How global finance and household brands are
fuelling deforestation, violence and human
rights abuses in Papua New Guinea

October 2021
Page 1 screenshot
KEY FINDINGS ........................................................................................................................... 4
INTRODUCTION: AN INDUSTRY UNCHECKED ......................................................................... 6
A growing threat ................................................................................................................. 6
New kids on the block ......................................................................................................... 7
Tobar’s Laughing Villain ...................................................................................................... 7
Political connections................................................................................................... 9
EAST NEW BRITAIN RESOURCES GROUP ..................................................................................... 10
‘Unofficial fees’ .......................................................................................................................... 10
Child labour ...................................................................................................................... 12
Women threatened at gunpoint .................................................................................. 12

Admissions of tax evasion ........................................................................................................ 13
Watch the tax gap ................................................................................................................................ 13
Tracking the tankers.......................................................................................................... 14
No paper trail ................................................................................................................... 14
‘Impossible’ to sell ............................................................................................................ 14
Car chase and attempted murder ................................................................................ 15

>   Box: Roundtable on Sustainable Palm Oil......................................................................... 16
Environmental cost ................................................................................................................... 16
International financing .............................................................................................................. 17
‘Severe assault’, hundreds evicted ........................................................................................... 19
>   Box: Special Agriculture and Business Leases: a toxic legacy............................................ 20
RIMBUNAN HIJAU GROUP ................................................................................................................ 21
Permanent injuries ........................................................................................................... 22
Father-and-son tragedy ..................................................................................................... 22
Amputations, chemical accidents............................................................................................. 23
Unreported tragedies ........................................................................................................ 23
‘Inhuman’ treatment ......................................................................................................... 23
Police terror...................................................................................................................... 24

>   Box: Unequal burdens ................................................................................................................... 25
Following the money ......................................................................................................... 25

Cover image: Terraced oil palm fields overlook Ataliklikun Bay, East New Britain Province, Papua New Guinea. © Global Witness
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BEWANI OIL PALM PLANTATIONS LIMITED .................................................................................. 28
‘Lost everything’ ........................................................................................................................ 28
Will the real owners please stand up? ..........................................................................29
The great switcheroo ......................................................................................................... 30
It takes two to Tago .................................................................................................................... 30

GLOBAL BUYERS ............................................................................................................................... 32
Sticks in the throat ............................................................................................................ 33
‘Journey of no deforestation’ .................................................................................................... 33
>Table 1. Global brands that have sourced from palm oil producers East
New Britain Resources Group, Rimbunan Hijau, and/or Bewani Oil Palm
Plantations Ltd in Papua New Guinea, and their responses to Global
Witness’s requests for comment. .................................................................................................. 34
>   Box: Crowd-sourcing due diligence ........................................................................................... 37
Heavy industry ...................................................................................................................................... 38
CONCLUSIONS ........................................................................................................................ 39
Recommendations ............................................................................................................. 40
APPENDIX 1 ............................................................................................................................. 42
APPENDIX 2 ............................................................................................................................. 54
REFERENCES...................................................................................................................................... 57
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Agribusiness, including the palm oil industry, is a key driver of tropical deforestation. © Global Witness

The climate crisis is no longer projection, but reality.                    > Palm oil executives and senior employees tell
Forests play a key role in regulating the global                            undercover Global Witness investigators they bribed
climate and are critical to preventing runaway global                       officials including a Papua New Guinean government
heating. They are also a treasure trove of biological                       minister; paid police to brutalize villagers; used
diversity, and home to many indigenous peoples                              child labour; and participated in an apparent tax
                                                                            evasion scheme.
and forest communities. Yet forests continue to
be burned and destroyed at an alarming rate. The
                                                                            > The Malaysian-backed firms clear-felled tens of
primary driver of deforestation is agribusiness, with
                                                                            thousands of hectares of Papua New Guinean rainforest,
palm oil a chief culprit.
                                                                            which supports rural communities and is among the most
Global Witness went undercover to investigate the                           biodiverse in the world.
growing threat facing Papua New Guinea’s (PNG)
communities and tropical forests from palm oil                              >   Tainted palm oil and its derivatives from Papua New
companies driving widespread deforestation and human                        Guinea plantations were sold on to well-known big
rights abuses. This investigation now exposes that                          brands including Kellogg’s, Nestlé, Colgate, Danone,
three of PNG’s newest palm oil producers appear to be                       Hershey, and PZ Cussons and Reckitt Benckiser, the
implicated in serious criminality and other harms. For                      parent companies of Imperial Leather and Strepsils.
the first time, we show how this tainted product is being
sourced by world-famous brands and their business                           > One palm oil firm, Rimbunan Hijau, negligently ignored
financed by iconic banks and investors:                                     repeated and avoidable worker deaths and injuries on
                                                                            palm oil plantations.

                                                                            > Global financiers such as BlackRock, the world’s largest
                                                                            asset manager, are indirectly profiting from these human
                                                                            rights and environmental abuses through investing in
                                                                            banks notorious for financing harmful palm oil firms.
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A pattern of coercion and violence right across PNG has
denied local people the traditional use of forests integral
to their culture and livelihoods. Huge areas of tropical
forests have been deforested, and much more remains
at risk unless action is taken. Global Witness is calling for
companies named in this report to be held to account for
causing, contributing to, or profiting from harms linked
to their global operations. International financiers
ought not to be bankrolling these companies - and
governments need to regulate to stop bankers enabling
this industry’s excesses.

                                                                           Papua New Guinea’s forest communities have managed their
                                                                           environment for generations. © Global Witness

Money in, palm oil out: global finance funds the production of deforestation palm oil
in Papua New Guinea

         Palm oil supply chain links
    S$   Global finance links

                                kr                                        South Korea                                         Mexico
                                                       Malaysian &
                                               India   Singaporean
                                                          banks                  Papua New

                                                                              Malaysian-backed companies
                                                                              producing palm oil

The production of palm oil in Papua New Guinea by Malaysian-backed companies is enabled by global finance. Palm oil from these
plantations has been sold around the world. This illustration depicts some of the flows of money and palm oil examined in this investigation.

                                                                                                              THE TRUE PRICE OF PALM OIL 5
Page 5 screenshot

    “When the boys woke up, they were                         be blindfolded and arrested, then held for weeks, only
                                                              to be released on payment of bail that the villagers can
    at gunpoint. They tied their hands at                     scarcely afford.
    the back and blindfolded their faces                      Welcome to Papua New Guinea’s palm oil industry, where
    so they could not see.”                                   such brutality is commonplace. Global Witness now tells
                                                              the story of communities across the country harmed,
    – Resident of Watwat village                              terrorised, and impoverished in pursuit of a liquid gold
                                                              foodstuff that has found its way into the supply chain of
                                                              global brands including Kellogg’s, Nestlé, Danone, and
It is late at night in July 2019, and a pair of off-road      Hershey. And a Global Witness undercover investigation
vehicles wind their way through the rainforests of New        helps unpick a web of apparent tax evasion and
Britain, a crescent-shaped island off the north-east coast    corruption, tracing money flows from financiers in
of Papua New Guinea (PNG). The transport has been             the US, UK, and EU to this troubled new frontier of
paid for by a palm oil company. On board are police           the global palm oil industry.
armed with guns and metal bars who have received
an ‘allowance’ from the company. In effect, this is a
private army.                                                 A growing threat
On arrival at the village of Watwat—where nearby oil          Chances are you have consumed some palm oil already
palm trees have been vandalised by persons unknown—           today. Despite growing awareness of its association with
the armed officers dismount, intent on retribution. They      deforestation, it is the most common vegetable oil in
then launch a violent raid on the village. Men and boys       the world, appearing in everything from baked goods to
as young as 16 are dragged from their beds, beaten with       instant noodles to shampoo and baby formula.1 2 3 4 And
metal bars, and thrust down into the mud at gunpoint,         in PNG, palm oil is an industry poised to explode. By 2030,
lying prone as tropical rain lashes from the sky. They will   the PNG government aims to have 1.5m hectares (ha)

© Mapbox © OpenStreetMap

Page 6 screenshot
under oil palm cultivation, compared to about 150,000
ha in 2016 – a ten-fold increase.5 Yet, there is no national
                                                                  New Guinea has the highest plant diversity of any island on Earth,
policy guiding this expansion and creating safeguards             with the majority of its plants found nowhere else. © Global
to ensure communities are protected from acquisitive              Witness
corporations.6 Papua New Guinea’s history of land and
forests mismanagement makes this an urgent issue.7                major consumer markets, via favourite brands like
                                                                  Hershey and Kellogg’s.
A South Pacific nation, PNG makes up half of the massive
island of New Guinea, home to the world’s third-largest           East New Britain Province is home to thousands of square
remaining rainforest.8 The country’s borders include              kilometres of rainforest, and to operations of two of the
hundreds of smaller islands, and it controls an area of           oil palm producers that are the subject of this report.36
ocean over ten times the size of the UK.9 It is home
                                               10                 In October 2019, a team of Global Witness reporters drove
                                                                  south through the province to Watwat, site of the police’s
to at least five per cent of all species on Earth, many
found nowhere else: forest dragons, tree kangaroos,               night-time attack on village boys. An elderly villager,
resplendent birds of paradise, and the only known night-          Sharon, whose name has been changed to protect her
blooming orchid.11 12 13 14 15 16 17 Billions of metric tons of   safety, described how someone had vandalized palm
carbon are stored in the country’s towering trees. 18 With        trees there—destroying more than a thousand—and the
a population likely above eight million, richly diverse           Royal PNG Constabulary sought culprits. According to
cultures have developed in PNG, with more than 800                Sharon, they singled out five Watwat youths.
languages spoken. 19     20

                                                                  “The police were beating them and asking them
Most of PNG’s people live in rural areas and rely on              who cut the oil palm tree,” she recalled to Global
their land, seas, and forests for at least some of their          Witness reporters.
livelihoods.21 In turn, communities have carefully
managed the biodiversity of their local environment               Police dragged the young men and boys out of bed,
for generations.22 Papua New Guinea has strong laws
                    23                                            blindfolded them and tied their hands behind their
to protect Indigenous peoples’ rights and its stunning            backs, she said. Reporters were told officers beat the
biodiversity, but these are rarely enforced.24 Civil society      young people with metal bars and the flats of machetes,
and even the PNG government itself have documented                “jumping up and down on [a victim’s] back”.
its egregious failure to uphold these laws.25 26 27 This
                                                                  The men and boys were then taken to Kokopo, where
failure is on stark display in the sectors now dominated by       police allegedly hit their heads against posts to elicit
Malaysian-owned logging and agribusiness companies.
                                                                  confessions before they were charged with criminal
                                                                  damage. Global Witness has been unable to determine
New kids on the block                                             whether these charges led to convictions.

At the turn of the millennium, Malaysia itself was losing         Sharon told Global Witness the car that police
its forests faster than any other nation on earth.28 In just      arrived in was owned by a company called Tobar
twelve years, it lost 14% of its rainforest, much of which        Investment (“Tobar”).
was cleared to plant oil palm.29 Before long, its logging
companies sought new opportunities abroad. 30 They did
not have to look far. In PNG, they came to dominate the
                                                                                                     THE TRUE PRICE OF PALM OIL 7
logging industry, making it the world’s largest exporter
of tropical timber by 2014.31 Some of these companies

then planted oil palm on land they had cleared. 33

Global Witness has spent two years investigating three
such companies that began exporting palm oil from
PNG since 2014: the East New Britain Resources Group
(“ENB”), the Rimbunan Hijau Group (“RH”), and Bewani
Oil Palm Plantations Ltd (“Bewani”).34 Together, these

companies have recently cleared tens of thousands of
hectares of climate-critical rainforest in PNG. Despite the
growing urgency of the climate crisis, global financiers
have propped up these companies’ deforestation in the
expectation of profit. Their palm oil has now reached
Page 7 screenshot
“The company has a lot of money,” she said. “They are                    Watwat.37 It operates under a joint venture agreement

able to give it to the police. The police were working for               with East New Britain Palm Oil Ltd (ENBPOL), part of the
Tzen Niugini [an ENB company closely linked to Tobar].”                  ENB Resources Group of companies. This group is one
                                                                         of two major palm oil producers, along with Rimbunan
Global Witness asked the residents of Watwat whether
                                                                         Hijau, that have deforested thousands of hectares in East
anything good had come to their community from palm
                                                                         New Britain Province since 2010.
oil development.
                                                                         One of Tobar’s founding directors is Edward Lamur, a jolly
“Only destruction,” Sharon said.                                         figure and the former deputy provincial administrator for
To investigate these allegations, Global Witness went                    East New Britain.39 In February 2021, a Global Witness

undercover. Drawing on fieldwork and satellite imagery                   investigator posed as a commodities trader facing
and by following the money, Global Witness exposes in                    resistance from communities at a fictional plantation in
this report the growing threat facing PNG’s communities                  Thailand to ask how the police helped Tobar with the
and forests from palm oil companies that have acted                      Watwat development.
unaccountably, yet are financed by the world’s biggest
                                                                         “We had some problems when we were planting, before
banks and sold to global brands. Global Witness focused
                                                                         we... when we were preparing the land to plant, some
on three Malaysian-backed palm oil producers: the East
                                                                         people wanted to disturb us,” Mr Lamur said. “So we got
New Britain Resources Group, the Rimbunan Hijau Group,
                                                                         police... we sat down with them”.
and Bewani Oil Palm Plantations Ltd. Together they have
deforested tens of thousands of hectares since 2010.                     [...] Mr Lamur chuckled and said, “They did some bashing
Our investigation widened to include a PNG-owned                         up.” [...]
company, Tobar Investment Ltd, as serious admissions
of corruption and police violence were made to                           “Beating them?” the investigator asked.
our reporters.
                                                                         “That’s correct,” replied the businessman. [...] “... Even at
This report exposes instances of apparent tax avoidance,                 night those culprits... who you know did trouble and ran
corruption and abuses of both local communities and                      away to the hiding places [...] so we went after them in
their environment. We then reveal the financial actors                   the night, got them, belted them up and locked them up
profiting from these acts, as well as the global brands                  at the station. [...]
sourcing the companies’ product. The investigation
concludes by recommending the changes urgently
needed to safeguard PNG’s communities and
environment and hold these corporations accountable.

Tobar’s Laughing Villain
Tobar Investment Ltd is a Papua New Guinean-owned
agribusiness company with palm oil plantations around

        East New Britain Resources Group of companies
        operating in Papua New Guinea


                                                            East New Britain Palm Oil Ltd                   Tobar Investment Ltd

         Eng Kwee Tan                                        Tzen Plantation Ltd

                                                             Tzen Niugini Ltd

                                                                         “...I made sure those operations were done,” he added.
                                                                         [...] “They know we are owners now.”

The East New Britain Resources Group includes multiple companies in PNG directed by Malaysian nationals. Tobar Investment Ltd has a joint
venture agreement with one of these companies, East New Britain Palm Oil Ltd. © Global Witness

Page 8 screenshot
                                                                         The Royal PNG Constabulary did not respond to multiple
                                                                         requests for comment from Global Witness.
East New Britain Province is a seismically active area and experiences
frequent earthquakes. Active volcanoes lie just across a harbour from
                                                                         ENB said: “We generally deny all the allegations.” A
the provincial capital Kokopo. © Global Witness
                                                                         spokesperson called Global Witness’s findings “baseless
                                                                         and untrue”.
Later confronted with his own admissions, Mr Lamur
                                                                         They added: “Both Tobar and ENBRG deny any use of the
did not respond to multiple requests for comment from
                                                                         Royal PNG Constabulary to cause any violence against
Global Witness.
                                                                         any person or detain anyone illegally.”
Mr Lamur described the influence of both Tobar and ENB
over the police.                                                         Global Witness did not receive a separate reply
                                                                         from Tobar.
Both companies “assisted with logistically paying for
police, you know... fuel, cars”, he said.                                Political connections
[...] “When they [villagers] are aggressive, we naturally                Oil palm attracts powerful men. Another founding
use a little bit of force on them. [...] So the story you know           director of Tobar is Leo Dion, the ex-governor of East
went around, oh police... you know these people are                      New Britain Province and a former Deputy Prime
doing this and this. And police... So [...] we quietened                 Minister of PNG.41 42 43 (Mr Dion is still listed as a director
things down. No more, no more unnecessary disturbance                    in company filings but, according to Mr Lamur, he is no
to our workers who were planting.”                                       longer in that position.)

On a later phone call, Mr Lamur doubled down on his                      Asked whether having a Deputy Prime Minister on the
claims of this cosy relationship with the constabulary.                  board of Tobar was useful, Mr Lamur told our undercover
On questioning, he confirmed that a former member                        reporter: “Yes, he was very good for us and very good for
of Tobar’s staff had worked simultaneously as a police                   Mr Tan [ENB’s CEO Eng Kwee Tan] and them too.”
reservist. Then the businessman went further yet.
                                                                         “So he could secure some special deals, I guess, with the
“There is a special operation police,” he said. “The boss                ministry, or not?” asked Global Witness.
is actually a very close friend, we work hand in hand with
them [...] whenever we want assistance...”.                              “That’s correct, that’s correct,” replied the businessman.

Global Witness said, “So, whenever there is a problem,                   Contacted by Global Witness, Mr Dion said he “offered
you can call this special operation police and they                      help in acquiring coconut plantations during the early
help you?”                                                               years of the former chairman of Tobar Investment Ltd
                                                                         Joseph Lupin when I was the governor then helping our
[...] “Yeah, we’ve got the boss’s mobile number”, Lamur                  grassroot people [sic throughout] to take ownership of
said. “We just call or text any time”.                                   foreign own plantations here i[n] ENBP.”

Mr Lamur, the former deputy provincial administrator,                    He added, “Any other Tobar Investment businesses
has higher political aspirations. In 2017, he stood for                  carried out after the death of Mr Joseph Lupin has
the Kokopo Open seat in PNG’s Parliament. Will he                        nothing to do with me.
run again?
                                                                         “I denied any participation in any way by words or actions
                                                                         to condone anything that is illegal and unlawful.”

                                                                         Global Witness has found no evidence that improper
                                                                         deals did actually take place under Mr Dion’s auspices.

                                                                         But as we shall hear, Mr Lamur’s partners at ENB are no
                                                                         strangers to ‘special deals’ themselves. Global Witness’s
                                                                         undercover operatives infiltrated the higher echelons of
                                                                         ENB itself, dining on separate occasions with both senior
                                                                         managers and with the chief executive. This yielded
                                                                         admissions of serious white-collar crime and human
                                                                         rights abuses – which allegedly go right to the upper
                                                                         echelons of Papua New Guinean politics.

                                                                                                          THE TRUE PRICE OF PALM OIL 9
Page 9 screenshot
       EAST NEW BRITAIN                                                                       Total forest destroyed, 2007-2019:
                                                                                                                 18,900 hectares


     Deforestation in plain sight: Forest clearance surrounds ENB’s Liguria mill in this satellite imagery mosaic from 2017-2018.

     In a palm-thatched Kokopo restaurant that overlooks
     a smoking volcano across the harbour, two senior
     ENB executives readily admitted that bribery to obtain
     logging permits and access to land is a regular cost of
     doing business. Tzen Niugini’s Land Acquisitions Officer
     Bernard Lolot and public relations kingpin Michael
     Paisparea were in a boastful mood when they met Global
     Witness undercover reporters for a business dinner in
     October, 2019.44    45

     Asked whether a “special favour” had convinced
     government officials to approve projects, Mr Lolot said:
     “Of course [...] that’s what a lot of the leaders, they want.
     [...] Some school fees and they ask for token and all this.”

     “What is a token? A nice Land Cruiser?” asked Global

     “Yep, things like that,” Mr Lolot replied.

     [...] “Sometimes they’re bringing all this stuff back to
     their own areas.”

     ‘Unofficial fees’
     Mr Paisparea went further, acknowledging gifts to secure
     the renewal of a logging permit.

     “...Giving something to the minister, to the secretary, to
     [National Forest] Board members...” he said.

     Asked whether this constituted ‘unofficial fees’, he
     replied: “Yeah, that’s right.” [...]

     He said: “Roughly, sometimes the minister need about a
     hundred thousand, fifty thousand [Papua New Guinean
     kina].” Fifty thousand kina was about £10,000 at the time
     of writing.

     Asked if the chairman of the National Forest Board also
     needed paying, Mr Paisparea said: “Chairman as well.”

     Our reporter probed: “So [in total for one permit], you pay
     half a million?”

     Mr Paisparea responded: “That’s right. It’s enough.”

Page 10 screenshot
In addition to his work for ENB, Mr Paisparea serves on              The PNG Forest Authority did not respond to repeated
the East New Britain Provincial Forestry Management                  requests for comment, including a letter hand-delivered
Committee (PFMC), which assesses new forestry projects               to its headquarters.
and recommends to the national board to approve or
                                                                     In its response, ENB denied bribery and corruption,
reject them. This presents a serious conflict of interest.
                                                                     writing, “We generally deny all the allegations” put to it
Although Mr Paisparea said he does not rule on his
                                                                     by Global Witness. It added, “Most of your allegations are
own projects, the position may nonetheless allow him
influence over other members.                                        all hearsay with no accurate details”.

Asked about official fees, Mr Lolot said: “The official              In an apparent reference to Mr Paisparea’s position on
fee’s not so much [...] 200,000, 150 [thousand PGK,                  the PFMC, it said: “Renewal of existing and new forest
about £30,000].”                                                     projects are only approved by the PNG Forest
Explaining how to convince individuals to sign papers
suggesting the company has rights over their land,                   While this is true, the PFMC provides recommendations to
Mr Paisparea said: “Request of the school fee, I come                the Forest Authority.
there and we help them.”...
                                                                     Following the dinner, Mr Lolot supplied Global Witness
[...] “Because these things are not in [the official]                with numerous maps and documents relating to several
the agreement.”                                                      logging and agriculture projects, showing his intimate
                                                                     involvement with major deforestation plans.
Global Witness has been unable to discover what projects
these claims may refer to. Nor can we rule out that they             Eight months later, in a follow-up telephone discussion,
were groundless boasts. However, the comments suggest                an undercover Global Witness reporter repeated Mr
a detailed understanding of who needs to be bribed, such             Paisparea’s bribery admissions back to him. He did not
as the knowledge that the secretary and board members                deny them, and conceded paying “allowances” to entice
would need to be bribed in addition to a minister. Global            individual customary landowners whose forests Tzen
Witness is not suggesting that any employee, minister,               Niugini coveted, although he said they did not offer Land
or member of the Board did in fact accept a bribe.                   Cruisers in that instance, which is why a rival company
                                                                     obtained access to the land.

An employee of the East New Britain Resources Group shared documents from numerous logging projects with an undercover
Global Witness reporter. © Global Witness

                                                                                                       THE TRUE PRICE OF PALM OIL 11
Page 11 screenshot
Communities’ traditional use of their land is protected                   defines this category to include work in an environment
by the country’s laws and constitution, making virtually                  likely to harm the health or safety of children. 57
every Papua New Guinean a landowner.46 Most of the47

country is still under the legal control of such customary                Children working on a palm oil plantation therefore
landowners, at least on paper.48 49 50 But these laws are                 constitutes an offence under both the PNG Employment
poorly enforced, allowing companies like ENB to                           Act and Convention. ENB said Global Witness’s allegation
                                                                          that it used child labour was “absurd and denied”, and it
exploit rural communities and setting people against
their neighbours. 51 52 53                                                upheld PNG child labour laws.

