
7.7.3
7.7.3
7.7.3
7.7.3
7.7.3

380

7.7.3

381

7.7.3

382
383

7.7.3
7.7.3

384
385

7.7.3
7.7.3

386

7.7.3

387

7.7.3

GHG emissions must be monitored and made accessible to relevant stakeholders, notably customers, to enable them to track theirown GHG emissions across all scopes."
7.7.3 What would be the acceptable minimum content of this plan?
untuk indikator 7.7.3 ini sebaiknya dihapus, karena kriteria 7.7 hanya fokus mengatur terkait GRK
Indicators are deleted, because criteria 7.7 only focus on regulating GHK.
Proposed: Indicator 7.7.3 is deleted, because the criterion 7.7 only focus on regulating GHK
deleted, because criteria 7.7 only focus on regulating GHK related
Proposed Indicator 7.7.3: To be deleted, because the criterion 7.7 only focus on regulating GHK related
Proposed 7.7.3: Indicators are deleted, because it does not match the criteria 7.7 scope indicators related to GHG/GRK emissions.
Irrelevant, pollution has been spoken in the indicator of waste management.
"Indicator 7.7.3 (c) is proposed for:Deleted, because criteria 7.7 only focus on regulating GHK.""'Proposal:
deleted, because criteria 7.7 only focus on regulating GHK related"
7.7.3 - Proposal to be deleted, because the criteria 7.7 only focus on regulating GHK
Indicator 7.7.3 (c) Proposed:deleted, because criteria 7.7 only focus on regulating GHK related
7.7.3: The indicator is deleted, because the criterion 7.7 only focus on regulating GHK.
"Indicator 7.7.3
Proposal:deleted, because criteria 7.7 only focus on regulating GHK related""Proposed Indicator 7.7.3:- Deleted, because criteria 7.7 only focus on regulating GHK.""Proposed 7.7.3:
deleted, because criteria 7.7 only focus on regulating GHK related"#Indicator

Comment (English)

388
389
390
391

7.7.3
7.7.3
7.7.3
7.7.3

392

7.7.3

393
394
395

7.7.3
7.7.3
7.7.4

396

7.7.4

Indicator 7.7.3 (c) is proposed to: deleted, because the criterion 7.7 only focus on regulating GHK.
Proposed 7.7.3: deleted, because criteria 7.7 only focus on regulating GHK
Indicator 7.7.3 (c): proposed to be removed, because the criterion 7.7 only focus on regulating GHK.
7.7.3. This indicator should be removed, because the criteria of 7.7 are specific regarding the minimalization and reducing GHG
emissions.
"7.7.3: The indicator is deleted, because the criterion is 7.7 only focus
Regarding GHK."
7.7.3: Deleted, because criteria 7.7 only focus on regulating GHK
Indicator 7.7.3 (c) Proposed: deleted, because criteria 7.7 only focus
The non-use of fire on the plantations must be extremely well monitored on the plots with a clear educational process for workers
and smallholders"These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.

397
398
399

7.7.4
7.7.4
7.7.4

400

7.7.4

401
402

7.7.4
7.7.4

403

7.7.4

404

7.7.4

405
406

7.7.4
7.7.4

The reduction plan must be made public with objective figures that can be verified by third parties"
7.7.4 The definition of pollutants is required.
7.7.4 - Proposal so that this indicator is deleted, because the criterion 7.7 only focus
Pada indikator 7.7.4 ini diusulkan untuk dihapus, karena kriteria 7.7 hanya fokus mengatur terkait GRK tidak ada mengatur terkait
pencemaran
Indicator 7.7.4: Proposed in the guidelines for indicators 7.7.4 It is stated that the report on development monitoring to reduceand minimize the source of pollution and their publication can be met through various environmental performance reports carriedout by the certification unit (for example: reporting of each semester of RKL-RPL, reporting Every 3 months the use of liquid waste
for land application land, etc.).
Proposed: Indicator 7.7.4 is proposed to be deleted, because the criterion 7.7 only focus"The indicator is deleted, because the criterion 7.7 is only focused
Regarding GHK."
Proposed 7.7.4: Indicator 7.7.4 is proposed to be deleted, because the criterion 7.7 only focuses on indicators related to GHG/GHG
emissions do not regulate significant pollution ... not relevant.
Indocator proposal 7.7.4: This indicator is proposed to be deleted, because the criterion 7.7 only focusing on regulating GHK does
not exist regulating the pollution.
7.7.4 - Proposal so that this indicator is deleted, because the criterion 7.7 only focus
7.7.4 - Proposal so that this indicator is deleted, because the criterion 7.7 only focus#Indicator

Comment (English)

