GVL Status Report to RSPO re complaint by A-Bloteh Butaw District, Sinoe,

Quarter 4 Year 2015

Prepared by Golden Veroleum (Liberia), Inc.

2015-11-30 CONFIDENTIAL 1 Contents

1. Summary of key events 2. Community engagement and GVL development status 3. Complaints status: Butaw 4. Other Complaints 5. Conclusion and next steps

2015-11-30 CONFIDENTIAL 2 1. Summary of Key Events

2015-11-30 CONFIDENTIAL 3 Summary of Key Events (Q3/4 2015): 1/2

Date Event Details Status

19 Sep 2015 RSPO Complaints Panel (CP) Ref to RSPO Complaints GVL accepts RSPO Final issues Final Decision on GVL Website. Decision. Sent proposed Complaints. action plan on 26 Oct 2015 24 Sep 2015 RSPO meeting with NGOs, Proposed Palm Oil Advisory NGOs rejected proposal. CSOs, Govt, Growers in Committee to address local Growers agreed to discuss Monrovia. issues including complaints. further. 24 Sep 2015 BWDA and A-Bloteh issue Letter published on the RSPO Under consideration by RSPO Complaint Withdrawal letter to website. CP. RSPO. 25 Sep 2015 RSPO explains CP Final Objections raised by some RSPO requested Decision to complainants and parties (Green Advocates, complainants to provide stakeholders. Global Witness). feedback on decision. GVL Expression of progress by has not heard of any some parties (SESDev). feedback from RSPO. 9 Oct 2015 Butaw Community offered Documents forwarded Discussions ongoing, pending additional land to GVL separately to RSPO. RSPO lifting of stop-work order. 13-14 Oct 2015 GVL participates in SDI/FPP Information and knowledge FPIC Workshop for NGOs. sharing. Oct 2015 GVL meetings with FPP (Tom Updates on developments in To continue when FPP comes Lomax, Chris Kidd) in Liberia. the field. back to Liberia in Feb 2016.

2015-11-30 CONFIDENTIAL 4 Summary of Key Events (Q3/4 2015): 2/2

Date Event Details Status

26 Oct 2015 GVL submits action plan and Ref to RSPO Complaints Actions ongoing. Waiting for response to CP Final Website. decision on Butaw Complaint Decision. Withdrawal and lifting of Stop Work order from RSPO CP. Oct 2015 GVL awards contract to Work commencing in Dec perform ESIA and HCVA for 2015. GVL NGO Network potential areas in Grand Kru informed and encouraged to to Daemeter and Green work proactively with relevant Consulting. communities. 7 Nov 2015 Butaw and Murrysville Declaration submitted GVL continues to engage but Communities declare separately to RSPO. will not be able to proceed establishment of Joint pending RSPO decision on Committee to engage GVL to Butaw Stop Work order and offer land for development. official resolution of boundary dispute between Butaw and Murraysville communities. 14 Nov 2015 Butaw community meets with Notes of meeting submitted Next steps pending RSPO CP GVL senior management. separately to RSPO. decision on Stop Work order Makes formal apology for May and acceptance of Butaw 26 riots and requested update Complaint Withdrawal. on status of withdrawal of Regular engagement with complaint. GVL also community continues. apologised for past mistakes. UNMIL present and sent summary of meeting to RSPO.

2015-11-30 CONFIDENTIAL 5 2. Community Engagement and GVL Development Status

2015-11-30 CONFIDENTIAL 6 Sinoe Communities Engagement (West-1)

Community working Status Change from with GVL Previous Update Butaw GVL had continued working with Abloteh and the Butaw Youth Association (BYA) in Updated accordance with the agreements reached in Feb 2015 as part of the ongoing process to resolve the complaint submitted by the community to RSPO in September 2012.

On on 26 May 2015 BYA organized a petition and protest about the lack of progress implementing the February 2015 agreement and the resulting lack of new employment opportunities. The protest turned violent, through a attack by estimated 35-40 persons on the 4- 5 unarmed policemen, United Nations staff, government officials and GVL employees. The attack resulted in property damage, limited looting by the attackers, and seriously hurt two GVL employees who at current time are not yet recovered and can not return to work.

