FINAL
COUNTDOWN
Now or neverto reform thepalm oil industry

‘We can produce palm oil in a way that protects forests,
clean air and local communities, all while contributing todevelopment and prosperity in palm oil growing regions.
We know from our customers and other stakeholders
that there is a strong and rapidly growing demand fortraceable, deforestation-free palm oil, and we intend tomeet it as a core element of our growth strategy.’ 5
Kuok Khoon Hong, CEO, Wilmar International

22 August 2018, PT Sumatera Unggul Makmur (Gama), Kalimantan,
0°10’54.01”S 109°20’10.09”E:Greenpeace Southeast Asia volunteer firefighter in a Gama oil palm concession inWest Kalimantan. The Indonesian Ministry of Environment and Forestry reportedly
sealed off four concession areas controlled by the Gama group as a result of
the fires and was considering criminal charges. Gama is a long-standing Wilmar
supplier and the two groups are closely related.
©Hernawan/Greenpeace

In this report and its annexes and appendices, mentions of ‘Greenpeace’ should
be read as references to Greenpeace International, unless otherwise indicated.

ANGLO-EASTERN PLANTATIONSAUSTINDO NUSANTARA JAYABUMITAMACENTRAL CIPTA MURDAYACITRA BORNEO INDAH
DJARUMDTK OPPORTUNITYFANGIONO FAMILYFELDA/FGVGAMA (FORMERLY GANDA)
GENTINGHAYEL SAEED ANAM GROUPIJM CORPORATIONINDONUSAIOI GROUP
KORINDOLEMBAGA TABUNG HAJI
NOBLE
NPC RESOURCESPOSCO DAEWOORIMBUNAN HIJAUSALIMSAMLING / GLENEALYSUNGAI BUDI GROUPTEE FAMILY / PROSPER
WILMARUNILEVER

RECKITT BENCKISER

PROCTER & GAMBLEPZ CUSSONSPEPSICONESTLEMONDELEZMARS

L'OREAL

KRAFT HEINZKELLOGGSJOHNSON & JOHNSONHERSHEY

GENERAL MILLSFERRERODANONECOLGATE-PALMOLIVE

brand EXPOSURE TODIRTY PRODUCER GROUPSExecutive
Summary
In 2010, members of the Consumer Goods Forum pledged
to clean up global commodity supply chains by 2020.1 Theirefforts did not get off to an auspicious start, being too limited
in ambition and poorly enforced. But in December 2013,
there was a significant development: the world’s biggest
palm oil trader, Wilmar International, made a commitment to‘no deforestation, no peat, no exploitation’ (NDPE). Wilmar’s
CEO Kuok Khoon Hong promised that within two years thecompany would only be trading palm oil from responsible
producers that protected the environment and respected
human rights.2
This promise was a reaction to years of criticism of thepalm oil industry’s environmental and human rights abuses,
which had continued despite the establishment of theRoundtable on Sustainable Palm Oil (RSPO) a decade earlier.
Other traders and their customers followed suit, and within
a year most major traders of Indonesian palm oil – andthe brands they supplied – had published NDPE policies of
their own. The traders’ policies covered not only their own
plantations, but those of the third-party producer groups
from which most of their palm oil originates.
Since the end of 2014, all the conditions have been inplace to make ‘no deforestation’ the new normal for the palm
oil industry. The overwhelming majority of Indonesian and
Malaysian palm oil now passes through companies that havecommitted to forest protection; recent analysis suggests that
traders with NDPE policies operate 74% of the total refinery
capacity in Indonesia and Malaysia.3 Yet deforestation forpalm oil shows few signs of slowing down – because althoughbrands and their suppliers have these policies, they havetotally failed to implement them effectively.
The problems companies face when sourcing high-risk
commodities like palm oil are well understood. The palm oil
industry’s expansion into rainforests and peatlands has had adevastating effect on Indonesia’s people and wildlife, as wellas our global climate. Yet years after announcing their NDPE
policies, brands and traders are still falling at the first hurdle byfailing to identify the producer groups in their supply chains andmonitor them across their operations. In many cases, companies
are sourcing palm oil from a producer’s mature plantations while
the same business is destroying forests for new plantations
elsewhere. Yet brands and traders do not have – and do not
require their suppliers to provide – the concession maps thatwould show whether the producer groups that supply them arecompliant with their NDPE policies or are still clearing forest.

iv

25 March 2018,
PT Plasma Nuftah Marind Papua (Moorim), Papua,
7°53’5.837”S 140°0’20.454”E©Ifansasti/Greenpeace

final
countdown‘A lot of people think if you outsource
your value chain you can outsource yourresponsibilities. I don’t think so. We need
to be at the forefront of change. This is
why Unilever is committed to greatertransparency and continues to work with
our partners to drive positive change inthe palm oil industry.’6
Paul Polman, CEO, UnileverNow or never to reformthe palm oil industryv

20 September 2015,
Gunung Palung National Park, Kalimantan,
1°17’7.269”S 110°4’6.644”E©Greenpeace‘You fly over Indonesianrainforests, burningand clearing for the
production of palm
oil and hear so manytuts and “isn’t that justawful”. But we’re to beheld accountable. Palmoil is in so many of the
products we eat [...]– we can’t do without
it. It’s easy enough to[blame] the Indonesians,
but we’re buying into it;it’s down to us.’7
Sir David Attenborough25 March 2018,
PT Plasma Nuftah Marind Papua (Moorim),
Papua,7°53’13.823”S 140°0’19.158”E©Ifansasti/Greenpeace

18 December 2017,
PT Pusaka Agro Lestari (Noble), Papua,
4°20’22.469”S 136°41’3.649”E©Sukarno/Greenpeace

vi

final
countdown24 October 2015,
Kalimantan©Rante/Greenpeace

Without this information, they have no way to guarantee thatthey are not sourcing palm oil from rainforest destroyers.
Despite promising to clean up their supply chains by
2020, brands and their suppliers are still sourcing palm
oil from producers that destroy rainforests. The second
section of this report documents extensive deforestationand human rights abuses by 25 palm oil producer groups,
all but one of which have supplied brands with palm oil inthe last 12 months. Between them, those producers are
known to have destroyed more than 130,000ha of forestand peatland since 2015,4 an area almost twice the size ofSingapore – and that is almost certainly an underestimateof the full scale of devastation, because the total sizeof their collective landbank is unknown. 40% of thisdestruction – 56,000ha – took place in Indonesian
Papua, the newest front in the palm oil industry’s war
against the environment.
Prior to publication Greenpeace contacted all the
producer groups discussed in this report to offer them theopportunity to comment on the findings. Methodology for ouridentification of groups and a link to responses received, bothprior to publication and subsequently, can be found in Annex 2.
As the world’s largest palm oil trader – and the first to
publish an NDPE policy – Wilmar International bears muchof the blame for the ongoing destruction of Indonesia’s
rainforests for palm oil. Greenpeace’s analysis indicates that
not only does Wilmar trade palm oil from more destructive
Now or never to reformthe palm oil industry

producers than most of its competitors, but it is often theirprimary route to market. The Forest Trust (TFT) and otherconsultants that support companies in the implementation of
their NDPE policies must also answer for their failure to holdclients to account.
It is now or never for the palm oil industry.As global
temperatures rise and populations of endangered
species dwindle, companies will come under increasingpressure to prove their supply chains are clean orditch high-risk commodities altogether. The futureof the palm oil industry and other sectors depends
on their adoption of a new model of trade based onradical transparency, independent verification and zerotolerance for deforestation and human rights abuses.
Wilmar must lead from the front. It must prove it nolonger sources from forest destroyers, by requiring all
producer groups in its supply chain to publish mill location
data and concession maps for their entire operations andcutting off any that refuse. Wilmar must then completelytransform its supply chain, so that by 2020 it is only
trading with producers whose entire operations have been
independently verified as compliant with all aspects of its
NDPE policy – even if that means it must sell less palm oil.
Wilmar’s CEO, Kuok Khoon Hong, promised in 2013
to supply the market with deforestation-free palm oil.
With 2020 less than 500 days away, the final countdown
has begun.

vii

15 September 2003,
Pindaunde Lakes, Papua New Guinea©Mauthe/GreenpeaceContents
EXECUTIVE SUMMARYIVPART ONE: FINAL COUNTDOWNTIME IS RUNNING OUT FOR INDONESIA’S RAINFORESTS

2POLICIES, PROMISES AND PLEDGES – BUT NO ACTION

7COMPLACENT TRADE OF A HIGH-RISK COMMODITY

9Wilmar International: Rogue Trader

12

HIDING IN PLAIN SIGHT: HOW PRODUCER GROUPSOBSCURE LINKS TO DEFORESTATION15LEAKAGE REFINERIES19

SUSTAINABILITY CONSULTANTS – FRIEND OR FOE?

20NOW OR NEVER FOR THE PALM OIL INDUSTRY

24

TIME FOR ACTION

27

PART TWO: CASE STUDIESDIRTY PRODUCERS IN THE GLOBAL MARKET

30

Anglo-Eastern Plantations		

32

Austindo Nusantara Jaya		

34

Bumitama		

38

Central Cipta Murdaya		

46

Citra Borneo Indah		48

Djarum		52

DTK Opportunity		

56

Fangiono Family		

58

FELDA/Felda Global Ventures (FGV)64

Gama/Ganda		

68

Genting		

76

Hayel Saeed Anam		

80

IJM Corporation		

86

Indonusa		

88

IOI		

92

Korindo		

96

Lembaga Tabung Haji 		

108

Noble Plantations		

112

NPC Resources		

118

POSCO Daewoo 		

122

Rimbunan Hijau		

126

Salim		

130

Samling		136

Sungai Budi		

140

Tee Family		

144

PART THREE: END MATTER
Annexes and appendices		150

Endnotes
Part One: Final Countdown		

162Part Two: Case Studies		
Part Three: Annexes and Appendices

164
171

Bibliography		Now or never to reformthe palm oil industry

174

1Time isrunning out
for Indonesia’s
rainforests
The plantation sector – palm oil and pulp – is the single
largest driver of deforestation in both Indonesia andMalaysia.8 According to figures released by the Indonesian
Ministry of Environment and Forestry (MoEF), around24 million hectares (ha) of the country’s rainforests
were destroyed between 1990 and 20159 – an area
almost the size of the UK10 – with a further 1.6m halost between 2015 and 2017.11 Around a fifth (19%) of
Indonesia’s 2015–2017 deforestation took place in palm
oil concessions.12
The destruction of Indonesia’s rainforests is a
global crisis. Deforestation and peatland destruction are
major sources of greenhouse gas emissions; rainforest
destruction has pushed Indonesia into the top tier ofglobal emitters, alongside the United States of America
and China.
Plantation development is a root cause of Indonesia’sforest and peatland fires, with many fires started
deliberately to clear land before planting. In July 2015,
devastating forest and peatland fires spread across large
areas of Sumatra, Kalimantan and Papua, grounding
flights and forcing the closure of schools and offices
across the region. During September and October
2015, daily greenhouse gas emissions from the forest
fires regularly surpassed those of the United States.13
These fires also produce a haze that affects millions ofpeople across Southeast Asia: researchers at Harvard andColumbia Universities estimate that 100,000 people will
die prematurely from respiratory diseases linked to the2015 haze.14 The World Bank calculated the cost of thedisaster at US$16bn.15
Deforestation for pulp and oil palm plantations
has devastated lowland forests in Sumatra andBorneo, destroying vital habitat for tigers, elephants,rhinoceroses, orangutans and other endangered species.
Scientists estimate that just two robust breeding
populations of Sumatran tigers are left in the wild.16
Bornean orangutan numbers fell by over 50% between

2

final
countdown

4 October 2007,
Kapuas river, Kalimantan©Behring/Greenpeace31 April 2018,
PT Megakarya Jaya Raya (HSA), Papua,
6°26’48.948”S 140°14’20.087”E©Ifansasti/Greenpeace4

1999 and 2015, with no more than 70,000–100,000
individuals remaining.17 In 2015–2017, over a quarter (28%)
of the loss of forested Bornean orangutan habitat in Indonesia
was in palm oil concessions.18 Over 69% of potential habitat
for the Sumatran elephant has been destroyed within just one
generation.19 The Sumatran rhinoceros is said to be ‘hanging
on by a thread’,20 with fewer than 100 left in the wild.21 The
crisis within Indonesia risks being repeated as the palm oil
industry expands into new countries and regions: according
to the International Union for Conservation of Nature (IUCN),
undeveloped areas suitable for palm oil production are hometo half of the world’s threatened mammals, and almost twothirds of all threatened birds.22
Palm oil lobbyists talk up the sector’s contributions
to Indonesia’s economy and present it as a lifeline tosmallholder farmers. In reality, the economic benefits of thepalm oil boom have fallen on the handful of already wealthy
individuals that control the big plantation companies.23
Even initiatives that are supposed to help smallholder
farmers, such as the Indonesian government’s export levy,
are misused to provide even more support to the largest
players in the sector.24
By contrast, many of the costs have been borneby workers and communities. Social conflicts between
local people and plantation companies – including many
owned by major traders – are widespread, brutal andunresolved.25 Non-governmental organisations (NGOs)
and unions report that even plantations that have beencertified as ‘sustainable’ often show signs of child labourand forced labour.26 Workers in the palm oil industry
are routinely exposed to hazardous pesticides, paid
below the minimum wage and deterred from forming
unions to seek redress27 – a far cry from the pictures ofsmiling plantation workers that dominate companies’
sustainability reports.
The palm oil industry’s failure to address deforestationand other notorious practices is putting its long-term
future in doubt. Public opinion in many major markets
is already turning against palm oil. In opinion polls
worldwide, respondents consistently rate it as the mostenvironmentally destructive vegetable oil,28 even thoughother oils (such as soya oil) are equally problematic.29 The
European Union (EU) has debated removing subsidies
for biofuels made from palm oil.30 Some supermarkets inAustria31 and the United Kingdom32 have begun phasing
palm oil out of their own-brand products; other European
retailers are expected to follow suit. Calls for brands tostop using palm oil will only get louder until traders candemonstrate that they only source from responsible
producers that comply with NDPE standards.

Now or never to reformthe palm oil industry

5100% CLEAN
PALM OILMILLS/PRODUCERSTRADERS/
SUPPLIERS

NDPE
POLICY

How brands
perform on NDPE
implementation

Policies, promises
and pledges –but no action

On the first day of the Cancun climate summit in2010, the Consumer Goods Forum acknowledgedthat deforestation for agricultural commodities isa major contributor to the global climate crisis andmade an unequivocal commitment to eliminate
rainforest destruction from palm oil and other highrisk commodity supply chains by no later than 2020.33
By the end of 2016, 447 companies, including bothbrands and traders, had made public commitments toaddress deforestation in their supply chains.34 Somecompanies have enshrined these commitments into
commodity-specific NDPE policies that also have
explicit 2020 deadlines.
At the start of 2018, Greenpeace International
challenged leading consumer brands to demonstrate
their progress towards responsible sourcing by
revealing the mills that produced their palm oil and thenames of the producer groups that controlled thosemills. If disclosed, this information would show whether
brands had forest destroyers in their supply chains.
Many responded positively to this challenge; at the timeof writing, 17 brands now disclose these data. In doing
so, these brands have forced several previously nontransparent palm oil traders to divulge the producergroups and palm oil mills in their own supply chains,
helping to establish a new baseline for transparency
that all companies can expect to be held to.
At the same time, however, the supply chain
information disclosed by brands and traders indicatesthat little progress has been made towards cleaning
up the global palm oil trade. Every company that has
opened its supply chain to public scrutiny is sourcing
from producers that are known to be clearing rainforests,
exploiting their workers and/or embroiled in land
conflicts with local communities.
This should come as no surprise: as Greenpeace andother NGOs have consistently argued, brands have failed
to take the lead when it comes to implementing their
Now or never to reformthe palm oil industry

NDPE policies.35 Instead, they have outsourced much of
the responsibility to their sustainability consultants, like
TFT, and to their suppliers, including global commodities
traders such as Golden Agri-Resources (GAR), Musim
Mas and Wilmar. Many brands are in effect measuring
progress in terms of the percentage of their suppliers
that have published NDPE policies, rather than in termsof the successful implementation of those policies.
There is a world of difference between having a
policy and implementing it. As Greenpeace showed
in its November 2017 report, Still Cooking the
Climate,36 traders have largely failed to establish any
meaningful systems, either individually or collectively,
to enforce their NDPE commitments. The same is trueof their customers.37 Our analysis suggests that four
years after making their commitments, traders andconsumer brands are still:• failing to require the producer groups in their
supply chains to publish concession maps anddisclose the extent of their operations;• failing to proactively monitor their entire
supply chains to identify all producer groups
that are still involved in deforestation;• failing to ensure producer groups cease andthen remedy their deforestation (and othernon-compliant behaviour) in a transparent andtimebound fashion;• failing to exclude producer groups that missdeadlines or refuse to reform;• failing to obtain independent verification that all
remaining producer groups are fully compliant with
NDPE standards across their operations.
As a result of these collective failures, the global
market remains contaminated with palm oil from some of
the most destructive producer groups in Southeast Asia.
In other words, brands are not just complicit in rainforest
destruction and exploitation, but – through their palm oilpurchases – actively funding those responsible for it.

7

1 25 June 2005, MODIS satellite
imagery of fire smoke over Riau 2 23June 2013, PT Rokan Adiraya, Riau,
1°10’8.4”N100°50’54.83”E ©Ifansasti/
Greenpeace 3 23 June 2013, PT Rokan
Adiraya, Riau, 1°10’8.4”N 100°50’54.85”E©Ifansasti/Greenpeace1

4 31 March 2018, PT Megakarya Jaya Raya
(HSA), Papua, 6°26’9.25”S140°15’4.25”E©Ifansasti/Greenpeace 5 23 August
2018, Kubu Raya, Kalimantan ©Hernawan/
Greenpeace 6 18 June 2013, Singapore©Natasya/Greenpeace 7 4 June 2014,
Malaysia ©Roslan/Greenpeace 8 24 June
2013, PT Bumi Langgeng Perdanatrada
2

4

5

6

7

8

9

8

(Eagle High), Kalimantan, 2°46’28.799”S
111°50’30.7” ©Greenpeace 9 19 September
2017, Kalimantan ©Sukarno/Greenpeace
10 17 September 2013, PT Jatim Jaya
Perkasa (Gama), Riau, 1°55’55.41”N
100°49’33.19”E ©Tambunan/Greenpeace

final
countdownComplacent
trade ofa high-risk
commodity

3

The palm oil industry in general – and consumer
brands in particular – continues to treat instances ofdeforestation as the exception, not the norm. Years
after adopting NDPE policies brands and traders arestill unable to monitor the producer groups in their
supply chains, due in part to their failure to gather
concession maps and other necessary data. Instead
they rely on NGOs to identify deforestation or otherpolicy breaches and file grievances. When NGOs raise
instances of non-compliance by suppliers, brands
and traders treat them as isolated cases meriting‘engagement’ or ‘monitoring’. Producers that are notsubject to complaints are presumed to comply with
NDPE policies, even though there is little reason tobelieve this is the case and plenty of evidence that the
opposite is often true.
In this climate, existing initiatives that should
improve governance and transparency in the sector areoften counterproductive, because they are hamperingrather than speeding reform. The long-awaited
publication of RSPO members’ concession maps39
is a case in point – in theory this mapping databaseshould be an invaluable tool, allowing stakeholders
to get a complete picture of each producer group’s
landholdings and any deforestation within theirconcession boundaries. However, the RSPO has chosen
to release these maps in the most dysfunctionalmanner, with no working search function and no way
to see a producer group’s complete holdings. It iscompletely unusable, yet producer groups and traders
use it to justify their refusal to publish maps themselvesin a format that is usable.

10

Now or never to reformthe palm oil industry

925 August 2006,
Riau,©Dithajohn/Greenpeace‘Greenpeace appears to be seeking
a commitment to an ever-watchful
Orwellian Big Brother approach tosupply chain management with punitive
measures against suppliers who are notyet meeting standards as their
key method of delivering change.’38
Golden Agri-Resources blog

10

All of this leaves brands and traders still sourcing palm oilfrom producer groups that are destroying rainforests, years
after they’ve promised to stop. The second section of thisreport profiles 25 palm oil producer groups that are known tohave violated NDPE policies. In most cases, evidence of thesegroups destroying rainforests or violating human rights was
already in the public domain: covered in NGO reports or RSPO
complaints, documented in media articles or reported bydirectly affected communities. Although this is by no means acomprehensive list of all non-compliant palm oil producers –and producers not profiled here should not be assumed to becompliant – these producers represent the greatest known
threats to Indonesia’s rainforests and local communities.
Prior to publication Greenpeace contacted all the
producer groups discussed in this report to offer them theopportunity to comment on the findings. Methodology
for our identification of groups and a link to responses
received, both prior to publication and subsequently, canbe found in Annex 2.
In November 2017, Greenpeace presented several
traders with evidence that a number of these producer groups
final
countdownwere clearing rainforests, in violation of the traders’ NDPE
policies. In May 2018, Greenpeace wrote to 18 brands and 15
traders, asking each to confirm whether any of the 25 groups
in this report were in its supply chain and the actions they
had taken in response to their well-documented violations.
Their responses, and our own analysis of public domain supply
chain data, confirmed that all but one of these producers had
supplied palm oil to major traders in the last year, and throughthem to global brands with NDPE policies.
Following their contact with Greenpeace, several
traders began to record these cases as grievances on theirwebsites and to log their efforts at dialogue, engagement
and monitoring. No efforts appear to have been made toassess whether the producer groups were clearing rainforest
except in the specific concessions identified by Greenpeace.
Nor did brands and traders acknowledge the obvious
conclusion that there is something fundamentally broken in
their NDPE implementation procedures. Instead, they claimed
that the system was working, despite the number of cases
Greenpeace had raised, because several producers agreed tocease further deforestation and others were excluded from
Now or never to reformthe palm oil industry

their supply chains. CEO Kuok Khoon Hong, for example,
asserted that Wilmar was ‘constantly engaging with noncompliant suppliers’ and was ‘on the right path’.40
But this reactive approach, where brands and traders
rely on NGOs to play ‘supply chain cop’, is treating thesymptom, not the disease. Given how much evidence
against these producers is in the public domain, brands andtraders should never have allowed them into their supply
chains in the first place. The sheer number of cases detailed
in this report proves that the approach traders and brands
are taking is not fit for purpose.
Brands and traders need to take responsibility forscreening the producers in their supply chains to ensure
they are not doing business with groups that are destroying
rainforests. They need their own comprehensive monitoring
system, based on their suppliers’ mill location data andconcession maps, to ensure that the producer groups in their
supply chains comply fully with NDPE standards. Crucially,
information regarding producer groups’ landholdings andoperations should be placed in the public domain to enable
any claims to be independently verified.

11

WilmarInternational:
rogue trader
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br

Wilmar International is the world’s largest palm oil trader,
responsible for around 40% of global trade.41 It is listed on
the Singapore Exchange.42
Wilmar has been an RSPO member since 2005.43
In December 2013, it led the field by adopting an NDPE policythat applied both to its own operations as a producer and to
those of its suppliers.44 Wilmar is co-chair of the High Carbon
Stock Approach (HCSA) steering group, although its NDPE
policy has yet to explicitly reference the HCSA – a requirementof members since 2015.45 Wilmar has not made maps of its
concession boundaries publicly available in a usable format.
Wilmar was founded by Kuok Khoon Hong and Martua
Sitorus; Sitorus is also the CEO of the highly destructive
Gama group (see case study below).46 In addition to a large
amount of managerial overlap between the two groups,
Wilmar has a history of selling problematic concessions
to Gama when serious human rights or environmental
violations are exposed in its own operations.47 In July 2018,
Sitorus and his brother-in-law, Hendri Saksti (Wilmar’s
Country Head for Indonesia),48 resigned from Wilmar
following the publication of a report by Greenpeace into
deforestation in Gama concessions.49
At the end of 2017, Wilmar had a total planted areaof 239,935ha of oil palm, around 68% of which was inIndonesia, 24% in Malaysian Borneo and 8% in Africa.
Its Indonesian plantations are located mainly in Sumatra
and Central and West Kalimantan,50 with some in the
Bangka Belitung Islands and Sulawesi.51 Wilmar also owns
Australian foods company Goodman Fielder jointly withFirst Pacific,52 the majority shareholder of Indofood,53 partof the Salim Group (see case study below).
Although Wilmar was the first trader to adopt an
NDPE policy, it has yet to bring its own operations intofull compliance. Several of Wilmar’s concessions haveunresolved land conflicts that involve intimidation of andviolence against local communities. The dispute concerning
PT Permata Hijau Pasaman 1, which operates concessionsin West Sumatra, has been especially lengthy.54 Similarly,
final
countdownSince 2007,
Greenpeace reports
have exposed Wilmar
as a key player inthe dirty palm oil
sector.

PT Bumi Sawit Kencana II, based in Central Kalimantan,
has reportedly been at the centre of a land conflict for
more than a decade, with repeated violence towards local
residents.55 On 19 December 2017, members of the police
mobile brigade (Brimob) shot and wounded two farmers
within the concession, after local people had gone to thecompany offices to demonstrate about the land issue.56
Wilmar also faces serious allegations of worker
exploitation. In November 2016 Amnesty International
reported systematic abuses in the North Sumatra estatesof PT Perkebunan Milano and PT Daya Labuhan Indah,
including unrealistic targets that resulted in excessive
workloads and meant that employees’ children were being
asked to help with dangerous tasks on the plantation.57
Failure to meet the targets resulted in financial penalties,
and Amnesty concluded that the extra workload
constituted forced labour. There was also discrimination
against women, who were not given contracts but only
employed as casual labourers. Similarly, in April 2017,
SOMO and CNV International investigated labour issues in
PT Murini Sam Sam’s concession in Riau and found many
workers in insecure employment, along with possible
evidence of forced labour.58
Approximately 10-20% of Wilmar’s palm oil supply
comes from its own concessions: more than 80% comes fromthird-party suppliers.59 Wilmar’s NDPE policy explicitly applies
to those producer groups; indeed, it states that suppliers
are expected to be ‘fully compliant with all provisions of thispolicy’ by 31 December 2015.60 That deadline has come andgone, yet Wilmar still fails to monitor its suppliers across all of
their operations to determine whether they comply with its
policy or are destroying forests. This negligence is especiallyproblematic in the case of suppliers’ concessions in frontierareas from which Wilmar does not yet source – exactly where
deforestation is most likely to be taking place.
Responding to Greenpeace’s investigation into Gama,
CEO Kuok Khoon Hong admitted that Wilmar had failed to
identify the extent of Gama operations, that ‘there should
Now or never to reformthe palm oil industry

have been more stringent oversight on the ownershipverification process’ and that Wilmar was ‘still awaiting
the specific list of companies within Gama’.61 In earlier
correspondence, Wilmar could only complain that ‘it is very
difficult [to take action against suppliers] when there is no
information that backs up an allegation’62 – even though
it could have found plenty of evidence through a simple
internet search. At the same time, Wilmar’s grievance
tracker suggests that it knew many of the producer groups
profiled in this report were problematic but only acted whenpresented with the evidence by Greenpeace.63 Even whenproblems within particular concessions are brought to its
attention Wilmar appears unwilling to investigate beyond
those specific concessions – almost as if it would prefer not
to know the extent of its suppliers’ transgressions.
As a result of its failure to adequately screen andmonitor its suppliers at group level, Wilmar is supplying its
customers with palm oil from producer groups that destroy
rainforests and exploit local communities. Supply chain
analysis indicates that Wilmar has been sourcing from 18of the 25 producer groups profiled in this report;64 its own
disclosures reveal that trade with most of these companies
continues. Wilmar is often these producer groups’ primaryroute to market, supplying their palm oil to brands both
directly and indirectly via other traders. Given its size andpivotal role within the palm oil industry, Wilmar is too big– and too important – to be allowed to fail. Its customers,
sustainability consultants and other stakeholders must
hold it to account.
The first step is for Wilmar to prove it no longer sourcesfrom forest destroyers, by requiring all producer groups in its
supply chain to publish mill location data and concession maps
for their entire operations and cutting off any that refuse.
Wilmar must then completely transform its supply chain, sothat by 2020 it is only trading with producers whose entire
operations have been independently verified as compliant
with all aspects of its NDPE policy – even if that means it mustsell less palm oil.

13

mature PALM OIL PLANTATIONS
and DEFORESTATION OWNEDBY THE SAME GROUPS

lls

14

final
countdown

Hiding in plain sight:
how producer groups
obscure links to
deforestation

A large segment of the plantation industry, especially inSoutheast Asia, has always been controlled by complex
conglomerates owned by individuals and families. Groups
and their owners use these structures for a number ofreasons, often including illegitimate ones: to evade tax, toavoid liability for fires or other illegal practices, to circumvent
other laws (such as one that prevents a group controlling
more than 100,000ha of land in Indonesia or laws preventing
foreign ownership; see Annex 1) or to conceal their links
with a member company whose destructive or exploitative
activities breach either the RSPO’s Principles and Criteria66
or their own (or their customers’) NDPE policies.
Brands and traders, along with government andregulatory bodies such as the RSPO, must therefore lookbeyond the specific plantations from which they source
to the individuals, families or corporate groups that own,
control or manage them.
In many cases, a group has no single ultimate parent
company. It may consist largely of privately held companies,
not listed on any stock exchange and therefore not subject toeven basic financial transparency requirements. The resulting
group structures are often complicated, informal and opaque.
The concept of a group as used in the profiles and case studies
in this report reflects this complexity, which goes beyond
formal parent–subsidiary company relationships, as describedin the following paragraphs.
Companies with common ownership may be partof formally distinct corporate entities; companies may
be owned via multi-layered shell structures of holding
companies; different family members may be the direct or
ultimate owners of companies within the group; or partsof the group may be held offshore, rendering the ultimate
Now or never to reformthe palm oil industry

owner unknowable. The use of nominees – individuals
in whose name companies are registered but who act as
custodians only – is another option for the concealment of
the beneficial owners who in fact control the company.
However, there are other criteria beyond explicit
ownership that indicate that companies within the palm
oil sector should be considered as part of the same group.
Indicators of an otherwise hidden overlap in beneficial
ownership include:• financial control (eg when one company can oblige
another to act under its direction as a result of afinancial contract);• managerial control (when the same individuals, ortheir family members or known associates, serve as
senior officers or directors of different companies –even if these companies belong to formally distinct
corporate structures);• operational control (eg when one company’s employees
manage another company’s plantations, or whendifferent companies share the same offices).
If corporate NDPE policies are to be effective intransforming the industry, palm oil traders and theircustomers will need to take a broad view of what constitutes
a group, including the various types of control and ownershiplinks described above, and conduct effective due diligence inorder to identify those links.
While most NDPE commitments explicitly apply
at the group level – meaning they should apply to theentirety of a producer group’s plantation and refinery
operations, landholdings, joint ventures and third-party
suppliers – many brands and traders still continue to
avoid responsibility for acting on non-compliance when

15

16

final
countdown‘A corporate group is aset of individuals or legal
entities in the plantation
sector that are connectedto each other throughownership, management
and/or financial links.’65
Indonesian Ministry of Agriculture,2013 regulation

it occurs outside their direct supply chain. This creates asignificant loophole: NDPE breaches such as deforestationand peatland drainage occur during the early stagesof plantation development, when the concession inquestion may not be producing palm oil at all. Commercialpressure must therefore be applied to all other companies
in the group if there is to be any chance of stopping
environmentally or socially harmful development.
Thankfully, the concept of group-level responsibility is
gaining traction. For example, a 2013 regulation from theIndonesian Ministry of Agriculture governing plantation
licences (IUPs; see Annex 1) partly acknowledges this rangeof possibilities: ‘A corporate group is a set of individuals or
legal entities in the plantation sector that are connectedto each other through ownership, management and/or financial links.’67 The principle was also highlighted
in the 2015 decision of Norway’s Government Pension
Fund Global (GPFG) to refrain from investing in Korean
conglomerate POSCO and its subsidiary Daewoo following
evidence of Daewoo palm oil subsidiary PT Bio Inti Agrindo
clearing primary forest in Indonesia:
The [GPFG] follows the guiding principle that if aparent company is the controlling owner of a subsidiary,
the parent company must also be excluded if thesubsidiary breaches the guidelines. As the controlling
owner, the parent company has deciding influence on
the activities of the subsidiary.68
Within the palm oil sector itself, the RSPO has
since March 2017 required all members to register at
the parent group level, though it has yet to show itself
willing to enforce the requirement even in relatively
straightforward cases. Its membership rules define aparent group in terms not only of ownership but also ofmanagement or operational control.69 Moreover, sometraders (such as Wilmar70) and consumer companies have
Now or never to reformthe palm oil industry

included the principle of group-level responsibility in theirsustainability policies as they apply to their own and thirdparty suppliers’ operations.
There has even been some acknowledgement of thisextended sense of corporate responsibility from palm oilcompanies themselves. Bumitama’s 2015 sustainability
policy advised its executive directors to embrace an NDPE
policy comparable to its own when investing in palm oilcompanies on their own account71 (although as our casestudy shows, the group has failed to respect its own policy).
A new Indonesian presidential regulation,72 effective
since March 2018, requires every corporation (definedas ‘an organised group of persons or assets, whether or
not it takes the form of a legal entity’)73 to provide thegovernment with information on its beneficial owners.74
This information will be accessible to third parties under
freedom of information legislation.75 Brands and traders
should insist on disclosure of such information to them by
their suppliers.
Ultimately, requiring producers to disclose theircorporate ownership and management structures isnecessary to improve governance, implement NDPE
policies and limit the opportunities for corruption andother unacceptable activities. This must include disclosureof beneficial owners and informal structures of family
or managerial control. Brands and traders must impose
contractual obligations on producer groups to disclose theextent and location of their group operations, and strong
penalties – notably contract cancellation – whenever a
producer is found to have concealed the full extent of its
operations. If the palm oil industry is serious about NDPE
then stakeholders need to be able to hold it to account;the information producer groups disclose, including milllocations and concession maps, must be placed in the
public domain, either by producers or their customers.

