RSPO Grievance - SAVE Wildlife Conservation Fund

RSPO GrievanceSG Sustainable Oils CameroonOil Palm ProjectResponses to the responses by RSPO onthe 26. April 2012SAVE Wildlife Conservation Fund, 11.05.2012

Summary:Generally: ............................................................................................................................................ 2Response to Herakles bold comments: ............................................................................................. 4SGSOC Response 1.......................................................................................................................................... 4SGSOC Response 2.......................................................................................................................................... 4SGSOC Response 3.......................................................................................................................................... 4SGSOC Response 4: ........................................................................................................................................ 6SGSOC Response 5: ........................................................................................................................................ 6SGSOC Response 6: ........................................................................................................................................ 7SGSOC Response 7: ........................................................................................................................................ 7SGSOC Response 8.......................................................................................................................................... 8SGSOC Response 9: ........................................................................................................................................ 9SGSOC Response 10 ...................................................................................................................................... 11Attachments ........................................................................................................................................ 12

Generally:In their introduction they speak now of overwhelming support, but they said that since thebeginning of the project. How come that they now acknowledge that there was a opposition?As for their highlighted items: SGSOC’s concession area does not include: (a) any protected areas; (b) areaspreviously protected or (c) areas that were scheduled or planned to be protected by theGovernment of Cameroon (GoC) under any short-- or long--term plans.First is to mention that monocultural projects of this scale almost certainly exert a very harshpressure on all areas nearby. Recent scientific studies found out that neighboringagroindustrial projects put a lot of stress and pressure on protected areas nearby. A project thisbig with a size of about 100 000 football fields in the middle of 4 protected areas whichbelong to one of the oldest remaining rainforests of Africa will certainly be not good for thebiodiversity, not to mention the fragmentation and isolation of these PA's through cut-downsof the connecting forests.Especially point (c) is wrong as nearly the whole eastern part of the concession overlaps withthe planned Forest-Management Unit 11-007 and 11-008 as shown in the map (Attachment 1).The Image shows a forest management unit, which is part of the permanent forest domainaccording to Cameroon law. The concession has definitely an impact on the realization of thisplanned protected area. The Project area is with on the land suggested by WWF in the Korup Master Plan assuitable for agricultural development The “Agricultural development"in the Korup Master Plan does not mean that agroindustrialshould extend in this area. It concerns small holder community development"agricultural, agro-forestry, livestock and fishing development"with improvement ofrural roads, water and health schemes and including also out grower schemes fromPAMOL.More recently WWF Cameroon published new reports 1 warning that projects such as SGSOCare damaging Cameroons wildlife and forests. Commercial logging by contract with the Government of Cameroon has been extensiveundertaken throughout the SGSOC Concession and is currently on goingMost if not all previous loggings were done selectively by cutting only good trees and leavingmany others behind. The forest can constantly recover if the logging is managed in asustainable way. Animals and Plants can use these trees, local NFTP such as bushmango ormedicine can grow in these forests as well. Large Parts in the western parts of the Ndiandivision have never been commercial logged and are still primary undisturbed forests. Thiscan be seen in the company’s ESIA (Attachment 2) and also through an analysis of the intactforests in the region (Attachment 3). Intact forests are forests, which show no sign ofsignificant human activity and are large enough that all native biodiversity can bemaintained 2 . We used GIS Data provided by the Intact forest landscapes Mapping Team 3 .1http://www.pfbc-cbfp.org/doc_rech_en.html2 http://www.intactforests.org/concept.html

Here we found out, that the concession overlaps with 14,776.28 ha intact forest in the westand 2748.1 ha in the eastern part of the concession (Attachment 3). All major protected areasin the region are themselves mostly intact forests. Even the protected areas in the vicinity have little provision for scientific management,protection, and monitoring – primarily due to lack of funds. The Korup National Park(KNP) has an annual budget of $20,000 per year for protection and maintenance ofthe 128,000 hectares. This is the only protected area, which even maintains aManagement Plan. According to the April 2008 Management Plan of Korup NationalPark and its Peripheral Zone (2003--2013) 1st draft, Co--Funded by KfW and WWF--CFP below is a listing of equipment for the entire park (section3.6.3.3).First it is true that KNP certainly has a lack of funds. But nevertheless the Republic ofCameroon and especially its responsible ministerial divisions see the necessity to act and toprotect Cameroons Wildlife better in the future. In Mbanyang-Mbo for example theyacknowledge this area as a zone where the rare Nigerian chimpanzee has to beprotected 4 .Second, KNP is not the only protected area in the area. There is Rumpi Hills(Forest Reserve), Bakossi (National Park), Mbanyang-Mbo (Wildlife Sanctuary) and Nta Ali(Forest Reserve). Some of these protected areas were just recently established and willcertainly favor the name development of the region, because of its high density of rainforestscovered protected areas. Herakles and his NGO All-For-Africa came to this place to supportresponsible and sustainable development and this is what they promised the people living nearthe protected area. This Palmoil-Plantation will certainly even worsen the situation for KorupNational Park and others due to (1) genetic isolation, (2) massive increased bushmeat-huntingthrough worker migration, (3) will destroy nearly 60,000 ha of forest covered land and (4)hinder other sustainable agricultural projects in the future. Herakles never presented a legalbinding Management plan how they want to deal with this problem. In absence of SGSOC, the swidden farming, plantation of commercial crops, artisanaland commercial lumbering, and hunting will continue and will most likely increase asthere are very few options for alternative means of sustenance and monetary income,thus having likely adverse effects on biodiversity; with time encroachment within theprotected areas is also possibleIn presence of SGSOC there will be no place for any other alternatives. The people in thisregion depend on traditional medicine and food from the forest. This is how they lived overcenturies and SGSOC won't change their diet so suddenly. Many people from these villageslink the forests in the concession not only with their cultural and religious identity, but alsowith their traditional lifestyle. With the establishment of the plantation additional workershave to come to both division to fill all low plantation worker jobs and this will most certainlyintensify the bushmeat-impact on all adjacent protected areas in the region. With the largeforest between the villages gone, the people will have no choice than to hunt in the protectedareas. Up to date we have seen no detailed legal binding bushmeat management plan ofSGSOC and we fear that once the plantation is established and the oil palms are growing themanagement-plan will involve to toothless obligations and regularities.3 Potapov P., et al. 2008. Mapping the World's Intact Forest Landscapes by Remote Sensing. Ecology andSociety, 13 (2)http://www.pfbc-cbfp.org/doc_rech_en.html4 http://www.ellioti.org/ActionPlan/English/elliotiAP-mediumres.pdf