Papua New Guinea scores dismally on Transparency                          Oil palm plantation workers carry out heavy labour.
International’s corruption perceptions index, scoring a                   They are at risk of musculoskeletal injuries, infectious
mere 27 points out of 100 in 2020. This puts it in 142nd                  disorders including malaria, pesticide exposure,
place out of the 180 countries assessed.54                                and sexual harassment and rape. 58 As Global  59

                                                                          Witness’s investigation reveals, deaths among workers
                                                                          are commonplace.
Child labour
During the Kokopo dinner, Mr Lolot and Mr Paisparea                       Women threatened at gunpoint
also admitted the company used child labour, with
schoolchildren as young as ten working on their                           A mediation process in East New Britain Province in
plantations. Mr Lolot conceded this was against PNG law.                  June 2018, which brought to light serious allegations
He had added just before: “Sometimes we bend the rules                    by villagers against the ENB group, also implicated Mr
just to make things happen.”55                                            Lolot and Mr Paisparea. Multiple witnesses said the ENB
                                                                          company Tzen Niugini “brought in” police officers to
Employing a person under 16 years of age in work                          Pulpul in the East Pomio region to coerce community
that is likely to be injurious is an offence under the                    members, as landowners, into signing agreements for a
PNG Employment Act.56 PNG is also a signatory to the                      logging project. In an incident with strong echoes of the
Convention on the Worst Forms of Child Labour, which                      Watwat village repression, police allegedly forced the men

East New Britain Palm Oil Ltd operates the Narangit palm oil mill in northern East New Britain Province. © Global Witness

Page 12 screenshot
into a shed at gunpoint and held them there for hours and
threatened the women at gunpoint. Pulpul community
                                                                   Kokopo, the capital of East New Britain Province. © Global Witness
members alleged police punched the village magistrate
and beat him with a fan belt. The aim of this atrocity,
according to members of the community, was to override             “So we have to make it show like it come from Malaysia,”
objections they had already voiced to Mr Paisparea                 he continued. “It’s always a bit technical.”
and Mr Lolot, when they had rejected the idea of this
new development. Speaking to a local NGO, villagers                The reporter replied: “Oh, so it goes on the paper to
claimed that this physical abuse had happened on                   Malaysia. But directly to India.”
Mr Lolot’s land.60
                                                                   Mr Tan said: “Yes, yes. So we make it that it comes
Mr Paisparea and Mr Lolot did not respond to Global                from Malaysia.”
Witness’s subsequent requests for comment.
                                                                   He continued: “The vessel has to go to Malaysia, offload
ENB said: “ENBRG has complied with all Forestry and                the PKO [palm kernel oil], and then offload the CPO
Environmental laws in Papua New Guinea and denies                  [crude palm oil] in India.”
participating in any illegal activity in connection to any
                                                                   This would appear to be an admission that the ENB
Forest projects or planting of oil palms.”
                                                                   Group has dishonestly evaded the imposition of import
“ENBRG has and continues to comply with all land laws in           duty on its palm oil exports to India. Such a scheme could
Papua New Guinea to acquire and/or develop land”.                  have benefitted the company by claiming preferential
                                                                   Indian tariffs for palm oil exports from Malaysia rather
During their dinner with Global Witness, Mr Lolot and              than from PNG.
Mr Paisparea revealed ENB was running two palm oil
projects: one in Pomio District and the other in Gazelle
District at the north end of the province.61 As we shall see,      Watch the tax gap
at the latter site, the company stands accused of brutally         Between March 2018 and 27 November 2020,64 India taxed
evicting smallholders and bulldozing their homes and               crude palm oil imports from countries it did not have free
cacao trees.
                                                                   trade agreements with—including PNG—at a base rate of
                                                                   44%.65 But Malaysian imports were not taxed as heavily.

But the pair were not the only ones who made damaging
                                                                   In 2019, when Mr Tan spoke to an undercover Global
admissions. Their Malaysian boss Eng Kwee Tan, chief
                                                                   Witness researcher, the Malaysia-India Comprehensive
executive of the ENB Group, also confessed to a tax
                                                                   Economic Cooperative Agreement (MICECA) established a
evasion scheme on an international scale.62
                                                                   duty on Malaysian palm oil of only 40%.67

Admissions of tax evasion                                          India also charges a Social Welfare Surcharge equal to
                                                                   10% of the total duty on imports, in addition to the
“I would also be lying to you if [I said] there is no conflict,”   import duty itself.68 In 2019, this resulted in a 4.4
Mr Tan told a Global Witness undercover reporter over              percentage point difference between tariffs levied
a dinner of red snapper. “We do have conflicts, but                on PNG and Malaysian imports of palm oil to India. This
solvable conflicts.                                                tax gap appears to lie behind Mr Tan’s scheme. And our
                                                                   research shows shipments were indeed made by ENB to
“We have people, you know, that come and stop our work             India in the relevant period.
[...] and I think this is a common phenomenon.”63

Mr Tan was referring to local villagers. Land conflicts are
a frequent by-product of palm oil plantations.                                                       THE TRUE PRICE OF PALM OIL 13

In a swanky hotel in the port town of Kokopo, the
businessman bragged of owning no fewer than
20 German Shepherd dogs - and soon it became clear
how he can fund such indulgences.

Halfway through the meal in October 2019, he made the
unprompted remark that palm oil destined for India “has
to come from Malaysia, otherwise they impose taxes”.
Page 13 screenshot
     Global Witness tracked the oil tanker Chem Peace from East New Britain, Papua New Guinea, to Kolkata, India. © Mapbox, ©OpenStreetMap

     Tracking the tankers
     Global Witness documented two voyages of the oil tanker
                                                                            ‘Impossible’ to sell
     Chem Peace travelling from PNG to India in 2019 (one
     arriving in January that year and the second in May).                  With Indian tariffs on PNG palm oil so high in 2019,
     Social media posts, commercial shipping data and a                     selling legitimately to the country in this period appears
     Kolkata Port Traffic Control document illustrate the ship’s            to have been economically unattractive. According to
     travels. A Facebook photo posted on 21 December 2018                   UN Comtrade data, during 2019, India imported more
     reveals the Chem Peace collected palm oil from ENB’s                   than 6.6 million metric tons of crude palm oil, of which
     “Liguria” palm oil mill in Pomio. From there, records                  1.7 million tons came from Malaysia. By comparison,
     show, it travelled to Singapore, then Malaysia - where Mr              a mere 11,346mt was declared as coming from Papua
     Tan told our undercover reporter his company sometimes                 New Guinea, despite its burgeoning plantations.75 This
     unloads palm kernel oil - before arriving in India on 4                illustrates how rare legitimate palm oil sales between
     January 2019. There, Kolkata port records indicate it                  Papua New Guinea and India were during this period
     consigned 6,118 metric tonnes (mt) of crude palm oil                   compared to those from Malaysia.
     to leading agribusiness Ruchi Soya Industries (Ruchi                   Global Witness spoke to two palm oil industry experts in
     Soya).69 This quantity matches Mr Tan’s estimates to
                                                                            India. One said it was “impossible” to import from PNG
     our undercover reporter of his total monthly exports.                  because of the significantly higher tariffs compared to
     A documented journey therefore supports Mr Tan’s                       Malaysian palm oil.
     assertion that ENB exports palm oil from PNG to India.
     Yet the Kolkata Port document describing the Chem
     Peace’s palm oil delivery indicates only that the vessel
     had been in Pasir Gudang, Malaysia. It does not state
     that the palm oil originated from PNG. This would appear
     to be a smoking gun that in 2019 at least one ENB palm
     oil delivery to India was not accurately badged as
     coming from PNG.

     No paper trail
     There is further supporting evidence of this. In 2018,
     commercial shipping records show, an “ENB Trading Ltd”
     exported one shipment of palm oil from PNG to India. (An
     entity registered in Singapore, “ENB Trading & Shipping
     Pte Ltd”, appears to be wholly owned by the British Virgin

     Islands-registered company that also owns East New
     Britain Palm Oil Limited.71 ) Yet for 2019, not a single

     shipment appears in these records as being exported
     from PNG to India by ENB Trading. This is despite the
     voyage plotted above.

     Mr Tan told our undercover reporter that ENB exports
     approximately 5,000-6,000mt of crude palm oil per
     month. In 2019, palm oil prices averaged 2,248 Malaysian
     ringgit per ton (about £414, at December 2019 exchange
     rates).73 Global Witness calculates that if each of the two

     2019 shipments we tracked carried an average of 6,000mt,
     they would have been worth about £4,970,400. That
     year, the 4.4 percentage point tax gap meant that if the
     full cargo was unloaded in India, the Indian government
     would have lost out on about £219,000 of public revenues
     compared to if it had been honestly labelled.

Page 14 screenshot
Paranjoy Guha Thakurta, an investigative journalist,                   deforestation into its supply chain. Checking the origin of
author, and the former editor of the academic journal                  its purchases is a basic step. If Global Witness is able to
Economic and Political Weekly,76 said: “If the customs                 find out this information, major companies could
duty on oil from Papua New Guinea is higher than the oil               too. Ruchi Soya did not respond to multiple requests
imported from Malaysia, and given the fact that Papua                  for comment.
New Guinea is geographically located further away from
                                                                       It should be noted that commercial records show that
India than Malaysia, the landed price of oil from Papua
New Guinea would be substantially higher than oil                      in 2020, ENB Trading Ltd was again named on shipments
imported from Malaysia.                                                of palm oil from PNG to India.77 If an illicit scheme was

                                                                       in operation in 2019, perhaps the ENB group had
“Since private businesspersons would like to maximise                  decided to bring it to an end. But Mr Tan’s admission to
their profits, it is logical that they would not want to               an undercover Global Witness reporter, married with
purchase oil at a higher price from Papua New Guinea.”                 clear evidence that ENB palm oil was shipped to India
                                                                       from PNG that year, with no trace of such deliveries on
It would appear, therefore, that ENB found a dishonest                 trade databases or port records, means there are clear
route to marketing its product in India profitably.                    grounds for Indian authorities to investigate a possible
Overall, then, Global Witness’s analysis found that palm               tax scam.
oil shipments from PNG to India were indeed made in                    Not far from the hotel where Mr Tan made his admissions,
2019, and there are serious grounds for believing this was             meanwhile, the tensions seeded by the palm oil industry
undeclared. And this would likely have been of financial               had exploded in an incident far more frightening than the
benefit to Mr Tan and ENB, by opening up their product                 relatively placid world of white-collar crime.
to a market that tariffs rendered otherwise unprofitable.

ENB categorically denied any involvement in tax                        Car chase and attempted murder
evasion and said it “has and continues to proudly
market and sells all palm products it ships and sells                  In September 2019, Doug Tennent, a Catholic lay
as of Papua New Guinea origin”.                                        missionary from New Zealand, drove to Warangoi,
                                                                       south of Kokopo, to inspect disputed land. 79 80 81 A legal
It added: “ENB Trading & Shipping Pte Ltd has been                     officer for the Archdiocese of Rabaul, Mr Tennent spent
dormant since incorporation, without any business                      years helping communities with land claims involving
activities since day 1. Your allegations are entirely                  logging and oil palm development.82 Too often, predatory
inaccurate.”                                                           companies pursue a policy of ‘divide-and-conquer’ with
                                                                       local people to enable such projects.83 Now the results of
“ENBRG has always done business with integrity, and we                 this policy would be turned on him.
hold ourselves to high ethical standards.”
                                                                       After a local group had obtained a title over a parcel
There is no suggestion that Ruchi Soya, to whom the                    of land the Church claimed to have owned since the
Chem Peace consigned the crude palm oil in January                     1960s, Tzen Niugini planted more than 2,700 ha of oil
2019, was complicit in this alleged scheme. But it should
                                                                       palm there, according to Mr Tennent.84 85 86 And when the
carry out due diligence and not allow palm oil tainted by
                                                                       churchman arrived in his small Suzuki car, his presence
                                                                       provoked an angry response, he alleged. Mr Tennent
                                                                       tried to drive off, swerving around five men who tried to
Rural communities in PNG often need roads to access health care,       block his way. A car and a truck then gave pursuit in what
schools, and markets, but the roads built by extractive industry can   had become a high-speed chase. When the truck rammed
be worse than nothing. © Global Witness
                                                                       his Suzuki from behind, locking his steering, it sent the
                                                                       car careening down a steep slope, rolling six times, Mr
                                                                       Tennent said. He believes he was lucky to have survived
                                                                       the attack and described it to Global Witness as an
                                                                       attempted murder.

                                                                       Contacted by Global Witness, the local police confirmed
                                                                       the near-deadly attack on Mr Tennent.87

                                                                       “They [Tzen Niugini] were not behind that”, said Mr
                                                                       Tennent. While there is no suggestion that this incident
                                                                       was directed by Tzen Niugini, it is symptomatic of the

                                                                                                     THE TRUE PRICE OF PALM OIL 15
Page 15 screenshot
conflicts the industry has provoked over time within and       ENB operates two plantation sites in East New Britain.
between communities.                                           Part of one plantation, operated by ENBPOL in the
                                                               Gazelle District, was cultivated by smallholders growing
“ENBRG has and continues to comply with all land laws in       cacao and coffee – until ENB bulldozed their trees to
Papua New Guinea to acquire and/or develop land”, the          plant oil palm (see p. 18). The other, operated by Tzen
company told Global Witness.                                   Niugini in the island’s Pomio District, was formerly
                                                               rainforest. At that Pomio concession, Global Witness
Environmental Cost                                             calculates some 18,900 ha of forest was destroyed
                                                               between 2007 and 2019. (See Appendix 2.) ENB exported
The ENB Resources Group is thus implicated in bribery,         about 800,000m3 of valuable tropical timber from
violence and tax evasion. But what of the environmental        this project.91
harms? Between 2002 and 2014, a greater proportion of
forests on New Britain were clear-cut than in any other        Together, these findings paint a picture of a company
part of PNG.88 Global Witness’s analysis now indicates ENB     that is willing to defy national and international law,
has cleared thousands of hectares of forest on the island.     and destroy highly biodiverse, culturally critical forested
                                                               landscapes to produce its palm oil.
New Britain is part of an ‘Endemic Bird Area,’ home to
                                                               ENB told Global Witness it complied with all forestry,
14 species of bird found nowhere else on earth.89 Some
are highly dependent on lowland forest such as that            environmental, and land laws in PNG and denied
found on the island, putting them at risk of extinction. 90    participating in any illegal activity.

     Roundtable on Sustainable Palm Oil
     The Roundtable on Sustainable Palm Oil (RSPO), touted by supporters as a green credential, is a palm oil
     certification scheme that covers 19% of global production, according to its own estimate. 92 The association

     says its objective is to advance the production and use of sustainable palm oil, in part via its eponymous
     certification programme.94 Both oil palm growers and their customers can be certified under RSPO.95 While the
     scheme has recently incorporated a no-deforestation requirement, it has repeatedly come under scrutiny
     for being ineffective due to poor implementation, lack of oversight, a sluggish grievance process and conflicts
     of interest. 96 97 98

     Neither ENB nor RH companies in Papua New Guinea are RSPO-certified. However, many of their recent big-
     name clients are (see “Global buyers”, below). This results in ENB and RH palm oil finding its way into RSPO-
     certified supply chains, casting further doubt on the scheme’s validity. Under RSPO’s ‘Mass Balance’ system
     of certification, palm oil that violates RSPO’s own standards can still be sold as “certified”. This scheme means
     if a trader buys 5,000t of certified and 5,000t of non-certified palm oil from a plantation like ENB’s, it is
     allowed to mix the oils together and sell 5,000t of it onwards with Mass Balance certification, even if some of
     that oil
     is from an uncertified and harmful site.99 This policy completely undermines the scheme and could mislead
     consumers. Consequently, buying some palm oil from plantations engaged in large-scale deforestation and
     with dangerous working conditions is not a violation of these companies’ commitments under their RSPO
     certification.100 It should be.

     An RSPO spokesperson said: “It is our mission to ensure the sustainable palm oil sector respects biodiversity,
     natural ecosystems, local communities, and workers’ rights and safety.”

     “All RSPO members are required to make time-bound commitments to only purchase certified sustainable
     palm oil (CSPO).”

     The organisation described the Mass Balance model as a way for companies to begin to do this. It pointed
     out that mills producing Mass Balance palm oil must check that the oil palm fruit they process has been
     grown legally.

Page 16 screenshot
                                                                      financing available to the company group.106 107
                                                                      The documents refer to ENBPOL’s revenues from
PNG’s forests provide innumerable ecosystem services to its people,
including the provision of fresh water. © Global Witness              “plantation land”.108

                                                                      This comes as no surprise. Maybank is one of the world’s
                                                                      largest palm oil financiers, pouring US$3.9 billion in
International financing                                               loans and underwriting services into the sector between
                                                                      2010 and 2016, according to an analysis published
Large-scale industrial agriculture is a capital-intensive
                                                                      by Tuk Indonesia and Profundo. 109 It has been

industry, and ready access to capital is thus a pinch-point
on the ambitions of destructive corporations such as                  previously criticized for financing clients involved in land
ENB.101 That is why Global Witness is campaigning for                 grabbing, devastating vegetation-clearance fires in their
the UK, US and EU to compel its banks and investors to                concessions, development on peatlands, and lack of free,
screen out companies engaging in deforestation from                   prior and informed consent (FPIC) in dealings with local
their client base.102 During this investigation, Global
                                                                      and Indigenous communities.111
Witness obtained first-hand testimony as to how effective
                                                                      Maybank’s 2020 sustainability report refers to a
this would be. ENB chief executive Mr Tan told our
                                                                      framework for assessing risks of financing palm oil, but
undercover reporter when it came to funding, “that alone
                                                                      Global Witness has been unable to find it or the bank’s
is a constraint to our expansion”. [...]
                                                                      overarching ESG (Environmental, Social and Governance)
                                                                      policy. This raises the question of how communities are
He continued: “...We are not able to expand, not because
                                                                      meant to avail themselves of rights under a policy that
we are not, not because our appetite are [sic] small, just
                                                                      they can’t even see. According to Maybank, however,
because we feel that ... financial resources are limited...”
                                                                      it requires its palm oil customers—in this case ENB—to
Irregularities and abuses in land and forest-related                  comply with NDPE (No deforestation, development on
industries in Papua New Guinea are extensively                        peatland and exploitation of Indigenous and local people
documented, routine, and severe. Despite this, Global                 and workers) policies.112 It is unclear how or if this policy
Witness has discovered the Malaysian financial                        is implemented.
powerhouse Malayan Banking Berhad (Maybank) has
chosen to bankroll ENB’s activities.104 Maybank itself is
                                            105                       Global Witness’ investigation finds that by financing
owned in part by a host of well-known financial names in              ENB, Maybank has enabled the company’s abuses,
the UK, US, and EU. These institutions are thus enablers              from deforestation to the apparently corrupt acts
of the crimes and abuses detailed above.                              described by its senior staffers. While we do not know
                                                                      how much money Maybank made on its deal with ENB,
Documents filed with the PNG Investment Promotion                     the bank certainly expected to profit, and entered into
Authority reveal that in July 2015, Maybank Group                     the deal despite the well-documented risks of illegality
subsidiary Maybank Islamic Berhad inked an agreement                  and serious harms endemic to the PNG land and
with ENBPOL to make as much as US$40 million of                       forestry sectors.

                                                                      “Maybank is fully cognisant of the environmental, social
                                                                      and governance impacts associated either directly or
                                                                      indirectly with the activities within the countries we
                                                                      finance and specifically [...] the issues associated with
                                                                      deforestation, improper governance, labour as well as
                                                                      human rights,” the bank said.

                                                                      “We would like to stress that the Group is cautious in
                                                                      its approach when engaging or financing companies
                                                                      that may have a negative impact on the environment
                                                                      and communities.”

                                                                      Maybank said it engaged clients to “ensure alignment
                                                                      with sustainable practices”, and high-risk companies were
                                                                      required to undergo additional assessment. Where clients
                                                                      fell short, business relationships are “re-considered”.

                                                                      The bank went on: “Maybank is unable to confirm or
                                                                      discuss any alleged banking relationships we may have,

                                                                                                    THE TRUE PRICE OF PALM OIL 17
Page 17 screenshot
                                                                          Some of these financiers have developed policies
                                                                          or principles that should limit their investing in
     Both Rimbunan Hijau and ENB operate on East New Britain Province’s
                                                                          deforestation. CalPERS, for example, says that
     South Coast. Jacquinot Bay is visible in this aerial view of the
     coastline. © Global Witness                                          companies should disclose and manage environmental
                                                                          risks, including deforestation.118 Robeco boasts it is a
                                                                          signatory to over 60 sustainable investing memberships,
     or have had with any organisation, owing to banking
     secrecy laws.                                                        statements, and principles.119 The asset manager states it
                                                                          will exclude palm oil producers that have less than 20% of
     “We, do however, wish to reiterate that Maybank in                   their land certified by RSPO from its funds. But it does not
     2015 had disposed of our banking subsidiary in Papua                 exclude the financiers of palm oil – meaning the likes of
     New Guinea.”                                                         Maybank can slip through the cracks.120

     Maybank did not respond to Global Witness’s allegations              CalPERS acknowledged holding millions of shares in
     regarding ENB and Rimbunan Hijau (see p. 21) operating               Maybank, as well as in RHB Bank Berhad and Oversea-
     without community consent. The bank said that it                     Chinese Banking Corporation (see p. 25). But, a
     intends to publish its NDPE commitments and an                       spokesman said, “We don’t have insight or comments
     ESG policy soon.                                                     about the material contained in [Global Witness’s] letter,”
                                                                          adding that these investments were passively managed
     “Maybank is committed to playing our role in helping                 as part of an index fund.
     countries and companies [...] to grow the economy in a
     sustainable manner, whilst remaining responsible to local            Robeco said: “Regarding our engagement with Maybank,
     communities and the environment,” it said.                           we are part of the PRI working group on palm oil and
                                                                          deforestation [...] that has actively engaged Maybank
                                                                          on strengthening their no deforestation, no peat, no
     International financiers                                             exploitation policy since 2019 to reduce the negative
                                                                          impact on biodiversity they are exposed to as one of the
     Maybank’s shareholders include some of the globe’s
                                                                          largest financiers of the palm oil industry.”
     most powerful financiers. These include two subsidiaries
     of the world’s largest asset manager BlackRock.                      The company claimed it actively addressed the risk of
     Additional backers include the giant California Public               deforestation in its investments with an “active
     Employees’ Retirement System (CalPERS), and Norges                   ownership strategy”.
     Bank Investment Management (NBIM), the manager
     of Norway’s oil fund, the world’s largest sovereign                  “As a responsible investor, NBIM has focused on climate
     wealth fund.113 114 115 The Vanguard Group, Inc. and                 change and human rights issues for more than ten years,”
     Dimensional Fund Advisors, LP also appear among the                  the Norwegian sovereign wealth fund manager said.
     top shareholders, as does the Netherlands-based Robeco               “We expect companies engaged in activities with a direct
     Institutional Asset Management B.V.116 UK-based Pyrford
     International Limited is also a shareholder.117
     By investing directly in Maybank, these funds and
     asset managers are partly responsible for the abuses
     carried out by the bank’s customers that its financing
     has enabled.

     “Pyrford International takes its ESG responsibilities very
     seriously,” the investment firm said, adding that it had
     been a signatory to the UN Principles on Responsible
     Investment (PRI) since 2014.

     Pyrford said it was part of BMO Global Asset Management,
     which it called “an industry leader in terms of responsible

     The fund said it had raised Global Witness’s concerns with
     Maybank. Nevertheless, it declined to commit to pressing
     Maybank to investigate Global Witness’s findings.

     Dimensional Fund Advisors did not respond to repeated
     requests for comment.

Page 18 screenshot
or indirect impact on tropical forests to have a strategy              boards to understand how companies are managing
for reducing deforestation from their own activities and               sustainability risks.”
from their supply chains”, and to conduct human rights
due diligence.                                                         Vanguard said it took the concerns raised seriously and
                                                                       would incorporate them into its analysis and monitoring
“Since 2018, we have proactively engaged with banks                    of companies with direct and indirect business exposures
in Southeast Asia regarding their policies for lending to              in the PNG region.
companies that contribute to deforestation”, NBIM said.
“We urge the banks to strengthen their due diligence and               “We have engaged on this topic and associated matters
to report on climate and deforestation risks.”                         such as deforestation,” it said, noting that it participated
                                                                       in the Net Zero Asset Managers initiative. “When a
NBIM said it did not provide information about its                     company’s products, services, or practices pose a risk to
engagements with individual companies.                                 its employees, customers, and the communities where
                                                                       the company operates, it can manifest into material
For their part, BlackRock and Vanguard have voted                      reputational, competitive, legal, and regulatory risks that
against almost every shareholder resolution to halt                    can affect long-term shareholder value.”
deforestation by the companies in their portfolios since
2012. These asset managers are facing growing pressure                 The severity of the cases that Global Witness have
on their poor record on deforestation, land rights and                 uncovered raises disturbing questions of if, and how,
Indigenous rights issues.121 122 123                                   laws or norms relating to due diligence required to
                                                                       avoid financing linked to companies engaged in illegal
Approached for comment, BlackRock said: “Palm oil                      activities have been broken. They also reinforce the
production is an example of a particularly complex                     need for countries that import, use or finance forest-risk
investment stewardship issue.”                                         commodities such as palm oil to recognise that company
                                                                       self-regulation has failed. Clear requirements are needed
It pointed Global Witness to a 2021 publication that said
                                                                       for businesses, including finance, to undertake adequate
BlackRock encourages companies to disclose their plans
                                                                       due diligence on deforestation, the lack of FPIC, and
for sustainable use of natural resources.
                                                                       related human rights abuses. Such laws are currently
“As an asset manager, BlackRock cannot substitute                      being proposed in the EU and UK, and potentially the US
one company for another company or exclude any                         – and Global Witness is campaigning to ensure that the
particular companies from the indices selected by                      finance sector is not exempted from these provisions.
our clients,” a spokesperson continued. “We focus on
engaging with companies’ management teams and                          ‘Severe assault’, hundreds evicted
                                                                       There was more than enough evidence of problems to
                                                                       have steered Maybank away from financing the ENB
                                                                       group. A legal battle involving ENB in the Gazelle district
                                                                       of East New Britain Province illustrates Maybank’s
                                                                       disregard for palm oil’s impact on communities.124
                                                                       Landowners and settlers there told the PNG National
                                                                       Court they had not known about nor agreed to a 99 -
                                                                       year agricultural lease granted over their land for oil
                                                                       palm development.125 A local government official who
                                                                       objected to the project said he was “severely assaulted”
                                                                       by supporters of the project in retaliation.126 The land had
                                                                       previously been included in a US$50 million World Bank
                                                                       project to improve the livelihoods of smallholder coffee
                                                                       and cacao growers.127 128

                                                                       Global Witness has now seen unpublished documents
                                                                       indicating that 120 households that benefited from this
                                                                       scheme were forcibly evicted, with their homes, gardens,
                                                                       and equipment destroyed.129 In 2017, a Global Witness
                                                                       team visited the area and interviewed some of those
Land cleared for oil palm plantations in the Bainings region of East   landowners objecting to the project, who alleged an
New Britain Province, Papua New Guinea. © Global Witness               entire village had been evicted, leaving people internally

                                                                                                      THE TRUE PRICE OF PALM OIL 19
Page 19 screenshot
displaced. Hundreds of families not supported by World          in place strategies to help prevent similar issues from
Bank funds were also allegedly evicted, while dozens            occurring again.”
more families were affected by ENB’s activities, with their
                                                                ENB wrote: “Squatters can be evicted from State
water sources or gardens damaged. At an average family
                                                                Land if they are residing there without the authority or
size of six, this would mean ENB’s actions affected the
                                                                the permission of the registered Lease holder.
lives of well over one thousand people.