17

1 April 2013, Kalimantan ©Alejo Sabugo/
International Animal Rescue Indonesia
2 24 February 2014, PT Karya
Makmur Abadi Estate II (KLK),
Kalimantan,1°56’50.742”S 112°26’27.27”E©Ifansasti/Greenpeace

3 4 May 2013, PT Tunggal Perkasa
Plantations (Astra Agro Lestari), Riau,
0°17’58.8”S 102°11’3.42”E ©Jufri/Greenpeace 4 26 October 2007, Riau
©Budhi/Greenpeace 5 15 May 2012, Riau
©Novis/Greenpeace 6 8 November 2008,
Wilmar mill, Riau ©Novis/Greenpeace

1

2

4

6

7 1 April 2018, Korindo bulking
terminal, Papua, 6°39’3.252”S140°24’51.27”E ©Ifansasti/Greenpeace
8 14 November 2008, Dumai, Riau ©Rante/
Greenpeace 9 ©Hamilton/Greenpeace

5

7

18

8

final
countdownleakagerefineries

3

Palm oil refineries have been described as ‘the bottleneckin the supply chain’: a relatively small number of companies
handle large volumes of palm oil.76 Although the majority ofpalm oil refineries in Indonesia and Malaysia are controlled
by companies with NDPE policies, over a quarter ofcapacity is operated by companies that have made no suchcommitments.77 This is known in the industry as the ‘leakage’market, and Chain Reaction Research provides a usefuldefinition: ‘any activity in the palm oil industry, production,
trade and/or consumption, that is not subject to any NDPE
policy requirements’.78
Chain Reaction Research has identified a total of 52
leakage refiners79 (see Appendix 1 for the full list). The bulkof the leakage refining capacity is controlled by a handfulof producer groups: BEST Group, Felda IFFCO, Hayel Saeed
Anam Group (HSA), Incasi Raya, Intercontinental Specialty
Fats/Nisshin Oil and Tunas Baru Lampung.80 Some of thesegroups are profiled in the second section of this report.
Refiners without NDPE policies represent a significant
challenge to efforts to clean up the sector, because they
provide a market for producers that have been excluded byother traders. This gives traders with NDPE policies an excuse
to continue sourcing from non-compliant producer groups,
on the spurious grounds that they need to maintain leveragewith them in order to encourage them to comply. Consultants
take a similar line: TFT argues that excluding producers iscounterproductive because ‘suspended suppliers can continue
to clear forests while selling to other refinery companies thatare not committed to responsible sourcing’.81
Although the leakage market has been well documented,
Chain Reaction Research’s analysis indicates that brands
and traders with NDPE policies remain an important market
for leakage producer groups with refinery capacity. Wilmar
trades extensively with refiners in the leakage market, evenas it uses those companies as an excuse for not properly
implementing its own NDPE policy. The same is true of manyother traders. Similarly, many brands receive palm oil fromrefiners in the leakage market, directly or via supposedly
responsible traders with NDPE policies.
In terms of outcomes, there is no difference between
companies that knowingly source from forest-destroying
palm oil producers and those that do so through negligence.
Either way, companies with NDPE policies must close
the leakage loophole by sourcing only from producergroups and traders with NDPE policies that have taken thenecessary steps to prove that all the palm oil in their supply
chains complies with NDPE commitments.

9

Now or never to reformthe palm oil industry

19

Sustainability
consultants– friend or foe?
‘We are not auditors. Nor do we tellcompanies what to do. We help themdevelop policy responses to issues thatconcern them. We help them to come up
with policies they are happy with, andthen go into the field with them to build
their capacity to carry them through.’82
Scott Poynton, founder, TFT

Companies have always turned to sustainability
consultants to help them implement their environmental
commitments. These organisations, often referred to as‘implementation partners’, claim to accelerate supply chaintransformation and to offer brands and traders economies
of scale and opportunities for sharing solutions. Twoorganisations dominate the palm oil sector: TFT, which lists
almost 100 clients spanning 13 commodities and all tiersof the supply chain;83 and Proforest, which does not list
its clients but claims to work ‘throughout the supply chain
with farmers, plantation and forest managers, processors
and traders, as well as consumer goods companies,
investors and retailers’.84
It is understandable that companies should seek outside
expertise and support. Major brands and traders cannot
become proficient at responsible sourcing overnight, andthey stand to benefit from the advice and experience ofcredible experts. However, it is often unclear whether
sustainability consultants are being hired to help acompany change or to protect it from criticism by NGOs
and other stakeholders. Indeed, sustainability consultants
are increasingly hindering reform of the palm oil industry,
especially when it comes to making the sector moretransparent. In some cases, they appear to be prioritising
the defence of their clients and the long-term viability of
their own existing business model over the reforms that areneeded to protect the environment and meet their clients’

20

NDPE commitments before the 2020 deadline. This may begood for business, but it is a disaster for rainforests.
Sustainability consultants work across all tiers of the palm
oil supply chain, from producers to traders to brands. This ispresented as an advantage, especially to companies higher
up the chain: brands are told they can trust the traders theybuy from because they have all hired the same consultants.
However, despite their common NDPE commitments,
producers, traders and brands have different and often
conflicting interests, notably regarding the implementationof those commitments. If companies outsource their NDPE
implementation they will want to know their interests arebeing prioritised over those of their customers or suppliers.
It is unclear whose agenda TFT and other sustainability
consultants are promoting.
NGOs advocate for data – notably, comprehensive lists
and maps of each producer group’s mills and concessions,and information on ultimate beneficial ownership – to bemade public so that producers and their customers can beheld accountable for their actions and any claims companies
make can be verified. By contrast, one of the services
sustainability consultants provide is a ‘safe space’ for clientsto examine their supply chains in private and control what
information is disclosed. As TFT puts it, its services are‘private and independent, in order to let companies bein control [and] choose how they use the information’.85
Symptomatic of this is traders’ practice of having two
final
countdown

17 May 2009,
Kalimantan©Rante/Greenpeace

grievance lists, one public (including only violations thathave been the subject of public complaints by NGOs or
stakeholders) and one private (additionally including
violations of which they are aware but that have not beenraised publicly by third parties).
When asked by Greenpeace to confirm their exposure
to the problematic producer groups discussed in this report,
many brands claimed information regarding the producergroups in their supply chains was held by their sustainability
consultants. Some brands claimed their consultants would
only provide yes/no confirmation when provided with a listof specific producer groups and would not provide brands
with a comprehensive list. By blocking access to data in thisway, sustainability consultants are preventing brands fromtaking meaningful action to clean up their palm oil supply
chains – the opposite of what sustainability consultants aresupposed to be being paid to do.
Withholding access to data appears to be part of adeliberate strategy. Defending its trader clients’ refusal tooperate transparently by disclosing ‘high-risk’ producers andmills in their supply chains, TFT acknowledged that ‘it may
be tempting for some brands to … pick and choose whichpalm oil mills should be allowed in their supply chain with thegoal of excluding the ones perceived as risky’ but asserted
that this process was best outsourced to traders: ‘[a] brand’s
best assurance that a supplier is aligned with their policy isif the supplier is carrying out and acting on a prioritisation
Now or never to reformthe palm oil industry

process throughout its own global supply chain’.86
Greenpeace does not agree. Brands must takeresponsibility for ensuring that the palm oil they use
comes solely from responsible producers that meet NDPE
standards. Further, brands must insist that the traders theysource from are not contributing to the leakage market
by continuing to buy from destructive or exploitative
producers, even if those producers are not in brands’ own
supply chains. Sustainability consultants should holdtheir clients to achieving these objectives – by no later
than 2020 – and they and their clients must operatetransparently so any claimed results can be independently
verified. Naturally, this requires concession maps and othersupply chain data to be made public so that brands (andstakeholders) can monitor producer groups and determine
whether they comply with NDPE standards.
Ultimately, sustainability consultants are not ensuring
their clients deliver a deforestation-free palm oil industry
by 2020. Nor are they prepared to work in a way thatallows that goal to be achieved. Instead, TFT and othersustainability consultants are promoting a model thatamounts in practice to incremental progress throughsecrecy and unverified (and unverifiable) reporting. As
a result, the international market is far more exposed toproblematic producer groups than companies either knowor are willing to disclose – as Greenpeace’s analysis oftrader and brand disclosures indicates.

21

‘Publicity is justly
commended as a remedy
for social and industrial
diseases. Sunlight is said tobe the best of disinfectants;
electric light the mostefficient policeman.’87
Louis Brandeis, Other People’s
Money and How the Bankers Use It

31 March 2018,
Digul river, Papua©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

23

Now or neverfor the palm
oil industry

2020 is ground zero for ending deforestation. Governments
and many of the world’s largest companies have promised tobreak the links between forest destruction and agriculturalcommodities by 2020. Governments will also make newand ambitious climate and biodiversity commitments in
2020. The United Nations (UN) will hold the Convention on
Biological Diversity (CBD) to set targets for the next ten
years. At the 26th UN Climate Change Conference (UNFCCC
COP), world leaders are expected to strengthen thecommitments they made in 2015 at the Paris COP.

24

As 2020 approaches, companies and governments
will be eager to claim progress on social, environmental
and biodiversity goals. Yet the focus on the next decadecannot be allowed to bury the bad news that, despite
countless pledges, far too little has changed in places likeIndonesia this decade. Deforestation and its associated ills
will only be arrested when governments and companies
are held accountable for what happens on the ground andnot just agreements at global summits. The true measureof progress can only be how much of the world’s forests
have been protected.
The systemic problems that the numerous casestudies in this report illustrate are not unique to the palm
oil sector. Brands and traders – and indeed, governments– are failing in their commitments to end deforestationfor other commodities, notably pulp and paper, beef
final
countdownmal Rescue Indonesia©International Ani

and soya. Much more can and must be done to ensurecompanies do not evade their supply chain commitments.
It is time for an honest conversation about the global
commodities trade, and how the land we have is used and forwhose benefit. As global temperatures rise and populationsof endangered species dwindle, companies will come underincreasing pressure to prove their supply chains are clean orditch high-risk commodities altogether.
The future of the palm oil industry and other sectors
depends on their adoption of a new model of trade basedon radical transparency, independent verification and zerotolerance for deforestation and human rights abuses.
As the world’s largest palm oil trader, and the first to
make an NDPE commitment, Wilmar must lead from thefront. Wilmar must prove it no longer sources from forest
destroyers, by requiring all producer groups in its supply
Now or never to reformthe palm oil industry

chain to publish mill location data and concession maps
for their entire operations and cutting off any that refuse.
Wilmar must then completely transform its supply chain,so that by 2020 it is only trading with producers whose
entire operations have been independently verified ascompliant with all aspects of its NDPE policy – even ifthat means it must sell less palm oil.
Wilmar’s CEO, Kuok Khoon Hong, promised in 2013
to supply the market with deforestation-free palmoil. With 2020 less than 500 days away, this is his lastchance to deliver.

25

1 12 November 2009, Riau ©Rante/
Greenpeace 2 14 November 2013, Wilmar
office, Jakarta ©Rante/Greenpeace
3 10 November 2008, Dumai, Riau
©Novis/Greenpeace

4 12 November 2009, Riau ©Rante/
Greenpeace 5 20 October 2013, PT
Agrindo Indah Persada (Wilmar), Riau,
1°53’53.501”S 102°4’31.301”E©Hilton/Greenpeace

1

2

3

4

5

26

final
countdown

Time foractioncompanies must:

Adopt strong standards

Verify results

•

•

•
•

Publish a strong NDPE policy that requires
compliance with the HCS Approach toolkit,89
the integrated HCV–HCSA assessment manual90
and credible human rights and labour standards.
Adopt and enforce a conversion cut-off dateof no later than 31 December 2015.91
Publish an engagement protocol for dealing
with non-compliant producers, including
trade restrictions and suspensions along with
time-bound milestones that non-compliant
producers must meet for these to be lifted.

Stop the problem
•

•

•

•

Publish and implement a plan to ensure aclean palm oil supply chain by 2020, with all
producers independently verified as compliant
with NDPE standards92 across their operations.
Monitor the producers in their supply chain atgroup level to identify deforestation and otherpolicy violations.
Report non-compliant producers to therelevant suppliers, and require them to resolve
each case in line with the brand’s engagement
protocol or to exclude the producer from their
supply chains.
Support and fund forest conservation andrestoration initiatives, along with rights
recognition and livelihoods for
local communities.
Now or never to reformthe palm oil industry•

Require independent verification that noncompliant producers have come into compliancewith NDPE standards across their operations,
including restoring all areas cleared since thebrand’s conversion cut-off date.
By 2020, require traders and other suppliers
to provide independent verification that all
producer groups in their supply chain arecompliant with NDPE standards.

Be transparent
•

•

•

•

•

Publish and maintain a comprehensive list of
all mills and producer groups whose palm oilentered their supply chain in the previous year.
Disclose annually the percentage of their palm
oil coming from producer groups whose entire
operations have been independently verified
as compliant with NDPE standards.
By the end of 2018, require suppliers topublish maps of all concessions controlled by
the producer groups in their supply chain.
Publish and maintain a list of all non-compliant
producers in their supply chain, including thetime-bound actions each is being required totake to address its non-compliance.
Report annually on the results of theirinitiatives to deliver forest conservation andrestoration and to support community
rights and livelihoods.

27

WILMAR

SIME DARBYOLAMMUSIM MASGARCARGILL

BUNGE(PREVIOUSLY IOI LC)

APICALAAL

AAK

Trader exposure todirty producer groups

ANGLO-EASTERN PLANTATIONSAUSTINDO NUSANTARA JAYABUMITAMACENTRAL CIPTA MURDAYACITRA BORNEO INDAH
DJARUMDTK OPPORTUNITYFANGIONO FAMILY / FIRST RESOURCESFELDA/FGVGAMA (FORMERLY GANDA)
GENTINGHAYEL SAEED ANAM GROUPIJM CORPORATIONINDONUSAIOI GROUP
KORINDOLEMBAGA TABUNG HAJI
NOBLE
NPC RESOURCESPOSCO DAEWOORIMBUNAN HIJAUSALIMSAMLING / GLENEALY PLANTATIONSSUNGAI BUDI GROUPTEE FAMILY / PROSPER

28

final
countdownCASE
STUDIES
29

Dirty producers
in the global
marketANGLO-EASTERN PLANTATIONS
1PT Kahayan Agro Plantation

AUSTINDO NUSANTARA JAYA
2A
2B

PT Permata Putera Mandiri
PT Putera Manunggal Perkasa

BUMITAMAPT Gunajaya Harapan Lestari
PT Hatiprima Agro
3C PT Damai Agro Sejahtera
3A
3B

CENTRAL CIPTA MURDAYA
4PT Hardaya Inti Plantations

CITRA BORNEO INDAH
5

PT Sawit Mandiri Lestari

DJARUM
6

PT Gemilang Sawit Kencana

DTK OPPORTUNITY
730

PT Lahan Agro Inti Ketapang

final
countdown

FANGIONO FAMILY

KORINDOSALIM

PT Agrindo Green Lestari
8B PT Citra Agro Abadi

15A PT Berkat Cipta Abadi

21A PT Duta Rendra Mulya

15B PT Dongin Prabhawa

21B PT Sawit Khatulistiwa Lestari

15C PT Gelora Mandiri Membangun

21C PT Rimbun Sawit Papua

15D PT Papua Agro Lestari

21D PT Subur Karunia Raya

8A

FELDA/FELDA GLOBAL VENTURES (FGV)9PT Temila Agro Abadi

GAMA (FORMERLY GANDA)
10A PT Graha Agro Nusantara
10B PT Agriprima Cipta Persada
10C PT Agrinusa Persada Mulia

GENTING
11

PT Permata Sawit Mandiri

HAYEL SAEED ANAM GROUP
12

PT Megakarya Jaya Raya

IJM GROUP
13

PT Prima Bahagia Permai

INDONUSA
14

PT Internusa Jaya Sejahtera

Now or never to reformthe palm oil industry

15E PT Tunas Sawa Erma Blok A

LEMBAGA TABUNG HAJI
16

PT Persada Kencana Prima

SAMLING
22A PT Tunas Borneo Plantations
22A Ome Ome Project

NOBLE PLANTATIONSSUNGAI BUDI GROUP

17A PT Henrison Inti Persada

23A PT Samora Usaha Jaya

17B PT Pusaka Agro Lestari

23A PT Solusi Jaya Perkasa

NPC RESOURCESTEE FAMILY

18

PT Sumber Alam Selaras

24

BOPPL

POSCO (POSCO DAEWOO CORP)
19PT Bio Inti Agrindo Blok II

RIMBUNAN HIJAU
20A Eastern Eden - Malaysia
20B Gilford - PNG

31

Anglo-Eastern
Plantations
CONCESSION:yPT Kahayan Agro
Plantation (PT KAP),
Central Kalimantan,
Gunung Mas district
W il

ma

r

Darb

s

IL
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B
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KIT T
REC P Z C U S SON
AMBLE
PROCTER & G
PEPSICOll

Bunge

API C A L

DELE

Z

RS

Between 15 February 2015 and 21
December 2017, PT KAP cleared
about 2,650ha of secondary forest.
Some of the cleared forest wasorangutan habitat.

a

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LS

GENERAL MIL

HERSHEY

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MARKET LINKS to
TRADERS AND BRANDS

br

Anglo-Eastern has a formal parent–subsidiary ownership
structure. Its executive director is John Lim Ewe Chuan.1
Anglo-Eastern is not a member of the RSPO and has
no public NDPE policy. The group does not make maps of its
concession boundaries publicly available in a usable format.
Anglo-Eastern’s 2016 annual report lists a total oil palm
landbank of 128,099ha, with 3,696ha in Malaysia and therest in Indonesia, across Sumatra, Bangka Belitung Islands
and Central Kalimantan. 62,466ha of its concessions inIndonesia are planted with oil palm.2

Clearance: 2,653ha

Group response
Greenpeace provided the group the opportunity to comment
before publication of this report. No comment was received.

Market response
Mars told Greenpeace that actions had been taken to
exclude the group from its supply chain.

32

0

2

4

6

8 KM

0
2
4M
Scale 1:400,000

final
countdown9 November 2017,
PT Kahayan Agro Plantation(Anglo-Eastern), Kalimantan,
0°55’8.525”S 113°22’16.631”E©Aidenvironment

Concession boundary based on State Forest Release Letterreference SK.534/MENHUT-II/2012.

15/02/2015

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

21/12/201733

Austindo
Nusantara
Jaya

ERS
D
A

Ca

rgi

Ol am

TR

MARKET LINKS to
TRADERS AND BRANDS

UN

ll

Bunge

REC

IL E

VE

BE
KIT T

R

NK I

SE R

AMBLE
PROCTER & G
PEPSICO
DELE

Z

s

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a

nd

LS

GENERAL MIL

HERSHEY

MO
PA
L
L GA
TE-

AL
RE
L'O
G'S
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IN Z
F T HEN
JOHNSOCOMA

NE S T L E

KR A

34

N&
JOHNSO

LI V

E

MON

br

PT Austindo Nusantara Jaya Tbk (ANJ) is family-owned
and has a formal parent–subsidiary ownership structure.
The group is majority-owned by the Tahija family,
including Commissioners George Santosa Tahija andSjakon George Tahija.1 George Santosa Tahija is a memberof the board of advisors of The Nature Conservancy(Indonesia Chapter).2
ANJ is a member of the RSPO. It has a sustainability
policy, but this is lacking in scope and substance and does notinclude a commitment to avoid deforestation.3 The groupdoes not make maps of its concession boundaries publicly
available in a usable format.
ANJ’s 2016 annual report lists a total oil palm landbank
of 157,681ha, of which 49,539ha are planted. Its eight
concessions are in North and South Sumatra, West
Kalimantan, Bangka-Belitung Islands and West Papua
provinces. ANJ also manages a 40,000ha sago forest on apeatland area just south of its oil palm concessions in West
Papua province.4
Following pressure from NGOs, ANJ announced in August
2016 that it had temporarily halted development in its Papuan
concessions.5 A letter from the company to Greenpeace
Southeast Asia in October 2016 claims that clearance wasstopped in March 2015.6 However, clearance resumed in thelatter half of 2017 (see case studies below).
ANJ’s 2016 annual report stated that it had carriedout a new set of high conservation value (HCV) andhigh carbon stock (HCS) assessments and reviewed its
approach to dealing with local communities.7 To date,new documentation in accordance with the New Planting
Procedure (NPP) has not been published on the RSPO
website for stakeholder consultation,8 despite ANJ’s
acknowledgement in the same annual report that its
original HCV assessment had failed to identify areas ofprimary forest, and the existence of government surveys
indicating peat within the concession.9
In late 2017, a coalition of NGOs asked the RSPOSecretariat to file a complaint against ANJ, citing the
final
countdown9 November 2017,
PT Kahayan Agro Plantation(Anglo-Eastern), Kalimantan,
0°55’8.525”S 113°22’16.631”E©Aidenvironment

Detail of PT PPM, August 2018
Satellite image source:
Planet Labs Inc.

evidence in the following case studies.10 The Secretariat
conducted a preliminary investigation, including a ‘visual
review’ to detect primary forest and peatland clearance
within the company’s concessions using the Indonesian
government’s indicative moratorium maps.11 It is unclear
why the Secretariat chose to use these maps, which
record only primary forest and peatland located outside
concessions that existed at the time the moratorium cameinto force. Since two of ANJ’s location permits in West Papua
province were issued before that date, these concession
areas have always been excluded from the moratorium
maps. By contrast, official Ministry of Environment andForestry landcover maps that predate ANJ’s deforestation
show extensive areas of primary forest within theconcessions, including in areas ANJ has deforested since
resuming land clearance in 2017 and 2018.
In March 2018, the RSPO Secretariat stated that it had
decided not to take any action against ANJ.12
Now or never to reformthe palm oil industry

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. On 12
September, ANJ replied, stating that it was ‘under noobligation to provide [Greenpeace] with information’ butthat if Greenpeace publishes an incorrect information about
the group, or ‘published any request for boycott or otherrestraint of trade against our Group’, it reserved its right tohold Greenpeace liable. Specifically, regarding the reported
beating of a local man by Brimob officers, ANJ stated thatthe its ‘independent investigations concluded… that thereported assault and hospitalization did not occur’. ANJ
failed to provide concession maps or other data requested.

Market response
Bunge, Mars, Reckitt Benckiser and Unilever told
Greenpeace that actions had been taken to exclude thegroup from their supply chains.

35

CONCESSIONS:PT Permata Putera
Mandiri (PT PPM) &PT Putera Manunggal
Perkasa (PT PMP),
West Papua province

Note: The neighbouring concession previously known
as PT Pusaka Agro Makmur has merged with its parent
company PT Austindo Nusantara Jaya Tbk and is now
referred to as PT ANJT. Land clearing has not commenced
in this concession. An HCV assessment on this concession
was judged ‘unsatisfactory’ by the HCV Resource Network
in October 2017.14
Forest clearance in PT PPM and PT PMP began inlate 2013 or early 2014, and satellite images show
extensive deforestation by 2015.15
Between 3 January 2015 and 16 March 2018, PT
PPM cleared 1,300ha of forest including primary forest
according to the Ministry of Environment and Forestry
2015 national landcover map.
Between 3 January 2015 and 20 March 2018,
PT PMP cleared around 2,700ha of forest, including
peatland forest within the government-determinedpeat protection zone.
In November 2017, ANJ told the awasMIFEE
website that it intends to develop 23,000ha of theconcessions over the next five years16 – it is not clear
how much of this is forest or peatland.
Both concessions have had troubled relationships
with local indigenous groups, who allege that ANJ has
cleared land without obtaining permission or giving
compensation, and that work has led to damage towatersheds, water sources running dry, destruction ofsacred sites and loss of livelihood.17 Local people werearrested and imprisoned for alleged vandalism during a

36

Clearance:
PT PPM: 1,300ha PT PMP: 2,707ha

demonstration against the plantation18 and a legal casewas brought against the company by one indigenous
group, although this was dismissed for failure to join
an indispensable party, without judgment on the
merits of the case.19 The level of conflict suggests that
ANJ did not obtain free, prior and informed consent(FPIC) for its activities from local communities before
commencing land clearance.
In September 2017 – as PT PT PPM resumed land
clearance near Puragi village – indigenous customarylandowners, who have long disputed the legitimacy
of PT PPM’s claim to have acquired their land, began
staging blockades aimed at stopping work until the
dispute could be resolved using customary laws. They
claimed ANJ had not carried out its obligation to holda decision-making meeting with the community toreach an agreement about the status of the land andcompensation for lost sources of livelihood.20
ANJ has been relying on the police mobile brigade(Brimob) as guards on the concession. Local people
allege multiple incidents of threats and violence by
Brimob guards against those protesting in October andNovember 2017, including an incident in which a man
claims to have been severely beaten with rifle butts
by three guards, requiring hospital treatment.21 The
company subsequently produced an official note statingthat it would pay the costs of treatment and an IDR
50 million (US$3,700) penalty for the beating, thoughseveral weeks later it was reported that this sum had
not been paid as promised.22
final
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03/01/2015

Concession boundaries basedon HGU maps from the Indonesian
National Land Agency (BPN),
which matches RSPO NPP.13

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

16/03/2018

Now or never to reformthe palm oil industry

37

Bumitama

Lim Hariyanto family and IOI joint venture

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The parent company of Bumitama, BAL, is registeredin Singapore and listed on the Singapore Exchange.7 From2012 onward, BGA and BSL were both 90% owned by BAL.8
Members of the Lim Hariyanto family have historicallycontrolled (and Bumitama has had operational managementof) a number of oil palm concessions outside the formal BALgroup structure9 that later passed into Bumitama ownership.10
In view of the evidence set out below, Bumitama and otherformally separate Lim Hariyanto family palm oil interests
should be seen as one group both now and historically.
Bumitama has been a member of the RSPO since2013, although one of its two subsidiaries, BGA, had joinedin 2007.11 The group adopted an NDPE policy in 2015.12
Bumitama does not make maps of its concession boundaries
publicly available in a usable format.
As of the end of 2017, Bumitama listed investments
in 32 plantation subsidiaries13 with a total landbank ofapproximately 233,000ha spread over Riau, Central
Kalimantan and West Kalimantan, 78% of which had beenplanted. The group was also operating 14 crude palm oil mills
with a total processing capacity of 5.49 million tonnes offresh fruit bunches (FFB) a year.14

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Main palm oil companies: Bumitama Gunajaya
Agro (BGA) and Bumitama Sawit Lestari (BSL),
both held by Bumitama Agri Ltd (BAL)
Bumitama1 has a formal parent–subsidiary ownership
structure. It is a joint venture (JV) between the Harita
Group, controlled by members of the Lim Hariyanto family,
and Malaysian conglomerate IOI Group. As of March 2018,
it was majority-owned by members of the Lim Hariyantofamily (52%),2 with IOI having a 32% stake3 dating from2007.4 IOI’s CEO Dato’ Lee Yeow Chor5 serves on BAL’s
board of directors and has served on the boards ofindividual Bumitama companies.6

38

On 12 April 2012, BAL launched its initial public offering(IPO) on the Singapore Exchange.15 The IPO prospectus
claimed that the company ‘owned and/or controlled ...
191,948 hectares of land’,16 though it admitted that nearly
80% of its landbank was ‘land for which title … has not been
conferred on the landholder’17 and that over 60% of thetotal comprised land where even the initial permits to obtain
land title from the current landowners (Ijin Prinsip or Ijin
Lokasi) had expired.18
Indonesian law prohibits development of land without
these and other permits (see Annex 1). Nevertheless, theIPO prospectus stated that a total of 119,162ha of land that
Bumitama claimed to own or control had been planted.19
Excluding the roughly 44,500ha to which it had title,20
final
countdown

CLEARANCE

Detail of PT DAS, August 2018
Satellite image source: Landsat 8
and Planet Labs Inc.

Bumitama appeared to implicitly acknowledge responsibility
for an area of at least 74,000ha that had been illegally or
unlawfully planted.
Analysis of corporate registry profiles suggests
Bumitama resolved this inconvenient situation through anelaborate, artificial scheme to obscure true control of anumber of concession areas and plantations which either
did not have permits or where the permits which were inplace had been revoked. The scheme was also designed tomislead the RSPO into closing associated complaints against
Bumitama. This ‘concession laundering’ was achieved bypassing nominal ownership of the concessions concerned
from members of the Lim Haryanto family or Bumitama
to apparently unrelated companies that had in fact been
established by a handful of individuals closely associatedwith the family business. The group would then acquire
the plantation companies for an insignificant sum once
the relevant permits were obtained and any complaints
had been closed.21 The arrangement enabled Bumitama
to disassociate itself from land clearing in the concessions,although in some cases, such as that of PT Golden Youth
Plantation Indonesia and PT Gunajaya Harapan Lestari(discussed below), it continued to carry out this clearing
and to manage the unlawful plantations while it was notlegally their owner, and to trade FFB and palm oil producedby them. As well as regularising the concessions’ position
with respect to Indonesian law and the RSPO, the scheme
allowed Bumitama to disassociate itself from the taintof past illegality and breaches of RSPO rules. Bumitama
subsequently joined the RSPO Complaints Panel,22 making itwell placed to hinder further investigations and complaints
about its operations.
As discussed below, two men – Djoni Rusmin and TommySantoso – were at the heart of the scheme. Bumitama has
persistently denied any connection with Rusmin and Santoso
in its announcements of company acquisitions: these statethat the pair are ‘a third party’,23 that they are ‘individuals
who are unrelated to the Group’24 or that ‘none of the
Now or never to reformthe palm oil industry

directors or controlling shareholders of [Bumitama Agri Ltd]
has any direct or indirect interest in the Acquisition’.25 When
Greenpeace challenged Bumitama about its connection withthe pair in early 2017, the company claimed the relationshipwas coincidental: ‘Tommy Santoso and Djoni Rusmin are Oil
Palm developers and the former shareholders of PT LMS,
who sold the company to Bumitama because of financial
constraints. They also happened to be the shareholders of
PT DAS.’26 However, at least ten plantation companies havepassed through Rusmin and/or Santoso’s hands before beingbought by Bumitama – nearly one-third of the 32 plantations
Bumitama declares in its 2017 annual report.

Group response
Greenpeace provided Bumitama and, separately, IOI the
opportunity to comment before publication of this report. On
7 September, Bumitama replied, stating that while ‘Bumitama
refutes the claims that the acquisition of the mentioned[plantation companies] would be a part of a scheme designed
to allow Bumitama to regularise illegality, allow land clearing,
mislead the RSPO or defraud our investors’, it would ‘reflect
on this method of company acquisition, and ... review andupdate our procedure via the Investment Committee’. The
group failed to provide concession maps for its operations.
On 12 September, Dato’ Lee Yeow Chor, CEO of IOI and
non-executive director of Bumitama, replied acknowledging
that IOI would have some responsibility for ‘any major
malpractice by Bumitama’ and that personally he has ‘a dutyof oversight’ for ensuring ‘that the company complies with thelaws of the country and the commitments which are spelt out
in the company’s Sustainability Policy’. He emphasised that IOI
was willing ‘to put pressure on Bumitama’s management as a
substantial shareholder’ and would ‘welcome any advice fromGreenpeace or other NGOs on how to exert more pressure’.