Response to Herakles bold comments:SGSOC Response 1This was not an actual claim, but rather a summary of the company names who claimed tobe a sustainable Palm oil Producer since the start of the project. While only SGSOC wasan actual member of the RSPO in early 2011, Herakles claimed to be a member too at thistime. SGSOC, who is also active in Ghana, was the only active participant in the RSPOduring the establishment of the nurseries and the logging of the first forests without prioradequate impact research. The company Herakles labeled themselves as sustainableaccording to RSPO during donor weeks and fund-raising events 5 , which was during thattime simply public misleading.SGSOC Response 2Herakles didn't explain why they want to establish a palm oil plantation of this scale in anarea known worldwide as a biodiversity hotspot 6 . Cameroon has a lot of truly degradedareas with little to no forest cover where oil palms could be planted. If the company reallycares about sustainable production and social and ecological behavior, they should putresponsibility over profit.SGSOC Response 3Herakles/SGSOC didn't answer (1) why they presented an unfinished and/or inadequateESIA to the people who attended the hearings and (2) why they didn't distributed allsupporting documents between the villages. When the first caterpillars arrived in Fabenobody knew that their village is in the palmoil concession. This is totally intransparentand Herakles claimed during that time that they want to build a plantation in accordanceto RSPO principles, which demand transparent and open participation of all stakeholders.Up to date we and most likely all villagers who oppose this project haven't seen anyevidence for open and transparent meeting. All evidences of informal meetings orconsultations Herakles presented 7 so far showed only that they invited singlerepresentatives to far locations.We have received numerous reports of villagers 8 and befriended NGO's 9 active in theregion that SGSOC was constantly absent from all major meetings of culturalOrganizations and meetings of villages chiefs. Rather they invited more wealthy divisionofficers and higher persons to hotels in Mundemba for private discussions. Most decisionsand consultations were not hold in open transparent process.For an example of SGSOC absence on public meetings: With the support of Rettet denRegenwald e.V., SAVE and WWF Cameroon a meeting of the BIMA Cultural Union for5 Fundraising week 2010 - http://www.allforafrica.org/wpcontent/uploads/POP_WEEK_SPONSORSHIP_OPPORTUNITIES.pdf6 http://www.conservation.org/where/priority_areas/hotspots/africa/Guinean-Forests-of-West-Africa/Pages/default.aspx7 http://heraklesfarms.com/docs/Cameroon/ESIA/Final%20SGSOC%20ESIA%20Combined%20Annexes.pdf8 Notice of the Village Chief of Toko to SAVE, Notice of Fabe inhabitants to SAVE9 Notice from Nasako Besingi, Managing Director of the local NGO SEFE to SAVE. SEFE was founded inJanuary 1996, was recognised by the state of Cameroon on the 26th of July 1996 and is since then active inthe region to support sustainable livelyhood in Ndian and protect develop the Rumpi Hills WatershedCommunity Conservation Iniative.

Development was organized in 4th August 2011 to inform all BIMA tribes about theplantation. According to the former BIMA-Chairman Moli Ibeku 10 over 314 peopleattended this meeting and all Ndian tribes, journalists, national and international NGOswere present. However despite being invited SGSOC or any other official representativefrom the company was totally absent to this meeting. See the Attachment“SAVE_Meeting-Report.pdf” and “SAVE_Meeting-Report-Attachment.pdf” for detailsabout the meeting.Furthermore: The SAVE Wildlife Conservation Fund never participated in any officialmeeting between villagers and SGSOC. This is a false claim!We have the minuted interviews from the public consultations for the ESIA at hand 11 . TheNGO consultations were held very far away in the Charlot Hotel in Buea in 27th ofSeptember 2010. A travel to such a far destination could only be afforded by very fewindividuals and therefore not many people(35) attended these meetings. The publicconsultations in Nguti 12 were disrupted by many people and chiefs who feel deceived.These participants raised attention that “During the months of October and November weare used to harvesting and eating fish. River Bakube has plenty of fish and if SGSOCinvades this area, it will dry the river and there will be no more fish.” (page 117) andasked questions like “I have farms of palm oil and cacao, what will SGSOC do about myfarmland?”(page 117). These and many more problems were not addressed or answered;instead the meeting was obviously closed by the discussion holder.The “socio-economic” study mentioned was conducted by the local NGO NatureCameroon (page 114). Nature Cameroon representative moan that the draft of the reportwas never send to any village and that SGSOC threats the draft-paper as full and completeversion. This shows that this “study” was far from being a consent study and far frombeing transparent and open to everybody. As for the ESIA's Surveys: In the official ESIAby H&B Consulting 13 it was noticed (page 4-121) that for their surveys they (1) traveledwith armed guards which obviously were meant to influence oppositional forces in thevillages, (2) several village chiefs didn't want to talk to the visitors and were somehowagainst the project, others weren't even invited or took notice that SGSOC was visiting inthese few hours, (3) that the surveys were hindered by logistical and time constraints(visited each village only few hours). Based on these surveys it is very hard to say thatevery local resident and all responsible decision makers were adequately informed.The Memorandi of Understanding (MoU) were signed with very few individuals and notall villages. Malle Adolf, a barrister active against this plantation from the very start waspresent in most of the earlier meetings. He reported 14 that these MoU 15 were not the result10 Report by Moli Ibeku of the enlarged Stake-Holder Meeting on the Implantation of large-scale Oil PalmPlantations in Mundemba and Toko sub divisions held on Thursday, 4th August 2011 at the MundembaCouncil Chambers11 Minuted Interviews from the public Consultations of SGSOCs ESIA –http://heraklesfarms.com/docs/Cameroon/ESIA/Final%20SGSOC%20ESIA%20Combined%20Annexes.pdfpage 109-11112 Minuted Interviews from the public Consultations of SGSOCs ESIA –http://heraklesfarms.com/docs/Cameroon/ESIA/Final%20SGSOC%20ESIA%20Combined%20Annexes.pdfpage 112-11713 http://heraklesfarms.com/docs/SGSOC-ESIA.pdf14 Report by Malle Adolf as a response to a Herakles article. Downloadable here: http://www.savewildlife.com/downloads/save_the_forest/Letter_Malle_Adolf.pdf15 http://cameroonveritas.wordpress.com/2011/12/20/sgsoc-memorandum-of-understanding/

