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APP Responds to Greenpeace International’s 10-year Progress Report

On 15th October, Greenpeace International (Greenpeace) emailed Asia Pulp & Paper (APP) to seek comment on an upcoming report about its environmental commitments. APP was given two working days to respond to the draft originally shared by Greenpeace.

APP endeavoured to respond as comprehensively as possible given the relatively short deadline. However, the comments offered by APP were only marked as footnotes instead of being incorporated into the main report for full context. For brevity, APP pointed to statements made in the past addressing these same issues Greenpeace is now again raising.

APP understands that Greenpeace’s publication alleges that APP has wilfully contravened its own Forest Conservation Policy (FCP) and has engaged in deforestation, peatland destruction and ignored human rights. This is completely and demonstrably not the case.

Greenpeace’s publication points to alleged violations of APP’s FCP commitments in several areas but did not address APP’s fourth commitment – that of securing its supply chain and ensuring that it is deforestation-free.

The reasonable questions to ask would then be “why”? Why would APP engage in deforestation when it is one of the most scrutinized forestry businesses in Indonesia? Why would APP jeopardize its reformation process and reassociation with global standards organizations? What benefit would APP gain by setting fires within its own pulpwood concessions? If APP engaged in these criminal actions for profit, then why is APP’s supply chain still verifiably free from deforestation?

Alleged Association with Deforestation
All APP suppliers have ceased natural forest conversion since 2013. The forest management units alleged to be engaged in deforestation, from footnotes 35 through 37 in Greenpeace’s report, were all proven not to be APP suppliers at all. This point has been responded to numerous times in the past, but the same mistaken allegations continue to emerge with every new publication.

Alleged Intention to Deforest in the Future
Even more curious is the allegation that APP is deliberately weakening its FCP commitments so that it may engage in some future deforestation. 

The “evidence” presented is APP’s alignment with the Tropical Forest Alliance, and subsequently the Forest Stewardship Council, in bringing forward the cut-off date to 2020. When APP updated its SERA process in 2022, it was not done “quietly” as alleged in the summary section of Greenpeace’s report. The update came after consultation with stakeholders at our annual Stakeholder Advisory Forum, which Greenpeace and other stakeholders have always been invited to. Greenpeace did not attend. 

It is impossible for any of APP’s suppliers to commit deforestation as a result of this change as all our suppliers to date have ceased deforestation since 2013. It is unclear how APP’s FCP commitments would be “weakened” as alleged.

The change does allow APP, at some point in the future, to accept new suppliers who have converted post-2013 and before 2020. This, too, is not a weakening of APP’s commitment. In fact, by providing economic incentives for past offenders to commit to a  new, sustainable and responsible forestry approach, it strengthens forest protection overall and prevents these FMUs from backsliding into old habits.

Despite the change, APP has yet to accept any new supplier that has converted post 2013 into its supply chain. The most updated list of approved suppliers is available at

This more constructive line of thinking is surely something Grant Rosoman, a senior campaign advisor to Greenpeace International, also considered. 

Greenpeace New Zealand’s Grant Rosoman told Climate Home: “There’s a lot of environmental and social benefits that come from (the passing of FSC’s Motion 37) and they outweigh the risks of it being abused or not being interpreted properly”.

- Climate Home interview with Greenpeace New Zealand’s Grant Rosoman 


APP recognizes that these may be Mr. Rosoman’s personal views and not those of Greenpeace, which has itself disassociated from FSC, but APP is in full agreement with his statements and believes Greenpeace’s view is misguided.

Allegations of Peatland Destruction and Forest Cover Loss
The allegations of peatland destruction, like deforestation, is also verifiably untrue. This allegation is mostly the result of conflicting maps, definitions, and timelines.

As an Indonesian forestry concern, APP’s maps and definitions are based on the official ones as represented by the laws and regulations of the Republic of Indonesia. APP’s production and conservation workplans are submitted annually to the Ministry of Environment and Forestry for review, in accordance with all appropriate laws and regulations. No new areas of protected peatland have been cleared since 2013. Based on the maps available on Nusantara Atlas’s website, APP can confirm the accessibility of the maps on that site are not the updated maps based on the updated regulation on peatland management.

