#Indicator

Comment (English)

1

Definition

The definition of small system or associate producer does not fit the small associated producers that exist today in Latam. These small
producers want to maintain a direct relationship with the extractor plant and certify under the umbrella of the certification unit, but
this producer is autonomous and has total management, management, exploitation, financing of their land or property.

2Introduction

The ISH standard has not much changed from the 2019 version. We do not see a difference on the definitions of (i) smallholder (ii)independent smallholder (iii) scheme smallholder. This is a big discussion in Latin America as in most of the cases smallholders areindependent smallholders and there is a confusion to define if the smallholder is either a scheme or an independent smallholder.
Furthermore, there are social enterprises (see Honduras NI definitions). It's important to have more discussion about how to read thesmallholders in different regions. Examples: Guatemala, Honduras, PNG> Suggest RSPO to follow up closely with the NI to indicate what would be appropriate in each case, to review all the scenarios.

3Principle 1

1.1 There are two (2) core business vehicles which are legal entities and business entities ( are we covering business entities as well?).
To establish legal entities requires the approval of some government authorities, on the other hands to establish a business entity
requires registration with government authorities.

4Principle 1

Do we need to add four (4) GAP pillars for clarity ? As can be referred inFAO ( https://www.fao.org/3/y8704e/y8704e.htm) pillar one: economic viability, pillar
two : environmental stability,pillar three: social acceptability, and pillar four: food safety and quality

5Principle 1

The legal figure limits the independence of the producer, another strategy could be sought that allows the union of several producers
to achieve their certification without implying creating a legal figure, example a commitment of union as a group and compliance withthe standard as proposed in the annex 2 of the norm.

6Principle 1

1.1e specify or direct the indicator so that the small producer can be certified alone, without being associated or with a benefit plant.

7Principle 1

The legal entity of the certification group implies tax costs (tax payment, accountant, legal advice, etc.), which sometimes hinders theprocess of grouping members.

8Principle 1[Abidjan WS] 1.3 - provide a list of GAP and BMP. How many BMP in a year?

9Principle 2This is not fair for smallholder with Land Application status (LA). It's because, some of smallholder applied the land since around 70-anand still pending getting the Approval or Grant from state government (NT). As a group manager for smallholder group, we are advice,
who is smallholder with LA's status, RSPO/auditor take the consideration at least, the smallholders;
1. Can proof there is no land dispute,
2. Can proof the smallholder not doing any encroachment for any sensitive area, i.e., forest reserve, waterbody, any HCV area, etc.,(proof during stakeholder consultation with nearby stakeholder or any related to the Government agency),
3. The smallholder have proper boundaries

#Indicator

Comment (English)

10Principle 2>Welcome the addition – aligned with PC2023:
Principle 2 : Smallholders provide the coordinates or maps of their plots and evidence of ownership, or rights to use the land ordemonstrate that they are in the process of legalisation of that right (2.1 E); Smallholders declare any existing disputes on the land,commit to resolving said disputes, develop a plan to address them, including initiating a participatory mapping with relevant
stakeholders as may be required, and provide information on the current status of those disputes (2.3 E); Smallholder plots are locatedoutside areas prohibited by national park or protected area, as well as steep terrain (2.4),

11Principle 2

It makes no sense to demand a CLPI for established plantations: it would no longer be prior.
In addition, even for the PPI there is no clarity about the simplified CLPI

12Principle 2

It is important to clarify that in Latam there are PPI that were before some places such as protected natural areas (ANP) were declared... They cannot be certified?
Likewise, in many of our countries the ANP have a management plan, where a core zone (100% conservation) and other areas, forexample, of damping, where non -extensive agricultural crops can be established, which apply for PPI. Then, in this indicator there
should be a procedure note that indicates that the ANP management plan must be reviewed to verify whether or not to establish thecrop.

