
Statement on ‘Who watches the Watchmen? 2’
A report released by the Environmental Investigation Agency (EIA) and Grassroots provides recommendations for improvement of the Roundtable on Sustainable Palm Oil (RSPO) assurance systems.
A report released by the Environmental Investigation Agency (EIA) and Grassroots provides recommendations for improvement of the Roundtable on Sustainable Palm Oil (RSPO) assurance systems.
On November 3rd, EIA and Grassroots released a report titled ‘Who watches the watchmen? 2’.The HCV Resource Network (HCVRN) appreciates the report’s statements about the significant improvements in HCV assessments resulting from HCVRN’s Assessor Licensing Scheme (ALS) quality assurance and encourages EIA to continue providing feedback that will help us, and others involved, improve our work.
The HCV Resource Network created the Assessor Licensing Scheme (ALS) in 2014 to licence HCV assessors and gradually improve their competency and the quality of their assessments globally. From 2015, the Roundtable on Sustainable Palm Oil (RSPO) started requiring that HCV assessments for new oil palm plantings were carried out by HCVRN-Licensed Assessors. From November 2018, integrated HCV-HCSA Assessments led by HCVRN-Licensed Assessors are required by RSPO to ensure land clearing for oil palm plantations does not cause deforestation or damage any area required to protect or enhance High Conservation Values (HCVs) or High Carbon Stock (HCS) forests. Licensed Assessors are required to follow the HCV Assessment Manual and the HCV-HCSA Assessment Manual, along with other normative documents and templates, and submit their reports for evaluation to the HCVRN. Their HCV and HCV-HCSA Assessment report evaluations can be publicly tracked on our website.
Since 2014, the HCVRN ALS has approved 90 assessment reports covering over 900,000 hectares, out of which 36% was identified for protection. In most cases, the quality assurance process added a substantial number of hectares for protection on top of what was originally proposed by the assessor. The ALS is proving to be useful in not only ensuring that HCV and HCV-HCSA assessments are done correctly, but that more areas are protected from damage or destruction.
We agree that stakeholders should continue to work together to collectively strengthen assurance systems in RSPO with clear and shared goals and processes, striving for innovation and learning. The HCVRN is willing to continue to provide support to RSPO’s new Assurance Standing Committee (ASC).
Clarifications tothe report
HCVRN would like to provide some clarifications to the report:
Terms ‘Auditor’ and ‘HCVRN ALS Assessor’ are used interchangeably and responsibilities of HCVRN and ASI are blurred
Statement (Page 2): Auditorsproviding methodologically and substantively flawed High Conservation Value(HCV) area assessments that will enable destruction of HCVs.
Statement (page 11): Objective 4:Monitor the quality and performance of auditors and pursue suspensions orsanctions against underperforming or persistent offenders. The RSPO has reliedon ASI, and the HCV Resource Network, to perform this function.
Clarification:
HCVRN does not have a direct role inmonitoring the quality and performance of auditors, nor in pursuing related suspensionsor sanctions.
In several sections, the report usesthe terms ‘Assessors’ and ‘Auditors’ interchangeably. It is important toclarify that HCVRN Licensed Assessors and Auditors have different scopes ofwork within the RSPO system and their work occurs at different times in thecertification process.
HCVRN Licensed Assessors are professionals who are contracted by oil palm growers to conduct HCV (or HCV-HCSA) assessments. Licensed Assessors follow strict requirements when conducting assessments (see here)and when submitting their reports for evaluation.
Auditors are responsible for verifying whether oil palm growers comply with the RSPO Principles and Criteria. Auditors produce audit reports informing if the grower is in conformance with the RSPO’s P&Cs requirements. Auditors rely on the RSPO Generic Checklist for Audits and an HCV Audit Guide developed by HCVRN in 2018, among other documents and training provided by RSPO, to verify grower compliance with HCV requirements.
Nyoto Santoso
Statement (Page 17): Following a complaint made to the HCV Resource Network by EIA in 2017, Nyoto Santosa was de-listed as an HCV assessor.
Clarification:
The HCVRN Secretariat received and processed a complaint by EIA following the Assessor Licensing Scheme (ALS) Dispute Resolution Process. The complaint was deemed invalid as it related to events that occurred before the ALS was launched. On May 12th, 2018, provisionally licensed assessor Nyoto Santoso’s licence was revoked. As per ALS rules (see ALS Specification), provisionally Licensed assessors have three attempts to submit two satisfactory assessment reports within two years of receiving a provisional licence. If the assessor fails to do so, the licence is cancelled.
In late 2015, the Environmental Investigation Agency (EIA) and Grassroots published the report ‘Who Watches the Watchmen? 1’, which identified several weaknesses in the Roundtable on Sustainable Palm Oil’s (RSPO) assurance and certification systems. The HCV Network released a clarification statement to that report here.
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Femexpalma
In April 2022, FEMEXPALMA and the HCV Network signed a 5-year cooperation agreement to promote sustainable production of palm oil in Mexico. FEMEXPALMA is a Mexican independent entity that represents palm production at the national level and promotes the increase of productivity in a sustainable way.
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The High Carbon Stock Approach (HCSA) is an integrated conservation land use planning tool to distinguish forest areas in the humid tropics for conservation, while ensuring local peoples’ rights and livelihoods are respected.
In September 2020, HCV Network and the HCSA Steering Group signed a five-year Memorandum of Understanding (MoU) to strengthen their collaboration to conserve forests and uphold community rights in tropical forests. The HCS and HCV Approaches are cornerstones of corporate no deforestation and conservation commitments, and increasingly for actors working at different scales. The collaboration aims to further support effective implementation of these commitments through increased uptake of the HCV and HCS tools.
Through this MoU, HCSA and HCVRN are pursuing two main strategic goals:
- Strive to promote the application of the two approaches in tropical moist forest landscapes and explore further opportunities for collaboration.
- Ensure that, where the two approaches are applied together, this happens in a coordinated, robust, credible, and efficient manner, so that HCS forests and HCVs are conserved, and local peoples’ rights are respected.