of a comprehensive and open discussion with local people, but rather consist of signaturesof few handpicked individuals who don't speak for anybody. Furthermore no official ofSGSOC signed the documents which are required by Cameroon law.Whenever Herakles representatives were confronted 16 about the actual state of the ESIA'sthey appeased and told us that the ESIA will be finished soon and that they value anycomments and suggestions for improvement. Rather than telling us when the ESIA andHCV-Assessments are released they quietly submitted a short summarized version to theRSPO 17 and obviously hoped that the deadline for comments fades away before anybodynotice.The subsequent studies, such as RSPO should know, were only publishes as summary.The publication has been requested several times by us. We have got always theinformation, that we will be informed about the publication. On the 28th February 2012we get the information that Herakles wanted to check the status of the publication. Inreality the publication has long been published by Herakles and they hoped that SAVE isseen it after the deadline on the RSPO 15th March 2012. Then SAVE is having nopossibility to give an opinion. Herakles has consciously tried to betray and deceive gobehind the participants (Attatchment Herakles email).SGSOC Response 4:(1) The presented ESIA 18 is totally insufficient for a palm oil concession in thisproblematic location as only 0.003% of the area was surveyed for the ESIA. This wasconfirmed by many renowned scientists from Cameroon and abroad 19 20 . While it isnoteworthy that Herakles finally released all documents, this was definitely not the casewhen the first loggings were conducted. Additionally it was many times noted that theESIAs and the HCV assessments are very poor done. Whenever SAVE confrontedSGSOC with these allegations they just answered that additional studies will be conductedin the future 21 . But during this time more and more forest is cleared in the process ofplanting palm oil.SGSOC Response 5:Cameroon law → 100 ha before ESIAThe Court Cases haven't been dismissed; rather they also mentioned that SGSOC shouldstop the project as long as all documents aren't ready. We have information that the projectis still going as usual. (Attachment Malle Adolf )16 Personal Communication with SAVE17 http://www.rspo.org/sites/default/files/SGSOC-%20Summary%20Report%20of%20Planning%20%20Management%20SG%20Sustainable%20Oils%20Cameroon.pdf18 http://heraklesfarms.com/docs/SGSOC-ESIA.pdf19 Combined letter by concerned scientists: http://www.savewildlife.com/downloads/save_the_forest/scientists_letter_herakles_farms.pdf20 Letter from Thomas Struthsaker to SGSOC: http://www.savewildlife.com/downloads/save_the_forest/Response_to_SG_Sustainable_Oil.pdf21 Personal communication between Herakles and SAVE

SGSOC Response 6:The “Agricultural development" in the Korup Master Plan does not mean that agro-industrialshould extend in this area. It concerns small holder community development "agricultural,agro-forestry, livestock and fishing development" with improvement of rural roads, water andhealth schemes and including also out grower schemes from PAMOL.For further information for wildlife and primary and secondary forest (response 9)It is not corecct that the Korup National park has only an annual budget of USD 20000 peryear. The Park has a conservator and eco-guards and benefits from operational funds from thegovernment of 40000 USD/year. This program is supporting on side park management, parkprotection conservation education and on the other side the involvement of the localsurrounding population in the park management benefitting from the elaboration of villagedevelopment plans and financing of prioritized income generating activities and socioeconomicinfrastructure. According to our information between 2006 and 2011 approx.890000 € are spent. for park management and approx. 360000 € village development.(Source: KFW Cameroon)Furthermore HF wrote them that animals claim corridors between the protected Areas.Where are these corridors? At this time no corridors are planned or include in a map.Again, HF proves once again his false intentions. It is assumed, that HF doesn’t want toconsider any corridors and thus irrevocably convert four conservation areas in singleareas. This has strong negative consequences for the already highly pressurizedEndangered Species. More precisely – HF provides for an accelerated extinction ofspecies. Sufficient alternatives for the protection and really sustainable developmentalready exist.A monoculture farm has nothing to do in this most sensitive system. It is completely outof place. By realization of this planned palm oil project the Cameroonian Governmentwill risk, that Cameroon will lose the right to use the intact forest to get REDD+ Carboncompensation certificates. Which means, for the whole areas, no Carbon rights can besold into a global market and cannot generate any income from this side. Actually or innear future carbon rights are estimated to be sold up to 1.200-1.500USD/hectare.HF has not yet prepared any management plan or fund for conservation. HF only makemere pretenses. To ensure a monoculture farm in the middle of the Protected Areaprotection of Protected Areas is absolutely absurd excrescent and show the completelymissing knowledge for conservation of nature by HF. The opposite will happen. Theadditional employment and thus in the region migrate people will highly pressure thewild animals by a multiple. 80% of Poachers usually are farm employees.The world's leading scientists have made a statement. In this statement they haveaccented the facts and our doubt.This potential is a reasonable alternative to the deforestation of such intact forest areas.(Attachment open letter scientists)SGSOC Response 7:There is no evidence that Herakles truly consulted the opinion of every village before theybegan to establish this plantation. Many people from different villages opposed this