In August 2016, the judge found for the plaintiffs, ruling      “This is not unusual and both the District Court and
that land was “hijacked from appropriate land owners”           National Court can issue eviction Orders [sic] where
in breach of the Land Act and the Constitution.130              squatters refuse to move.
Nevertheless, during the trial, in December 2015, ENB
                                                                “Their only ‘right’ is the right to receive reasonable notice
had already awarded a contract to build the group’s
                                                                to vacate. To our knowledge, ENBRG has not participated
Narangit palm oil mill in Gazelle District.131 This mill is

                                                                in any forceful evictions as claimed by you.”
now producing palm oil sold around the world, while the
families who lost their land have reportedly received           “All labourers of the previous cocoa and copra plantation
no compensation.                                                and persons living near the plantation have been given
                                                                employment opportunities to work at the oil palm
The case had been in progress since 2012, three years
                                                                estates,” the company also said.
before the Maybank deal with ENB.133 Proper due
diligence by the bank on this case alone should have            As we shall see, this litany of offences has not barred the
precluded it from lending to the group. The terms of its        ENB Group’s palm oil from making its way into a global
financing required ENBPOL to check and ascertain that           array of goods, made by companies such as Colgate-
no pending litigation against it might have a “material         Palmolive and Nestlé, whose products you likely have at
adverse effect” against the company’s operations.134            home right now. But ENB is not the only malevolent actor
Global Witness asked both parties if ENBPOL disclosed           in PNG’s palm oil industry. Global Witness can also reveal
the lawsuit to Maybank, but did not receive a reply.            that the activities of a far more influential company are
                                                                resulting in an ongoing and avoidable human tragedy.
Reached for comment, the World Bank said it had raised
concerns with the PNG government when land incursions
impacting farmers in its project area were reported in
2015. It said 95 cocoa blocks were destroyed, and the              Special Agriculture and Business
bank had communicated this to the government, which                Leases: a toxic legacy
issued a stop work notice to ENB.

“Although the Productive Partnerships in Agriculture               ENB, RH (Rimbunan Hijau Group) and Bewani
Project closed in May 2021, we remain concerned by the             (Bewani Oil Palm Plantations Ltd) all obtained
land incursions in East New Britain,” the bank said. “In           access to land through Special Agriculture and
preparing further PNG agriculture sector projects, the             Business Leases (SABLs).135 This now-infamous
World Bank supported the Government of PNG to put                  system allowed the control of over 50,000 km2
                                                                   of PNG land to be wrested from Indigenous
                                                                   communities and transferred to foreign
                                                                   companies.136 137 138 The PNG Forest Authority issued
                                                                   forest clearance authorities (FCAs) alongside
The Productive Partnerships in Agriculture Project supported       SABLs, allowing companies to flatten rainforests
smallholder coffee and cocoa farmers across Papua New Guinea.
© Global Witness                                                   and export timber worth hundreds of millions of
                                                                   dollars.139 In 2013, a government commission

                                                                   into these leases found the vast majority of SABLs
                                                                   that it published findings for violated PNG law -
                                                                   typically by ignoring communities’ constitutional
                                                                   land rights.141 Yet, for reasons that have never
                                                                   been made public, many leases the commission
                                                                   reviewed were not included in its final report,
                                                                   including all of those in East New Britain Province –
                                                                   which included the ENB Group and RH leases.142

Page 20 screenshot
    RIMBUNAN HIJAU                                                                                     Total forest destroyed, 2011-2019:
                                                                                                                                24,600 ha


Rimbunan Hijau’s deforestation is starkly visible in this satellite imagery mosaic from 2019.

Rimbunan Hijau Group (RH) - the name means ‘Forever                                  Rimbunan Hijau did not respond to Global Witness’s
Green’ - is a sprawling global business empire with                                  repeated requests for its comment for this report,
interests in forestry, palm oil, plastics manufacturing,                             including a request hand-delivered to its headquarters in
mining and the media.143 144 145 Its founder, Malaysian
                                                                                     Papua New Guinea.
businessman Tiong Hiew King, is listed on Forbes’ Richest
                                                                                     RH subsidiary Gilford Ltd acquired FCAs for three leased
50 List for Malaysia, with an estimated net worth, in
                                                                                     areas in the Pomio District of East New Britain Province
2021, of US$1.3 billion.146 In Papua New Guinea, RH

                                                                                     in 2010.154 Since then, the company has devastated the
owns one of PNG’s airlines, The National newspaper, and
                                                                                     coastal rainforest where it operates, clear-cutting tens of
a plush hotel in the capital Port Moresby. It is logging
                                                                                     thousands of hectares that local communities had relied
several areas throughout the country and operates palm
                                                                                     upon for sustenance. In 2017, Global Witness revealed RH
oil plantations in Pomio, East New Britain Province.148 149
                                                                                     had cleared almost 210 km2 of rainforest and exported
150 151 The logging and plantation projects have been the
                                                                                     about 1.2 million cubic meters of timber—worth about
source of protests for many years from communities who
                                                                                     US$122m—from its leased areas in East New Britain
say RH has exploited them and their forests.152 Global         153

                                                                                     Province.155 We calculate that a further 30 km2 has now
Witness has previously reported community landowners’
allegations that its access to Pomio land was obtained                               been cleared and another 100,000 cubic meters of timber
through fraud and forgery. RH denied these claims.                                   shipped out (see Appendix 2). Communities in the Pomio

i     In its 2005 report The Untouchables, Greenpeace described Rimbunan Hijau as “a conglomeration of many hundreds of companies . . . all owned and
controlled by the Tiong family but which sometimes have no other official connection.” We consider this definition accurate a nd apply it here. For instance,
although Gilford Ltd is described as a subsidiary of Rimbunan Hijau (PNG) in this article by the RH-owned newspaper The National, in company filings its owner is
listed as the Malaysian Prime Resources Corporation Limited. This latter company does not appear in the database of the Companies Commission of Malaysia.

                                                                                                                                THE TRUE PRICE OF PALM OIL 21
Page 21 screenshot
      district of East New Britain Province have calculated that           vehicle accidents on the plantation, where heavy trucks
      over the lifetime of the leases, they will suffer more than          laden with fruit bunches or logs share the rough tracks
      US$730 million in damages due to this destruction.156                constructed by RH with pickup trucks, motorbikes, and
      This calculation, made by 17 communities, includes                   workers on foot. Global Witness believes it is the first
      among other items the loss of timber exported by RH, lost            organisation to publish these findings.
      subsistence agriculture and market income, and the
      near-                                                                Papua New Guinean health and safety consultancy
      total destruction of the environmental goods and services            Niugini Environment Management Services (NgEMS)
      provided by the forest.157                                           reviewed the findings for Global Witness. Principal
                                                                           Tony Aromo has over a decade’s experience in the palm
      Global Witness can now reveal new evidence of serious                oil sector in PNG and served as a technical expert on
      human rights abuses and negligence by RH on its oil                  the working group developing nationally appropriate
      palm plantations. These have led to a spate of serious               standards for RSPO.160 Some readers may find the
      injuries - some life-changing - and tragic and preventable           following examples upsetting.
      workplace deaths. It is a human cost to RH’s wealth
      and influence that should appal potential investors and
      business customers.                                                  Father-and-son tragedy
                                                                           On the night of November 28th, 2014, Leo Kaukau, a
      Permanent injuries                                                   forklift operator at an RH subsidiary, cooked dinner
                                                                           for himself and his 11-year-old son Ronald using water
      A 2019 study found that the over one million oil palm                from a container that had held chemicals used for killing
      plantation workers globally are at risk of suffering from            grass in the plantation.161 162 163 Paraquat and glyphosate,
      bone and muscle injuries, chemical exposure, infectious              herbicides used by the oil palm industry in PNG, are both
      diseases including malaria, and depression and anxiety.158           toxic to humans.164 165 166 Just one sip of paraquat can kill,
      Workers, especially women and girls, are also subject to             producing vomiting and kidney and respiratory failure.167
      sexual assaults and violence.159 By any measure, palm                Felix Tau, Leo’s brother, said the father and son began
      oil labour is stressful and often dangerous work. It is              vomiting within ten minutes into their dinner. Leo Kaukau
      therefore especially important for plantations to maintain           died on the way to a health clinic the next morning,
      robust safety standards.                                             while his son died shortly thereafter. No autopsy was
      Global Witness began investigating worker safety on the              performed, nor inquest held.168
      RH plantations in East New Britain after being tipped off            PNG’s Employment Act provides penalties for employers
      by two former employees that a catalogue of preventable              who fail to provide their housed workers with safe
      deaths and serious injuries were taking place.                       drinking water.169 To avoid such deaths, hazardous
                                                                           chemical waste must also be properly disposed of. In
                                                                           its review of the evidence for Global Witness, NgEMS
                                                                           said that under guidelines established by the Food and
     Pomio communities depend on their forests for their livelihoods and
     traditional ways of living. © Global Witness
     “It’s very bad,” one employee said. “[Workers] live in a
     house with no lighting, no water. Compliance? Zero.”

     Asked what safety equipment the company provided, he
     said: “They give them boots but then deduct it back from
     their pay.

     “If you ask for it, you get it, but you have to pay for it.”

     At least 12 people died on the RH plantations between
     2012 and 2020. Eleven of these were RH employees, and
     one was an employee’s school-aged dependent. Over the
     same time span, a dozen more were involved in serious
     accidents, some life-altering. (See Appendix 2 for an
     explanation of our research methods. A full list of the
     deaths and injuries Global Witness has catalogued is in
     Appendix 1.) The deceased workers died from blunt-force
     injuries, falls or unknown and un-investigated causes.
     Many of the deaths and accidents stemmed from motor

Page 22 screenshot
                                                                 Amputations, chemical accidents
Logs harvested from Papua New Guinean forests can measure many
meters long. © Global Witness                                    Global Witness compared these tragedies with the safety
                                                                 record of two comparably-sized plantations operated by a
Agriculture Organization of the United Nations (FAO),            different company in Papua New Guinea. In stark contrast
used pesticide containers should have been triple-               to the lack of public reporting of incidents at Rimbunan
washed and then made unusable, to prevent exactly                Hijau operations, accidents at New Britain Palm Oil Ltd
such a tragedy from occurring.170 The victims’ family has

                                                                 (NBPOL), one of the RSPO-certified palm oil companies
reportedly received no compensation for their deaths.172         operating in PNG, are publicly reported. Company reports
Another fatality occurred on November 11, 2020. Father           show that between 2010 and 2020, one worker died at the
of four Anton Kelal, who had worked for RH subsidiary            company’s Higaturu plantation, and three died at its Milne
Sinar Tiasa since 2011, was a passenger in a dump truck          Bay plantation. Both of these sites employ roughly the
on the plantation.173 Five witnesses saw the truck speed         same number of workers as RH’s Pomio operation. (For
up and Mr Kelal fall from the cab, hitting his head and          more details, see Appendix 2). This suggests health and
dying instantly. His brother, Lawrence Lapuli, was among         safety measures can be put in place to improve conditions
the witnesses.174 Mr Kelal’s death certificate indicates         on the RH plantation, which the company has failed to do.
his brain was contused and both his lungs collapsed.175          Workers’ injuries on the RH plantations include amputated
According to his brother, RH provided PGK5,000                   fingers, broken bones, and the impacts of chemical
(about £1,000) for burial costs, but has not otherwise           exposures and vehicle accidents. Almost without
compensated Mr Kelal’s family. His children are being            exception, accident survivors also seem to have gone
taken care of by extended family members.176                     financially uncompensated.
Noting that there was evidently no motor vehicle accident        Truck driver Charles Sai was 22 years old on 1 March 2013,
report done, NgEMS’ review of this case recommended              when a log slipped from a pile and hit him on the neck.
a police investigation into the accident. Reckless driving       177 178 The logs loaded onto ships for export from PNG can
may be a violation of the PNG Road Traffic Act.                  measure over a meter in diameter and fifteen meters in
“Allowing employees to drive negligently without due             length. This one caused ligament damage and fractured
care and attention for other and company property                three vertebrae, including the C6 vertebra: a severe
show[s] a total lack of duty of care”, NgEMS wrote.              injury that risks paralysis and nerve injury.179 A medical
“The ultimate responsibility and accountability [for]            assessment concluded the use of Mr Sai’s back had been
employees’ negligence lies with the top management               reduced by 80%.
of the organisation.”
                                                                 Records seen by Global Witness indicate he received no
                                                                 recompense – and even had to pay PGK250 (about £50)
                                                                 for a copy of his own workers’ compensation report. Mr Sai
                                                                 said he had to pay for his own medical expenses as well,
                                                                 adding that he felt used by the company.

                                                                 In its assessment of this case, NgEMS noted that East New
                                                                 Britain is a highly seismically active area, with frequent
                                                                 small earthquakes. Stockpiles of logs must therefore never
                                                                 be raised too high and must be appropriately barricaded
                                                                 and signposted for the safety of workers and passersby.
                                                                 According to NgEMS, there is no indication that such
                                                                 simple precautions were taken. If they had, Mr Sai would
                                                                 almost certainly never have been injured, NgEMS said.

                                                                 Unreported tragedies
                                                                 Only seven of the twelve deaths Global Witness
                                                                 documented seemed to be recorded in the governmental
                                                                 Office of Workers Compensation (OWC) database when
                                                                 this report was written. And only seven of the twelve
                                                                 serious injuries Global Witness documented appeared.
                                                                 Employers who fail to give notice of employees’ injuries

                                                                                               THE TRUE PRICE OF PALM OIL 23
Page 23 screenshot
or deaths are guilty of an offence under the PNG Workers’          Mr Salmang said, they were held tightly packed for five to
Compensation Act.180                                               six hours, through the height of the tropical sun - without
                                                                   water or access to toilet facilities..

An official at the East New Britain Provincial Health
Authority declined to discuss the incidents on the phone,          “We were crushed inside,” he recalled. “There was no
saying they “might get into trouble”.                              room for us to sit. You could not move. It was inhuman.”

RH did not respond to Global Witness’s request for                 Elderly men were among those allegedly locked up, not
comment. It did not even issue a statement of regret               accused of any offence at that point: the incident could
for the loss of life on its plantations, nor sympathy for          easily have been fatal.
the bereaved families or those who have suffered life-
changing injuries.                                                 Mr Salmang’s account has been by corroborated by
                                                                   Sarawak Report, which interviewed another of the sixty-
In addition to accidental death and injury on its                  five men held in a 2020 video report.186
plantations, RH is also linked to a particularly shocking
case of human rights abuses.                                       Although most were then released, nine remained in
                                                                   the container overnight, Mr Salmang recalled. The next
                                                                   day, they were brought by boat to Kokopo, many hours’
inhuman’ treatment                                                 voyage from their homes. There, they were finally arrested
                                                                   on charges of interfering with police duties and jailed for
In October 2019, Global Witness met Anthony
                                                                   two nights in a holding cell with between 60 to 70 men,
Salmang, a Pomio landowner who described the impact                he said.187
the RH operations have had on his community.
                                                                   RH made no comment on this incident.
“We always get fresh fish from the water,” he said. “In the
bush, we hunt for animals like wild pigs. They are
precious in our life. We live by the nature.”                      Police terror
But this way of life has been obliterated by the company’s         Accusations that RH uses the police to intimidate and
activities.                                                        violently attack communities objecting to their activities
                                                                   date back years. In 2012, Mongabay reported RH-funded
“Now [the water] is full of chemical activities, fertilizer that   police “terrorized” communities in the Pomio area now
flows down the river, and all the corals are killed,” he said.     developed for palm oil, beating people with sticks and
“It really changed our life. We lost most of our traditional       fan belts and locking people in shipping containers
livelihoods, like sacred sites.”                                   for up to three nights.188 These allegations from Pomio
                                                                   communities of police violence led to an independent
He added: “Empty, I can use that term, empty, because all
                                                                   fact-finding mission in 2013 organized by civil society and
those things are gone. We cannot bring them back.”181
                                                                   including members of the police and local government
                                                                   employees.189 This found that police hired by RH
Allegations of RH’s ruinous impact on communities’
                                                                   subsidiary Gilford had forced landowners to sign logging
environments are nothing new. Local government official
and outspoken Pomio landowner Paul Palosualrea Pavol,              consent forms under fear of death, and beat others with
                                                                   gun butts and tree branches. The report concluded
who won the Alexander Soros Award for his environmental
activism in 2016, also told Global Witness the company’s           these “acts of assault did amount to serious indictable
forest destruction has driven away wild animals.182                criminal offences”.190 Previously, RH told Global Witness
183 He said: “The concern is that our children do not              that a March 2017 police investigation found no evidence
know hunting skills and most of them don’t know what               of malpractice at the sites and that local community
cassowary looks like and how a wild pig reacts against             members had “requested a larger police presence to
a hunter.                                                          maintain order as the area experienced strong
                                                                   economic growth”.
Pavol said water in the area was “polluted” and fish had
                                                                   Multiple PNG Police Commissioners have forbidden
been caught that tasted of “oil and fuel”.184
                                                                   officers to be stationed in logging camps across the
But when Mr Salmang and other landowners tried to                  country.191 The fact that these edicts have been repeatedly
photograph RH’s environmental devastation, armed                   issued points to their ineffectiveness. In September 2020,
police swooped. They allegedly forced him and sixty-four           the then-Minister for Police, Bryan Kramer, released
other people from villages in the Pomio area affected by           a statement condemning the lack of integrity of
RH’s activities into a single metal shipping container that        the Constabulary.
doubled as a holding cell at the plantation camp. There,

Page 24 screenshot
                                                                 vehicle businesses flourish. Families are now able to bring
                                                                 produce to market. Students can get to school more easily,
Women waiting for transportation in East New Britain Province,
Papua New Guinea. © Global Witness                               and people seeking medical services can reach them
                                                                 without life-threatening delays.”

“The very organization that was tasked with fighting             RH said it had dedicated “significant funds” to a
corruption had become the leading agency in acts of              PNG malaria eradication initiative and had signed
corruption,” he wrote, describing “a rampant culture of          an agreement with the East New Britain provincial
police ill-discipline and brutality.”192                         administration to support local aid posts.

Global Witness repeatedly contacted the Royal PNG                The company called Global Witness “a group of economic
Constabulary for its comment on this report, but the             vandals who do not care about the lives they destroy”.
police force did not comment.                                    It claimed that the specific allegations presented in this
                                                                 report were presented out of context and “without any
These findings show that RH has committed grave human            real basis”.
rights abuses and neglected the health and safety of its
workers, leading to deaths and life-altering injuries.           RH said it abided by all relevant laws and regulations,
                                                                 recognized the socio-economic needs of forest
RH did not respond directly to Global Witness, but it            communities, and took environmental obligations
did send a response to one of its customers, the Mewah           seriously.
Group, regarding our allegations. The company said: “The
                                                                 Consumers may be shocked to learn products they are
Sigite Mukus Integrated Rural Development Project has
the full approval of Government and has been operating           consuming – from brands such as Kellogg’s and Danone –
since 2011.”                                                     are linked to the abuses this investigation has uncovered.
                                                                 But as we will see below, tracing the palm oil stream leads
“Since project commencement, it already transformed [sic         directly from RH’s dangerous and repressive operations to
throughout] the lives of thousands of families in East New       huge commodity traders and a multinational consumer
Britain. More than 4,000 people are directly employed by         goods company that claims to have its brands in more
the project. Millions in royalties and development levies        homes than any other company worldwide.193
has been paid directly to landowner communities.”

It said the project had constructed “hundreds of kilometres
                                                                    Unequal burdens
of new roads” and new and rehabilitated airstrips.
                                                                    The impact of harmful palm oil companies is not
“National business entrepreneurs have been able                     felt uniformly – women feel the burden most.
to capitalise on the increased economic activity and                Land in East New Britain Province is inherited
improved infrastructure to open their own businesses.               through matrilineal custom, from mother to
We have seen new trade stores and public transport                  daughter.194 Despite this, women have increasingly
                                                                    been excluded from decision-making over their
                                                                    own land as logging and palm oil development
                                                                    have encroached on the province.195 The loss of the
                                                                    forest itself has brought additional tribulations.
                                                                    PNG women typically do the lion’s share of
                                                                    gardening and produce most of the country’s crops,
                                                                    while also taking care of children and the family.196
                                                                    197 Access to clean drinking water is very poor, and

                                                                    women and girls in rural communities are often
                                                                    tasked with collecting water from springs and other
                                                                    waterways.198 The destruction of forests, where

                                                                    women manage their gardens and which provide
                                                                    clean freshwater, makes these already challenging
                                                                    tasks significantly harder.

                                                                                                THE TRUE PRICE OF PALM OIL 25
Page 25 screenshot
     Rimbunan Hijau has cleared approximately 240 km 2 of rainforest for its palm oil operations in Pomio, East New Britain Province. © Global Witness

      Following the money                                                      Contacted by Global Witness, OCBC Bank said that banking
      Much of this destruction might have been prevented if RH                 regulations prevented it from discussing individual
      did not have access to big finance. Global Witness has now               clients. “However,” it wrote, “we require our borrowers to
      uncovered documents showing RH companies secured a                       have safeguard[s] against deforestation and to take into
      loan for up to US$300 million from a consortium of major                 consideration social issues such as child/forced labour,
      Malaysian banks in 2012.200 A document filed with the
      Investment Promotion Authority names a consortium of
      banks including Maybank, Singapore’s Oversea-Chinese
      Banking Corporation (OCBC Bank), and Malaysia’s RHB
      Bank Berhad (RHB) entities as being behind the deal.
      The financing was provided to RH’s subsidiary Gilford,
      which holds the clearance authorities for the plantation
      areas. The deal was struck as clear-felling there
      began to accelerate.201

      Maybank’s lending to the palm oil industry is well-
      established (see its response to Global Witness in
      ‘International Financing’ In 2015, Maybank (PNG) Ltd,

      one of the banks in the $300m deal, was acquired by
      Kina Bank, an arm of Kina Securities Ltd. 202 The bank,
      whose red, white, and orange logo is a familiar sight in
      PNG’s capital, is listed on both the national and Australian
      stock exchanges.203

      Kina Bank said that it had no financing arrangements
      with RH. It said the Asian Development Bank, as a major
      shareholder, had conducted a detailed ESG audit of all
      the issues Global Witness had raised with Kina, “to ensure
     the business complied with the highest standards in
     this regard”.

     Asked whether the 2012 agreement with RH had matured
     before or after Kina’s acquisition of Maybank (PNG) Ltd,
     Kina did not respond.

     Singapore’s Oversea-Chinese Banking Corporation,
     Ltd is the second-largest financial services group, by
     assets, in Southeast Asia.204 The bank says it “will not
     engage in or knowingly finance any activity where
     there is clear evidence of immitigable adverse impact
     to the environment, people or communities”.205 It
     requires borrowers to have their own policies against
     deforestation.206 The bank’s Environmental, Social and
     Governance (ESG) risk assessment process, implemented
     in 2017, requires it to check their customers’ management
     of ESG risks like deforestation and occupational safety at
     least annually.207 RH’s actions in PNG should have been

     scrutinized several times over by the time this report was
     written. That OCBC should finance RH illustrates perfectly
     why internal policies are not sufficient to prevent financing
     of the kind of abuses detailed in this investigation.

