CONTROVERSY REPORT - Stand.earth

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CONTROVERSY REPORT - Stand.earth
CONTROVERSY IRRESPONSIBLE PULP
            PROCTER &  GAMBLE’S
     REPORT & PALM OIL SOURCING                                                          AND ITS IMPACTS ON PRIMARY
                                                                                         FORESTS AND HUMAN RIGHTS

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 P&G sources pulp from clearcuts like these. Photo: National Resources Defence Council   P&G sources palm oil from clearcuts like these. Photo: Pok Rie from Pexels
CONTROVERSY REPORT - Stand.earth
EXECUTIVE SUMMARY
                                                       Consumer goods giant Procter & Gamble
                                                       (P&G) is now embroiled in a growing number
                                                       of controversies stemming from its sourcing of
                                                       wood pulp and palm oil.1 These controversies
                                                       implicate P&G in violating human rights,
                                                       degrading primary forests and endangering
                                                       threatened species for ubiquitous products
                                                       like toilet paper and soap. They also create
                                                       material and reputational risk for the company’s
                                                       brand equity, especially among socially and
                                                       environmentally conscious consumers and
                                                       investors.2 P&G has four key areas of controversy
                                                       linked to its sourcing of pulp and palm oil:

P&G sources from palm oil plantations that pose an
      immediate threat to nearby habitats like this.

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CONTROVERSY REPORT - Stand.earth
CONTROVERSY 1:

                                                     P&G sources pulp from clearcuts like these. Photo: Kels Pitchenese, Eagle Lake First Nation in Canada

DESTROYING & DEGRADING PRIMARY FORESTS, INTACT FOREST LANDSCAPES
For its pulp and palm oil supply      • Purchases hundreds of thousands of                       last place these trees should end up.
chains, P&G has failed to adopt and     tons of fiber annually from clear-                       P&G uses zero recycled fiber in its
implement mandatory policies and        cut logging in primary and old                           tissue products, while competitor
enforcement protocols that prohibit     growth forests in British Columbia,                      Kimberly Clark uses an average of
deforestation and conversion of         and key boreal forests in Ontario,                       nearly 30% with a goal to reach 50%
natural ecosystems, as well as          Alberta, and Quebec, rather than                         recycled fiber by 2025.
halt expansion into Intact Forest       adding recycled fiber to its single-                  • Sources palm oil from 22 Indonesian
Landscapes (IFLs), old growth and       use name brand products such as                         producers engaged in on-going
primary forests. It has also failed     Charmin toilet paper and Bounty                         peatland destruction, some under
to commit to time bound goals           Paper Towels.3 Boreal forests store                     government indictment.
for reducing forest fiber in tissue     massive amounts of carbon, and
products. For example, the company:     single use tissue products are the

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CONTROVERSY REPORT - Stand.earth
CONTROVERSY 2:

                P&G purchases palm oil from suppliers that dramatically impact farmers like this. Photo courtesy of Rainforest Alliance Network, Farmers of Jambi Province, Indonesia

VIOLATING HUMAN RIGHTS
In regions affected by P&G’s fiber                    • In Canada, some of P&G’s pulp                                      linked to corruption as executives
and palm oil sourcing, the company                      suppliers in BC, Ontario and Quebec                                from its subsidiaries were sentenced
seems comfortable perpetuating                          have Free Prior and Informed                                       to prison for bribing government
colonialist practices rather than                       Consent (FPIC) policies that fail to                               officials.
working to build respectful                             enforce non-compliance issues or                                • A September 2020 investigation
relationships with frontline and                        offer transparency to the Indigenous                              by the Associated Press found that
Indigenous communities, affected                        people who depend on these                                        more than one-hundred current
rights holders and the civil society                    forests, one of the fundamental                                   and former workers from two
organizations supporting them. P&G                      rights laid out in the United Nations                             dozen palm oil companies had been
does not require its suppliers to                       Declaration of Indigenous People.                                 cheated, threatened, held against
demonstrate that adequate policies,                   • In Indonesia, Astra Agro Lestari                                  their will or forced to work off
standard operating procedures and                       (AAL) is implicated in ongoing land                               insurmountable debts. Others said
independent verification mechanisms                     conflicts in rural areas in West and                              they were harassed by authorities
are in place to guarantee that                          Central Sulawesi. AAL’s subsidiaries                              and detained in government
Indigenous Peoples and traditional                      allegedly seized land from the                                    facilities. In Malaysia, P&G’s palm
communities’ rights to free, prior,                     local communities without their                                   oil suppliers4 like FGV and Sime
and informed consent (FPIC) are                         consent and then felled forests to                                Darby are linked to forced labor and
respected. P&G has also failed                          make way for oil palm plantations.                                human trafficking and U.S. Customs
to commit to Zero Tolerance                             Impacted communities allege that                                  and Border Protection has blocked
for Violence, Harassment and                            the company has criminalized local                                palm oil imports from them.
Intimidation. Examples of supplier                      community members who have
violations include:                                                                                                     • P&G has refused to meet with
                                                        resisted the takeover of their lands,                             impacted communities in conditions
                                                        leading to the wrongful incarceration                             that guarantee their security and
                                                        of several land defenders. Another                                anonymity, and arbitrarily picks the
                                                        supplier, Golden Agri Resources, is                               communities it consults.

