Grievance List & Report

• DSNG has received a letter dated 10 August 2026 from the Environmental Investigation Agency (EIA) , signed by Faith Doherty (Forest Programme Lead at EIA UK). The letter requests information and a statement concerning the operational areas of two subsidiaries, namely PT Dewata Sawit Nusantara (PT DWT) and PT Pilar Wanapersada (PT PWP), which are situated within forest areas as defined by Ministry of Forestry Decree No. 36 of 2025 (SK Menhut No. 36/2025).



• Following up on the complaint letter regarding this matter, DSNG has responded to the data and information provided by clarifying the plantation areas of PT DWT and PT PWP that fall within the forest area, as set out in DSNG’s Response to the Environmental Investigation Agency dated 21 August 2026 regarding the updated findings in accordance with the Minister of Forestry’s Decree No. 36/2025.

• DSNG, through its subsidiary PT Bima Palma Nugraha (BPN), has received deforestation alerts from PT APICAL and PT WILMAR on 22 June and 6 July 2026, relating to an area within the Tepian Prima Sawit Cooperative, at the coordinates 0.8072567, 117.3735097, covering an area of 25 ha. According to the information we received via email, the land clearing took place between 16 and 31 May 2026.



• Following up on the deforestation alert received, DSNG, through the Sustainability Operations & CSR team at PT Bima Palma Nugraha, carried out an initial verification on 24 June 2026 based on the coordinates provided dan on 7 July 2026 , the same set of coordinates was re-verified .



• Based on the results of the field verification, the location reported as having undergone deforestation is a plasma plantation owned by a company in the vicinity of the PT BPN area. This company is collaborating with a cooperative from Tepian Langsat Village. The verification results confirm that the coordinates in question are indeed within the plasma area of the Tepian Prima Sawit cooperative, which holds decision letter no. 525.26/K.527/HK/IX/2020, covering an area of approximately 347.31 hectares. The planting of oil palm trees at the Tepian Prima Sawit Cooperative (Kop. TPS) was completed in 2014, and the entire Plasma area of Kop. TPS has been converted to oil palm plantations.



• Following the verification results, DSNG, through PT BPN, has sent a letter official response to PT APICAL and, at the same time, an official response to PT WILMAR dated 7 July 2026, together with an annex containing the minutes of the previous field verification that had been carried out, and a commitment not to accept fresh fruit bunches (FFB) from suppliers sourced from forest areas or the clearing of High Conservation Value (HCV) areas.

• DSNG received a letter of complaint from the Dahas Bolau family on 3 September 2025 regarding a request for a visit to seek clarification on the plasma partnership process with DSNG's subsidiary, PT Pilar Wanapersada (PT PWP).


• DSNG received clarification of the letter by holding a meeting between PT PWP's management and the Dahas Bolau family on 10 September 2025. The following results were presented by the Dahas Bolau family:
  
  
  
  1. Demanding that the Bukit Bolau Conservation Area be excluded from the PT Pilar Wanapersada HGU
  
  
  2. Demanding a plasma/partnership for the Tapin Bini community, particularly the extended family of Dahas Bolau descendants, whose land is included in PT Pilar Wanapersada's HGU
  
  
  
  


• DSNG, through the management of PT PWP, held a follow-up meeting with the Dahas Bolau Community on 24 September 2025 with the following results:
  
  
  
  1. PT PWP is willing to enter into a partnership with the Dahas Bolau community.
  
  
  2. The Dahas Bolau community agreed to cooperate/accept a partnership with PT PWP.
  
  
  3. The community agrees to the process in accordance with Company procedures and is willing to assist.
  
  
  
  


• Based on the meeting between PT PWP and representatives of the Dahas Bolau family, DSNG sent an email to RSPO on 18 October 2025 explaining that on 16 October 2025, DSNG, through PT PWP, had received a letter from the Dahas Bolau Family Representative of Tapin Bini Village regarding a request to open a plantation in PT PWP's Bukit Bolau Block.


• On 18 November 2025, PT PWP and the Dahas Bulao family held a meeting with the Regent of Lamandau to discuss the following agenda:
  
  
  
  1. The company reported on the progress of the partnership to date, including that the legal entity status of the cooperative has been finalised, including the processing of the AHU and NIK, while the Business Identification Number (NIB) is still in progress.
  