Market response
Mars told Greenpeace that actions had been taken to exclude
the group from its supply chain.

39

10 December 2016,
PT Damai Agro Sejahtera (Bumitama),
1°35’10.001”S 110°19’30”E©Irmawan/Greenpeace

40

final
countdown

Now or never to reformthe palm oil industry

41

CONCESSION:PT Gunajaya Harapan
Lestari (PT GHL),
West Kalimantan,
Ketapang district

15 July 2018
Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

PT GHL is a plantation company owning a concession on Bawal
Island off West Kalimantan. The company was founded in
February 2007 by members of the Lim Hariyanto family.27
It has always shared the same registered Jakarta address as
BAL’s Indonesian office.28
From 1 January 2011 until 31 July 2014 Bumitama
assumed formal operational management of the concession,under the GHL Cooperation Agreement.29 Mapping shows
significant forest clearance and plantation development
between 2010 and 2013 within and beyond the concession
boundaries, even though the concession did not yet have allits legal permits. PT GHL finally acquired a plantation businesspermit (IUP; see Annex 1) on 11 September 2013, five years
after the initial location permit30 and after the majority of theplantation development was completed. Under ministerial
regulations, the concession area should have been forfeited
because a location permit expires after three years and can
only be extended one further year.31
Under the terms of the GHL Cooperation Agreement,

42

Bumitama had the right to buy the concession from membersof the Lim Hariyanto family. However, it announced in July 2014
that it would not exercise this option nor continue managing theconcession, citing Indonesian regulations that restricted foreigncompanies from owning land on small islands.32
Then, in September 2014, PT GHL was sold to PT Selaras
Hijau Sentosa, a company established by Bumitama-linked
nominees Rusmin and Santoso. The plantation was repurchasedby companies owned by members of the Lim Hariyanto family
in June 2015.33 From May 2012 until November 2015, PT
GHL was under the management control of another pair ofstand-ins connected to the Lim Hariyanto family,34 whose
management bridged the ownership periods of members of
the Lim Hariyanto family, Rusmin/Santoso and the company’s
return to Lim Hariyanto family interests.
The PT GHL plantation was brought into the Bumitama
portfolio in January 2016.35 By the time of its official
acquisition in 2016, Bumitama claimed some 2,982ha had beencultivated.36 No HCV assessment is in the public domain.
final
countdown

CONCESSION:PT Hatiprima Agro37 (PT HPA),
Central Kalimantan

PT HPA is a 4,800ha concession in Central Kalimantan.
IOI’s current CEO Dato’ Lee Yeow Chor became theCommissioner of PT HPA when Bumitama took overownership from members of the Lim Hariyanto family
on 28 January 2008,38 and he remained in the post
until 22 March 2012,39 a period during which thecompany engaged in substantial illegal deforestation.
In March 2008, the Ministry of Forestry revoked
the State Forest Release Letter for PT HPA for failure
to obtain the necessary agreements from communities
and land cultivation right (HGU; see Annex 1) overthe forest release area.40 Despite the minister’s orderto halt all activities and remove its equipment,41 thecompany continued to clear and develop its concession
during 2010–2012.42 Then, in April and June 2012, thelocation and plantation business permits were revokedby the local authorities.43
PT HPA’s illegal development led NGO Sawit
Watch to lodge a complaint with the RSPO.44 In
December 2012 the RSPO ordered Bumitama tocease all work in the concession until the complaint
was resolved.45 PT HPA challenged the revocations,but the Indonesian Supreme Court ultimately upheld
them in December 2013,46 leaving Bumitama with nofurther claim on the land or the plantation.
On 15 November 2013, just before the Supreme
Court announced its verdict, Rusmin and Santoso
established a new plantation company, PT Langgeng
Makmur Sejahtera (PT LMS).47 In August 2014
Bumitama announced that it had lost the case andthreatened to sue the district head.48 That same month,
PT LMS applied to the same district head for a location
permit covering the same area as PT HPA. By late 2014,
PT LMS had acquired both a location permit49 and aplantation business permit.50
In January 2015 Bumitama announced that it would
sell PT HPA’s assets, including the immovable assets
embodied in the palm plantings, to PT LMS in return fora payment of approximately IDR 400 billion (US$32m).51
Now or never to reformthe palm oil industry

Shortly after this, Bumitama successfully applied to havethe RSPO complaint against it closed on the grounds thatit no longer controlled the concession.52
With the complaint closed, Bumitama bought theplantation back again the following year: in June 2016
Bumitama announced that it had purchased 95% of PT
LMS for just IDR 250m (approximately US$18,500),53
less than a thousandth of the sale price PT LMS had
agreed to pay Bumitama the previous year. This was
remarkably good value, given the business now had avalid location permit and plantation business permit.
Bumitama subsequently admitted that purchasemonies never passed from PT LMS to Bumitama
during the approximately 18-month nominal controlof the concession by Rusmin and Santoso.54 Bumitama
omitted from its announcement of the acquisition to
the Singapore Stock Exchange any mention of previous
Lim Hariyanto and Bumitama ownership of the estatethrough PT HPA. It finally obtained an HGU certificate forthe concession in January 2017.55
Bumitama appears to have continued to manage
the estate during its time under Rusmin and Santoso’s
nominal ownership.56 This suggests the transactions
between Bumitama and PT LMS were a premeditatedarrangement to ensure the closure of the RSPO
complaint, to limit any negative impact on Bumitama’s
public share value, and to enable Rusmin and Santoso to
procure new permits to legalise Bumitama’s control of
the illegally developed area.
Following a request from Sawit Watch, Greenpeace
and the Environmental Investigation Agency, the
RSPO Complaints Panel decided to reopen the PT
HPA complaint on 21 November 2017.57 In May 2018
the panel directed the RSPO Secretariat to appoint athird-party expert to conduct an independent review ofrelated permits of PT HPA.58
Bumitama acknowledges that ‘the development of
HPA has not been compliant with the RSPO NPP’ and that
there will be RSPO sanctions against PT LMS.59

43

CONCESSION:PT Damai Agro
Sejahtera(PT DAS), West
Kalimantan

Concession boundary basedon AMDAL BUPATI KETAPANG
No.27/PEM/2016.

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

Clearance: 1,442ha

PT DAS was founded by Rusmin and Santoso on 15
November 2013, the same day they founded PT LMS.60
In January 2016, PT DAS was granted a location
permit covering some 9,400ha,61 which included
over 1,000ha of oil palm plantation developed by
PT Golden Youth Plantation (PT GYP), owned bymembers of the Lim Hariyanto family since 2011.62
As with the other cases described here, the plantation
was illegal because PT GYP had failed to obtain thenecessary permits.
Between July 2015 and 10 April 2018, there wassome 1,450ha of deforestation within what would
become the PT DAS concession, including peatland
forest within the government-determined peat
protection zone. Most of this occurred in 2016. Field
evidence suggests Bumitama remained informally
responsible for the management of this area evenafter a public statement in 2014 officially ending
its involvement.63. Greenpeace field investigations
found that a nursery servicing PT DAS was locatedwithin a neighbouring palm oil concession owned by
Bumitama. Other evidence of Bumitama’s longer-term
involvement includes marker stakes, security posts
and a company signboard in the area, all marked BGA(ie Bumitama).64

44

On 20 December 2016, just four months
after Rusmin and Santoso finally obtained aplantation business permit for PT DAS, Bumitama
announced that it had bought the concession.65 In
a news release issued six months later, it claimed
that the reason for its acquisition was the impact
the company’s deforestation was having on
Bumitama’s efforts to build an orangutan corridor
in a neighbouring concession.66
In announcing its purchase of PT DAS, Bumitama
made no mention of the Lim Hariyanto family
and Bumitama’s long-term history with the area.
Bumitama did not acknowledge having formallymanaged the illegal PT GYP plantation, nor thatit had processed and traded FFB from that illegal
plantation during its formal management period
and subsequently. Rusmin and Santoso were again
described as ‘unrelated’ to Bumitama and the Lim
Hariyanto family,67 although this was by no means the
only concession that had been traded between them.
The total sum paid by BSL (90%) and the Lim
Hariyanto company PT KMS (10%) for the 9,436ha PT
DAS concession was a mere IDR 250m (approximately
US$18,500)68 – the same low amount Bumitama had
paid Rusmin and Santoso for PT LMS.
final
countdown

11 December 2016, PT Damai Agro Sejahtera(Bumitama), Kalimantan, 1°30’27.774”S
110°15’46.121”E ©Ifansasti/Greenpeace

23/06/2015

11 December 2016, PT Ladang Sawit Mas (Bumitama),
Kalimantan, 1°32’20.856””S 110°18’58.122””E©Ifansasti/Greenpeace

10/04/2018

10 December 2016,
PT Damai Agro Sejahtera (Bumitama),
Kalimantan,
1°34’55.847”S 110°20’4.242”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

45

Central
Cipta Murdaya
Murdaya family

Main palm oil company:
Hardaya Plantations Group

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This is a family group in which formally separate
companies owned by members of the same family shareoperational or managerial control.
Informally known as Hardaya Plantations Group(HPG), it is owned by the Murdaya family, including
Siti Hartati Murdaya (CEO and co-founder), Murdaya
Widyawimarta Poo (co-founder, her husband) and theirsons Karuna Murdaya (director and head of palm oil
operations in Papua province and Sulawesi) and Prajna
Murdaya.1 In February 2013, Siti Hartati Murdaya wassentenced to 32 months in prison and fined IDR 150
million (equivalent to US$15,000) for bribing the former
regent of Buol district, Central Sulawesi, to get permits
for the PT Hardaya Inti Plantations (PT HIP; see below) oil
palm concession in Sulawesi.2
Neither Central Cipta Murdaya (CCM) nor HPG is amember of the RSPO and neither has a public NDPE policy.
Neither CCM nor HPG makes maps of its concession
boundaries publicly available in a usable format.
Aidenvironment has identified around 145,000ha inat least five HPG concessions, of which 82,600ha are
in Papua province (based on location permits) and theremainder in North Kalimantan and Central Sulawesi.3

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. No comment
was received.

Market response
Mars told Greenpeace that actions had been taken to
exclude the group from its supply chain.

46

final
countdown

CONCESSION:PT Hardaya Inti
Plantations (PT HIP),
Central Sulawesi,
Buol district

Clearance: 434ha

Between 26 December 2014 and 8 March 2018, PT
HIP cleared 434ha of forest, including primary forest
according to the Ministry of Environment and Forestry
2015 national landcover map.

26/12/2014

08/03/2018

Concession boundary basedon HGU map from regional
government.

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

47

Citra Borneo
Indah
Abdul Rasyid–associated

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Main palm oil companies: PT Sawit Sumbermas
Sarana and others
The Citra Borneo Indah group has a formal parent–subsidiaryownership structure, which encompasses PT Citra Borneo
Indah and its subsidiaries, including its principal plantation
subsidiary PT Sawit Sumbermas Sarana (PT SSMS) andthe subsidiaries of that company.1 Citra Borneo Indahis controlled by tycoon Abdul Rasyid, who has been
described as a ‘former illegal logging kingpin’;2 Rasyid’s
nephew Sugianto Sabran became the governor of Central
Kalimantan in 2016,3 and in May 2017 Rasyid’s sister-in-law,
Nurhidayah, was elected head of West Kotawaringin districtof Central Kalimantan.4
Citra Borneo Indah is not a member of the RSPO andhas no NDPE policy. Its subsidiary PT SSMS is an RSPO
member (and as a result of the wider Citra Borneo Indahgroup’s non-membership is in violation of the RSPO’s rules
on group membership5) and has recently published an NDPE

48

policy.6 Neither of these companies makes maps of its
concession boundaries publicly available in a usable format.
PT SSMS’s 2016 Annual Communication of Progress(ACOP) submission to the RSPO reported a total landbank
of 62,339ha, with 44,513ha of this planted.7 However,in its 2016 annual report the company claims a total
landbank of 96,040ha and a planted area of 70,125ha.8
The data in the annual report match closely with
Greenpeace mapping analysis, suggesting that PT SSMS
is underreporting its landbank to the RSPO. All estates arelocated in Central Kalimantan.
In December 2015, PT SSMS sold two of its plantationcompanies, including PT Sawit Mandiri Lestari (PT SML;
see case study below),9 meaning the concessions would
no longer be subject to the RSPO’s Principles and Criteria.
At the time, there was an RSPO complaint pending on PT
SML, initiated by the NGOs Environmental Investigation
Agency and JPIK Kalteng.10 PT SML is presently 60%
owned by Rinawati,11 apparently linked to Citra Borneo
Indah.12 The other 40% of PT SML is owned by Hamidi
Mukhdar Said, reportedly also known as H Hamdhani,
who is a member of Commission VI of the House ofRepresentatives of the Republic of Indonesia,13 and apolitical ally of Abdul Rasyid’s nephew, Governor SugiantoSabran. The director mentioned in the corporate registry
profile for PT SML, Ramzi Sastra, is also the commercial
director of PT SSMS and the address of PT SML is thesame as the address of another of PT SSMS’s plantationcompanies.14 This suggests that the Rasyid family still has
control over PT SML’s operations.
In January 2018 PT SSMS claimed that ‘TFT has accepted
SSMS as their newest palm oil grower member’.15 Threemonths later, another company within the Citra Borneo
Indah group (PT BSG; see case study below) was accused ofdeforestation and peatland development.16

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. No comment
was received.

Market response
Bunge, Mars, Reckitt Benckiser and Unilever told
Greenpeace that actions had been taken to exclude thegroup from their supply chains.
final
countdown

CONCESSION:PT Borneo Sawit
Gemilang (PT BSG),
West Kalimantan
In April 2018, Forest Hints, the semi-official news
website of the Indonesian Ministry of Environment
and Forestry,17 accused PT Citra Borneo Indahsubsidiary PT BSG18 of deforestation and peatland
development.19 According to Forest Hints, PT BSG
began clearing and developing its concession in
December 2017.
Forest Hints released pictures, apparently takenon 20 April 2018, showing excavators clearing forest
and an extensive canal network seemingly draining
peatland to prepare it for planting. It claimed thearea forms part of the peatland protection zone andhas been identified for restoration by the Peatland
Restoration Agency (Badan Restorasi Gambut; BRG).20
Any such development would violate Indonesianlaw and corporate NDPE policies, including thesustainability commitments made by PT BSG’s sistercompany PT SSMS in September 2017.21
In May 2018 PT SSMS acknowledged being
part of the same group as PT BSG, and confirmedthat as ‘SSMS’s sustainability commitments reflect
those of our parent company’, PT BSG (and byinference, all other Citra Borneo Indah groupcompanies) should be held to the same standards.22
PT SSMS also claimed to have conducted a field
investigation which determined not only that ‘thealleged development’ was carried out by PT BSG but
that it ‘took place outside BSG’s permit [area]’.23 If true,
this would be a further violation of Indonesian law.
PT SSMS claimed that PT BSG had cleared thearea ‘at the request of the local communities’,24 a factdisputed by Forest Hints, which alleges to have been
told by employees of the company that the clearance
was ‘to develop new palm oil plantations for PT BSG’.25

Now or never to reformthe palm oil industry

49

CONCESSION:PT Sawit Mandiri
Lestari (PT SML),
Central Kalimantan,
Lamandau district
Clearance: 6,243ha

Between 10 March 2015 and 14 February 2018,
PT SML cleared 6,243ha of secondary forest.
The cleared forests were orangutan habitat.

Concession boundary based on
State Forest Release Letterreference 1/1/PKH/PMDN/2015
and RSPO NPP.26

50

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown10/03/2015

14/02/2018

20 May 2016,
PT Sawit Mandiri Lestari (Citra Borneo Indah), Kalimantan,
1°54’26.52”S 111°13’51.41”E©Aidenvironment

Now or never to reformthe palm oil industry

51

Djarum

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Main palm oil company: PT Hartono
Plantations Indonesia, also known as HPI Agro
Djarum is family-owned and appears to have a formalparent–subsidiary ownership structure. The groupis owned by brothers Robert Budi Hartono (CEO)and Michael Hartono, the richest men in Indonesia
in 2016.1 Djarum is best known as a kretek cigarettemanufacturer but also has banking and otherinterests, including Indonesia’s third largest bank bytotal assets, Bank Central Asia (BCA).2
Neither Djarum nor HPI Agro is an RSPO member,and the group has no public NDPE policy. The group52

does not make maps of its concession boundaries
publicly available in a usable format.
Aidenvironment has identified an oil palm
landbank of more than 100,000ha linked to thegroup, all in West Kalimantan, mostly in Landak
district.3
In August 2018, a report by a coalition ofIndonesian NGOs revealed that two pulpwood
concessions in East Kalimantan owned by the Hartono
family have cleared approximately 32,000ha since2013 (9,500ha since 2016).4 The clearance isreportedly to supply a new pulp mill in the province.5
final
countdown

18 January 2016,PT Gemilang Sawit
Kencana (Djarum), Kalimantan,
0°12’56.53”N 109°42’11.91”E©Aidenvironment

Group response
Greenpeace provided the group the opportunity
to comment before publication of this report.
On 12 September, Djaru/HPI Agro replied,stating that it had not cleared any peat within thegovernment-determined peat protection zone,
although not denying peatland clearance. Moregenerally, regarding NDPE violations, ‘this year
the Company had committed to implement the
NDPE into its sustainability policy. However werealized that the fully adjustment of NDPE policy
into the Company’s policy requires time andNow or never to reformthe palm oil industry

process.’ The group failed to provide concession
maps for its operations.

Market response
Mars told Greenpeace that actions had beentaken to exclude the group from its supply chain.

53

CONCESSION:PT Gemilang Sawit
Kencana (PT GSK),West Kalimantan,
Landak district

Clearance: 1,092ha

04/05/2015

54

final
countdown

Between 4 May 2015 and 10 April 2018, PT GSK
cleared 1,100ha of peatland forest, including within thegovernment-determined peat protection zone.

Concession boundary basedon information from theEnvironmental Office ofLandak and the Ministry ofForestry6 and analysis ofclearing pattern.

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

10/04/2018

Now or never to reformthe palm oil industry

55

DTK
Opportunity

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DTK has a formal parent-subsidiary ownership structure.
However, its ultimate ownership and control are obscured
by registration in the British Virgin Islands.1 Some of its
concessions were previously part of the RGE Group,
which also includes pulp giant APRIL. Some plantations areoperated or managed by Acapalm.2
In 2014, the president/director of DTK concession PT
Archipelago Timur Abadi (PT ATA) was sentenced to 10
months in prison and a fine of IDR 2 billion (approximately
US$170,000) by the Palangkaraya District Court because
PT ATA had developed its plantation without a plantation
business permit (IUP; see Annex 1).3
DTK is not a member of the RSPO and has no public
NDPE policy. The group does not make maps of its
concession boundaries publicly available in a usable format.
Aidenvironment has identified a landbank of 133,000ha
in 11 DTK concessions in Papua and Kalimantan, with around65,000ha planted.

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. On 12
September, DTK Opportunity replied, stating that ‘[w]e arestill in an infant stage in the area of sustainability’ and ‘[i]nrecent months, we took the business decision to sell off PT
LAIK. It is no longer part of DTK.’ Further, it claimed to havestopped its own clearance within that concession in October
2017, following meetings with Aidenvironment. The groupfailed to provide concession maps for its operations.

Market response
Mars, Nestlé and Wilmar told Greenpeace that actions had
been taken to exclude the group from their supply chains.

56

final
countdown

CONCESSION:PT Lahan Agro Inti
Ketapang (PT LAIK),West Kalimantan,
Sambas district
Between 14 July 2015 and 16 March 2018 PT LAIK
cleared around 2,050ha of forest, including peatland
forest within the government-determined peat protection
zone. Despite a stop work order by Apical in January
2017,5 the company continued clearing in 2017. Some of
the cleared forests were orangutan habitat.

14/07/2015

Clearance: 2,048ha

16/03/2018

Concession boundary based on
information from provincial
plantation office West
Kalimantan and NPP map for aneighbouring concession ofanother company group, PT
Musim Mas.4

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

57

Fangiono
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Main palm oil companies: First Resources,
PT Fangiono Agro Plantation and the
Ciliandry Anky Abadi group

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brMartias Fangiono (Martias)1 was a major player in theIndonesian timber business during and after the Suharto era.
He was also the founder of the logging and palm oil company
PT Surya Dumai Industri (PT SDI), which is presently inactive.
Children from Martias’s first and second marriages
control a number of ostensibly separate producer
companies. However, a review of corporate registry profiles
highlights numerous connections between these companies,
including shared addresses and overlapping management.
The full picture is obscured by the unusual refusal ofIndonesian government officials to disclose corporate
registry profiles for some companies controlled by membersof the family. In the absence of full disclosure, and given theevidence of close connections, brands and traders should
consider First Resources and other companies controlled
by members of the extended Fangiono family to be one
group for the purposes of compliance with NDPE policies,
unless and until the producer companies have been able tosatisfactorily demonstrate that they operate independently
from one another.
First Resources is a spin-off of Surya Dumai. Its current
CEO is Martias’s son from his first marriage, Ciliandra
Fangiono. Martias has no official function within First
Resources.2 As of March 2018, 70% of First Resources
was owned by discretionary trusts presumably linked to
the Fangiono family.3 In a statement of 12 July 2018, First
Resources stated that Ciliandra Fangiono and his siblings
were the controlling shareholders of First Resources.4
final
countdownOther palm oil interests of the family include the Ciliandry
Anky Abadi (CAA) group and PT Fangiono Agro Plantation(PT FAP). As of June 2018, the CAA group was owned byMartias’s second wife, Silvia Caroline, and her presumed
children living at the same residential address, Ciliandry
Fangiono (not to be confused with Ciliandra) and Wiras Anky
Fangiono.5 PT FAP is 95% owned by Prinsep Management
Ltd, a trust based in the British Virgin Islands, and 5% by
PT Fangiono Perkasa Sejati (PT FPS), a company owned byWirastuty and Ciliandrew Fangiono (Ciliandra’s siblings)6
and Matthew Fangiono (believed to be Ciliandra’s nephew),7
which is also one of the parent companies of PT SDI.8 In its
2007 prospectus for the Singapore Exchange, First Resources
attributed a 94% interest in PT FAP to Irawaty, Martias’s
former wife and Ciliandra’s mother.9 The evidence for thesevarious palm oil interests constituting a single family group is
set out in the box below.
In December 2007, Martias was sentenced to 18 months’
imprisonment after being found guilty of collaborating with
the East Kalimantan governor (among others) in an illegal
logging scam during the period 1999–2002.10
First Resources is an RSPO member, but PT FAP and the
CAA group are not. First Resources adopted an NDPE policy in
July 2015; this applies to ‘associates’ and third-party suppliers.11
The CAA group has no NDPE policy. PT FAP has, according toFirst Resources, agreed to observe First Resources’ HCS policy
as a supplier.12 None of these companies makes maps of its
concession boundaries publicly available in a usable format.
First Resources reports 208,691ha of planted area inIndonesia, in Riau and East and West Kalimantan.13 Greenpeace
mapping suggests that it has a total landbank of 234,000ha.
Now or never to reformthe palm oil industry

3 December 2015, PT Limpah Sejahtera(Fangiono–First Resources), Kalimantan,
1°46’7.931”S 110°13’45.246”E©Ifansasti/Greenpeace

Aidenvironment has identified a landbank of more than
128,000ha held by the CAA group – mostly in Central
Kalimantan but with one concession in Riau – with a plantedarea of approximately 20,000ha. PT FAP holds a landbank of atleast 140,000ha in Kalimantan, of which more than 80,000ha
are planted. Taken together with Sulaidy’s interests of some
65,000ha, this means the Fangiono family’s landbank andlinked interests may cover an area of 540,000 – 565,000ha.

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. No comment
was received.

Market response
AAK, Bunge, Johnson & Johnson, Mars, Nestlé, Reckitt
Benckiser, Unilever and Wilmar told Greenpeace that actions
had been taken to exclude the group from its supply chain.

59

Evidence of links
between the Fangiono
family’s palm oilinterests
First Resources has emphasised that neither Ciliandra
Fangiono nor those of his siblings who are controllingshareholders of First Resources have any interest in PT
CAA, the holding company of the CAA group.14 First
Resources has also stated that ‘FAP Agri is not a subsidiaryor an associated company of First Resources’.15 However, areview of corporate registry profiles highlights numerous
connections between First Resources, the CAA group, PT
FAP and their subsidiaries. In terms of the Fangiono family
itself, the ownership or senior management crossover
between the business interests of the offspring of Irawaty
and those of the offspring of Silvia Caroline is confined
to Martias. The major identifiable overlap is throughinfrastructure (shared office premises) and the roles played
by a handful of Martias’s long-term business colleagues
in supporting the young Fangionos in establishing andmanaging their business empire.

Wisma 77 as clearing house
The 2007 prospectus for First Resources (see above) statesthat the registered office for its main subsidiary holding
company, PT Ciliandra Perkasa is ‘Wisma 77, 7th Floor, Jl
Letjend S. Parman Kav. 77, Slipi, Jakarta 11410, Indonesia’.16
The address is confirmed by the company’s current
Facebook page17 and other social media sites, though othersources indicate it is now at APL Tower (see below).
Corporate registry profiles show that numerous othercompanies linked to both sides of the Fangiono family havebeen registered at that address, including:• PT CAA from 1 July 2008 to 15 March 2016, inaddition to various of its plantation companies atdifferent times• PT FAP from 4 November 2008 until at least 16
November 2017 (the date for the most recently
obtained corporate registry profile) and several of its
plantation companies and shareholder companies:–	PT Borneo Bhakti Sejahtera (a PT FAP plantationcompany) from 28 May 2008 until at least 11
January 2017
–	PT Bumi Khatulistiwa Kencana (a recent
shareholder of PT FAP still holding shares in the
PT FAP plantation company PT Riau Agung Karya
Abadi) from at least 9 September 2015 to thepresent, according to the PT RAKA corporate
registry profile

60–	PT Tirta Madu Sawit Jaya (a PT FAP
plantation company) from 11 April 2008
to at least the end of 2016, as well as PT
Karangjuang Hijau Lestari, the company
acting as the majority shareholder of PT
TMSJ for the same period• PT Citra Palma Pertiwi (a plantation company
forming part of the Sulaidy cluster – see
below) from 14 June 2012 until at least 17
November 2016
• PT SDI from 27 June 2008 to 17 June 2016,
in addition to its then parent companies PT
Fangiono Jayaperkasa and PT FPS, according to
the PT SDI corporate registry profile.18
Floor 7 of Wisma 77 was also given as Ciliandry
Fangiono’s residential address while he was ashareholder of PT Citra Palma Pertiwi from 14 June2012 until 28 August 2014.

APL Tower as clearing house
The 2011–2012 Annual Communication of Progressto the RSPO by First Resources provides its contact
address as APL Tower – Central Park, 28th Floor,
Podomoro City, Jl Letjend S. Parman Kv 28, GrogolPetamburan, Jakarta Barat 11470, Jakarta.19 Thissame address is the contact address listed on the First
Resources website.20
Corporate registry profiles show that other First
Resources and Fangiono family interests are registeredat that address, including (according to some profiles)family holding company PT FPS, former part-owner of
PT SDI and current part-owner of PT FAP.

The Sulaidy cluster
Floor 28 of APL Tower is also the registered addressof the holding company PT Persada Prima Agro
Mandiri (PT PPAM), which until 25 June 2018
had a JV with First Resources but was otherwise
superficially unrelated to the Fangiono family, as well
as of the six plantation companies21 held by the JV
holding company PT Setia Agrindo Jaya; on that date,
First Resources announced that one of its indirect
subsidiaries now held 99.61% of the shareholding.22
The move came four days after the publicationof a report by Chain Reaction Research on the
final
countdownthreat posed to NDPE efforts by so-called ‘shadow
companies’,23 which featured the Fangiono family.
Together with another partner, the controllingshareholder of the JV had been an individual called
Sulaidy,24 who has been linked to many Fangiono familyinterests as both a senior manager and a shareholder(including owning 5% of PT FAP from its foundation
until July 2010, when his share was taken over by PT
Fangionoperkasa Sejati). Corporate registry profiles
from 2016 and 2017 reveal Sulaidy as a controllingshareholder of at least five other companies with nocurrent shareholder or managerial link to the Fangiono
family. Key among these is PT Bangka Bumi Lestari (PTBBL), which is the holding company of the remaining
four, as follows:• PT Borneo Citra Persada Abadi• PT Citra Palma Pertiwi (PT CPP)
• PT Palmdale Agroasia Lestari• PT Setia Agro Abadi (PT SAA).
These companies’ concessions are thought tocover some 65,710ha. While the registered addressfor PT CPP is Wisma 77, Floor 7 (see above), themost recent known address for PT BBL and PT SAA
is APL Tower, 28th–29th Floor. These companies
also historically share management or shareholder
links with individuals associated with Fangiono familyinterests and discussed below. First Resources’buyout of PT PPAM’s stake in PT Setia Agrindo Jaya
may have been designed to obscure the family’s links
to these companies.

Management crossover
According to corporate registry profiles, current or
recent senior managers or shareholders of PT CAA andits subsidiaries are also linked to the business interestsof Martias’s children by his first marriage, PT FAP andFirst Resources – in the latter case notably throughSulaidy, First Resources’ JV partner. The individuals
concerned include:• Ciliandry Fangiono• Citra Gunawan• Edward Utomo• Lau Cong Kiong• Martias
Ciliandry Fangiono, a current shareholder of
PT CAA, held a minority shareholding in the Sulaidy
plantation company PT CPP until 28 August 2014.
Citra Gunawan has historically played amanagement role within PT CAA; he is the current
Commissioner of CAA group subsidiary PT Agrindo
Green Lestari. He was the original Managing Directorof PT FAP and has historically held senior management
positions with the PT FAP companies PT Borneo Bhakti
Sejahtera, PT Bulungan Hijau Perkasa and PT Tirta
Madu Sawit Jaya. His links to First Resources include
historic management positions in the Sulaidy plantationcompanies PT CPP and PT SAA. He was President
Director of Martias’s apparently dormant company PT
Now or never to reformthe palm oil industry

SDI (from which First Resources was established) until
at least 12 January 2017 (the date of acquisition on themost recent corporate registry profile).
Edward Utomo has historically held senior
management positions within PT CAA and PT Agrindo
Green Lestari, as well as within the PT FAP company PT
Setia Agro Utama. His links to First Resources include
historic management positions in the Sulaidy plantationcompanies PT CPP and PT SAA.
Lau Cong Kiong was for several years (until 2011)a minority owner of CAA group subsidiary PT Citra
Agro Abadi and also played a senior management role
within that company as well as CAA group subsidiary
PT Heroes Green Energy. He was the original Chief
Commissioner of PT FAP and has historically held senior
management positions with its subsidiaries, including
PT Borneo Bhakti Sejahtera, PT Bulungan Hijau Perkasa,
PT Setia Agro Utama and PT Tirta Madu Sawit Jaya.
His links to First Resources include being the current
Commissioner of First Resources subsidiary PT Ciliandra
Perkasa.25 He is also associated through historic senior
management roles with the Sulaidy companies PT BBL,PT Borneo Citra Persada Abadi, PT PPAM and PT SAA.
Martias has been directly linked as a shareholder
at one time or another to various companies acrossthe different Fangiono family interests, including PT
SDI; PT FAP subsidiaries PT Borneo Bhakti Sejahtera,
PT Bulungan Hijau Perkasa and PT Tirta Madu Sawit
Jaya (as well as the latter’s former parent company PT
Karangjuang Hijau Lestari); and PT CAA along with its
subsidiary PT Citra Agro Abadi.

Blocked corporate registry profiles –an additional barrier to transparency
Government officials have obstructed Greenpeacein its attempt to confirm current links between First
Resources and other Fangiono family interests.
Requests for a raft of corporate registry profiles for
Sulaidy-linked companies and PT FAP subsidiaries havebeen blocked by the Directorate General of Public Law
Administration, and officials have refused to disclose
whether this was at the request of shareholders or
because of a government investigation. Despite theinformation being normally available to the public upon
payment of a fee, staff claimed that the organisation
was afraid Greenpeace might ‘misuse’ it. Such denialof access to registry profiles and the refusal toexplain why they are blocked hinders the efforts ofGreenpeace and other stakeholders to track ultimate
beneficial ownership both within and across companies.
The blocked registry profiles include those for:• PT Bangka Bumi Lestari• PT Borneo Bhakti Sejahtera• PT Borneo Citra Persada Abadi• PT Citra Palma Pertiwi• PT Marsam Citra Adiperkasa• PT Setia Agro Abadi• PT Setia Agro Utama.