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CONTROVERSY REPORT - Stand.earth
CONTROVERSY 3:

                                                                                             P&G sources pulp from clearcuts like these.

PUTTING THREATENED AND ENDANGERED SPECIES AT RISK
P&G continues to source from              • In Quebec, Resolute Forest             • In British Columbia, P&G sources a
suppliers that degrade critical caribou     Products is likely sourcing wood         range of companies impacting old
habitat, putting threatened caribou         from the Pipmuacan caribou range         growth and primary forests in the
populations already on a trajectory of      in Quebec, where approximately           province. Some of the logging takes
decline, at further risk. For example:      one-hundred caribou eke out an           place in critical caribou habitat
• In Ontario, Domtar is likely              existence in habitat that is already     including various endangered
  sourcing wood from the Sydney             68 percent disturbed, primarily          herds.
  caribou range, where the caribou          from logging, and being more and
  population is fewer than one-             more disturbed every year.5
  hundred animals and declining past
  the point of no return.

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CONTROVERSY REPORT - Stand.earth
CONTROVERSY 4:

                                                         P&G sources pulp from clearcuts like these. Photo: Kels Pitchenese, Eagle Lake First Nation in Canada

TRANSPARENCY & ACCOUNTABILITY
P&G has failed to develop the            • Despite the weaknesses of the                         • Failed to meet the demands of
systems necessary to create                industry-controlled Roundtable on                       shareholders, 67% of whom voted
transparency and public                    Sustainable Palm Oil (RSPO), P&G                        in favor of a resolution put forward
accountability within P&G’s pulp and       still fell far short of its commitment                  by Green Century Equity Fund
palm oil supply chains. The company:       to achieve one-hundred percent                          calling on the company to report on
• Relies on third party certification      RSPO certification of all palm oil                      how and whether it can eliminate
  systems to provide oversight and         processing facilities. Less than 10                     deforestation and intact forest
  accountability for its pulp supply       percent of P&G’s palm and palm                          degradation from its supply chain.7
  instead of developing effective due      kernel oil sourced in 2019 was
  diligence systems and infrastructure     RSPO certified.6
  that ensure intact primary forests
  and threatened species habitat are
  not in their supply chains.

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CONTROVERSY REPORT - Stand.earth
P&G’S FAILURE TO DISTANCE
 ITSELF FROM IRRESPONSIBLE
SUPPLIERS--SUPPLIERS THAT
     VIOLATE HUMAN RIGHTS,
 DEGRADE PRIMARY FORESTS
   AND ENDANGER    CONCLUSION

      THREATENED
                   Consumer goods giant Procter &
                   Gamble has knowingly and willfully
                   refused to take full responsibility for
                   its supply chain and failed to manage
                   the reputational risk associated

     SPECIES--HAS
                   with its suppliers of pulp fiber and
                   palm oil. P&G’s failure to distance
                   itself from irresponsible suppliers
                   that violate human rights, degrade
                   primary forests and endanger

         BECOME A
                   threatened species--has become a
                   material risk to P&G and its investors.
                   The ongoing controversy regarding
                   its pulp fiber and palm oil sourcing

    MATERIAL RISK
                   will continue to tarnish its brands,
                   including Charmin, Bounty, and
                   Head & Shoulders.
                   P&G has the resources to grow
                   its capacities and lead its sector in

   TO P&G AND ITS
                   truly innovative ways. It simply lacks
                   the will and follow through. These
                   controversies will continue to haunt
                   them unless they make the kinds of

       INVESTORS.
                   changes that the planet and future
                   generations need.