13

Principle 2

2.2 Define if it is for new plantations or for existing plantations, even if for existing plantations in production request consent is toreturn to the past14

Principle 2

2.2. Clip, will apply only for new plantations. And when the simplified approach procedure will be established.

15Principle 2[Abidjan WS] 2.1EA replaced 'can' with 'shall'

16

Principle 2[Abidjan WS] 2.2E replaced 'can' with 'shall'

17

Principle 3[Accra WS] 3.1 MS A 'No evidence of force-labour should be in MSA' MS A: Shall include both i) no evidence of force- labour and ii)
completion of training. MS B are the same as MS A

#Indicator

Comment (English)

18

Principle 3>Welcome the addition – aligned with PC2023:
Principle 3: Smallholders agree not to use forced labor and ensure that any use of forced labor on the farm ends at the Eligibility stage.
At a minimum, a simplified labor agreement (i.e., a labor register) stipulates workers' basic employment terms, in accordance withnational context and regulation (3.1 E); There is no evidence of forced labor. Smallholders implement measures to ensure that all workis voluntary, and the following practices are prohibited: • Retention of identity documents, including but not limited to passports; •Payment of recruitment fees by workers; • Contract substitution; • Involuntary overtime; • Lack of freedom of workers to resign; •Penalty for termination of employment; • Debt bondage; • Withholding of wages (3.1 MS B); Are there workers on the farm?... . Theterm workers includes permanent and non-permanent workers, and based on the regional customary for temporary workers (3.3);
Smallholders commit to providing safe working conditions and facilities including appropriate Personal Protective Equipment (PPE)
free of charge (3.5 E)

19

Principle 3[Accra WS] 3.1 E should break into three separate indicators - else one non compliance will need to the entire indicator NC: i)
Agreement not to use force labour; ii) Simplified agreement shall be signed for an labour engagement longer than 3 months,stipulates.... regulation.; iii) source of labour. MSA and MSB are the same across all three.

20Principle 3

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.

21Principle 3

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 migrantworkers, or illiterate workers

22Principle 3This 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)

23

Principle 3

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 process24

Principle 3

3.1 has defined the scope of contract substitution25

Principle 3

3.3 Leave what national legislation indicates and not opt for customs of the region

26

Principle 3

In most indicators, the commitment is first and then the training in the relevant issues ... I understand that it was left to facilitatecompliance; But, at least it should be clarified that to establish the commitment, the group manager must inform and explain what
each term is being ensured that the PPI understands it.

27

Principle 33.6 E Define that it is discrimination, harass or commit abuse, or leave it as the national legislation of the country indicates, or firstplace the 3.6 ha and train it prior and then compromise

28

Principle 4>Welcome the addition – aligned with PC2023:
Principle 4: Do any smallholders within the group have plans for new planting of oil palm? New planting of independent smallholders,since November 2019:.. • Are not located in restricted areas or protected by national laws • Are not on riparian areas (4.3); Do anysmallholders within the group have plans for replanting plots that are located on peat? If no, SKIP. Plots on peat are replanted only on
areas with low risk of flooding or saline intrusion as demonstrated by an RSPO approved flood risk assessment, in accordance with theRSPO ISH Flood Risk Assessment Template(4.5); Riparian buffer zones are identified and managed to ensure maintenance and/orimprovement, in accordance with national legislation and taking into account the RSPO Manual for the latest version of theManagement and Rehabilitation of Riparian Reserves - Simplified Guide (4.7)

29Principle 4

Please look into the RSPO P&C gap analysis vs. the EU Deforestation Regulation. The conclusion in that analysis should be checked for
the RISS as well: "The above means that there is a misalignment between the ‘deforestation-free’ requirement of the EUDR and theRSPO Principles & Criteria approach using HCV and HCS assessments, including relevant definitions.” At the same time, the risk of
introducing this requirement is: making RISS more difficult to comply with while many smallholders do not deliver into the EU market.

30

Principle 4

HCSA strongly advocates that the Simplified HCS-HCV Approach for Indonesian Palm Oil smallholders to be used as the basis for theRSPO HCS-HCV procedure.
Any forthcoming develop or trials of a simplified or adapted approach for smallholders, the HCSA Simplified HCS-HCV Approach should
be used as the starting point.

31

Principle 4

If the smallholder refer and follow to the actual RSPO riparian management guideline, size/wide of riparian will be effect to the size ofcultivation oil palm and it's will be reduce income of FFB harvesting.