61

CONCESSION:PT Agrindo Green
Lestari (PT AGL) andPT Citra Agro Abadi,
Central Kalimantan,
Pulang Pisau district

Clearance
PT AGL: 3,542ha
PT CAA: 653ha

02/07/2015

62

final
countdown

Between 2 July 2015 and 31 January 2018, CAA
group subsidiary PT AGL cleared around 3,550haof secondary forest. Some 650ha of forest,
including orangutan habitat and potential peatland
forest, were also cleared in a concession locateddirectly south of PT AGL’s run by another CAA
group subsidiary, PT Citra Agro Abadi.

Concession boundary based on State Forest Release Letter reference
SK.586/MENHUT-II/2014.

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

31/01/2018

Now or never to reformthe palm oil industry

63

FELDA/
Felda Global
Ventures (FGV)

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FELDA is Malaysia’s government-owned Federal Land
Development Agency. FGV, formerly the commercial
arm of FELDA, is now a publicly traded company,
though FELDA remains the largest shareholder.1
FELDA and FGV are members of the RSPO. FGV
announced an NDPE policy in 2016.2 FELDA holds
influential positions in the RSPO, including on the boardof governors3 and the task force reviewing the RSPO’s
Principles and Criteria.4 The group does not make mapsof its concession boundaries publicly available in a
usable format.

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According to its 2016 annual report, FGV holds a
total landbank of 440,662ha, 418,044ha in Malaysia and22,578ha in Indonesia5 (6,712ha of this planted6).
It also holds 42,000ha in Indonesia under a joint venturewith Lembaga Tabung Haji (see case study below) called
Trurich Resources Sdn Bhd.7 Its wholly owned Indonesianconcessions are in West Kalimantan.8
Extensive labour rights abuses have been documented
in FGV’s Malaysian operations, including workers having to
pay recruitment fees and having their passports retainedby the company.9 Following media reports10 and an RSPO
complaint, FGV withdrew its 58 mills from the RSPO
certification scheme in May 2016.11

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. On 13
September, FGV replied, stating that FGV and FELDA are
two different companies. It claims that to make maps ofits Malaysian concessions public would violate Malaysianlaw, but that its Indonesian concession maps have been
submitted to the RSPO for public view. ‘No labour rights
violations have been documented or reported in any of
FGV’s concessions. FGV no longer practices the retainingof passports of foreign guest workers.’ In relation to PT
TAA, the company claims that no development has takenplace since April 2017; consequently, 4,000 families
who had welcomed ‘the exciting prospect of economic
development … are still waiting for an opportunity to lift
them out of poverty, and to allow them the opportunity
for a better life.’ It claimed to have fully implemented
a peatland restoration plan imposed by the Ministry ofEnvironment and Forestry.

Market response
Apical, Ferrero and Unilever told Greenpeace that
actions had been taken to exclude the group fromtheir supply chains.
final
countdownApril 2017,
PT Temila Agro Abadi(FELDA), Kalimantan,
0°3’51.45”N; 109°38’43.17”E©Aidenvironment

Now or never to reformthe palm oil industry

65

CONCESSION:

PT Temila Agro
Abadi (PT TAA),West Kalimantan
Clearance : 1,173ha

Between 4 May 2015 and 10 April 2018, PT TAA clearedsome 1,170ha of forest, including peatland forest within
the government-determined peat protection zone, anddeveloped substantial areas of areas of non-forested
peatland. Mapping by Aidenvironment shows at least
1,900ha of forest and peatland impacted over the period.
More than half of this area – 1,035ha – was cleared after
FGV published its NDPE policy in August 2016.
FGV has not denied responsibility for the clearance
in PT TAA. Instead, it first claimed the clearancecomplied with its sustainability policy on the grounds
that it had ‘procured all necessary approvals from therelevant authorities in Indonesia’ and ‘complied with theRoundtable on Sustainable Palm Oil (RSPO) New Planting
Procedure in 2010’.13
Subsequently, the company cited an independent
assessment which it said had found ‘no deforestationof natural forest’ because the ‘natural forest has been
completely destroyed by massive forest fires in the 1980’s
and in 1997, and also by continuous logging operations by
logging companies and by the local communities’.14
Drone footage obtained by Aidenvironment inApril 2017 shows recently deforested areas in PT
TAA crisscrossed by drainage canals and completely
surrounded by natural forest.
In August 2017, FGV announced that it would restore
all areas of peatland developed since August 2016 (whenit published a sustainable palm oil policy that included acommitment to end peatland development15).16 However,the company has yet to publish a meaningful time-boundwork plan to deliver on its commitment.

04/05/2015

Concession boundary based on
RSPO NPP.12

66

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown10/04/2018

Now or never to reformthe palm oil industry67Gama Plantation
Wilmar International–relatedyOther names by which group is known:
AMS Group, AMS Ganda Group, Ganda Group

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This is a family group in which formally separate companies
owned by members of the same family share operational ormanagerial control.
Gama Plantation is a collection of palm oil operations
owned or managed by two brothers, Martua Sitorus andGanda, and members of their family, including their brotherin-law Hendri Saksti and Ganda’s sons Darwin and Andy Indigo.
Sitorus, Ganda, Saksti and Darwin Indigo are all closely
connected to Wilmar. Sitorus was a co-founder of Wilmar
and served as a board member until he stepped down in July
2018;1 he has also been Wilmar CEO Kuok Khoon Hong’s
partner in a number of significant property deals.2 Ganda
helped establish and manage a refinery that subsequently
became part of Wilmar.3 Saksti was Wilmar’s Country Head forIndonesia4 until July 2018, when he also stepped down,5 andDarwin Indigo is Wilmar’s Deputy Country Head for Indonesia.6
Both Sitorus and Saksti resigned from Wilmar
immediately after the publication of a report by Greenpeace
into deforestation in Gama concessions7 that also highlighted
Wilmar’s history of selling problematic concessions to Gama
when serious human rights or environmental violations were
exposed in its own operations.8
Greenpeace analysis of corporate registry profiles
identified nearly 40 plantation companies, contractors or
mills as part of Gama.9 In correspondence with Greenpeacein June 2018, Gama executive Andy Indigo acknowledged
23 companies as linked to the family group;10 he failed toacknowledge a number of companies – including PT Agrinusa
Persada Mulia (PT APM) and PT Agriprima Cipta Persada (PTACP), profiled below – currently under his own management.
final
countdown22 August 2018, PT Sumatera
Unggul Makmur (Gama), Kalimantan,
0°10’54.011”S 109°20’10.091”E©Hernawan/Greenpeace

19 December 2017, PT Agrinusa Persada
Mulia (Gama), Papua,
7°30’33.978”S 140°46’23.615”E©Sukarno/Greenpeace

23 August 2018, PT Sumatera
Unggul Makmur (Gama), Kalimantan,
0°10’54.011”S 109°20’10.091”E©Hernawan/Greenpeace

Greenpeace’s June 2018 report, Rogue Trader,provides more information on Gama, including its
history, corporate structure and links between Gama
and Wilmar.11
Gama is not a member of the RSPO. S&G Biofuel Pte
Ltd, a joint venture between Gama and Samsung C&T
Corporation,12 has been an RSPO member since August
2017.13 Gama does not make maps of its concession
boundaries publicly available in a usable format.
Gama has no public NDPE policy. In June 2018, thegroup promised to impose a moratorium on developmentin 22 concessions.14 Notably, the concessions coveredby the moratorium make up three-quarters of Gama’s
identified landbank (some 280,000ha), but containjust 11,000ha of forest. By contrast, the concessions
excluded from the moratorium cover approximately
100,000ha and contain almost 30,000ha of forest.
In other words, the group was committing to end
Now or never to reformthe palm oil industry

deforestation – but mainly in concessions that have little
to no forest left to clear.
On 10 August 2018, Gama announced that it would
be extending its June moratorium to cover 25 concession
areas.15 However, the inclusion of the two concession areas
in Papua, PT Agrinusa Persada Mulia and PT Agriprima Cipta
Persada (see below), was ‘under review’ because they were
‘subject to a Conditional Sale and Purchase Agreement(CSPA) with a third party since 31st March 2017’. Gama
later announced that the sale agreement was terminatedand that the two companies would be included in its
commitment to develop and implement an NDPE policy.16

Market response
AAK, Apical, Johnson & Johnson, Mars, Procter & Gamble,
Reckitt Benckiser, Unilever and Wilmar told Greenpeacethat actions had been taken to exclude the group fromtheir supply chains.

69

CONCESSION:

PT Graha Agro
Nusantara (PT GAN),West Kalimantan,
Kubu Raya district

Clearance:
2,217haPT GAN has been clearing in the Kubu Raya district of West
Kalimantan since at least 2013. Since 2014 the company has
cleared over 7,000ha of forest and peatland.
Until December 2016, PT GAN was ultimately owned
by Andy Indigo and Jacqueline Sitorus through PT GSU; it iscurrently a subsidiary of one of Gama’s main offshore holding
companies, Capital Ocean Ventures Ltd.18
The PT GAN concession overlaps with some 4,500ha oforangutan habitat. While some of this habitat remains, mostof these forests have already been cleared and plantation
blocks have been marked for clearance in the remaining areas(see below). In September 2015, plantation workers inside
the PT GAN concession reported finding a disorientated baby
orangutan – its mother was not found.19
Between 4 May 2015 and 10 April 2018, PT GAN clearedsome 2,220ha of forest, including primary forest according
to the Ministry of Environment and Forestry 2015 national
landcover map and peatland forest within the governmentdetermined peat protection zone. Between January and

September 2017, plantation blocks were marked out overmore than 1,200ha of peatland forest in preparation forclearance. Aerial photos from March 2018 confirm that
ditches have been dug in peatland forest.20
The new plantation blocks have been cut in areas
released from the Forest Estate by former Forestry
Minister Zulkifli Hasan on 29 September 2014, hisfinal day as minister. On that same day he signed awhole sheaf of letters releasing State Forest land fordevelopment by various plantation companies; manyof these letters were problematic and several of thembroke the ministry’s own regulations.21
The Indonesian government is reportedly taking law
enforcement action against PT GAN for developing on
peatland,22 according to ForestHints, widely regarded asa semi-official news website of the Indonesian Ministryof Environment and Forestry.23
PT GAN has recently opened a new palm oil mill within its
concession.24 It is not yet known whom it supplies.

3 December 2015,
PT Graha Agro Nusantara(Gama), Kalimantan,
0°12’18.698”S 109°40’32.66”E©Ifansasti/Greenpeace

70

final
countdown

04/05/2015

Concession boundary based on March 2014 plantation business permit(Izin Usaha Perkebunan; IUP) map from Kubu Raya district government
and information from local sources.17

10/04/2018

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

13 September 2015, Kalimantan:
A baby orangutan rescued from PT
Graha Agro Nusantara (Gama) oil palm
concession following extensive forestand peatland fires.
©Nanda/Greenpeace

Now or never to reformthe palm oil industry

71

CONCESSION:PT Agriprima Cipta
Persada (PT ACP),
Papua province,
Merauke district

Clearance: 3,600ha

19 December 2017,
PT Agriprima Cipta Persada (Gama), Papua,
7°31’3.618”S 140°30’36.264”E©Sukarno/Greenpeace

18 January 2014,
PT Agriprima Cipta
Persada (Gama), Papua,
7°24’30.821” S 140°30’41.652”E©Ifansasti/Greenpeace

72

final
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25/01/2015

Concession boundary based on location permit (Izin Lokasi),
reference SK No. 42, tgl 22-02-2010.

PT ACP appears to have originally been destined to be a
Wilmar company. It was established on 11 June 2008 by two
men who were at that time managers of Wilmar subsidiary
PT Wilmar Cahaya Indonesia.25 Furthermore, in April 2009,
Wilmar executives and the Governor of Jambi province
reportedly signed a memorandum of understanding to build
a port in Tanjung Jabung Timur district, which was to be
operated by PT ACP.26
Less than a year later, plans had evidently changed: thecompany was issued with a location permit in Merauke,27 andfour months later a majority stake in PT ACP was transferred
to Fullest Holdings Ltd.28 Ganda was briefly Commissioner of
PT ACP in June 2010.29
PT ACP now operates as a subsidiary of Gama holding
company PT PPM, which is owned by four different offshore
companies, including Fullest Holdings Ltd, and managed byAndy Indigo.30
Between 3 December 2015 and 28 July 2018, PT
ACP cleared 3,600ha of forest,31 including primary forest
according to the Ministry of Environment and Forestry 2015
national landcover map.
In July 2017, the Indonesian Minister of Environment andForestry gave permission to release a portion of its concessionthat still lay within the Forest Estate.32 By October 2017, PT
ACP had started cutting new plantation blocks in that area.
Forest clearance has continued in 2018.33
The concession, in the Muting area of Merauke
district in southern Papua province, is situated close
to the Trans-Papua road which runs along the borderNow or never to reformthe palm oil industry

28/07/2018

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

with Papua New Guinea, an area with a heavy militarypresence. It lies within the ancestral land of the Marind
ethnic group. Land conflict between PT ACP and theMahuze Besar clan is reportedly ongoing,34 with claims
that the company has not obtained the free, prior andinformed consent (FPIC) of the whole clan for its clearingof the forest. PT ACP reportedly claims to have obtained
consent for development of the collectively owned clan
land based on the signature of one man, who has sincedied;35 significant areas of forest belonging to the clan
have already been cleared.
In 2015, the clan began erecting notices to signifythat it had placed the land under sasi, a form of customarylaw prohibition. Nevertheless, the company reportedly
continued to clear the land, removing the signs.36 In 2016,a representative of the military visited the clan leader,
who opposed the plantation, to inform him that a military
cooperative was taking over the contract for land clearing.37
The clan refused to back down, however, and as of
September 2017 no agreement had been reached.38
In a statement released by Gama on 10 August 2018, PT
ACP was one of the concessions excluded from the group’s
moratorium on deforestation and NDPE commitment;a subsequent announcement revealed that the plannedsale of the area had been called off and the company
would be subject to the new commitment; a subsequentannouncement revealed that the planned sale of the area
had been called off and the company would be subject tothe new commitment.39

73

CONCESSION:PT Agrinusa Persada
Mulia (PT APM),
Papua province,
Merauke district

The ownership history of PT APM is almost identical tothat of PT ACP. It was established on the same day in2008 by the same two Wilmar managers.40 Ganda wasalso Commissioner for the same few weeks in June 2010.
Like PT ACP, PT APM is currently a subsidiary of PT PPM,
which is managed by Andy Indigo and controlled by Gama
through a network of offshore companies.41
Between 3 December 2015 and 28 July 2018, PT
APM cleared some 3,290ha of forest. Forest clearing has
continued in 2018.42
The PT APM concession is located on the land of theYei ethnic group, and there are clear indications that thecompany has not engaged in a responsible FPIC processwith them. Several clans own land in Bupul village; when
the company approached them, some clans agreed to aconcession while others rejected the company’s offer.43
The company reportedly continued to press individual
members of these latter clans for signatures that it could
use to claim consent had been given, without obtaining
the consent of the whole clan. In the case of the Mandaljaiclan, the company reportedly obtained the signature of
the brother of the clan chief, who was himself opposed
to development. In another case, a clan leader was
reportedly pressured to sign a letter by two police officers
who approached him while he was at Sunday mass.44
Such actions would be neither honest and open nor
respectful of clans’ right to decide collectively whether
to accept or reject a company’s offer. Nor would they belegal: the Papuan Special Autonomy Law (UU21/2001)
states that any decision about customary land must be
made by a decision-making council (musyawarah), in
recognition of the fact that customary rights (ulayatrights) belong to the clan, in accordance with customary
law in the area, not to individuals.45
In a statement released by Gama on 10 August 2018,
PT APM was one of the concessions excluded from thegroup’s moratorium on deforestation and
NDPE commitment.46‘

74

Clearance: 3,291ha

31 March 2018,
PT Agrinusa Persada Mulia (Gama),
Papua, 7°32’31.655”S 140°47’52.596”E
Ifansasti/Greenpeace©

31 March 2018,
PT Agrinusa Persada Mulia (Gama),
Papua, 7°31’2.754”S 140°44’24.012”E
Ifansasti/Greenpeace

©

final
countdown

25/01/2015

Concession boundary based on location permit (Izin Lokasi),
reference SK No. 4, tgl 13-01-2010.

28/07/2018

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

31 March 2018,
PT Agrinusa Persada Mulia (Gama), Papua,
7°33’23.35”S 140°46’43.78”E
Ifansasti/Greenpeace©

Now or never to reformthe palm oil industry

75Genting

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Genting Group has a formal parent–subsidiary ownership
structure, plus informal operational or managerial links toother plantations.
Genting Group’s parent company Genting Berhad andGenting Berhad’s subsidiary Genting Plantations Berhad arelisted on the Bursa Malaysia.1 Tan Sri Lim Kok Thay is Chief
Executive of both Genting Group and Genting Plantations.2
Besides palm oil, the group has interests in property, leisure,energy and biotechnology.3

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Main palm oil company:
Genting Plantations Berhad

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Genting Plantations is a member of the RSPO.4 The
company has no public NDPE policy and does not makemaps of its concession boundaries publicly available in a
usable format.
Genting Plantations’ 2017 annual report lists a
total landbank of 247,655ha, of which 183,027ha
are in Indonesia (100,122ha of this planted), in West,
Central and South Kalimantan, with the remainder in
Malaysia.5 This landbank is slightly smaller than the259,714ha (with 194,850ha in Indonesia6) listed in
its latest RSPO ACOP.7 The annual report lists 11 mills,
final
countdown30 October 2017,
PT Permata Sawit Mandiri(Genting/Sepanjang), Kalimantan,
1°21’14.99”S 110°39’43.76”E©Aidenvironment

four of them in Indonesia.8 PT Varita Majutama, an oilpalm plantation in Papua province with a concession
area of 55,782ha (based on forest release data), is
not included in these figures. It became an indirect
subsidiary of Genting Berhad in July 2014,9 but has notbeen incorporated in its plantation division Genting
Plantations Berhad.
Genting is the subject of active RSPO complaints
alleging killing of an orangutan on one of its plantationsin 201710 and illegal plantation development inproduction forest by three of its subsidiaries.11
Now or never to reformthe palm oil industry

Group response
Greenpeace provided the group the opportunity
to comment before publication of this report. No
comment was received.

Market response
Apical, Ferrero and Mars told Greenpeace that actions
had been taken to exclude the group from their supply
chains.

77

CONCESSION:PT Permata Sawit Mandiri(PT PSM), West Kalimantan,
Ketapang district

Clearance: 495ha

PT PSM obtained a location permit for 17,022ha in
December 2012. HCV and social and environmental
impact assessments were carried out in November
2013. An NPP was submitted to the RSPO in May
2014.13 At that time PT PSM was a majority-owned
subsidiary of Genting Plantations.
In September 2014, Greenomics Indonesia
reported significant deforestation in theneighbouring Genting-owned concession PT
Citra Sawit Cemerlang (PT CSC), and questioned
whether the rainforest and orangutan habitat in
PT PSM would be protected.14 Wilmar, which was
sourcing from Genting at the time, reported in
March 2015 that ‘Genting has committed not todevelop on HCS areas as recommended by their
HCS assessors’.15 This commitment appeared toapply to both PT CSC and PT PSM. A subsequentGreenomics report suggested that deforestation in
PT CSC continued during 2015.16
Genting did not proceed with developing PT
PSM. But instead of protecting the forest, Genting
announced in January 2017 that it had agreed
to sell its 70% stake to the Sepanjang Group, its
joint venture partner. Genting’s stake in PT PSM
was to be transferred to PT Suryaborneo Mandiri,which Genting described as ‘wholly owned by the
Sepanjang Group’.17
In September 2017 ownership of PT PSM wastransferred to PT Mulia Agro Investama, a company
not formally owned by Genting or the SepanjangGroup.18 However, corporate registry profiles showthat PT PSM continues to be managed by people78

associated with Genting or the Sepanjang Group:• The current director of PT PSM, Albert Ruslim, has
occupied that role since 2008, during the period
when PT PSM was 70% owned by Genting and 30%
owned by the Sepanjang Group.19• The current majority owner, Kurni Samsudin, was a
director of Sepanjang Group subsidiary PT Bintang
Harapan Desa from 2006–2016.20• The current Commissioner, Andy Laurencius, wasVice Executive Commissioner between March 2015
and September 2017, during the period when PT
PSM was 70% owned by Genting and 30% ownedby the Sepanjang Group.
These links suggest that Genting or the
Sepanjang Group may continue to exercise
some management control or influence over theconcession. Either way, Genting’s decision to sell
PT PSM led directly to substantial destructionof forests within the concession – forests that
Genting, as the concession’s majority owner,
should have taken responsibility for protecting.
The tacit approval of Wilmar and other tradersthat continued to source from Genting after it soldoff PT PSM also highlights their complicity in the
deforestation that followed.
Between 10 March 2015 2017 and 15 June
2018, PT PSM cleared nearly 500ha of forestson the south side of the concession. In addition, it
logged extensively in some 600ha of forests on
the north side. Both areas were mostly orangutan
habitat.21 As of May 2018, some 9,300ha of forests
remained in the concession.
final
countdown10/03/2015

Concession boundary based on
RSPO NPP.12

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

15/06/2018

Now or never to reformthe palm oil industry

79

Hayel Saeed
Anam GroupTR

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brMain palm oil companies: Pacific Inter-Linkand various other downstream operations
Hayel Saeed Anam Group (HSA) is a large Yemeni
private-sector conglomerate, owned and managed by
the family of founder Hayel Saeed Anam. The present
CEO of HSA is Abdul Gabbar Hayel Saeed.1 The Managing
Director of HSA’s principal palm oil company, PacificInter-Link Sdn Bhd (PIL), is Fouad Hayel Saeed Anam,2also an HSA board member and Regional Director for
Malaysia and Indonesia.3
HSA is a large trader and processor of palm oilwith three refineries and a number of oleochemical
facilities located in Sumatra and Peninsular Malaysia. The
downstream palm oil operations of the group consist of
the following companies: PIL, Pacific Oils & Fats Industries
Sdn Bhd (PACOIL), PT Pacific Indopalm Industries, PT
Pacific Palmindo Industri, PT Pacific Medan Industri, PT
Pacific Indomas and PT Oleochem & Soap Industri.4 The

80

majority owner of these companies is Commodities House
Investment Ltd in the Cayman Islands.5 The first five of
these companies are members of the RSPO, but the othertwo are not; none of the RSPO members has reported
oil palm growing operations. The group’s multiple RSPO
memberships (as well as the non-membership of remaining
subsidiaries) suggest it is in breach of RSPO rules requiringgroup-level membership.6
Palm oil trade and marketing of palm oil products ishandled by HSA’s Malaysian subsidiary PIL,7 often the mostvisible of the HSA palm-related subsidiaries.
Until July 2018, none of HSA’s palm oil operations had apublic NDPE policy. In July 2018, PIL published a ‘Sustainability
Charter’ on its website, which commits the company to an
NDPE supply chain and to launching a sustainability dashboard
by the end of the third quarter of 2018.8
Since the group denies controlling any oil palm
concessions, it is unsurprising that it does not make maps ofits concession boundaries publicly available in a usable format.
Until June 2018 the Hayel Saeed family had
management control (see below) of four concessions witha total landbank of 154,527ha, forming part of the palm
oil development known as the Tanah Merah Project in the
Boven Digoel district of Indonesia’s Papua province (see casestudy below).9 The plantation companies operating theseconcessions were (and remain) PT Megakarya Jaya Raya (PT
MJR), PT Kartika Cipta Pratama (PT KCP), PT Graha Kencana
Mulia (PT GKM) and PT Energi Samudera Kencana (PT ESK).
The concession areas totalled 80% primary forest in 2013,
according to Ministry of Forestry maps.
In late April 2018, Greenpeace released footage ofextensive clearance in two of the concession areas, operated
by PT MJR and PT KCP.10 HSA and PIL have subsequently taken
steps to deny and erase evidence of the group’s involvement.
As recently as 5 June 2018, HSA was claiming on its
website to have ‘recently acquired 160,000 acres [sic] ofIndonesian land’ for palm oil cultivation.11 The relevant page
was removed on 6 June 2018 – the same day that HSA
released the following statement:“HSA Group wishes to clarify that – despite recent
reports – it has not invested in any palm oil concessions inIndonesia, or elsewhere. While HSA Group had previously
considered such an investment, the organisation decided
not to proceed after due diligence studies demonstrated
there was no clear business case to do so.”12
final
countdown

1 April 2018,
PT Tulen Jayamas Timber Industries construction
site in PT Kartika Cipta Pratama (HSA), Papua,
6°22’49.025”S 140°18’48.047”E©Ifansasti/Greenpeace
31 March 2018,
PT Megakarya Jaya Raya (HSA), Papua,
6°26’9.246”S 140°15’4.254”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry81

A similar statement was made in an email to the Asia
Times, dated 13 June 2018, from PR consultancy Burson
Marsteller, which appears to have been contracted by HSA
and/or PIL.13
A statement also issued on 6 June 2018 on PIL’s newly
revamped website provided a more detailed denial:14“As an organization which has long placed sustainability
at the heart of its business, PIL took recent, misinformed
allegations of involvement in the deforestation ofconcessions in Indonesian Papua extremely seriously.
PIL wishes to clarify that these reports are notaccurate. Neither PIL nor HSA owns or operates any
palm oil plantation in Papua, or in any other part of theworld. The HSA family had once intended to invest in
the Indonesian upstream palm oil sector – which wasprematurely advertised on its websites – but terminated
all such plans by mid-2017 after due diligence studies
demonstrated there was no clear business case to do so.
Any confusion on this issue is unintended.”
These statements explicitly claim that PIL/HSA neverinvested in the plantations.
However, registry profiles for the four plantationcompanies show that from 2014, when planting started, until
major changes were made on 31 May 2018, members of the
Hayel Saeed family and other directors of PIL and others of
the group’s downstream palm oil companies15 were directors
or commissioners of all four of these plantation companies.
Fouad Hayel Saeed Anam, who is still the Managing Directorof PIL, was the Chief Commissioner of all four companies.
Salah Ahmed Hayel Saeed, a director of PIL and HSA’s
Indonesian palm oil operations companies PT Pacific Palmindo
Industri, PT Pacific Indopalm Industries, PT Pacific Medan
Industri and PT Pacific Indomas, was the President Director of
PT KCP and PT GKM and a commissioner of PT ESK.16
Comprehensive changes to the boards of all four
plantation companies were approved by notaries on 31 May
2018 and published on 5 June,17 the day before the group’s
denials of involvement were issued. All identifiable membersof the Hayel Saeed family were removed from the boards.
However, the shareholding structures have not changed, with
80% of shares held by offshore companies based in the United
Arab Emirates (UAE) and 20% of shares held by Indonesianholding companies. The plantation companies’ registeredaddresses have also not changed: for instance, PT ESK and PT
KCP are still registered at PIL’s Jakarta office (Menara Kadin
Lantai 17). Arvind Johar – currently listed as the contact for
PIL’s Indonesia office by METCO18 (another HSA company) andpreviously a representative to the RSPO for a PIL subsidiary19– remains in his position as President Director of PT MJR,
which he has held since 2013, and has been appointed to thesame position in PT ESK.20

82

On 3 August 2012, PIL entered into a joint ventureagreement for an integrated timber complex in Boven Digoel,to be operated under the name of PT Tulen Jayamas Timber
Industries.21 Construction is now under way, as documented
by Greenpeace field investigations in April 2018. Some
40% of the shares of the Malaysian parent company, Tulen
Jayamas Sdn Bhd, are held by Malindo Investments Ltd,a UAE-registered company believed to be linked to HSA/
PIL. The same company also owns 80% of PT KCP – theplantation company operating the concession in which theconstruction is taking place. Salah Ahmed Hayel Saeed,
Fouad Hayel Saeed Anam and Arvind Johar are all directorsof Tulen Jayamas Sdn Bhd, in addition to their positions in its
Indonesian subsidiary (reaffirmed by the latest corporate
registry profile, dated 28 April 2018).
Although the ultimate beneficial owners of Malindo
Investments Ltd and the other UAE-registered companies
remain hidden, the evidence indicates that the family
remains in control of the four Tanah Merah concessions,despite HSA’s and PIL’s claims never to have had any
investment in them.

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. On 12
September, Arup Pal from PIL replied on behalf of Hayel
Saeed Anam Group denying that HSA Group or PIL
claiming that they were or operated the four Tanah Merah
concessions and were therefore ‘not in a position tocomment on their ownership structures’.
Regarding the registration of several of the plantationcompanies at the PIL offices in Jakarta, he stated that‘when PIL had considered investment, it allowed theorganisations to register locally using our address. Upon
the decision not to invest, this registration should havebeen transferred to another address. We became awareof this and our legal team is looking into remedying thissituation as a priority.’
He acknowledged several family members andexecutives had had ‘prior involvement’ with the Papuan
concessions and the associated timber processing facility‘out of personal interest distinct from their roles in the
PIL business’ but stated that ‘[a]ll of these executives hadformally stood down from these positions’ and that ‘Arvind
Johar left the PIL organisation a number of years ago, andno longer represents PIL on any work or assignment.’
Greenpeace stands by the findings of this report.

Market response
Nestlé and Unilever told Greenpeace that actions had beentaken to exclude the group from their supply chains.
final
countdown

1 April 2018,
PT Megakarya Jaya Raya (HSA), Papua,
6°25’17.64”S 140°14’7.542”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

83CONCESSION:PT Megakarya
Jaya Raya (PT MJR),
Papua province,
Boven Digoel district
Clearance: 4,500ha

25/01/2015

24/01/2018

Concession boundary based on State Forest Release Letter reference
SK.127/MENHUT-II/2012.

84

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

final
countdownPT MJR is one of the four HSA-linked
concessions in the Tanah Merah
Project.22 Between May 2015 and 6
February 2018 PT MJR cleared around4,500ha of forest, including primary
forest according to the Ministry ofEnvironment and Forestry 2015
national landcover map and including
peatland forest within the governmentdetermined peat protection zone.
Recent clearance is also evident in theneighbouring concession of PT Kartika
Cipta Pratama.

31 March 2018,
PT Megakarya Jaya Raya (HSA), Papua,
6°26’29.819”S 140°14’13.247”E©Ifansasti/Greenpeace

31 March 2018,
PT Megakarya Jaya Raya (HSA), Papua,
6°25’41.406”S 140°15’14.652”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

85

IJM
Corporation

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IJM Plantations Bhd

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IJM Plantations has a formal parent–subsidiary ownership
structure. Its CEO is Joseph Tek Choon Yee.1
IJM Plantations was an RSPO member until it
resigned in February 2016.2 The group has no public
NDPE policy and does not make maps of its concession
boundaries publicly available in a usable format. IJM
Corporation is one of four companies that were
excluded from Norway’s Government Pension Fund
Global in August 2015 due to links with deforestation.3
The group’s 2017 annual report lists 60,570ha
planted area; approximately 60% of this is in Indonesia(Kalimantan and Sumatra) and the remainder in
Sabah, Malaysia.4 The report states that there is ‘nofurther land-bank for expansion’ in Malaysia and thatthe remaining landbank in Indonesia, approximately
3,000ha, ‘will be cultivated over the next two years
as conditions permit’.5

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. On 10
September, IJM Corporation replied, acknowledging theidentified deforestation. It claimed that two customers– IOI and Wilmar – questioned it about the clearance
after seeing a draft version of this report and that it
subsequently committed to ‘no deforestation, no peat
planting and no open burning’. It claims to have ceased allland clearing in the PT Prima Bahagia Permai (PT PBP; seecase study below), while undertaking a joint assessmentwith Wilmar to identify any corrective actions needed.
The group failed to provide concession maps for its
operations.

Market response
Mars told Greenpeace that actions had been taken
to exclude the group from its supply chain.

86

final
countdown

CONCESSION:PT Prima Bahagia
Permai (PT PBP),North Kalimantan,
Bulungan district

Clearance :302ha

Between 28 August 2015 and 19 July 2018 PT PBP clearedsome 300ha, mostly secondary forest.

28/08/2015

19/07/2018

Concession boundary based on
HGU map from the Indonesian
National Land Agency (BPN).