project and even confronted caterpillars intending to destroy their village forests. SG-SOCis constantly ignoring this opposition to the degree that they say that in the past up to nowall people favored this plantation.Neither Herakles nor any Herakles subsidiary firm has ever commented on the severalcomplains letter sent to the Cameroon government by concerned villagers.Neither has Herakles responded to any protest letters send by SAVE and other NGOs.The socio-economic study is highly insufficient (See Response to 3).There are several issues regarding the MoU 22 :1. The MoU purportedly made for Mundemba and Toko sub-divisions was not signedby any official of SGSOC and as such it cannot be binding.2. The MOU concerning Nguti subdivision is also not signed by an official of SG.SOC. The signature you find on it in the place reserved for SGSOC is that of theirCounsel Barrister Etah Akoh, and in the absence of a duty executed and registeredpower of attorney; he is not in a position to bind the company. By law only theManaging Director or maybe the CEO who can sign such a document.3. Besides, these MOU'S have been seriously challenged both by the Communities inNdian Division and Nguti who are affected by the project. The MOU'S were notthe product of a general consensus of the people. This document was prepared wellin advance and specific persons chosen to sign it, and many did not even knowwhat they were signing. The individuals who signed the MoU did so forthemselves and not on behalf of the members of the communities.4. An analysis of the communities who signed (See Attachment 4) showed, that only23 (of 57) villages or doubtful representatives of these villages in the nearer rangeof the plantation (up to 1km) signed these MoUs. Many signs were from peoplewho live on the outskirts of the plantation concession and who aren't as muchaffected as the people on the inside. The rest of the villages in the concession hasto our knowledge never signed any official binding contracts with Herakles.(There are 77 villages within a certain range around the SGSOC concession.Totally 31 (40%) of them have not signed the MoUs, but inside the concession59% of Villages have not signed the MoU. Consequently totally 36 villages (60%)have signed a MuO, but only 41% of the villages inside the concession.(attachment 4 )SGSOC Response 8Legal oppinion.Even if the company acted according to the Cameroon law, they didn't act to the P&C ofthe RSPO, which demands a High Conservation Value Assessment to be conducted beforeany logging is realized. Additionally they never acknowledged any rulings of regularCameroonian judges and courts and worked all the time even while the injunction was inplace.22 http://cameroonveritas.wordpress.com/2011/12/20/sgsoc-memorandum-of-understanding/

SGSOC Response 9:First of all, it is not clear, why the SGSOC has supervised their independent RSPOcertifiedassessor to work accurate. It is implausible, that assessors would act in theinterest of the company, if they would list rare and endangered species and a greatproportion of the SGSOC concession would declare to HVC. Why should the SGSOChave interest in this?A few critics of the poor HVC-assessment by Herakles farms:1. Proportion of the primary forest in the SGSOC ConcessionThe Assessment commissioned by SGOC could show the existence of primaryforests and HCV in this area. This is also noted by the high quantity of bird species,which are often representatives of an accompanying forest fauna (Guineo-Congolian-forest-biome). 30% of the sampling points are dominated by thosespecies. In this context nearly the same proportion of primary forest is expected,because the distribution of such species is dependent on a stable primary foresthabitat. In the same magnitude a lot of Experts estimate the proportion of primaryforest for the SGSOC Concession. Compared with the proportion of the by theassessors committed HVC area, it seems to exist a discrepancy.Almost whole Mundemba area is unlogged and has to get a HCV. AnywaySGSOC is planning that nearly all HCV-areas would be founded only oninaccessible areas, which are unusable for agriculture. On page 30 in the SGOCassessment the SGSOC is showing their true intention “steep ridges (e.g. 25 degreeor higher) that are anyway difficult to plant should be left intact as biodiversityplots in the entire concession.”2. Conditions for a HCV-statusFurthermore, it is incorrect to say, that a secondary forest is useless for a richbiodiversity. Also a stable secondary forest population can have a HighConservation Forest by the own RSPO-specifications. This assessment tries to givethe impression, that secondary forest would not be an intact forest. A largeproportion of the Korup-National-Park is secondary forest and has a HCV.In the other hand the report shows it clearly, that the primary forest or theproportion which the assessors have declared as primary forest, in the plantationwould only exist in a few fragmented areas (and on steep ridges; see above point1). Studies in other rainforest locations (Amazonia) have shown that small isolatedprimary forests fragments can lose their biodiversity in a few decades.The areas of the concession on which the communities depend for livelihood needstherefore constitute HCV forest under criterion 5.3. Expectation to find gorillas in the SGSOC ConcessionIt does not become clear, why in this report (two paragraphs!) the lack of gorillasis determined at this location. It was never expected to find them there, the naturaldistribution area of gorillas remains to be in south of this SGSOC concession(except a small population further in the north).

In the other hand, the report is reticent in case of elephants and chimps, whichmost likely exist there (human-elephant conflict management plan for thislocation). In the case of Drill, an endangered species, the SGSOC pretends thatthey would establish corridors. But it seems to be only a non-verified promise -there are no records about.4. Non-resident species listed in the assessmentA few animals are listed, which are proven non-resident in this part of Cameroon(for example the dwarf antelope Neotragus batessi and the moustached guenonCeropithecus cephus). Both are found only in the south of the Kanaga-river. In onecase a non-resident species (again the moustached guenon) looks very similar to aresident species (Red-eared guenon Cercopithecus erythrotis), but they aredifferent on their conservation status. While the non-resident species is leastconcern, the resident species is vulnerable. It seems to be, that this report containsknowingly deceptions. Perhaps additional species with a threatened IUCN statuswould question the whole plantation-project.5. Methode of assessment for the herpetofaunaThe assessment of the herpetofauna in the SGSOC concession is another examplefor poorly executed work. According to the report the assessment was carried outonly during the day. Most species in this group of vertebrates are only nocturnal.Plausible results would make it necessary to undertake expeditions at night.Because nevertheless one endangered species was found, it can expected to findmore in the night, what likely means to deport more HCV. Similarly theassessment of ichthyofauna in the streams can be seen critically. It does notbecome clear, why the samplings was taken only in the near of settlements, withrespective disturbances.6. Critics on the method of survey generallyA study of only 18 days is not enough to find the species which is expected for thisarea. So it is no surprise, that only a few rarely animals or/and large mammalswere listed. A regular study will take at least 12 months in such an area.Furthermore, the concept of the survey would not work for large animals. Toomuch people were involved during the surveys, the large mammal expert isfollowing at the end!Another critic is that surveys only at day especially for the herpetofauna (point 6)Almost all transects they have done in the near of roads an settlement (in a 700km² area with a population of about 10 Inhabitants/km²). So they did not see aanimals, that we could expected there.What is about the use of a genetic heat index? Conservation aims to protectingviable populations.It seems to be, that these experts of the assessment are lacking in knowledge offlora and fauna in Cameroon in general or for the region of the SGSOC concessionin special. Why have they conducted not really experts who went in the field?