  
  2. An HCV-HCS assessment plan will be conducted from 26 November to 10 December 2025, involving a team from the RSPO. This is because PT PWP is an RSPO member and the Dahas Bulou area is already registered as an HCV/HCS conservation area with the RSPO.
  
  
  
  


• On 30 November 2025, the RSPO responded to the DSNG's response of 18 October 2025 and the results of the discussion of 19 November 2025. The RSPO stated that it understood the concerns and current situation faced by one of its RSPO-certified plantation units, PT PWP. , PT PWP was under pressure from the local community, particularly indigenous communities, to open up part of the HCV area designated by the company for oil palm cultivation.


• In response to the meeting results and the previous email from RSPO, DSNG sent an email on 5 December 2025 to submit a Proposal Request for the Tapin Bini Community at PT PWP , containing:
  
  
  
  1. The Tapin Bini community designated an area known as Dahas Bolau as an HCV, detailing the Dahas Bolau community's history of land ownership. The Dahas Bolau community are descendants of the Dayak Tomun tribe who live in Tapin Bini.
  
  
  2. Risks to the environment, society and reputation arising from community demands for HCV areas.
  
  
  3. DSNG hopes that the RSPO will review this proposal and provide recommendations that can help to solve this issue.
  
  
  
  


• Subsequently, PT PWP collaborated with Ecotrop consultants to conduct a Land Tenure study and HCV-HCS assessment in the PT PWP area. On 18 February 2025, Ecotrop presented the study's results:
  
  
  1. Representatives of the Dahas Bolau family stated that they had not yet received the official results of the assessment. This was because the area declared as non HCV–HCS was only around 91 hectares, whereas the family had requested around 200 hectares — equivalent to 20% of the 984-hectare PWP core plantation area in Tapin Bini Village.
  
  
  2. In light of these circumstances, the family proposed several measures. These included staging a demonstration at the PT PWP headquarters to demand a 20% plasma quota, and plans to withdraw land from Dahas Bolau and partner with another party.
  
  
  
  


• On 26 February 2026, the Tapin Bini Village Community held another meeting with PT Pilar Wanapersada to reiterate their demands for the plasma plantation to be realized, with the following results:
  
  
  
  1. The community of Tapin Bini Village is demanding a 20% share of the plasma plantation managed by PT Pilar Wanapersada.
  
  
  2. PT Pilar Wanapersada has expressed its willingness to develop the Dahas Bolau – Sungai Lamandau area, which covers approximately 500 hectares. However, the company has refused to grant a 20% stake in the HGU it currently manages.
  
  
  3. To date, the community has not accepted the offer and continues to demand 20% of the managed land be returned to them. As a follow-up, the community plans to form a special team to negotiate with PT Pilar Wanapersada.
  
  
  
  


• Following deliberations on 26 February 2026, the Tapin Bini Village Community proceeded to hold a Peaceful Protest on 7 March 2026 which contained several demands to PT PWP, including:
  
  
  
  1. Demanding the realisation of 20% of the potential land in Tapin Bini Subdistrict, which has been managed by PT PWP since 2009.
  
  
  2. Demanding a re-measurement of all potential land in Tapin Bini Village that has been cultivated by PT PWP since 2009. The measurement process is requested to involve:
     
     
     1. The measurement team from the Lamandau Regency Local Government.
     
     
     2. The measurement team from PT PWP.
     
     
     3. An independent measurement team representing the community of Tapin Bini Village.
     
     
  
  


• Following up on the DSNG email dated 18 October and the proposal dated 5 December 2025 to the RSPO, as well as the request for results from the Dahas Bolau Community of Tapin Bini Village to PT PWP, which gave a deadline of 30 March 2026, on 10 March 2026 DSNG sent another letter to the RSPO containing the following information:
  
  
  
  1. Results of the Land Tenure & HCV-HCS Re-Assessment Study for the Tapin Bini Village Community.
  
  
  2. Results of meetings between the Lamandau Regency Government, the Dahas Bolau family, the Tapin Bini Village community, and PT PWP from 19 November 2025 to 7 March 2026.
     DSNG hopes to receive guidance from the RSPO regarding the changes to the HCV. They propose that an RSPO team conduct a field review to obtain first-hand information and facts.
  
  
  
  
  


• On 10 March 2026, the RSPO responded to an email from the DSNG stating that they would conduct an internal review and study the development documents before responding to the updated information.