#Indicator

Comment (English)

32

Principle 4>Welcome the addition – aligned with PC2023:
A- ICS group entity and group management requirements: participation of members and/or consultation in planning to implement thegroup’s ICS system (A2.1E)
B-ICS: policies and management: The ICS is implemented and an annual internal audit of the group is conducted on at least half of thegroup members (for IC), followed by the balance half in the following year (ASA1). In the next following year until recertification,
sampling size for group annual internal audit will be based on risk assessment to all existing members, which include members that fallunder Medium and High risk, and new members (if any). The total sampling size for annual internal audit shall not be less than 33% ofgroup size (B 1.1 MS B)
Annex 2 Smallholder declaration: C. I will provide the following information to my group manager 6. Any plots located on riparian
(NEW)

33

Principle 4

Clarify that alternative livelihoods and saline intrusion are, these terms are not understood34

Principle 4

Clarify that remediation and/or compensation should be done as the case may be and this will be done in the area resulting from theLUCA analysis, the above since compensation is not included and a maximum area to be remedied is indicated, which implies that A
minimum area could be chosen.
On the other hand, the indicator establishes a plan to identify the area to be remedied, which is not true since a simplified luca wascarried out in the mile also simplified remediation and compensation that today does not exist

35

Principle 4

Clarify what type of training should be completed or referred to simply to training

36

Principle 4This principle contemplates the identification of natural ecosystems, AVC, identification of riparian areas, ARC forests, rap species,
peat areas, ect. Taking into account that these identifications are carried out through specialized evaluations and studies, the standard
must contemplate simplified studies and supported by the RSPO so that the PPI meets these requirements according to theirresources and capacities.

37

Principle 4

The compensation does not apply to the PPI, only remediation.

38

Principle 44.2 Correct the indicator according to the version they will take in Luca's consultation that is not compensation

39

Principle 4

Adjusting the text since what should be minimized is the use of pesticides but not pesticides and herbicides

40

Principle 4

Include phytosanitary management within exceptional circumstances since the term covers both pests and diseases

41

Principle 4

Change the term pesticides by pesticides

42

Principle 4

4.8 E Change pesticides for pesticides such as the English version

43

Principle 4

4.6 Include that fire can be used in circumstances for pests and diseases.

#Indicator

44

Comment (English)
This is an issue that has been discussed in different forums and has not echoed.
It is necessary that the small independent producer be included (because it makes the decisions about their property) that it does notwant to form a group or certify independently but prefers to certify under the certification of the extractor plant, to which its fruit
gives.
Like the "PPI", the "PPI-Associated" has lower resources and should be audited under the PPI indicators and not under those of full
PyC, as applied today.

45A1-ICS

A1.4 meet the members of membership according to the language of the country that is carrying out the process more for a small
producer who has to translate it, see the times of attention.

46

A2-ICS

I consider relevant to create a guide from the RSPO on the internal control system model to facilitate the group manager.

47

A2-ICS

From RSPO, training is promoted through coaches coach prioritizing the participation of group producers or managers in these training
spaces.

48

A2-ICS

It is necessary that a guide be indicated on the relevant aspects of the Internal Control System (SIC), for example: what does
governance include?; What includes the training plan? What does the audit plan include? How can a managing team be formed?

49

Annex 2[Abidjan WS] C1 - please provide details on what are 'details information' on land holdings?

50

Annex 2[Abidjan WS] C 10 - provide definition of land ownership - stating based on NI guidance.

51

C-ICS

Add C2.1.e: Approach to strengthen the chain in the supply chain, including the potential partnership with the Certification Unit (Mill)in the supply of certified material.

52C-ICS

To meet the EUDR regulation, I suggested to include additional bullets in this section. To ensure there is an urge to traceability at thelevel of self -help farmers.
C1.1. E:
Annual group business plans are available and include:- Estimated production and income based on historical records;- Expansion plan, and- Collaboration and production partnership plans with certified mill or RSPO members

53

C-ICS

C2.1.ETo add in bullet 2: Approach to strengthen the chain in the supply chain, including the potential partnership with UC in the supply ofcertified materials

54

C1-ICSA transition period must be generated to achieve the group's financial stability, since they are new issues for them, achieving financialbalance requires time to make decisions and evaluation of variables.