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CONTROVERSY REPORT - Stand.earth
BODY OF REPORT
                                                            For years, mounting evidence indicates that Procter
                                                            & Gamble is sourcing forest products from suppliers
                                                            implicated in environmentally irresponsible logging
                                                            and human rights abuses. Last October, 67 percent of
                                                            P&G’s shareholders responded by voting in support
                                                            of a shareholder resolution urging the company
                                                            to eliminate deforestation and forest degradation
                                                            from its supply chain.8 Rather than demonstrating
                                                            leadership by distancing itself from irresponsible
                                                            suppliers and adding recycled fiber to its toilet paper
                                                            and other tissue products, P&G responded to the
                                                            shareholder revolt with a misleading marketing
                                                            campaign that failed to include a clear plan to end its
                                                            reliance on irresponsible and high risk suppliers.9
                                                            P&G’s management has chosen to retreat to tired old
                                                            talking points about “replanting trees” and outsourcing
                                                            supply chain oversight to third-party certifications.
                                                            10
                                                              This leaves P&G right where it began—highly
              P&G sources pulp from clearcuts like these.
Photo: Kels Pitchenese, Eagle Lake First Nation in Canada   exposed to suppliers that degrade intact primary
                                                            forests and critical habitats and fail to adequately
                                                            protect the rights of local and Indigenous peoples,
                                                            particularly in Canada’s boreal forest and in palm oil
                                                            operations in Indonesia and Malaysia.
                                                            The growing understanding of deforestation, forest
                                                            degradation, and human rights controversies
                                                            means most of P&G’s shareholders know that such
                                                            ineffectual steps cannot prevent the destruction
                                                            of intact primary forests and threatened species
                                                            habitat and guarantee respect for human rights.
                                                            More importantly, P&G’s obfuscation and inaction
                                                            creates significant reputational and financial risks that
                                                            undermines socially responsible investment funds that
                                                            hold P&G stock.

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CONTROVERSY REPORT - Stand.earth
P&G CONTROVERSY
                                             safeguards, putting at risk the           is likely sourcing wood from the
                                             rights of Indigenous communities,         Pipmuacan caribou range in Quebec,

IN CANADA
                                             critical habitat for a federally listed   where approximately 100 caribou
                                             threatened species, and an important      eke out an existence in habitat that
Procter & Gamble purchased 523,900           storehouse of carbon. And yet             is already 68 percent disturbed,
metric tonnes of wood pulp from              Procter & Gamble continues to             primarily from logging, and being
Canada in 2019-20 to make its                source its pulp from these companies      more and more disturbed every year.19
flagship brands Charmin toilet paper         to make single-use products like          Why is so much critical habitat
and Bounty paper towels.11 This              toilet paper while boasting about the     of a federally listed threatened
pulp is made from industrial-scale           sustainability of its operations.         species being destroyed by logging?
logging operations that are driving                                                    Because the Ontario and Quebec
the loss and fragmentation of forests        IMPERILING THREATENED CARIBOU             governments have allowed too much
in boreal and mountain ecosystems            POPULATIONS                               logging to take place in federally
across Canada. The boreal forest,            According to a recent analysis by         designated critical caribou habitat.
in particular, is a climate-critical         NRDC, these three companies               Inexplicably, Ontario has exempted
ecosystem known as the “Amazon of            sourced an average of 9.4 million         logging operations from prohibitions
the North” that stores more carbon           cubic meters of wood from boreal          in its 2008 Endangered Species
per hectare than just about any other        forests in northern Ontario and           Act against destroying habitat of
forest on Earth.12Both boreal and            Quebec.15 This wood comes from            caribou and other species at risk.20
mountain forests are populated by            boreal forest that is carved up by        In 2018, the Quebec government
hundreds of Indigenous communities           roads that allow for industrial-scale     announced that it would not protect
and also home to an array of                 logging, the primary threat to the        the Val D’or caribou herd, which
wildlife species, including dozens of        health and persistence of Canada’s        excessive logging and road building
woodland caribou herds that were             threatened woodland caribou               had reduced to just 18 individuals,
listed as threatened or endangered           populations.                              because it would be too expensive.21
by the federal government in 2012.           Much of the wood supplying the            In late 2019, the Quebec Ministry of
Federal guidelines also established          mills that make P&G’s pulp comes          Forests, Fauna and Parks revoked
that these threatened caribou will           from forest units that encompass          a policy that protected 46,000
have a much greater chance at                legally designated critical habitat       hectares of critical caribou habitat so
long-term survival if their range            for Canada’s threatened woodland          that it could be logged.22
habitat is 65% intact. However, P&G          caribou populations. To maintain and
refuses to commit to ensuring that its       recover these caribou populations,        FAILED CERTIFICATION SCHEMES
suppliers adhere to this science-based       Canada’s 2012 caribou recovery            In practice, this leaves only forest
threshold - essentially cementing their      strategy indicates these forests          certification programs as the primary
acceptance of key threatened species         must remain at least 65 per cent          means of protecting caribou habitat
habitat in their supply chains. This flies   undisturbed (i.e. only 35 per cent can    outside of protected areas. Forest
in the face of the 85% of Americans          be altered by logging and wildfires).     certification programs are, in theory,
that want greener toilet paper.13            Aditya Birla Group, Domtar and            supposed to voluntarily impose
                                             Resolute Forest Products likely are       stricter forest management practices

