Transparency Policy

Constructive Engagement and Collaborative Progress

TLFF advocates constructive engagement and collaboration with all its stakeholders. In the spirit of continuous improvement, TLFF welcomes all stakeholders to guide, support and work with us as we identify and resolve gaps and improve the way we operate.

In line with practices on transparency, we publish independent third-party audits for our lending facility on our website.

We have established a section on our website that is dedicated to our project ESG progress and is regularly updated with the latest information on key sustainability progress, policies, documents and statements

The Policy

TLFF recognizes that in order to fully carry out the mandate entrusted by the four founding partners, it is critically important to disseminate and make accessible information concerning its work or information generated though its projects, in particular with respect to environmental and social aspects, as widely as possible.

At the same time, TLFF has an obligation to handle sensitive information in an appropriate manner consistent with the relevant rules and practice of the its founding members.

This Policy endeavours to strike an appropriate balance between the need to grant the public maximum access to information in the TLFF’s possession, including environmental information, and TLFF’s obligation to respect the confidentiality of information regarding its project partners, founding members, and other parties.

The Policy will be reviewed and may be updated as necessary by TLFF. Such review of the Policy will be undertaken in consultation with its founding members and relevant stakeholders.

1. TLFF is committed to making information relating to its work, including environmental information, available to the public.

2. The Policy is guided by openness. Any information in the custody of TLFF, including information generated and maintained through TLFF projects, is available to the public, in the absence of a compelling reason for confidentiality in line with the exceptions to the Policy listed in paragraph 5 below.

3. The information relating to TLFF’s functions and responsibilities will be made available to the public.

4. Primarily, information will be made available, in the available language or languages, on TLFF’s public website

5. While TLFF commits to providing access to information relating to its work, the implementation of this Policy will be consistent with the relevant rules and practices of its founding members. Information to be designated confidential and handled as such includes the following:

  • Documents created by the TLFF, received from or sent to third parties, under an expectation of confidentiality which has been expressly stated orally or in writing;
  • Documents whose disclosure is likely to endanger the safety or security of any individual, violates his or her rights, or invades his or her privacy;
  • Documents whose disclosure is likely to endanger the security of its founding members and project partners or prejudice the security or proper conduct of any operation or activity of TLFF;
  • Documents covered by legal privilege or related to internal investigations;
  • Internal inter-office or intra-office documents and other communications, including draft documents, if disclosure would undermine the Organization’s free and independent decision-making process;
  • Documents containing commercial information, if disclosure would harm either the financial interests of TLFF or those of other parties involved;
  • Information which, if disclosed, in TLFF’s view, would seriously undermine the policy dialogue with parties concerned.

6. Information that is not available on TLFF public website may be made available upon request, with the exception of information covered in paragraph 5 above. The request should be directed to:

Secretariat of the Tropical Landscapes Finance Facility
UNEP Office
10th Floor, Menara Thamrin
Jl. M.H. Thamrin Kav. 3, Central Jakarta 10250, Indonesia

7. Regarding request for information that may be considered an exception under this Policy, TLFF secretariat should seek guidance from TLFF Steering Committee and legal advisors on handling of such requests.

8. All information requests should be handled promptly. TLFF will endeavour to handle all requests within thirty (30) calendar days after the acknowledgment of receipt is sent. If it is not possible to handle a request within thirty days, TLFF will inform the requestor of the reason why it needs more time and the estimated date for communicating the information concerned.

9. If a document contains both confidential information and non-confidential information, and if in TLFF’s view it is consistent with the purpose of paragraph 5 above, part of such document containing only non-confidential information may be made available to the public upon request.

10. TLFF may partially or wholly deny a request for information in accordance with the limitations set out in this Policy.

11. If a request of information is denied, the requestor may seek the review of the decision by addressing a letter to the Secretariat, providing reasons for the appeal.

12. The Steering Committee will have the authority to take a final decision concerning the request for information in question.

13. In case of rejecting an appeal, TLFF secretariat will provide the requestor with a reason for such rejection.

14. That review should normally be completed within sixty (60) working days of being requested. The outcome of the review will be communicated to the requestor.


The following is the consolidated TLFF/RLU response to the October 2020 report from Mighty Earth (ME)

1. ME’s allegations around illegal deforestation in the Jambi concessions held by Barito Pacific Group subsidiaries PT Lestari Asri Jaya (LAJ)* and PT Wanamukti Wisesa (WMW) between 2012 and 2014, prior to the establishment of RLU, a JV between Michelin Group and Barito Pacific Group, are without basis in fact.

2. In its report, ME alleges that LAJ and WMW, which operated concessions that were later designated as part of the RLU JV, committed industrial-scale deforestation for development/ expansion of rubber plantation.

3. In fact, both LAJ and WMW operated as licensed industrial forest (HTI) companies**, which fully respect and comply with all prevailing Indonesian laws and with proper forestry permitting.