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

87

Indonusa

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Papua (managed by PT Internusa Jaya Sejahtera), and one
concession in South Sorong, West Papua province, whichhave not yet obtained all the necessary permits.5
In 2012 Indonusa reportedly bought a third Sumatranplantation company, PT Sawit Mas Perkasa in Jambi,6whose previous owner had cleared land for timber but had
not planted oil palm.7 It has not been confirmed whether
this land was subsequently planted by the Indonusa Group.
It is possible that there are other concessions controlled
by the group, as its website claims that it is expanding in
Sumatra, Kalimantan and Papua.8
At one time, Indonusa had two other plantationcompanies in West Papua province: PT Persada Utama
Agromulia and PT Anugerah Sakti Internusa. However,shares in these companies were transferred in April 2014
to other individuals with no known connection to theIndonusa Group or Rosna Tjuatja.9

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Group response

The Indonusa Group is family-owned and has a formal parent–
subsidiary ownership structure. The group is controlled by
Rosna Tjuatja and family.1 Tjuatja also has interests in financial
services through PT Profindo International Securities2 andproperty through PT Suryasakti Bumipersada.3
Indonusa is not a member of the RSPO and does not havea public NDPE policy. The group does not make maps of its
concession boundaries publicly available in a usable format.
Indonusa is a small palm oil group with at least two
established concessions in Sumatra (in Jambi, managed by
PT Indonusa Agromulia, and South Sumatra, managed by PT
Hamita Utama Karsa),4 one 18,590ha concession in Merauke,

88

Greenpeace provided the group the opportunity
to comment before publication of this report. On
13 September, after expiry of the time window forcommenting, Indonusa replied, claiming that the grouphad ‘implemented policies and Standard Operating
Procedures (SOP) relating to NDPE Policy’. It claimed tohave all the necessary permits for PT Indonusa Agromulia,
PT Hamita Utama Karsa and PT Internusa Jaya Sejahtera
but did not provide references for them. It clarified
that ‘the purchase of PT Sawit Mas Perkasa in 2012 byIndonusa Group has been declared legally null and void’.
Finally, it stated that ‘Land Clearing activities by PT IJS
are… Secondary Forests’. The group failed to provide
concession maps for its operations.

Market response
Mars, Nestlé, PZ Cussons, Reckitt Benckiser, Unilever andWilmar told Greenpeace that actions had been taken to
exclude the group from their supply chains.
final
countdown

1 April 2018,
PT Internusa Jaya Sejahtera (Indonusa),
Papua, 7°14’16.145”S 140°42’39.293”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

89

CONCESSION:PT Internusa
Jaya Sejahtera(PT IJS), Papua,
Merauke district

Clearance: 5,172ha

Between 25 January 2015 and 28 July 2018 PT IJS clearedsome 5,170ha of forest, including primary forest according
to the Ministry of Environment and Forestry 2015 national
landcover map. The company has still not been granted adefinitive State Forest Release Letter.

90

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25/01/2015

Concession boundary based on location permit (Izin Lokasi)
signed 1 July 2013.

28/07/2018

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

1 April 2018, PT Internusa Jaya
Sejahtera (Indonusa), Papua,
7°14’26.544”S 140°42’34.212”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

91

IOI group

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IOI Group (sometimes also referred to as IOI Corporation
Berhad1) has a formal parent–subsidiary ownership
structure. IOI is part-owner of Bumitama (see case study
above),2 and thus the two groups should be consideredlinked in terms of responsibility. IOI’s CEO Dato’ Lee Yeow
Chor is also a non-executive director of Bumitama AgriLtd.3
IOI has been an RSPO member since 2004.4 It has asustainability policy including NDPE commitments.5 IOI has
made maps available of its concession boundaries in Indonesia,
but claimed in a letter to Greenpeace that it is prevented bylaw from doing so for its Malaysian concessions.

92

According to its website IOI has 90 oil palm estates with a
total landbank of 217,917ha, of which 179,271ha have beenplanted. Of the total holding, 64% is located in Malaysian
Borneo, 24% in Peninsular Malaysia and 12% in Indonesia.
The group’s five Indonesian plantation companies are jointly
owned with Bumitama, which has a 28% stake in their holding
company PT Sawit Nabati Agro.6 A little more than half of theIndonesian landbank (21,062ha of 39,477ha) has so far beencleared for planting.7
Several of IOI and Bumitama’s jointly owned concessionsin West Kalimantan have been the subject of repeatedcomplaints from Greenpeace and other organisations
final
countdown16 April 2016
PT Bumi Sawit Sejahtera (IOI), Kalimantan,
2°55’55.686”S 110°44’41.496”E©Vaugn/Greenpeace

regarding illegal planting outside concession boundaries andother breaches of the RSPO’s Principles and Criteria, such as
clearance of peatland and HCV forest including orangutan
habitat.8 IOI’s Pelita concession in Sarawak is also embroiled ina long-running complaint concerning breaches of community
land rights (see case study below).
Until recently IOI Group included the traded oils division
IOI Loders Croklaan. However, in March 2018 the US-based
commodities trader Bunge completed the purchase of amajority stake in Loders Croklaan, which it has now mergedwith its own palm oil division.9 IOI Group retains ownershipof three Malaysian refineries.10
Now or never to reformthe palm oil industry

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. On 12
September, IOI replied, acknowledging that the Pelita
case ‘has taken far too long to resolve, costing a lot of
anguish to the affected communities’. IOI stated that it
had published the maps of its Indonesian concessions
on its palm oil dashboard in December 2016 but
claimed; ‘we are prohibited from publishing [maps of
our Malaysian plantations] under the Official Secrets
Act in Malaysia’.

93CONCESSION:

IOI-Pelita
Plantations Sdn
Bhd, Sarawak

In 2006 IOI acquired a 70% stake in palm oil
plantation joint venture Rinwood-Pelita, changing
its name to IOI-Pelita Plantations Sdn Bhd.11 The
original minority partner in the joint venture,
which has retained its 30% stake, is the Sarawak
government’s Land Custody and Development
Authority (LCDA), an agency specifically created topromote commercial development on indigenous
customary land.12
The history of the conflict has been extensively
documented by Forest Peoples Programme. In
1996–97 Rinwood-Pelita obtained leases todevelop oil palm plantations on 7,840ha of land in
the area (later increased to 9,040ha) and proceeded
to clear and replant the land, without following aproper FPIC process. Villagers tried to protest but
were either ignored by the company and officials
or intimidated by company employees.13 In 1997
the community took the joint venture partners andthe state government to court, seeking recognitionand enforcement of their customary land rights.
After over 12 years the High Court finally reacheda judgment on 25 March 2010, confirming thecommunity’s customary rights and ruling that thecompany’s leases were invalid and that it should pay
the community damages.14
Meanwhile, however, IOI had taken overRinwood’s stake in the company and plantation
expansion had continued. Compensation was paid
but covered only the value of destroyed crops andimprovements to the land, not the value of the land
itself, while IOI-Pelita apparently pressured villagers
not to try to reclaim their land and did not settle
claims arising from its predecessor’s clearance,
despite the community’s repeated attempts at
engagement.15
Aware that the RSPO’s Principles and Criteria
required IOI to resolve the land conflict before94

its holdings could be certified, community
representatives and supportive NGOs brought theissue to the attention of the RSPO in 2008,16 witha further complaint filed in March 2010.17 This
led in March 2011 to the RSPO suspending future
certification of IOI operations and calling on thecompany to propose an acceptable resolution.18
This failed to manifest, and following the successof IOI’s appeal of the High Court judgment in 2013,19
in February 2014 the company told the RSPO that it
was unwilling to comply with FPIC standards because
the courts had not recognised the community’s claim
to the land.20 Mediation efforts continued through2016, with the case transferred back to the RSPO
Complaints Panel in January 2017.21
In December 2017, IOI suddenly announced its
intention to divest its 70% stake in IOI-Pelita to athird party that was not a member of the RSPO. Sucha sale would have made successful resolution of theland conflict all but impossible. However, following
intense criticism from NGOs and other stakeholders
it stated that it had become ‘clear to IOI that thedivestment cannot and will not proceed’.22
In January 2018, IOI reaffirmed its ‘commitment
to resolving the dispute with local communities’.23
Though the RSPO approved an action plan inJune 2018 and IOI claims that ‘the relationshipbetween IOI and the communities has improved
significantly’,24 at the time of writing the dispute has
not been finally resolved.

final
countdown16 April 2016
PT Bumi Sawit Sejahtera (IOI), Kalimantan,
2°55’13.4”S 110°43’40.2”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

95

Korindo

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brKorindo1 is a privately held company controlled by theSouth Korean Seung family. It publishes little financial orownership information.
Korindo is not a member of the RSPO and does
not have a public NDPE policy covering its oil palm andforestry operations. It has not made maps of its concession
boundaries publicly available in a usable format.
Korindo holds eight oil palm concessions, sevenin Papua province and one in North Maluku, totalling
159,600ha. Mapping analysis indicates that two ofthese concessions are fully developed, four are partiallydeveloped and two remain undeveloped.
An investigation conducted by Aidenvironment in2016 found that Korindo had cleared over 50,000ha of96

forest across its palm oil concessions, of which 30,000ha
had been cleared since 2013, including 11,700ha classified
as primary forest according to official Indonesian Ministryof Forestry maps.2 Some 8,711ha were cleared across fiveconcessions between 2015 and 2017, 1,992ha of whichwere mapped as primary forest. The Aidenvironment
analysis identified 894 fire hotspots in Korindo’s
concessions between 2013 and 2015, suggesting Korindo
deliberately used fire in the course of its clearance.3
Following customer pressure, Korindo subsidiary
PT Tunas Sawa Erma (PT TSE) announced in August
2016 a three-month moratorium on development
while it established a comprehensive NDPE policy
and conducted stakeholder engagement.4 Korindo
final
countdown

1 April 2018,
PT Inocin Abadi (Korindo), Papua,
6°52’0.018”S 140°42’20.861”E©Ifansasti/Greenpeacesubsidiaries PT Papua Agro Lestari (PT PAL; see casestudy) and PT Gelora Mandiri Membangun (PT GMM)
announced further moratoria in December 2016,
supposedly to enable completion of HCS and HCV
studies on their concessions. Barely two months later the
PT PAL moratorium was breached, with over 1,000ha
being cleared.5
Korindo subsequently claimed to have reinstated themoratorium in PT PAL,6 and in 2017 submitted five HCV
assessments to the HCV Resource Network.7 However,its commitment to NDPE is questionable. For example,
in August 2017, Korindo staged high-profile events
together with local Papuan government leaders bothin Jakarta8 and in Merauke, Papua,9 where it claimed to
Now or never to reformthe palm oil industry

need to clear more forest to meet its commitments tolocal people. These actions call into question the group’s
intention to stop deforestation in the long term.

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. No comment
was received.

Market response
Bunge, Colgate-Palmolive, Hershey, Mars, Nestlé,
Reckitt Benckiser and Unilever told Greenpeace that
actions had been taken to exclude the group from their
supply chains.

97CONCESSION:PT Berkat
Citra Abadi

Clearance:
128ha

Since 29 January 2016, PT Berkat Cipta Abadi has cleared
only a negligible area of forest.

25/01/2015

28/07/2018

Concession boundary basedon maps from East Kalimantan
Plantation Agency (2012).

98

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown

1 April 2018,
PT Berkat Cipta Abadi (Korindo), Papua,
6°51’34.823”S 140°30’29.334”E©Ifansasti/Greenpeace
26 March 2013,
PT Berkat Cipta Abadi (Korindo), Papua,
6°48’33.599”S 140°30’14.58”E©Rante/Greenpeace

Now or never to reformthe palm oil industry

99

CONCESSION:PT Dongin
Prabhawa

Clearance: 1,451ha

Since 8 May 2015, PT Dongin Prabhawa has clearedsome 1,450ha of forest, including primary forest
according to the Ministry of Environment andForestry 2015 national landcover map.

08/05/2015

24/01/2018

Concession boundary based on
BPN online 2017 Surat Keputusan
Menteri Kehutanan RI No.:
SK.623/Menhut-II/2009 date 05
October 2009.

100

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown29 March 2018,
PT Dongin Prabhawa (Korindo), Papua,
7°20’56.135”S 139°42’2.76”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

101

CONCESSION:PT Gelora
MandiriMembangun
Since 13 March 2015, PT Gelora Mandiri
Membangun has cleared some 1,635ha of forest.

Clearance: 1,635ha

13/03/2015

102

final
countdown24/05/2018
Concession boundary based on MoEF, 2013 SK.266/MENHUT-II/2008.

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

103

CONCESSION:PT Papua Agro Lestari(PT PAL), Papua
province, Boven
Digoel district

Clearance: 5,190ha

According to official Ministry of Environment and Forestry
landcover maps, PT PAL’s concession was almost entirely
covered by primary forest in 2013.10 Between 25 January
2015 and 28 July 2018, PT PAL cleared some 5,190ha offorest, including primary forest according to the Ministryof Environment and Forestry 2015 national landcover map.
In August 2016, Aidenvironment published aninvestigation into deforestation in PT PAL and other
Korindo concessions.11 Under pressure from customers
in the wake of these revelations, PT PAL announced a
moratorium on new clearing in December 201612 –tacitly admitting that deforestation had been going on. It
proceeded to break and – when challenged – reinstate thismoratorium in quick succession.13
Mapping analysis shows a strong correlation between
forest clearance and fire hotspots in PT PAL, strongly
suggesting that fire was being deliberately used to clear
the land before planting. During 2013 and 2014, prior tothe clearance, there had been no recorded fire hotspots
in the concession. However, a total of 221 hotspots wererecorded between August and November 2015 – mostly
in the recently cleared northwest of the concession.
In September 2016, Korindo strenuously denied any
deliberate use of fire for land clearance to Greenpeace,
just as it claimed to have been practising NDPE during theperiod when PT PAL’s concession was being deforested.14

25/01/2015

Concession boundary basedon BPN online 2017 Surat
Keputusan Menteri Kehutanan No.
552/Menhut -II/2012, date 4
October 2012.

104

28/07/2018

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown

1 April 2018,
PT Papua Agro Abadi (Korindo), Papua,
6°48’54.167”S 140°46’40.812”E©Ifansasti/Greenpeace
1 April 2018,
PT Papua Agro Abadi (Korindo), Papua,
6°48’47.316”S 140°47’34.127”E©Ifansasti/Greenpeace

Now or never to reformthe palm oil industry

105

CONCESSION:PT Tunas
Sawa Erma

Clearance: 2,816ha

Since 25 January 2015, PT Tunas Sawa Erma has clearedsome 2,815ha in Blok A, potentially including peatland
and including primary forest according to the Ministry ofEnvironment and Forestry 2015 national landcover map.

25/01/2015

28/07/2018

Concession boundary based on
MoEF online 171/KPT. S-II/98.

106

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown31 March 2018,
PT Tunas Sawa Erma (Korindo), Papua,
6°39’7.998”S 140°14’47.249”E©Ifansasti/Greenpeace
19 December 2017,
PT Tunas Sawa Erma (Korindo), Papua,
6°38’53.765”S 140°16’33.671”E©Sukarno/Greenpeace

Now or never to reformthe palm oil industry

107

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final
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Main palm oil company:
TH Plantations Bhd
Lembaga Tabung Haji is managed on behalfof the Malaysian government; it is a nationalsavings/investment body funding pilgrimage
activities for Malaysian Muslims.1 TH Plantations
covers the group’s oil palm plantation interests.2
TH Plantations is not a member of the RSPO
and has no public NDPE policy. The group does notmake maps of its concession boundaries publicly
available in a usable format.
TH Plantations holds a landbank of
100,986ha, mostly in Malaysia, with 60,350ha
planted.3 One concession of 8,800ha is in North
Kalimantan, Indonesia.4
Lembaga Tabung Haji also owns a 50% stakein PT Synergy Oil Nusantara (PT SON), a refinery
business with a reported capacity of 1 million
tonnes.5 PT SON is a member of the RSPO,6 but
operates without an NDPE policy and is therefore
part of the leakage market. PT SON is reported tohave continued sourcing from both PT Austindo
Nusantara Jaya and PT Sawit Sumbermas Sarana
after they were suspended by other traders for
deforestation.

Now or never to reformthe palm oil industry

PT SON was a joint venture between
Lembaga Tabung Haji and FELDA until the lattersold its stake in May 2018;7 the buyer’s identity
is not known.

Group response
Greenpeace provided the group the opportunity
to comment before publication of this report. No
comment was received.

Market response
Bunge and Mars told Greenpeace that actions
had been taken to exclude the group from their
supply chains.

21 March 2016,
PT Persada Kencana Prima(Lembaga Tabung Haji),Kalimantan,
3°42’05.85”N 117°04’24.47”E©Aidenvironment

109

CONCESSION:PT Persada Kencana
Prima (PT PKP),
North Kalimantan
PT PKP began clearing forest in early 2015. Between
29 November 2014 and 27 October 2017, PT PKP
cleared 3,685ha, including peatland forest within
the government-determined peat protection zone.
Nearly all of the concession is on peat, much of it
deep peat.

Clearance: 3,685ha

29/11/2014

27/10/2017

110

final
countdown

21 March 2016,
PT Persada Kencana Prima (Lembaga
Tabung Haji), Kalimantan, 3°42’06.29”N
117°03’52.33”E©Aidenvironment

Concession boundary based on information from East Kalimantan
Plantation Agency (2012).

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

111

NoblePlantations

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Noble Group has a formal parent–subsidiary ownership
structure. Noble Plantations is a wholly owned subsidiary of
Noble Group,1 which is listed on the Singapore Exchange.2
Noble Group’s largest shareholder, with a 17.9% interest,
is Noble Holdings Limited,3 which is wholly owned by adiscretionary trust whose beneficiaries include the children of
the founder of the group, Richard Elman (though not Elman
himself).4 Various institutions including the China Investment
Corporation and Abu Dhabi Financial Group LLC are also
substantial shareholders.5
Noble Plantations Pte Ltd has been a member of the
RSPO since 2011.6 In October 2017 it issued a ‘Sustainability
information document’ which masquerades as an NDPE
policy, using key words without an absolute commitment to
no deforestation or peat development based on credible field
assessments.7 However, in light of the company’s actions in its
palm oil concessions (see case studies below), this document
lacks any credibility on both environmental and social fronts.

112

Noble Plantations encompasses two plantation companies
with concessions in Papua and West Papua provinces, totalling
just under 71,000ha. According to its 2016 ACOP submission
to the RSPO, the company had planted or otherwise developed
16,539ha by this date.8 Noble Plantations has not made maps ofits concession boundaries publicly available in a usable format.
Noble Group formerly included an agricultural trading
division, Noble Agri, which its oil palm plantation operations
formed part of. However, when in 2014 it sold a 51% stakein Noble Agri to Chinese state-owned enterprise Cofco9 (tobe followed in 2016 by the sale of the remaining 49% to a
Cofco subsidiary10), its plantation interests were excluded
from the sale. Instead, Noble Group issued a promissory note
under which the net proceeds of the sale of its two plantationcompanies would be remitted to Noble Agri – now the Cofco
Agri Limited (CAL) Group – once a buyer could be found,and the palm business is now said to be ‘classified as held
for sale’.11 Although Noble Group claimed to be in talks with
final
countdown

18 December 2017,
PT Pusaka Agro Lestari (Noble),
Papua, 4°20’22.469”S 136°41’3.642”E©Sukarno/Greenpeace

potential buyers as early as the end of 2014,12 this claim wasrepeated at the end of each of the three succeeding years,13
suggesting that the plantation companies did not present an
attractive commercial prospect. This is unsurprising in view of
the controversy in which they have both been mired (see casestudies) and the impact that this has had on Noble’s credibility– some institutional investors have actually been put off
investing in the group as a whole by the shortcomings of its
palm oil operations.14

Group response
Greenpeace provided the group the opportunity to comment
before publication of this report. On 12 September, Noble
replied, stating that ‘we are in an active RSPO dispute process
and as such we are prohibited from a bi-lateral discussion
with any other party’. With regards to its ‘Sustainability
information document’, it stated that ‘no Noble plantations
have planted on peat and we have no desire or intention to do
Now or never to reformthe palm oil industry

so’, without addressing whether any clearance of peatland hastaken place. Regarding PT HIP, the company claimed that it
had ‘successfully demonstrated the invalidity of the demandsof the local clans’ made in 2015, on the grounds that they
had already received compensation in the past.. It stated it
has ‘made considerable efforts to address their concerns
and implemented a number of additional benefits’, including
educational support, housing and healthcare. Regarding PT
PAL, the company reiterated that it could not comment onwhether it had cleared primary forest because of the RSPO
Complaints Process. It offered to share concession maps with
Greenpeace once it was released from the constraints of the
RSPO Complaints Process ‘on the basis that the information is
not to be put into the public domain’.

Market response
Mars, Nestlé and Unilever told Greenpeace that actions had
been taken to exclude the group from their supply chains.

113CONCESSION:PT Henrison Inti
Persada (PT HIP),
West Papua,
Sorong district

Clearance: 1,334ha

PT HIP, in which Noble acquired a majority stake in2010,15 operates a 32,546ha oil palm concession
and palm oil mill.16 Community opposition to theconcession dates back to 2006, when clan leaders
released customary land to PT HIP, with communities
allegedly being pressured into entering into exploitative
agreements that offered minimal compensation.17
Noble’s arrival on the scene brought little
improvement. According to a testimony provided
in 2014, over four years after Noble took over theconcession, communities had still not received in-kindbenefits that they had been promised by PT HIP, including
support for education and healthcare, new housing andclean water – in fact, according to reports, access toclean water had actually deteriorated, as the company
had polluted local streams.18 A year later, in September
2015, representatives of nine clans stated that PT HIP
had not obtained their consent to take over land and thatthey were seeking compensation from the company.19
Between 15 March 2015 and 19 February 2018,
PT HIP cleared about 1,335ha of forest.

15/03/2015

Concession boundary basedon Noble Group 2016 SK.409/
MENHUT-II.

114

19/02/2018

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown

18 May 2011,
PT Henrison Inti Persada (Noble), Papua©EIA

18 May 2011,
PT Henrison Inti Persada (Noble), Papua©EIA

Now or never to reformthe palm oil industry

115

CONCESSION:PT Pusaka AgroLestari (PT PAL),
Papua province,
Mimika district

Clearance: 4,628ha

In 2011 Noble acquired 90% of PT PAL,20 with a38,159ha oil palm concession that it began to clear
in 2013.21 According to Ministry of Forestry maps,
approximately 27,000ha – 70% of the total concession
area – was primary forest in 2011. Around two-thirds
of PT PAL’s concession was classified in 2013 as an
Intact Forest Landscape, meaning that it has particularvalue for conservation as an integral forested area.22
A similar percentage of the concession is on peat ofvarying depths.23
According to analysis of satellite imagery by
Aidenvironment, most of the secondary forest in PT
PAL’s concession was cleared between 2011 and 2014;by 2016, the company had also cleared considerable
areas of primary forest. Between 13 December 2014
and 27 March 2018, PT PAL cleared some 4,630ha offorest, more than half of which were mapped by the
MoEF as primary forest and including peatland forest.
As of 2017, more than 23,000ha of land mapped as
primary forest remained in the concession. In July 2017,
HSBC triggered an RSPO investigation into clearanceof primary forest in PT PAL’s concession; the following
month the RSPO advised the company to stop all further
development of the concession pending the complaints
panel’s assessment. At the time of writing, the results ofan independent investigation are still awaited.24
PT PAL’s clearing of forest has been blamed forsevere impacts on local communities. In October 2014
serious flooding in Miyoko and Aikawapuka villages,
downstream from PT PAL,25 was blamed locally on
deforestation there.26 The local bupati responded by
revoking the company’s operating licence,27 but thecompany objected with the support of the Director
General of Plantations at the Ministry of Agriculture28
and succeeded in getting the decision reversed29 (thoughlater admitting that its plantation had had negative
impacts along the rivers and proposing reforestation to
mitigate the problem).30

13/12/2014

116

27/03/2018

final
countdown

18 December 2017,
PT Pusaka Agro Lestari (Noble), Papua,
4°20’47.616”S 136°40’0.096”E©Sukarno/Greenpeace

Concession boundary based on HGU Chief of National Land Agency
No. 11/HGU/BPN/2011 IUP Decree of Papua Province Governor No.
143/2008, 30 Dec 2008.

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

117

NPC Resources

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The group structure of NPC Resources is not clear – itappears to have some formal ownership of concessions
along with managerial control of further concessions.
The largest owners of NPC Resources are Loo Pang Keeand Wong Siew Ying.1
NPC Resources is not a member of the RSPO andhas no public NDPE policy. The group does not makemaps of its concession boundaries publicly available in a
usable format.
The group’s website lists 11,669ha of ‘plantation
land’ in Malaysia and 46,564ha in Indonesia (East
Kalimantan), of which 18,296ha are planted.2
Aidenvironment research has identified concessions
managed and part-owned by NPC Resources covering
78,900ha in East Kalimantan.3

Group response
Greenpeace provided the group the opportunity
to comment before publication of this report. No
comment was received.

Market response
Bunge and Mars told Greenpeace that actions had beentaken to exclude the group from their supply chains.

118

final
countdown22 August 2017,
PT Sumber Alam Selaras (NPC), Kalimantan,
0°10’57.162”N 116°38’42.132”E©Aidenvironment

Now or never to reformthe palm oil industry

119CONCESSION:PT Sumber Alam
Selaras (PT SAS),
East Kalimantan,
East Kutai district

06/04/2015

Clearance: 3,577ha

PT SAS is managed (not owned) by NPC Resources.
NPC Resources cleared some 3,580ha of forest in PT
SAS between between 6 April 2015 and 14 April 2018,
including orangutan habitat and peatland forest within thegovernment-determined peat protection zone.

Concession boundary based on
HGU maps from the Indonesian
National Land Agency (BPN) andthe regional government.

120

14/04/2018

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown

6 March 2016,
PT Sumber Alam Selaras (NPC), Kalimantan,
0°13’1.64”N; 116°37’16.52”E©Aidenvironment

6 March 2016,
PT Sumber Alam Selaras (NPC), Kalimantan,
0°13’10.72”N; 116°37’23.90”E©Aidenvironment

Now or never to reformthe palm oil industry

121

POSCO(POSCO Daewoo
Corporation)

Main palm oil company: PT Bio Inti Agrindo
POSCO is a South Korean multinational with interests in steel, oiland gas production and mining, as well as palm oil. The current
CEO of POSCO Daewoo Corporation is Young-Sang Kim.1
PT BIA became a member of the RSPO in July 2018.2 It has
no public NDPE policy. The group does not make maps of its
concession boundaries publicly available in a usable format.
The group holds one concession in Papua, covering
36,401ha.3 Palm oil from this concession is now believed to beentering the marketplace.

Group response
Greenpeace provided the group the opportunity to comment
before publication of this report. On 13 September, POSCO
replied, stating that ‘PT BIA will publish maps including its
concession boundaries and the location of a mill in digitalformat via its website’. It added that land clearing has beenpaused since October 2017 ‘until proper assessments and land
use planning are completed’, as part of which it is ‘exploring
credible mechanisms, including the RSPO’s Remediation andCompensation Plan’, and is in a ‘process of engagement witha reputable partner that is experienced in implementation of
NDPE’. It claimed the fires in its concession in 2015 resulted
from ‘burning practices by a third party’, and that the ‘Forest
Department of Regency of Merauke … made a conclusion thatthe incident was an accident’. It added that PT BIA has a noburning policy and fire fighting equipment and personnel.

Market response
Nestlé and Unilever told Greenpeace that actions had beentaken to exclude the group from their supply chains.

122

final
countdown

18 December 2017,
PT Bio Inti Agrindo (POSCO), Papua,
6°59’5.628”S 140°53’25.35”E©Sukarno/Greenpeace

Now or never to reformthe palm oil industry

123CONCESSION:PT Bio Inti
Agrindo (PT BIA),
Papua province,
Merauke district

Clearance: 15,385ha

PT BIA cleared some 15,385ha of forest between 25 January
2015 and 28 July 2018, nearly one-third of which was
primary forest according to the Ministry of Environment andForestry 2015 national landcover map.
Satellite analysis by Aidenvironment revealed 158 fire
hotspots in the eastern block of the concession in September
and October 2015, concentrated in the area that was
deforested earlier that year.4 Analysis published by theawasMIFEE website suggests a similar pattern in previous
years.5 This gives rise to the suspicion that the company may
have systematically used fire during its land clearing process.

25/01/2015

28/07/2018

Concession boundary based on
State Forest Release Letterreference SK.572/MENHUTII/2009.

124

Satellite image sources:
Landsat 8 courtesy of the U.S.
Geological Survey.

final
countdown

18 December 2017,
PT Bio Inti Agrindo (POSCO), Papua,
7°1’57.786”S 140°54’14.742”E©Sukarno/Greenpeace
18 December 2017,
PT Bio Inti Agrindo (POSCO), Papua,
7°1’57.786”S 140°54’14.742”E©Sukarno/Greenpeace

Now or never to reformthe palm oil industry

125

Rimbunan
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Main palm oil companies: Rimbunan Sawit Bhd,
Jaya Tiasa Holdings Bhd, Subur Tiasa Holdings Bhd,
Mafrica Corporation Sdn Bhd and Gilford Ltd

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Rimbunan Hijau is a family-owned group, owned by the Tiong
family. The CEO is Tiong Hiew King. Known concessions appear
to have a formal ownership structure. Originally a logging
company, Rimbunan Hijau now also holds palm oil, media,
pulpwood and other interests.1
Rimbunan Hijau is not a member of the RSPO and has
no public NDPE policy. The group does not make maps of its
concession boundaries publicly available in a usable format.
Rimbunan Hijau is the largest palm oil company in Sarawak,
Malaysia, with an estimated landbank of at least 220,000ha in
the state. Palm oil concessions are held via various companies.
Jaya Tiasa Holdings Bhd has a landbank of 83,483ha in Malaysia,
with 69,652ha planted as of June 2017.2 Rimbunan Sawit Bhd
holds 92,312ha, of which 55,110ha were planted as of 31
December 2016.3 Subur Tiasa Holdings Bhd has a landbank of
28,743ha, of which 11,080ha were planted by 31 July 2016.4
The above three companies are listed on the Bursa Malaysia, butlittle data is available for the fourth, unlisted company: Mafrica
Corporation Sdn Bhd.5 Aidenvironment has identified an oil palm
landbank of at least 20,000ha for Mafrica.6
In Papua New Guinea, Rimbunan Hijau’s subsidiary Gilford
Ltd holds a concession area of 42,000ha, of which 31,000ha
are allocated for oil palm development.7
Between June 2016 and July 2017, traders/refinerspurchasing from Rimbunan Hijau’s palm oil mills in Sarawak
included Wilmar, Cargill and IOI (the latter through Wilmar,
Cargill and the Kirana palm oil refinery of BLD Plantation).8

Group response
Greenpeace provided the group the opportunity to comment
before publication of this report. No comment was received.

Market response
Mars told Greenpeace that actions had been taken to exclude
the group from its supply chain.

126

final
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CONCESSION:

Eastern Eden Estate(EEE), Sarawak,
Malaysia

EEE is owned by Jaya Tiasa. Satellite imagery is
incomplete, but shows around 920ha of clearance ordevelopment between 30 June 2016 and 22 June 2018,
including potential peatland.

Clearance:
923ha

30/06/2015

22/08/2018

Concession boundary basedon map from environmental
impact assessment, obtained
from library of Natural
Resources and Environment
Board Sarawak (NREB).10

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

127

CONCESSION:

Gilford Ltd,
Papua New Guinea,
East New Britain
province

Clearance: 11,043ha

Between 14 December 2014 and 16 June 2018 Gilford Ltd
cleared some 11,040ha of forest.

2016, Gilford Ltd (Rimbunan Hijau), Pomio, Papua New Guinea

128

final
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14/12/2014

16/06/2018

Concession boundary based on Special Agriculture and Business Lease(SABL), as depicted in Global Witness report Stained Trade.9

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

2016, Gilford Ltd (Rimbunan Hijau), Pomio, Papua New Guinea ©Alessio Bariviera

Now or never to reformthe palm oil industry

129

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Main palm oil companies: Indofood (including
IndoAgri and downstream businesses) and otherplantation interests held separately by Anthoni
Salim or his associates. This includes a numberof companies referred to collectively as theIndo Gunta group.