The attack effectively put a stop to progress. After suspending operations in Butaw, GVL then began to recall workers in July 2015 on community and Government request and the Butaw farm is now running normally. Workers in excess of the natural employment level unfortunately had to be laid off. The school and clinic are again running normally. GVL has requested the Liberian National Police to maintain a presence.

GVL and the Butaw community recommenced direct dialogue in July 2015. The Butaw community suspended Abloteh and the BYA, and appointed the Butaw Welfare and Development Association (BWDA), represented by senior members of the community, to enter dialogue with GVL. Over an intensive three month process, many key issues were discussed.

On 25 September 2015, Abloteh and BWDA on behalf of the community submitted a complaint withdrawal letter to RSPO personnel then visiting Liberia. In October 2015, they submitted a proposal offering further land to GVL. The Butaw and Murrysville communities have now agreed to discuss boundary issues which were the principal cause of delay in implementing the February 2015 resolution. GVL as reiterated both its commitment to the Butaw community and its willingness to develop mutually acceptable solutions to outstanding issues.

2015-11-30 CONFIDENTIAL 7 Sinoe Communities Engagement (West-2)

Community working Status Change from with GVL Previous Update Tarjuowon Gleater Sonnuhn Town Elementary School construction is complete and handed over through a joint Updated ceremony, with additional provision of 60 pulpits, 20 chairs and 10 tables. An additional six month stipend for teachers at Unification school was approved from September to February, 2016. GVL is to provide teachers for the Sonnuhn Town school and others. An improvement project for Shaw David Town school has provided 45 desks, 8 tables and 16 chairs. GVL continues to operate the Unification City community clinic. Construction of Unification Community toilet under the CSR project is complete, Road rehabilitation work from ENI mission to Shaw David community is ongoing. The rehabilitation of 11 wells in 11 communities is about 80% complete. Nomination for Tarjuowon CDF members have been made by both the community and GVL.

Proposed reserved forest corridor management meetings were held with stakeholders of Tarjuowon District to discuss how the site can be co-managed by GVL and communities. Some Tarjuowon citizens were awarded slashing, production timbers and construction contracts.

Major civil construction work for the mill is about to begin. Over one hundred locals have been recruited to do skilled and unskilled works at the mill site.

A group of citizens previously organized under the Kulu United Development Association (Kuda) have established a Blogbo Section group and are engaged in discussion with GVL on their claim to specific “old towns” areas in tarjuowon.

2015-11-30 CONFIDENTIAL 8 Sinoe Communities Engagement (West-3)

Community working Status Change from with GVL Previous Update Juarzon In April 2015 GVL resumed engagement with the communities in the District. Rapid Updated assessment of the vegetation types and land use to identify suitable areas for oil palm development was done. This rapid assessment was shared with and endorsed by the communities. The planning process for the FPIC consultation in the communities is substantially complete but subject to communities’ approval of the main workplan towards FPIC. The full consultation process is expected to begin at the turn of 2015/2016. The timing of ESIA and HCV assessment will be considered in early 2016. Sanquin-Geetroh GVL has received repeated land offers which are being reviewed. The vegetation cover has No material change region been assed and found to be mostly forested.

Lousiana – Butaw GVL has received an invitation and has made initial contact with the Community. No material change District

2015-11-30 CONFIDENTIAL 9 Sinoe Communities Engagement (East-1)

Community working Status Change from with GVL Previous Update Kpanyan/ Numopoh- The Community and GVL are establishing the community Development Fund Committee and Updated East Sinoe revision and calculation of the development map in is in progress. Active land preparation is ongoing in Numopoh Phrase II(a) and is complete in Phrase II(c). The Numopoh provisional MOU/SA is being reviewed. The Environmental team has completed HCV demarcation in Numopoh Phrase II(b), which is now awaiting Land Preparation.

Finally Numopoh local stakeholders and Numopoh Citizens Welfare Committee are in negotiation with Communities and GVL to offer an additional portion of land in the Geepo Chiefdom. This would provide local employment, plus facilities such as a road, hand pumps and other infrastructure that will benefit the community.

GVL is fixing 100 school pulpits for the Numopoh Public School.