4. Further, the Environmental Impact Assessment (AMDAL) work completed prior to the operational activities of LAJ and WMW demonstrates that the areas in question by ME were already considered degraded, logged over or shrub lands when these licenses were initially granted.

5. Indeed, the Jambi landscape had suffered severe deforestation and degradation from illegal encroachment, slash and burn practices and illegal development of oil palm plantations and illegal logging over many years.

1. Upon RLU’s establishment as a JV in 2015, Barito Pacific Group and Michelin Group undertook to introduce environmental and social safeguards, in order to produce sustainable natural rubber in degraded land. These production areas were designed to serve as buffer zones and protect national park areas as well as designated conservation areas within the concessions from further encroachment, illegal logging and poaching, as well as to protect biodiversity, in accordance with the norms stipulated under forestry regulatory as HTI License.

2. At the same time, LAJ and WMW undertook to ensure that the rubber industrial forest concessions would provide jobs and underpin other social infrastructure within the ±70,000-hectare Jambi concessions, to support livelihoods and communities.

3. Since the establishment of the JV, Barito Pacific Group, RLU and Michelin Group have all issued their own No Deforestation, No Peatland Development, No Burning, and No Exploitation (NDPE) policies.

4. Conditions subsequent from Michelin under the JV to be adopted by RLU included to stop any illegal deforestation from communities occurring in the concessions, protect remaining isolated trees, start patrolling, engage government and other stakeholders to stop any deforestation in the concession.

5. Barito also agreed to no clearing or development of High Carbon Stock (HCS) or High Conservation Value (HCV) areas, protection of these areas to prevent illegal activities, protection and conservation of flagship species and habitats, responsible water management, progressive improvement of management of the concessions.

6. Among the first actions undertaken by RLU upon its formation was a High Conservation Value (HCV) & High Carbon Stock (HCS) assessment to its subsidiaries in 2015 to re-evaluate, set aside and define production areas (Go and No-Go Zones). This involved an almost year-long moratorium on planting and resulted in 25% of the LAJ and WMW concessions being set aside for conservation and Community Partnerships purposes.

7. A Survey of Land Use (SLUS) is published monthly that shows plantable areas, conservation areas, areas under survey and planted areas based on the HCV/HCS assessment and other legal requirements.

8. The company, five years later, is undergoing a second HCV/HCS assessment, through the latest scheme from HCVRN — the Integrated HCV and HCSA Assessment.

9. Ahead of the RLU transaction a substantial ESG due diligence was undertaken by Daemeter consulting, which subsequently also delivered an Integrated Forestry Management Plan to the company, including the design for the Community Partnership Program.

10. In Jan 2018, a 9,700 Wildlife Conservation area was established with Partnership for Forests and another NGO partner adjacent to the 143,000 ha Bukit Tigapulluh National Park to allow for the transit of animals through the concessions. The WCA did not exist prior to this – the ME report describes a WCA that did not exist prior to the creation of RLU.

11. Beyond direct land conservation and restoration, LAJ and WMW has delineated a sustainability strategy to generate positive impact for more than 50,000 people living in and around the concessions, guided by safeguards and standards such as the IFC Performance Standards towards which the company is working. RLU offers expanded livelihood opportunities, access to markets as well as improved health and education to local communities through a Community Partnership Program (CPP).

12. LAJ and WMW are the first HTI concessions in Jambi Province that have obtained a Ministerial Decree for Recognition and Protection of Forestry Partnership Programs for community livelihood improvement.

1. RLU has also developed an Indigenous Peoples (IP) Engagement Framework and agreement with the Orang Rimba Group, to help support and sustain livelihoods. RLU cooperates with the regional government to facilitate access to national identity cards (KTP) for Orang Rimba to be able to use public services, such as health care facilities and education.

2. The company has developed a grievance mechanism process and guidelines for managing stakeholder grievances.

3. LAJ and WMW initiated a multi-stakeholder platform called the Conflict Resolution Task force (TRK) together with the government. The TRK is comprised of various stakeholders led by regional government and participated by NGO representative (ie. Warsi, FZS, Jambi’s Malay Traditional Communities), community representatives and research agency.

1. Ahead of the Tropical Landscapes Finance Facility (TLFF) 1 transaction, which provided debt finance to RLU in 2017, extensive E&S due diligence was completed with reference to the IFC Performance Standards, which the company is working to achieve with an Environmental Social Action Plan (ESAP) and a Landscape Protection Plan (LPP) in place.

2. An annual third-party audit is shared with noteholders.

3. As part of RLU commitment to transparency and measurement, the Environment Social Governance (ESG) Annual Audit is published on RLU’s website contained in the annual Sustainability Report.

4. and the &Green Fund contain transparent information about RLU’s ESG progress.

5. The company has hired an additional third-party E&S consultant to ensure documentation and practices are up to international standard and work with the company to correct any perceived gaps.