ONTARIO AND                                  sourcing wood from several caribou
                                             ranges (which each harbor several
                                                                                       than required by law. Only one,
                                                                                       Forest Stewardship Council (FSC)

QUEBEC
Each year, Procter & Gamble
                                             local populations) that are already
                                             approaching or beyond the 35 per
                                                                                       certification, has standards that have
                                                                                       the potential to raise the bar above
                                             cent disturbance thresholds, beyond       status quo industrial clearcut logging.23
purchases approximately 500,000              which caribou herds will continue to      But P&G still finds a way to cut corners.
tonnes of pulp made from industrial          decline. In Ontario, Domtar is likely
forest-clearing in primary boreal                                                      P&G has publicly committed to a
                                             sourcing wood from the Sydney             “preference” for wood pulp from
forests in Ontario and Quebec.               caribou range, where the caribou
These mills are owned by powerful                                                      Forest Stewardship certified suppliers.
                                             population is fewer than 100 animals      Yet its commitment is misleading.
companies such as Aditya Birla               and declining past the point of no
Group, Domtar (Paper Excellence)13                                                     The company exploits loopholes in
                                             return.16 Their forest habitat is 64      the FSC system, resulting in more
and Resolute Forest Products, some           percent disturbed, almost twice
of the largest producers of pulp and                                                   than half of its North American
                                             the sustainable limit.17 The caribou      wood pulp (5.6 million cubic
paper in the world, and they are key         population in the Churchill range (45
suppliers of pulp to U.S. markets.                                                     meters) coming from non-FSC-
                                             percent disturbed) is also fewer than     certified forest units. That fiber is
Unfortunately, these companies               100 and declining, and the habitat is     sourced through some of the worst
consistently fail to implement               already 35 per cent disturbed.18          logging practices in North America,
critical social and environmental            Resolute Forest Products, likewise,       including excessive spraying of

