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Sustainability Action Plan

No Area Activity Sub-activity 6 months 12 months 18 months Update January 2023 Update March 2023 Update February 2024
A GOVERNANCE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
A.1 Structure Review and strengthen organization structure (especially the sustainability team and GIS team) to allow clear role and collaboration between teams. A1.1.1 Review and finalization of organization structure Completed. Completed. Completed
A1.1.2 Establish role function, job description, and authority level   Completed. Under implementation, with Quarterly KPI stetting Completed Completed
A1.1.3 Resource audit and hiring of relevant people to fill in any gaps in the structure Completed. Completed. Completed
A1.1.4 Socialization and implementation of new organization structure On-going On-going Completed
A.1.1.5 Evaluation of organization structure On-going On-going Completed and being implemented on annual basis
A.2 Coordination and Oversight Establish regular meetings on sustainability issues A.2.1.1 Establish regular meeting on mill/plantation level and regional level On-going. On-going. On-going.
A.2.1.2 Establish sustainability steering committee and its regular meeting On-going. On-going. On-going.
Establish sustainability related Key Performance Indicators A.2.2.1 Establish clear KPIs for sustainability team Completed Completed Completed
A.2.2.2 Establish additional sustainability related KPIs for non-sustainability teams On-going On-going On-going
A.2.2.3 Evaluation of KPIs On-going On-going On-going and annual basis implementation
A.3 Talent and Culture Training / Capacity Building A.3.1.1 Conduct training needs assessment to create sustainability training plan for relevant people On-going On-going On-going
A.3.1.2 Implement and establish a training record On-going On-going On-going
A.4 Infrastructure and logistics Establish relevant policies and SOPs A.4.1.1 Establish SOP on stakeholder management Completed. Completed. Completed.
A.4.1.2 Establish SOP and system to track legal requirement Completed. Under implementation Completed. Under implementation Completed. Under implementation
A.4.1.3 Establish SOP for boundary demarcation and its maintenance Completed. To be trialed when on-going arrangements with Liberia Land Authority (LLA)  and other stakeholders are completed for boundary review. Completed. To be trialed in Tarjuowon in clan boundary remapping exercise Completed and being implemented. 
A.4.1.4 Review and update FPIC and PM SOP according to: Module 2 – Social requirements (version 2.0 May 2017) Module 3 – Integration of HCV HCS Forest and FPIC (version 2.0 May 2018) FPIC guide for RSPO members Completed and being implemented.  Completed and being implemented.  Completed and being implemented. 
A.4.1.5 Establish SOP for participatory mapping for disputed areas Draft completed. To be tested after resolution of Blogbo dispute. Second site visit by independent facilitator was carried in Mar 2021. Awaiting final facilitation report, and decision by RSPO. Completed. To be trialed in Tarjuowon in clan boundary remapping exercise Completed and being implemented. Include to solve disputed area between Numopoh & DWN which assistance by Liberia Land Authority.
A.4.1.6 Establish SOPs for mill operations in appropriate languages Completed; decision to do in English only, as the official language of Liberia Completed; decision to do in English only, as the official language of Liberia Completed; decision to do in English only, as the official language of Liberia
A.4.1.7 Establish SOP for monitoring of environmental management plan, implementation, and reporting Completed.  Completed.  Completed. 
A.4.1.8 Establish SOP for HCV HCS Peat management and monitoring Draft completed . Review of  EF assessment report submitted, and currently guiding the implementtation of the Draft SOP. Draft completed.  Being reviewed for approval Completed and on going on the implementation. Management & Monitoring plan of HCV HCS approved by GVL Top Management.
A.4.1.9 Establish SOP and system for grievance handling for both external and internal stakeholders. Also add mediation step before legal option. Completed. In use. Completed. In use. Completed and implemented. 
