A complaint was filed by Greenpeace, WWF-Indonesia and Rainforest Action Network to FSC in May 2013, accusing APRIL of being involved in large-scale deforestation activities in Indonesia and bringing negative social and environmental impacts to areas with high conservation values. FSC disassociated from the company in August 2013 after APRIL unilaterally decided to file a withdrawal of the FSC certifications held by the group.
FSC and APRIL have agreed to enter a dialogue process with the view of eventually developing a roadmap to end disassociation.
APRIL has completed the relevant preconditions for undertaking the process for ending disassociation with FSC, in accordance with FSC-PRO-01-009 (Processing FSC Policy for Association Complaints).
APRIL and FSC continue to be engaged in a dialogue around the FSC Remedy Framework (FSC-PRO-01-007) which becomes effective from July 2023. This dialogue is supported by a Memorandum of Understanding between two organizations.
APRIL’s company specific remedy plan will be developed and implemented according to the provisions of the FSC Remedy Framework.
APRIL can end disassociation with FSC once the relevant thresholds as described in the remedy plan have been met, which are verified by a qualified third-party verifier, and a decision to end disassociation is taken by the FSC Board of Directors.
FSC will be hosting two webinars on the results of the Baseline Analysis and on the next steps on the FSC Roadmap process for APRIL, on the 7 and 9 of December 2020. Please see here and here to register to each of the webinars. We look forward to your participation!
-Webinar #1: 7 December 2020, 10:00 am CET: ‘Methodology, findings, and conclusions from FSC's Baseline Analysis of APRIL conducted by Forest Finest Consulting: Establishing a comprehensive baseline of information’. This webinar will provide an in-depth explanation of the scope, procedure, findings and conclusions of the FSC baseline analysis of APRIL.
Click here to access the recording of this webinar.
-Webinar #2: 9 December 2020, 10:00 am CET: ‘FSC next steps and roadmap process for APRIL’. This webinar will ill present insights from the baseline analysis and will consider how they may lead to the next phase in the FSC process: the ‘roadmap’.
Click here to access the recording of this webinar.
APRIL Group shared an acknowledgement of harm letter with FSC - submitted by its President, Mr. Praveen Singhavi. Mr. Kim Carstensen, FSC Managing Director “welcomes the acknowledgement of environmental and social harm from the APRIL Group and the commitment to fully and sincerely engage in the process of remediation. This is highly significant for the forests of Indonesia and the people who depend on them”.
To view the letter, please see the documents section below.
To view the public summary report, please see the documents section below.
FSC will be hosting two webinars on the results of the Baseline Analysis and on the next steps on the FSC Roadmap process for APRIL, on the 7 and 9 of December 2020. Please see here and here to register to each of the webinars.
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FSC has engaged an independent consultancy, Forest Finest Consultants, to conduct the baseline analysis on APRIL Group and its long term suppliers between 1994 and 2019. This evaluation will be conducted between January and May 2020.
This analysis is not part of an FSC certification process, but rather FSC is seeking to evaluate the allegations of the original complaint and other potential violations of the Policy for Association since 2013. A summary of the final report will be published on this page of the FSC website.
For more information please contact Salem Jones at email@example.com
From January 2020, FSC will conduct a baseline assessment of the complaint allegations about APRIL Group and its alignment with the FSC Policy for Association.
FSC performs a re-evaluation of APRIL’s readiness to engage in a dialogue with FSC towards ending the disassociation. The FSC Board of Directors agrees to continued dialogue between FSC, APRIL and complainant NGOs.
FSC analyzes APRIL’s SFMP (Sustainable Forestry Management Plan) and stakeholder engagement. FSC enters into a formal dialogue with APRIL based on this evaluation, concluding that APRIL is exemplifying commitment, policy and progress at a high level.
APRIL approaches FSC and expresses its willingness to comply with the FSC Policy for Association and work towards regaining FSC certification by ending disassociation. Informal dialogue begins.
FSC disassociates from APRIL.
APRIL files a withdrawal of its (and its subsidiary group's) FSC certifications.
FSC receives a joint complaint against APRIL from Greenpeace, WWF-Indonesia and Rainforest Action Network, denouncing on-going large-scale deforestation activities by the company in Indonesia. The complaints are made based on the company's purported violations of the Policy for Association alleging that large-scale forest conversion to pulpwood plantations had brought negative social and environmental impacts to areas with high conservation values.
FAQs on the Baseline Analysis and APRIL’s Policy for Association ending disassociation process
What is the “baseline analysis”?