Page 26 screenshot
occupational health and safety as well as any                  Global Witness has also discovered an entry in Papua
resettlement of affected communities in our assessment.”       New Guinea’s national collateral registry indicating
                                                               BSP Financial Group Limited (BSP Financial, previously
The bank did not say whether it had checked RH’s
                                                               Bank of South Pacific Limited) provided a 30-year loan
management of environmental and social risks, as
                                                               to Gilford in 2018.219 The publicly available information
required under its policy.                                     does not specify the loan amount, but as collateral,
“We are committed to this sustainability journey,” it added.   Gilford listed all its current and future property. 220
                                                               Major shareholders of BSP Financial include the PNG
A third funder, RHB Bank, controls dozens of commercial        Sustainable Development Program Ltd (“PNGSDP”) and
and investment banking entities throughout Southeast           the International Finance Corporation, whose mandate
Asia. This includes two banks in the consortium that           is to improve people’s lives “by encouraging the
provided the loan to RH’s subsidiary Gilford.209 It did        growth of the private sector in developing countries”. 221
not formalise a policy framework requiring social and
environmental sustainability of its customers’ operations      its part, SDP’s self-described goal is to provide “lasting
until 2019.210 This framework states it is “integrating        benefits for the people of Papua New Guinea”.223 Once
ESG factors and risks” into its business and seeking to        again, given the litany of harms and unethical practices
minimise “negative impacts to the environment and              discussed earlier, this is a deal that should never have
society”.211 The bank’s involvement with the loan makes a      been made.
mockery of this commitment.
                                                               BSP Financial did not respond to repeated requests
RHB did not deny having financed RH. The bank said:            for comment.
“At RHB, we formally embarked on our sustainability
                                                               PNGSDP said that its mandate to deliver development
journey in the fourth quarter of 2018 and institutionalized
                                                               initiatives for the people of PNG involved investing its
it in 2019. Since then, we continue to take a practical
                                                               Long Term Fund to generate attractive returns. It added,
approach and have progressively embed [ESG] practices
                                                               “Our investment in BSP represents a very small part of our
or considerations into our business and operations as part
                                                               overall investment portfolio” and said that it was a passive
of our overall sustainability journey.”
                                                               investor in BSP with no knowledge of or influence over the
                                                               bank’s lending.
The bank said that under its ESG Risk Assessment tool
for the palm oil sector, customers with a plantation size
                                                               PNGSDP said that it was in the process of reducing its
of over 100 acres were required to obtain sustainability
                                                               exposure to BSP. “This orderly process is in keeping with
certification, abide by the Malaysian Palm Oil Board’s
                                                               our investment strategy and the decision was made for
(MPOB) codes of good practices, and “avoid virgin forest,
                                                               completely unrelated, commercial considerations,” it said.
aboriginal or heritage land”.
                                                               The International Finance Corporation said: “IFC has no
Yet as with ENB’s financing, the money trail does not only
                                                               knowledge of the specific allegations of abuse raised by
originate in Malaysia - for these banks count among their
                                                               Global Witness and condemns any acts of violence against
major shareholders some of the biggest names in global
                                                               individuals and communities.”
finance. These include many of the same investors as
Maybank’s, such as BlackRock, Norges Bank Investment           The corporation said it had not been made aware of any
Management (NBIM), and the Vanguard Group.212 Many             BSP exposure to Gilford.
of these financiers’ names appear repeatedly behind the
flows of money enabling the wholesale destruction of           A spokesperson said: “IFC takes any environmental and
tropical forests, despite their own investment guidelines      social concerns relating to [its] Performance Standards
acknowledging climate risk.213 214 215 216 217 NBIM’s 2019     very seriously.”
annual report said it “urged [banks] to strengthen their
due diligence and to report on climate and deforestation       They added that the IFC and IFC Asset Management
risks”.218 Yet actions speak louder than words; it has not     Company each held less than 1% of BSP’s shares, and the
divested from the likes of Maybank, which continually          IFC had been reducing its shareholding over several years.
finance deforestation.                                         The corporation said it had supported BSP to strengthen
                                                               its environment and social risk management practice
Despite their massive influence and power - BlackRock          through a programme beginning in 2018.
is the world’s largest asset manager and NBIM manages
the world’s largest sovereign wealth fund - these financiers   By investing in banks that directly financed RH’s
did not acknowledge responsibility for the abuses they         operations in PNG, these financiers are partly
had enabled. See p. 18 for these financiers’ responses.        responsible for the abuses carried out by the company.

                                                                                              THE TRUE PRICE OF PALM OIL 27
Page 27 screenshot
     BEWANI OIL PALM                                                                    Total forest destroyed, 2011-2019:
                                                                                                                  30,600 ha


Satellite imagery from 2019 reveals extensive forest clearance in the Bewani project area.

A short drive from Indonesian-controlled Papua, the                      ‘Lost everything’
port of Vanimo in north-west PNG’s West Sepik
Province, has the grit and dust of an industrial border                  A recent BBC documentary about the Bewani plantation
town. At night, cigarette, alcohol, and gun-runners’ boats               uncovered children there working barefoot amid
leave the harbour, destined for the other side of the                    dangerous working conditions.
border.224 The small port is stacked high with logs from

                                                                         According to one villager in the documentary: “We used
inland forests, most destined for China.226 The province
has seen astronomical logging rates over recent years,                   to live by the forest, the forest was our source of food.
with millions of cubic meters of timber exported. 227 228
                                                                         “Now the company came, we lost everything.”
It has come in part from the area operated by Bewani
Oil Palm Plantations Ltd (“Bewani”), which operates a                    When Global Witness previously visited in 2016, to
139,909 ha concession south of Vanimo.229 Bewani was                     reveal widespread community opposition to Bewani’s
registered in PNG in 2010 by a member of the prominent                   lease—which the company contested—investigators
and controversial Malaysian Tee dynasty.230 231 232 The                  saw just one timber ship anchored in Vanimo’s harbour.
family’s other business interests span industries from                   By 2019, the bay was full of vessels. A stream of logging
Malaysian palm oil to phosphate mining on Australia’s                    trucks rolled down the main road, hundreds of logs from
Christmas Island.233 234 235 236
                                                                         the province’s felling operations stacked in piles ready for
                                                                         export. Assuming Global Witness’s team were tourists—
                                                                         Vanimo is also a surfing hotspot—residents approached
                                                                         our investigators unprompted to describe the impact. 237
                                                                         They spoke candidly about the loss of their forests and
                                                                         resources, and how this had not led to any improvement

Page 28 screenshot
in their standard of living. Health centres meant to serve
entire districts were said to have no staff, nor even basic
                                                              Vanimo was crowded with logging trucks when Global Witness
medicines. (In 2018, the New York Times described a           researchers visited in 2019. © Global Witness
“public health emergency” in PNG, driven in part by
widespread corruption and a collapsing medical supply         Will the real owners please
chain that had left shelves bare of essential drugs and
driven many rural clinics to closing.238)                     stand up?
Global Witness’s deforestation analysis indicates that        Against the backdrop of Bewani’s growing infamy, in
over 30,000 ha has been cleared in the area since Bewani      2019 the Tee family claimed to have washed their
began its operations, destroying ecosystems once integral     hands of the plantation.240 The Prosper Group, a
to the lives of local communities.239                         conglomerate
In its response to Global Witness, Bewani said:               including palm oil mills in which the Tees have controlling
“The allegations in your letter are factually and legally     stakes, had come under pressure from some of its
incorrect, clearly defamatory and do not represent the        biggest palm oil customers to cut ties with Bewani.241
                                                              242 243 Prosper’s clients, according to Chain Reaction
position of the overwhelming majority of the landowners
who not only own the title to the SABL in question,           Research, included giant traders and corporations
but who support the oil palm development on the               including Cargill, Mewah, AAK, Wilmar International,
land concerned.”                                              IOI, and Unilever. These in turn supply massive fast food
                                                              outlets, supermarkets, and household brands, reportedly
“All land clearing activities undertaken since 2010 were      including McDonalds and Walmart.244 Some of these
conducted in strict supervision and compliance with           traders received grievance reports following revelations
all regulatory requirements imposed by both the PNG           by Greenpeace and Chain Reaction Research of
Forest Authority and the Conservation and Environment         deforestation carried out by Bewani.245 In what appeared
Protection Authority”, Bewani said.                           to be an effort to maintain Prosper’s trading contracts
It added that the only complaints from the government         with international brands, the Tee family divested from
of Papua New Guinea concerning environmental                  Bewani’s sole shareholder, the Malaysian company PNG
issues in its operations were minor and “were rectified       Plantations Development Sdn Bhd.246 The Prosper Group
in                                                            was then welcomed back into lucrative palm oil supply
no time”.                                                     chains, able to once more sell to powerful trading
“Approximately 16,700 hectares of oil palm fruit [sic]
have been planted to date of which majority portion of        Regarding the Tees’ divestment from Bewani, Prosper
planted land is already bearing fruit and landowners          admitted to Global Witness: “The divestment warded
are enjoying profit sharing as well as employment and         off the risk of trade suspensions that were already being
business spin-off opportunities that marks significant        imposed on Prosper.”
improvements to their livelihoods”, the company wrote.
“We have significantly expanded the road network in the       It added: “The Tee family no longer has commercial
project area”.                                                interest in the PNG plantation and its mill, but this does

Bewani said it had not cleared any forest since 2019. It
claimed there had been “rogue and unauthorized logging
operators operating within SABL Portion 160C [the                                               THE TRUE PRICE OF PALM OIL 29
Bewani project area]” that had been dealt with in court.

Despite admitting to not having seen the 2019 BBC
documentary due to it being unavailable in PNG,
Bewani called it “unbalanced and partial”.

The company said it had a strict policy restricting child
labour. “If there are children entering the plantations,
it is not something that BOPPL allows or endorses,”
the statement continued.
Page 29 screenshot
                                                                              Global Witness has also discovered Malaysian corporate
                                                                              records for what appears to be a closely related company,
      Palm oil from the Bewani plantation has been exported to India, South
                                                                              Ocean Paradise Sdn Bhd. Registered in July 2012, just one
      Korea, and Singapore. © Global Witness
                                                                              month before Ocean Paradise Ltd was registered in Papua
      not necessarily diminish their sense of responsibility for              New Guinea, the apparent Malaysian incarnation of the
      the development.                                                        company is owned by four individuals. These include
                                                                              Tee Kim Tee, who owns 40% equity, alongside its largest
      “It is for this very reason the family keeps an open-door               individual shareholder in PNG, Kong Fatt Yap, who holds
      approach to the new owners.”                                            30% equity in both the PNG and Malaysian companies.257

      “Given the absence of coordination with the current                     The apparent continued involvement of dynasty kingpin
      owners of the Bewani plantation project, it is not realistic            Tee Kim Tee in what appears to be a Malaysian sister
      for the Tee family to effectively compensate deforestation              company of Ocean Paradise Ltd, and of the Tees’ long-
      in Bewani.”                                                             term associate Kong Fatt Yap in both the PNG and
                                                                              Malaysian firms, strongly suggests coordination between
      Bewani pointed to a peatland rehabilitation project it had
                                                                              the Tee family and Top Leap. This raises further suspicion
      instead launched in Malaysia.
                                                                              that despite the divestment, the Tees continue to work
      It said Prosper had adopted its own sustainable palm oil                closely with the new Bewani directors and their business
      policy which was “up to par with many international palm                partners at Top Leap Holdings. As a company registered
      oil traders’ procurement policies”.                                     in a secrecy jurisdiction, the ultimate owners of Top Leap
                                                                              Holding remain a mystery.
      But evidence uncovered by Global Witness shows the Tee
      dynasty continues to hold shares in a company operating                 Reached for comment, a Tee family spokesperson
      in the Bewani plantation. Global Witness can also reveal                said: “None of the [Tee] family members or their legal
      previously undisclosed business ties between Tee family                 representatives own shares or has directorship in Top
      members and two of the plantation’s new directors.                      Leap Holdings and their related core business.

                                                                                “It is true that there are some corporate entities where
      The great switcheroo                                                      ownership restructuring has not yet been wrapped up.

      The divestment took place in early 2019. According to                   “This is the result of considerations other than those
      Malaysian corporate registry documents revealed by                      implied in your letter, namely as if the Tee family and Top
      Chain Reaction Research, on 1 February that year an                     Leap Holdings would maintain an ongoing but concealed
      anonymous company, Top Leap Holdings Ltd—reportedly                     business relationship.”
      registered in the British Virgin Islands—took over
      ownership of PNG Plantations Development Sdn Bhd,                       The spokesperson added: “We understand that you could
      the vehicle that owned Bewani.247 248 249 Just days earlier,            construe things in such [a] manner but in reality, such is
      new directors of Bewani had also been installed. These                  not the case.”
     included Kong Fatt Yap and Eng Seong Goh.250 (Mr Goh
     was previously exposed by analysts at Chain Reaction
     Research as having other long term business ties to
     the Tees.)

     A Global Witness analysis of Papua New Guinean
     corporate records reveals these directors, Mr Yap and
     Mr Goh, are shareholders with Top Leap Holdings in two
     other companies associated with the Bewani plantation:
     Bewani Forest Products and Ocean Paradise Ltd.251 252
         (Bewani says it has “appointed” Bewani Forest
     253 254

     Products to work on its plantation, and Ocean Paradise
     Ltd lists the plantation as its operation location in records
     on file with the PNG government.255) Top Leap and the
     new directors of Bewani became joint shareholders of
     Bewani Forest Products on the same day, 23 January
     2019 - strongly suggesting that they are closely
     coordinating their business activities.256

Page 30 screenshot
Both Bewani and the Tee family/Prosper disputed                          This suggests an ongoing business relationship between a
that there is any relationship between the two                           Tee family-controlled company and Bewani.
“Ocean Paradise” entities. A spokesman for Prosper
acknowledged that Mr Yap, the Bewani director, was a                     The Tee family/Prosper said: “Tago Maritime is a fully
shareholder of Ocean Paradise Sdn Bhd. It said that the                  owned company by the Tee family.
company was currently dormant, adding that Ocean
                                                                         “This company was set up to operate the landing
Paradise Ltd was “fully owned and run by former staff
                                                                         vessel that was required to transport goods to the
who have joined Top Leap since then”.
                                                                         development area.
Bewani said: “Ocean Paradise Sdn Bhd has never been
                                                                         “It still operates at the direction of local marketing and
part of or an entity under the Bewani Oil Palm Project”,                 shipping staff.”
adding, “Ocean Paradise Sdn Bhd has nothing to do with
our Ocean Paradise Ltd in any way whatsoever”. (Mr Yap,                  Mr Goh, the Bewani director, was “just a passive director”
one of Bewani’s directors, is a major shareholder in both                in Prime Horizon Ltd, the family said. “Prime Horizon
companies.)                                                              Ltd was incorporated in 2018 and after the divestment in
                                                                         BOPPL [Bewani], the Tee family has not been able to
It takes two to Tago                                                     find a replacement director since,” it added.

But there are yet more links between the Tee family and                  Prosper disputed Global Witness’s deforestation
Bewani’s new directors Kong Fatt Yap and Eng Seong Goh.                  calculation, saying that it estimated closer to 21,000-
Global Witness has discovered that another company,                      23,000 ha had been cleared between 2011 and 2020.
Prime Horizon Limited, is directed partly by Goh, while                  It said this number did not include degradation due
also being 70%-controlled by a transport company called                  to logging, and again claimed that there had been “a
Tago Maritime Services Ltd (“Tago”).258 Tago is owned by                 number of encroachments by illegal loggers” in the area.
two members of the Tee family.259 It is further evidence
                                                                         Beyond the companies identified by Global Witness, the
that Bewani’s new owners are closely linked to the
                                                                         Tee family maintain they have no other shareholding or
Tee clan.
                                                                         directorships in any other PNG registered companies.
In a PNG corporate registration filing, Tago lists its
                                                                         Global Witness was unable to reach Top Leap Holdings
operating location as the Bewani plantation.260
                                                                         for its comment.

Land cleared for oil palm in the Bewani project area, 2016. © Global Witness

                                                                                                           THE TRUE PRICE OF PALM OIL 31
Page 31 screenshot

Palm oil produced by the companies in this report has been sold to big brands around the world.

Given the litany of offences detailed above, it may be                 with hundreds of members that committed to end
surprising to learn ENB and RH sell palm oil to reputable              deforestation in its supply chains by 2020.269 It has

companies. But Global Witness has discovered their                     failed to do so.271
product in the supply chains of a staggering list of
                                                                       British manufacturer PZ Cussons – which makes Imperial
household-name companies around the world. Brands
                                                                       Leather soap and Carex hand soap - was also supplied by
from Nestlé to Colgate-Palmolive and Hershey admitted
                                                                       the ENB Pomio mill.272 Grupo Bimbo, in 2018 the largest

to having been previously supplied by the ENB and/
                                                                       baking company in the world, was another customer.274 275
or RH mills in PNG.261 This is despite long-time industry
                                                                       Neste Oyj, the world’s largest producer of jet fuels made
pledges to eliminate deforestation-related palm oil from
                                                                       from biodiesel, listed the group’s Pomio mill among its
supply chains, and internal company policies committing
themselves to upholding human rights and avoiding                      suppliers of palm oil byproducts. 276 Other companies
environmental abuses.                                                  recently listing this palm oil in their supply chains include
                                                                       the Mewah Group, which claims that over a billion people
In 2019, both ENB and RH mills began appearing in the                  use its products; the Swedish oils and fats manufacturer
supplier lists of major corporations around the globe.                 oil processor AAK, which claims to sell to more than 100
This was a breach of many of their internal policies or                countries; and the commodity trader Cargill, known
public commitments. Cargill, Colgate-Palmolive, Danone,                as the second-largest privately-owned company in the
Kellogg’s, Nestlé, and Reckitt Benckiser (Reckitt)—the                 United States. Stratas Foods, a joint venture of giant
parent company of Strepsils and Lysol—have all listed                  commodities trader and food processing company ADM
ENB and/or RH mills in PNG among their suppliers.262                   and ACH Food Companies, also listed an ENB mill among
263 264 265 266 267 268 These companies are members of the             its suppliers. 277 278 279 280 281 282 283 284 Mewah, AAK, and Cargill
Consumer Goods Forum (CGF), an industry group                          have also all listed the RH mill among their suppliers.

Page 32 screenshot
Palm oil from some of the worst plantations in the world             For details of these companies’ responses, see Table 1
thus finds its way into a ‘Who’s Who’ list of global food,           on p. 34.
biofuels, toiletries, and medicines producers. This broad
                                                                     Industry wholesale giants Cargill and AAK are among
list of buyers shows tainted palm oil from PNG plantations
                                                                     these mills’ other recent customers. AAK has listed not
where grave human rights and environmental abuses and
                                                                     only ENB’s Pomio mill but its Narangit mill in Gazelle
unethical practices have occurred has been traded and used
                                                                     District, where smallholders were kicked off their land.293
                                                                     These purchases appear to violate the companies’
                                                                     internal policies. AAK is a founding member of the
Sticks in the throat                                                 Roundtable on Sustainable Palm Oil. 294 Its sustainable
                                                                     palm oil policy commits the company to sourcing palm oil
Many of these companies have No Deforestation, No Peat
                                                                     produced without the conversion of “High Conservation
and No Exploitation (NDPE) policies, prohibiting                     Value” or “High Carbon Stock” forests, or where the
deforestation, development on peatland and exploitation              plantation was developed without community consent.295
of Indigenous and local people and workers. Nestlé, which            AAK’s palm oil product customers include some of the
listed ENB as a supplier, once committed to                          largest and most well-known consumer brands in the
using 100% “responsibly-sourced palm oil” by 2020.285 After it       world, reportedly including General Mills, Kraft Heinz,
was accused in 2019 of having sourced palm oil from                  PepsiCo, and Unilever.296
producers linked to forest fires in Indonesia, the
manufacturer promised it would “immediately cease sourcing           Cargill, meanwhile, is one of the world’s largest importers
from any supplier found to be linked to any deforestation            and exporters of palm oil and has been implicated in
activity”.286 Iconic American chocolatier Hershey has also           multiple serious palm oil-related scandals, including
committed to sourcing 100 percent responsibly grown palm oil         widespread destruction of tropical forests and orangutan
and boasts it can trace virtually all the palm oil it uses back to   habitat. 297   2 98
                                                                                           The company’s palm oil policy commits it
its mill of origin.287 Unfortunately, these mills recently           to preventing the clearance of “ecologically and socially
included both mills operated by ENB.288 Reckitt, meanwhile, is       important forests”, to uphold the principle of prior
the manufacturer of staples like Lysol cleaning products and         consent by communities, and to prohibit child labour
Woolite detergent.289 In its response to Global Witness,             by companies in its supply chain.299 Allowing
Reckitt acknowledged that it was connected to ENB via its            ENB palm oil into its supply chain makes a
supply of palm oil derivatives, used in products including           mockery of these commitments.
Lysol.290 The company claims to work “proactively with

our suppliers to eliminate deforestation over time”.292              For details of these companies’ responses, see Table 1
                                                                     on p. 34.

                                                                     ‘Journey of no deforestation’
Papua New Guinea’s forests are critical to global climate.
Credit: Fábio Erdos/Panos                                            Another major player to buy up tainted palm oil from ENB
                                                                     and RH is the Mewah Group, the giant Singapore-based
                                                                     oil processing company. 300 It has purchased crude palm oil
                                    THE TRUE PRICE OF PALM OIL 33
                                                                     from both PNG mills owned by ENB, as well as crude
                                                                     palm kernel oil from ENB’s Liguria mill and RH’s “Mamusi”
                                                                     mill in Pomio. 301 Mewah’s sustainable palm oil policy
                                                                     pledges the company to “continue the journey of no
                                                                     deforestation”, requiring direct suppliers to comply with
                                                                     a sustainable palm oil policy and vowing to take remedial
                                                                     action should violations occur.302 Mewah says it sells its
                                                                     products to customers in over 100 countries.303 One of
                                                                     those is Neste Oyj, the Finnish palm oil refiner that claims
                                                                     to be the world’s largest producer of renewable jet fuel.
                                                                     The ENB Pomio mill was listed explicitly among Neste’s
                                                                     suppliers of PFAD (palm fatty acid derivate, left over from
                                                                     palm oil refining). 304 305

                                                                     For details of these companies’ responses, see Table 1
                                                                     on p. 34.
Page 33 screenshot
Neste claims it sources PFAD only from suppliers                       sourcing or failed to apply them correctly.
with a “proactive approach to avoiding                                 Many have failed to respect human rights as required
deforestation”.306 The company says it requires all its                under international human rights standards applicable
suppliers to be members of the RSPO, and claims that                   to business, and even those in PNG law. They have also
all its suppliers are committed to no-deforestation                    failed to carry out the requisite checks on their supply
policies.307 Its
                                                                       chains to prevent, identify and address and account for
Responsible Sourcing Principles commit it to not sourcing              deforestation. And they have failed to detect any other
from areas where High-Conservation Value forest was                    unethical practices, such as apparent corruption.
converted to cultivation areas, or where FPIC was not
obtained from communities.309 This means the purchase                  It is a stark illustration of why companies cannot
of palm oil residues from ENB plantations blatantly                    continue to be allowed to mark their own homework on
violates its own policy.                                               deforestation and other abuses in their supply chains.
                                                                       Without robust legal requirements accounting for
Colgate-Palmolive listed both the RH Mamusi mill and                   deforestation and human rights abuses in supply chains,
the ENB Liguria mill among its 2020 suppliers.310 Colgate              we will fail to save critical carbon sinks and allow abusive
itself is reportedly the UK’s best-selling toothpaste, while           practices harming people on and around these palm oil
Colgate-Palmolive claims to sell its products in “over                 plantations to continue.
200 countries”.311 312
                                                                       For details of these companies’ responses, see Table 1
These findings prove that industry self-regulation,                    on p. 34.
including for financial actors, does not work. The
companies in this report either lacked policies on ethical

Table 1. Global brands that have sourced from palm oil producers East New Britain Resources Group, Rimbunan Hijau,
and/or Bewani Oil Palm Plantations Ltd in Papua New Guinea, and their responses to Global Witness’s requests for

 Global brand                           Extracts from brands’ responses to Global Witness
                          Palm oil
 AAK                      ENB, RH       “AAK is committed to the sustainable and responsible sourcing and production of palm oil and other
                                        commodities,” the company wrote. “We take reports of such incidents [of social and environmental
                                        harms] very seriously.” AAK acknowledged having sourced palm oil from the Liguria, Narangit,
                                        and Mamusi mills, but said its only connection was via the Mewah Group, which had suspended
                                        purchases pending an investigation into the allegations raised by Global Witness. It said Mewah’s
                                        purchases from all three mills were one-off occasions, and another AAK supplier possibly exposed
                                        to Rimbunan Hijau’s Malaysian mills had initiated an investigation. AAK said it had also engaged a
                                        technical sustainability partner, Earthqualizer, to estimate deforestation at each mill that had taken
                                        place after 31 December 2015.

 Cargill                  ENB, RH       Cargill acknowledged that it was connected to RH and ENB via its indirect supply chain. It said that
                                        it had contacted its direct suppliers as part of its investigation, adding that in accordance with its
                                        palm oil grievance procedure, it would engage with and suspend suppliers where appropriate if they
                                        were found to be not compliant with its human rights and/or palm oil policies. “Cargill is
                                        committed to treating all people in our supply chains with dignity and respect and have written
                                        this formally into our Commitment to Human Rights”, the company wrote. “We are also working to
                                        eliminate deforestation in our supply chains”, adding that its palm oil policy “outlines our commitment
                                        to a transparent, traceable and sustainable palm oil supply chain and aims to deliver palm oil that
                                        is produced in accordance with No Deforestation, No Peat and No Exploitation (NDPE) practices.”

