06 November 2019

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’.[1] 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 to the 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): Auditors providing 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 or sanctions against underperforming or persistent offenders. The RSPO has relied on ASI, and the HCV Resource Network, to perform this function.


HCVRN does not have a direct role in monitoring the quality and performance of auditors, nor in pursuing related suspensions or sanctions.

In several sections, the report uses the terms ‘Assessors’ and ‘Auditors’ interchangeably. It is important to clarify that HCVRN Licensed Assessors and Auditors have different scopes of work within the RSPO system and their work occurs at different times in the certification 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.


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.

[1] 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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