Greenpeace’s publication also takes issue with the scale and progress of peatland retirement and restoration. In eight years since 2013, we have retired 26,883 ha of peatland, commenced restoration work on 81,245 ha, and have earmarked an additional 7,300 ha for retirement (voluntary in SPA, TPJ) in the future.

It is important to note that forests do not just materialize once restoration work starts. Individual trees can take years to mature. Our restoration work combines the deliberate planting of rare endemic species, to guide biodiversity, and natural regeneration. Natural regeneration begins very quickly, and visible signs of new growth can be seen in just a few years. Full restoration can take upwards of 60 years, but partial regeneration can be achieved in just 20 years depending on the ecosystem. APP has been working with various partners including NERI to continue the restoration research. As for the claim that we have not heeded the advice of peat experts that gave us advice, APP has been working with Deltares since in 2015 and continues to do so with the same experts who are now with D4S as well as its local peat expert partner, PT Alas Rawa Khatulistiwa.

We are unclear which other ‘experts’ have offered advice to APP and were not taken into consideration.

It will take a lot more time to reach the level of restoration that meets the standard of restoration, but we remain committed to the process and continue to invest in the planning, protection, and monitoring of our restoration projects.

On forest cover loss, APP maintains a publicly available resource on our dashboard to track forest cover. While APP works to monitor and protect our conservation areas, that does not mean that these areas will not experience any forest cover loss. This can be a result of natural events – such as landslides, fires, droughts, flooding or disease – or indications of human interference – illegal logging, illegal mining, community land clearance.

In the event of the former, work commences on rehabilitation and restoration, which may require the removal of diseased trees to prevent the spread.

In the event of illegal land clearance, these cases are reported to the proper authorities to take appropriate action.

Allegations of Social Conflicts 
APP is very keenly aware that there are a number of conflicts with local communities across its supplier concession areas. These conflicts are all catalogued, and a process of resolution is implemented to address the root causes. However, these cases are often very complex, with a combination of different actors and stakeholders who must be consulted and brought into the process. 

Comparing apples to apples, APP’s resolution rate for such conflicts are well ahead of the curve. If progress seems slow for the remaining cases, it is a testament to complexities of such incidents. Often, these cases involve illegal occupation of the area or conflicting rights, which makes it unclear who should be at the negotiation table.

Such incidents also attract self-interested parties, such as illegal logging or other vested companies, who profit from muddying waters and prolonging conflicts. This is one of the reasons why APP does not maintain a publicly available dashboard that identifies areas and communities that are still in the process of mediation and resolution.

The cases that are listed are often already in the implementation stage of resolution, and even then, only if the stakeholders involved consent to making such information public.

APP also strenuously object to the characterization in Greenpeace’s publication that asserts APP “used drones to destroy” local communities and their crops, which conjures images of warfare and destruction. This was a single herbicide drone mistakenly veering off course. The affected crops were 15 one-month-old oil palm trees, and restitution was made to the affected community. This was not reflected in Greenpeace’s narrative.

The allegation of the “persecution” of indigenous Sakai communities is also blown well out of proportion. 

APP remains fully committed to its Social commitments under the FCP, including Free, Prior and Informed Consent. Social conflicts, which often coincide with other issues like deforestation, land fires or poaching, are often a symptom of a deeper root cause – rural poverty. APP’s resolution outcomes often include enrolment into our Desa Makmur Peduli Api community development program to help address these root causes and prevent future conflicts.

Given the facts as presented above, APP believes that Greenpeace’s report reflects a very narrow, selective set of datapoints that skews opinions of APP’s sustainability transformation. 

APP recognizes that this is Greenpeace’s imperative – to “expose” irresponsible businesses and create pressure for reform. However, APP believes it is unfair to only highlight transgressions long past and ignore all evidence to the contrary or inform their audience of resolutions since.
APP, with Greenpeace’s input, developed a series of commitments and a progressive roadmap to improve its sustainability performance. APP has taken responsibility for its past failures and has developed robust systems to prevent future failures. APP has acted in accordance with its commitments for a decade.

APP has no intention of going back on these commitments and trust that APP’s actions have proven this and will continue to prove this.

We thank Greenpeace for the opportunity to comment.

For further clarifications or enquiries, please contact  or (+6012 392 5343)

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