• On 11 March 2026, following up on the results of the peaceful action taken by the community, the Regent of Lamandau sent a letter to the leadership of the RSPO containing several points related to the conditions of the Dahas Bolau community and plans for developing plasma plantations in the Tapin Bini sub-district. The letter stated that:
  
  
  
  1. The Dahas Bolau community has lived in the area for generations.
  
  
  2. The economic conditions of the community are still limited and most do not yet have a steady income.
  
  
  3. Tapin Bini Village has not yet obtained plasma plantation from nearby companies.
  
  
  4. The plasma area is proposed to be allocated from legal APL land in Tapin Bini Village that has not yet been planted with oil palms and does not yet have individual ownership.
  
  
  
  

In this regard, the Lamandau Regency Government requested the RSPO's support and consideration so that the aspirations of the Tapin Bini Village community could be considered, while continuing to prioritise sustainability, environmental balance, and improving the welfare of local communities.

• DSNG menerima grievance dari Sinar Mas pada 11 Februari 2026 terkait pemberitaan yang diterbitkan di https://kaltimpost.jawapos.com/kutai-timur/2387151213/konflik-agraria-melibatkan-11-kelompok-tani-dan-pt-bas-di-karangan-tak-kunjung-selesai pada 4 Februari 2026 mengenai dugaan tumpang tindih lahan antara PT BAS dan 11 kelompok tani.


• DSNG menyampaikan klarifikasi melalui surat tertanggal 23 Februari 2026 yang menjelaskan bahwa:
  
  
  
  1. Klaim tumpang tindih lahan tersebut memang pernah terjadi sejak tahun 2017 di masa kepemilikan PT BAS sebelum diambil alih dan masih berlangsung hingga diakuisisi oleh DSN Group.
  
  
  2. Telah dilakukan Ganti Rugi Tanam Tumbuh (GRTT) kepada anggota kelompok sesuai mekanisme dan legalitas yang berlaku.
  
  
  3. Penyelesaian telah ditempuh melalui proses mediasi dan jalur hukum sesuai peraturan yang berlaku.
  
  
  4. Melalui proses hukum diperoleh keputusan pengadilan sebagai berikut:
     
     
     
     • Putusan Pengadilan Negeri Sangatta Nomor 56/Pdt.G/2018/PN Sgt tanggal 28 Juni 2019 yang menyatakan gugatan tidak dapat diterima.
     
     
     • Putusan Pengadilan Tinggi Samarinda Nomor 134/Pdt/2019/PT.SMR tanggal 19 November 2019 yang menguatkan putusan tersebut.
     
     
  
  
  5. Tidak terdapat upaya hukum lanjutan sehingga putusan berkekuatan hukum tetap (Inkrach). PT BAS menghormati dan mematuhi sepenuhnya putusan tersebut.
  
  

• On 25 November 2024, DSNG received a Research Report study from Wahana Lingkungan Hidup Indonesia (WALHI), West Kalimantan conducted in 2023 contained a request for clarification/rebuttal of the study results regarding PT Prima Sawit Andalan (PSA) and PT Dharma Persada Sejahtera (DPS). The results of this study are highlighted:
  
  
  
  1. PT DPS and PT PSA are suspected of omission, neglect and violation of labour rights and labour law, particularly in relation to RSPO labour standard Principle 6 on Respecting Workers‘ Rights and Working Conditions, which aims to protect workers’ rights and ensure safe and decent working conditions.
  
  
  2. Land Conflict and GRTT regarding the overlap of customary territories with the HGU concessions of PT DPS and PT PSA which are managed without consent (FPIC), without submission, and without compensation.
  
  
  
  
• DSNG responded to this request by meeting with the Sintang local government and WALHI on 13 January 2025, as stated in the Minutes of the Synchronisation and Evaluation of WALHI Research Results.

• On 12 February 2024 DSNG received an email via info@dsngroup.co.id requesting clarification/rebuttal of the results of study on PT Pilar Wanapersana (PT PWP). The study highlights:
  
  
  
  1. PT PWP's involvement in the killing of orangutans and gibbons, by employing local people (2010-2015)
  
  
  2. Company activities that cause damage to river systems, drying up of groundwater levels within the HGU, as well as air and noise pollution.
  
  
  3. Non-compliance with NDPE policy with respect to monitoring the fulfilment of workers' fundamental rights throughout the supply chain and by contractors.
  
