24 Jun 2022
Environmental lobby group ignores key information in its bid to influence EU deforestation law
London – Environmental lobby group Global Witness has carried out an investigation which, it said, links industrial rubber plantations in West and Central Africa to an area of tropical deforestation 16 times the size of Brussels – the city spans an area of 32km square kilometres – since 2000.
The findings, claims the NGO, establishes the rubber industry “as the leading European driver of deforestation in the region” – in a press release arguing for the inclusion of rubber in a draft EU law to tackle global deforestation.
Analysing satellite data, Global Witness found that rubber plantations had impacted ‘ecosystems ranging from old-growth equatorial forests to forest reserves, devastating indigenous communities’ in both African regions over the last 22 years.
“The rubber industry is threatening the land, livelihoods and rights of local communities and destroying a crucial carbon sink,” stated Global Witness, attacking the industry for lobbying against an EU law to prevent investment in projects linked to deforestation and sale of deforestation-linked products in Europe.
The NGO linked these claims to the activities of the three main plantations owners Olam, Halcyon Agri and Socfin, as well as to their tire-maker customers such as Michelin and Continental, and financial institutions like Rabobank, BNP Paribas and Deutsche Bank.
The Global Witness release, however, made no reference to information supplied by the rubber plantation companies (see below), which gives a completely different perspective to the situation.
Socfin, for one, said that contrary to the image portrayed by Global Witness, it plays a leading role in multipartite stakeholder initiatives, including the Global Platform for Sustainable Natural Rubber (GPSNR) – the company is a founding member of the platform leading socioeconomic and environmental progress in the rubber supply-chain.
At the end of 2016, Socfin (see statement below) made a commitment to zero-deforestation as a central element of its responsible management policy (RMP), which also covers respect for human rights as defined under United Nations principles.
In the 16 years prior to the establishment of its zero-deforestation policy, Socfin said a total of 4,890 hectares of rubber extensions were planted by clearing degraded forest. Since 2017, no new plantation projects are being launched without its RMP being “strictly applied”.
Similarly, Halcyon Agri provided detailed statements to the Global Witness investigation clearly explaining the activities of its operations in tackling deforestation and supporting local communities (see statement below).
Global Witness has also claimed that industry body the European Tyre and Rubber Manufacturers’ Association (ETRMA) had lobbied for the exclusion of rubber from the proposed EU anti-deforestation legislation.
In reality, the ETRMA – and other industry bodies – back legislative moves to prevent deforestation and measures that support responsible and sustainable sourcing of natural rubber.
ETRMA has explained that requiring ‘traceability to a plot of land’ would be impractical to apply to natural rubber (NR). Instead, the industry group has recommend that EU regulators adopt “a mandatory risk-based due diligence model based on ‘jurisdictional traceability’.”
This, it said, would more effectively “accelerate and scale up initiatives for sustainable commodity production” – as opposed to focusing on individual participants in an NR supply-chain, which comprises 6 million smallholders and many layers between tree and final consumer.
Likewise, the GPSNR (see statement below) believes appropriate legislative action can support its efforts to establish standards of sustainability, equity and fairness across the rubber supply-chain.
Comprising representatives from environmental groups, smaller holders and civil society as well as from the rubber, tire and automotive industries, the platform already has active policies in place to ensure that natural rubber is sourced in a way that does not contribute to deforestation.
GPSNR aims to go beyond members’ procurement policy commitments to introduce systems for risk assessment, monitoring & evaluation and a claims framework. It is also working on a traceability benchmark and transparency roadmap for the rubber industry.
Position statements regarding sustainable and responsible sourcing of natural rubber
Socfin Group
A report released by Global Witness on the 15th of June 2022 focuses on the environmental risks of rubber plantations and on certain players active on the African continent such as the Socfin Group. The report attempts to alert European leaders to the deforestation that can result from rubber tree cultivation.
