Open letter to the RSPO following criticisms of ‘Who Watches the Watchmen? 2’ report

To: Darrel Webber
Chief Executive Officer
Roundtable on Sustainable Palm Oil (RSPO)

SIR, We welcome and appreciate the RSPO’s response to our report. We do not accept that there were any ‘glaring inaccuracies’ in it.

We have already recognised throughout the report the positive role of Assurance Services International (ASI) and that guidance, monitoring and training has been happening to an extent.

Similarly, our report recognised that the RSPO had introduced a new complaints process and the improved RSPO Principles and Criteria standard. Our concerns in the report are focused on the implementation of that standard, particularly the failings of the Assurance Task Force, and how the RSPO is robustly ensuring its standard is adhered to. Similar to other RSPO workgroups, the Assurance Task Force was hampered by inconsistent and unsatisfactory work and poor management by the RSPO Secretariat and the Task Force itself.

In line with our recommendations in the report we would encourage the RSPO to:

• determine what actions have and have not been completed by the Assurance Task Force through an independent review, given that at the last update 55 per cent of actions had not been completed, address its disorganised running and ensure the newly formed Assurance Standing Committee completes the outstanding actions, recommendations and objectives, learning from the shortcomings of the Assurance Task Force;
• publish documents on the case tracker relating to complaints cases, recognising that it would of course be inappropriate and insensitive to release documents where this would reveal complainants who have chosen to remain confidential or similar, but also recognising that the RSPO has not published documents on numerous complaint cases where documents have not been not confidential and where documents are already shared among stakeholders and/or made publicly available elsewhere;
• verify that the spatial data submitted by companies includes all its concessions, so that it can comprehensively monitor and verify hotspots proactively, HCV areas and land clearing in members’ concessions and identify where there are non-compliances, raising them to the IMU or the complaints system;
• improve its complaints system to ensure it takes timely action, discloses all relevant information from complainants and respondents, as well as investigations on complaints, and provides regular updates to complainants. The fact that the RSPO has passed a resolution to stop members divesting when there is an open complaint suggests it does perceive this to be an issue.

We note that while Grassroots agreed to develop SEIA guidance for the RSPO in late 2016, in the same way as other NGOs in the Task Force agreed to take on certain tasks to help the RSPO, it lacked the capacity to deliver this and in 2017 recommended Aidenvironment and cooperated with the organisation to complete this work.

While research organisations, such as the IUCN, have identified the RSPO’s P&C as one of the best standards and systems for palm oil, independent research on the impacts of the RSPO on the ground to date have been underwhelming, such as no significant difference being found between certified and non-certified plantations for any of the sustainability metrics investigated – again, as outlined in our report. This continues to raise concerns on how well the RSPO is implementing its standard and assurance processes. Any sustainability standard stands or falls on the credibility of the system it uses to verify its implementation. We would welcome continuous improvements from the RSPO.

EIA recognises, more than anyone, how information can be dangerous to complainants, whistleblowers and human rights defenders vulnerable to criminals operating in forests and within this sector. However, to use that as a reason not to release even basic information where sensitive reporting can be redacted shows the lack of understanding and will for the urgency to be as transparent as possible.

The RSPO cannot afford to miss opportunities to address the credibility of its system for certification and assessments further or it will be irrelevant.

If the Assurance Standing Committee indeed signals the RSPO Board’s serious intent to rectify the matter, it must support RSPO Resolution 6b and incorporate the second Watchmen report’s findings and recommendations into a structured and clear action plan with measurable results.

Yours sincerely

Siobhan Pearce
Forests Campaigner
Environmental Investigation Agency (EIA)