 Colgate-Palmolive        ENB, RH       Colgate-Palmolive confirmed it had supply chain connections to the Liguria and Mamusi mills as of
 Company                                the first half of 2020, but said its mill list to be published in August 2021 would show that this was
                                        no longer the case. It said it had also identified links to RH via two mills in Malaysia. “We will include
                                        ENB and RH groups on our internal grievance log and continue to work with Earthworm Foundation
                                        and our suppliers to investigate the concerns raised and determine appropriate actions,” the
                                        company wrote. “We appreciate you bringing your concerns to our attention.”

Page 34 screenshot
Danone S.A.      ENB       “Danone is committed to the principles of no deforestation, no development on peat, and no
                           exploitation of rights of workers, indigenous peoples and local communities”, the company wrote.
                           “We signed the New York Declaration on Forests and are a member of the Forest Positive Coalition
                           of the Consumer Goods Forum (CGF).” Danone added that it participated in numerous other
                           “alliances that further collaboration and progress toward zero deforestation”, including the RSPO
                           and the Palm Oil Innovation Group. The company said it had stopped sourcing from ENB’s Liguria
                           mill since the beginning of 2020, and that it had asked its supplier(s) to conduct investigations into
                           their supply chains. “We are fully committed to achieve segregated sustainable palm oil,” Danone
                           wrote. “We put in place a traceability system allowing us to map our supply chain, and a formal
                           grievance process, with the support of Earthworm.”

General Mills    ENB, RH   General Mills said that although it was a “relatively minor user” of palm oil that it bought through a
                           complex supply chain, it was committed to sourcing palm oil sustainably and took allegations of
                           deforestation seriously. “Conducting ethical business and respecting human rights are core to our
                           values,” it said. “Through our Global Responsible Sourcing program, we uphold our Supplier Code of
                           Conduct and drive ongoing supplier progress in areas of health and safety, human rights, business
                           integrity and the environment.” General Mills said it had entered Global Witness’s allegations into its
                           grievance process and would engage its suppliers and report on its findings.

Grupo Bimbo      ENB       Grupo Bimbo said that since releasing its global palm oil policy in 2016, it had been working on
S.A.V. de C.V.             improving traceability, engaging with suppliers to implement its policy, investing in two
                           projects in Mexico to halt deforestation and improve smallholders’ livelihoods, and verifying
                           deforestation through satellite analysis. Regarding its exposure to ENB, it said, “[Our suppliers]
                           have already confirmed that the source from those mills has been suspended. We can assure
                           you that at
                           Grupo Bimbo we have the right monitoring mechanisms and rigorous processes to supervise
                           the compliance of our Global Palm Oil Policy and in the case of any violations, we will take the
                           required actions.”
GS Global        Bewani    GS Global said that it had bought palm oil from “ENB Trading Ltd”, which in turn had bought it from
                           Vanimo Green Palm Oil Mill. When asked by Global Witness if it denied having bought palm oil from
                           Bewani, which controls the Vanimo Green mill, the giant corporation said it could not check where
                           ENB Trading had sourced its oil.

Mewah Group      ENB, RH   “Your report is certainly useful for us as well as the entire palm oil industry, as we have not seen
                           another similar grievance case being reported by another NGO,” wrote the Mewah Group. It
                           said it had reached out to ENB and RH to begin an investigation and had filed a formal grievance
                           in Mewah’s sustainability grievance log. Mewah said it put in place a groupwide suspension on
                           all trading with the companies pending the completion of its investigation, and that it had not
                           purchased from ENB or RH since April 2020 and June 2020, respectively. “If any of these
                           allegations is proved genuine,” the company wrote, “we will demand the respective company to
                           undertake necessary recovery plan to compensate for HCS [high carbon stock] forest loss or
                           human rights violation that is identified within its operation.”

                 Bewani    MGV Commodity said that it had not bought from Bewani since 2019. “We did very small volume of
MGV Commodity
                           shipments,” the company said, adding: “We are very ethical in our trade”. It said it had no plans to
Pte Ltd                    buy from Bewani in the future.

Neste Oyj        ENB       Neste said that its investigation had found that its exposure to ENB had been via Mewah, which
                           not been a supplier to Neste since the second half of 2020. It provided a link to its sustainability
                           dashboard but did not otherwise comment on Global Witness’s findings.

Nestlé S.A.      ENB       “Nestlé is committed to sourcing 100 percent responsibly sourced and deforestation-free palm
                           oil,” the company said.

                           Nestlé said it had implemented responsible standards in its palm oil supply chain, prioritizing
                           traceability to plantations, and monitored deforestation by satellite. The company said it
                           applies a “suspend and engage” policy with suppliers found deforesting or not able to
                           demonstrate they
                           had followed FPIC processes, and works to improve sustainability in the industry. “As of December
                           2020,” Nestlé wrote, “70% of the palm oil we sourced was assessed as deforestation-free and we are
                           progressing towards achieving 100% by the end of 2022.” Nestlé said it had not received any palm oil
                           from ENB’s Liguria mill since 2019, but that it appeared to be connected to nine RH mills in Malaysia
                           via various suppliers. The company said it had asked Earthworm to investigate Global Witness’s
                           allegations, and if any mill was involved in deforestation or had failed to seek proper consent from
                           traditional landowners, it would suspend them at the group level.

                                                                                                 THE TRUE PRICE OF PALM OIL 35
Page 35 screenshot
     PZ Cussons      ENB   PZ Cussons said it had worked with the Earthworm Foundation to confirm the deforestation
                           described by Global Witness. “Having confirmed it has taken place and is identifiable as palm
                           plantation, we immediately activated our non-compliance grievance mechanism,” it said. “We
                           are already engaging with [...] suppliers directly to instruct them to engage with East New Britain
                           Resource Group to request an immediate stop to current activities that contravene our NDPE
                           position.” It added, “If we do not receive an appropriate response from them then we will instruct
                           [suppliers] to confirm the removal of the plantation company and parent group from their supply
                           chains.” The company said its goal was to buy 100% of its palm oil from suppliers independently
                           verified to be NDPE-compliant.

     Oleon           ENB   Oleon said: “Oleon is committed to protecting human rights in the workplace and in the
                           communities where we do business. This commitment is shared with our shareholder the Avril
                           Group. The Avril Group strives to obtain its palm oil from suppliers who can prove that its cultivation
                           is in line with the Group’s No Deforestation, No Peat, No Exploitation (NDPE) commitment, and is
                           fully traceable back to the mills.

                           “Oleon is sourcing from Narangit and Liguria palm oil mills via other suppliers. Our suppliers have
                           informed us that as of July 2021 there is a groupwide suspension of ENB until the investigation
                           process is completed. We know, that cutting off purchases alone does not usually solve the
                           problem on the ground for the local communities, and workers who have been harmed. As such, we
                           are in conversations with Earthworm Foundation to explore what could be done to bring some
                           level of support to the communities and workers who have been impacted.”

 Reckitt Benckiser   ENB   Reckitt said that palm oil from the Liguria and Narangit mills had not entered its supply chain, but
 Group plc                 that it did have a supply chain connection to ENB via a supplier of palm oil derivative products.
                           “Our supplier is investigating further with ENB and we have required ENB’s removal from our
                           supply chain,” it wrote. Reckitt said: “We take our responsibility for meeting our standards very
                           seriously and continue to work in a number of ways to strengthen standards in our and the wider
                           palm oil supply network.” It pointed to its membership in the Consumer Goods Forum’s ‘Forest
                           positive’ and ‘Human rights’ coalitions of action, and said that it was using satellite analysis to
                           monitor deforestation in its supply chain and working to support smallholder farmers. “We will
                           naturally continue to investigate, working with Earthworm and others, and taking any further action
                           necessary to exclude these suppliers from our network,” it said.

     Stratas Foods   ENB   Stratas, a joint venture of ADM and ACH Food Companies, acknowledged that ENB was part
                           of its supply chain “for a very limited time in the third quarter of 2019”, via its supplier AAK.
                           “Our Sustainable Palm Policy spells out what actions we might take in response to a substantiated
                           grievance. In addition, your allegations implicate our Corporate Ethics and Human Rights
                           Policies,” it said. “Stratas and AAK are committed to accountability and transparency in our supply
                           so I am confident we will be able to conclude our investigation promptly. The results of that
                           investigation and our next steps will be disclosed in our grievance log at the conclusion of
                           our investigation.”

                           ADM said that it took “extremely seriously” any allegations of social and/or environmental non-
                           compliance, and that it had zero tolerance for such violations in its supply chain. “ADM is working
                           diligently to implement its Policy to Protect Forests, Biodiversity and Communities, and Human
                           Rights Policy and to ensure these are upheld across its supply chain. The policies apply to ADM’s
                           own operations and across all supply chains in which ADM operates, including all supplier tiers
                           back to the origin from which commodities are sourced, and for all companies/JVs in which ADM holds
                           an ownership stake,” it wrote. ADM said it was supporting Stratas in engaging in its grievance resolution
                           mechanism, and that it would enter Global Witness’s allegations into its own grievance log and
                           would reach out to its direct supplier(s) for an investigation.

                           ACH Food Companies did not respond to repeated requests for comment.

Page 36 screenshot
The Hershey           ENB            “The Hershey Company takes all allegations of NDPE violations very seriously”, the company wrote.
                                    “Since 2013, Hershey has been committed to achieving a traceable and sustainable NDPE palm oil
Company                             supply chain in line with our Responsible Palm Oil Sourcing Policy as well as our Supplier Code of
                                    Conduct and No Deforestation Policy.” It noted that it did not purchase palm oil directly from
                                    mills, but acknowledged that the Liguria and Narangit mills appeared in a 2020 mill list, via its
                                    AAK. “The list represents all mills connected to Hershey’s suppliers during the reporting period
                                    and likely includes mills whose product was not specifically sold to Hershey”, it said. Nevertheless,
                                    it said it had initiated a grievance procedure and had suspended ENB from its supply chain. “We
                                    will continue to work with supply chain partners and Earthworm Foundation to define necessary
                                    corrective actions and what support can be given to the communities and workers who have been
                                    impacted,” Hershey said.

The Kellogg           ENB            Kellogg’s said: “Thank you again for contacting us regarding this issue and we take it very seriously.
                                    We have internally reviewed the complaint and are following our public grievance process. We have
Company                             performed outreach to three potentially impacted suppliers.” It said it would continue to monitor
                                    the situation.

 Crowd-sourcing due diligence
 Global Witness has found palm oil from the ENB Group’s plantations in the supply chains of major companies
 from Cargill to Nestlé. Many of these are paying members of the Earthworm Foundation, formerly known as
 The Forest Trust.313 Earthworm says it helps companies eliminate deforestation from their supply chains.314 It
 works with these companies on their use of palm oil, including by improving transparency and implementing
 NDPE policies.315 The not-for-profit organization requires its members to provide it all relevant information from
 their supply chains.316 But in every case, these companies’ partnerships with Earthworm pre-date by years their
 publicly disclosed purchases of palm oil from the ENB Group’s mills.317 That means all these companies’ new
 purchases from groups that Global Witness calculates has deforested many thousands of hectares of rainforest
 since 2010 have apparently escaped scrutiny.

 An Earthworm spokesperson said: “We admit that we were not aware of the serious legal and human rights
 violations that were carried out” by ENB and RH. “We are taking these very seriously and are calling on our
 members to do the same.” Earthworm said that since receiving this information, it had identified all its members’
 supply chain links to ENB and RH, including at the parent company level, notified its members, and urged them to
 treat these issues “with the highest priority”.

 “We know [...] that cutting off purchases alone does not usually solve the problem on the ground for local
 communities, and workers who have been harmed,” Earthworm continued. “As such, we are initiating
 conversations with our members to explore what may be possible to do to bring some level of support to the
 communities and workers currently who have been impacted.

 Earthworm said it worked with its members to require each of its suppliers to provide information about its palm
 oil supply chain back to the mill level, which could result in a list of over a thousand mills, depending on the
 member. It could not credibly check the environmental and social performance of each mill itself, the organisation
 said, and so encouraged members to make these lists public to enable the crowd-sourcing of such checks.

                                                                                                         THE TRUE PRICE OF PALM OIL 37
Page 37 screenshot
Heavy industry
Global Witness has obtained PNG customs records
indicating that Bewani has exported shipments of palm
oil to customers in at least three countries: India (via the
Seychelles), Singapore, and South Korea.318 319

Two of its customers, based in the Seychelles and
Singapore, according to customs data, keep a low
profile. A Global Witness researcher visited an address
given for MGV Commodity Pte. Ltd in Singapore,
in a firm of accountants. While they were able to confirm
that the company does exist, the principal was said
to rarely visit the office. No record of the Seychelles
company Perfect Essence International exists in the
country’s corporate register, and Global Witness was
unable to reach the company for comment. But if Global
Witness’s investigation of where ENB and RH’s product
ends up is anything to go by, there is every chance that
from these merchants, Bewani palm oil may soon reach
                                                                      Waterfront at night in Papua New Guinea’s capital Port
the supply chains of well-known brands that have failed               Moresby. © Global Witness
to perform basic due diligence on their supply chains.

The third Bewani customer identified by Global Witness
                                                                      by rapper PSY. Its buyer was GS Global Corporation, a
is a different story. In September 2019, according to                 metals, petrochemicals, and industrial products trader
customs documentation, the oil tanker MT Bnoah sailed                 with revenues of about £1.5 billion in 2020.320 321
out of Vanimo carrying over 1.5 million kilograms of palm
oil. Its destination: the Gangnam District of Seoul, home             For these companies’ responses, see Table 1 on p. 34.
to the glitterati of South Korean society and immortalized

Banana boats wait for passengers along the Papua New Guinea coast. © Global Witness

Page 38 screenshot

Mangroves at Wara Puk Puk (Crocodile River) in the north coast region of East New Britain Province, Papua New Guinea. © Global Witness

PNG stands on a precipice. Rural communities and the                    Governments whose businesses are engaged in palm oil
forests and biodiversity they depend on are in the path                 supply chains or financing must hold them accountable
of a massive expansion of the palm oil industry.                        for their impacts on deforestation and forest-related
This would be catastrophic if allowed to proceed in                     human rights risks.
the same reckless, irresponsible and unethical way as
exposed in this report.                                                 The PNG government must immediately take action to
                                                                        uphold land rights, stamp out any corruption and tax
Our investigation shows the extent of these predatory                   evasion, and hold to account companies breaking the
practices – they are systemic and widespread across                     law and abusing human rights or ignoring the safety
key new players in the palm oil sector in PNG. ENB, RH,                 of workers.
and Bewani all engaged in large-scale deforestation of
climate-critical forest. Community landowners, who                      The financiers of these destructive oil palm plantations
depend on these forests for their livelihoods, have raised              also bear a heavy responsibility. They have profited
grave concerns about the lack of free, prior and informed               from tens of thousands of hectares of PNG rainforest
consent involved in these companies’ access to land.                    being flattened, untold numbers of communities being
This investigation has documented other abuses, from                    left destitute, and the brutalization of communities by
detaining community members and the use of police                       police paid to harm rather than protect them. Many oil
to violently suppress protest, to negligence leading to                 palm workers have been killed or seriously injured on
workers’ deaths. Two of the companies we investigated                   projects they have bankrolled. In several instances local
enjoyed extensive financing from a web of banks and                     laws protecting people and the environment have been
financial actors, and all have sold on tainted palm oil to              broken. This report illustrates once again how internal
global brands without any checks, sanctions or penalties.               policies are not enough to steer financiers to make the
All of this must stop.                                                  right decision, when they are so often ignored.

                                                                                                          THE TRUE PRICE OF PALM OIL 39
Page 39 screenshot
If the story told by this report hinges on rural PNG, it                   > Immediately investigate companies involved for
began in New York, Oslo, Rotterdam, Singapore, and                        potential violations of statutes including, but not limited
Kuala Lumpur. The governments of countries where                          to, the Employment Act, the Industrial Health, Safety and
these financiers and their global owners are based                        Welfare Act, the Workers Compensation Act, and the Road
must act responsibly and require banks and investors                      Traffic Act. Where applicable, impose relevant penalties.
to conduct thorough checks to ensure their money is
not used to destroy forests. The global brands buying                      > Assign an industrial safety inspector to initiate and
from these plantations, which now circle the globe and                    maintain a regular system of industrial safety inspection
sell products from toothpaste to biodiesel, must stop                     for the PNG palm oil plantations and mills that do not
contributing to and benefiting from deforestation and                     already report publicly on their safety record. The cost of
other harm in their palm oil supply chains. The gravity                   these inspections should be a user-pays system where the
of the crimes and human rights abuses outlined in this                    company pays for the inspector’s visits.
report means there can be no more excuses.
                                                                           >  Review the records of any Royal PNG Constabulary
                                                                          officers involved in alleged harassment of or violence
Recommendations                                                           toward citizens. Take appropriate disciplinary action
                                                                          where applicable.
Government of Papua New Guinea
                                                                           > Freeze the issuance of new forest clearance authorities
                                                                          (FCAs) and cancel existing FCAs except where the
>    Immediately investigate all injuries and deaths on oil               holder can prove they are complying with all national,
palm plantations.                                                         customary, and international laws and have obtained
                                                                          free, prior and informed consent from local communities
 > Ensure that all workers injured on oil palm plantations,               in order to operate.
or the next of kin of workers who died on the plantation,
are immediately acknowledged and compensated.                              > Require all palm oil operations in Papua New Guinea
                                                                          to meet or exceed industry best practices with regards to
 > Provide support for injured workers and their next of                  protecting ecosystems; avoiding deforestation; upholding
kin to find suitable replacement employment in palm oil                   community and human rights, including worker rights;
agriculture or, if desired, an alternate industry.                        and ethical and transparent business dealings.

Papua New Guinea is home to at least five per cent of all species on Earth. © Global Witness

Page 40 screenshot
Governments of the UK, US, EU, and other                        > Cooperate with investigations into the allegations
                                                               named in this report, including allegations of child
countries home to companies importing
                                                               labour, bribery, environmental devastation, tax evasion,
palm oil or financing palm oil-linked banks                    and negligence regarding worker health and safety,
or companies:                                                  where relevant.

> Introduce and implement legislation requiring                >   Work to ensure that all workers injured on oil palm
businesses, including the finance and investment sector,       plantations, or the next of kin of workers who died
to identify, prevent, mitigate, and report on deforestation    on the plantation, are immediately acknowledged
and forest-related human rights risks and impacts in their     and compensated.
supply chains and financing.
                                                                > More broadly, work to provide redress and remedy for

> Host governments for banks named in this report              any harms arising from their business.
should investigate and report on whether the banks have
legally misled their shareholders or clients as to their due   Global buyers
diligence processes, including any potential exposure to
handling the proceeds of crime                                 >   Cease sourcing palm oil and palm oil products
                                                               originating from ENB’s, RH’s, and Bewani’s mills in PNG,
                                                               with immediate effect.
Banks funding these palm oil companies:
                                                                > Review internal processes and third-party assistance
> Immediately suspend any services, financing or               to identify how these companies were allowed into their
contracts with ENB, RH, and Bewani Oil Palm Plantations        supply chains.
Ltd and their subsidiaries or affiliate companies,
pending a full review of any potential legal and human         >   Work to ensure that all workers injured on oil palm
rights violations.                                             plantations, or the next of kin of workers who died
                                                               on the plantation, are immediately acknowledged
> More broadly, exclude financing to PNG palm oil and          and compensated.
related operations unless adequate due diligence has            > More broadly, work to provide redress and remedy for
been undertaken, including that the bank has gained            any harms arising from their business.
independent, community-informed data that ensures
that business practices exclude deforestation, have             > Publicly disclose the end products manufactured
secured the legitimate free, prior and informed consent        using this palm oil or palm-related derivatives, as well as
of Indigenous peoples and local communities, and               country of origin.
are not exposed to human rights abuses, including
labour violations.

Investors and shareholders in banks
financing these palm oil companies:
> Withhold financing from any bank or agribusiness
company that is unable to show that it has clear,
implemented practices to exclude deforestation
and require the free, prior and informed consent of
Indigenous peoples and local communities

 >   Ensure that any bank or company claims are
cross-checked by ground-truthed data (information
provided by independent third parties based on on-the-
ground information) and that banks and investors are
contributing to remedy for any prior harms caused.

 > East New Britain Resources Group, Rimbunan Hijau
Group, and Bewani Oil Palm Plantations Ltd:

                                                                                              THE TRUE PRICE OF PALM OIL     41
Page 41 screenshot

Deaths and accidents of Rimbunan Hijau employees on its oil palm
plantations in Pomio District, East New Britain Province, Papua New Guinea.
Workers’ ages and occupations at the time of their accidents are shown. Information on reported deaths and accidents,
including the circumstances of individual incidents, workers’ personal details, and compensation received, was
drawn from Office of Workers’ Compensation records, where available, and/or interviews conducted with next of kin
and other community members in Pomio District between October 2020-February 2021. When this report went to
publication, the OWC database was undergoing renovations and was offline.

 1. Ms. Monica Alois                                                           2. Mr. Joe Lui
                               Age                   221 years                                                  Age                     30 years4
                               Occupation            Loose fruit                                                Occupation              Mechanic
                                                                                                                Employer listed         Sinar Tiasa (PNG)
                              Employer listed        RH Trading,                                                as:                     Ltd
                              as:                    Frontier Holdings,
                                                     and Niugini Lumber

                               CRN-0660319-F12121118                                                            CRN-0510819-F12EAS291118
 PNG Office of Workers                                                         PNG Office of Workers
 Compensation Case                                                             Compensation Case
 Report Number:                                                                Report Number:
 Incident                     Ms. Alois fell from the back of a moving         Incident                         Mr. Lui suffered a motor vehicle accident
                              Toyota Land Cruiser vehicle on her way                                            while road testing a repaired motorbike
                              back to the camp site on the plantation,                                          after repairing, resulting in his death.5
                              resulting in her death by cerebral
                                                                               Outcome                          Fatality
                                                                               Areas of concern             >       Official accident reports maintained
 Outcome                       Fatality
                                                                                                                by OWC are illegible. This is a concern in
 Areas of concern             > Whether safe and reliable                                                       and of itself.
                              transportation to and from the workplace                                          >   For a young mechanic to lose his
                              was provided by the company.                                                      life while working in a controlled
                               >PNG Road Traffic Act                                                            environment may suggest a lack of rules
 Potential non-
                               2014 > PNG Employment                                                            and regulation determining work safe
 compliances:                                                                                                   procedures and processes.
                               > Workers Compensation Act
                                                                                                                >   Industrial Safety, Health and Welfare
 Date of incident:             2018                                            Potential non-
 Compensation received:        None                                                                             >   Road Traffic Act 2014
                                                                                                                >   Workers’ Compensation Act
                                                                               Date of incident:                2018

                                                                               Compensation received:           Unknown

1     Monica Alois coroner report, on file with Global Witness.
2     Monica Alois next of kin interview, on file on file with Global Witness.
3     Monica Alois police report, on file on file with Global Witness.
4     Data obtained from the PNG Office of Workers’ Compensation database at
5    NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

Page 42 screenshot
3. Mr. Joachim Kankan                                                          4. Mr. Leo Kaukau
                                 Age                     38 years6                                      Age                    49 years8

                                 Occupation              Driver                                         Occupation             Forklift Operator
                                 Employer listed         Sinar Tiasa (PNG)                              Employer listed         Sinar Tiasa (PNG)
                                 as:                     Ltd                                            as:                     Ltd

                                 CRN-0980619-F12WES240417                      PNG Office of Workers    No records found on           PNG Office of
PNG Office of Workers
                                                                               Compensation Case        Workers Compensation            website
Compensation Case
                                                                               Report Number:           (
Report Number:
Incident                         Mr. Kankan was hit by a dump truck and
                                 subsequently passed away.7                                             While on the plantation, Mr Kaukau
                                                                                                        cooked dinner for himself and his son
Outcome                          Fatality                                                               Ronald Kaukau with water collected and
Areas of concern             >   Official files are insufficient for review.                            stored in a used chemical container; he
                                 This is a concern of itself. In Global                                 promptly began vomiting in the night
                                 Witness’s assessment, Mr. Kankan’s                                     and died the next day.
                                 death contributes to a troubling pattern      Outcome                  Fatality
                                 of motor vehicle fatalities on the RH
                                                                               Areas of concern          Whether ample clean, safe drinking
                                 plantations.                                                           >

                                 > If an investigation was not conducted                                water was provided to workers on the
                                 into Mr. Kankan’s death, it should be                                  plantation.
                                                                                                        >   Chemical containers appear to have
                                 done immediately and used to develop
                                                                                                        been negligently unsecured and not
                                 company safety procedures.
                                                                                                        made unusable, in violation of FAO best
Potential non-                   > PNG Road Traffic Act 2014                                            practices and RSPO PNG NIWG Criteria
                                 > Industrial Safety, Health and Welfare                                4.6.10. Storage and disposal of chemicals
                                 Act 1965                                                               as prescribed in the GIFAP Code of
                                 >   Workers Compensation Act                                           Practice:
Date of incident:                2017                                                                   Specific Guidance: Proper storage and
                                                                                                        disposal of waste material, according to
Compensation received:           Unknown                                                                procedures that are fully understood by
                                                                                                        workers and managers. Also see Criterion
                                                                                                        5.3 on waste disposal. All redundant and
                                                                                                        excess plantation chemical containers
                                                                                                        must be triple rinsed and then punctured
                                                                                                        before disposal in a designated landfill.
                                                                                                        Records to be kept.