Another example for their lack knowledge In page 19 of the Flora/Fauna report,they list the large mammal species that they encountered in the field, and then– among other info – the mode of identification (Table 6). The forest buffaloand the bushbuck are listed as having been confirmed present via interviews.Fair enough – we all value local knowledge. How is it possible then that theyreport encounter rates in Page 22/Table 7 for both species? Based oninterviews?7. OthersThey claim that the plantation itself is actually going to benefit wildlife in the area,because all the people will be too busy working for them that they will not havetime to hunt. We very well know that palm oil workers from PAMOL plantationnear Korup frequently cross into the park and hunt...they have been arrested doingso. So, employment for the plantation is no guarantee that they will not have timeto hunt.SGSOC Response 10We hereby revoke all claims and allegations of the Company Herakles Farms that theirproject in Cameroon is sustainable and responsible towards nature and people according tothe RSPO Principles and Criteria.

Attachments

Attachment1:The Image show how the concession overlaps the planned FMU 11-007 and 11-008. The shape ofthe concession is based on the officially released ESIA and the Protected Area data is provided byMINFOF/SDIAF/SC, 2012 and can be downloaded here (http://data.camerounforet.com/download-gis-data)

Attachment 2:Blurry map taken from the officially released ESIA(http://heraklesfarms.com/docs/SGSOCESIA.pdf page 4-110). The blue area waspossibly selectively logged in the past. The large part in the Ndian division hasnever.been logged before fore.

Attachment 3Green area is intact forest according to Potapov et al. (2008) 23 . The lined area is the SG-SOC concession. Green lines mark the borderlines of these protected areas. Theplantation overlaps with 14776.28 ha Intact forest in the west and 2748.1 ha in theeastern part of the concession.23 Potapov P., Yaroshenko A., Turubanova S., Dubinin M., Laestadius L., Thies C., Aksenov D., Egorov A.,Yesipova Y., Glushkov I., Karpachevskiy M., Kostikova A., Manisha A., Tsybikova E., Zhuravleva I. 2008.Mapping the World's Intact Forest Landscapes by Remote Sensing. Ecology and Society, 13 (2)

Attachment 4The picture shows the villages who signed a MoU with Herakles. Blue dots are villageswithin the plantation or a buffer of 1km. Each red dot marks a villages from whichrepresentatives have signed a MoU with the company. Many villages have according toour information never signed any official documents with Herakles or SGSOC.

-----Ursprüngliche Nachricht-----Von: Lars Gorschlueter [mailto:l.gorschlueter@save-wildlife.com]Gesendet: Freitag, 2. März 2012 11:30An: 'Delilah Rothenberg'Betreff: AW: AW: Follow-up from last week's meetingDear Delilah,thank you for your comments. For sure, we are interested in a trustful and honest and open dialog.You are welcome to let us know or suggest, where we should do changes. It will be difficult just from spoken words to do so, but we willseriously consider about it, it will help us a lot to get it in written official words. Of course, if there are wrong contents, we willchange it.We will send you soon our suggestion for this.Regarding your points:- not releasing the ESIA - change that too "releasing an inadequate ESIA that several independent scientists and organizations criticizedfor being poorly conducted and presented. The ESIA was released AFTER the destruction of forests and creation of oil palm nurseries andAFTER several scientists and organizations voiced their discontent and disappointment to the Govt. of Cameroon."- Fabe being against us - We have people which stand by the protest letter written by people from Fabe and other villages and culturalorganizations. They are still denying the opposition exists.- Profit of the wood- Would be great if you can confirm that by official written letter- we will change then- Blackstone relationship - the relationships is that Blackstone was involved in the initial investment/development since it wasinitially a Sithe Global deal- wasn’t it?Another point in the enclosed letter- This is not a way of true relationship, if you tell me, that you will check the status of thereports, when you released them 2 weeks ago on RSPO already without any former promised notice. http://www.rspo.org/content/herakles-farms-cooperatief-ua-sg-sustainable-oils-cameroon-ltd-new-planting-assessment-call-Please let me know, why you don’t release to public information the fully studies, which I got from Herakles beginning of February?Our information from Cameroon is the opposite to what you wrote me- Can you forward me the document which shows you, that the casedismissed?I still believe there is a way for a cooperate relationship and we are ready to move on for this.I m looking forward to your feedback.With best regards/Mit besten GrüssenLars Gorschlüter(founder & board member)-----Ursprüngliche Nachricht-----Von: Delilah Rothenberg [mailto:rothenberg@heraklescapital.com]Gesendet: Dienstag, 28. Februar 2012 00:16An: Lars GorschlueterBetreff: Re: AW: Follow-up from last week's meetingDear Lars,Thank you for your message. I hope all is well with you, too. I am checking on the status of the reports and will let you know.Also, we had been checking back to the SAVE Wildlife website after our meeting in hopes that the clarifications we provided would bereflected there. We see that the site still makes claims about us moving people from their land (and on the petition site, about notconsulting them), not releasing the ESIA, having degrading working conditions, profiting from the wood, and also Fabe being against us.The site also seems to imply we would be planting in Korup National Park, and there are other ambiguities, as well (e.g. Blackstone, Allfor Africa relationships).It was our understanding from our meeting that you and Mark had developed a true understanding of the SGSOC project and the dedication wehave to the environment and to the communities. We are making our very best and most sincere efforts to be a sustainable company, and itis difficult to have such misinformation out there. Will you be changing the sites to reflect our conversations? Also, the SEFE caseagainst SGSOC was dismissed today in Mundemba.Many thanks.Kind regards,DelilahOn Wed, Feb 22, 2012 at 1:04 PM, Lars Gorschlueter wrote:> Dear Delilah,>>>> I hope you are well over there. Can you please let me know, when we> can expect, that the Studies get public?>>> Thank you in advance and have a good day.>>> With best regards/Mit besten Grüssen>> Lars Gorschlüter> (founder & board member)>> Von: Delilah Rothenberg [mailto:rothenberg@heraklescapital.com]> Gesendet: Donnerstag, 9. Februar 2012 23:38> An: Lars Gorschlüter> Betreff: Re: AW: Follow-up from last week's meeting>>> Dear Lars,>> Thanks very much. We expect to publish them soon, as they are part of> our RSPO new planting procedures. We will certainly keep you posted> on their release.>> Kind regards,> Delilah>>> 2012/2/9 Lars Gorschlüter >> Dear Delilah,>>> I already asked him tonight and he confirmed so.>>> May I ask you, when are you planing to publish the studies?>> Regards/ liebe Grüsse> Lars Gorschlüter