The baseline analysis is a concept FSC dispute resolution is currently testing as a part of the ending disassociation process. The baseline analysis will provide a starting point for drafting the company specific roadmap to establish the thresholds and timelines.
The baseline concept developed out of the generic roadmap for ending disassociation. The original idea was to conduct an analysis of the allegations of unacceptable activities for those disassociation cases in which FSC was unable to conduct a complaints panel investigation. As conceived, the baseline would also be applied to ending disassociation cases in which many years have passed between ending disassociation and the roadmap drafting process. We are currently testing the applicability of the baseline analysis in the case of APRIL, which tests both use cases for the analysis, considering the absence of a complaint panel report and multiple years having passed since the disassociation.
How is this baseline analysis being conducted?
FSC has hired an independent consultancy firm, ForestFinest Consulting, to conduct the baseline analysis. The consultancy, together with FSC, has developed the methodologies to conduct the baseline as a desk-based analysis.
The baseline analysis is designed to be a desk-based exercise to provide FSC with an idea of the scope including extent of the legacy of unacceptable activities to be managed through the company specific roadmap. Field verification, peer reviews, and affected stakeholder outreach will be determined as part of the company specific roadmap process.
How does the baseline relate to the generic roadmap for ending disassociation?
The baseline analysis as designed is part of the prerequisites for entering the ending disassociation roadmap drafting phase. Other prerequisites include a disclosure of corporate structure, a readiness assessment, and acknowledgement of harm.
The drafting of the company specific roadmap will commence after all the prerequisites have been completed. The information from the baseline will be used to establish the timelines
Why was APRIL selected to test the baseline concept?
FSC conducted two readiness assessments on APRIL finding high-level commitment and dedication to the ending disassociation process.
As the ending disassociation process is not yet formalized, the FSC International Board of Directors directed the Secretariat to test the generic roadmap in the development of the APRIL company specific roadmap, which includes the baseline analysis. APRIL agreed to participate in the baseline concept and its applicability.
What if I disagree with some of the findings from the baseline analysis?
The final baseline analysis summary report will be published on the FSC website on the APRIL case page.
The baseline analysis is a quantification-oriented exercise and hence public consultation is not included at this stage. Any questions and further inputs can be raised during the public consultation of the APRIL company specific roadmap.
What is the generic roadmap for ending disassociation?
The generic roadmap is a framework of requirements, indicators and guidance for ending the disassociation between FSC and disassociated companies. The objective of the roadmap is to remedy, correct and prevent reoccurrence of unacceptable activities under the FSC Policy for Association.
It also includes other trust-building measures. Disassociation can be lifted only upon completion of the agreed conditions and thresholds specified in the roadmap. The generic roadmap framework is an adaptable set of guidelines and indicators for ending disassociation with organisations through a credible, transparent and fair procedure.
The generic roadmap framework has been organized into four sections, each containing distinct requirements, indicators and reporting for the roadmap to be implemented and achieved in full as follows:
1) Remedy of environmental harm focuses on the legacy of forest conversion since 1994, the destruction of High Conservation Values since 1999 and providing a process for attaining remedy.
2) Remedy of social harm is about identifying, documenting and measuring the impact of social harm stemming from conversion activities and violation of traditional and human rights and lays out a process for remediation of harm. This track provides the opportunity for capacity building across multiple stakeholders.
3) Prevention of the re-occurrence of FSC Policy for Association violations.
4) Protecting FSC’s reputation from controversial activities and building trust with economic, social and environmental stakeholders.
Accusations against APRIL
What was APRIL accused of?
A complaint was filed by Greenpeace, WWF-Indonesia and Rainforest Action Network to the Forest Stewardship Council (FSC) in May 2013, accusing Asia Pacific Resources International Holdings Ltd. Group (APRIL) of being involved in large-scale deforestation activities in Indonesia and bringing negative social and environmental impacts to areas with high conservation values (HCV).
What action did FSC take?
In accordance with the FSC International Dispute Resolution System, FSC set in motion the process of dealing with the complaint. However, FSC then disassociated from APRIL in August 2013 after the company unilaterally decided to file a withdrawal of the FSC certifications held by the group.
Why is FSC engaging with APRIL now?
APRIL approached FSC in September 2014 and expressed its willingness to comply with the FSC Policy for Association (PfA) and work towards regaining FSC certification by ending disassociation.