A.4.1.10 Establish SOP to describe the process of information sharing and dissemination Completed. Completed. Completed
A.4.1.11 Review the recently announced Human Rights Defender Protection protocol by the RSPO and develop policy on human rights Completed Completed Completed
A.4.1.12 Review Greenbook SOP to be clearer on pest attack intensity and IPM Completed. Completed. Completed
A.4.1.13 Revise Greenbook SOP section 6.5.3 on empty pesticide package disposal Completed. Completed. Completed
A.4.1.14 Review recruitment policy to include a statement on no recruitment of workers under 18 years old Completed. Completed. Completed
A.4.1.15 Review recruitment policy to include non discrimination based on sexual orientation, union membership, and political affiliation Completed. Completed. Completed
A.4.1.16 Update policy of promotion to include non-discrimination promotion Completed. Completed. Completed
A.4.1.17 Establish policy to ensure no harrasment or abuse in the work place and reproductive rights are protected Completed. Completed. Completed
A.4.1.18 Establish policy on forced trafficked labor Completed. Completed. Completed
A.4.1.19 Establish SOP for waste management that cover all of the waste produced by operational including domestic waste. Completed. Completed. Completed
A.4.1.20 Establish policy to circumvent instigated violence to maintain peace and order Completed. Completed. Completed
A.4.1.21 Establish SOP for third party FFB sourcing Completed. Completed. Completed
A.4.1.22 Establish SOP for pollution and GHG emission mitigation or reduction Completed. Completed. Completed
Data and document management A.4.2.1 - Establish clear filing system for data and documents Completed. In operation. Completed. In operation. Completed and being implemented. 
- Ensure that documents and records are protected and retrieval (clarify the responsibilities and authorities for back up and the medium to be used)
- Establish systematic endorsement of documents shared with the communities (meeting minutes, maps, etc.)
A.4.2.2 Establish a clear hand over procedure and induction for new personnels on sustainability Completed. Completed. Completed
A.4.2.3 Strengthen the sustainability team in the documentation and filing system (hard and soft copy). Need to be enforced through KPIs Done. In operation. Done. In operation. Completed and being implemented. 
A.4.2.4 Strengthen the capacity of the sustainability team to ensure rigorous data record (meeting minute, evidences, endorsements, …) for every meeting with communities/ complaints.  Done. In operation. Done. In operation. Completed and being implemented. 
A.4.2.5 Evaluation of data and document management On-going. On-going. On-going.
Tracking of legal A.4.3.1 Establish a list of legal requirement and the copy of laws and regulations Completed. Completed. Completed
A.4.3.2 Establish a comprehensive system to track legal requirements, its update and its compliance analysis, including  personnel in charge, source of information, and frequency of update to track the regulation and legal law update. Draft completed. Under review Draft completed. Under review Draft completed. Under review to be implemented
A.4.3.3 Conduct an assessment of compliance (internal audit) to ensure that all legal requirements are fulfilled On-going. Quarterly updates. On-going. Quarterly updates. On-going bi-annual basis implementation
Establish baseline maps A.4.4.1 Establish clear and agreed baseline maps for: Done. In regular use Done. In regular use Completed and implemented. 
- soil fragility map
- slope map
- HCV and HCS maps
- Community map and participatory maps
- Land conflict map / encroachment area
- Area planted / developed
A.4.4.2 Establish clear guidance on map production, verification, approval and sharing. Ensure that RSPO needs are followed. Completed. In regular use Completed. In regular use Completed and implemented. 
Appropriate logistics A.4.5.1 Assess the logistic needs of the sustainability and GIS team and plan for their provision (transportation, computers, handheld GPS, etc.) Done. Done. Completed
A.4.5.2 Fulfilment of logistical needs On-going. Improved  in allocations under 2022 Annual Budget. Still affected by cost-cutting measures in response to global economic downturn. On-going. On-going.