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brThe Salim group has a complex informal structure, with formal
segments alongside various informal segments connected byoperational, managerial and possibly financial group links.
As of 31 December 2017, Anthoni Salim held 44.35%of the shares of the Hong Kong–listed First Pacific Company
Ltd.1 As of 20 March 2018, First Pacific had a 50.1% interest
in Indofood and a 62.8% interest in Indofood Agri Resources
Ltd (IndoAgri).2
IndoAgri’s subsidiary PT Salim Ivomas Pratama Tbk(SIMP), which covers all of its Indonesian oil palm concessions,is a member of the RSPO, as is SIMP’s subsidiary PT PP
London Sumatra (Lonsum). IndoAgri has a partial NDPE policy
lacking in scope and substance.3 Other palm oil companies
linked to Salim are not members of the RSPO and do not havepublic NDPE policies. No Salim company makes maps of its
concession boundaries publicly available in a usable format.
In its 2016 ACOP submission to the RSPO, SIMP claims
a total landbank of 364,195ha, including 56,715ha underscheme/plasma smallholders.4 IndoAgri reports a total plantedarea of 300,387ha as of 31 December 2017, which matches
the area listed in SIMP’s annual report.5
Anthoni Salim also owns stakes in oil palm businesses
that are not part of Indofood. For example, he is a 50.5%
owner of PT Duta Rendra Mulya (PT DRM; see case study),
which has location permits for 7,400ha in Sintang district,
West Kalimantan.6
final
countdown27 July 2018,
PT Bintuni Agro Prima Perkasa (Salim),
Papua

Besides these interests, associate companies of
Anthoni Salim active in various sectors including property,
transportation and foods conducted transactions totalling
US$148m in 2017 with the plantations business of the
Indofood group.7
Corporate registry profiles reveal at least 25 plantationcompanies with concessions in Kalimantan and Papua
province, including PT DRM, that largely have the same
directors and commissioners as one another.8 Apart from his
majority stake in PT DRM, Anthoni Salim has no ownershipstake in these companies;9 however, his influence on someof these companies through associates is clear, as set out inGreenpeace International’s 2017 report Dirty Bankers.10
In August 2015, job advertisements were circulated
for positions in West Kalimantan and West Papua provinces
referring to an Indo Gunta (or Indogunta) group;11 theadvertisements appeared on paper headed with the nameof PT Gunta Samba, an IndoAgri/SIMP subsidiary.12 The
Indo Gunta group now appears to be the Salim group’s
operational name for the 25 non-IndoAgri plantationcompanies mentioned above, with many of thesecompanies having been observed to be using the name (egon staff LinkedIn profiles or on signboards at plantationsites). Evidence of the group link includes shared officepremises with PT Gunta Samba and its parent company
PT Mega Citra Perdana: a 2017 job advertisement on Indo
Now or never to reformthe palm oil industry

Gunta headed paper posted on the University of Lampung
website gives its address as Duta Merlin Office Complex
B/22, Jalan Gajah Mada 3–5, Gambir, Central Jakarta,13which is the registered address for PT Gunta Samba14 andis listed in SIMP’s 2013, 2014 and 2015 annual reports
as the address of PT Mega Citra Perdana.15 It is also theregistered address of PT Gunta Samba Jaya,16 one of the
25 Indo Gunta plantation companies linked to Anthoni
Salim through his associates.
Through analysis of satellite images, recent deforestation
has been observed in the concessions of PT AnekareksaInternasional, PT Bintuni Agro Prima Perkasa, PT Duta Rendra
Mulya, PT Rimbun Sawit Papua, PT Sawit Berkat Sejahtera, PT
Sawit Khatulistiwa Lestari and PT Subur Karunia Raya.

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. No comment
was received.

Market response
AAK, Bunge, Danone, Ferrero, General Mills, Hershey,
Johnson & Johnson, Mars, Mondelēz, Nestlé, Procter &Gamble, Reckitt Benckiser, Sime Darby and Unilever told
Greenpeace that actions had been taken to exclude thegroup from their supply chains.

131CONCESSION:PT Duta Rendra Mulya(PT DRM) and PT
Sawit Khatulistiwa
Lestari (PT SKL), West
Kalimantan, Sintang
district

Clearance:
PT DRM: 1,720ha
PT SKL: 5,314ha

PT DRM: 27/04/15

Between 27 April 2015 and 2 March 2018, PT DRM clearedsome 1,720ha of forest, mostly on peatland, and including
peatland forest within the government-determined peat
protection zone.
Over the same period, PT SKL cleared 5,315ha of forest,
also including peatland forest within the governmentdetermined peat protection zone.

PT DRM: 02/03/18

Concession boundary basedon 2014 location permit(Izin Lokasi).

132

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown

3 November 2017,
PT Duta Rendra Mulya (Salim), Kalimantan,
0°14’57.15”N 111°34’54.16”E©Aidenvironment

PT SKL: 27/04/15

Now or never to reformthe palm oil industry

PT SKL: 02/03/18

133

CONCESSION:PT Bintuni Agro Prima
Perkasa (PT BAPP)
and other Papuan
concessions

Clearance: PT RSP 2,650ha

21/10/2014

The Salim group is expanding its operations rapidly
in Papua and West Papua provinces, using companies
believed to be part of the Indo Gunta group. Three ofthese – PT Rimbun Sawit Papua (PT RSP), PT Subur Karunia
Raya and PT Bintuni Agro Prima Perkasa (PT BAPP) – havebegun clearing forest in their concessions, including withinareas designated as peatland hydrological units, clearanceof which contravenes the Indonesian Government’s 2016
peat regulations.17
Between 13 September 2014 and 20 June 2018, PT
BAPP cleared nearly 100ha of forest.
Between 3 January 2015 and 16 March 2018, PT SKR
cleared about 800ha of forest.
Between 31 October 2014 and 29 July 2018, PT RSP
cleared some 2,650ha of forest, including peatland forest
within the government-determined peat protection zone
and including primary forest according to the Ministry ofEnvironment and Forestry 2015 national landcover map.
Three further companies (PT Menara Wasior, PT
Tunas Agung Sejahtera and PT Permata Nusa Mandiri) are
believed to have obtained all the main permits necessary
for clearing to begin in their concessions, and at least fourother Salim-linked companies18 have been issued location
permits in Papua since 2013.
However, in the case of PT BAPP, it is not oil palm
Concession boundary based on
BPN online 2017.

134

29/07/2018

Satellite image sources:
Sentinal 2 courtesy ofEuropean Space Agency - (ESAand Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown27 July 2018,
PT Bintuni Agro Prima Perkasa (Salim), Papua

for which the forest is being cleared, but corn. The
company gained a State Forest Release Letter from
Forestry Minister Zulkifli Hasan on 29 September
2014, his final day as minister. This was one of a raftof letters releasing State Forest land for developmentthat the minister signed on that day, many of whichwere problematic and several of which broke theministry’s own regulations.19 The stated purpose of
the Forest Release Letter was to enable developmentof an oil palm plantation; but possibly as a result of
opposition to palm oil from the Mpur people of the
Kebar Valley, the company instead applied to theDistrict Head of Tambrauw district for a location
permit to grow food crops (soya, peanuts and corn) on
the same land. This was issued in September 2015,20
on the same day as a business permit.21 The issuingof all three documents was highly irregular: the State
Forest Release Letter should not have been issued until
the company had a business licence,22 which in turnshould not have been issued until an environmental
impact assessment (EIA) had been carried out andapproved.23 In fact the EIA process has still not been
completed, even though land clearing and planting
have been ongoing for over two years. This is a serious
concern in the Kebar Valley, which is a unique mixed
ecosystem of forest and grasslands bordering onprotected forest areas, and in the headwaters of amajor river system.
Presumably soon after it had obtained thebusiness licence, PT BAPP’s representatives persuaded
the local clans to surrender their customary rights
Now or never to reformthe palm oil industry

to the land, amounting to 19,368ha. Interviews withcustomary landowners in the Kebar Valley indicatethat the company did not follow a valid FPIC process.24
In their one and only meeting with the company, clan
leaders were allegedly misled into believing that inreturn for the modest financial compensation offered
they were granting permission not for a commercial
agricultural development by the same company that
had previously proposed to plant oil palm, but merely
for a two-year trial by the district agricultural agency
that would involve only small grassland areas. They
were not shown any maps, were not given a copy ofthe document they were persuaded to sign and wereleft unaware that the company possessed a permit
covering the entire Kebar Valley area. The company
was then able to obtain cultivation rights (HGU; seeAnnex 1)25 and begin clearing not just of grassland, butof the clans’ ancestral forests.
The clans have protested against the loss of theirforests and sago groves, although the presence ofarmed Brimob guards has created an atmosphere of
intimidation.26 On 17 November 2017, members of
the Mpur ethnic group held an assembly to discuss theissue and produced a joint statement of opposition to
the company, which has attracted the support of the
Synod of the Evangelical Christian Church in Tanah
Papua and the Asian Human Rights Commission.27
Some of the clans affected have attempted to returnthe money they were given, but the company refuses
to accept it.28

135

Samling

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Main palm oil company:
Glenealy Plantations Sdn Bhd

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Samling is a family-owned group, owned by the Yaw
family: Yaw Teck Seng is the founder1 and Yaw Chee Ming
is the CEO of Samling and Managing Director of Glenealy
Plantations.2 Known concessions appear to have a formal
ownership structure.
Neither Samling nor Glenealy is a member of the
RSPO and the group has no public NDPE policy. The groupdoes not make maps of its concession boundaries publicly
available in a usable format.
Glenealy claimed a total ‘plantable area’ of 68,679ha
in Malaysia, Indonesia, Myanmar and Papua New Guinea asof March 2015, of which 14,545ha were in Indonesia. Of
this, 7,682ha were planted, in Sumatra and Kalimantan.3
Aidenvironment research has identified a total landbank of
111,600–116,600ha, including 42,100ha in Indonesia.4
Wilmar’s grievance tracker records that ‘Samling has ...
committed to a moratorium on land clearing activities intheir Malaysia and Indonesia operation,’5 although no suchcommitment appears on the group’s website.

Group response
Greenpeace provided the group the opportunity tocomment before publication of this report. No comment
was received.

Market response
Bunge and Mars told Greenpeace that actions had beentaken to exclude the group from their supply chains.

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CONCESSION:PT Tunas Borneo
Plantation (PT TBP),North Kalimantan

Clearance:
2,868haSome 2,867ha of forest were cleared within the PT TBP
concession between 2015 and June 2017, including
potential peatland forest.

28/08/2015

19/08/2018

Concession boundary basedon maps from East Kalimantan
Plantation Agency (2012).

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

137

CONCESSION:Ome Ome Project,
Papua New Guinea,
Central province
Clearance:
1,623haBetween 19 April 2015 and 22 February 2018, about
1,625ha of forest were cleared in the Ome Ome Project.
Satellite analysis of fire hotspot data suggests a strong
correlation between forest clearance in this concession andoutbreaks of fire. Between 2014 and 2017, 74 fire hotspots
were recorded in the concession, almost all within previously
cleared areas. This suggests that the company may haveused fire deliberately during its land clearing process.
Wilmar’s grievance tracker records that ‘Samling wasin the process of divesting their PNG concession in 2017,
and the divestment process has officially completed in early2018’.7 In other words, having deforested much of the land
– and presumably profited from the sale of the timber –Samling has sold the operation.
The reported sale does not erase Samling’s liability
for the deforestation it caused. If anything, it makes thesituation worse: the group now has less scope to remedy
its NDPE violations. Allowing Samling to continue to supply
palm oil to companies with NDPE policies without addressing
its deforestation of the Ome Ome Project will justencourage other producer groups to similarly evade their
responsibilities by offloading controversial concessions.

138

19/04/2105

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Concession boundary not available – location based on research
article6 and location of clearing.

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

22/02/2018

Now or never to reformthe palm oil industry

139

Sungai
Budi
Group
18 November 2017,
PT Samora Usaha Jaya (Sungai Budi), Sumatra,
3°21’41.06”S 105°27’8.47”E© Aidenvironmenty

Main palm oil company:
PT Tunas Baru Lampung Tbk

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Sungai Budi is a family-owned group, controlled by the
Widarto Oey family. Known concessions appear to have aformal ownership structure.
Sungai Budi subsidiary PT Tunas Baru Lampung Tbk(TBL) is a member of the RSPO. It has no public NDPE policy
and does not make maps of its concession boundaries
publicly available in a usable format.
TBL’s website shows a total landbank of 95,393ha foroil palm, in South Sumatra, Lampung and West Kalimantan.1
The company’s 2016 ACOP submission to the RSPO
lists only 23,375ha and does not mention land in West
Kalimantan,2 suggesting that TBL is underreporting its
landbank to the RSPO.
In November 2016, the plantation companies PT
Dinamika Graha Sarana (PT DGS, majority-owned by TBL’scontrolling shareholders) and PT Samora Usaha Jaya (PTSUJ, 99% owned by TBL) became the subject of a (pending)
Ministry of Environment and Forestry investigation.3 PT DGS
obtained a forestland release permit in May 2012 to develop
a sugarcane plantation.4 However, the released forestland
was split into PT DGS and PT SUJ, and PT SUJ started
developing an oil palm plantation (see case study below). PT
SUJ has a landbank of 27,553ha according to TBL’s website.5

Group response
Greenpeace provided the group the opportunity to comment
before publication of this report. No comment was received.

Market response
Bunge, Johnson & Johnson, Mars, Reckitt Benckiser andWilmar told Greenpeace that actions had been taken to
exclude the group from their supply chains.

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CONCESSION:PT Samora Usaha
Jaya (PT SUJ),South Sumatra,
Ogan Komering
Ilir district
Between 26 June 2015 and 30 March 2018, PT SUJ
cleared some 5,535ha of forest, much of this peatland
forest including within the government-determined peat
protection zone.
Though TBL lists PT SUJ as an oil palm company on its
website,6 it is apparently also planting sugarcane.

CLEARANCE: 5,535ha

26/06/2015

30/03/2018

Concession boundary based on
State Forest Release Letterreference SK.249/MENHUTII/2012 (for PT Dinamika
Graha Sarana).

Now or never to reformthe palm oil industry

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

141

CONCESSION:PT Solusi Jaya
Perkasa (PT SJP),
West Kalimantan,
Kubu Raya district
Between 4 May 2015 and 10 April 2018, PT SJP
cleared about 1,415ha of peatland forest, including
peatland forest within the government-determinedpeat protection zone.

04/05/2015

Clearance:
1,414ha10/04/2018

Concession boundary basedon information the company
supplied to the RSPO.

142

Satellite image sources:
Landsat 8 courtesy of the
U.S. Geological Survey.

final
countdown10 November 2017,
PT Solusi Jaya Perkasa (Sungai Budi), Kalimantan,
0°16’26.77”S; 109°54’41.17”E©Aidenvironment

Now or never to reformthe palm oil industry

143Tee familyyMain palm oil companies: Bewani Oil
Palm Plantations Ltd, Far East Holdings
Bhd and Prosper Group

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brThis is a family group in which formally separate companies
owned by members of the same family share operational ormanagerial control.
The Tee family holds a significant minority of the sharesof Far East Holdings Berhad (FEHB),1 which is listed on the
Bursa Malaysia. Prosper Trading Sdn Bhd, one of two major
shareholders in FEHB,2 is majority-owned by members of
the Tee family,3 ten of whom also have individual holdingsin FEHB. Tee family members who are FEHB shareholders
also hold directorships of FEHB: Tee Cheng Hua is Executive
Director, Plantations, while his brother Tee Kim Tee and son
Tee Lip Teng are non-executive directors.4
According to FEHB’s annual reports, its operations
encompass 13 palm oil estates covering 21,167ha,5 six
palm oil mills and a biodiesel plant in Peninsular Malaysia.6
The family has interests in another two Malaysianpalm oil mills that are not acknowledged by FEHB:
Tagar Properties Sdn Bhd (which is majority-owned by
Prosper Trading Sdn Bhd and is linked to FEHB throughthat company and Prosper Palm Oil Mill Sdn Bhd, oneof the mill companies that FEHB does acknowledge)
and Cheekah-Kemayan Plantations Sdn Bhd (in which
Tee Lip Sin – another of the FEHB shareholders – has asignificant minority interest). Although the designation
appears to have no formal basis, these business interests
present themselves collectively as the ‘Prosper Group’:
FEHB’s annual reports describe Tee Cheng Hua as the
Senior Executive Director and Tee Lip Teng as a directorof ‘Prosper Group’,7 while Greenpeace has received
correspondence from an individual purporting to be thegroup’s legal manager. Mills (including Tagar Properties
Sdn Bhd and Cheekah-Kemayan Plantations Sdn Bhd8)
are often referred to as belonging to Prosper Group in
trader and brand supplier lists.
Nine of the same Tee family members who own stakes
in FEHB together own 100% of the Papua New Guinean
company Bewani Oil Palm Plantations Ltd (BOPPL).9 Tee
Kim Tee is a director of the company.10 The company issubleasing a 139,909ha oil palm concession in Sandaun
province, Papua New Guinea.11 In June 2018, BOPPL
confirmed that its sister mill Vanimo Green Palm Oil Ltd
was due to commence operation;12 the first shipment was
final
countdown6 April 2016,
Bewani Oil Palm Plantations (Tee Family),
Sandaun, Papua New Guinea

scheduled to leave in July.13 A representative of ‘Prosper
Group’ has denied to Greenpeace that the group has
any connection to BOPPL, despite the close family links
between the businesses and additional evidence such as
the Bewani palm oil project being launched with an official
signing ceremony between Prosper Palm Oil Products
Marketing Sdn Bhd (a company owned by Prosper Palm
Oil Mill Sdn Bhd and its parent company Winners Acres,and of which Tee Lip Teng is a director14) and the peopleof Bewani (with the agreement being signed by thethen Managing Director of ‘Prosper Group’, Tee Kim
Tee). Strikingly, an article about the ceremony on thewebsite of the Malaysian High Commission in Papua New
Guinea15 appears to have been doctored years after its
original publication16 to remove all references to Prosper
Group and Prosper Palm Oil Products Marketing Sdn
Bhd, including photographs of press cuttings, with thewording ‘Prosper Palm Oil Products Marketing Sdn Bhd,
Kelana Jaya, Selangor’ being replaced by ‘Bewani Oil Palm
Plantations Limited’.
In contravention of RSPO rules on group membership,17
only one company associated with the Tee family is a
Now or never to reformthe palm oil industry

member of the RSPO: Future Prelude Sdn Bhd, operator of
the aforementioned biodiesel plant belonging to FEHB.18 No
known Tee family–associated company has a public NDPE
policy. None of the companies associated with the Tee family
makes maps of its concession boundaries publicly available ina usable format.

Group response
Greenpeace provided the group the opportunity to comment
before publication of this report. On 13 September, after
expiry of the time window for commenting, Jennifer Lam,legal manager for the Prosper Group, replied, stating that thecompany was preparing a full reply but that ‘we reckon you
will not proceed with the publication of the allegations... asthey are factually and legally incorrect, clearly defamatory’,
without elaborating. She failed to provide concession maps
for the group’s operations.
Greenpeace stands by the findings of this report.

Market response
Mars told Greenpeace that actions had been taken to
exclude the group from its supply chain.

145

CONCESSION:

Bewani Oil Palm
Plantations Ltd(BOPPL), Papua
New Guinea,
Sandaun province

Clearance:
13,462ha

Between 25 January 2015 and 28 July 2018, BOPPL
cleared some 13,460ha of forest. According to
Chain Reaction Research, more than 1,500ha were
deforested in 2018.20
The project has a troubled history predating
BOPPL’s involvement. It was established under a
SABL, a type of licence declared invalid in March2017 by the government of Papua New Guinea,21though this cancellation has not yet been fully
enforced. A Commission of Inquiry in 2013 foundthat ‘Informed consent of the landowners … was not
obtained prior to the issuing of the SABL title’22 andthat ‘Garden areas, sago patches and hunting grounds
and other areas of importance to the majority of thepeople within the SABL area … were not preserved.’23
The land is described as ‘139,909 hectares of virgin
tropical rainforest’24 and the means by which thelease was obtained are described diplomatically by

the Commission of Inquiry as ‘almost criminal’.25
The Commission’s recommendation (which
was subsequently quashed, without regard for thecorrectness of the decision) was that the SABL be‘revoked and reviewed’.26 The local NGO ActNow
PNG reports that “Malaysian logging companies”
used force to encourage local people to sign overrights to their land,27 and has published accusations
by regional leaders that the police and army havebeen providing support to the company.28 In 2017,
InfoSawit reported that BOPPL was sending FFB fromits plantation some 76km across the international
border from PNG into Indonesia’s Papua province toa mill owned by PT Perkebunan Nusantara II29 – theIndonesian government–owned plantation company.
As noted above, BOPPL’s own mill may now have beencommissioned, with oil being shipped directly to theglobal market.

6 April 2016,
Bewani Oil Palm Plantations (Tee),
Sandaun, Papua New Guinea

146

final
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25/01/2015

Concession boundary based on Special Agriculture and- Business
Lease (SABL), as depicted in Global Witness report Stained Trade.19

28/07/2018

Satellite image sources:
Landsat 8 courtesy of the U.S. Geological Survey.

7 April 2016,
Bewani Oil Palm Plantations (Tee Family),
Sandaun, Papua New Guinea
3°6’19.548”S 141°23’8.892”E

Now or never to reformthe palm oil industry

147

17 September 2017, Kalimantan©Syafi/Greenpeace31 March 2018, Papua
Ifansasti/Greenpeace

©

150

final
countdownAnnexes
andappendices
Now or never to reformthe palm oil industry

151

ANNEX 1:

Legal permits required to establish
and develop an oil palm plantation

Permit process
Industrial-scale oil palm plantations in Indonesia require
permits both to establish land rights and to develop the land.
The process includes the following permits, guidelines andlegal documents:
1. Usually, an Indonesian limited company (Perseroan
Terbatas; PT) must be established. Regulations limit
the area of oil palm plantation held per company orgroup of companies to 20,000ha per province,1 andnationally to a total of 100,000ha. The maximum
total area is doubled to 40,000ha for operations
located in Papua and West Papua provinces.
Exceptions are made for cooperatives, state-owned
companies and publicly listed companies where themajority of shares are held by the public.2
2. District governments may issue preliminary
documents with names such as in-principle permit(Izin Prinsip), land information permit (Izin Info Lahan)or in-principle location referral (Persetujuan Prinsip
Arahan Lokasi) indicating that a company is allowed tosurvey the land and to consult with landowners.
3. A location permit (Izin Lokasi) is issued by the
district head (bupati) or by the provincial governor
where the permit area falls across two districts.3
Regulations state that neither location permits
nor in-principle permits may be issued outside
areas where plantation development is permitted
according to the district spatial plan.4 The location
permit itself does not give a company landholding
rights;5 it gives the company the opportunity toseek to acquire those rights from the state orfrom private landholders, as the case may be,
through appropriate compensation payment once
landholders’ agreement is secured.6 The acquisition
should be based on consultations with the current
landowners, including the Ministry of Environment
and Forestry (MoEF), other plantation companies
and local communities.
Under regulations in place since 1999 andupdated in 2015, location permits are valid forthree years7 with a further year’s extension
possible in cases where a company has acquired
rights over more than 50% of the land within the152

location permit area.8 Previously, under the 1993
regulations, a location permit was limited to one
year, with a maximum extension of one year.9
Where a company secures rights over morethan half the location permit area before thepermit period (plus extension) expires, the location
permit area is reduced accordingly and subsequent
steps in the plantation permitting process may
continue. Where rights have not been secured orhave been secured over less than half the area, theconcession is forfeited.10
4. State Forest (Kawasan Hutan Negara) is a legal
designation and does not necessarily indicate thepresence of natural forest in an area. Where the areaof interest designated under the location permit
includes State Forest, the MoEF must approve therelease of forestland through a State Forest Release
Letter (SK Pelepasan Kawasan Hutan), and the landarea must be delineated and its status converted
to ‘other land uses’ (Areal Penggunaan Lain; APL).11
Conducting land clearing and other operations withinState Forest prior to the completion of the releaseprocess is a criminal offence under forestry law.12
Only ‘convertible production forest’ (Hutan Produksi
Yang Dapat Dikonversi; HPK) may be released.13
5. An environmental permit (Izin Lingkungan) isissued when the regional environmental impact
assessment commission (Komisi AMDAL Daerah) is
satisfied with the environmental impact assessment(Analisis Mengenai Dampak Lingkungan; AMDAL).
An environmental impact assessment consists ofan Environmental Impact Study (Analisis Dampak
Lingkungan Hidup; ANDAL), an Environmental
Monitoring Plan (Rencana Pemantauan Lingkungan
Hidup; RPL) and an Environmental Management Plan
(Rencana Pengelolaan Lingkungan Hidup; RKL).
Under the original Plantation Law 2004,14 andcontinuing under the current Plantation Law 2014,15
a plantation business permit must not be issued to
a company until it has produced an environmental
impact assessment. Since 2009 it has been acriminal offence under environmental law to operate
without this permit.16
final
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The Plantation Law requires environmental
monitoring, risk analysis and adherence tothe environmental plan.17 It also requires thegovernment to involve the community in monitoring
companies,18 and requires companies to carryout their own reporting. The law states that suchreporting ‘constitutes public information which mustbe published and be made openly available to the
public’.19 The Environment Law 2009 also enshrines
the public right to access environmental information,
including environmental impact assessments,
environmental monitoring and government
monitoring of companies’ legal compliance.20
6. A plantation business permit (Izin Usaha Perkebunan;
IUP) is issued by the district head or by the provincial
governor, where the area falls across more than one
district. It allows a company to develop a nursery andcarry out land preparation and clearing on undisputed
land within the area covered by the location permit.
It provides no rights to land but is merely a licence tooperate; operating without one is a criminal offence.21
Plantation business permits must only be issued
over areas permitted under district spatial plans,22 andcannot be issued prior to an environmental permit.23
IUPs must not be issued over indigenous lands, except
where the consent of traditional landowners has beenobtained;24 breaching this protection is punishable by
up to five years’ imprisonment.25
7. Plasma is the name for community plantations thata company must facilitate for the benefit of people
living in the area surrounding its plantation. Plasma
should cover at least 20% of the total company
concession area and must be established within three
years of securing a plantation business permit.26
Funding assistance is to be provided in the form ofcredit, profit sharing or similar.
8. Under Indonesia’s Basic Agrarian Law, all land
is ultimately owned by the state.27 After being
granted a location permit and completing acquisition
negotiations over the land it intends to use toestablish a plantation, a company must apply fora land use permit, known as land cultivation right(Hak Guna Usaha; HGU).28 Land cultivation right is a
Now or never to reformthe palm oil industry

temporary land title in the form of an HGU certificate
issued by the National Land Agency (Badan
Pertanahan Nasional; BPN)29 and is valid for up to 35
years, extendable for up to a further 25 years.30 Land
cultivation right may be used as collateral for loans
and may be transferred to another company. Only
Indonesian citizens and companies incorporated inIndonesia, including foreign investment companies,
can be granted land cultivation right.
Legally, land cultivation right is granted only
over non–State Forest land (APL; see [4] above).
Time limits apply: companies are required to obtain
land cultivation right within two years of receiving aplantation business permit31 and where a company
has been required to obtain a State Forest Release
Letter see [4] above),32 the forest release may becancelled if the company fails to obtain an HGUcertificate within one year.33
Land cultivation right must be secured before acompany commences plantation operations.34
The Indonesian Sustainable Palm Oil (ISPO)
standard, introduced by the government in 2011, ismandatory for all large plantation companies. The
standard, which largely seeks to ensure compliancewith existing legislation, specifically requires
companies to have an HGU certificate (criterion 1.4)
and is explicit about legal requirements regarding
land and permits.35
9. A timber utilisation permit (Izin Pemanfaatan Kayu;
IPK) must be obtained by a plantation company or its
contractor prior to clearing any forest with remaining,commercially viable standing timber.36 The IPK is notdirectly connected to the land acquisition permits andplantation business permit.
To obtain an IPK, a timber stand survey must
be conducted to estimate royalties payable. These
include stumpage fees (Penggantian Nilai Tegakan) and
Reforestation Fund (Dana Reboisasi) contributions.37
Based on the survey, the company must deposit a bankguarantee for 100% of the expected yield. Thereupon,
if an environmental permit and (where applicable) a
State Forest Release Letter have been submitted, theIPK will be issued by the local Forestry Office.

153

22 September 2017,
Gunung Palung National Park,
Kalimantan
Sukarno/Greenpeace

©

154

final
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ANNEX 2:

Producer group identificationand case study selection

The palm oil producer group profiles and case studies
presented here focus on groups’ involvement in deforestationand peatland clearance. Spatial analysis exposing these
violations of NDPE policies can be carried out quickly andremotely. The companies responsible can choose to end
clearance activities immediately. Violations of the social
component of NDPE policies (including failure to obtainthe free, prior and informed consent (FPIC) of affected
communities; reliance on the coercive presence of security
forces; and use of child or forced labour) are just as importantas deforestation and peatland destruction but are much harder
to monitor and often slower to rectify. In this report, somesocial issues have been noted where information was available(eg with regard to PT Austindo Nusantara Jaya); however,identifying such violations was not the primary objective.
The producer groups discussed in this report are
generally listed under the group names traders are likely
to be familiar with, though these sometimes appear underthe ‘Main palm oil company’ heading in cases where thegroup also has other interests (eg Lembaga Tabung Haji/THPlantations) or where the group structure is informal and the
key family or individual has control of more than one major
palm oil company (eg Salim/IndoAgri). The list of groups is
not comprehensive, nor do the case studies for each groupconstitute a complete review of their violations.
The analysis underlying the profiles and case studies
is based primarily on a review of publicly available
Now or never to reformthe palm oil industry

information. Primary sources of information used
included RSPO Annual Communications of Progress(ACOPs) and producers’ annual reports and stock market
disclosures, as well as official Indonesian, Malaysian or
Singaporean corporate registry profiles, which detailcurrent and historic shareholders, commissioners
and directors in addition to registered addresses forcompanies. Social network profiles (eg Facebook,
Instagram, LinkedIn), media reports, court transcripts andother public domain sources were also drawn upon, while
photographs and testimonies from workers, membersof affected communities and reports from other NGOs
provided supporting evidence.
While every effort has been made to keep
information up to date and reflect current ownership
structures, many of the producer groups discussed
frequently restructure the ownership or managementof their plantation companies – perhaps in part to
obscure their true control. The full extent of a group’s
control of plantation companies and mills may therefore
be underestimated.
Prior to publication Greenpeace contacted all the
producer groups discussed in this report to offer themthe opportunity to comment on the findings. Responses
received can be viewed in full at the following location:
https://drive.google.com/drive/folders/1GOCTrTgu-_
LVZsSLm8ToLBBydSHL3uZI?usp=sharing.