30 April 2012RESPONSE TO SGSOC RESPONSE TO OPEN LETTER FROM SCIENTISTSThe responses from SG Sustainable Oils Cameroon (SGSOC) to comments from 10 leadingenvironmental scientists that were sent to the RSPO on March 14, 2012 do not alleviate our concernsabout the negative ecological impacts of the Herakles Farms/SGSOC/All for Africa proposed oil palmplantation in southwestern Cameroon. Our claims that the proponents of this development haveviolated RSPO guidelines, misrepresented the condition of the forest in the affected area,misinformed the public, and downplayed the magnitude of local opposition have not beenadequately addressed in the SGSOC response.The site of the proposed plantation is located in an area of exceptional biological richness andendemism for vascular plants, insects, birds, amphibians, and mammals 1 . As such, the samplingprocedures they used to evaluate the condition of the vegetation and the presence of threatened andendemic species are completely inadequate, especially given that the ramifications of declaring theforest as “degraded” is total conversion of the forest to a monoculture. Only a long-term, careful, andsystematic study of the habitat (including its structure and floristic composition) and its animalpopulations is acceptable. Furthermore, their sample size was too small to extrapolate their survey resultsto the entire proposed plantation area. As most of the proponent’s vegetation surveys were conducted onor near roads and vast areas were never surveyed (e.g., the eastern portion of the Mundemba-Toko sectionand the western and northeastern sections of the Kupe-Muanenguba section), it is simply inexcusable forthe proponents to declare their proposed plantation area has highly degraded. Although portions of theKupe-Muanenguba section have been logged, logging licenses in Cameroon typically permit only lightto-moderateselective logging (2-5 trees per hectare) thus reducing the ecological impact of timberexploitation.There is clearly a discrepancy between the proponent’s characterization of the condition of theforest in the proposed plantation area and that of our own analysis and of the Programme for SustainableManagement of Natural Resources in the South West Region of Cameroon (PSMNR-SWR), adevelopment program of Cameroon in partnership with the German Development Bank (KfW) and GIZ 2 .Based on analysis of the MODIS Vegetation Continuous Fields collection for forest cover 3 , the proposedplantation area is covered on average by 72±11% tree cover, which is the same as the mean percent coverin the unlogged, primary forest in Korup National Park (72±10%). The PSMNR analysis of land coversuggests that 60% of the Ndian sections of the proposed plantation are characterized by >70% tree cover.This alone should convince the RSPO that the proponent’s conclusions about the condition of the forest intheir proposed plantation area may not be accurate and that a detailed, large-scale independent analysisof the vegetation is necessary before the proponents clear any more forest.According to their ESIA, the project’s proponents surveyed the forest for animals for 10 days,between June and July 2010 4 . Their Consolidated Field Study Report: Wildlife Survey 5 indicates thatfaunal surveys were conducted within the proposed plantation area July 11-28, 2011. Another SGSOCdocument 6 suggests that the project’s proponents conducted a faunal study and “site visits” in September2010, June 2011, July 2011, and August 2011. In their response to our RSPO comments, SGSOC note1 Oates, J.F., Bergl, R.A., Linder, J.M. 2004. Africa’s Gulf of Guinea Forests: Biodiversity Patterns andConservation Priorities. Conservation International Center for Applied Biodiversity Science.2 Letter from the PSMNR-SWR co-coordinator to SG Sustainable Oils, 27 September 2010.3 http://glcf.umiacs.umd.edu/data/vcf/4 SG Sustainable Oils Environmental Social Impact Assessment. Submitted by H&B Consulting, August 2011.5 Ndzefemmegho, P.K., Chuyong, G.B., Wanzie, C.S., Forzi, F.A., Gonwouo, L.N., Ekechea, A.E. 2011.Consolidated Field Study Report: Wildlife Survey. Report submitted to SG Sustainable Oils Cameroon. December.6 Asamoah, A. 2011. Assessment of High Conservation Value on the SGSOC Concession for Oil Palm Developmentin South-Western Cameroon. Report submitted to SG Sustainable Oils. December.