Although Global Witness shared its concerns prior to publication and included the Socfin Group’s position in the final report, we feel it is our responsibility to provide the following information and clarification:
At the end of 2016, Socfin made a commitment to zero-deforestation. This commitment is central to its Responsible Management Policy (RMP) as published in March 2017 and revised in March 2022. SOCFIN's Responsible Management Policy also integrates the principles of the Global Platform for Sustainable Natural Rubber (GPSNR), of which SOCFIN is a founding member, and further extends to the respect of human rights as defined by the internationally recognised Guiding Principles of the United Nations.
Between 2000 and 2016, prior to the establishment of its zero-deforestation policy, a total of 4890 hectares of rubber extensions were planted by clearing degraded forest. Since 2017, and as stated in the Socfin Group's Responsible Management Policy, no new plantation projects are being launched unless the following approaches and procedures have been strictly applied:
- High Carbon Stock (HCS);
- High Conservation Value (HCV);
- Free, Prior and Informed Consent (FPIC) principles.
Regarding the Socfin Group's subsidiary in Nigeria, Okomu Oil Palm Company, the original plantation was created in 1976 by the Federal Government of Nigeria out of a degazetted area of the Okomu Forest Reserve. Today, this operation strictly applies Socfin's Responsible Management Policy. It is ISO14001 certified since 2014 and RSPO certified since January 2020 - clear commitments to the respect of communities’ rights and the environment.
Furthermore, and contrary to the image portrayed in this report, the Socfin Group plays a leading role in multipartite stakeholder initiatives:
- Socfin is a founding member of GPSNR (as mentioned above), whose mission is to lead socio[1]economic and environmental progress in the natural rubber supply chain. Members of GPSNR are all major players of the natural rubber industry as well as representatives from civil society.
- Socfin is an active member of RSPO (Roundtable on Sustainable Palm Oil) since 2004 through Socfindo and Socfinco and has obtained a Group membership in February 2019. It has to[1]date certified 91% of its sites with the aim to be fully certified by December 2022.
- Socfin is a member of Earthworm Foundation (EF = ex-TFT), which supports the Group in the implementation of its Responsible Management Policies within its subsidiaries.
Throughout all its operations, Socfin implements integrated actions to fight deforestation and preserve the environment. The Group aims to reduce and mitigate its impact by means of innovative and transformative agricultural practices.
Halcyon Agri
Corrie Maccoll response to Global Witness (GW) assertions, 25 May 2022 [Corrie Maccoll is a subsidiary of Halcyon Agri, which manages the group’s plantations in Cameroon]
GW assertion: We note that your company controls the Cameroonian subsidiaries Hevecam and Sudcam. According to our analysis these subsidiaries plantations contain 20,916 hectares of land that has been converted from natural forest to rubber plantation since 2000.
Corrie Maccoll: Correct
GW assertion: Hevecam plantations contain 3,686ha and Sudcam 16,816ha of land deforested since 2000. We note however that a proportion of this deforestation likely took place before your company’s acquisition of these plantations.
Corrie Maccoll: Correct. Halcyon took over management of the plantations in late 2016.
GW assertion: However, in the case of Sudcam 2,300 hectares of deforestation took place after your company acquired the plantation.
Corrie Maccoll: Correct. Our management was informed that the land being cleared had already been logged meaning it was not primary forest. At the time of the Greenpeace report, Halcyon immediately called for a cease of all clearing until we conducted an investigation. No clearing has since been done and we have had a No Deforestation policy in Cameroon since December 2018. This is monitored annually by an independent satellite imagery provider. Our land in Cameroon is now, and will remain, 65% unplanted. This includes 25,000 hectares that we are currently in the process of protecting as a community forest.
GW assertion: We further note, on the basis of interviews carried out with communities that there appears to be a widespread sense of disappointment in the communities of Bitye and Ndjikoum about a perceived failure of Sudcam to deliver schools and clinics which communities say they were promised.