2015-11-30 CONFIDENTIAL 10 Sinoe Communities Engagement (East-2)

Community working Status Change from with GVL Previous Update Du-Wolee/Nyannue- Numopoh, Du-Wollee Nyannue and Worteh communities have in principle agreed to resolve Updated East Sinoe overlapping land claims. Through the faclitation of the national government, represented by Hon. Varney Sirleaf, an 8 km road linking Nyannue clan to Worteh has been constructed & dedicated. It is now used by over 200 residents in surrounding communities and improves travel to Greenville. Worteh, Du-Wollee and Numopoh government has produced a map setting out community metes and bounds. The map has been signed by only DWN as the Numopoh and Worteh communities have yet to agree to the proposed metes and bounds.

Tartweh/Drapo & On June 19, 2015, Golden Veroleum Liberia opened Divisions 1 & 2 of Tartweh operation. GVL Updated Nitrain-East Sinoe has employed over 100 local citizens at staff level and general workers. GVL has offered scholarship to 10 high school graduates in Tartweh to study at the UMU Agriculture College in Gbason Town, Juarzon District, . Ground HCV demarcation is ongoing in Tartweh Division 4 and the environmental team has complete HCV demarcation in Tartweh Division 3 prior to Land Preparation. An agreement has been signed with Nitrain and a first payment made to the Nitrain Development Association. Further information sharing as part of FPIC process is ongoing with other communities. Land preparation and palm planting are in progress in Nitrain Division 2. Land preparation and palm planting is in Division 1 is complete. Ground HCV demarcation is ongoing in Nitrain Division 3.

2015-11-30 CONFIDENTIAL 11 Sinoe Communities Engagement (East-3)

Community working Status Change from with GVL Previous Update Dugbe River District – Dugbe River District has been divided into four MOU/SA zones due to the large size of the Updated East Sinoe district. This will facilitate community input in the planning process and MOU development. Community Future Farm land Identification, GPS tracking and bush walk is ongoing in Sarbo Chiefdom. Sarbo chiefdom has presented MOU/SA inputs for GVL management consideration. Jaedea Statutory Participatory Mapping, Household Survey, Environmental and Social Impact Assessment, Updated District – Titiyen HCV assessment completed. EPA permit received. NPP 30-day public consultation completed Community-East Sinoe with no comments. Draft MOU for consultation and input is ongoing. Community/Future Farm Lands (CFFL) walk-through is the next step. Nyennnasue – GVL mapping exercise using satellite imagery is ongoing to assess whether the area is a go Updated Jadeop-East Sinoe or a no go area.

2015-11-30 CONFIDENTIAL 12 Grand Kru Communities Engagement (1)

Community General status March 26, 2015 Change Trembo: Sorroken, Pre-FPIC completed in new area offered by community. A company has been appointed to Updated Wutuken undertake ESIA and HCV assessment. Implementation of the Memorandum of Understanding and Social Agreement is ongoing in old MOU area. Community nomination for setting up of CDF completed pending community review of documents. Communities have opted for individual town-based CDFs although they have been asked to reconsider (as in all cases where town-based CDFs are proposed) whether this will produce the most effective use of funds for community improvement purposes. Trembo: Gbanken Land preparation completed with implementation and review of the MOU/SA ongoing. Updated. Community opted for town-based CDFs, which are being processed.

Newaken Land preparation progressing with implementation and review of the MOU/SA ongoing. No material change. Community opted for town based CDFs, which are being processed.

Trembo: Dougbo Discussion paused on feasibility grounds. Current assessment shows the number of rubber No material change farms in the area proposed by the community for oil palm development means that conversion is not economically viable.

Wedabo: Zoloken Planting land preparation, with implementation and review of the MOU/SA ongoing. Updated Documentation for setting up CDF completed.

Bleebo Pre- FPIC completed. A company has been appointed to undertake ESIA and HCV Updated assessment.

Garraway: Beach and Land preparation progressing based on MOU reached through FPIC. Implementation and Updated Weteken, Piddy and review of the MOU/SA, road construction and rehabilitation, supply of school materials Nyanbo, Nemiah, Po- ongoing. CDF nominations for all communities ongoing. River Wedabo: Gbanken, Land preparation completed in Ylatwen and Beloken with planting ongoing. Gbanken land Updated. Ylatwen, Beloken preparation started and ongoing. Implemenyation of MOU/SA ongoing as well in the three communities. 2015-11-30 CONFIDENTIAL 13 Grand Kru Communities Engagement (2)

Community General status October 26, 2015 Change Wedabo: Grandcess Pre- FPIC completed. A company has been appointed to undertake ESIA and HCV Updated. assessment.