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CONTROVERSY REPORT - Stand.earth
toxic chemicals that poison people,       FSC-certified.26 In the Domtar-           All of these inconvenient facts
water and wildlife, destruction of        managed Trout Lake Forest Unit,           about P&G’s sourcing of pulp from
critical habitat for threatened and       which is almost all critical caribou      Canada’s boreal forests are likely
endangered species, and massive           habitat, logging has increased by 431     only going to get worse. Global pulp
clearcuts in old-growth forests.          percent in the last six years.27          and paper giant Paper Excellence,
There is no requirement to obtain         These three companies are just            headquartered in Richmond, BC,
free, prior and informed consent          the tip of the iceberg. Many more         recently purchased Domtar. Domtar
from Indigenous People whose land         timber companies also operate in          is now owned by a private company
is being transformed into clearcuts       and cut down Canada’s boreal forest,      run by a family that is notorious
and/or plantations, and there are         and decades of scientific research        for both human rights abuses and
not adequate grievance systems for        has made it very clear that wide          deforestation.29 Transitioning from a
impacted communities.24                   scale industrial logging continues        publicly-traded company to a private
                                          to reduce the size and resilience         one could limit both transparency
                                          of Canada’s caribou herds, despite        and accountability and make it even
                                                                                    more difficult for P&G to make
“CARIBOU ARE, SADLY,                      the fact they have been listed as
                                          “threatened” for two decades.
                                                                                    good on its unfulfilled promises of
                                                                                    sustainability.
VERY SENSITIVE TO                         INDIGENOUS RIGHTS
HUMAN DISTURBANCES,                       The continued decline of threatened
                                          caribou herds isn’t the only problem
                                                                                    BRITISH COLUMBIA
                                                                                    In BC, industrial logging of intact
AND WE ARE                                from such unsustainable logging
                                          activity in the boreal forest. Several
                                                                                    forests is the primary reason for
                                                                                    the massive losses of old growth
DISTURBING CARIBOU                        First Nations have traditional
                                          territories and treaty rights in the
                                                                                    forests and steep declines in caribou

MORE AND MORE,”
                                                                                    populations over recent decades,
                                          boreal forest areas being logged          particularly the threatened southern
                                          for wood pulp. Aditya Birla Group,        mountain population of woodland
DR. JUSTINA RAY,                          Domtar and Resolute Forest Products       caribou. Southern mountain caribou
WILDERNESS CONSERVATION SOCIETY           may have Free Prior and Informed          once roamed suitable habitat in
CANADA PRESIDENT AND SENIOR SCIENTIST     Consent (FPIC) policies, but they         all of SW BC, but today, only 17
                                          fail to provide transparency, ensure      subpopulations hang on in a fraction
                                          compliance, and enforce non-              of their historic range. Despite being
Reliance on inadequate certification      compliance for the Indigenous             listed under Canada’s Species at Risk
schemes explains why caribou              people who depend on these forests,       Act in 2003, logging, as well as other
habitat is being destroyed by P&G’s       one of the fundamental rights laid        human activities and forest fires,
suppliers. Of those public forest units   out in the United Nations Declaration     has extirpated six subpopulations of
that are majority (i.e. more than 50      of Indigenous People.                     southern mountain caribou30 and
per cent) caribou range habitat, only                                               three additional population units are
                                          Eagle Lake First Nation, for
10 per cent (425,700 of 4.3 million                                                 now all but guaranteed to vanish from
                                          instance, is working to protect its
cubic meters) of the wood sourced                                                   the face of the earth in the near future.
                                          traditional lands on the Farabout
each year by Aditya Birla Group,                                                    In 2018, a scientific analysis indicated
                                          Peninsula in Eagle Lake, which is
Domtar and Resolute Forest Products                                                 that 18 of 23 (78%) local population
                                          slated to be logged by non-FSC-
combined is from FSC-certified                                                      units were declining and 22 of 34
                                          certified Dryden Forest Company
forests.25 This means that the vast                                                 (65%) subpopulations were less than
                                          Ltd. There are no caribou here,
majority of the wood being sourced                                                  100 individuals.31
                                          but it’s an unspoiled refuge of
from critical caribou habitat is from
                                          biodiversity full of thousands of         The central reason for these tragic
non-FSC-certified forests, which puts
                                          irreplaceable Indigenous cultural and     declines and disappearances is
the caribou herds in these areas at
                                          archaeological sites dating back 7000     the destruction of caribou habitat,
significant risk of continued decline
                                          years. “The peninsula is sacred to us,”   primarily by road building and clear-
and extirpation.
                                          wrote Chief Arnold Gardner to the         cut logging of old growth and intact
Resolute Forests Products, for            Ontario Minister of Natural Resources     primary forests. More than 900 sq km
instance, sources 2.6 million cubic       and Forestry in 2018. “Any disruption     of southern mountain caribou critical
meters of wood from non-FSC-              of these sites … by the Dryden Forest     habitat was logged in BC during the
certified public forest units that are    Management Company would be               five years after it was identified in 2014,
majority caribou habitat, and none of     a violation of the Ontario Heritage       an estimated 50% increase in the area
the wood sourced by Aditya Birla and      Act” and “would violate Indigenous        of critical southern mountain caribou
Domtar in public forest units that are    rights and would be an action of          habitat logged. Logging in old growth
majority caribou habitat is               remarkable cultural insensitivity.”28     forests and caribou habitat continues