                                                                               Potential non-           >   Industrial Safety, Health and Welfare
                                                                                                        Act 1965
                                                                                                        >   Workers Compensation Act
                                                                               Date of incident:        2014

                                                                               Compensation received:   None

6   Data obtained from the PNG Office of Workers’ Compensation database at
7   Ibid.
8   Global Witness interview with Felix Tau (2021).

                                                                                                                   THE TRUE PRICE OF PALM OIL 43
Page 43 screenshot
    5. Ronald Kaukau                                                              6. Mr Anton Kelal10
                                 Age                      119 years                                        Age                     22 years

                                 Dependent Child, Student.                                                 Occupation              Ramp Keeper
                                 While living on the plantation with his                                   Employer listed         Sinar Tiasa (PNG)
                                 father Leo Kaukau, ate dinner cooked                                      as:                     Ltd.
                                 with water collected and stored in a used
                                 chemical container; he promptly began
                                 vomiting in the night and died the next day.

    Outcome                      Fatality                                         PNG Office of Workers    No records found on PNG Office of
    Areas of concern                                                                                       Workers Compensation website
                                 >Whether ample clean, safe drinking              Compensation Case
                                 water was provided to workers on the             Report Number:
                                 plantation.                                      Incident                 Mr Kelal fell out of the crew side of a
                                 >   Chemical containers appear to have                                    dump truck, hitting his head, and died of
                                 been negligently unsecured and not                                        his injuries.11
                                 made unusable, in violation of FAO best
                                                                                  Outcome                  Fatality
                                 practices and RSPO PNG NIWG Criteria
                                 4.6.10. Storage and disposal of chemicals        Areas of concern         > No police report on this motor vehicle
                                 as prescribed in the GIFAP Code of Practice:                              accident was available for sighting at the
                                 Specific Guidance: Proper storage and                                     time of this publication.
                                 disposal of waste material, according to         Potential non-           >   Industrial Safety, Health and Welfare
                                 procedures that are fully understood by          compliances:             Act 1965
                                 workers and managers. Also see Criterion
                                                                                                           >   Workers Compensation Act
                                 5.3 on waste disposal. All redundant and
                                                                                                           >   Road Traffic Act 2014.
                                 excess plantation chemical containers must
                                 be triple rinsed and then punctured before       Date of incident:        2020
                                 disposal in a designated landfill. Records       Compensation received:   PGK5,000 (about £1,000) for funeral
                                 to be kept.                                                               expenses

    Potential non-               >   Industrial Safety, Health and Welfare
                                 Act 1965
                                                                                  7. Mr. Joe Kingsly12
    Date of incident:            2014
                                                                                                           Age                     22 years
                                                                                                           Occupation              General Worker
                                                                                                           Employer listed         Sinar Tiasa (PNG)
                                                                                                           as:                     Ltd.

                                                                                                           No records found on PNG Office of
                                                                                  PNG Office of Workers
                                                                                                           Workers Compensation website
                                                                                  Compensation Case
                                                                                  Report Number:
                                                                                  Incident                 Mr Kingsly reportedly fell and hit his
                                                                                                           side on a rock while cutting fresh fruit
                                                                                                           bunches from an oil palm tree, later
                                                                                                           dying of his injuries.

                                                                                  Outcome                  Fatality
                                                                                  Areas of concern         >   Insufficient documentation is available
                                                                                                           to ascertain whether Mr Kingsly’s death
                                                                                                           was the result of negligence.
                                                                                                           >   PNG Employment Act
                                                                                  Potential non-
                                                                                                           >   Workers Compensation Act
                                                                                  Date of incident:        April 2020

                                                                                  Compensation received:   None

9       Global Witness interview with Felix Tau (2021).
10 Global Witness interview with Lawrence Lapuli (2021).
11 Anton Kelal witness statement and Anton Kelal death certificate, on file with Global Witness
12 Global Witness interview with J. Kingsly’s son (2020).

Page 44 screenshot
 8. Mr Cosmas Manane                                                            9. Mr Patrick Puka
                                                       25 years13
                                                                                                                                       4015 years
                                Age                                                                             Age

                                Occupation             Survey aide                                              Occupation             Surveyor16
                                Employer listed        Niugini Lumber                                           Employer listed       Niugini Lumber
                                as:                    Merchants Limited                                        as:                   Merchants Limited

                                CRN-0360618-F12WES261115                                                        Link
 PNG Office of Workers                                                          PNG Office of Workers
 Compensation Case                                                              Compensation Case
 Report Number:                                                                 Report Number:
 Incident                       Mr. Manane walked through the bush              Incident                        While in a company car, Mr Puka was
                                (forest) alone to the plantation camp                                           involved in a motor vehicle accident
                                after working in the field. He died in his                                      and died from severe head and spinal
                                sleep that night.                                                               injuries.17

 Outcome                        Fatality                                        Outcome                         Fatality
 Areas of concern               >There is no record of an inquest or            Areas of concern            >    Available documentation is insufficient
                                autopsy in Mr Manane’s OWC file.14                                              to determine whether RH was negligent
                                                                                                                in allowing its employees to travel in this
                                >   PNG Employment Act
 Potential non-
                                >   Workers Compensation Act                                                    vehicle.18
                                                                                Potential non-                  >   PNG Road Traffic Act 2014
 Date of incident:              2015                                            compliances:                    >   PNG Employment Act
 Compensation received:         Unknown                                                                         >   Workers Compensation Act

                                                                                Date of incident:               2014

                                                                                Compensation received:          Unknown

13   Cosmas Manane police report, on file with Global Witness.
14   Cosmas Manane supervisor report, on file with Global Witness.
15   Patrick Puka death certificate, on file with Global Witness.
16   Patrick Puka supervisor statement, on file with Global Witness.
17   Patrick Puka witness statement, on file with Global Witness.
18   NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness

                                                                                                                         THE TRUE PRICE OF PALM OIL 45
Page 45 screenshot
 10. Mr Robert Rolpha                                                         11. Mr Edgar Tanewa
                                                      37 years
                              Age                                                                          Age                   20 years
                              Occupation                     Chainsaw                                      Occupation            Bunch recorder
                                                                                                           Employer listed       Sinar Tiasa (PNG)
                              Employer listed        Niugini Lumber                                        as:                   Ltd.
                              as:                    Merchants Limited

                              No records found on PNG Office of                                            CRN: 0050518-F12EAS200317
 PNG Office of Workers                                                        PNG Office of Workers
                              Workers Compensation website
 Compensation Case                                                            Compensation Case
 Report Number:                                                               Report Number:
 Incident                     Mr. Rolpha caught a ride on a                   Incident                     Mr. Tanewa was operating a motorbike
                              construction road grader to travel home                                      on the plantation. He was hit by a truck
                              from work; he fell from the grader,                                          whilst attempting to overtake it and died
                              rupturing his spleen and resulting in his                                    of his injuries: a severe head injury and
                              death.                                                                       associated haemo-pneumothorax. 21 22

 Outcome                      Fatality                                        Outcome                      Fatality
 Areas of concern             > Whether safe and reliable                     Areas of concern             > Has RH implemented safety training,
                              transportation to and from the workplace                                     including driver safety training, on its
                              was provided by the company.                                                 plantations?23
                              >   An additional passenger appears to          Potential non-               >PNG Road Traffic Act
                              have been negligently allowed to ride on        compliances:                 2014 > PNG Employment
                              single-seat heavy equipment.                                                 Act
 Potential non-               >PNG Road Traffic Act                                                        > Workers Compensation Act
                                                                              Date of incident:            2017
 compliances:                 2014 > PNG Employment
                              Act                                             Compensation received:       Unknown
                              > Workers Compensation Act
 Date of incident:            2016

 Compensation received:       None

19 Robert Rolpha death certificate, on file with Global Witness
20 Robert Rolpha next of kin interview, on file with Global Witness.
21 Edgar Tanewa witness statement, on file with Global Witness.
22 Edgar Tanewa postmortem, on file with Global Witness.
23 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

Page 46 screenshot
 12. Mr Dominic Wainau                                                        13. Mr Philip Alrea
                                                                                                                                   5528 years
                                Age                     41 years                                          Age

                                Occupation              Dump truck driver24                               Occupation               Supervisor29
                               Employer listed          Sinar Tiasa (PNG)                                 Employer listed         Niugini Lumber
                               as:                      Ltd.                                              as:                     Merchants Limited

                                CRN: 0979619-F12WES020917                     PNG Office                  CRN-0210818-F11WES310517
 PNG Office of Workers
 Compensation Case                                                            of Workers
 Report Number:                                                               Compensation Case
 Incident                      The truck Mr Wainau was driving                Report Number:
                               overturned; he either jumped or was            Incident                    Mr. Alrea fell off a bike while supervising
                               thrown from the cab.25 He died of his                                      work, breaking his leg and losing 60% of its
                               injuries, including a fractured pelvis and                                 efficient use.30 31

                               flail chest, in which a segment of the rib
                                                                              Outcome                     60% loss of efficiency of left leg.
                               cage is broken and detached from the
                               chest wall.   26                               Areas of concern            >   No police report is available.
                                                                                                          > Interviews do not indicate evidence of
 Outcome                        Fatality
                                                                                                          a company safety officer or safety training
 Areas of concern              >    Was Mr Wainau was wearing a safety                                    provided to employees.32 Has such training
                               belt?                                                                      been provided and mandated?
                               > No medical officer was apparently on                                     >   PNG Road Traffic Act 2014
                                                                              Potential non-
                               site to treat his injuries, necessitating
                                                                              compliances:                >   Workers Compensation Act
                               his evacuation to the Palmalmal health
                               center.                                        Date of incident:           2017
                               > After the accident, it appears that Mr.                                  None
                               Wainau was still alive. An investigation       Compensation
                               should assess whether he could have            received:
                               been saved, if incident management had
                               been handled by trained safety and/or
                               medical officers at the incident site.27

 Potential non-                 >   PNG Road Traffic Act 2014
 compliances:                   >   Workers Compensation Act

 Date of incident:              2017

 Compensation received:         Unknown

24 Dominic Wainau supervisor statement, on file with Global Witness.
25 Dominic Wainau witness statement, on file with Global Witness.
26 Dominic Wainau death certificate, on file with Global Witness.
27 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.
28 Data obtained from the PNG Office of Workers’ Compensation database at
29 Global Witness interview with Philip Alrea (2020).
30 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness
31    Philip Alrea final medical report, on file with Global Witness.
32 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

                                                                                                                     THE TRUE PRICE OF PALM OIL 47
Page 47 screenshot
 14. Mr Bakom Anak Jali                                                       15. Mr Timothy Joe
                                                      56 years   33
                                                                                                                                  2936 years
                               Age                                                                         Age

                               Occupation             Bulldozer operator                                   Occupation             Fertilizer stacker37
                               Employer listed       Sinar Tiasa (PNG)                                     Employer listed        Sinar Tiasa (PNG)
                               as:                   Ltd.                                                  as:                    Ltd.

                               CRN-0540319-F11EAS260 818                                                   CRN 0990619-F11WES030117
 PNG Office of Workers                                                        PNG Office of Workers
 Compensation Case                                                            Compensation Case
 Report Number:                                                               Report Number:
 Incident                      Mr Jali’s hand and arm were crushed            Incident                     Mr. Joe’s hand was crushed by a falling
                               while he was crossing a flooded river in                                    pallet; he developed an infection
                               an excavator as a passenger.34                                              and extension contracture, requiring
 Outcome                       Loss of 80% efficacy of left arm.
 Areas of concern                                                             Outcome                      Contracture requiring plastic surgery39
                               ~ Crossing a flooding river in an
                               excavator as a passenger on a single seat      Areas of concern             ~Apparent lack of supervision of
                               earth moving machinery is a serious                                         employees working with heavy objects
                               breach of safety protocols, suggesting a                                    and working at heights; no record
                               lack of safety training.35                                                  keeping of near miss, minor injuries and
                                                                                                           accidents; no inspection and monitoring
                               ~   PNG Employment Act
 Potential non-                                                                                            of safe and unsafe working conditions.40
                               ~   Workers Compensation Act
                                                                                                           ~   PNG Employment Act
                                                                              Potential non-
 Date of incident:                                                                                         ~   Workers Compensation Act
 Compensation received:        Unknown
                                                                              Date of incident:            2017

                                                                              Compensation received:       Unknown

33 Bakom Anak Jali interim medical report, on file with Global Witness.
34 Bakom Anak Jali statement, on file with Global Witness.
35 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.
36 Data obtained from the PNG Office of Workers’ Compensation database at
37 Timothy Joe witness statement, on file with Global Witness.
38 Timothy Joe medical report, on file with Global Witness
39 Timothy Joe medical diagnosis report, on file with Global Witness
40 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

Page 48 screenshot
 16. Mr Paul Kinroro                                                          17. Ms Bertha Kanmugurea
                              Age                     54 years                                          Age                      –

                              Occupation              GPS Surveyor                                      Occupation               General worker
                              Employer listed        Sinar Tiasa (PNG)                                  Employer listed          Sinar Tiasa (PNG)
                              as:                    Ltd.                                               as:                      Ltd.

                              No records found on PNG Office of                                         No records found on          PNG Office of
 PNG Office of Workers                                                        PNG Office of
                              Workers Compensation website                                              Workers Compensation            website
 Compensation Case                                                            Workers
                              (                                Compensation              (
 Report Number:
 Incident                                                                     Case Report
                              Mr. Kinroro was involved in a motor
                              vehicle accident during working hours,
                              sustaining scalp lacerations and a broken       Incident                  Ms. Kanmugurea was accidentally
                              wrist. He had to pay for his medical costs                                sprayed by another employee with
                              out of pocket.                                                            herbicide 2,4-D; she sustained eye
 Outcome                                                                                                injuries and still feels weak and suffers
                              Injuries to scalp and head. Fulfilled his
                                                                                                        chest pain. She is currently unable to
                              own medical bills.
                                                                                                        work due to her injuries. 41
 Areas of concern             >  Mr Kinroro’s accident is part of a
                                                                              Outcome                   Injuries to eyes. Alleged loss of energy
                              troubling pattern of motor vehicle
                                                                                                        and pain in her chest.
                              accidents on the RH oil palm plantations.
                                                                              Areas of concern          >   For one employee to spray another
 Potential non-               >   PNG Road Traffic Act 2014
                                                                                                        with chemicals indicates a lack of safety
 compliances:                 >   Workers Compensation Act
                                                                                                        awareness, training and identification
 Date of incident:            2014                                                                      of risks and in handing agricultural
                                                                                                        chemicals at work. 42
 Compensation received:       None
                                                                                                        > Apparent failure to use personal
                                                                                                        protective equipment when handling
                                                                                                        > Agrochemical use should be guided

                                                                                                        by GIFAP/industry best practices as
                                                                                                        established by the RSPO, which should
                                                                                                        – Eye protection
                                                                                                        – Full body protection
                                                                                                        – Gloves and rubber boots
                                                                                                        >   PNG Employment Act
                                                                              Potential non-
                                                                                                        >   Workers Compensation Act
                                                                              Date of incident:         2012

41 Global Witness interview with Bertha Kanmugurea (2020).
42 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

                                                                                                                  THE TRUE PRICE OF PALM OIL         49
Page 49 screenshot
 18. Mr Timothy Kundi                                                         19. Mr Kevin Lolale
                                                  35 years
                                                                                                                                  5546 years
                          Age                                                                             Age

                          Occupation              Field worker
                                                                                                          Occupation              Maintenance
                          Employer listed         Sinar Tiasa (PNG)
                          as:                     Ltd.                                                    Employer listed         Sinar Tiasa (PNG)
                                                                                                          as:                     Ltd.

                          No records found on        PNG Office of                                        CRN-0480819-F11EAS210818
 PNG Office                                                                   PNG Office of Workers
                          Workers Compensation           website
 of Workers                                                                   Compensation Case
 Compensation             (
                                                                              Report Number:
 Case Report                                                                  Incident                    Mr Lolale was in a motor vehicle accident
 Number:                                                                                                  whilst driving a motorbike on the
 Incident                 Mr Kundi was sprayed in the eye with                                            plantation and was referred to hospital
                          a glyphosate herbicide, resulting in                                            with back pain.
                          infection, corneal corrosion, and partial
                                                                              Outcome                     Back injury
                          blindness. He is currently unable to work.
                                                                              Areas of concern            > No evidence of motor vehicle safety
 Outcome                  Eye infection, corneal corrosion, and
                                                                                                          training. Possible lack of upkeep of
                          partial blindness. 44
 Areas of concern         >No evidence of safety training or
                                                                              Potential non-              >PNG Road Traffic Act 2014
                          protective personal equipment provided
                                                                              compliances:                 PNG Industrial Safety, Health and
                          to employees.   45                                                              >

                                                                                                          Welfare Act
                          > Agrochemical use without following
                          recommended safety procedures by ILO                                            >   Workers Compensation Act
                          conventions and PNG Industrial Safety,              Date of incident:           2018
                          Health and Welfare Act places workers
                                                                              Compensation received:      Unknown
                          at risk of injury to themselves and the
 Potential non-           >PNG Industrial Safety, Health and
 compliances:             Welfare Act
                          >   PNG Employment Act
                          >   Workers Compensation Act

 Date of incident:        2018

 Compensation             None

                                                                         43 Global Witness interview with Timothy Kundi (2020).
44 Timothy Kundi medical report, on file with Global Witness.
45 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.
46 Kevin Lolale statement, on file with Global Witness.
47 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

Page 50 screenshot
 20. Mr Barnabas Momkale                                                      21. Mr Peter Pavulo
                                                     24 years
                                                                                                                                   50 years51
                               Age                                                                         Age

                               Occupation            Security guard                                        Occupation              Welder
                              Employer listed        Sinar Tiasa (PNG)                                     Employer listed         Sinar Tiasa (PNG)
                              as:                    Ltd.                                                  as:                     Ltd.

                               CRN-0141014F11EAS141212                                                     CRN-0470416-F11EAS270715
 PNG Office of Workers                                                        PNG Office of Workers
 Compensation Case                                                            Compensation Case
 Report Number:                                                               Report Number:
 Incident                     An unsecured log fell from a loaded truck       Incident                     While Mr Pavulo was repairing a
                              and hit Mr Momkale, breaking two bones                                       bulldozer, the roller chain fell and
                              in his leg and requiring surgery.49                                          crushed half of one finger, which was
                                                                                                           subsequently amputated. Witness
 Outcome                       Lost 60% of the efficacy of the right leg.
                                                                                                           statements include no evidence of lifting
 Areas of concern             >    Logs were negligently unsecured                                         aids for heavy machinery, safety staff, or
                                         during transportation. 50                                         supervision provided to employees.52 He
 Potential non-                >PNG Road Traffic Act 2014                                                  had to pay for his own medical expenses
 compliances:                                                                                              and says he still finds it very difficult to
                               >PNG Industrial Safety, Health and
                               Welfare Act                                                                 work with the injured hand.

                               >   Workers Compensation Act                   Outcome                      Right middle finger crushed by roller
                                                                                                           chain, later amputated.
 Date of incident:             2012
                                                                              Areas of concern             > Mr Pavulo’s accident forms part
 Compensation received:        None
                                                                                                           of a troubling pattern of serious and
                                                                                                           avoidable injuries on the RH oil palm
                                                                               Potential non-              >   PNG Employment Act
                                                                               compliances:                >PNG Industrial Safety, Health and
                                                                                                           Welfare Act
                                                                                                           >   Workers Compensation Act

                                                                              Date of incident:            2015
                                                                              Compensation received:       Compensation received: PGK1,060
                                                                                                           (about £210)

48 Global Witness interview with Barnabas Momkale (2020).
49 Barnabas Momkale medical report, on file with Global Witness.
50 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.
51 Peter Pavulo medical report, on file with Global Witness.
52 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

                                                                                                                   THE TRUE PRICE OF PALM OIL 51
Page 51 screenshot
 22. Mr George Ravungkia                                                      23. Mr Charles Sai
                                                        45 years53
                                                                                                                                     22 years55
                                 Age                                                                          Age
                                 Occupation             Subcontracted                                         Occupation             Dump truck driver
                                                                                                              Employer listed        Sinar Tiasa (PNG)
                                 Employer listed        Sinar Tiasa (PNG)                                     as:                    Ltd.
                                 as:                    Ltd.

 PNG Office of Workers           No records found on PNG Office of                                            No records found on PNG Office of
                                                                              PNG Office of Workers
                                 Workers Compensation website                                                 Workers Compensation website
 Compensation Case                                                            Compensation Case
 Report Number:                  (                                                             (
                                                                              Report Number:
 Incident                        Mr. Ravungkia hitched a ride home from       Incident                        A log slipped and hit Mr Sai on the neck,
                                 work on the plantation on a motorbike.                                       fracturing several of his vertebrae and
                                 He fell from the motorbike, lacerating his                                   risking paralysis. Mr Sai reportedly had to
                                 Achilles tendon.                                                             pay for his medical care and a copy of his
 Outcome                         Permanent injury to Achilles tendon on                                       own worker’s compensation report.
                                 the leg                                      Outcome                         Risk of potential paraplegia due to neck
 Areas of concern                                                                                             and spinal injuries
                             >    No sa fe and reliab le transpo rt
                                 evidently provided for plantation            Areas of concern            >    There is no evidence of safety signage
                                 employees: this indicates a lack of due                                      and barricades to safeguard employees
                                 care for workers and is a serious safety                                     and the public from the potential
                                 risk.54                                                                      collapse of logs in this highly seismically
 Potential non-                                                                                               active area.56
                                 >PNG Road Traffic Act 2014
 compliances:                    >PNG Industrial Safety, Health and           Potential non-                  >PNG Industrial Safety, Health and
                                 Welfare Act                                  compliances:                    Welfare Act
                                 >   Workers Compensation Act                                                 >   PNG Employment Act
 Date of incident:               2017                                                                         >   Workers Compensation Act

                                                                              Date of incident:               2013
 Compensation received:          None
                                                                              Compensation received:          None

53 Global Witness interview with George Ravungkia (2020).
54 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.
55 Charles Sai radiology report, on file with Global Witness.
56 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

Page 52 screenshot
 24. Mr Samson Waso                                                          Abbreviations used
                                                     42 years57
                              Age                                            RSPO Round Table on Sustainable Palm Oil
                              Occupation             Jinker driver                      (production)
                              Employer listed        Niugini Lumber
                                                                             NIWG National Interpretation Working Group
                              as:                    Merchants Ltd.
                                                                                        (for RSPO)

                                                                             OWC PNG Office of Worker Compensation
 PNG Office of Workers
                                                                             CRN       Case Report Number (used by OWC) to register
 Compensation Case
 Report Number:                                                                        individual cases
 Incident                     A log fell from a loaded truck onto Mr
                                                                             GIFAP International Group of National Associations of
                              Waso’s hand, crushing two of his fingers,
                              which were subsequently amputated.58
                                                                                        Manufacturers of Agrochemical Products

 Outcome                      Amputation
 Areas of concern             > There is no evidence of a safety officer
                              on site, nor of a supervisor’s presence
                              during dangerous industrial activities
                              (offloading logs).59
 Potential non-               >PNG Road Traffic Act
 compliances:                 2014 > PNG Employment
                              > Workers Compensation Act
 Date of incident:            2016

 Compensation received:       Unknown

57 Samson Waso statement, on file with Global Witness.
58 Samson Waso interim medical report, on file with Global Witness.
59 NiuGini Environment Management Services (2021). Palm oil producer safety and health review prepared for Global Witness.

                                                                                                                THE TRUE PRICE OF PALM OIL   53
Page 53 screenshot

                                                           accessed corporate records using publicly accessible
                                                           databases of the PNG Investment Promotion Authority,
Global Witness focused this investigation on the East      Companies Commission of Malaysia, and Singapore’s
New Britain Resources Group of companies (ENB), the        Accounting and Corporate Regulatory Authority.
Rimbunan Hijau Group of companies (RH), and Bewani         Company shareholding was assessed via Refinitiv Eikon.
Oil Palm Plantations Ltd (Bewani) in Papua New Guinea      Global brands’ exposure to the ENB and RH mills was
(PNG). ENB and RH are operating oil palm plantations       checked using publicly available mill lists published by
in East New Britain Province (ENBP), and Bewani is         the companies themselves.
operating an oil palm plantation in Sandaun (West Sepik)
Province. While there are other palm oil companies
operating in PNG, these three have together deforested     Deforestation analysis
tens of thousands of hectares since 2010, and were         Global Witness used shapefiles for the Rimbunan Hijau
exporting palm oil in 2019, when we began this research.
                                                           and Bewani concessions previously published in our 2017
                                                           report Stained Trade. We derived a shapefile for the ENB
Between 2019-2021, Global Witness researchers met with
                                                           ‘Ili-Wawas’ project drawing from the map included in that
and interviewed local community members and civil
                                                           project’s 2005 Environmental Impact Statement.
society organizations in both provinces. We interviewed
two former oil palm plantation workers in ENBP, and        We used the global forest change 2000-2019
subsequently conducted an extensive investigation          dataset (Hansen/UMD/Google/USGS/NASA) to calculate
into worker health and safety on the Rimbunan Hijau        forest loss within each concession boundary by year,
plantations in Pomio District, ENBP, described below.      using ArcGIS. To ensure the forest lost area was originally
In PNG, and remotely, undercover Global Witness            natural forest, we used images from sources including
researchers carried out multiple covert interviews with    Google Earth, Sentinel 2 and Landsat to check the forest
ENB employees and with a director of Tobar Investment      type of the lost area before deforestation. The vast
Ltd. This report also draws on an interview with           majority of forest loss (ca. ~99%) appeared to be
community members from Gazelle district, ENBP, that        natural forest.
Global Witness researchers conducted in 2017.