Wedabo: Juduken Boundary challenge between two communities resolved. Field demarcation Updated. completed. Ongoing discussion between Diaspora base group and Juduken community at home.

Gbatao (Picnicess) Community invited GVL to help measure potential land and to discuss. GVL has held No material change. exploratory meetings and these are continuing. Initial walk around land area with community leaders and representatives completed. Now pending decision whether ESIA and HCV leading to FPIC and NPP can be resourced and economically justified.

Gbleebo Pre-FPIC completed. A company has been appointed to undertake ESIA and HCV Updated. assessment.

Barclayville: Gbalapoh, Big Pre-FPIC completed. A company has been appointed to undertake ESIA and HCV Updated. Suehn, Filoken, Topoh, assessment. Fleneken

Sasstown Invitation letter received by GVL to start FPIC process. Initial walk around land area No material change with community nominated leaders and representatives completed. Now pending decision whether ESIA and HCV leading to FPIC and NPP can be resourced and economically justified.

2015-11-30 CONFIDENTIAL 14 River Gee Communities Engagement

Community General status October 26, 2018 Change Sarpo Sarpo Community representatives have made initial contact with GVL about the No material change possibility of beginning discussions on development. GVL is considering a response.

Tienpo, Jedepo, Kilepe GVL has been approached to consider development. GVL is following up the initial No material change and Chedepo areas invitation for more information.

2015-11-30 CONFIDENTIAL 15 2. Complaints Status: Butaw

2015-11-30 CONFIDENTIAL 16 Butaw – Status Update Summary

Context: • GVL new land development in Butaw have been suspended since February 2013 following the RSPO CP directive. • GVL accepted RSPO CP / TFT recommendations and has provided quarterly updates, the latest Mar 2015. Past Steps Recent Update 1. GVL implemented original recommendations, pending confirmation, to August 2013 1. The Butaw Welfare and Development Association and A- 2. Green Advocates (GA), representing the Abloteh community based Bloteh issued a Complaint Withdrawal Letter to the RSPO organization in the original complaint, ended their participation in on 25 Sep 2015. Butaw September 2013 2. On 7 Nov 2015, Butaw and Murraysville communities 3. The local Abloteh community based organization has been directly agreed to set up a Joint Committee to resolve the boundary engaged with GVL since January 2014 conflict and discuss the offer of additional lands to GVL for 4. RSPO team visited June 2014 development. 5. Specific recommendations for GVL from discussions during RSPO 3. Butaw senior community leaders met with GVL senior visit and subsequent draft report carried out management on 14 Nov 2015. Issued a formal apology for 6. Significant community expectations from RSPO visit outcome, damage done to GVL property during 26 May riots and particularly on resumption of development and community oil palm. repeats withdrawal of complaint. Seeks quick resumption of development activities. 7. GVL, Abloteh and communities worked together during Ebola crisis August to December 2014, succeeding to maintain zero infections and casualties. 8. In January 2014, GVL received letters from Butaw Youth Association (BYA), demanding a speed up of the resolution of the RSPO complaint. 9. On 26 February 2015, GVL issued a requested letter of commitment to Abloteh. A detailed agreement and schedule for completion of the complaint resolution and resumption of development in Butaw was signed, including endorsement by the Government of Liberia. 10. Action plan stopped pending resolution of boundary conflicts between Butaw and neighbouring communities. 11. Violent attack on GVL farm 26 May, by BYA and others. Led to personal injuries, destruction and theft of property (documented elsewhere) 2015-11-30 CONFIDENTIAL 17 Status of GVL followup to RSPO Complaints Panel Decision 1-9

RSPO 9-point request per letter dated 4 GVL follow up status Update Track Feb 2013 Status 1. GVL responds within two weeks to Clarification teleconference on 14 Feb 2013. Historical Per plan requirements listed below. Official GVL response within two weeks of RSPO confirmation, on 6 (previous Mar 2013. reports) 2. GVL complies with RSPO’s NPP from 4 GVL confirmed compliance in letter dated 6 Mar 2013. Historical Per plan Feb 2013 for any further clearances for All new potential development areas will be compliant with RSPO (previous development. NPP. reports)