1. RLU is committed to engaging with stakeholders to ensure the success of this ambitious project and both RLU and TLFF welcome any constructive feedback that helps deliver sustainable natural rubber supply whilst protecting and strengthening the environment and local communities.

2. RLU is proud of this project and committed to achieving long-term progress. No matter its difficulties, we believe the greatest risk lies in inaction – in not stepping in to try to stem deforestation and biodiversity loss in a challenging landscape such as this and certainly in not acting to improve rural livelihoods in Jambi.

1. *LAJ is located south of the 143,000 ha Bukit Tigapuluh National Park (“BTPNP”), a critical and threatened habitat for species such as Sumatran tiger, elephants and other wildlife.

2. **Applicable standards/relevant laws include the formulation of its Environmental Impact Assessment (AMDAL) approved by the Government of the Republic of Indonesia, RKU & RKT (annual and 10-year work plan) approved by the Government of the Republic of Indonesia, Minister of Forestry and Environment of Republic of Indonesia Regulation No. P.62/MENLHK/SETJEN/KUM 1/10/2019 on Development of Industrial Forestry (HTI).

For further inquiries, please contact OCTOBER 14, 2020

Touchpoints between Mighty Earth and RLU

  1. First Touch Point

    Mighty Earth (ME) first approached RLU with nonspecific allegations of deforestation and conflict within the RLU and adjacent ABT ecosystem restoration concessions. RLU's partial response: 1. The company notes that there is little specific, clearly cited information in the report making a full response difficult. 2. RLU and its subsidiaries have a policy of being transparent and open, and, recognizing the complexity of the landscape, are keen to work with stakeholders to find solutions in balancing development of a commercial plantation with conservation and community needs for expanded livelihoods. 3. RLU is looking to build long-term solutions to the BTP landscape, which is heavily degraded and encroached but is still home to unique biodiversity. The company has shown willingness to engage with stakeholders, with dedicated teams in Jambi building Community Partnership Programs and engaged in conservation efforts with WWF,  an early partner of RLU.

  2. RLU Invited ME to Headquarters

    RLU received ME representatives at its Jakarta Headquarters and presented relevant E&S documents regarding the concessions to foster communication and encourage transparency. ME made specific deforestation allegations that were refuted by the company, backed by 2016 LIDAR survey results.  

  3. ME Contacted RLU Again

    ME contacted RLU regarding deforestation 2012-2015, prior to the formation of the joint venture and RLU responded directly to the queries with continued dialogue and posting a point-by-point response on the RLU website

  4. Dialogues with ME

    RLU scheduled a call with ME to explain the challenges, process and progress within the project, the introduction of environmental and social safeguards following the formation of the JV in 2015 and the rationale for the approach. An HCV/HCS assessment in 2015; the establishment with WWF of "go-no go" planting areas; the introduction of IFC PS as the approach to RLU's sustainable plantation development; the Environmental Social Action Plan for risk mitigation; partnerships with NGOs and consultants to achieve best practices in community development and conservation aspects; ongoing monitoring and reporting to ensure compliance are some of the E&S initiatives underway.

  5. The Final Meeting

    RLU attended a meeting with ME, again responding to ME concerns with further data and insight.

  6. Mighty Earth Released Report, RLU Responded

    RLU released a statement in response to ME's report, "Complicit" 8 days later on RLU's website.

  7. March 2021 ME Writes Complaint Letter to CBI

    ME urges the Climate Bonds Initiative to "delist" TLFF I due to deforestation prior to the formation of the Michelin-Barito JV, which became RLU. The letter alleges that deforestation in the concessions was not disclosed in the Offering documents for the bond. RLU and TLFF again respond, in part: "RLU project is forward-looking, designed to address the significant challenges of past deforestation and other issues in the Bukit Tigapuluh landscape by implementing environmental and social safeguards. This was clearly stated in all documentation and E&S due diligence, including a 2017 Environmental and Social Due Diligence Assessment (ESDD) document, which notes the difficulties of determining attribution in such a complex context. The RLU concessions cover +88,000 Ha, with over approximately 50,000 people living in and around the landscape. The E&S objectives of TLFF I, clearly set forth in the Offering Circular, were to protect remaining HCV/HCS areas in the concessions from further degradation; restore biodiversity where possible by protecting the remaining conservation areas; deliver fair wage jobs to people living in the landscape; provide rubber training and purchase programs to others and thus build an integrated, sustainable, commercial rubber plantation. At core, however, the company needs to be both sustainable and profitable. At maturity, the company plans to have planted + 34,000 ha in commercial rubber with the rest set aside for conservation, restoration, and community livelihood. A total of + 28,000 ha has been dedicated to conservation, representing 30% of RLU HTI total concessions in Jambi and East Kalimantan. As of December 2020, approximately 22,000 ha have been planted with natural rubber."