B ENVIRONMENTAL MANAGEMENT
B.1 No development of and conservation of HCS areas Organize a training on the new HCS Approach especially on: oModule 2 – Social requirements (version 2.0 May 2017) oModule 3 – Integration of HCV HCS Forest and FPIC (version 2.0 May 2018) B.1.1.1 Explore opportunity for HCS training with HCSA Africa and attend training when available Exploring appropriate training opportunities in Africa. Secondment of GAR expert to do in-house training planned Secondment of GAR expert to do in-house training, planned within 2024
B.1.1.2 Obtain approval from HCSA on the reports and maps Reviewing pending grievance case developments To follow RSPO process, given GAR withdrawal from HCSA To follow RSPO process, given GAR withdrawal from HCSA
Review the previous HCS work (Grand Kru & Sinoe) in alignment with the new HCS Approach toolkit (integration of the community livelihoods programme (COPP perspective and alternative livelihoods) B.1.2.1 Review all HCS work (Grand Kru and Sinoe) and produce new updated HCS reports and maps to be submitted to HCSA Done.  Done.  Done. 
B.1.2.2 Ground check of HCS clearance claim and develop remediation action. Develop and implement the ICLUP (Integrated Conservation and Land Use Planning) Report completed and submitted to HCSA. Action plan developed for  mitigation, and under implementation. ProForest developing HCS remediation plan.   ProForest supporting HCS remediation plan. Mapping done and community agreement obtained for remediation plan. Official approval from relevant authorities delayed because of transition of presidential administraiton.
B.1.2.3 Define a prospective land acquisition plan for all the new development (Example: Barclayville, Juazon, etc.) Yet to commence. Subject to further consideration on the proposed  new areas. Expansion drive suspended indefinietly. Yet to commence. Subject to further consideration on the proposed  new areas. Expansion drive suspended indefinietly. Yet to commence. Subject to further consideration on the proposed  new areas. Expansion drive suspended indefinietly.
B.2 No development of and conservation of HCS areas Develop management and monitoring plan as well as implementation for protecting the HCV area. B.2.1.0.1 Conduct HCS assessments on all developed areas; construct land use change maps, establish cleared HCS and develop new baseline maps As in B.1.2.2 above. HCS assessments completed for existing MOU areas.  HCS/HCV management / monitoring SOP being reviewed HCS assessments completed for existing MOU areas.  Management & Monitoring plan of HCV HCS approved by GVL Top Management.
B.2.1.0.2 Conduct HCV/HCS Assessments for MoU areas for planned development As in B.1.2.2 above. As above As above
B.2.1.0.3 Update HCV/HCS maps As in B.1.2.2 above. As above As above
B.2.1.0.4 Get community agreement and incorporate into MOU As in B.1.2.2 above. As above As above
B.2.1.1 Development of management and monitoring plan according to established HCV maps.  As in B.1.2.2 above. As above As above
B.2.1.1.1 Development of forest restoration / remediation / conservation plan based on HCSA decision  As in B.1.2.2 above. As above As above
B.2.1.2 Conduct socialization to Operations, workers and community to increase awareness and protection of HCV and HCS areas On-going as part of routine community and employee engagement. On-going as part of routine community and employee engagement. On-going as part of routine community and employee engagement.
B.2.1.2.1 Demarcation of buffer zones and no-go areas On-going On-going On-going
B.2.1.3 Conduct field inspections conducted regularly to ensure implementation of mitigation plan Inspection on-going. To be reviewed and consolidateed subject to final report of HCV-HCS re-assessment, and submission of mitigation plan. Inspection on-going.  Filed inspections carried out according to the Management Plan regularly.
