European Environmental Paper Network to Asia Pulp and Paper
Environmental Paper Network
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IV27 4JB, Scotland, UK
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Asia Pulp and Paper
Jl. M.H. Thamrin 51
BII Plaza Tower I
Tuesday, 3 May 2016
Dear Ms. Greenbury,
Thank you for the invitation to the Stakeholder Advisory Forum (SAF) to be held on 9 th May 2016. We appreciate that APP is trying to inform and engage stakeholders but have some concerns about the SAF as the most appropriate stakeholder engagement mechanism. We’re writing to suggest initial ideas for developing an alternative approach for effective stakeholder consultation that addresses these issues and we would like to discuss these further with you.
We recognize that the SAF can be a useful forum for briefing a wide range of external parties on the status and implementation of APP’s Forest Conservation Policy (FCP). However, we do not think it is functioning effectively as a mechanism for identifying and facilitating meaningful input from or discussion with stakeholders on some of the more complex issues and challenges facing the company.
During the first SAF meeting, the broad ranging agenda and the presence of a very diverse range of participants, from diplomats and development agencies to NGOs and consultants, all with different levels of knowledge, interest and engagement in the FCP implementation process, made it difficult to explore issues in depth and discuss ways to address them. Furthermore, only a limited amount of information was shared and stakeholders did not have input on which issues should be on the agenda.
When issues were raised or input was given, it has not been clear what APP is doing about these issues or how the suggestions are being taken up. Where they are not being addressed, it is not clear why this decision has been taken. As an example, several inputs and concerns that were raised during the SAF, and reiterated in a letter sent on October 6 th 2015 by a group of NGOs 1 , were not included in the report from the meeting 2 and appear not to have resulted in actions being taken by the company.
Despite some shortcomings, the Solutions Working Group (SWG) did at least provide a forum for constructive and more in depth dialogue on many key issues. The development of APP’s policy of association, the agreement on third party verification that led to the Rainforest Alliance evaluation and the development of APP’s commitment on restoration were all positive outcomes from this process. We believe however, that in certain cases the SWG did not involve all the right stakeholders or provide an effective venue for some issues and we are therefore not calling for its re-establishment. We are of the opinion, however, that APP needs to rethink and redesign its stakeholder engagement approach and involve stakeholders in this process.
We would like to request that APP revisit the process and mechanisms for stakeholder engagement in an inclusive, transparent and accountable way. We are interested to work with APP in a transparent process of redesigning stakeholder engagement mechanisms and processes that build on and learn from the SWG and SAF and forward APP and civil society’s shared interest in successfully implementing the FCP. A couple of immediate suggestions come to mind for an improved or additional stakeholder engagement:
• identify collaboratively a group of NGOs that can provide substantive in-depth input on high level issues related to the implementation of the FCP (while, from time to time other NGOs could bring focused expertise on specific issues)
• identify and set agenda items collaboratively and share relevant information well in advance of meetings
• limit the number of issues discussed at each meeting and organize meetings in such a way that allows sharing sensitive information and conducting a dialogue and in-depth discussion of issues. This will contribute to the opportunity to discuss and agree on innovative solutions.
• develop a clear process for considering, adopting or rejecting stakeholder inputs and demands, and agree on procedures for monitoring and reporting on how input is adopted and followed-up
It will be important that improving the stakeholder engagement has wide agreement on ground rules, participants, facilitators and agendas. We look forward to discussing APP’s proposals for recasting its stakeholder engagement processes and mechanisms.
(European Environmental Paper Network)