3. GVL engages approved CB to verify GVL confirmed Grievance and Complaints SOP in place, as verified Historical Per plan SOPs in place to prevent recurrence of by BSI. Relevant SOPs have since been further updated and (previous events leading to complaint. submitted to RSPO. reports)

Table continues on next page

2015-11-30 CONFIDENTIAL 18 Status of GVL followup to RSPO Complaints Panel Decision 1-9

RSPO 9-point request per letter dated 4 GVL follow up status Update Track Feb 2013 Status

4. TFT is instructed to provide statement TFT issued its draft report on 20 Feb 2013 and final on 5 March Historical Per plan on FPIC prior to impending 2013. GVL accepts the recommendations and is currently (previous development/clearance in addition to implementing them. The full TFT report has been published on reports) RSPO NPP. GVL website since 16 March 2013 and is available at http://www.veroleum.com/roadmap-social-sustainability-1. Updated FPIC and NPP process has been complied to for any further community engagement from 4 Feb 2013 onwards. A letter by TFT dated 10 June 2013 with summary of visit findings on GVL progress was enclosed in June 2013 update to RSPO. SOPs available on website. Regular reports and briefings issued by TFT.

5. GVL continue to engage Green Engagement with Green Advocates have not progressed since Updated Ongoing, Advocates and Forest People Program RSPO visit in June despite repeated invitations from GVL and GA (FPP) via field study by TFT. Status informing on 2014-04-21 it would like to engage again with report to be submitted quarterly. meetings in Monrovia on recommendations by RSPO during visit and in draft report. GVL continues to engage the community directly and to keep Green Advocates informed. Contact with FPP continues but mainly via its NGO partners in Liberia eg SDI. GVL participated in October FPIC workshop organised by FPP and SDI in Liberia. Meetings between Andrew Kluth of GVL and Tom Lomax and Chris Kidd of FPP in October, to continue in February 2016. GVL has volunteered to field-pilot the 2015 RSPO FPIC Guidelines authored by FPP.

CONFIDENTIAL 19 2015-11-30 Table continues on next page Status of GVL followup to RSPO Complaints Panel Decision 1-9

RSPO 9-point request per letter dated 4 GVL follow up status Update Track Feb 2013 Status 6. GVL to work on a roadmap to engage Direct engagement between GVL, A-Bloteh and BYA has resulted Updated Ongoing, communities to be agreed between GVL, in a 25 Feb 2015 agreement to a schedule of activities to resolve recent RSPO and complainants within six the complaint. Activity stalled because of boundary conflict. significant months. Engagement continued with BWDA/A-Bloteh issuing complaint progress withdrawal letter to RSPO in Sep 2015. Details are provided separately in this report. 7. GVL to make changes to SOP as Changes to SOP have been made as recommended by TFT and Historical Per plan recommended by TFT and implement the are being implemented for all new FPIC and plantings. (previous same for all new plantings. Continuous improvement in process and relevant SOPs and report) updates publicised in GVL website at http://www.veroleum.com/roadmap-social-sustainability-1. FPIC SOP further discussed with A-Bloteh on 31 Aug 2013. As further comments or feedback has not been received, GVL considers the SOP’s to be applicable in use, and any further comments and feedback will be considered for incorporation as Continuous Improvement (CI). GVL will issue adjustments from time to time, and will be glad to receive suggestions. A further new SOP for Land Preparation activitivities was issued in November 2013. GVL has submitted its FPIC SOP and other related documents to RSPO working group on FPIC guidance review and has actively participated in the review process. GVL plans to next update the SOP’s upon RSPO new Guidance.

CONFIDENTIAL 20 2015-11-30 Table continues on next page Status of GVL followup to RSPO Complaints Panel Decision 1-9

RSPO 9-point request per letter dated GVL follow up status Update Track 4 Feb 2013 Status 8. Plans and field operations to be TFT recommendations are being incorporated into plans and field Historical Per plan developed to incorporate operations. TFT has assisted GVL to develop and implement a (Previous recommendations of TFT assessment. further new SOP for Land Preparation activities as mentioned Reports) above. TFT continues to monitor progress.

9. GVL to declare all areas cleared or Declaration of areas cleared was reconfirmed in GVL letter dated Historical Per plan planted which may have infringed 6 Mar 2013. Management and monitoring plans were developed (Previous Principle 7 of the P&C but as yet and submitted to RSPO in file “2013-02-22.1 GVL HCV SUMMARY Reports) undisclosed to RSPO within 3 months. MGMT PLANNING.pdf” as part of the March 11, 2013. Ongoing GVL to submit management and NPP submissions posted on RSPO website. monitoring plans of all HCV areas that have been already currently identified.