Global Witness used ship tracking data accessed via        Worker health and safety incidents
the commercial service MarineTraffic to reconstruct
the voyage of the Chem Peace from PNG to India. We         Acting on tips received from two former employees

Page 54 screenshot
and a community member, Global Witness launched an
investigation into worker health and safety on the RH oil
palm plantations in Pomio District, ENBP. We began by
searching the publicly accessible PNG Office of Workers’
Compensation (OWC database. Under the Workers’

Compensation Act, companies are required to report
workplace accidents and deaths to the OWC. Each such
report is given a unique reference number in a searchable
database. Global Witness found records of seven deaths
and seven accidents that we were able to determine had
happened on RH’s plantations in Pomio.

We then worked with a local community member in
Pomio District to interview accident survivors and/or
their next of kin, and to identify additional incidents. (We
are omitting the name of our local colleague for their
safety.) This process ran between Oct 2020-Feb 2021 and
captured interviews with fourteen survivors or their next
of kin. It produced additional documentation for several
cases we had identified from the OWC database, and
revealed five additional deaths and five additional serious
injuries that Global Witness could substantiate based on

The majority of the injured and deceased workers Global
Witness documented were men. This may reflect the fact
that women more often work in an informal capacity on
palm oil plantations, e.g. as “loose fruit” collectors.

Global Witness has seen and collected copies of
documentation related to these cases including workers’
medical reports; autopsy reports; police reports; worker,
witness, and supervisor statements; insurance forms;
proof of employment, including payslips; and accident
and autopsy photos. We arranged for one worker and the
next of kin of a deceased worker to be interviewed on
video. All interviews were captured in writing with our
interviewer translating from spoken Tok Pisin to English
where necessary. When this report went to publication,
the OWC database was undergoing renovations and
was offline.
Page 55 screenshot
Papua New Guinean health and safety consultancy                                   Table 1. Full-time staff of RH companies operating in
Niugini Environment Management Services (NgEMS)                                   Sigite Mukus, according to annual reports filed with the
reviewed the findings for Global Witness. Principal                               PNG Investment Promotion Authority              .

Tony Aromo has over a decade’s experience in the palm                              Company                    2010            2015           2020
oil sector in PNG and served as a technical expert on                                                         98              98             183
                                                                                   Rimbunan Hijau
the working group developing nationally appropriate
                                                                                   (PNG) Limited
standards for RSPO.1
                                                                                   Sinar Tiasa (PNG)          2               2              2,218
Comparison of fatal accidents,                                                     Gilford Limited            0               20             142
Rimbunan Hijau/New Britain                                                         Niugini Lumber             467             470            268
Palm Oil Limited                                                                   Merchants Limited
                                                                                   Totals                     567             590            2,811
Global Witness compared the fatal accidents we
documented at Rimbunan Hijau’s operations with                                    According to annual company reports filed with the PNG
those at another oil palm company operating in PNG.                               Investment Promotion Authority, the total number of
                                                                                  employees at these four companies combined varied
Four Rimbunan Hijau (RH) companies are working in
                                                                                  between 567-2,811 in the years Global Witness assessed
the group’s “Sigite Mukus” project in Pomio, ENBP:
                                                                                  (2010, 2015, and 2020).
    >   Rimbunan Hijau (PNG) Limited2
                                                                                  In order to compare the fatalities Global Witness
                                        3                                         documented at the Sigite Mukus operation with another
    >   Sinar Tiasa (PNG) Limited
                                                                                  PNG operation of roughly similar size, we looked at
                                                                                  publicly available reports from New Britain Palm Oil Ltd.
    >   Gilford Limited4                                                          (NBPOL). NBPOL, owned by Sime Darby,7 operates six
    >   Niugini Lumber Merchants Limited 5                                        plantations in PNG.8 The company is RSPO certified and
                                                                                  publishes its policies regarding human rights and worker
Because it is unknown how many personnel from each                                health and safety.9
company are entirely devoted to the Sigite Mukus project,
and in order to produce a conservative comparison with                            Of NBPOL’s PNG operations, the Higaturu and Milne Bay
another company’s operations, for the purpose of the                              plantations are closest in size to the largest number of
analysis of fatal accidents undertaken in this report all                         employees calculated for Sigite Mukus (employing 2,325
employees listed as working in annual company reports                             and 3,132 people respectively).10
for all four of these companies were included in the
table below. In 2010, work officially began on the Sigite
Mukus project.6

1      Roundtable on Sustainable Palm Oil (undated). National Interpretations
2 Srinivisan, P. PNG MP responds to allegations of exploitation and abuse in logging industry - Pacific Beat - ABC Radio Australia (2020).
3 Hambloch, C. Land formalization turned land rush: the case of the palm oil industry in Papua New Guinea. Paper prepared for presentation at the “2018
World Bank Conference on Land and Poverty” (2018).
4         Ibid.
5 Tunama, D. An Exploration of the Impact of Oil Palm Development on Women in Pomio, East New Britain Province, Papua New Guinea (2014).
6 Global Witness. Stained Trade: how U.S. imports of exotic flooring from China risk driving the theft of indigenous land and deforestati on in Papua New
Guinea. (2017)
7     Reuters. Malaysia’s Sime Darby completes $1.74 bln New Britain Palm Oil buy. (2015)
malaysias-sime-darby-completes -1-74-bln-new-britain-palm-oil-buy-idUSL4N0W508H20150303
8         New Britain Palm Oil Limited. “Our operations at a glance.”
9        New Britain Palm Oil Limited. “Roundtable on Sustainable Palm Oil and Sustainable Agriculture Network.”
10       New Britain Palm Oil Limited. “A safe and fair workplace.”

                                                                                                                      THE TRUE PRICE OF PALM OIL 55
Page 56 screenshot
 Compared to both of these plantations, there were
 significantly more fatalities at the Rimbunan Hijau
 operation (see Table 2). Over the 2010-2020 time span
 assessed, one worker died at the Higaturu plantation
 and three workers died at the Milne Bay plantation. In
 comparison, 12 people—11 workers and one school-
 aged dependent of a worker—died at the RH operation
 over the same time period, according to Global Witness’s
 analysis of Office of Workers’ Compensation records and
 interviews with survivors conducted in 2020 and 2021.

 Table 2. Fatalities at three PNG oil palm plantation
 operations, 2010-2020.11
  Company                       Employees                 Fatalities
                                (est. in 2020)            2010-2020
  Rimbunan Hijau –               2,811                    12
  Sigite Mukus

  NBPOL - Higaturu               2,325                    1
  NBPOL – Milne Bay              3,132                    3

It is unknown how many hectares (ha) of oil palm have been
planted within the Sigite Mukus project. RH has claimed that
31,000 ha are slated for oil palm.12 However, Global Witness
estimates that ~24,600 ha of forest has been cleared within the
project area. The total amount of palm planted therefore is
unlikely to exceed 24,600 ha, and may be significantly less.

The NBPOL Higaturu and Milne Bay plantations combined had
a total area of 20,459 hectares devoted to oil palm in 2015.13
Combining the fatality rate for these two operations likewise,
the NBPOL operations are still far less lethal on a per-hectare, as
well as a per capita, basis.

 11     NBPOL 2010-2015 data is drawn from New Britain Palm Oil Limited Sustainability Report
 downloads/2016/11/NBPOL-Sustainability-Report-2015-Final-SP.pdf. 2016-2020 data is drawn from: New Britain Palm Oil Limited. “A safe and fair workplace.”
 12 Business Advantage PNG. Spotlight focus on palm oil. (2012)
 13     New Britain Palm Oil Limited Sustainability Report 2014/2015.

Page 57 screenshot

1     UCSUSA (2016). Palm oil.            14 National Geographic Society Photo Ark (undated). Combed Dragon or
2    Reuters (2019). Malaysia’s Mahathir says linking palm oil to                   Indonesian Forest Dragon
deforestation ‘baseless’.              photo-ark/animal/lophosaurus-dilophus/
deforestation-baseless-idUSKCN1VD0CR                                                15   IUCN (2016). Huon Tree Kangaroo (Dendrolagus matschiei). https://
3    Bronsky, J., et al. (2019). Palm Oil and Beta-palmitate in Infant Formula:
A Position Paper by the European Society for Paediatric Gastroenterology,           16     South Pacific Regional Environment Programme. A pocket guide to the
Hepatology, and Nutrition (ESPGHAN) Committee on Nutrition. Journal of              birds of paradise of Papua New Guinea.
Pediatric Gastroenterology and Nutrition: May 2019 - Volume 68 - Issue 5 - p        VirLib/PNG/bird-paradise-birdwatching-pocket-guide.pdf
742-760.            17   Schuiteman, A., Jan Vermeulen, J., De Vogel, E., and A. Vogel (2011).
Beta_palmitate_in_Infant_Formula__A.28.aspx                                         Nocturne for an unknown pollinator: first description of a night-flowering
                                                                                    orchid (Bulbophyllumnocturnum). Botanical Journal of the Linnean Society.
4    Rainforest Action Network (2015). Maruchan responds to pressure in
an instant but its new palm oil commitment falls short.
5     Bito, B. and N. Petit (2016). Final report: toward sustainable agricultural
commodities in Papua New Guinea. Toward Sustainable Agricultural
Commodities in Papua New Guinea (2016)
6    Personal communication, UNDP Papua New Guinea (2020).
7     Mongabay/Hance. J. (2014). Illegal logging makes up 70 percent of
Papua New Guinea’s timber industry.
8    Convention on Biological Diversity (undated). Papua New Guinea.
9    ABC Australia (undated). Charting the Pacific – Places. https://www.
10 See Papua New Guinea Defence Force Core Services (undated).
Maritime Surveillance, Patrol Response
core_services/cs_maritime_patro l.html; and The Commonwealth (undated).
United Kingdom.
11   Papua New Guinea Department of Agriculture and Livestock (2016).
Report on the state of biodiversity for food and agriculture in Papua New
12    Barrows, L.R. et al. (2009). Making the most of Papua New Guinea’s
biodiversity: Establishment of an integrated set of programs that link
botanical survey with pharmacological assessment in “The Land of the
Unexpected.” Pharmaceutical Biology.
13    Convention on Biological Diversity (undated). Papua New Guinea.
Page 58 screenshot
18    Vincent, J.B. et al. note in Forest carbon in lowland Papua New Guinea:
local variation and the importance of small trees (2015). Austral Ecology.
“Forest carbon estimates for PNG have been contentious. Ground-based
forest inventories have produced estimates of lowland rainforest carbon
ranging from 111.34 Mg [megagram] C ha−1 (Bryan et al. 2010a) and
120.8 Mg C ha−1 (Fox et al. 2010) to 169.9 Mg C ha−1 (Bryan et al. 2010b)
whereas estimates from remote sensing ranged 147–153 Mg
C ha−1 (Saatchi et al. 2011). Scaling such variation to the estimated 18.65
million hectares of lowland rainforest in PNG (Shearman & Bryan 2011)
suggests that massive uncertainty is associated with the regional carbon
stock.” GW calculates, based on these ranges and noting that 1 Mg = 1 metric
ton, that the lower bound of lowland rainforest carbon is (111.34 mt C/ha *
18.65 m ha =) 2,076,491,000 mt C and that the upper bound is (169.9 mt
C/ha * 18.65 m ha =) 3,168,635,000 mt C.
19   Conn, B. and K. Damas. Araucaria hunsteinii in Guide to trees of Papua
New Guinea.
20 SIL-Papua New Guinea (undated). Languages of Papua New Guinea.
21     Jubilee Australia, Oakland Institute, and Act Now. From Extraction to
Inclusion (2020).
22    Kik, A. et al. (2021). Language and ethnobiological skills decline
precipitously in Papua New Guinea, the world’s most linguistically
diverse nation. PNAS2021 Vol. 118 No. 22
23    Novotny, V. et al. (2012). The role of paraecologists in 21st
century tropical forest research.
24   Mongabay/Woods, L. E. J. (2019). ‘Beautiful legislation’ fails to protect
PNG’s environment, landowners
25    Chatham House/Lawson, S. (2014). Illegal logging in Papua New Guinea
26    Forest Trends (2006). Logging, legality, and livelihoods in Papua New
Guinea, Volume 1
27 Australian Conservation Foundation and Centre for Environmental Law
and Community Rights (2003). Bulldozing Progress: human rights abuses and
corruption in Papua New Guinea’s logging industry https://pngforests.files.
28    Mongabay/Butler, R.A. (2013). Malaysia has the world’s highest
deforestation rate, reveals Google forest map https://news.mongabay.
29     Guardian Environment Network/Young, T. (2011). Malaysian palm
oil destroying forests, report warns
30    Gabriel, J. and Wood, M. (2015). Rimbunan Hijau in the Forests of
Papua New Guinea. Journal of Pacific History.
31   Sarawak Report (2019). ‘If It’s Not A Profitable Business You Pack Up
And You Leave!’ Papuans Tell Sarawak Loggers https://www.sarawakreport.
32   Oakland Institute (2016). The Great Timber Heist: The Logging Industry
in Papua New Guinea

                                       THE TRUE PRICE OF PALM OIL 57
Page 59 screenshot
33     Global Witness (2017). Stained Trade: how U.S. imports of exotic            56    PNG has ratified the International Labour Organization’s Minimum Age
flooring risk driving the theft of indigenous land and deforestation in Papua      Convention of 1973, which allows children as young as 12 to conduct “light”
New Guinea             work deemed not harmful to their health or schooling. The PNG Employment
trade/                                                                             Act allows children as young as 12 to legally work, but only if they are
34     Hambloch, C. Land formalization turned land rush: the case of the           working in a family-owned business. Papua New Guinea Employment Act
palm oil industry in Papua New Guinea. Paper prepared for presentation             section 103 (2)
at the “2018 World Bank Conference on Land and Poverty” (2018). https://           57    International Labour Organisation (1999). Worst Forms of Labour             Convention
Turned%20Land%20Rush%20Hambloch%202018.pdf                                         ::NO::P12100_ILO_CODE:C182

35     The National (2018). Bewani Oil Palm project all set for first shipment     58      Myzabella, N., et al. (2019). Occupational health and safety in the palm          oil industry: a systematic review. Int J Occup Environ Med; 10(4); 159-173.
36   Bryan, J. and P. Shearman (eds.) (2015). The state of the forests             59   Washington Post/Mason, M. and McDowell, R. (2020) Palm oil labor
of Papua New Guinea                 abuses linked to world’s top brands, banks https://www.washingtonpost.
State%20of%20Forest%20in%20PNG%202014.pdf                                          com/business/palm-oil-labor-abuses-linked-to-worlds-top-brands-
37 Tobar Investment Ltd and Tobar Business Group information accessed              banks/2020/09/24/d51fa282-fed7-11ea-b0e4-350e4e60cc91_story.html
via the PNG Investment Promotion Authority.                                        60     Wide Bay Conservation Association (undated). Balokoma Limited Relog
38   Papua New Guinea Post-Courier/ Umau, P. (2019). East New Britain              Situational Report
Business Grows from Strength to Strength.         Isidor.Kaupan.Pulpul%20situational%20report%202.pdf
new-britain-business-grows-from-strength-to-strength/                              61   Global Witness undercover interview with Michael Paisparea and
39 Tobar Investment Ltd information accessed via the Papua New Guinea              Bernard Lolot (2019)
Investment Promotion Authority.                                                    62    The National (2017). Oil palm industry grows, new project launched
40     Loop PNG/Mou, F. (2017). Lamur plans to rescue Kokopo District                           launched/
                                                                                   63 Global Witness undercover interview with Eng Kwee Tan (2019)
41 Tobar Investment Ltd information accessed via the Papua New Guinea              64     Government of India Ministry of Finance (2017).
Investment Promotion Authority. (                          NotificationNo.50/2017–Customs
42   Papua New Guinea Post-Courier/ Umau, P. (2019). East New Britain              cbec/customs/cs-act/notifications/notfns-2017/cs-tarr2017/cs50-2017.pdf
Business Grows from Strength to Strength.         65    Government of India Ministry of Finance (2018). Notification No.
new-britain-business-grows-from-strength-to-strength/                              29/2018-Customs
43     Pacific Media Watch (2017). O’Neill’s government loses ministers,           cs-act/notifications/notfns-2018/cs-tarr2018/cs29-2018.pdf
Speaker and deputy PM in PNG vote         66    Government of India Ministry of Finance (2020). Notification
44   Bito, B. and N. Petit (2016). Final report: toward sustainable agricultural   customs/cs-act/notifications/notfns-2020/cs-tarr2020/cs43-2020.pdf
commodities in Papua New Guinea. Toward Sustainable Agricultural
                                                                                   67 Comprehensive economic cooperation agreement between the
Commodities in Papua New Guinea (2016)
                                                                                   Government of Malaysia and the Government of the Republic of India (2011).
45     Bernard Lolot Linkedin profile:
                                                                                   68   GST Law India (2018). Social Welfare Surcharge on Imports – A new levy
46   Klopf, S. Private Lands Conservation in Papua New Guinea (2004).              by the Finance Act, 2018
University of Colorado/Colorado Law School Scholarly Commons https://              imports-w-e-f-02-02-2018-a-new-levy-by-the-finance-act-2018/
                                                                                   69    Kolkata Port Traffic chart (6 January 2019)
47      Papua New Guinea Land Act sections 10-12
                                                                                   70   Business Standard News (2016) Ruchi Soya ranked no. 1 food and agri
legis/consol_act/la199648/ and Papua New Guinea Constitution, section 53                            products company in Fortune 500 Report on India’s largest corporations
48   Mongabay/Woods, L. E. J. (2019). ‘Beautiful legislation’ fails to protect     1-food-and-agri-products-company-in-fortune-500-report-on-india-s-largest-
PNG’s environment, landowners
                                                                                   71   ENB Trading & Shipping Pte. Ltd business profile accessed via the
49     Jubilee Australia, Oakland Institute, and Act Now. From Extraction to
                                                                                   Singapore Accounting & Corporate Regulatory Authority
Inclusion (2020).
                                                                                   72    ENBPOL information accessed via the Papua New Guinea Investment
                                                                                   Promotion Authority.
50     Papua New Guinea Land Act section 4, 10
legis/consol_act/la199648/                                                         73    Reuters/Chu, M.M. (2020) Palm oil prices to climb 17.9% in 2020 on tight
                                                                                   supplies, biodiesel programs: Reuters poll
51   Mongabay/Woods, L. E. J. (2019). ‘Beautiful legislation’ fails to protect
PNG’s environment, landowners
beautiful-legislation-fails-to-protect-pngs-environment-landowners/                74 Historical exchange rates accessed via
                                                                                   75     UN Comtrade Database
52   Lattas, A. (2014). Land, environment & violence: the high cost of
logging in Pomio.            76    Bio of Paranjoy Guha Thakurta (undated).
violence-the-high-cost-of-logging-in-pomio.html                                    77    Copyright 2020, S&P Global Market Intelligence (and its affiliates as
53   World Resources institute (2013). Papua New Guinea Forest Legality            applicable). All rights reserved.                      78      Copyright 2020, S&P Global Market Intelligence (and its affiliates as
54     Transparency International (2020). Corruption Perceptions Index             applicable). Reproduction of any information, opinions, views, data or                                 material, including ratings (“Content”) in any form is prohibited except
55     Interview with Mr Michael Paisparea and Mr Bernard Lolot, on file with      with the prior written permission of the relevant party. Such party, its
Global Witness.                                                                    affiliates and suppliers (“Content Providers”) do not guarantee the accuracy,
                                                                                   adequacy, completeness, timeliness, or availability of any Content and
                                                                                   are not responsible for any errors or omissions (negligent or otherwise),

Page 60 screenshot
regardless of the cause, or for the results obtained from the use of such          103 Global Witness (2020). Strengthening corporate responsibility https://
Content. In no event shall Content Providers be liable for any damages,  
costs, expenses, legal fees, or losses (including lost income or lost profit and   responsibility-uk-briefing/
opportunity costs) in connection with any use of the Content. A reference to       104 NEPCon (2017). Timber Legality Risk Assessment: Papua New Guinea
a particular investment or security, a rating or any observation concerning
an investment that is part of the Content is not a recommendation to buy,          TIMBER-PapuaNewGuinea-Risk-Assessment-EN-V1.1.pdf
sell or hold such investment or security, does not address the suitability of
                                                                                   105 Radio New Zealand/Blades, J. (2017). New minister aims to clean
an investment or security and should not be relied on as investment advice.
                                                                                   up corrupt PNG Lands Dept
Credit ratings are statements of opinions and are not statements of fact.
79    Email from RPNGC to Global Witness (2020).
                                                                                   106 ENBPOL charge document on file with Global Witness.
80    ABC News/Tlozek, E. (2017). PNG deports Catholic missionary assisting
                                                                                   107 Maybank (2013). Key business entities
locals with logging legal fight
                                                                                   108 ENBPOL charge document on file with Global Witness.
81    Global Witness interview with Doug Tennent (2019).
                                                                                   109 Chicago Tribune/Mason, M. and McDowell, R. (2020). Palm oil is a big
82    ABC News/Tlozek, E. (2017). PNG deports Catholic missionary assisting
                                                                                   business and virtually impossible to avoid. The workers who cultivate it are
locals with logging legal fight        abused.
deports-catholic-missionary-over-logging-legal-fight/8615042                       worker-abuse-20201121-q2grzchac5b2hg57gnww4dex7m-story.html
83    Lattas, A. (2014). Land, environment & violence: the high cost of            110 Profundo and Tuk Indonesia (2018). Maybank: the single largest
logging in Pomio.
                                                                                   palm oil financier
violence-the-high-cost-of-logging-in-pomio.html                                    largest_palm_oil_financier/maybankreportenglish210218.pdf
84 Roman Catholic Archdiocese of Rabaul v Sam [2019] PGNC 427; N8145               11 1 I bid.
(29 November 2019)                112 Maybank Sustainability Report 2020 https://maybankfoundation.
PGNC/2019/427.html?stem=&synonyms=&query=archdiocese                               com/index.php/media-center/sustainability-reports?task=calleleme
85 Archdiocese of Rabaul (2020). The matter of Putput. Accessed                    nt&format=raw&item_id=323&element=8956f649-9a99-4a73-bcaa-
via                   09214efe8e5e&method=download
                                                                                   113 Maybank shareholders report accessed via Refinitiv on 13 June 2021
86    Email from Doug Tennent to Global Witness (2020).                            114 MarketWatch/Beals, R.K. (2020). World’s largest asset manager
87    Email from RPNGC to Global Witness (2020).                                   BlackRock joins $41 trillion climate-change investing pact https://www.
88   Bryan, J. and P. Shearman (eds.) (2015). The state of the forests of
Papua New Guinea.                   trillion-climate-change-investing-pact-2020-01-09
State%20of%20Forest%20in%20PNG%202014.pdf                                          115 Sovereign Wealth Fund Institute (undated). Top 100 Largest Sovereign
                                                                                   Wealth Fund Rankings by Total Assets
89   BirdLife (2018). Are we too late to save the elusive birds of this Papua
New Guinea island?             rankings/sovereign-wealth-fund
late-save-secretive-birds-papua-new-guinea-island                                  116 (2020) Robeco profile
90    Ibid.                                                                        company/robeco/

91     PNGi Forest Portal (2020). Retrieved June 2021 from https://                117 Pyrford International Ltd (2009). Disclaimer                                                                    pyrford/disclaimer
92            WWF (undated). Responsible purchasing         118 CalPERS (2019). CalPERS’ governance-and-sustainability-principles
discover/our_focus/food_practice/sustainable_production/palm_oil/respon -
sible_purchasing/                                                                  sustainability-principles.pdf
93           Roundtable on Sustainable Palm Oil (2021). Impact https://rspo.       119 Robeco (2020). Sustainable Investing Memberships, Statements,
org/impact                                                                         and Principles
94           Roundtable on Sustainable Palm Oil (undated). About RSPO              memberships.pdf
95           Roundtable on Sustainable Palm Oil (undated) RSPO Supply              120 Robeco (2021). Exclusion Policy Robeco
Chains                                docm/docu-exclusion-policy.pdf
96 Mongabay/Jong, H.N. (2019). RSPO adopts total ban on deforest-                  121 Friends of the Earth/Profundo (2020). Doubling down on deforestation
ation under sweeping new standards    
                                                                                   122 BlackRock’s Big Problem (2020). In surprise move, BlackRock votes for
97           Greenpeace (2021). Destruction: Certified -
                                                                                   Procter & Gamble to disclose on deforestation https://blackrocksbigproblem. -certified/
98           Environmental Investigation Agency UK Ltd and Grassroots              com/in-surprise-move-blackrock-votes-for-procter-gamble-to-disclose-on-
(2015). Who Watches the Watchmen? Auditors and the breakdown of                    deforestation/
oversight in the RSPO               123 Amazon Watch (2021). Investing in Amazon Crude II https://
99           Greenpeace (2021). Destruction: Certified -         124 Puipui v Pat [2016] PGNC 326; N6538 (25 August 2016). Accessed -certified/                  19 August 2020 at
100           Ibid.                                                                PGNC/2016/326.html?stem=&synonyms=&query=east%20new%20
101 Inside Climate News/Gustin, G. (2019). Industrial Agriculture, an              britain%20palm%20oil
Extraction Industry Like Fossil Fuels, a Growing Driver of Climate Change          12 5 I bid.            12 6 I bid.
102 Global Witness (2021). The EU needs to hold the financial sector to
account if it is to end its complicity in global deforestation https://www.

