Asia Pacific Resources International Holdings Ltd. Group (APRIL)

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.

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.

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 

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. 

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.  

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.  

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:

1. A quantification of the forest conversion by APRIL (1994-2019);
2. 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);
3. A quantification and mapping of the total number of settlements and buildings within the concession areas (1994 – 2019);
4. An identification, quantification and assessment of the allegations of a potential violation of the PfA (2013-2019);
5. 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.

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.

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.

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.  

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.

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).

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.

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%.

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

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.