Jakarta, 28 October 2015
Thank you for your letter dated 6th October 2015.
Let me begin by expressing my thanks to all the signatories for their continuing efforts to constructively engage with APP around the ongoing implementation of our Sustainability Roadmap and Forest Conservation Policy (FCP) and for the thorough recommendations set out in your letter. We recognise that we are on a journey of continual self-improvement and I am confident that our existing policy implementation is already addressing many of the points put forward.
As you acknowledge from the Rainforest Alliance evaluation conducted in 2014, APP has been recognized to have made moderate progress in implementing its Forest Conservation Policy. Complex biodiversity assessments spanning an area of 2.6 million hectares have been completed. The landscape planning process which seeks to integrate and balance the results of those assessments into long-term sustainable forest management plans is now well underway and almost completed in some regions.
Substantial progress has been made in other areas too – much of it since the Rainforest Alliance field evaluations were completed well over a year ago. On social issues for example, many conflicts have been resolved and others are in the active process of finding solutions. APP is committed to respect the customary rights of communities and we have a clear and proven process for resolving land and community conflicts which was developed with input from NGOs and social conflict experts.
Work to develop and implement our Peatland Best Practices Management Plan (PBPMP) is progressing well. The LiDAR aerial mapping of around 4.5 million hectares of peatland in and around APP’s suppliers’ concession has been completed. APP and our peat expert partners are now analysing the data and we aim to finalize it in Q1 2016. The peatland quick scan analysis is also complete and as a result we took the decision to retire 7,000 hectares of active plantation on peatland. This should be evaluated as an important milestone in the longer-term delivery of our FCP peatland commitment. It should be noted that no other company or concession license holder in Indonesia has attempted something similar, despite the fact that new management approaches to peatland are so badly needed.
You are right to identify challenges. Forest clearance by unauthorized third-parties continues to interfere with our ability to protect remaining natural forest in our supplier’s concession areas, just as it plagues sustainable forest management across the whole of Indonesia and other parts of the world. Earlier this year, we set out a series of new strategic measures designed to help tackle this problem and we will publicly report on our progress in implementing those. More detail on those measures, including a range of other enhanced FCP implementation activities, can be found in our FCP Implementation Action Plan for 2015 and Beyond.
APP acknowledges the need for strong engagement with stakeholders in order to find solutions to these and other complex challenges. We cannot do it alone or working in isolation which is why we are engaged with multiple stakeholders, through multiple platforms, in pursuit of solutions.
With regard to the tragic death of Mr Indra Pelani, let us begin by once again reassuring you that we were utterly appalled by this criminal act and that we strongly condemn violence in all its forms. Our response was immediate and pro-active. After the incident, we immediately ordered the suspension of all relevant operational activities by our supplier, PT Wirakarya Sakti (WKS), and required them to terminate their relationship with the security contractor PT MCP.
We also welcomed, and provided full support to, the independent investigation carried out by Komnas HAM, the Indonesian Human Rights Commission. Findings from that investigation were received by APP in July and APP is now acting on a number of the recommendations made in the report. That includes the appointment of an independent security contractor to conduct a security management review for improvement across our operations.
The fires in Indonesia and the haze that is currently blighting the wider region are never acceptable. Fires harm the economy, the environment and most importantly people’s lives. It also costs our business financially; through losses of plantation and conservation areas, costs of restoration as well as in the millions of dollars we spend annually to monitor, contain and put out fires.
We would like to re-iterate that none of our pulpwood suppliers practice burning to clear land. APP has implemented a Zero Burning Policy since 1996 and as far as we know, we are the only industry player who voluntarily makes public the full list and maps of its pulpwood suppliers. We also submit this information to both the Government of Indonesia, and the World Resources Institute (WRI).
As work being undertaken by the Center for International Forestry Research (CIFOR) shows, fire is a hugely complex issue. It involves the rights of local communities, illegal activity by small enterprises and fundamental complexities over land use rights, maps, ownership and protection. Solutions are possible, but they must address these root causal factors and avoid the blame game which has, so far, achieved very little. Critically these solutions have to be delivered by a wide range of stakeholders. Needless to say, if a supplier of APP were to be found to have been involved in setting fires, then APP would disengage with that supplier. We have been in regular contact with relevant authorities and provided all information requested, to deadline.
We believe that independent evaluation of our suppliers is critical in ensuring that they are in compliance with APP’s policies and that we remain transparent in our implementation of them. The final product of our FCP work is the development and implementation of the Integrated Sustainable Forest Management Plan (ISFMP), which incorporates the recommendations from the environmental and social assessments we have carried out thus far, for each supplier’s forest concession. It is in APP’s plan to regularly evaluate each supplier’s implementation of their ISFMP using independent third- parties. The involvement of CSOs and other stakeholders in this process is welcomed.
At the landscape level, we have commissioned the development of a Master Plan for the 1 million hectare conservation program. This plan is to be used by APP and any other stakeholders to develop specific projects that will support the maintenance, enhancement or restoration of high conservation value forest and/or peat land across the 10 landscapes we’ve identified. APP has also established a non-profit organization, Belantara, to channel funds for conservation initiatives related to the 1 million hectare program. We welcome the active participation of other stakeholders within the Belantara organization.
Finally, we are concerned about the references in your letter to opaque management, corruption and illegal land speculation. We would encourage you to substantiate any specific allegations you may have so that we can investigate these thoroughly in accordance with due process.
APP remains one hundred percent committed to the implementation of its Forest Conservation Policy and we look forward to our continued constructive engagement.
Managing Director, Sustainability and Stakeholder Engagement Asia Pulp and Paper Group