  
  4. Non-compliance with NDPE policy in terms of ensuring that there is no deforestation associated with the FFB purchased by the company.
  
  
  
  


• DSNG responded to the request with a letter of response and clarification on 19 February 2024, as well as an invitation to dialogue


• On 24-25 February 2024, DSNG representatives met the complainant and had a dialogue on the background and purpose of the scientific study.


• DSNG sent a request to upload the study paper along with the name of the writing team on 15 March 2023, and was responded by the head of the writing team with permission on 18 March 2024 by confirmation through a statement letter on 26 March 2024.


• DSNG replied to the authors on 8 April 2024 thanking them for their permission, explaining the grievance mechanism, and informing them that HCV-related data and DSNG's sustainability performance can be accessed through the RSPO website, &Green, and other public domains. DSNG hopes that the authors can use the information verified by the accredited institutions in their scientific work.


• The head of the writing team did not respond to the email officially, instead sending a chat via whatsapp to the CSR Head of the West Kalimantan Region, informing him that he would submit a complaint to SRI-Kehati.


• The head of the team of authors sent a response letter on 16 April 2024, responding to the DSNG's request for detailed information with an exchange of detailed data. The author also submitted allegations of NDPE violations in the form of deforestation and labour rights violations by PT PWP's contractors. Upon further verification, the land clearing in question was outside PT PWP's HGU, and DSNG explained the applicable contractor compliance mechanism. This letter was responded by DSNG on 6 May 2024.


• The author team leader sent another response letter on 8 May 2024, providing verification conducted by DSN regarding the omission of alleged deforestation and labour rights violations by PT PWP from data in the ISPO and RSPO domains. In the same letter, the author team leader conveyed that fundamental improvements should be made to the principles of CGG (Good Corporation Government) and the implementation of obligations to former employees.


• DSNG sent a reply letter acknowledging the information provided by the lead author on 12 July 2024, explaining that DSNG had conducted further verification and investigation into the matters reported. On 18 July 2024, the lead author responded by sending a reply letter dated 17 May 2024 requesting clarification on the discrepancies in deforestation coordinates at PT PWP and the intimidation received.


• DSNG responded by sending a reply letter on 26 July 2024, stating that the location of the alleged deforestation was outside of PT PWP's Cultivation Rights (HGU) and Lamanku Sukses Bersama Cooperative Partnership Concession. Regarding the author's report of intimidation, DSNG reiterated the company's zero-tolerance policy on intimidation and said that the author could file a report with the relevant authorities if any party intimidated the author.


• The response letter from DSNG was replied by the Team Leader on August 1, 2024, highlighting the discrepancies between the reported and verified deforestation coordinates at PT PWP, the authors' reporting to the RSPO of NDPE policy violations including land clearing in riparian areas, and the intimidation received by members of the research team, which the team reported to the German and Dutch governments. The letter also stated that the results of the research will be presented at a scientific conference in Norway and the research will also be published in a journal or paper on December 25, 2024, with a revision deadline of August 5, 2024.


• DSNG responded to the letter on August 26, 2024. In this letter, DSNG responded to the coordinate discrepancies submitted by conducting re- measurement using two devices with different units, which are UTM DD (decimal degree) and UTM DMS (degree, minute, second) at the indicated location. In addition, DSNG also invited researchers to come directly to the location to conduct joint measurements, if they still had doubts about the results of this clarification. Regarding NDPE policy and land clearing in riparian areas, DSNG has conducted compensation procedures that have been reported and approved by RSPO. DSNG also verified that the rivers around their mills do not dry up. In addition, DSNG rejected allegations of intimidation and confirmed that there were no violations. DSNG also supports responsible information disclosure and respects the rights of researchers to publish their papers in accordance with academic procedures.


• On September 20, 2024, the Authors' Team Leader sent a follow-up letter. He accepted the invitation to re-measure measurements, as well as requesting measurements for 86 other points. He also rejected the river verification on the grounds that there were no guarantees regarding water discharge conditions during the dry season as part of the measurements. In addition, it was informed that the Team was planning an in-depth study of the on the Dharma Satya Nusantara Group, covering various aspects such as crisis management, CSR, financial analysis, and crisis management, and work culture, which will be compiled based on scientific methods, and requested a formal report of the results. scientific method, while requested an official report on the results of the company's investigation into the intimidation experienced.