2015-11-30 CONFIDENTIAL 21 4. Other Complaints

2015-11-30 CONFIDENTIAL 22 Other complaints: status summary

Summary • GVL is not aware of any further complaints sent to RSPO except for a letter dated 24 Sep 2015 signed by three members of the Gbleebo Chiefdom claiming that a previous boundary dispute with a neighbouring community which was deemed to be resolved with Government facilitation was done under duress. This was refuted by a letter from representatives of the Gbleebo Chiefdom to RSPO dated 18 Oct 2015. • GVL has invited continued direct engagement with all NGOs to break complaint-response cycle, and has made progress with a group of NGOs facilitated by SDI. This group is referred to as the GVL NGO Network. • The RSPO Complaints Panel has issued its Final Decision on 19 Sep 2015. GVL has substantially accepted this decision in its letter to the RSPO dated 26 Oct 2015. • GVL has provided ongoing updates to RSPO on any significant events and progress in its operations in Liberia. GVL view • GVL will continue to encourage direct engagement and continues to comply strictly to all relevant processes and SOPs, including FPIC, HCV and HCS, in its operations, as well as further refine GVL’s processes. • GVL hopes that with the issuing of the Complaints Panel final decision, the work-suspension order in Butaw can finally be lifted and the complaint be placed in the monitoring mode. The Butaw community has strongly expressed its desire for development to resume in its areas. It is not clear how the best interests of local communities are being served by drawing this process out further as, contrary to the purpose of FPIC, the express desires of some local communities to take forward development opportunities with GVL cannot be satisfied while this impasse continues.

2015-11-30 CONFIDENTIAL 23 Complaint / Report to RSPO Date lodged Complainant / Status Complaints / ReportsOriginator to RSPO (1) 1. Land clearance in Butaw 3 Oct 2012 Green Advocates Updated. All actions stipulated by the Complaints Panel without NPP public notification (GA) on behalf of completed or ongoing. Further specific recommendations and FPIC not done. communities. by RSPO during and after June visit carried out or in progress. BWDA and A-Bloteh has issued a Complaint Withdrawal to RSPO on 25 Sep 2015. 2. Report on GVL/TFT 26 Jul 2013 FPP Historical. GVL responded to points raised on 26 Aug progress report on Butaw 2013. RSPO responded on 11 Sep 2013 to which GVL complaint. Kpanyan. replied on 13 Sep 2013. No subsequent action from Intimidation raised as key RSPO. issue. 3. Non-compliance to RSPO 2 Oct 2013 SDI / SESDev Historical. GVL responded to all points on 17 Oct 2013. P&C following NPP notification RSPO agreed that complainant had fundamental for Grandcess-Wedabo and misunderstanding of sequence of FPIC and NPP Threnbo. notification. No subsequent action from RSPO. 4. Joint statement on 12 1 Nov 2013 FPP, Samfu, SDI, Historical. GVL responded to RSPO on all points on 8 Nov outstanding issues relating to SESDev, GA 2013. GVL wrote to all complainants on 7 Nov 2013 GVL development. suggesting dialogue to break unproductive cycle of complaints-response. Meetings have not taken place. 5. Letter to GVL cc to RSPO 14 Nov 2013 KUDA Chairman. Updated. Subsequent to the KUDA Chairman letter of Nov rejecting GVL development on (Faction within 14, 2013, on 18 Nov 2013 KUDA Vice-chairman and Sec- Kulu land. (See also 7,8 and KUDA) general wrote to GVL and RSPO refuting claims made in 10) letter and indicating it does not represent views of KUDA. SDI on behalf of the GVL NGO Network has been facilitating resolution of dispute with some members of the Kulu community. GVL has voluntarily stopped work in some areas as a precautionary measure.