407

7.7.4

408

7.7.4

409

7.7.4

410

7.7.4

411

7.7.4

412

7.7.4

413

7.7.4

414

7.7.4

415

7.7.4

416
417

7.7.4
7.7.4

418

7.7.4

"7.7.4: The indicator is deleted, because the criterion is 7.7 only focus
Regarding GHK.
"
This indicator is proposed to be deleted, because the criterion 7.7 only focusing on regulating the GHK does not regulate theregarding pollution"Proposed indicator 7.7.4:- This indicator is proposed to be deleted, because the criterion 7.7 only focus on regulating the GHK does not regulate regarding
pollution."
Indicator 7.7.4 is proposed in order to: This indicator is deleted, because the criteria 7.7 only focusing on regulating GHK does not
regulate the regarding pollution.
Indicator 7.7.4 is proposed to be deleted, because the criteria 7.7 only focusing on regulating GHK does not regulate regarding
pollution.
"Indicator 7.7.4'Proposal:
This indicator is proposed to be deleted, because the criterion 7.7 only focusing on regulating the GHK does not regulate theregarding pollution""7.7.4: The indicator is deleted, because the criterion is 7.7 only focus
Regarding GHK.
"
7.7.4. This indicator should be removed, because the criteria of 7.7 are specific regarding the minimalization and reducing GHG
emissions.
"'Proposed 7.7.4:
This indicator is proposed to be deleted, because the criterion 7.7 only focusing on regulating the GHK does not regulate theregarding pollution"
7.7.4: Indicators are deleted, because criteria 7.7 only focus on regulating GHK.
"'Proposed 7.7.4:
This indicator is proposed to be deleted, because the criterion 7.7 only focusing on regulating the GHK does not regulate theregarding pollution"
7.7.4: This indicator is proposed to be deleted, because the criterion 7.7 only focus#Indicator

Comment (English)

419

7.7.4

420

7.7.4

421

7.7.4

422

7.8.2

423

7.8.2

"Indicator 7.7.4 Proposed:This indicator is proposed to be deleted, because the criterion 7.7 only focusing on regulating the GHK does not regulate theregarding pollution""The inclusion of this indicator, I consider that it is worth specifying it, like this:""The Certification Unit will monitor progress towards the reduction and/or minimization of the identified GHG pollutants and will
publish a summary of the progress achieved together with the relevant management document of the certification unit.""""The inclusion of this indicator, I consider that it is worth specifying it, like this:""The certification unit will monitor progress towards the reduction and/or minimization of the identified GHG pollutants and will
publish a summary of the progress achieved in the relevant management document of the certification unit.""""The non-use of fire on the plantations must be extremely well monitored on the plots with a clear educational process forworkers and smallholders"
We are in support of WWF's comment regarding: "Suggested criteria: Human wildlife conflict, (indirectly) driven by the cultivationof oil palm, is minimized by developing responsible management measures and damage is compensated to local communities if
applicable. Suggested indicators: - management measures implemented to prevent/minimize HWC - number of HWC incidents
Suggested : ToC outcomes: improved risk management, human rights upheld, ecosystems protected"

#Indicator

Comment (English)

424

7.8.2

"(Human Wildlife Conflict) HWC is only mentioned in 2018 Standard- Annex 2 - Guidance, which dilutes the importance ofcompanies taking their responsibility to reduce conflicts. Since HWC is an issue of global concern with severe impact on local
communities and wildlife, WWF advises RSPO to include language on HWC in the criteria themselves.
Currently, RSPO mentions the following in Annex 2 - Guidance - Criteria 7.12 - Indicator 7.12.4. Developing responsible measures
to resolve human-wildlife conflicts (e.g. incursions by elephants).
We advise to include the following either in Principle 4: Respect community and human rights and deliver benefits or Principle 7:
Protect, conserve and enhance ecosystems and the environment, as HWC concerns both local communities as wildlife.
Suggested criteria:
Human wildlife conflict, (indirectly) driven by the cultivation of oil palm, is minimized by developing responsible management
measures and damage is compensated to local communities if applicable.
Suggested indicators:- management measures implemented to prevent/minimize HWC- number of HWC incidents

425

7.9

Suggested :ToC outcomes: improved risk management, human rights upheld, ecosystems protected""The HCV or HCS risk zones must be clearly defined by GPS coordinates, be made public and be the matter of particular attention
from the mills
The RSPO must be able to transmit knowledge so that the unit of certification can increase its skills in understanding these areas
with high environmental value.
The mills are then required to provide this information in training to their workers but also to smallholders.
The actions carried out in the field must be monitored and the results must be made accessible."#Indicator

Comment (English)