FSC started an informal dialogue with APRIL in 2014 and, in 2016, conducted analysis of the company’s Sustainable Forestry Management Plan and stakeholder engagement. This evaluation concluded that APRIL was showing a high level of commitment and progress. FSC therefore entered a formal dialogue with APRIL to re-evaluate the company’s readiness for moving towards ending the disassociation.
FSC believes ongoing dialogue with APRIL and any interested and affected stakeholders offers the most effective route to social and environmental remedy.
The baseline analysis
What is the baseline analysis?
To continue the dialogue with APRIL and NGOs, FSC needed a comprehensive baseline of information on APRIL and its long-term suppliers as a prerequisite for the process of ending disassociation with the company.
The purpose of this analysis is to assess the extent of any potential past environmental and social harm or damage caused by APRIL’s operations in Indonesia. This analysis aims to establish a complete, objective and comprehensive baseline data to inform the development of FSC’s ending disassociation process.
The baseline study consists of the following evaluation deliverables in relation to APRIL and its supply partners:
- A quantification of the forest conversion by APRIL (1994-2019);
- An estimation of the probability of the presence of HCVs within the concession boundaries based on retrospective analysis of proxies, and resulting from an estimation of potential HCV damage and loss within the plantation areas (1999-2019);
- A quantification and mapping of the total number of settlements and buildings within the concession areas (1994 – 2019);
- An identification, quantification and assessment of the allegations of a potential violation of the PfA (2013-2019);
- An identification of any potential system improvements and/or mitigation and remediation actions made by APRIL (2013 -2019).
The baseline analysis started in January 2020, with the purpose of assessing the extent of any potential past environmental and social harm or damage caused by APRIL’s operations in Indonesia, using the best information available. The consultancy firm ForestFinest Consulting (FFC) was appointed by FSC to develop such a baseline analysis of APRIL.
What was the scope of the baseline assessment?
The scope of the analysis covers 50 concessions located in Sumatra, Indonesia owned by APRIL and its supply partners, covering an area of 885,957.78 Hectares (Ha). The baseline analysis assesses the land use transformation in these concessions in the period from 1994 to 2019. Any relevant data sets for 2020 and into the future will be addressed as part of FSC’s process for ending disassociation.
How was the assessment carried out?
In January 2020, FSC engaged an independent consultancy, ForestFinest Consulting (FFC), to conduct the baseline analysis on APRIL Group and its long-term suppliers between 1994 and 2019. FFC deployed remote, desk-based evaluation and spatial technology. The assessment also included an onsite visit to APRIL’s operations in Kerinci, Indonesia, in January 2020, with the purpose of data collection.
Why didn’t you carry out more analysis on the ground?
Analysing satellite imagery is a widely used and effective approach that allowed us to establish complete, objective and comprehensive baseline data, to assess the extent of any potential past environmental harm or damage.
As part of any roadmap process for ending disassociation, APRIL would also need to gather more information on any impacts its operations had on the environment and local communities. Independent third-party verifiers will evaluate the company’s progress in the implementation of the requirements to be defined by FSC under the scope of the Roadmap.
What did the baseline analysis conclude?
FFC gathered detailed data related to the establishment of APRIL’s and its supply partners’ concessions, including quantification of conversion, estimation of potential damage and loss of HCVs and quantification of buildings and settlements. The baseline analysis also provides an overview of the allegations against APRIL since 2013 and identified improvement measures implemented by APRIL.
For a full overview of the findings and conclusions of the baseline analysis, please see the public summary available on the FSC website here.
What were the findings related to forest conversion?
The total forest cover change within APRIL’s and its supply partners’ concessions since 1994 is 531,350.31 ha. Of this, 435,877.08 ha constitute irreversible forest conversion (i.e. transition of forest cover change from dense forest to commercial plantations).
Which HCVs were present within the concession boundaries?
For the estimation FFC used data from multiple sources on HCV proxies (indicators of probability of presence of HCVs).
Of the total study area of 885,957.78 ha, 582,902.35 ha (66% of the total area) were identified as HCV1; 269,939.02 ha (30.47% of the total area) as HCV2; 537,561.66 ha (61 % of the total area) as HCV4; and 602.30 ha (0.07% of the total area) as HCVs 5-6. (Please note that this accounts for overlapping presence of values across the study area.)