                                                                                                                            THE TRUE PRICE OF PALM OIL 59
Page 61 screenshot
      127 PNGexposed (2016). Malaysian company destroying cocoa blocks and            publication/279942791_The_Rimbunan_Hijau_Group_in_the_Forests_of_
      evicting landholders in East New Britain https://pngexposed.wordpress.          Papua_New_Guinea
      com/2016/03/16/malaysian-oil-palm-company-destroying-cocoa-blocks-              149 The National (2016). The Stanley a class of Hotel – its own https://www.
      128 The World Bank (updated 2021). Development Projects PNG Productive
                                                                                      150 SGS (2021). Log export monitoring monthly report December 2020 to
      Partnerships in Agriculture - P110959        the Papua New Guinea Forestry Authority.
                                                                                      151 Global Witness (2017). Stained Trade: how U.S. imports of exotic
      129 The United Nations defines forced evictions as ““the permanent
                                                                                      flooring risk driving the theft of indigenous land and deforestation in Papua
      or temporary removal against their will of individuals, families and/or         New Guinea.
      communities from the homes and/or land which they occupy, without the           trade/
      provision of, and access to, appropriate forms of legal or other protection”.
                                                                                      152 PNGi (2019). Rimbunan Hijau abuses court system to deny landowners
      130 Puipui v Pat [2016] PGNC 326; N6538 (25 August 2016). Accessed              to-deny-landowners-justice
      19 August 2020 at
                                                                                      153 Australian Conservation Foundation and Centre for Environmental Law
                                                                                      and Community Rights (2003). Bulldozing Progress: human rights abuses and
                                                                                      corruption in Papua New Guinea’s logging industry. https://pngforests.files.
       131 PNG Report (2015). New mill for ENB palm oil https://www.pngreport.
      com/png/news/1110796/new-mill-for-enb-palm-oil                                  pdf
      132 The Star (2015). CBIP wins RM60mil deal to supply another mill in PNG       154 Global Witness (2017). Stained Trade: how U.S. imports of exotic              flooring risk driving the theft of indigenous land and deforestation in Papua
      wins-rm60mil-deal-to-supply-another-mill-in-png                                 New Guinea.
      133 Puipui v Pat [2016] PGNC 326; N6538 (25 August 2016). http://               trade/                         15 5 I bid.
                                                                                      156 Radio New Zealand (2018). PNG villagers count huge cost of damage
      134 Charge document on file with Global Witness.                                from logging
      135 Global Witness (2017). Stained Trade: how U.S. imports of exotic            villagers-count-huge-cost-of-damage-from-logging
      flooring risk driving the theft of indigenous land and deforestation in Papua   157 Communities of Atu, Bairaman, Gugulena, Kaiton, Lau, Malmaltalie,
      New Guinea.         Manginuna, Mauna, Meinge, Mu, Polo, Pomai, Porosalel, Puapal, Rano,
      trade/; Hambloch, C. Land formalization turned land rush: the case of the       Rovan, and Tontongpal (2018). West Pomio Community Damage Assessment
      palm oil industry in Papua New Guinea. Paper prepared for presentation
      at the “2018 World Bank Conference on Land and Poverty” (2018). https://        Community%20Damage%20Assessment.pdf          158 Myzabella, N., et al. (2019). Occupational health and safety in the palm
      Turned%20Land%20Rush%20Hambloch%202018.pdf                                      oil industry: a systematic review. Int J Occup Environ Med; 10(4); 159-173.
      136 Radio New Zealand (2019). PNG govt told to act now https://www.rnz.       159 Al Jazeera (2020). Rape, abuses in palm oil fields linked to top cosmetic
      137 Papua New Guinea Today (2019). PNG Government must publish full             brands: AP
      list of SABL Lease            palm-oil-fields-linked-to-top-cosmetic-brands-ap
      must-publish-full-list.html                                                     160 Roundtable on Sustainable Palm Oil (undated). National
      138 Earthsight (2017). Papua New Guinea’s government resurrects zombie          Interpretations
      ag licenses            161 Global Witness interview with Mr Felix Tau (2021).
                                                                                      162 Oakland Institute (2016). The Great Timber Heist: The Logging Industry
      139 Act Now/War on Want (2018). The SABL landgrab: Papua New Guinea’s           in Papua New Guinea
      ongoing human rights scandal         logging-industry-papua-new-guinea
      SABL_PNG_LANDGRAB.pdf                                                           163 Filer, C. with J. Numapo. In Kastom, property, and ideology: land
      140 Global Witness (2017). Stained Trade: how U.S. imports of exotic            transformations in Melanesia
      flooring risk driving the theft of indigenous land and deforestation in Papua   state-society-and-governance-melanesia/kastom-property-and-ideology
      New Guinea.         164 Page, B., and S. Lord (undated). The Oil Palm Industry’s approach to
      trade/                                                                          the use of pesticides in Papua New Guinea
      14 1 I b id .                                                                   content/uploads/downloads/2011/02/Pesticides_in_Papua_New_Guinea.pdf

      142 Filer, C. with J. Numapo. In Kastom, property, and ideology: land           165 Bradberry, S., Proudfoot, A.T., and J.A. Vale (2004). Glyphosate
      transformations in Melanesia      poisoning. Toxicol Rev.
      state-society-and-governance-melanesia/kastom-property-and-ideology             166 Centers for Disease Control and Prevention (2018). Facts about
      143 Rimbunan Hijau Group (undated). Executive Chairman’s Profile &              Paraquat
      Sharing        167 United States Environmental Protection Agency (undated). Paraquat
      144 Rimbunan Hijau Group (undated). Forestry - Upstream & Downstream            Dichloride: One Sip Can Kill
      Timber Operations                paraquat-dichloride-one-sip-can-kill
      downstream-timber-operations/                                                   168 Global Witness interview with Mr Felix Tau (2021).
      145 Rimbunan Hijau Group (undated). About Us          169 Papua New Guinea Employment Act, section 121 http://www.
      146 Bloomberg Markets (undated). Rimbunan Hijau Group -                         html?stem=&synonyms=&query=employment%20act
      Company Profile and News                     170 NiuGini Environment Management Services (2021). Palm oil producer
      company/2266745Z:MK                                                             safety and health review prepared for Global Witness.
      147 Forbes (2021). Tiong Hiew King & family

     148 Gabriel, J. and Wood, M. (2015). Rimbunan Hijau in the Forests of
     Papua New Guinea. Journal of Pacific History

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171 Food and Agriculture Organization of the United Nations (1999).          199 The World Bank (2018). Papua New Guinea clean water access to end
Guidelines for the management of small quantities of unwanted and             the walk for water for women and girls
obsolete pesticides            feature/2018/03/20/papua-new-guinea-clean-water-access-to-end-the-walk-
obsolete_pesticides/docs/small_qties.pdf                                     for-water-for-women-and-girls
172 Global Witness interview with Mr Felix Tau (2021).                       200 Notice for registration of charge on file with Global Witness.
173 Global Witness interview with Lawrence Lapuli (2021).                    201 Global Witness (2017). Stained Trade: how U.S. imports of exotic
174 Anton Kelal witness statement, on file with Global Witness.
175 Anton Kelal death certificate, on file with Global Witness.               trade/
                                                                             flooring risk driving the theft of indigenous land and deforestation in Papua
                                                                             New Guinea.
176 Global Witness interview with Lawrence Lapuli (2021).                       202 Kina Securities Ltd (2020). Investor Centre https://investors.kinabank.
177 Charles Sai medical records, on file with Global Witness.      
178 Global Witness interview with Charles Sai (2020).                        20 3 I bid.
179 Cedars-Sinai (undated). Burst Fracture     204 OCBC (2021). Group Business Overview
health-library/diseases-and-conditions/b/burst-fracture.html                 about-us/group-business
180 Papua New Guinea Workers Compensation Act, sections 42 and 45            205 OCBC (2021). Being environmentally and socially responsible            
181 Global Witness interview with Anthony Salmang (2019). Global
Witness has previously documented downstream pollution from logging and      20 6 I bid.
clearance activities at other sites in Papua New Guinea.                     20 7 I bid.
182 Mongabay/Gaworecki, M. (2016). Papua New Guinea activist                 208 OCBC (undated). OCBC’s ESG Risk Assessment Process https://www.
receives prestigious award for protecting forests https://news.mongabay.
com/2016/10/papua-new-guinea-activist-receives-prestigious-award-for         risk%20assessment%20process.pdf
protecting-forests/                                                           209 RHB Bank (2021). Group Corporate Structure https://www.rhbgroup.
183 The National (2019). Plans in place to upgrade Pomio airstrip https://   com/files/others/about-us/RHB%20Bank_Grp%20Corp%20Structure.pdf             210 RHB Bank (2020). Building a sustainable future: our approach to
184 Email from Paul Pavol to Global Witness (2020).                           sustainability
185 Global Witness interview with Anthony Salmang (2019).                    Our_Approach_to_Sustainability__Mar_2020__v3__1_.pdf
186 Sarawak Report (2020). Malaysian Colonialism in Papua New Guinea         21 1 I bid.                                  212 RHB Bank Berhad and OCBC Bank shareholder reports accessed via
187 Global Witness interview with Anthony Salmang (2019).                    Refinitiv, June 2021
188 Mongabay/Hance, J. (2012). Police hired by loggers in Papua              213 Global Witness (2019). Money to Burn: how iconic banks and investors
                                                                             fund the destruction of the world’s largest rainforests https://www.
New Guinea lock locals in shipping containers https://news.mongabay.
shipping-containers/                                                         and-investors-fund-the-destruction-of-the-worlds-largest-rainforests/
189 Independent fact finding mission (2013). Investigation of police         214 Global Witness (2020). Beef, Banks and the Brazilian Amazon https://
brutality – West Pomio, ENBP https://pngexposed.files.wordpress.   
com/2014/11/investigation-of-police-brutality-west-pomio.pdf                 amazon/
190 Ibid.                                                                    215 BlackRock (2021). BlackRock Investment Stewardship Global Principles
191 NBC News PNG (2020). Manning stops police at logging sites https://      investment-engprinciples-global.pdf
sites-all-police-personnel-operating-at-logging-/1038257933194460/            216 Norges Bank Investment Management (2021). Climate change https://
192 The Guardian/Doherty, B. (2020). Papua New Guinea police accused of      to-companies/climate-change/
gun running and drug smuggling by own minister https://www.theguardian.
com/world/2020/sep/18/papua-new-guinea-police-accused-of-gun-running          217 Amazon Watch (2020). Complicity in Destruction https://amazonwatch.
and-drug-smuggling-by-own-minister                                           org/assets/files/2020-complicity-in-destruction-3.pdf
193 Colgate-Palmolive (undated). About Us https://www.colgatepalmolive.      218 Norges Bank Investment Management (2020). Responsible Investment
com/en-us/about                                                              Government Pension Fund Global
194 Tunama, D. (2014). An Exploration of the Impact of Oil Palm              web.pdf
Development on Women in Pomio, East New Britain Province, Papua New
Guinea                          219 BSP Financial Group Limited (2021). BSP shareholders approve
                                                                              company name change to BSP Financial Group Limited https://www.bsp.
195 Mongabay/Cannon, J. (2020). Gender-based violence shakes       
communities in the wake of forest loss    approve-company-name-change-to-bsp-financial-group-limited/
                                                                              220 PNG security interest # 1003795383, on file with Global Witness.
196 The World Bank (2013). Women in Papua New Guinea to Play Stronger
Role in Agriculture    221 BSP shareholder report accessed via Refinitiv, June 2021.
women-in-papua-new-guinea-to-play-stronger-role-in-agriculture                222 International Finance Corporation (2021). About IFC https://www.
197 Mikhailovich, K., Pamphilon, B., Chambers, B., Simeon, L.,      
and J. R.Zapata (2016). Exploring the lives of women smallholder             about+ifc_new
farmers in Papua New Guinea through a collaborative mixed methods            223 PNG Sustainable Development Program Limited (undated). Our Focus
approach; Cogent Social Sciences  
full/10.1080/23311886.2016.1143328                                           224 FTI Consulting (2019). Illicit Tobacco in Papua New Guinea https://
198 The World Bank (undated). Water Supply and Sanitation          
Development Project (P155087)

                                                                                                                      THE TRUE PRICE OF PALM OIL 61
Page 63 screenshot
225 Pacific Islands Report (2014). Smuggling Between PNG,                       247 PNG Plantations Development information accessed via the PNG
Indonesia Becoming ‘Lucrative’                         Investment Promotion Authority.
articles/2014/04/22/smuggling-between-png-indonesia-becoming-                   248 Chain Reaction Research (2019). The Chain: Bewani Oil Palm Plantation
%E2%80%98lucrative%E2%80%99                                                     Divestment Increases Risks of Continued Deforestation in Palm Oil Supply
226 The Guardian (2021). From a forest in Papua New Guinea to a floor in        Chains
Sydney how China is getting rich off Pacific timber https://www.theguardian.    plantation-divestment-increases-risks-of-continued-deforestation-in-palm-
com/world/2021/jun/01/from-a-forest-in-papua-new-guinea-to-a-floor-in-          oil-supply-chains/
                                                                                249 Bewani Oil Palm Plantation Limited information accessed via the PNG
227 PNGi Forest Portal (2020). Retrieved June 2021 from https://                Investment Promotion Authority.
                                                                                250 Bewani Oil Palm Plantation Limited information accessed via the PNG
228 Ibid.                                                                       Investment Promotion Authority.
229 Chain Reaction Research (2019). The Chain: Bewani Oil Palm Plantation       251 Ocean Paradise Ltd filing accessed via the PNG Investment Promotion
Divestment Increases Risks of Continued Deforestation in Palm Oil Supply        Authority.
                                                                                252 Bewani Oil Palm Plantations Ltd (2019). Announcements https://boppl.
                                                                                253 Bewani Forest Products shareholders report from the Papua New
230 Bewani Oil Palm Plantation Ltd information accessed via the Papua
New Guinea Investment Promotion Authority.                                      Guinea Investment Promotion Authority.

231 Singh, U. (2018). Company owned by Malaysians clearing PNG forests          254 Ocean Paradise Ltd information accessed via the Papua New Guinea                                     Investment Promotion Authority.
                                                                                255 Operations in Plantations – Boppl
232 Greenpeace (2018). The final countdown
palm-oil/                                                                       256 Bewani Forest Products shareholders report accessed via the PNG
                                                                                Investment Promotion Authority.
233 The Edge Markets (2019). East, Prosper group UMB’s largest
shareholders           257 Ocean Paradise Sdn. Bhd. corporate information report accessed via
group-umbs-largest-shareholders                                                 the Malaysian Companies Commission.

234 Far East Holdings Berhad (2020). Company profile http://cms.                258 Prime Horizon Limited information accessed via the PNG Investment                                                  Promotion Authority.

235 CI Resources Ltd (2015).          259 Tago Maritime Services information accessed via the PNG Investment
236 CI Resources Ltd (2015). Directors           Promotion Authority.
corporate/directors.phtml                                                       260 Tago Maritime Services Ltd Foreign Enterprise Certificate accessed via
237 Surfing Association of Papua New Guinea (2021). Vanimo http://www.          the PNG Investment Promotion Authority.                                                     261 The Hershey Company (2020). July through December 2020 Palm Oil
                                                                                Traceability - Mill listing
238 The New York Times/Chandler, J. (2018). Papua New Guinea Is Rich in
Resources but Poor in Health
asia/papua-new-guinea-apec-polio-health-crisis.html                             262 Cargill (2020). Cargill Global Mill List ‐ Quarter 4, 2020 https://www.
239 Global Witness (2017). Stained Trade: how U.S. imports of exotic
flooring risk driving the theft of indigenous land and deforestation in Papua   263 Colgate-Palmolive (2020).
New Guinea.         dam/cp-sites/corporate/corporate/en_us/corp/locale-assets/pdf/colgate-
trade/                                                                          palmolive-list-of-mills-2020h1.pdf

240 Chain Reaction Research (2018). The Chain: Bewani oil palm mill in PNG      264 Danone (2019). Palm oil suppliers & mills list https://www.danone.
may supply the palm oil leakage market       com/content/dam/danone-corp/danone-com/investors/en-sustainability/
the-chain-bewani-oil-palm-mill-in-png-may-supply-the-palm-oil-leakage -         en-policies/business-for-inclusive-growth/supply-chain/danone-palm-oil-
market/                                                                         suppliers-mills-list-update-2019-h2.pdf
241 Unattributed (2018). Far East Holdings Berhad Monitoring report             265 Kellogg (2019). Mill list 2019
December 2018               download/Kellogg+Mill+List+2019.pdf
East%20Holdings%20December%202018.pdf                                           266 Nestlé (2019). Nestlé supply chain disclosure: palm oil https://www.
242 Greenpeace (2018). The final countdown
international/publication/18455/the-final-countdown-forests-indonesia-          267 RB (2020). RB overall master mill list 2020
palm-oil/                                                                       media/8883/rb-overall-master-mill-list-2020_external-final.pdf
243 Chain Reaction Research (2019). The Chain: Bewani Oil Palm Plantation       268 RB (undated). Our Brands
Divestment Increases Risks of Continued Deforestation in Palm Oil Supply
                                                                                269 Consumer Goods Forum (2021). Who We Are https://www.
oil-supply-chains/                                                              270 Global Witness (2020). A letter to the Consumer Goods Forum https://
244 Mighty Earth (2019). The worst company in the world http://www.
                                                                                271 Ibid.
245 Unilever (2021). Palm Oil Grievance Tracker
Images/unilever-palm-oil-grievance-tracker_tcm244-530071_en.pdf                 272 PZ Cussons (2020). Discover Brands
246 Chain Reaction Research (2019). The Chain: Bewani Oil Palm Plantation
Divestment Increases Risks of Continued Deforestation in Palm Oil Supply        273 PZ Cussons (2020). PZ Cussons Palm Oil Mill List – December 2020
plantation-divestment-increases-risks-of-continued-deforestation-in-palm-       2020-Mill-List-Final-Public-Version_FV.pdf

Page 64 screenshot
274 Grupo Bimbo (2014). Grupo Bimbo, Largest Bakery in the World,                298 Rainforest Action Network (2010). Cargill’s problem with palm oil: a
Signs Agreement with Invenergy for 100 Percent Renewable Energy for              burning threat in Borneo
U.S. Operations                cargills_problems_with_palm_oil_low.pdf
grupo-bimbo-largest-bakery-world-signs-agreement-invenergy-100-percent-          299 Cargill (2019). Cargill policy on sustainable palm oil https://www.cargill.
275 Grupo Bimbo (2019). Mill list on file with Global Witness.
                                                                                 300 Mewah Group (2006). About us
276 Mewah Oils Sdn Bhd. Sustainability and traceability report (2019).
                                                                                 301 Mewah Oils Sdn Bhd. (2020). Year of 2020 CPO Traceability to               Mill Declaration Document
sustainability/sustainable_supply_chain/traceability_dashboard_                  Sustainability/MOSB_CPO%20Traceability%20to%20Mill%20Declaration%20
attachments_2h2019/mewah_oils_sdn_bhd.pdf; also see Neste (undated).             Document.pdf and Mewah Oleo Industries Sdn. Bhd. (2020). 2020 CPKO
PFAD residue from palm oil refining          Traceability to Mill Declaration Document
products/raw-materials/pfad-residue-palm-oil-refining                            Sustainability/MOIPG_Imported%20CPKO%20Traceability%20to%20Mill%20
277 Mewah Group (2020). Our company                  Declaration%20Document.pdf
278 Mewah Oils Sdn Bhd. (2020). Year of 2020 CPO Traceability to                 302 Mewah Group (undated). Sustainable palm oil policy http://
Mill Declaration Document            
Sustainability/MOSB_CPO%20Traceability%20to%20Mill%20Declaration%20              Sustainable%20Palm%20Oil%20Policy.pdf
Document.pdf and Mewah Oleo Industries Sdn. Bhd. (2020). 2020 CPKO
                                                                                 303 Mewah Group (2006). About us
Traceability to Mill Declaration Document
Sustainability/MOIPG_Imported%20CPKO%20Traceability%20to%20Mill%20               304 Mewah Oils Sdn Bhd. Sustainability and traceability report (2019).
279 AAK (undated). Worldwide
280 AAK (2021). Mill list
                                                                                 305 Neste (undated). PFAD residue from palm oil refining https://www.
281 Stratas Foods LLC (2021). History              refining
history                                                                          3 0 6 I bi d.
282 ADM Stratas (2019). Stratas Palm Oil Supply Chain Traceability July          307 Neste (undated). Supplier requirements
2019 – September 2019        sustainability/sustainable-supply-chain/supplier-requirements
                                                                                 308 Neste (undated). Protecting biodiversity and forests https://www.neste.
283 Cargill (undated). Cargill Global Mill List ‐ Quarter 4, 2020 https://www.
                                                                                 309 Neste (undated). Neste Responsible Sourcing (Principle) https://www.
284 The Business Journals/McCoy, D. (2020). Cargill loses top spot on
Forbes private companies list to Koch Industries https://www.bizjournals.        managing_sustainability/neste_responsible_sourcing_principle_0.pdf
                                                                                 310 Colgate-Palmolive (2020).
285 Nestlé (undated). What is Nestlé doing to ensure palm oil is sourced         dam/cp-sites/corporate/corporate/en_us/corp/locale-assets/pdf/colgate-
sustainably?           palmolive-list-of-mills-2020h1.pdf
                                                                                 311 Statista (2021). Brands of toothpaste ranked by number of users in
286 Food Navigator/Southy, F. (2019) Nestlé and Mondelēz respond to              Great Britain from 2018 to 2020
Greenpeace palm oil report on fires in Indonesia https://www.foodnavigator.      leading-brands-of-toothpaste-in-the-uk/
oil-report-on-fires-in-Indonesia                                                 312 Colgate-Palmolive (2020). CL Investor Presentation https://investor.
287 The Hershey Company (undated). Palm Oil Facts https://www.
                                                                                 313 Earthworm Foundation (undated). Member Handbook: A guide to
                                                                                 working with Earthworm Foundation
288 The Hershey Company (2020). January through June 2020 Palm Oil
Traceability - Mill listing, on file with Global Witness.                        314 Earthworm Foundation (2019). Deeper deforestation insights pave
                                                                                 the way for accelerating the fight against deforestation and call for greater
289 RB (undated). Brands that touch people’s lives https://www.reckitt.          company action - Earthworm
com/brands/                                                                      earthworm-foundation-deeper-deforestation-insights-pave-the-way-for-
290 RB (2020). RB overall master mill list 2020         accelerating-the-fight-against-deforestation-and-call-for-greater-company-
media/8883/rb-overall-master-mill-list-2020_external-final.pdf                   action

291 RB (2019). Protecting ecosystems across our value chain https://www.         315 See for instance -                   palmolive, and https://www.
292 Ibid.                                                              
293 AAK (2021). Mill list         316 Earthworm Foundation (undated). Member Handbook: A guide to
aak-public-mill-list-april-2021.pdf           working with Earthworm Foundation
a5bb91b203604ee2bae695050414fd15/aak-public-mill-list-sept-2020.pdf              files/earthworm-member-handbook.pdf
294 AAK (undated). Better sourcing of palm                    317 Companies’ membership dates are listed on their individual pages on
sustainability/responsible-sourcing/responsible-sourcing-of-palm/                  Earthworm’s website, e.g.
295 AAK (2018). AAK group policy: sustainable palm oil https://www.              318 Customs documents on file with Global Witness           319 Chain Reaction Research (2018). The Chain: Bewani oil palm mill in PNG
sustainable-palm-oil.pdf                                                         may supply the palm oil leakage market
296 Chain Reaction Research (2019). AAK lags in implementation of NDPE           the-chain-bewani-oil-palm-mill-in-png-may-supply-the-palm-oil-leakage -
best practices             market/
                                                                                 320 GS Global (2018). CEO’s message
297 Mighty Earth (2019). The worst company in the world http://www.              Business/Greeting.aspx
                                                                                 321 GS Global (undated). Investor Relations - Financial Statements http://

                                                                                                                           THE TRUE PRICE OF PALM OIL 63
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ISBN: 978-1-911606-57-4
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