2015-11-30 CONFIDENTIAL 24 Complaint / Report Date lodged Complainant / Status Originator 6. Non-Complaintscompliance to RSPO 21/ NovReports 2013 SDI / toSESDev RSPOHistorical (2). GVL responded to all points raised to RSPO on 5 P&C following NPP notification Dec 2014. GVL notes that much of the allegations are for Garraway-Thren and Grand repeated and that NGOs still hold the wrong view that FPIC Cess Wedabo must be completed prior to NPP notification, contrary to RSPO process rules. No further action from RSPO. 7. Lack of FPIC process and 17 Feb 2014 SESDev Historical. GVL responded to all points raised to RSPO on intimidation of communities in 24 Feb 2014. No further action from RSPO. GVL submitted Tarjuowon. (Related to 5) to RSPO requests from community for road and other development in Feb and Mar 2015. Senate election results overwhelmingly support candidate earlier accused of being involved in intimidation, throwing accusations into doubt. 8. Intimidation of communities 17 Feb 2014 On behalf of Historical. GVL responded to all points raised to RSPO on and non-compliance to RSPO KUDA by Green 12 Mar 2014. No further action from RSPO. GVL submitted NPP procedures in Tarjuowon. Advocates to RSPO requests from community for road and other (Rel to 5) development in Feb and Mar 2015. Senate election results overwhelmingly support candidate earlier accused of being involved in intimidation, throwing accusations into doubt 9. Liberian newspapers Newspapers Green Advocates Historical. GVL has not received any approach on this from reported Cllor Alfred Brownell on 11 Mar 2014 Green Advocates nor the said Clan. However, the land of Green Advocates having conflict the clan has with a neighbouring clan has been well made a complaint to RSPO known and has been attended to by GVL in planning. GVL about GVL encroaching on had consulted with both Clans and established a safety Blebo clan land. zone, which has not been encroached. The dispute has been amicably resolved with resolution signed in August 2014. 10. RSPO visit to Liberia 18 Oct 2014 KUDA Historical. While this is not a new complaint against GVL but more of comments on the RSPO visit and the subsequent report, GVL has investigated some specific allegations which may be related to it or its employees. In the process, some people named in the report have protested against personal allegations against them and 2015-11-30 CONFIDENTIALrequested GVL to forward these to RSPO, which was25 done on 21 Nov 2014. 5. Conclusion and Next Steps

2015-11-30 CONFIDENTIAL 26 Conclusion and Next Steps

1. Commercial oil palm development is new to Liberia. GVL sees this as an opportunity to help build this industry in a sustainable manner and has made significant efforts to do this. 2. GVL believes there remain gaps between the theory and application of what truly represents robust yet practical FPIC processes, particularly in the African context. For its part, GVL has engaged international experts to help develop its FPIC and related SOPs and monitor its execution, but there is a need for common ground in this. 3. In this context, GVL has participated in RSPO’s review of FPIC guidance, led by FPP. GVL has actively provided inputs to the guidance document and has volunteered to field-test the revised guidance in a pilot in Liberia. 4. Meanwhile, GVL will continue to comply strictly to its FPIC and other important processes in all developments. GVL also works towards further developed and refined FPIC methods and implementation. 5. Where there are disagreements in what this entails or if there are gaps in its operational execution, GVL believes that the most productive way to resolve this is through direct engagement, discussion and possibly even experimentation, rather than the current cycle of complaints and responses by NGO’s ostensibly respresenting communities or dissatisfied individuals, which shows no signs of progressing to a mutually accepted outcome. GVL notes that this has also been recommended in the draft RSPO visit report released in September 2014. 6. GVL continue to look forward to discussion on and continuing dialogue and meaningful engagement with Liberian and international NGOs, as we believe the current complaint-response-cycle does not serve the communities’ interest. 7. GVL notes and supports the recommendation of establishing a National Palm Oil Advisory Committee as contained in the RSPO Complaints Panel final decision. GVL believes this will facilitate engagement among key stakeholders and also enable quicker resolution of complaints and issues. 8. GVL is disappointed that some NGOs have verbally challenged the decision of the RSPO Complaints Panel when it was presented in Monrovia on 26 Sep 2015. GVL hopes that this will not delay any further the final resolution of the complaint as this will not benefit, and indeed go against the expressed desire, of the vast majority of communities. 9. GVL believes that RSPO Secretariat and the Complaints Panel has expended significant time and effort in an attempt to resolve the complaint. GVL urges the Complaints Panel to close the complaint as GVL has in good faith complied to all instructions and cooperated with all parties in this process.

2015-11-30 CONFIDENTIAL 27