that they spent approximately 4 weeks surveying animals in their proposed concession. While theirdescriptions of the time actually conducting forest surveys are vague, it is clear that they only surveyedduring the rainy season. Extrapolating results from 4 weeks of forest surveys during the rainy season ofrelatively rare species (e.g., elephants and primates) that are wary of human presence is professionallyunacceptable.In an area of such ecological importance, the costs of failing to properly characterize the forestare too great to rely on poorly conducted and potentially biased rapid assessments. Therefore,SGSOC failed to refute our claim that they used inadequate sampling techniques.Despite constant insistence from Herakles Farms and SGSOC that their concession area does notinclude, “areas that were scheduled or planned to be protected by the Government of Cameroon (GoC)under any short-- or long--term plans”, according to our maps (see Attachment 1), the Kupe-Muanenguba section of the proposed plantation overlaps extensively with Forest Management Unit(FMU) 11007, which was planned in December 2008 7 . According to Cameroon law (Forest Code 94/01of January 20, 1994) 8 , permanent forests include not only national parks, forest and wildlife reserves andsanctuaries, and buffer zones, but also council forests and production forests (such as FMUs). Thepermanent forest domain according to Cameroon law is zoned for biodiversity conservation andsustainable management of natural resources. The development of an oil palm monoculture in this areadirectly conflicts with the goal of “permanent forest”, which is to sustainably manage the forest, not tocompletely remove it.To our knowledge, the only study that has attempted to systematically quantify local knowledgeand perceptions of the proponent’s plantation indicates that only 52% of the population favors thedevelopment 9 . This is in stark contrast to the claims made by Herakles Farms and SGSOC that the vastmajority of the local population supports their proposed plantation. We do not doubt that there is localsupport, as this project may help to generate jobs in an area lacking employment opportunities. Wesimply wish to inform the RSPO that the proponents have overstated the magnitude of local support fortheir development and that the local opposition should be given an opportunity to have their protestsheard and considered before more forest is removed.We are disappointed that SGSOC refused to respond to our comment that All for Africa hasmisinformed the public about the potential benefits of the proposed oil palm plantation. ThroughHerakles Farms, SGSOC is closely collaborating with All for Africa to develop this plantation. All forAfrica is actively accepting donations from the public to buy subsidized oil palm trees from HeraklesFarms to plant in the proposed concession area. Bruce Wrobel founded SGSOC, Herakles Farms, and Allfor Africa and all three share the same office space in New York. The public should be made awarethat the proposed plantation will not mitigate climate change and they should know that All forAfrica and its collaborators misled them into believing otherwise.Importantly, SGSOC has brushed aside our comments that they have violated RSPO guidelines.The fact of the matter is that the proponents have cleared at least 30 ha of forest (and have reportedlycleared forest for a ~3 km road near their Talangaye nursery) prior to obtaining certification from theRSPO. Were these forests “primary” or were they of high conservation value? It is impossible to answerthose questions since the forest has already been removed.Finally, we are deeply troubled by the decision by SGSOC to direct their response only toDr. Linder, when our initial letter was signed by 10 other world-leading scientists with extensiveknowledge of the impacts that oil palm developments have on biodiversity, and to include two documentsin their response that attempt to isolate and discredit Dr. Linder and his work in Cameroon. Theirattempts at discrediting single individuals when conservation, human rights, and development7 Localisation et Description des UFA 11006 et 11007, 1 December 2008.8 Law No. 94/01, To Lay Down Forestry, Wildlife and Fisheries Regulations, 20 January 1994.9 Tanebang, T.C.L. 2011. Perception des populations riverains sur l’impact social de la palmeraie en cours decreation dans les departments du Kupe Muanengoumba et du Ndian (Sud-ouest Cameroun). Rapport soumis en vuede l’obtention du Diplôme D’Ingénieur des Travaux des Eaux, Forêts et Chasses. University of Dschang, Cameroon.

organizations from around the world have expressed deep concerns about the Herakles Farms oil palmplantation lead us to question the motives of SGSOC, their representatives, and their collaborators. Toaddress the accusations in the letters addressed to Dr. Linder, we have attached a response by Dr. Linder(see Attachment 2). Furthermore, a letter dated April 26, 2012 (see Attachment 3) addressed to Dr.Linder from 50 members of the Fabe community indicates that SGSOC has caused a tremendous amountof intra-village conflict. This letter expresses anger towards and frustration with SGSOC and disavowsthe initial Fabe letter dated April 7, 2012 that was attached to the SGSOC response to our comments.The SGSOC response to our comments to the RSPO confirms our belief that the proponents ofthe proposed oil palm plantation have misinformed the public about the state of the forests they intend toremove, that they have removed intact, dense, high canopy forest prior to submitting a HCVF assessmentto the RSPO, and have wrongly targeted and attempted to discredit individuals who have spoken outagainst the company.Given the controversy surrounding this oil palm development, we agree with the WWF positionpaper that all oil palm investments in Cameroon should be halted until a government policy on palm oildevelopment is established 10 . We also agree that new oil palm developments should be postponed untilthe government of Cameroon identifies and maps degraded areas that could be used to develop palm oil.We reiterate our position that the environmental problems associated with oil palm developmentcan be significantly reduced if oil palm plantations are established on truly degraded lands, far frombiologically rich areas. If done properly and responsibly, oil palm plantations (through smallholder farmsor larger-scale enterprises) can be a good source of local employment and economic development.Unfortunately, Herakles Farms, SGSOC, and All of Africa have not developed an ecologically andsocially responsible project. The RSPO should not be in the business of certifying such plantations,especially when they are located in the heart of a biodiversity hotspot.Sincerely,Joshua M. Linder, Ph.D.Assistant ProfessorDepartment of Sociology and AnthropologyJames Madison University, Harrisonburg, Virginia, USAWilliam F. Laurance, Ph.D., FAAASDistinguished Research Professor & Australian LaureatePrince Bernhard Chair in International Nature ConservationJames Cook University, Cairns, Queensland, Australia10 Hoyle, D. and Levang, P. 2012. Oil palm development in Cameroon. WWF Report.