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EAGLE LAKE FIRST NATION CASE STUDY
In the heart of Ontario’s boreal forest, Migisi Sahgaigan (Eagle Lake) First Nation is a
rural Anishinaabe Ojibwe First Nation of about 700 people in northwestern Ontario,
situated along the northeast shores of Eagle Lake, approximately 25 km southwest of
Dryden.
Historically, their livelihood consisted of fishing, hunting, trapping, gathering,
harvesting wild rice, and horticulture. Today, the Eagle Lake First Nation’s economy is
based primarily on trapping, forestry and manufacturing, as well as employment in the
service sector.
Cultural activities are as important to Eagle Lake society as economic affairs, and
include pow-wows, ceremony, sharing circles, arts & crafts, traditional healing and
Elders’ activities. And at the center of it all is the land and the water they have occupied
for thousands of years.
“Everything that makes us up as people comes from the land,” says Miles Pitchenese
who works for ELFN Lands and Resources. “Our language comes from the land. We go
out there to look for answers. The trees, rocks, water have spirits, too, and understand.
We have to stop and listen and understand, and we have to make decisions not only
for us but also our great great grandchildren.”
Several decades ago, members of the community started to notice logging crews and
equipment, and large clear cuts soon followed. Logging companies cut trees right up
to the edge of waterways and fly over spraying herbicides with helicopters, practices
that demonstrate a blatant disregard for health, safety and sovereignty of Eagle Lake
First Nation. Now they are trying to protect their traditional lands on the Farabout
Peninsula in Eagle Lake, which is slated to be logged by non-FSC-certified Dryden
Forest Company Ltd.
“The biggest problem for the community is that irresponsible logging is changing how
community members interact with the land,” says Daniel Morriseau, also with ELFN
Lands and Resources. “It reduces what areas the people can interact with the land
safely. “Cutting to shore impacts fish habitat, water quality, changing wetlands and
canoe routes, and wild rice harvesting areas. It also affects food and medicinal plant
gathering and how far community members have to go to harvest.”
The forest destruction leaves “a sadness you can’t explain,” Morriseau laments.
“You can’t understand why [the logging is] happening. It’s a tragic feeling to know
that the impact on plants and animals will have a severe impact on the people. It’s
heartbreaking.”
Morriseau knows there are better, more sustainable forestry practices, and would like
the logging companies to work with Eagle Lake First Nation to implement the best
possible practices: no cutting to shore, no spraying, no clearcutting and protections
for sacred sites and areas of intact forest.
“The practices now are unsustainable,” he says. “P&G needs to hold itself to a higher
standard. Some forests are FSC certified, some are not FSC at all. FSC has the highest
standard for environmental and social. Those standards are not being adhered to.”

WILL P&G HONOR THEIR RIGHTS AND WISHES?