• DSNG responded to the letter on October 16, 2024, stating that The Company only agreed to a joint verification process for the coordinates already submitted and rejected verification of the additional 86 new points as they went beyond the original subject matter. DSNG also welcomed a broader scope of research and was open to dialog.


• The letter was replied to by the Research Team on October 22, 2024, asserting the right to measure the 86 points in question based on HGU law as state assets. He highlighted the intimidation and involvement of unrelated parties that undermined the procedure and requested clarification from the person in charge (CEO or President Director).


• DSNG responded on November 25, 2024, confirming that field verification would only be conducted at the agreed initial coordinates to maintain the focus and effectiveness of the process. The company responded to the intimidation complaint by informing them that an internal investigation is underway and suggested reporting to the authorities. Regarding the alleged river pollution, the company requested specific details of the location and time of the incident to be able to conduct further analysis. The company respects the authors' broader research plans but emphasizes the need for additional information to support the process.


• The lead of authors replied news by expressing disappointment with the company's unprofessionalism, especially regarding communications that are considered poorly organized, such as sending emails outside working hours and poor coordination during meetings with company representatives. He was also confirming that field verification of the river is ongoing and highlights the company's lack of attention to the social, economic and health impacts of Liku Village communities affected by company activities, including dust from CPO transport. He was also questioning the company's commitment to good corporate governance (GCG) and was calling for formalized communication and data submission processes.


• DSNG replied by acknowledging an incorrect statement in its previous letter regarding the location of the meeting, clarifying that the meeting on February 24, 2024 took place at Hotel Figo, Banjarmasin, not Palangkaraya. The company also noted that the latest correspondence did not present any new facts that could help deepen the discussion. DSNG keeps the lines of communication open and invites the submission of necessary information, and wishes the researcher success in his research and professional activities.


• On December 9, 2024, the lead of authors sent a reply, reiterating the original complaint, stating that findings related to NDPE policy, HCV, and violations by subcontractors at PT PWP had not been adequately followed up by DSNG. Findings included pollution of the Kampar River allegedly caused by the mill, HGU boundary violations in Bukit Pedulangan, and alleged human-orangutan conflicts involving company employees. In addition, reported violations by subcontractors related to payment below the minimum wage, withholding of wages, violation of work safety rules, and dangerous driving behavior in Liku Village. He offered to assist with the investigation and emphasized the importance of having it handled by competent parties.


• DSNG responded to the letter on December 19, 2024, expressing appreciation for the concerns raised, but reiterated that since the report was not provided with sufficient details such as time, date, or location, DSNG could not investigate further. DSNG continues to open the door of communication for the Author Team to provide detailed information regarding all reports submitted.

1. On 22 January 2024, DSNG received an email from Ghina Syafira Shofia (PT GAR representative) asking for indications of deforestation in PT Dewata Sawit Nusantara from 2018-2023 covering 49.41 Ha.


2. DSNG has conducted field verification on 23 September 2022 of deforestation alerts.


3. The clarification letter was sent on 23 February 2023 to email sender and was accepted with the addition of the latest field evidence.


4. DSNG resubmits results and updated verification form by 25 January 2024.

1. On 8 February 2023 DSNG received an email from Sinar Mas Agribusiness and Food asking for clarification on indications of deforestation within PT PWP's concession in the period January-March and June-August 2022.


2. DSNG conducted field verification on 9 February 2023.


3. Clarification letter sent on 13 February 2023 to email sender and acknowledged as received.

1. A report titled "Palm Oil deforestation in Indonesia levels off in 2022" published on the Nusantara Atlas blog on 5 January lists PT Putra Utama Lestari as one of the companies that has deforested 83 Ha.


2. In response to this report, DSNG wrote to TheTreeMap (as the owner of Nusantara Atlas blog) on 19 January 2023 explaining that DSNG had conducted clarification and field verification and stated that no deforestation had taken place. Detected land clearing is in an area that used to be part of the PT PUL concession.


3. In response to DSNG's letter, TheTreeMap replied on 20 January 2023, by including a link to a deforestation map whose coverage they have developed.


4. In further response, DSNG on 27 January 2023 sent a cadastral shapefile of PT PUL's HGU to TheTreeMap to emphasize that the area position in question was outside the HGU of PT PUL.


5. On 31 January 2023 TheTreeMap stated that it had examined the data provided by DSNG and amended its report accordingly