Thomas T. Struhsaker, Ph.D.Department of Evolutionary AnthropologyDuke University, Durham, North Carolina, USAMatthias Waltert, Ph.D.Georg-August Univerity, Göttingen, Germany

Attachment 1: Location of FMU 11007 relative to the SGSOC proposed oil palm plantation.

Attachment 2.Response to Fabe Village Letter “Disclaimer to Joshua Linder’s Allegations” Sent toPresident Linwood Rose, James Madison UniversityJoshua M. Linder, Ph.D.Assistant ProfessorJames Madison UniversityVirginia, USA30 April, 2012On April 7, 2012, 17 people from the village of Fabe in South West Cameroon addressed a letterto the president of James Madison University (JMU) in Virginia, USA in response to commentsallegedly made by Dr. Joshua Linder (Assistant Professor of Anthropology at JMU) in a reportwritten by David Robinson on 20 March, 2012.Before I respond to each of the points outlined in the letter from Fabe village, it is important tofirst understand the context of this letter. Since the early 2000s, I have been traveling toCameroon to study the primates of Korup National Park and how they respond to hunting byhumans. I have known the people of Fabe village for nearly 10 years, have visited the village onseveral occasions, and have hired many of my field assistants from Fabe. In May 2011, Ibrought 6 American students and one Cameroonian student to Fabe to learn about Cameroonianculture and about how people in Fabe view conservation efforts in Korup NP. The Fabe peoplewelcomed us with traditional dancing and singing, opened their homes to us, and taught us howthey farm, trap, fish, make baskets, and prepare traditional meals. Over the last 10 years, thepeople of Fabe have been incredibly generous, kind, and welcoming to me, my students, and mycolleagues. In fact, some of my closest Cameroonian friends are from the village of Fabe.Recently, the American agribusiness company Herakles Farms, with their subsidiary SGSustainable Oils, and in collaboration with the American non-profit All for Africa, haveattempted to develop a 70,000 hectare oil palm plantation directly adjacent to Korup NP. Withinthe proposed plantation are over 30 villages and 8,000 people, including the people of Fabevillage. Local Cameroonian and international conservation and development organizations havepublicly denounced this development on social and environmental grounds. Formal grievancesand several letters outlining the problems with the Herakles Farms proposed plantation havebeen submitted to the Roundtable on Sustainable Palm Oil (RSPO), of which Herakles Farms aremembers. Herakles Farms is seeking to certify their plantation as ecologically sustainable.Since Herakles Farms has come to this region of Cameroon, there has reportedly been a dramaticincrease in intra- and inter-village conflict, with people arguing in support of and in opposition tothe oil palm development.On March 14, 2012, in one of the few public statements that I have made on this issue, I cosigneda letter (with 10 of the world’s top conservation scientists) that outlined our concernsabout the oil palm development, especially Herakles Farms’ claim that the proposed plantationwill follow the highest environmental and social standards, complying fully with the Roundtable

on Sustainable Palm Oil. This letter was submitted to the RSPO and reproduced on many newswebsites, including National Geographic on March 20, 2012 (posted by Mr. David Robinson). Itis this news piece that the letter from Fabe references. This letter was not directed at nor acomplaint against the Cameroon government or any village in the affected area. On the contrary,the Cameroon government has graciously supported my research and has invested a great deal ofresources in protecting their environment. Our open letter served to voice our concernsregarding the environmental and social impact of this plantation and the claims being made byHerakles Farms, SG Sustainable Oils, and All for Africa.The Fabe letter claims that I have alleged that the Fabe people working for Herakles Farms willincrease their hunting activity in the surrounding protected areas. This is untrue. In the letter ofMarch 14, we indicated that immigration into the Mundemba-Toko-Nguti area of people seekingemployment with Herakles Farms will, “significantly increase demands for bushmeat, leading toincreased hunting pressure in the surrounding protected areas.” The scientific literature stronglysupports this argument – throughout the African tropical forest zone, the establishment of largescaledevelopment projects leads to an influx of migrant workers which leads to a dramaticincrease in bushmeat hunting that is nearly impossible to control.The Fabe letter claims that I have stated that there is only a 100m buffer zone between theproposed plantation and Korup N.P. This is untrue. In the letter of March 14, we indicated thataccording to the Herakles Farms Sustainability Guide, “The company has set aside 3-kilometerbuffer zones between the national parks and the area to be developed”. There are two nationalparks bordering the proposed plantation – Korup and Bakossi. Maps in the Herakles FarmsEnvironmental and Social Impact Assessment indicate only a 100-meter-wide buffer zoneadjacent to Bakossi National Park. Either the map that Herakles Farms submitted to thegovernment of Cameroon and to the RSPO is incorrect and should be amended or the claims intheir Sustainability Guide are false and misleading. I have never written, insinuated, or allegedthat there is a 100m buffer zone between Korup N.P. and the proposed plantation.The Fabe letter claims that I have meddled in Fabe village affairs, misinformed the public, anddistorted the facts. This letter also claims that no member of the Fabe community is concernedabout the oil palm development. In the March 14 letter, there was no mention of Fabe villageand all of our statements were supported by cited evidence. It cannot be denied that letters ofcomplaint against Herakles Farms have been written by members of the Fabe village (e.g., lettersdated April 11 and 15, 2011) and several other villages (and larger cultural groups) in theaffected area. These letters cite a lack of transparency; a lack of free, prior, and informedconsent of local communities; the illegal demarcation and clearing of land; and the biological,economic, and cultural importance of the forests as reasons for opposing the proposed project.Herakles Farms should have all of these letters in their files and should be able to provide themto the village of Fabe upon request.The Fabe letter claims that I describe myself as a “messiah” and “helper” to the Fabecommunity. In a separate letter, Mr. Carmine Farnan, Herakles Farms Project Manager, claimedthat I describe myself as a “son” of Fabe. I have never publicly or privately stated, described, oralleged that I am any kind of messiah or “son” of Fabe. In fact, in a public ceremony in Fabevillage it was the Chief of Fabe, Mr. Wangoe Philip (one of the signatories of the Fabe letter)