155

ANNEX 3:

Mapping methodology
for this report

Public availability of concession information is an importantvehicle for limiting the corruption that drives deforestation,verifying that FPIC is upheld and ensuring accountability
across the palm oil sector. Accurate and publicly available
official maps showing the concessions belonging to eachproducer group would demonstrate who controls the forests– and thus play a key role in identifying who is responsiblefor deforestation, peatland development and social conflict.
Combining such maps with satellite imagery allows improved
analysis and monitoring of land clearance, planting and otherplantation activities. However, neither the governments ofIndonesia or Malaysia, nor any of the major palm oil producergroups currently publish in a usable format up-to-date mapsof all their palm oil concession boundaries and ownership.
Prior to publication Greenpeace contacted all the
producer groups discussed in this report to request
comprehensive and current lists and maps of group mills andconcessions. Most did not respond to this request. The partial
exceptions are POSCO, which holds only one concession, and
IOI which has recently published boundaries for its Indonesianconcessions but claimed in a letter to Greenpeace that it isprevented by law from doing so for its Malaysian concessions.
At present, therefore, information about concession
boundaries (as well as about concession and mill ownership– see above) must be pieced together from a variety ofsources, which may be incomplete, out of date or inaccurate.
The case studies in this report are based on the best available
concession maps, usually obtained by requesting documentsfrom the licensing agencies and digitising maps from individual
concessions’ permit documents. (See Annex 1 for an
explanation of the plantation permit process.) In determining
boundaries for case studies, permits from later in the process

156

1 September 2005,
Lake Murray, Papua New Guinea
Sewell/Greenpeace©

have been preferred where available (eg HGU boundaries are
preferred to Izin Lokasi boundaries). Boundaries have beenchecked against (or, in the absence of other sources takenfrom) RSPO New Planting Procedure (NPP) documents wherethese are available.
In some cases, where no official permit information or
NPP documents are available, concession ownership andlocation can only be inferred from local media sources orby observing clearance and plantation development bymeans of satellite imagery. The satellite imagery used for thecase studies in this report is from USGS, ESA and Planet Inc(Landsat 5, 7 and 8 and Sentinel 2, Planet) accessed through
Google Earth Engine, Landviewer and www.planet.com. In
some cases, imagery was compiled from different dates (egover a month) to provide a relatively cloud-free view. Satellite
image analysis to identify deforestation, development andplanting was carried out by Aidenvironment and Greenpeace.
In order to identify plantation development within
known concessions on forestland, satellite images from2015, 2017 and 2018 were overlaid with concession
boundaries and official landcover maps were analysed using
GIS (Geographical Information System) software. Presenceor absence of forest was confirmed visually, and areas offorest loss measured. To identify deforestation on peatland
or within the government-determined peat protection zone
and loss of orangutan habitat, areas with forest loss wereoverlaid with peat and habitat maps. In all but one case study(PT LAIK), both recognised peatland maps used confirmed thepresence of peat. In the case of PT LAIK, only the Wetlands
International map showed peat. The analyses presented here
do not include an assessment of loss of high carbon stock(HCS) forest, which requires detailed field work.
final
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ANNEX 3:

Sources

Initial identificationof land cover:
MoEF (2015) National Forest Monitoring System http://nfms.dephut.
go.id/ArcGIS/rest/services/Land-

26 March 2018, Papua,
8°10’47.495”S 138°42’45.509”E©Ifansasti/Greenpeace

coverRC_Upd/LandcoverRC_2013_Upd/
MapServer accessed September 2015
26 March 2018, Papua,
8°20’10.433”S
138°44’54.545”E©Ifansasti/Greenpeace

Peatmaps:
MoEF (2017) ‘Peat ecological function’ http://
geoportal.menlhk.go.id/arcgis/rest/services/
KLHK_EN/Peat_Ecological_Function/MapServer
Ritung S et al (2011) ‘Map of Indonsian peatlands at 1:250,000 scale / Peta
lahan gambut Indonesia skala 1:250.000’
Wahyunto et al (2003–2006) ‘Maps of peatland
distribution area and carbon content in Sumatra(2003), Kalimantan (2004) and Papua (2006) / Peta-peta sebaran lahan gambut, luas dan kandungankarbon di Sumatera (2003), Kalimantan (2004) dan
Papua (2006)’ Wetlands International – Indonesia
Programme & Wildlife Habitat Canada (WHC)

Orangutan habitat:
IUCN/SSC Conservation Breeding Specialist Group (2017) ‘Final report:
Orangutan population and habitat
viability assessment’ http://forina.
or.id/orangutan-population-and-habitat-viability-assessment-2016/

Now or never to reformthe palm oil industry

8 October 2007,
Kalimantan©Behring/Greenpeace157

1 April 2018, PT Inocin Abadi (Korindo), Papua,
6°51’37.374”S 140°41’23.483”E
Ifansasti/Greenpeace©

©Hamilton/Greenpeace

158

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ANNEX 4:

Note on analysis of trader dashboards andidentification of group chain-of-custody links

In the last two years, many palm oil traders have taken awelcome step towards transparency and the implementation
of NDPE commitments by publishing details of the millsthat supply them, usually as part of the online ‘sustainability
dashboards’ on which they publish statistics relating totheir progress towards their NDPE commitments. Since thepalm oil industry is vertically integrated, with most traders
engaging in refining of crude palm oil (CPO) and palm kerneloil (PKO) and manufacturing oleochemicals and specialty fats,
this information is often presented in the form of summary
reports for each of the trader’s downstream processing units,
showing the originating mills for all the palm oil or PKO thathas entered that unit. Identifying information for each mill
may include GPS coordinates, the name of the plantationcompany that owns the mill (referred to as the ‘third-party
supplier’) and/or the ultimate group owner (parent company).
For this report we analysed mill data from the following
palm oil traders, covering the most recently available periods asof May 2018, as noted: AAK (undated, published May 2018),38
Apical (Q4 2017–Q1 2018),39 Cargill (Q4 2017),40 Bunge
Loders Croklaan (Jan–Dec 2017, for what were at the time
IOI Loders Croklaan’s downstream processing units),41 GAR(Jan–Dec 2017),42 Musim Mas (Q4 2017–Q1 2018),43 Olam(2017),44 Sime Darby (Jan–Sep 2018)45 and Wilmar (Jan–Dec
2017).46 (Some dashboards may now have more recent data
available.) IOI Group’s mill lists47 for its refineries not acquiredby Bunge have now been made public, as have the lists of millsin the supply chains for Fuji Oil,48 Louis Dreyfus Corporation49
and Mewah,50 but these were not available at the time ofanalysis and are therefore not included in this report.
Traders that have not made details of their mill supply
bases publicly available include Astra Agro Lestari and KLK.
Despite the large number of traders that have madetheir mill data available, and despite consumer brands
ostensibly having access to their suppliers’ mill data, prior
to 2018 no consumer brand published full details of themills and producer groups that produced the palm oil thatit received from its suppliers. In January 2018, therefore,
Greenpeace challenged a number of consumer brands with
NDPE commitments to publish lists of the mills in their palm
oil supply chains, along with the producer groups controllingthose mills.51 Several brands rose to this challenge, and more
continue to follow, although – as noted below – the quality of
the information is variable and generally brands significantly
underreport their exposure to producer groups.
Now or never to reformthe palm oil industry

For this report, we analysed the published millinformation of the following brands, covering the time periods
indicated: Colgate-Palmolive (2017),52 Danone (2017),53
Ferrero (January–June 2017),54 General Mills (undated,published March 2018),55 The Hershey Company (January–
June 2017),56 Johnson & Johnson (2017),57 Kellogg Company(2017),58 L’Oréal (2017),59 Mars (2016),60 Mondelēz
International (undated ‘snapshot’, published March 2018),61
Nestlé (‘snapshot November 2017’),62 PepsiCo (2017),63 P&G(2017),64 PZ Cussons (undated, published March 2018),65
Reckitt Benckiser (2017)66 and Unilever (2017).67 Kraft
Heinz recently published links to the most recent mill lists of
its main palm oil suppliers (AAK, ADM and Sime Darby), which
we have taken as the brand’s most recent mill information.68
Smuckers did not respond to our request to publish listsof the mills in its supply chain.
Disclosures by traders and brands are not standardised,with the scope and the quality of the traceability data varying
widely. Greenpeace analysis revealed a range of omissions,inaccuracies and discrepancies. Notably, information on
the producer groups owning the mills is often out of date,incomplete or missing entirely. Mill names are spelledinconsistently and GPS coordinates are not universallyprovided. Many of the producer groups identified in thisreport incorporate several discrete subgroups; when asked
about their exposure to these producer groups, sometraders or brands responded that they were not exposed
to a particular subgroup, while not commenting on theirrelationship with the producer group as a whole, even though
their disclosed mill data revealed supply from other parts ofthe group that they failed to identify.
In view of the deficiencies in the data provided by brands,
traders and producers, Greenpeace’s analysis of the trading
relationships between the 25 problematic producer groups
reviewed in this report and the global market is based on
our own extensive working data sets, identifying groups’
known concessions, mills and refineries. Data sources include
company annual reports and websites, corporate registry
profiles, permits and RSPO/ISPO documentation, as well as
the available concession mapping as described in Annex 3.
In assigning probable current group-level ownership to themills disclosed in brand and trader traceability data, we havedefined and applied a source hierarchy to determine whichsources are most accurate, authoritative and up-to-date, incases where multiple sources are available.69

159

11 September 2008, Papua©Beltrá/Greenpeace

160

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APPENDIX 1:

Chain Reaction Research’s
52 leakage refiners

12 November 2007, Dumai, Riau©Åslund/Greenpeace

As part of the research for its November 2017 report on refinersthat are not compliant with NDPE requirements,70 Chain Reaction
Research identified a total of 52 leakage refiners:71• 3F Group (India)• Agri Asia Group (Indonesia)• Agro Jaya Perdana (Indonesia)•	Almarbaee Holding Company(Saudi Arabia)• BCL Industries & Infrastructure(India)• BEST Group (Indonesia)• Bina Karya Prima (Indonesia)• Bintang Tenera (Indonesia)• BL Agro Oils (India)• BLD Plantation (Malaysia)• Camela (Nigeria)• Chinatex Corporation (China)• Deli Muda (Indonesia)• Dutapalma/Darmex (Indonesia)• Edible Group (India)• EFKO Group (Russia)• Emami Group (India)• Felda IFFCO (Malaysia)
Now or never to reformthe palm oil industry

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Gokul Group (India)
Great Wall Enterprise (Taiwan)
Green Ocean (Malaysia)
Hasil Karsa Group (Indonesia)
Incasi Raya (Indonesia)
Keck Seng Group (Malaysia)
Kretam Holdings (Malaysia)
Kurnia Tunggal (Indonesia)
Kwantas Corporation (Malaysia)
Lam Soon Group (Malaysia)
Muridke Refine Oil Mills (Pakistan)
MVO (Malaysia)
Nisshin Oil (China)
Pacific Inter-Link (PIL)/HSA Group(Malaysia/Yemen)
Pamina Adolina (Indonesia)
Royal Industries/Royal Group(Indonesia)
Ruchi Soya Industries (India)
Sangsook Industry (Thailand)

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Sarawak Oil Palms (Malaysia)
Sarimas (Indonesia)
SARL Group (India)
Sawit Asahan Tetap Utuh
(Indonesia)
Sawit Kinabalu SDN BHD(Malaysia)
Sawit Raya (Malaysia)
Senari Synergy (Malaysia)
Sheel Chand Agroils (India)
Siat (Nigeria)
Soon Soon (Malaysia)
Southern Group (Malaysia)
SSD Oil Mills Company (India)
Syarikat Kion Hoong
Cooking Oil Mills (Malaysia)
Tunas Baru Lampung (Indonesia)
Uni-President Enterprises(China)Yee Lee Group (Malaysia)

161

Endnotes
PART 1

1.	Consumer Goods Forum (2010)19.	IUCN Red List of Threatened

37.	Greenpeace International (2018a)

2.	Wilmar International Ltd (2013b) p8

Species website ‘Elephas

38.	Ling LS (2016)

3.	Chain Reaction Research (2017c)

maximus ssp. sumatranus’

39.	RSPO website ‘GeoRSPO –4.	Greenpeace mapping analysis

20.	Briggs H (2017)

5.	Wilmar International Ltd (2013b)

21.	International Rhino Foundation

6.	Unilever (2018)website ‘Sumatran rhino

7.	Cartwright J (2016)(Dicerorhinus sumatrensis)’

8.	Greenpeace mapping analysis.

RSPO mapbuilder app’40.	Kuok KH (2018b)
41.	Greenpeace analysis; see alsoeg Gore-Langton L (2017)22.	Meijaard E et al (2018) p75

42.	Wilmar International Ltd (2018a) p4

See also Wijaya A et al (2017)23.	Mongabay.com (2016)43.	RSPO website ‘Wilmar

and Gaveau DFL et al (2016).

24.	Jong HN (2018)

International Limited’

25.	Several examples are detailed in44.	Wilmar International Ltd (2013a)

natural forest. Sources:

the case studies in Greenpeace

45.	Steering Group on No Deforestation

1990–2012: MoEF (2016b)

International (2017a). See also RSPO

and the High Carbon Stock

Table Annex 5.1, pp90–1

website ‘Case tracker: PT Nabire

Approach (2015) p5– gross deforestation

Baru’ (Goodhope), Environmental

46.	Greenpeace International (2018c)

21,339,301ha

Investigation Agency & Telepak

47.	Greenpeace International (2018c)

2012–2013: MoEF (2014)(2012) (Noble), RSPO website ‘Case

48.	Wilmar International

Lampiran 1, Tabel 1.1 – grosstracker: PT Henrison Inti Persada

deforestation 953,977ha

subsidiary of RSPO member Noble

49.	Daubach T (2018)

2013–2014: MoEF (2015)

Plantation Pte Ltd’ (Noble),50.	Wilmar International website

Lampiran 1, Tabel 1.1 – grossLangowuyo Y (2014) (Rajawali)

deforestation 567,997ha

and Thoumi G (2017) (Salim).

2014–2015: MoEF (2016a)

26.	Amnesty International (2016b)

Lampiran 1, Tabel 1.1 – gross27.	OPPUK, Rainforest Action

9.	Figures cover loss ofdeforestation 1,223,553ha
10.	UK total area: 24,249,500ha‘Tropical oils: Plantations’51.	Wilmar International website‘Oil palm plantation Mar 2017’52.	Frazer S (2015)

Network & International

53.	First Pacific Company Ltd (2017) p239

Labor Rights Forum (2017)54.	RSPO website ‘Case tracker:(source: https://en.wikipedia.

28.	See eg TNS (2015).

org/wiki/United_Kingdom)

29.	See eg Bellantonio M et al

11.	Greenpeace mapping analysis

Ltd (2018a) p24(2017), Mighty Earth (2017b)

PT Permata Hijau Pasaman 1(Wilmar International Ltd)’
55.	RSPO website ‘Case tracker:

12.	Greenpeace mapping analysis

and Harvey F (2017).

PT Bumi Sawit Kencana II’

13.	GFED website ‘2015 fire season’30.	Delegation of the European

56.	Forest Peoples Programme (2018)

Union to Malaysia (2018)57.	Amnesty International (2016a)

and Harris N et al (2015)14.	Koplitz SN et al (2016)31.	SPAR (2018)58.	Kiezebrink V (2017)15.	World Bank Group (2016)32.	Iceland website ‘Palm oil’

59.	Greenpeace analysis of Wilmar

16.	Luskin MS, Albert WR &33.	Consumer Goods Forum (2010)refinery summary reports and mill

34.	Forest Trends (2017) p3

lists (source: Wilmar International

Tobler MW (2017)17.	Voigt M et al (2018)35.	Greenpeace International (2018a)

website ‘Supply chain map’)

18.	Greenpeace mapping analysis

36.	Greenpeace International (2017c)

60.	Wilmar International Ltd (2013a)

162

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countdown61.	Kuok KH (2018a)

capital of the corporation, and/cut-off date should be suspended

62.	George P (2018)

or who satisfies the other criteria

unless the producer commits to63.	Wilmar International Ltd (2018d)

set out in this Presidential

restoring the relevant areas

64.	Greenpeace analysis of Wilmar

Regulation’ (source: ABNR (2018)).

(and to obtaining independent

refinery summary reports and mill75.	ABNR (2018)

third-party verification

lists (source: Wilmar International76.	Chain Reaction Research (2017c) p1

that all its plantations

website ‘Supply chain map’)77.	Chain Reaction Research (2017c) p7

65.	Unofficial translation. The

78.	Chain Reaction Research (2017c) p2

original reads ‘Kelompok (group)
Perusahaan Perkebunan adalah
kumpulan orang atau badan usaha
perkebunan yang satu sama lain
mempunyai kaitan dalam hal
kepemilikan, kepengurusan, dan/atau hubungan keuangan’. Source:
Minister of Agriculture (2013) p4.

79.	Chain Reaction Research(2018c) pp8–9(2017c) pp7–8‘Palm oil Indonesia update:
December 13, 2016’82.	Pearce F (2014)83.	TFT website ‘Members’ and ‘Clients’84.	Proforest website

Pension Fund Global (2015b) p1‘About us – Implementing
responsible practices’85.	TFT (2017b) p2

69.	RSPO (2017) pp6–7, clause 5.2

86.	TFT (2017a)

70.	Wilmar International Ltd (2013a)87.	Brandeis L (1914) p92

71.	Bumitama Agri Ltd (2015b) p7

88.	Tempo.co (2014) and Greenpeace

72.	President of the Republicof Indonesia (2018)73.	ABNR (2018)74.	Defined in the regulation as ‘anindividual who enjoys the power toInternational (2014)89.	High Carbon Stock Approach website‘The HCS Approach toolkit’
90.	HCVRN & HCSA (2017)91.	Conversion cut-off dates areappoint and remove the directors,common practice in certificationcommissioners, managers,

schemes; when properly enforced

trustees, or supervisors of athey discourage deforestation

corporation, who has control overby ensuring that producers know

the corporation, who is entitled tothey will be unable to sell theirreceive, and/or actually receives,

products if they continue to

direct or indirect benefit fromclear forest. Trade with producers

the corporation, who is the truethat have cleared forest or

owner of the assets or sharedeveloped peatlands after the

Now or never to reformthe palm oil industry

equivalent; see POIG (2016).

81.	TFT Transparency Hub website

67.	Minister of Agriculture (2013)68.	Council on Ethics for the Government(POIG) Verification Indicators or80.	Chain Reaction Research

66.	RSPO (2013a)
p4 (unofficial translation)

are now NDPE-compliant).
92.	Using the Palm Oil Innovation Group163

Endnotes
CASE STUDIES

Anglo-Eastern Plantations

19.	Mucholik I (2016). The judges

1.	Anglo-Eastern Plantations

accepted ANJ’s argument that the

PLC (2017) p37

case should also have included

2.	Anglo-Eastern Plantations

the individuals who had accepted

PLC (2017) p27

Austindo Nusantara Jaya
1.	PT Austindo Nusantara
Jaya Tbk (2017) p32
2.	The Nature Conservancy
Indonesia (2017)

money from the company.

Bumitama Agri Ltd (2012) p33; seealso Bumitama Agri Ltd (2014b).
10.	Corporate registry profiles; seecase studies for details.
11.	RSPO website ‘Bumitama Agri Ltd’

20.	awasMIFEE (2017d)

12.	Bumitama Agri Ltd (2015b)

21.	Yayasan Pusaka et al (2017)13.	Bumitama Agri Ltd (2018a) pp98–9

22.	awasMIFEE (2017d)

14.	Bumitama Agri Ltd (2018a) p3

Bumitama
1.	To aid comprehension, the term

15.	Bumitama Agri Ltd (2012) p25
16.	Bumitama Agri Ltd (2012) p32
17.	Bumitama Agri Ltd (2012) p47.

3.	PT Austindo Nusantara‘Bumitama’ is used throughout

Jaya Tbk (2016b)

this section when referring to

4.	PT Austindo Nusantara

companies owned, controlled

Jaya Tbk (2018) pp28

or managed by the officiallyIjin Prinsip of 11,104 hectares, of

5.	PT Austindo Nusantara

recognised parent company, ie

which 8,684 hectares have expired

Jaya Tbk (2016a) p7

Bumitama Agri Ltd (BAL) and its

Ijin Prinsip; (b) Ijin Lokasi of

6.	Sudaka S (2016)

subsidiaries. When describing

136,320 hectares, of which 111,820

7.	PT Austindo Nusantara Jaya

explicit ownership links between

Tbk (2017) pp132, 136

companies, the term ‘BAL’ is used.

8.	RSPO website ‘New planting

2.	Held through Wellpoint

procedures public notification’‘Title’ here refers to HGU and/or freehold (Hak Milik).
18.	Bumitama Agri Ltd (2012) p45: ‘(a)hectares have expired Ijin Lokasi’.
19.	Bumitama Agri Ltd (2012) p175
20.	Bumitama Agri Ltd (2012) p46: ‘(c)Pacific Holdings Ltd, a wholly

Hak Guna Usaha of 32,729 hectares;

owned subsidiary of Fortuneand (d) Plasma Programme of

Ecological Function map (http://

Holdings Ltd. Source: Bumitama

11,795 hectares where the plasma

geoportal.menlhk.go.id/arcgis/

Agri Ltd (2018a) p142.

holders have obtained their own

9.	See for instance the Peat

rest/services/KLHK_EN/Peat_

3.	Held through Oakridge Investments

Ijin Lokasi and/or Hak Milik’.

Pte Ltd and Lynwood Capital

21.	See, for example, RSPO (2013a)

10.	Moran S (2017)

Resources Pte Ltd, both wholly22.	RSPO website ‘Complaints’

11.	Yaacob S (2018)

owned subsidiaries of IOI

23.	Bumitama Agri Ltd (2016d) p100

12.	Yaacob S (2018)

Corporation Berhad. Source:

regarding the acquisition

Ecological_Function/MapServer).

13.	RSPO website ‘New planting

Bumitama Agri Ltd (2018a) p142.

of PT Nabati Agro Subur

procedures public notification:

4.

Castle J et al (2007) p82

24.	Bumitama Agri Ltd (2016b) p1

PT Austindo Nusantara Jaya

5.	IOI Group website ‘Dato’

regarding the acquisition of– PT Permata Putera Mandiri’and ‘New planting procedures
public notification: ANJA – PT
Putera Manunggal Perkasa’
14.	HCV Resource Network website‘Ongoing and historicalevaluations of assessment

Lee Yeow Chor’
6.	Bumitama Agri Ltd website‘Dato’ Lee Yeow Chor’
7.	Bumitama Agri Ltd (2018a) pp2, 154
8.	Bumitama Agri Ltd (2013) p101;
Bumitama Agri Ltd (2018a) p97
9.	For example, the PT Gunajaya Harapan

reports’ accessed 22 November

Lestari (PT GHL) and PT Golden

2017. At the time of writing theYouth Plantation Indonesia (PTassessment is under appeal.

GYP) concessions were managed by

15.	Google Earth Engine,

PT Langgeng Makmur Sejahtera
25.	Bumitama Agri Ltd (2016a) p4
regarding the acquisition of
PT Damai Agro Sejahtera
26.	Mach M (2017a)
27.	Corporate registry profiles
28.	Corporate registry profile
for PT GHL; Bumitama AgriLtd website ‘Contact us’
29.	‘Pursuant to the GY Cooperation

Bumitama under the GHL Cooperation

Agreement and GHL Cooperation

Agreement and the GY Cooperation

Agreement, the Group will (i) manage

16.	awasMIFEE (2017a)

Agreement for several years

and operate the plantations of GMS

17.	Suara Pusaka (2015c)

from 2011 while they continued

and GHL in return for a management

18.	Suara Pusaka (2015a) andto be owned by members of thefee; (ii) have the exclusive right

Suara Pusaka (2015b)

Lim Hariyanto family. Source:

to purchase any FFB produced fromLandsat 7 and 8 imagery

164

final
countdown

the plantations of GMS and GHL; and40.	See RSPO website ‘Case tracker:(iii) have a call option over up

PT Hati Prima Agro’ andto 95% and 80% of the total issued

Minister of Forestry (2008).

shares in GMS and GHL (i.e. the41.	Orders 3(1) and 3(2) in

GY Call Option and the GMS Call

Minister of Forestry (2008)

Option), respectively.’ Source:

42.	Chain Reaction Research (2014)

a location permit over the area.
Source: Palangkaraya High Court,
Central Kalimantan (2015).
57.	RSPO website ‘Case tracker:
PT Hati Prima Agro’
58.	Email from RSPO to

Bumitama Agri Ltd (2014b) p1.

pp14–5. In court documents the30.	Bumitama Agri Ltd (2016c) p2

company stated it had planted

59.	Mach M (2017b)

31.	Minister of Agrarian Affairs andareas of PT HPA during 2010–201260.	Corporate registry profiles

Spatial Planning/Head of National(source: Palangkaraya High Court,

61.	Location permit no. 27/PEM/2016,

Land Agency (1999) Article 5(3).

Central Kalimantan (2015) p6).

See Annex 1 on legal permits.

43.	Kotawaringin Timur District

complainants, 22 June 2018

granted 8 January 201662.	In 2011, PT GYP was acquired by32.	Bumitama Agri Ltd (2014b)

Head Supian Hadi (2012a), andmembers of the Lim Hariyanto

33.	In Bumitama Agri Ltd (2016c) the

Kotawaringin Timur District

family. The sale included

Head Supian Hadi (2012b)

extensive plantation areas

company states that ‘the approvalof the Minister of Marine andFishery [is] now no longer being

44.	RSPO website ‘Case tracker:
PT Hati Prima Agro’previously developed with neither
forest release nor environmental

required’; however, there was45.	Krishnan R (2012)permit. Bumitama entered into an

no relevant legal revision.

46.	Supreme Court of Indonesia (2013)

explicit agreement from November

47.	Corporate registry profile.

2011 until August 2014 with other34.	Janta Winata Halim and Nita
Gartika: Mr Janta Winata Halim

Djoni Rusmin was Commissioner

Lim Hariyanto interests to manage

was co-director with Lim Gunawan

and 10% shareholder; Tommy

the plantations, which also gave

Hariyanto in Lim Hariyanto family

Santoso was Managing Director

it exclusive rights to purchasenickel mining company PT Trimegah

and 90% shareholder.

PT GYP’s palm fruit, although

Bangun Persada in 2013, while

48.	Bumitama Agri Ltd (2014a)

such trade would be illegal.

Ms Nita Gartika sat on its board

49.	Kotawaringin Timur Districtof commissioners beside Lim

Head Supian Hadi (2014a)(Bumitama Agri Ltd (2014b))63.	Bumitama Agri Ltd (2014b)

50.	Kotawaringin Timur District

64.	GPS coordinates:

also an employee of Lim Hariyanto

Head Supian Hadi (2014b). The- Marker stakes

family plywood company Tirta

letter serves to issue plantation(10 34’ 56.02”S 1100 20’ 6.33”E)

Mahakam Resources in 2009.

business permit (IUP) no. 009/

- Security post

IUP-B/PT.LMS/Kec. Antang(010 35’ 44.06”S 1100 19’ 55.26”E)

Kalang-1 Kec - Kab. Kotim/2014.

- Welcoming sign of PT LSM-BTJE

Gunardi Hariyanto. Gartika was

35.	Bumitama Agri Ltd (2016c).
Corporate registry profiles showthat during the nine-month period

51.	Bumitama Agri Ltd (2015a).

(010 35’ 11.91”S 1100 20’ 17.10”E)

30/9/14–10/6/2015, PT GHL was

The sale involved PT HPA’s

65.	Bumitama Agri Ltd (2016a) p3

owned by Selaras Hijau Sentosa‘plantation (biological66.	Bumitama Agri Ltd (2017a)(235 shares) and Tommy Santoso

assets) and other fixed assets

67.	See Bumitama Agri Ltd (2016a) p1(15 shares). Immediately priorover the Land, inventories

and p4, which states that ‘none

and subsequent to these dates, itand plasma receivablesof the directors or controlling(collectively, the “Assets”)’.

shareholders of the Company

was owned by PT Karya Manunggal
Sawitindo (PT KMS; 50 shares) andPT Sukses Manunggal Sawitindo (PT52.	RSPO website ‘Case tracker:
PT Hati Prima Agro’has any direct or indirectinterest in the Acquisition’.

SMS; 200 shares rising to 950 shares

53.	PT Karya Manunggal Sawitindo

As recently as 2018 Bumitama

on 10/6/2015). PT SMS was directly– also owned by the Lim

was declaring it had no priorcontrolled by the Lim Hariyanto

Hariyanto family – was theconnection to PT DAS; seefamily until February 2016, whenminority shareholder. Source:

BSL bought 95% of shareholdings,

Bumitama Agri Ltd (2016b).

with PT KMS holding the remainder.

54.	Bumitama Agri Ltd (2017c)

Bumitama Agri Ltd (2018b).
68.	Bumitama Agri Ltd (2016a) pp1–2

36.	Bumitama Agri Ltd (2016c) p2

55.	Bumitama Agri Ltd (2017b) p23

Central Cipta Murdaya

37.	This is the spelling used by the56.	As evidenced by Greenpeace field

1.	Corporate registry profile ofcompany and which appears on

investigations and by a criminal

plantation company Hardaya

its corporate registry profile;case instigated by ‘PT. HPA BGA

Plantations Group. See also

however, most government

Group’ in late 2014 claiming

http://www.hartatimurdaya.

correspondence uses thetheft of FFB from the company’s

com and Alexander H (2015).

conventional three-word company

plantation on 15 October 2014,

2.	Firdaus E (2013)name form, ie Hati Prima Agro.

a point in time after PT LMS had

3.	Analysis by Aidenvironment

38.	Corporate registry profile

begun applying for plantation(2017), held internally39.	Corporate registry profile

permits and was already holding

Now or never to reformthe palm oil industry

165

Citra Borneo Indah

3.	Aidenvironment (2017) p28

1.	PT Sawit Sumbermas Sarana

4.	Auriga et al (2018) pp2–3 citing

6.	First Resources (2007) p142

corporate registry profiles

7.	Corporate registry profiles

and mapping analysis based

8.	Corporate registry profile

on Hansen MC et al (2013)

9.	First Resources (2007) p155

(2018) pp2, 5, 35
2.	Environmental Investigation
Agency (2015)
3.	REDD-Monitor (2016); see also Forbes

5.	Auriga et al (2018) p2 citing BMJ

based on their dates of birth.

10.	CIFOR (nd)Performance Board website (www.

11.	First Resources (2015)

4.	Baskoro NB (2017)

bmjperformanceboard.com), Tribun

12.	First Resources (2017b,c)

5.	RSPO (2017) pp6–7, clauses 5.2 and 5.3

Kaltim (2015) and Pro Kaltim (2015)13.	First Resources (2017a) p4

website ‘Profile: Abdul Rasyid’

6.	PT Sawit Sumbermas Sarana (2017)6.	Ministry of Forestry (2010).

14.	In a statement of 12 July

7.	PT Sawit Sumbermas Sarana (2016b) p2

This map shows the concession

2018, in response to a report

8.	PT Sawit Sumbermas Sarana

as PT Global Sawit Kencana.

by Chain Reaction Research,

At some point the name wasFirst Resources claims:

9.	Palm Oil Magazine (2016)changed to PT Gemilang Sawita) 	PT Ciliandry Anky Abadi is not

10.	RSPO website ‘Case tracker: PT(2016a) pp64–5

Kencana; this name appears in,a subsidiary, an associatedSawit Sumbermas Sarana subsidiaryfor example, BCA’s 2014 annualcompany, or a related partyof PT Sawit Mandiri Lestari’report (see BCA (2015) p477).

11.	Through PT Metro Jaya Lestari and
PT Agro Jaya Gemilang. Source:

DTK Opportunity

corporate registry profiles.

1.	Incorporation forms of Hong Kong

12.	See Blog Souvenir123.com (2014)
and Citra Borneo Indah job

companies, available from https://www.icris.cr.gov.hk/csci/of First Resources.
b)	First Resources does not haveany financial or operational
relationship with PT
Ciliandry Anky Abadi.
c)	The controlling shareholders ofadvertisements, eg http://

2.	Analysis by Aidenvironment

First Resources, Mr. Ciliandra

jobmediaonline.blogspot.

(2017), held internally

Fangiono and his siblings, do

3.	Palangkaraya District Court,

not have any ownership, nor

Central Kalimantan (2013)

hold any management roles incom/2010/02/vacancy-vacancyat-cbi-group.html
13.	House of Representatives of
the Republic of Indonesia
website ‘Members of Parliament:
Period 2014–2019’14.	Gedung Palma One, Lantai 6, Jl.

4.	PT Musim Mas (2011)

PT Ciliandry Anky Abadi.

5.	Letter from Apical to PT Karya Dewid)	First Resources has not purchased

Putra (PT KDP), 27 January 2017any palm oil products from PT

Fangiono family

Ciliandry Anky Abadi, and will
not buy from any company that

H.R. Rasuna Said Kav. X-2, Nomor

1.	Indonesian sources usually refer4, Jakarta. Sources: PT Sawit

to Martias by a single name;compliance with First Resources’

Sumbermas Sarana (2016a) pp47,

sources from elsewhere often

sustainability policy.

57 and corporate registry profile
for PT Sawit Mandiri Lestari.

refer to ‘Martias Fangiono’.
2.	Source: First Resources annual

cannot prove that they are in

Source: First Resources (2018c).
15.	First Resources (2017b)

15.	PT Sawit Sumbermas Sarana (2018a)

reports since 2010, available

16.	First Resources (2007) p5

16.	foresthints.news (2018b)

at http://www.first-resources.

17.	https://www.facebook.com/

17.	See Wright S & Karmini N (2017).

com/annualreports.php.

18.	PT Sawit Sumbermas
Sarana (2018) p12
19.	foresthints.news (2018b)

3.	First Resources (2018a) p142
4.	First Resources (2018c)
5.	Corporate registry profile

pages/Ciliandra-PerkasaPT/965160946897952
18.	Note that here and elsewhere thecorporate registry profiles conflict.

20.	foresthints.news (2018b)

for PT Ciliandry Anky Abadi.

PT FPS’s own registry profile,

21.	PT Sawit Sumbermas Sarana (2017)

Beyond corporate registryobtained in January 2017, has its

22.	PT Sawit Sumbermas Sarana (2018b)

profiles, an in memoriam pageregistered address at the Surya

23.	PT Sawit Sumbermas Sarana (2018b)

for Martias’s father provides

Dumai building, Jl Jend. Sudirman

24.	PT Sawit Sumbermas Sarana (2018b)

some evidence of the extent of

No. 395 with no change in registered25.	foresthints.news (2018c)

the Fangiono family (see http://

address since its incorporation.

26.	RSPO website ‘New planting

meninggaldunia.blogspot.

Other corporate registry

procedures public notification:com/2011/02/bapak-hertanto.

PT Sawit Sumbermas Sarana Tbk

html). Details of Martias’s and19.	First Resources (2012) p1– PT Sawit Mandiri Lestari’

Silvia Caroline’s silver wedding

20.	First Resources website ‘Contact us’anniversary are found at http://

21.	PT Setia Agrindo Jaya, which in turnDjarum1.	Dolan K (2016). See also https://

2.