World Benchmarking Alliance
From May 2022, the HCV Network is an ally at the World Benchmarking Alliance (WBA). WBA is building a diverse and inclusive movement of global actors committed to using benchmarks to incentivise, measure, and monitor corporate performance on the SDGs, and will assess and rank the performance of 2,000 of the world’s most influential companies against seven systems of transformation by 2023.
The scope of WBA’s circular transformation was expanded to cover nature and biodiversity as recognition of the need for greater understanding, transparency and accountability of business impact on our environment. The WBA Nature Benchmark was launched in April 2022, which will be used to rank keystone companies on their efforts to protect our environment and its biodiversity. As HCV Areas are recognised as key areas important for biodiversity, companies that publicly disclose their actions to identify and protect HCVs will contribute to the assessment of their performance against the benchmark.


Taskforce on Nature-related Financial Disclosures - TNFD
The Taskforce on Nature-related Financial Disclosures (TNFD) is a global, market-led initiative, established with the mission to develop and deliver a risk management and disclosure framework for organizations to report and act on evolving nature-related risks, with the aim of supporting a shift in global financial flows away from nature-negative outcomes and toward nature-positive outcomes.
In April 2022, the HCV Network joined the TNFD Forum. The TNFD Forum, composed of over 400 members, is a world-wide and multi-disciplinary consultative network of institutional supporters who share the vision and mission of the task force.
By participating in the Forum, the HCV Network contributes to the work and mission of the taskforce and help co-create the TNFD Framework which aims to provide recommendations and advice on nature-related risks and opportunities relevant to a wide range of market participants, including investors, analysts, corporate executives and boards, regulators, stock exchanges and accounting firms.


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The Aquaculture Stewardship Council (ASC) is the world’s leading certification scheme for farmed seafood – known as aquaculture – and the ASC label only appears on food from farms that have been independently assessed and certified as being environmentally and socially responsible. In 2021, the HCV Network and ASC formalised their collaboration through a Memorandum of Understanding (MoU). The MoU represents the first step in a fruitful relationship aimed at conserving HCVs in aquaculture. Although, existing guidance on the use of the HCV Approach currently focuses mainly on forestry and agriculture, the HCV Approach is however generic, and in principle also applicable to aquatic production systems. Through this MoU, this is recognised by the Aquaculture Stewardship Council (ASC) in their ASC farm standard, in which the protection of HCV areas is mentioned in the context of expansion


Accountability Framework Initiative
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Biodiversity Credit Alliance
The Biodiversity Credit Alliance (BCA) is a global multi-disciplinary advisory group formed in late 2022. Its mission is to bring clarity and guidance on the formulation of a credible and scalable biodiversity credit market under global biodiversity credit principles. Under these principles, the BCA seeks to mobilize financial flows towards biodiversity custodians while recognising local knowledge and contexts.
The HCVN joined the BCA Forum in August 2023 to learn more from the many organizations already coming together to find effective pathways to opening up credit-based approaches, and how to contribute our knowledge and experience of years of working in a practical way, often with global sustainability standards and their certified producers, to protect what matters most to nature and people.
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Nature Positive Forum

Get Involved
Our Mission as a network is to provide practical tools to conserve nature and benefit people, linking local actions with global sustainability targets.
We welcome the participation of organisations that share our vision and mission to protect and enhance High ConservationValues and the vital services they provide for people and nature. By collaborating with the Network, your organisation can contribute to safeguarding HCVs while gaining valuable insights and connections that support your sustainability goals.
We are seeking collaborative partners to help expand and enhance our work, as well as talented professionals who can join the growing Secretariat team, and for professionals who can contribute to the credible identification of High Conservation Values globally.
Join us in securing the world’s HCVs and shaping a sustainable future.