APP Response to WWF Open Letter - Asia Pulp and Paper

Aida GreenburyMD Sustainability & Stakeholder EngagementAsia Pulp and Paper Group (APP)Sinar Mas Land PlazaJl. MH Thamrin 51Jakarta - Indonesia9 June 2013Nazir FoeadConservation DirectorWWF-IndonesiaGraha Simatupang7th Floor, Tower 2-Unit CJakarta, 12540IndonesiaDear Mr Foead,Thank you for your letter dated May 31 st 2013. We understand your concerns and take them veryseriously and we hope that our Sustainability Roadmap Vision 2020 update, released on June 4 th ,goes some way towards answering your concerns.We launched our Forest Conservation Policy (FCP) just 12 weeks ago on February 5 th 2013, andalthough we have made solid progress, our systems are not yet perfect. Inevitably there will bechallenges when operating across such a huge land area, but to be clear, our commitment to stopnatural forest clearance on February 1st was absolute. APP is not excluding any natural forestareas from the moratorium we announced; there are no exceptions to the policy.If an oversight is made during the implementation of FCP, we will address and use it tostrengthen and improve our systems. In the particular case you raised in your letter, natural forestclearance was found to be taking place on one of our suppliers’ concessions in Riau, becausetwo years previously, the land was signed over to the local community through an MoU, tosupport livelihoods - an obligation of concession owners. The timber in this case will not besupplied to APP. I want to emphasize again that no natural forest timber cleared in breach of theFCP is allowed to enter our mills.In implementing the FCP this case should have been identified sooner as a potential risk.However, as soon as we received the report from Eyes on the Forest highlighting this issue, weimmediately communicated our plan for dealing with it in a meeting on May 16th attended by theNGO community, including WWF. It was agreed that we would form a verification team consistingof APP, The Forest Trust (TFT), WWF and partners and that an investigation would take placefrom 29th – 30th May. The findings of this are due to be published by TFT in the next few days.Our Risk Assessment Project Team is also hard at work identifying any further high risk issuesthat might affect the FCP implementation across our supply chain. It was this process that Idescribed during the meeting on the May 16th, not any list, or a map, of areas where naturalforests can still be cleared. The outcome of this work on risk identification, and our strategy fordealing with issues identified will be shared in the next Focus Group Discussion (FGD), which wehope WWF will attend. Any solution we develop for such issues will need to take account ofcomplicating factors such as community agreements, national regulations and resolving issuessuch as concession overlap.1

With this letter we would like to reiterate that:1. Our commitment to protect all natural forest in our operations is absolute. Natural forestwill be identified through High Conservation Value (HCV) and High Carbon Stock (HCS)assessments currently underway across all APP land concessions in Indonesia.2. As a result of NGO feedback, we have set a fixed deadline of August 31, 2013 for allnatural forest wood to have reached our pulp mills, and we have invited NGOs to monitorthis process.3. Our Risk Assessment Project Team is working to determine if there are any moreinstances (such as the case in our supplier’s concession you raised in the letter) in whichour FCP commitments might be at risk, and will share the results of this work as well asthe strategy to address the issues in the next FGD. In line with our FCP there will be nodevelopment in the areas at risk, until solutions that deal with any challenges areimplemented, in consultation with stakeholders.4. We are committed to HCV principles and will adhere to any recommendations that mightcome out of the assessments currently taking place according to the HCV ManagementPlan. These recommendations may include forest restoration.5. To ensure we are being completely transparent, we have launched a pilot version of ourFCP monitoring dashboard, which shows our progress in terms of natural forestmoratorium, HCV and HCS assessments, RFPPP assessments and social engagement.We have provided access to WWF.We are pleased to hear that WWF would like us to succeed with the implementation of our FCP.Before we embarked on this project we knew it would be very difficult. This is why we have beenreaching out to NGOs and have set up Independent Observer and verification programmes aswell as a Grievance Procedure that would provide a platform to flag issues to us as and whenthey arise. These initiatives have been successful to date.We would like to invite WWF to work positively with us as we continue to implement our FCP, andto strengthen our protocols and guidelines. We would value the conservation experience thatWWF can bring to this process. Working together will take us a step closer to realizing ourcommon goal of overcoming the complex issues involved in protecting rainforests, whilerespecting the rights of the communities that live in them and ensuring the sustainability of ourbusiness as a whole.Sincerely,Aida GreenburyFCP Senior Issue TeamMD Sustainability & Stakeholder EngagementAsia Pulp and Paper Group (APP)Sinar Mas Land PlazaJl. MH Thamrin 51Jakarta – IndonesiaCC:- Linda WijayaAPP Shareholder- APP Stakeholders through FCP Grievance Procedure2