Corrie Maccoll: It is important to note that Sudcam engaged the local NGO, APIFED, to perform a community engagement with all the surrounding 42 communities. Built off the back of the grievances collected in that engagement, Sudcam, together with APIFED, developed a Social Action Plan which is a 5-year investment into the communities.
The 42 communities are grouped into 9 ‘poles.’ These poles (or groups) are represented by a ‘Focal Point’ (or leader) who was voted by the communities. These Focal Points meet monthly with APIFED and the Sudcam sustainability team to discuss the actions completed and the actions planned for that month. Each action is scheduled only after it has been mutually agreed at these meetings.
The Social Action Plan provides support under the following 5 main headings:
The agreed actions under the Education and Health support pillars for the BITYE and NDJIKOUM communities are being implemented and are as follows:
GW assertion: Local people complained in particular about a lack of drinking water, saying that certain wells installed by Sudcam to replace water sources that have been swallowed up by the plantation are insufficient and, in some cases, have failed to function properly.
Corrie Maccoll: There are 42 borewells scheduled for construction over the 5-year Social Action Plan (1 for each community). 7 borewells were completed in 2021, 11 are scheduled for 2022 with 6 already complete and the remaining 5 will start in September. The BITYE community benefitted from their borewell being completed last year while NDJIKOUM’s borewell is scheduled for later this year.
The construction schedule for these borewells is discussed in each monthly Focal Point meeting, as well as the confirmation of those complete. Last year, a borewell was constructed for the BITYE BAKA community (separate to the BITYE community). Unfortunately, the initial borewell stopped working after 2 days. A new borewell was constructed soon after and has been in operation since. As of now, all the borewells constructed under the Social Action Plan are fully operational, and this is reiterated in the Focal Point meetings.
GW assertion: Local people believe there is a lack of a transparent ‘cahier de charges’ outlining what social infrastructures Sudcam has promised to build.
Corrie Maccoll: Transparency has been a priority from the start. The Social Action Plan was developed off the back of grievances collected during the community engagement. The Plan was jointly put together by APIFED, the local communities and Sudcam. Completed tasks and scheduled tasks are discussed each month at the monthly Focal Point meetings, where the Focal Point for each group of communities was voted in by the communities themselves. We would welcome any further ideas on how we could increase the level of transparency throughout this process.
Global Platform for Sustainable Natural Rubber
’As demand for natural rubber continues to increase year on year, deforestation caused by extensive production is bound to soar if it is not addressed. At the Global Platform for Sustainable Natural Rubber, different parts of the supply chain - manufacturers, end users, smallholders, processors and civil society - come together to establish standards of sustainability, equity and fairness for their industry.
Supply chain wide actions like ours are not a replacement for legislation. Yet, they remain crucial in establishing standardised processes that have been agreed upon by the entire industry. As part of this effort, GPSNR members (who represent over 50% of the worlds natural rubber demand) already have policies in place, which include commitments to healthy functioning ecosystems and producing and sourcing natural rubber in a way that does not contribute to deforestation or degrade High Conservation Values (HCVs). However, reports like this one are an indication that GPSNR members and stakeholders outside of the platform need to do more sooner than ever.
The GPSNR assurance model, though not complete yet, is in fact, designed to do more and go beyond the procurement policy commitments that members make. It will include an implementation guidance, a risk assessment system, a monitoring and evaluation system and a claims framework. We are also working on a traceability benchmark and transparency roadmap for the industry which includes disclosure of sourcing information.
Once this assurance model is complete, GPSNR will be able to have a risk-based verification approach through all these industry wide processes, along with scalable capacity building projects. The continuous monitoring of this model will give us better traceability data in high risk areas of the supply chain. It will also help us analyse what solutions work best in specific contexts. In environments where traceability systems are complex and difficult to implement, for instance, it may be better to first invest in on ground sustainability solutions and mitigation measures based on capacity building.
We hope and call on all stakeholders, both in and outside of our membership, to collaborate on accelerating this process before the damage to forests and biodiversity is beyond repair.’
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