426

7.9

427

7.9

428

7.9

"The HCV or HCS risk zones must be clearly defined by GPS coordinates, be made public and be the matter of particular attention
from the mills
The RSPO must be able to transmit knowledge so that the unit of certification can increase its skills in understanding these areas
with high environmental value.
The mills are then required to provide this information in training to their workers but also to smallholders.
The actions carried out in the field must be monitored and the results must be made accessible."
In order to enhance biodiversity and ecosystem services on palm oil plantations, "tree islands" shall be implemented and installedon the plantations, like in the recently published and stimulating study of Zemp et al. (2023). Tree islands enhance biodiversity andfunctioning in oil palm landscapes.
"Here is the link to the article just published in Nature:https://www.nature.com/articles/s41586-023-06086-5
See also the News & Views written by Robert Nasi:
https://www.nature.com/articles/d41586-023-01733-3

429

7.9

430

7.9

431

7.9

and here is a podcast:https://www.nature.com/articles/d41586-023-01733-3"
Ideal Target is RSPO Deforestation free to be fully sustainable as a company as this is our responsibility but also to meet the new
EU DR regulations.
"Welcome the addition of peatland and other conservation areas including RTE species and its important habitats in this criterion
and also these areas shall be monitored.
[inc. peatland and other conservation areas; including RTE species and its important habitats shall be monitored …]."
"Comment for 7.9.7:
First sentence: we suggest you remove the second mention of ""areas"" as suggested here : The UoC shall not cause
deforestation or damage any areas required to protect and enhance HCVs, HCS forests, peatlands and other conservation areas.
Second sentence: Remove first mention of ""areas"", remove ""important"" (all RTE species' habitats will be important) and revise
punctuation as follows: Identified HCVs, HCS forests, peatland and other conservation areas, including RTE species and its
habitats, shall be monitored, protected and/or enhanced.
"

#Indicator

Comment (English)

432

7.9

433

7.9.1

434

7.9.1

The non-use of fire on the plantations must be extremely well monitored on the plots with a clear educational process for workers
and smallholders"Suggest (more directive language) that RSPO can insist that growers should have a plan towards a low GHG emissions target intheir operation but also in their supply chain (aware of the most critical factors to be prioritising in their plans for reducing
emissions). They should be distinguishing between different sources of emissions (emissions from palm oil mill effluent, emissions
from nitrogen fertilizers, emissions from land use change).
[This new monitoring indicator is too general. What is the target?].""These efforts must lead to a precise timeline with a strategic vision over 3-5 years of the projects to be implemented.
The reduction plan must be made public with objective figures that can be verified by third parties

435

7.9.3

436
437

7.9.3
7.9.3

438

7.9.3

"
7.9.3 PROCEDURAL NOTE: The "Annex 5" is not shared for consultation. If it is the same that was included in the 2018 P&C, it
must be revised since several of the scenarios are no longer applicable (deadlines expired). A better reference would be thedocument "Interpretation of Indicator 7.12.2 and Annex 5 (P&C 2018)," but again, that document also has contents that are
outdated (deadlines expired). If either document is used without an update it will cause confusion regarding the requirements.
7.93. Spelling error.
To make this indicator simple, the identification of HCV-HCS shall be guided by Annex 5 interpretation document. The reference
for HCS is HCSA Version 1.
"We suggested before:- focusing 7.9.3. on UoCs planning new land clearings after 15 November 2018
- referring to ""satisfactory"" HCV-HCSA assessment report which is not the same as having conducted the assessment (the quality
needs to be verified)- stating that clearing can only commence once the NPP (including outcomes of the satisfactory HCV-HCSA assessment report) andthe Integrated Management Plan (IMP) have been approved."#

Indicator

Comment (English)

439

7.9.3

"We urge swift progress on finding a solution for HFCC. We would envision such a solution to be supportive of HFCC RSPO CSPO toallow for market access also to the EU, which means that some modular approach is needed to differentiate volumes in line with
EUDR from volumes in line ‘only’ with RSPO HFCC provisions for local/smallholder/community production.

440

7.9.3

RSPO should continue engaging with the EC around recognising HCV-HCS as an equivalent to the FAO definition & importance of
HFCC provisions for equity for highly forested and less developed countries.
[Currently, the indicators are not aligned with EUDR’s FAO based definitions. As part of a modular EUDR compliant approach, wewould envision a further indicator to be developed for interim use that is aligned with the EUDR FAO based definition].""""The HCV or HCS risk zones must be clearly defined by GPS coordinates, be made public and be the matter of particularattention from the mills
The RSPO must be able to transmit knowledge so that the unit of certification can increase its skills in understanding these areas
with high environmental value.
The mills are then required to provide this information in training to their workers but also to smallholders.

