EPN statement: FSC Baseline Assessment for APRIL

4th December 2020 – The Forest Stewardship Council (FSC) has invited stakeholders to webinars to discuss a Baseline Analysis of paper company APRIL that FSC commissioned recently.  Non-governmental organisational members of the Environmental Paper Network (EPN) will not participate in the webinars as we consider that FSC has no legitimacy to develop this Baseline Analysis. For the same reasons, on August 26 a large number of civil society organizations active in the field wrote to FSC demanding, among other things, to halt ad-hoc baseline assessments and not to publish or refer to the baseline assessment of APRIL Group (1). These organisations continue to support that position.

The civil society groups also agree that this analysis presents several weaknesses:

    • It was conducted without transparency and key experts and stakeholders in Indonesia were not consulted to obtain inputs on the ToR nor on the actual analysis, excluding from the process also the original complainants that led to FSC’s disassociation with APRIL.
    • It covers only part of APRIL’s corporate group footprint and uses poor data and methodology, thus failing to report on substantial PfA violations and environmental and social harms by APRIL and the Royal Golden Eagle group operations: 
      • It does poorly in identifying PfA violations in “Destruction of high conservation values in forestry operations” and “Significant conversion of forests to plantations or non-forest use”: The analysis conducts retrospective HCV assessments without an agreement on the methodology used and uses an unacceptable approach that focuses on ‘An estimation of the probability of the presence of HCVs’. Comprehensive assessments must be undertaken to assess the previous and ongoing degradation and conversion of HCV areas and HCS forests in its operations and throughout its supply chain at a Corporate Group level, using credible methodologies as outlined by the High Conservation Value Resource Network. 
      • It does not publish maps of identified deforestation or detailed information on the presence of HCV 1-6 areas and other data used, failing to prove the assessment’s credibility or allow the spatial mapping results to be independently verified. 
      • The Analysis does poorly in identifying PfA “Violation of traditional and human rights in forestry operations”: The analysis does not include a detailed representation of outstanding conflicts with communities affected by APRIL’s operations, or the human rights violations perpetrated perpetrated by Golden Eagle group and sister companies controlled by the same owner family, such as its failure to respect the FPIC of communities affected by Toba Pulp Lestari’s operations. 
      • The Analysis excluded around 90% of cases of abuses as allegations not substantiated by information – without providing indicators or criteria, and without consulting the affected parties. The Analysis also assumes that APRIL’s grievance mechanism, land dispute resolution, FPIC process and conflict resolution are adequate or are addressing the disputes – but it fails to provide evidence.

EPN recommends that FSC: 

  1. not use this Baseline Analysis for any further process related to APRIL. FSC should instead clarify that APRIL violated PfA and require them to meet the same obligations as APP before establishing any further dialogue:
    • demand transparency about APRIL’s corporate structure and all associated and directly and indirectly linked companies in order to allow full understanding of the company’s environmental and social footprints,
    • obtain a full commitment from the owner family towards the remedy and other conditions required by the Roadmap,
  2. finalise the Generic Roadmap and other associated policies/procedures to build a legitimate foundation to deal with all disassociated companies, including APRIL and APP, instead of continuing to address illegitimate and unfair steps on an ad-hoc basis.

EPN and its member organizations are willing to support FSC in the two crucial steps mentioned above. Once these tasks have been completed, we will also support a legitimate and fair process aimed at ending FSC disassociation with APRIL and APP to bring remedy to harm. Once again, we would like to stress that we do not consider the proposed FSC Baseline Analysis to be a legitimate part of that process.


  1. Note: Signatories of the letter include: Auriga, Environmental Paper Network, Eyes on the Forest, Friends of the Earth West Australia, Forest Peoples Programme, Greenpeace New Zealand, Hutan Kita Institute, Kaliptra Andalas, LPESM Riau, PUSAKA, Rainforest Action Network, SKP KC Fransiskan Papua, Jayapura Social, TUK Indonesia, WARSI, WALHI North Maluku, WALHI South Sumatra, WALHI Jambi, WWF Indonesia, Yayasan Masyarakat Kehutanan Lestari