Regarding the estimated HCV loss or damage within the plantation areas, 303,834.95 ha (34% of the total area) were estimated as potential loss of HCV1; 158,696.29 ha (17.91% % of the total area) as potential loss of HCV2; 310,551.86 ha (35 % of the total area) as potential loss or damage of HCV4; and 402.79 ha (0.05% of the total area) as potential loss of HCVs 5-6. When the union of HCV categories is considered in the quantification, then 715,083.12 ha (80.72% of the total area) are classified as potential presence of HCV.
When the union of HCV categories intersected with APRIL activity area, there is a total of 404,810.13 ha (45.69% of the total concession area subject to this study) of estimated damage or loss to HCVs within the plantation areas since the baseline year.
However, these findings are not necessarily indicating a violation of the FSC PfA (regarding the amount of the above-mentioned 404,810.13 ha of estimated damage or loss of HCV), but rather indicate an estimation of HCV loss or damage in the plantation area. This would need to be further qualified in a a roadmap process, which would also aims to determine the quality of restoration and conservation.
Did this assessment find any evidence that settlements were removed?
No, the analysis did not show the movement or removal of any human settlement located within APRIL’s or its supply partners’ forest management concessions. The number of settlements and buildings located within the concessions has significantly increased since 1994, from 23 to 177 settlements and 16 to 338 buildings. There was a significant peak between 2009 and 2014 when the total amount increased by 169%.
What conclusions were reached in response to allegations that APRIL violated FSC’s PfA?
A total of 138 allegations of potential violations of the FSC PfA were identified in the period 2013-2019, as well as land tenure conflicts.
Of these 138 allegations, 13 were considered to be based on substantiated information and therefore classified as ‘significant cases’.
Of these 13 significant cases, six pointed to the involvement of APRIL and its supply partners. Seven of these significant cases were attributed to the involvement of third parties (e.g. local communities) in controversial activities (such as illegal logging and encroachment) outside the scope of the FSC PfA.
The baseline analysis also identified 124 cases of potential land tenure conflicts in the period assessed. These land tenure conflicts have not undergone a compliance assessment against the PfA but have been catalogued in the report
Why wasn’t an investigation carried out in 2013?
When the withdrawal of the FSC certificates by APRIL became legally effective, there was no longer any association between FSC and APRIL. Without an association with APRIL, FSC had no legal grounds to initiate an investigation of APRIL without their consent.
Considering the commitments demonstrated since 2013, the FSC Board of Directors has decided to continue dialogue with APRIL with a view to finding a successful social and environmental remedy, driving positive impacts for the Indonesian forest and the people that depend on them.
What improvements has APRIL made?
APRIL has undertaken system improvements, mitigation and remediation actions (see below) aimed at ensuring compliance with the FSC PfA since the complaint was filed in 2013.
Key system improvements identified by ForestFinest in the baseline analysis include:
- Increased transparency in monitoring and reporting on legal compliance and regulatory requirements
- Public declaration of policy commitments on sustainable forest management
- Implementation of measures towards the protection, management and monitoring of HCVs
The development and implementation of procedures and systems for managing grievances and land tenure disputes.
What steps has APRIL taken to mitigate negative effects of its operations?
Mitigation actions identified in this analysis include:
- Implementation of community development and engagement programs
- Conducting stakeholder consultation and engagement to mitigate and prevent any potential social impacts related to their operations
- Investment of resources in implementing systems and processes for the management (and towards the resolution) of land tenure disputes.
What has APRIL done in terms remediation?
APRIL has identified areas of high importance in terms of its biodiversity values and its implementing management actions and measures for its rehabilitation, restoration and conservation. This is the case of the APRIL’s established restoration area named RER (Restorasi Ekosistem Riau) for the maintenance and protection of RTE (rare, threatened, endangered) species on Kampar Peninsula.
How is FSC consulting with its members during this process?
FSC is hosting two webinars to discuss the results of the baseline analysis and the next steps for a roadmap process for APRIL.
In 2021, FSC will be running a public consultation to define the conditions that APRIL would need to meet as part of a roadmap process. FSC will provide ample opportunities to interested stakeholders to provide feedback in relation to the Roadmap process and the conditions for APRIL.
How is FSC responding to new allegations of deforestation against APRIL?
FSC considers any new evidence of deforestation when it is presented. In the case of APRIL, FSC will review it fully before setting the conditions that the company would have to meet as part of a roadmap process.
Is FSC helping to promote APRIL’s new sustainability program?
No, we are focused on continuing the constructive dialogue with APRIL and the other concerned parties, to set a clear path forward that protects Indonesia’s forests and their communities.
FSC’s baseline analysis is completely unrelated to APRIL’s sustainability program.