441

7.9.3

442

7.9.5

443
444

7.9.5
7.9.6

445

7.9.6

The actions carried out in the field must be monitored and the results must be made accessible.""""7.9.3. Remove second phrase starting with ""This will incude..."". Both HCV-HCSA TK and HCV-HCSA manual already require
stakeholder consultation and wider landscape consideration. "7.12.7 What happens if there is HCV loss in the certified unit? How is a status change accommodated? Where is the status change
being damaged?
[Abidjan WS] 7.9.5 to include - The integrated management plan is made available and communicated with relevant stakeholders.
7.9.6 What if the local communities want, have given consent, and are supportive of oil palm development in these HCV/ HCS
areas for the cause of poverty alleviation? Would their needs matter and exception to such cases?
Is there also room for improving status of monitored species? For example if it is found that better connectivity between HCV
areas is needed for this species, should companies create this ecological corridor? Also if it means replacing some oil palm
plantation with forest land? This links to our comments on restoration in peat and steep terrain. We suggest to create first steps
for more biodiversity improvement (instead of only assesment and monitoring) in plantation landscapes such as oil palm.

#Indicator

Comment (English)

446

7.9.6

447

7.9.7

448
449

7.9.7
7.9.8

"Agreed and it would be useful to link this more clearly with 7.9.5 which requires HCVs etc - but currently not explicitly RTE species- to be 'protected and/or enhanced'. Status should not just be monitored there, but improved, in line with 7.9.5. Should look more
at how well 'protected or enhanced' currently audited and how guidance and support on this can be strengthened, e.g. to include
consideration of active measures to increase habitat connectivity, reduce likelihood of human-wildlife conflict in broader
landscape, and increase core patch size in line with recommendations from Sensor project: e.g. this paper https://besjournals.
onlinelibrary.wiley.com/doi/pdf/10.1111/1365-2664.13472 - ""we recommend active management by plantation companies toimprove forest quality of degraded HCVAs (e.g. by enrichment planting). Future revisions to the
RSPO's Principles and Criteria should also ensure that large (i.e. with a core area >2 km2) HCVAs are reconnected to continuous
tracts of forest to maximize their connectivity benefits"""
Please define what an RSPO approved HCV assessor is? This term was initially made to refer to a list provided by RSPO – but thislist has been removed. As non-ALS HCV assessments are allowed, it is unclear which HCV assessors fall under this category. It isbest to remove this term.
7.9.7. What is meant by appropriate disciplinary measures?
"Recommendation for Indicator 7.9.8:
Consider adding a definition of “natural ecosystems”. A suggested definition is the Accountability Frameworks’ definition ofnatural ecosystem (see Definitions | Accountability Framework initiative - Accountability Framework (accountability-framework.
org))

450

7.9.8

451

7.9.8

Rationale:
Regarding the definition of “natural ecosystem”: to align with the existing responsible supply chain framework so that we canenhance the use of common language on the effectiveness of the grievance system.
"
Efforts to avoid/mitigate human-wildlife conflict are important as part of both conservation efforts and measures to protect
communities and workers - we'd suggest consideration of how this might be included more explicitly in P+C. This is already in
guidance and is linked with HCV protection so it would not be adding additional requirements necessarily - more about making
expectations re protection of people and species more explicit. Indicators would need to be carefully considered to ensure focus
is on effective and appropriate monitoring and management measures being put in place. If this is considered sufficiently coveredby existing indicators then this should be clarified, and guidance made more detailed re how to audit this.
Added sentence: changes to the NKT/SKT area or other conservation areas are outlined in the Management and Monitoring
Report#

Indicator

Comment (English)

452

7.9.8

"Added the phrase ""change or
NKT/SKT area update (if any) is poured inManagement and Monitoring Report ""

453

7.9.8

454

7.9.8

455

7.9.8

456

7.9.8

457

7.9.8

458

7.9.8

Reasons Why HCV Information May Change Over Time:
1. Natural Environmental Processes
2. Social & Political Process
3. Updated/improved techniques and data
4. Deliberate Damage and Destruction to HCVS"
"Proposed Indicator 7.9.8: The phrase ""Amendment or Updating the NKT/SKT area (if any) is set out in the Management andMonitoring Report"""
Proposed 7.9.8 Improvement of Indicators added Sentence: Changes to the NKT/SKT area or other conservation areas are outlinedin the NKT/SKT management and monitoring report
Proposed 7.9.8 Improvement of Indicators added Sentence: Changes to the NKT/SKT area or other conservation areas are outlinedin the NKT/SKT management and monitoring report"Proposed indicator 7.9.8: added the phrase ""change or
NKT/SKT area update (if any) is poured inManagement and Monitoring Report """"7.9.8: added the phrase ""Change or Update NKT/SKT area (if any) is set out in the Management and Monitoring Report""
Reasons Why HCV Information May Change Over Time:
1. Natural Environmental Processes
2. Social & Political Process
3. Updated/improved techniques and data
4. Deliberate Damage and Destruction to HCVS"[Abidjan WS] 7.9.8 outcome of monitoring should be incorporated into the management plan on annual/ five years basis - there isa need to specify the timeline for the update of management pan based on monitoring result.