166

profiles place it at APL Tower.

www.lightworks.id/2015/02/

holds PT Citra Palma Kencana, PT

silver-wedding-a-moment-to-Indo Manis Lestari, PT Indogreen

www.forbes.com/profile/r-

remember. Assumptions about

Jaya Abadi, PT Setia Agrindo Lestaribudi-michael-hartono/.

the parentage of the younger

Aidenvironment (2017) p14

Fangiono family members are

and PT Setia Agrindo Mandiri
22.	First Resources (2018b)

final
countdown23.	Chain Reaction Research (2018a)

Plantations, PT Wahana Karya

24.	Sulaidy and his partner each own 50%

Sejahtera Mandiri and PT Wawasan

41.	Corporate registry profilesof PT PPAM, which held 51% of the JV.

Kebun Nusantara. The letter also42.	Greenpeace mapping analysis

acknowledges Gama shareholdingsof satellite imagery; see25.	As of 29 July 2018. See

corporate registry profiles.

Bloomberg website ‘Executive

in PT Gandaerah Hendana and PT

profile: Lau Cong Kiong’.

Inecda. Source: Indigo A (2018a).

43.	Interview with a community leader

11.	Greenpeace International (2018c)from Bupul village (name withheld

FELDA / FELDA Global Ventures

12.	Corporate registry profiles of PT

also Suara Pusaka (2018)

for security reasons), August 20171.	Tan CK (2017)

Gandaerah Hendana and PT Inecda

44.	Paino C (2017)

2.	FGV (2016b)

and their parent companies,45.	Government of Indonesia (2001)

3.	RSPO website ‘Board of governors’

and Samsung C&T Corporation

46.	Indigo A & Adriani (2018), copy held

4.	RSPO website ‘Principles

and Subsidiaries (2017) p23

by Greenpeace, and Indigo A (2018b)& Criteria review’

13.	RSPO website ‘S&G Biofuel Pte. Ltd’

5.	FGV (2017) pp4, 33

14.	Indigo A (2018a)

Genting

6.	FGV (2017) p11

15.	Indigo A & Adriani (2018),

1.	Genting Group website

7.

Jakarta Post (2014)

8.	FGV (2017) p34
9.	Rainforest Action
Network et al (2016)

copy held by Greenpeace
16.	Indigo A (2018b),
copy held by Greenpeace
17.	Krisno O (2017)‘Stock information’2.	Genting Group website ‘Directors &management’ and Genting Plantations
website ‘Directors & management’

10.	Al-Mahmood SZ (2015)18.	Corporate registry profiles

3.	Genting Group website ‘Home’

11.	FGV (2016a)

19.	Irawan Y (2015) and Arlinus Z (2015)

4.	RSPO website ‘Genting

12.	RSPO website ‘New planting

20.	foresthints.news (2018a)

procedures public notification:

21.	awasMIFEE (2018b)

FELDA – PT Temila Agro Abadi’

22.	foresthints.news (2018a)

13.	Aziz A (2017)23.	Wright S & Karmini N (2017)14.	Bursa Malaysia website ‘Company

24.	Tribun Pontianak (2018)

announcements [announcement

25.	Benny Djuarsa is described

Plantations Berhad’
5.	Genting Plantations
Berhad (2017) pp28–9
6.	RSPO website ‘Genting
Plantations Berhad’
7.	Genting Plantations

on this site as management

Berhad (2016) p2

15.	FGV (2016b)

of PT Wilmar Cahaya: http://

8.	Genting Plantations

16.	Khairil AA (2017)

pupukmahkota.co.id/news/

dated 26 May 2017]’

Gama

Berhad (2017) p32

temu-tani-brebes-092017.

9.	Genting Berhad (2018) p148

html. Johannes (his full name)10.	RSPO website ‘Case tracker:

1.	Wilmar International Ltd (2018b)

is described on this site as

2.	Greenpeace International (2018c)

management: http://britama.com/

3.	Compliance Advisor/index.php/2012/10/sejarah-dan-Genting Plantation Berhad (PTOmbudsman (2009) p17

profil-singkat-ceka/. Ownership

Susantri Permai, PT Kapuas Maju

4.	Wilmar International
Ltd (2018a) p24

information was found in
corporate registry profiles.

5.	Wilmar International Ltd (2018c)

26.	Redaksi (2009)6.	InfoSawit (2017); see also

27.	SK No. 42, tgl 22-02-2010

PT Susantri Permai’
11.	RSPO website ‘Case tracker:

Jaya and PT Dwie Warna Karya)’
12.	PT Permata Sawit Mandiri (2014)13.	PT Permata Sawit Mandiri(2014) pp2, 7–8

28.	Corporate registry profiles

14.	Greenomics Indonesia (2014) p5

7.	Daubach T (2018)29.	Corporate registry profiles

15.	Wilmar International

8.	Greenpeace International (2018c)

30.	Corporate registry profiles

9.	Greenpeace International (2018c)

31.	Greenpeace mapping analysis based

10.	PT Agro Alam Nusantara, PT Alamon official MoEF landcover data

17.	Genting Plantations Berhad (2018)shows an area of 3,190ha was cleared

18.	Corporate registry profiles

Singapore Exchange (2015)

Jaya Persada, PT Berkat Sawit

Ltd (2018d) p24
16.	Greenomics Indonesia (2015)19.	See also Kementerian Lingkungan

Utama, PT Bumi Alam Sentosa,

32.	Asrida E (2018)

PT Citra Mahkota, PT Citra Riau

33.	Greenpeace mapping analysis;

Hidup dan Kehutanan (2017b).

Sarana, PT Ganda Sawit Utama, PT

see also Suara Pusaka (2018)20.	Corporate registry profiles

Graha Agro Nusantara, PT Intitama

34.	Suara Pusaka (2018)

Berlian Perkebunan, PT Jatimjaya35.	Basik-Basik M (2016)

Perkasa, PT Karya Agung Megah

36.	Ngelia Y (2016)

Utama, PT Nusa Jaya Perkasa, PT

37.	Koalisi Organisasi

Patiware, PT Perkebunan Anak

Masyarakat Sipil (2016)

Negeri Pasaman, PT Putralirik

38.	awasMIFEE (2017b)

Domas, PT Sentosa Asih Makmur,

39.	Indigo A & Adriani (2018), copy held

PT Sumatera Unggul Makmur, PT

by Greenpeace, and Indigo A (2018b)

Swadaya Indopalma, PT TH Indo40.	Benny Djuarsa and Johannes. Source:

Now or never to reformthe palm oil industry

21.	IUCN/SSC Conservation BreedingSpecialist Group (2017)

Hayel Saeed Anam
1.	HSA Group website ‘Group leadership’
2.	PIL website ‘Message
from management’
3.	HSA Group website ‘Group leadership’4.	HSA Group website ‘Malaysian167

companies’ and HSA Group website

April 2014 are Agus Frenando‘Director profile’
2.	SPOTT website ‘IJM Plantations Bhd’

Gurning and Andi Nurmanshah

3.	Norges Bank (2015)

Pramono, whilst PT Anugerahlink between Commodities House

4.	IJM Plantations (2017) p25

Sakti Internusa is owned by

Investment and PIL was documented in

5.	IJM Plantations (2017) p26

Togap Gurning and Herry Sen.

‘Indonesian companies’
5.	Corporate registry profiles. The

2005 as part of the US Congressional
Investigation mentioned

Indonusa

IOI

elsewhere. See United States

1.	Notes on group structure: of the

1.	Strictly speaking IOI Corporation

concessions described in thisBerhad is one of two arms of the

6.	RSPO (2017) pp6–7, clauses 5.2 and 5.3

profile, Rosna Tjuatja owns 99.875%

group, which also encompasses

7.	PIL website ‘About’of the shares of PT Internusa

the separate IOI Properties

8.	PIL website ‘Sustainability’

Jaya Sejahtera directly. PT

Group Berhad. Source: IOI Group

9.	Corporate registry profiles and Chain

Indonusa Agromulia is 90% owned

Reaction Research (2017a) pp10–1

by another Indonesian company,

House of Representatives (2005).

website ‘Group structure’.
2.	Held through Oakridge Investments

10.	Greenpeace International (2018b)

PT Radiant Internusa Utama,

Pte Ltd and Lynwood Capital

11.	HSA Group website ‘Commodities’.

which in turn is 90% owned by the

Resources Pte Ltd, both wholly

The page has since been deleted,

Singapore-registered company

owned subsidiaries of IOI

but an archive is available

Paramount Royale Pte Ltd, whose

Corporation Berhad. Source:

at https://web.archive.org/

owner is not known. Rosna Tjuatja

Bumitama Agri Ltd (2018a) p142.

web/20171218223219/http://www.

owns the remaining 10% of both

hsagroup.com/business-activities/

PT Internusa Agromulia and PT

core-business/commodities.aspx.

Radiant Internusa Utama. Source:

12.	HSA Group website‘Environmental statement’corporate registry profiles.
2.	Profindo website ‘Board

13.	Hagen C (2018)of commissioner’ and14.	PIL (2018)

Britama.com (2015)15.	Mohamed Hamid Abdullah Al-Sarari
has been a director of PT Pacific
Palmindo Industri, PT PacificIndopalm Industries, PT Pacific Medan
Industri and PT Pacific Indomas since

3.	Beritasatu.com (2012)
4.	Concessions are listed on thegroup website, http://www.
indonusaagromulia.com/index.php.
5.	PT Internusa Jaya Sejahtera,

3.	IOI Group website ‘Dato’
Lee Yeow Chor’
4.	RSPO website ‘IOI
Corporation Berhad’
5.	IOI Group (2017b)
6.	See IOI Group (2017a) pp228–9 andBumitama Agri Ltd (2018a) p105.
7.	IOI Group website‘Estates and mills’
8.	See Greenpeace International(2017a) pp28–9 and RSPO (2013a).
9.	Bunge (2018)

November or December 2016, and was

PT Anugerah Sakti Internusa

10.	IOI Group website ‘Refinery’

the President Director of PT ESK.

and PT Persada Utama Agromulia

11.	Colchester M, Jalong T &Nakul Rastogi, another director

were given in-principle State

Chuo WM (2013) pp240–1

of PT GKM and PT KCP, is a long-term

Forest Release Letters bydirector at PIL. Rami Mohammed Abdo

former Forestry Minister

Saeed, who was a commissioner of PT

Zulkifli Hasan on 13 August 2014,

GKM and PT KCP, was also a director

two weeks before his term inof PIL from 22 May 2014 until 12

office ended. PT Persada Utama

January 2018. He was also a director

Agromulia has now been granted

Chuo WM (2013) pp241–2

of PIL’s Indonesian processing anda definitive State Forest Release15.	Colchester M, Jalong T &trading companies from October
2012 to November or December 2016.

Letter by his successor.
6.	Insider Stories (2012). The

16.	Corporate registry profiles

corporate registry profile shows

17.	Corporate registry profiles

that the board changed at the18.	METCO website ‘Sistertime of this news, with Rosna

12.	Colchester M, Jalong T &Chuo WM (2013) pp237, 239
13.	Colchester M, Jalong T &Chuo WM (2013) pp239–40
14.	Colchester M, Jalong T &Chuo WM (2013) pp240, 244
16.	Colchester M, Jalong T &Chuo WM (2013) pp243–4
17.	RSPO website ‘Case tracker:
IOI – IOI Pelita Sdn Bhd’
18.	See Colchester M, Jalong

companies -> Pacific Inter-Link

Tjuatja and other company leaders

representative office V’

Risna Tjuatja, Djawi Santoso andT & Chuo WM (2013) p246 and19.	PT Pacific Palmindo Industri.

Ardian appointed as directors

RSPO website ‘Case tracker:

See RSPO (2013b) p3.

and commissioners; however, theIOI – IOI Pelita Sdn Bhd’.

20.	Corporate registry profiles

two shareholders Ripin and Sumadi

The suspension of new21.	Tadmax Resources Bhd (2012)

continued to hold the same stake.

certifications by IOI was

22.	See corporate registry
profiles and Chain Reaction
Research (2017a) pp10–1.

IJM Corporation
1.	IJM Plantations website

168

7.	Hadinaryanto SE (2014) andBeritabatavia.com (2012)
8.	Indonusa Group website ‘Lowongan’
9.	According to corporate registry

lifted in February 2013, withthe exception of IOI-Pelita.
19.	RSPO website ‘Status of
current disputes’

profiles, the shareholders of PT

20.	RSPO website ‘Case tracker:

Persada Utama Agromulia since

IOI – IOI Pelita Sdn Bhd’

final
countdown21.	RSPO website ‘Status of
current disputes’
22.	IOI Group (2017c); see also

2.	Noble Group (2018)
inside front cover
3.	Noble Group (2018) p159

organised by Yayasan Pusaka andother organisations in Waena,
Jayapura, 4–7 November 2014.

Rainforest Action Network &4.	Noble Group (2018) pp25, 17

19.	Radar Sorong (2015)

Forest Peoples Programme (2017)5.	Noble Group (2018) p159

20.	Noble Group (2012)

6.	RSPO website ‘Noble

21.	Noble Plantations Pte Ltd (2017) p2

23. IOI Group (2018a)
24.	IOI Group (2018b); see also Bunge
Loders Croklaan (2018b) pp10–3

KorindoPlantations Pte Ltd’
7.	For example, the policy refers to22.	The concept of an Intact Forest
Landscape (IFL), as mapped by

the government’s national peat

WRI, Greenpeace and Transparent

map as proof that there is noWorld in 2000 and 2013, refers

1.	Korindo website ‘Grouppeatland in PT PAL, rather thanto ‘an unbroken expanse ofprofile: At a glance’

any actual peat survey. The HCS

natural ecosystems within the

2.	Aidenvironment (2016) p13

commitment is only a commitment tozone of current forest extent,

3.	Aidenvironment (2016) p15‘applying HCSA as defined by HCSA

showing no signs of significant

4.	Musim Mas (2016)

toolkit’ and mentions discredited

human activity, and large enough

5.	Mighty Earth (2017a) p10

HCS surveys conducted by Nyoto

that all native biodiversity,

6.	Mighty Earth (2017a) p11

Santoso in 2013 and 2014 – before

including viable populations

7.	HCV Resource Network website

significant deforestation in theof wide-ranging species, could‘Ongoing and historicalconcession. No new assessments

be maintained’. See http://www.

evaluations of assessment reports’

are registered on the HCSA website

intactforests.org/index.html.

8.	Mongabay Indonesia (2017)(http://highcarbonstock.org/

9.	awasMIFEE (2017c)

registered-hcs-assessments/). See

published in Wetlands

10.	Mapping analysis from Kepo

Noble Plantations Pte Ltd (2017).

International (2006). In January

23.	Based on peat survey data

8.	Noble Plantations Pte Ltd (2016) p2

2017 Noble Group stated that11.	Aidenvironment (2016) p15

9.	Yun M & Humber Y (2014)no new development on peat

12.	Mighty Earth (2016)10.	Noble Group (2016b)

would take place (source:

13.	Mighty Earth (2017a) pp10–1

11.	Noble Group (2015a) p118 andemail to Greenpeace from Bell

Hutan and Global Forest Watch

14.	Korindo (2016), copy
held by Greenpeace

Lembaga Tabung Haji

Noble Group (2018) pp121, 139
12.	Noble Group (2015a) p118
13.	Noble Group (2016a) p188,

Pottinger, 11 January 2017).
24.	RSPO website ‘Case tracker:
PT Pusaka Agro Lestari’

Noble Group (2017) p149 and25.	Tabloid Jubi (2014)

1.	Tabung Haji website ‘About us’

Noble Group (2018) p139

26.	Suara Papua (2014)

2.	Tabung Haji website ‘Plantation’

14.	In 2013 the Council on Ethics

27.	Antara Papua (2014)

3.	TH Plantations Bhd (2018) p104

that advises the Norwegian28.	Noble Group (2015b)

4.	Information from East Kalimantan

Government Pension Fund Global

29.	Tabloid Jubi (2015)(GPFG) recommended against

30.	Salam Papua (2016)

Plantation Agency (2012)
5.	Chain Reaction Research (2017b)

any future investment in Noble

6.	RSPO website ‘PT. Synergy

Group, on the grounds that

NPC Resources

HCV assessments for the two

1.	NPC Resources (2017) pp37–8

concessions were inadequate

2.	NPC Resources website

Oil Nusantara’
7.	FGV (2018)

Noble
1.	As inferred from Noble Groupto ensure the conservation ofimportant habitats (source:
Council on Ethics for the‘Company overview’
3.	Analysis by Aidenvironment(2017), held internally(2017) pp17, 149 and Noble Group

Government Pension Fund Global(2018) p153. Noble Group’s palm

(2015a) pp137–8); in June 2015

oil business is acknowledged

Norwegian life insurance and

POSCO (POSCO
Daewoo Corporation)in its annual reports among

pensions company KLP also

1.	POSCO Daewoo website ‘Trade’subsidiaries classified as held

announced its intention to

2.	RSPO website ‘PT. Bio Inti Agrindo’for sale (see most recently

exclude Noble as a result of this

3.	Kementerian Lingkungan Hidup

Noble Group (2018) p139). Noble

decision (source: KLP (2015)).

dan Kehutanan (2017a)

Plantations Pte Ltd is the15.	Channel News Asia (2010)

4.	Aidenvironment (2016) pp35–7

company listed on the RSPO

16.	Noble Plantations Pte Ltd (2017) p2

5.	awasMIFEE (2015)

website as responsible for17.	Environmental Investigation

the business (see RSPO website

Agency & Telepak (2012)

Rimbunan Hijau‘Noble Plantations Pte Ltd’),18.	Testimony of Bernadus Gilik

1.	Teng LJ (2017)

but it is not acknowledged as

at ‘Profil Kasus, Temu Rakyat

2.	Jaya Tiasa (2017) pp6–7

a subsidiary of Noble Group

Korban Investasi Kehutanan

3.	Rimbunan Sawit Bhd (2017) p8

in the annual reports.

dan Perkebunan Besar’, an event

4.	Subur Tiasa (2017) p12

Now or never to reformthe palm oil industry

169

5.	Mafrica Corporation website
https://www.mafrica.com.my

Tbk (2016a) p111
13.	Fakultas Pertanian Universitas

3.	See Redaksi (2016),
foresthints.news (2016a) and6.	Analysis by Aidenvironment

Lampung (2017). Note other online

foresthints.news (2016b).

(2017), held internallyjob sites give the office address as

4.	Kementerian Lingkungan Hidup

7.	Rimbunan Hijau website ‘Home’elsewhere within the same complex,

dan Kehutanan (2017a)

8.	Greenpeace analysis ofeg Blok A no 34 and Blok C no 56–57

5.	PT Tunas Baru Lampung Tbk

trader dashboards
9.	Global Witness (2017)10.	Global Forest Watch website‘Sarawak oil palm concessions’Salim– see, for example, http://www.
loker.id/profile/indo-gunta-group.
14.	Duta Merlin Blok B no 22–23. Source:
Corporate registry profile.
15.	PT Salim Ivomas Pratama Tbk (2016a)

website ‘Plantation profile’
6.	PT Tunas Baru Lampung Tbk
website ‘Plantation profile’Tee family

p111, PT Salim Ivomas Pratama

1.	Corporate registry profiles

1.	First Pacific Company Ltd (2018) p116

Tbk (2015) p127 and PT Salim

2.	Far East Holdings Bhd (2017) p112

2.	First Pacific Company Ltd (2018) p252

Ivomas Pratama Tbk (2014) p125

3.	Corporate registry profile

3.	See IndoAgri (2017) and GreenpeaceInternational (2017b).
4.	PT Salim Ivomas Pratama

16.	Corporate registry profiles
17.	In violation of government
regulation 57/2016.

4.	Far East Holdings Bhd(2018) pp16, 17, 19
5.	Far East Holdings Bhd (2018) pp7, 29

18.	PT Ekolindo Palm Nusantara,

6.	Endau Palm Oil Mill Sdn Bhd, Future

5.	IndoAgri (2018) p14 and PT Salim

PT Ekolindo Palm Lestari,

Prelude Sdn Bhd, Kilang Kosfarm

Ivomas Pratama Tbk (2018) p39

PT Putra Palma Cemerlang

Sdn Bhd, Kilang Sawira Makmur Sdn

and PT Remboken Sawit.

Bhd, Prosper Palm Oil Mill Sdn

Tbk (2016b) p2

6.	Corporate registry profiles. PT
DRM is owned by several companies

19.	awasMIFEE (2018b)

Bhd, Rompin Palm Oil Mill Sdn Bhd

including PT Adi Mulya and PT Mulia

20.	PT Bintuni Agro Prima Perkasa,

and Wujud Wawasan Sdn Bhd. Source:

Abadi Lestari; a 50% stake is held

Kerangka Acuan Analisis

by PT Citra Kencana Kasita. Two

Dampak Lingkungancompanies hold a 50% stake each in21.	SK Bupati Tambrauw 521/297/2015

PT Citra Kencana Kasita: PT Zamrud

22.	See Minister of Forestry

7.	Far East Holdings Bhd (2018) pp17, 19
8.	See eg Bunge Loders
Croklaan (2018a).

Indahpersada and PT Wahanamulia

Regulations 33/2010 and 28/2014.

9.	Corporate registry profile

Wiranusa. Anthoni Salim holds a23.	The relevant legislation for Food

10.	Corporate registry profile

99% stake in both companies.
7.	First Pacific Company
Ltd (2018) pp86–7
8.	PT Agro Mulia Lestari, PT

Crops Business Licences is Minister11.	Numapo J (2013) pp125–30

of Agriculture Regulation 39/2010.

12.	Patjole C (2018)24.	awasMIFEE (2018a)

13.	The National (2018)25.	The HGU area does not yet include

14.	Far East Holdings Bhd (2018) p19

Anekareksa Internasional, PT

the whole 19,368ha concession area.

Berau Sawit Sejahtera, PT Bintuni

It is shown on the National Land

Agro Prima Perkasa, PT Citra Palma

Agency Map: http://peta.bpn.go.id/.

15.	Ministry of Foreign Affairs,
Malaysia (2010a)
16.	Ministry of Foreign Affairs,

Sejati, PT Duta Rendra Mulya, PT

26.	awasMIFEE (2018a)

Duta Sejahtera Utama, PT Ekolindo

27.	Asian Human Rights

17.	RSPO (2017) pp6–7,

Palm Lestari, PT Ekolindo Palm

Commission (2018)

clauses 5.2 and 5.3

Nusantara, PT Gunta Samba Jaya,

28.	awasMIFEE (2018a)18.	RSPO website ‘Future

Sawit Plantation, PT Permata

Samling19.	Global Witness (2017)

Nusa Mandiri, PT Putra Palma

1.	Samling Group website ‘Our

20.	Chain Reaction Research (2018b)

Cemerlang, PT Remboken Sawit,

milestones: Corporate’

PT Rimbun Sawit Papua, PT Sawit

2.	Bloomberg website ‘Executive

Berkat Sejahtera, PT Sawit Golden

profile: Yaw Chee Ming’

PT Menara Wasior, PT Perdana

Prima PT Sawit Khatulistiwa
Lestari, PT Sawitindo Plantation,,
PT Subur Karunia Raya, PT Tunas
Agung Sejahtera, PT Wahana

3.	Samling Group website ‘Oilpalm plantations’
4.	Analysis by Aidenvironment(2017), held internally

Malaysia (2010b)

Prelude Sdn Bhd’

21.	Orere B (2017)22.	Numapo J (2013) p141
23.	‘Not preserved’ in this context
appears to mean ‘not excluded
from development plans’. See
Numapo J (2013) p139.
24.	Numapo J (2013) p127

Murni Plantation, PT Wahana

5.	Wilmar International Ltd (2018d)

25.	Numapo J (2013) p128

Tritunggal Cemerlang and PT

6.	Nelson PN et al (2014)26.	Numapo J (2013) p141

Wira Inova Nusantara.

7.	Wilmar International Ltd (2018d)

27.	ActNow PNG (2017a)

9.	Corporate registry profiles
10.	Greenpeace International(2017a) p49

Sungai Budi

28.	ActNow PNG (2017b)
29.	InfoSawit (2017b)

1.	PT Tunas Baru Lampung Tbk

11.	PT Gunta Samba (2015)

website ‘Plantation profile’12.	PT Salim Ivomas Pratama

2.	PT Tunas Baru Lampung Tbk (2016) p2

170

Far East Holdings Bhd (2018) p7.

final
countdown

Endnotes
ANNEXes

1.	Minister of Agrarian Affairs andfor landholders (such as local

found (‘yang penutupan lahannya

Spatial Planning/Head of National

communities) who use state land.

didominasi lahan tidak berhutan

Land Agency (1999) Article 4(1)Source: President of the Republicantara lain semak belukar, lahan

of Indonesia (1996) Article 4.

kosong, dan kebun campur’).

7.	This is for location permits of overThis represents an intention

companies or corporate groups.

50ha. For smaller areas, shorterto preserve remaining forest

This limit was retained when the

periods of one year (<25ha) or twoareas, and was not present in thelocation permit regulations wereyears (25–50ha) apply. See Minister2010 regulation it supersedes

updated in Minister of Agrarianof Agrarian Affairs and Spatial(No. P.33/MENHUT-II/2010).

Affairs and Spatial Planning/Head

Planning/Head of National Land14.	Plantation Law 2004 Article 25

of National Land Agency (2015).

Agency (1999) Article 5(1); retained

15.	Plantation Law 2014 Article 67(c) prescribes a plantation limitof 20,000ha per province forin Minister of Agrarian Affairs and16.	Environment Law 2009 Article 109

Affairs and Spatial Planning/

Spatial Planning/Head of National

17.	The requirement is found in

Head of National Land Agency

Land Agency (2015) Article 5(1).

2.	See Minister of Agrarian(2015) Article 4 and Minister ofAgriculture (2013), which updates
Minister of Agriculture (2007).
3.	The process is set out in two

8.	Minister of Agrarian Affairs andPlantation Law 2014 Article
68, and Article 109 states that

Spatial Planning/Head of National

failure to comply is a criminal

Land Agency (1999) Article 5(3)offence carrying a penalty of up

9.	Minister of Agrarian Affairs andto three years’ imprisonment for

regulations: Minister of Agrarian

Spatial Planning/Head of National

Affairs and Spatial Planning/

Land Agency (1993) Article 3(5)(approximately US$222,000) fine.

Head of National Land Agency

10.	Minister of Agrarian Affairs and18.	Plantation Law 2014 Article 98(2).

company staff or an IDR 3 billion(1993) and Minister of Agrarian

Spatial Planning/Head of National

Article 70 of the Environment

Affairs and Spatial Planning/HeadLand Agency (2015) Article 5(7)Law 2009 similarly empowers theof National Land Agency (1999).
4.	President of the Republic ofIndonesia (2010) Articles 160,

11.	Minister of Environment
and Forestry (2016)12.	Forestry Law 1999 Article 50.

community to be actively involvedin environmental monitoring.
19.	Plantation Law 2014 Article 99(3).

163 and 165 require Izin Prinsip

The Prevention and Eradication

Article 100 also states thatand Izin Lokasi to be allocatedof Forest Destruction Law 2013

plantations must be developed inbased on district spatial plans.

Article 82(3) provides additionala participatory manner, including

penalties for corporations of

the public in planning and

up to IDR 15 billion (US$1m) and/monitoring and enabling them to

5.	As emphasised in the explanatory
text accompanying Section 5 of
Minister of Agrarian Affairs

or 15 years’ imprisonment.

and Spatial Planning/Head of

13.	Under the latest (Minister ofmake suggestions and complaints.
20.	Environment Law 2009 Article

National Land Agency (1999).

Environment and Forestry (2016))

65(2), with scope and examples

6.	This process is often abbreviatedregulations, only ‘unproductive’of documents provided in the

GRTT (ganti rugi tanah dan tanam

production forest may be released,

official explanatory notetumbuh; compensation for land andmeaning unforested land dominated21.	Plantation Law 2014 Article 105

plantings). It requires paymentby shrublands, empty land or mixed

22.	Plantation Law 2014 Article 45(1)(b)for land acquired from private

gardens, except in provinces

23.	Plantation Law 2014 Article

titled landowners and compensation

where no such unproductive land is

Now or never to reformthe palm oil industry

45(1)(a). Environment Law 2009171

Article 111 also makes it a

it must have secured both land(nd); see General Mills website

criminal offence for a government

rights AND a plantation business‘Statement on responsible

official to issue the plantation

permit. The original wording ofbusiness permit in the absence

that article in the Plantation

56.	The Hershey Company (2017)of an environmental permit. ThisLaw 2014 was land rights AND/OR

57.	Johnson & Johnson (nd)legal requirement has been in placea plantation business permit.

58.	Kellogg Company (2018)

since at least 2002, via Minister ofAgriculture (2002) Article 10(k).

35.	Minister of Agriculture(2015) p41, criterion 1.4, and24.	Plantation Law 2014 Article 17

SawitIndonesia.com (2015)25.	Plantation Law 2014 Article 10336.	Minister of Environment and26.	Minister of Agriculture(2013) Article 15; see also
Plantation Law 2014 Article 58

Forestry (2016) Article 2237.	Minister of Environment
and Forestry (2015)

palm oil sourcing’59.	L’Oréal (nd)60.	Mars (2018)61.	Mondelēz International (2018)62.	Nestlé (2018)63.	PepsiCo (2018)64.	P&G website ‘P&G’s direct
palm suppliers – 2017’27.	Basic Agrarian Law 1960 Article 2(1)38.	AAK (2018)65.	PZ Cussons (nd)28.	Minister of Agrarian Affairs and39.	Apical website ‘Supply chain map’

66.	Reckitt Benckiser (nd)Spatial Planning/Head of National40.	Cargill (2018)67.	Unilever (nd)Land Agency (1993) Article 7(1)41.	Bunge Loders Croklaan

68.	Kraft Heinz (2018)29.	For plantation areas of less69.	In a few cases, a concession

than 200ha, the land cultivation

42.	GAR website ‘Supply chain map’or a mill is currently definedright certificate is issued by the43.	Musim Mas website ‘Supply chain map’as ‘linked’ to a particularprovincial office of the BPN.

44.	Olam (2018)

producer group rather than as

45.	Sime Darby website ‘Open palm

an outright group member. Somethe same company if the land istraceability dashboard’. Moreconcessions or mills are defined

still being put to the same use.

recent lists have been madeas ‘potentially’ belonging

available since our analysis.

to a group – for example where30.	An expired HGU can be reissued to31.	Minister of Agriculture(2007) Article 34(a)32.	Additionally, land cultivation

46.	Wilmar International website‘Supply chain map’

unofficial evidence such as
LinkedIn profiles or social media

right may not be issued over47.	IOI Group website ‘List of mills’

indicates ownership but there is

any State Forest area before

48.	Fuji Oil Holdings (2018)no other evidence to establishthat status is changed. See

49.	Louis Dreyfus Co (2018)

it, or in some cases where a millPresident of the Republic of50.	Mewah (2018)name is generic, shared with one

Indonesia (1996) Article 4(2).

51.	See Greenpeaceor more other mills, or otherwise

33.	Minister of Forestry(2003) Article 15(1)(c)34.	The Constitutional Court (2015)172

website ‘List of mills’

International (2018a).

not unique to a producer group52.	Colgate-Palmolive (2018)

and where GPS coordinates

53.	The mill list was published(which would potentiallyruled (see p294 point 1.8) that thein July 2018 as an annex tocorrect and valid formulation ofDanone’s 2015 NDPE commitment;

Article 42 of the Plantation Law

see Danone (2015) pp11–13.

2014 is that for a company to legally54.	Ferrero (2017)

carry out plantation operations

55.	General Mills (2018) and AAK

locate the mill in a known
concession) are not disclosed.
70.	Chain Reaction Research (2017c)
71.	Chain Reaction Research(2018c) pp8–9

final
countdown

Ornate Fruitdove(Ptilinopus ornatus)in the Arfak Mountains,
Kwau, West Papua.
Bernard Van Elegem©

Now or never to reformthe palm oil industry

173

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1 April 2018,
PT Inocin Abadi (Korindo), Papua,
6°52’0.018”S 140°42’20.861”E©Ifansasti/Greenpeace23 October 2011, Pomio, Papua New Guinea
Hilton/Greenpeace©

Front cover:
11 December 2016, PT Damai Agro Sejahtera (Bumitama),
Kalimantan, 1°30’28”S 110°16’27”E
Ifansasti/Greenpeace©

September 2018
Published by Greenpeace International
Ottho Heldringstraat 51066 AZ Amsterdam
The Netherlands
www.greenpeace.org/finalcountdown

188

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