B.3 Yield improvement without intensification of use of chemical pesticides and fertilizers Establishment of integrated pest management B.3.1.1 Establishment of IPM Plan, which contain identification of potential pests and thresholds, technic use to control (cultural, biological, mechanical and physical methods) pest attacking, identify and plant native species used as part of biological control method refer to SOP and Concession Agreement. Completed. Completed. Completed
B.3.1.2 Having well documented IPM implementation records including records of training to IPM workers Completed. Completed. Completed
Proper usage of POME for fertilizers B.3.2.1 Conduct study of the optimum area for POME application for effluent mill with capacity 40 mt FFB/hour and for new pond capacity. Completed. Completed. Completed
B.3.2.2 Tarjuowon North (TNRE) estate/TRJM needs to record how much the total POME application, replace broken flowmeter Completed. Completed. Completed
B.3.2.3 Building of additional POME pond Completed. Completed. Completed
B.4 Greenhouse gas emissions Report and reduce greenhouse gas emissions B.4.1.1 Conduct assesment of pollution and GHG emission resource from the entire operational aspect . Completed. Completed. Completed
B.4.1.2 Establish action plan to mitigate or reduce the pollution and GHG emission. Completed. Completed. Completed
B.4.1.3 Calculate the operational GHG emission using RSPO GHG calculator ver.3.1 and report it to RSPO. Done. Iterative process. Done. Iterative process. Done. Iterative process.
B.5 Waste management Improve waste management B.5.1.1 Check BOD and other parameter in POME discharge to plantation refer to regulation. Done. Iterative process. Done. Iterative process. Done. Iterative process.
B.5.1.2 Engage the government about the license/permit for the hazardous warehouse base on the EMPL Regulation Section 64. Engagement done. Licencing process under periodic review. Engagement done. Licencing process under periodic review. Engagement done. Licencing process under periodic review.
B.5.1.3 Stored and disposed used chemicals and their containers responsibly according to GVL Procedure, EMPL and best practices. Done. Iterrative process. Done. Iterrative process. Done. Iterrative process.
B.5.1.4 Have well documented waste management and disposal plan to avoid or reduce pollution. Completed. Completed. Completed
B.5.1.5 Arrange logbook for hazardous warehouse. Some of the amount must refer to the logbook of general warehouse. For example amount of ex-pesticide bin in to the hazardous warehouse must be consider to the amount of pesticide bin put from chemical warehouse. On-going. Iterative. On-going. Iterative. On-going. Iterative.
B.5.1.6 Develop the implementation of 3R (Reduse, Reuse, Recycle) and separation of domestic waste into organic and inorganic waste to simplify the management. Completed. Completed. Completed
B.6 Energy efficiency  Improve energy efficiency  B.6.1.1 Improve efficiency of the use of fossil fuel and optimization of renewable energy. On-going On-going On-going
B.6.1.2 GVL should calculate how much renewable energy use per ton CPO or palm product, estimated fuel use by on-site contract workers and transport and machinery operations and electricity use in operations.  Draft completed. Review on-going. Draft completed. Review on-going. Draft completed. Review on-going.
C SOCIAL AND COMMUNITY ENGAGEMENT
C.1 FPIC Process Review all FPIC process to fulfill any process and documentation gaps C.1.1.1 Review and update the FPIC documentation process in alignment with the SOP that will be updated. This include improvement of scoping process and identification of community's self chosen representatives Completed. Completed. Completed
C.1.1.2 Conduct the boundary demarcation based on FPIC procedure with clear markers and maintain them regularly. In collaboration with Liberia Lands Authority (LLA). Implementation target deferred until further notice, due to review of funding mechanism. In collaboration with Liberia Lands Authority (LLA). Implementation target deferred until further notice, due to review of funding mechanism. In collaboration with Liberia Lands Authority (LLA), to be done as part of the ongoing MOU review process with all communities. National Bureau of Concessions to assist communities
C.1.1.3 Improve ESIA report by conducting participatory SIA assessment . Develop plans for avoidance or mitigation of negative impacts and promotion of the positive and monitoring of impacts. Entire environmental and social requirements subject to on-going discussions with RSPO. Entire environmental and social requirements subject to on-going discussions with RSPO As above
C.1.1.4 Develop a monitoring system with regular reporting to outline the plan on mitigation, implementation and monitoring according to the SIA report.