                                                                                               11
to threaten and extirpate southern         and pending cutblocks, as per              Interfor is the largest sawmiller in the
mountain caribou populations.32            government data, clearly overlaps          region around Celgar: it mills over one
Procter & Gamble admits on its             with caribou habitat (see Map 1).          million cubic meters of logs annually
website to buying pulp from BC.33          This includes critical habitat of          at two facilities alone, accounting for
They purchase an estimated 25,000          multiple southern mountain caribou         over 40% of the lumber production
to 50,000 metric tons per year of          herds east of their mills in Prince        capacity in the Selkirk Natural Resource
BC northern bleached (NBSK) kraft          George: George Mountain, Narrow            District.44 Both of these mills are major
pulp from industrial logging in BC,        Lake, North Caribou and the Hart           wood chip suppliers to Celgar,45 and
or roughly 15% of the total volume         Ranges. The George Mountain herd           one is located immediately adjacent to
of NBSK pulp exports from BC to the        is already likely extirpated,38 and        Celgar and supplies all its
US.34 While the lack of transparency       the Narrow Lake herd is down to            co-product wood chips to the pulp
in pulp supply chains makes it difficult   approximately 40 individuals.39 The        mill. The majority of logs for these
to know with certainty from whom           North Cariboo herd has declined            sawmills come from Interfor’s nearby
P&G buys it’s BC pulp, a review            from more than 275 in 2005 to about        forest operations, which overlap
conducted by Stand.earth Research          210 in 2016,40 while the Hart Ranges       extensively with mountain caribou
Group of customs data, trade               herd, the largest of the mountain          habitat (see Map 2) and includes
statistics, investor presentations,        caribou ecotype, has experienced           many endangered southern mountain
corporate filings, company websites        a 45% decline since 2006; the last         caribou herds.
and government data indicates pulp         population estimate in 2016 found          Overall, of the 909 sq. km. of critical
mills owned by Canfor and Mercer           just 375.41 And still Canfor logs in       southern mountain caribou habitat was
likely constitute supplies the vast        critical caribou habitat identified as     logged in the five years between 2014-
majority of BC softwood pulp to the        part of the recovery plan meant to         19, which had been legally identified
US market, with most other BC mills        prevent these herds from declining         under Canada’s Species at Risk Act
focused on Asian markets.                  further, including in old growth forest.   (SARA).46 This includes forest habitat of
According to an upcoming analysis                                                     the recently extirpated (locally extinct)
being conducted by Stand.earth
Research Group, Canfor and Interfor        “THE THREATS TO                            South Selkirk herd47 located to the east
                                                                                      of Celgar (see Map 2).
(Mercer’s primary chip supplier - see
below) are among the top loggers of
                                           CARIBOU CRITICAL                           P&G’S ROLE
old growth forests in the province,
and are active in several mountain
                                           HABITAT HAVEN’T                            To minimize its responsibility, P&G
                                                                                      claims that lumber is really the driver
caribou herd ranges.35 Like their peers
in Ontario and Quebec, these forestry
                                           REALLY CHANGED.                            of logging, not tissue products.48
                                                                                      However, selling wood chips for
companies have been certified
by one or another third-party
                                           IT’S UNSUSTAINABLE                         pulp is so lucrative that even the
                                                                                      logging industry regularly refers to
certification schemes. (SFI, PEFC,         LOGGING IN PRIMARY                         it as a “co-product” and not a “by-
                                                                                      product.”49 Furthermore, according
                                           FORESTS, MOSTLY IN
FSC).36 Unfortunately, like Ontario
                                                                                      to the government’s own data, BC
and Quebec, the lack of meaningful
                                                                                      pulp mills consumed about 5.8 million
government regulations means
these third-party certifications have      WESTERN CANADA, AND                        cubic meters of whole trees in 2019,
                                                                                      representing over 26% of their total
been wholly ineffective at protecting
old-growth forests, critical caribou       UNSUSTAINABLE OIL                          fiber input.50 For some mills such
                                                                                      as Mercer Celgar, the figure is even
habitat and other environmental
values in BC.                              AND GAS DESTRUCTION                        higher, as noted above (i.e. 33%).
                                                                                      Regardless of whether the fiber used
CANFOR                                     OF CRITICAL HABITAT.”                      by pulp mills comes directly from
                                                                                      forests (whole trees) or indirectly
Canfor’s logging operations around         HEBBLEWHITE
Prince George are the primary                                                         (wood chips from sawmills), BC pulp
supplier for their NBSK pulp mills                                                    mills and the demand for pulp by
(Northwood and Intercontinental),          CELGAR AND INTERFOR                        companies like P&G are a key driver of
Canfor claims that 100% of                 In 2019, Mercer’s Celgar mill,             logging in caribou habitat, despite the
their supply comes from non-               in Castlegar, BC, processed                fact the federal recovery strategy for
controversial sources, avoiding            approximately 2.3 million cubic meters     woodland caribou indicates no more
wood harvested from areas that             of fiber, made from both whole logs        critical habitat should be disturbed.
threaten high conservation values          (33%) and wood chips (67%).42 Celgar’s     P&G’s Box Elder Mill in Utah and Cape
such as endangered caribou.37              chips are sourced from 30 different        Girardeau Mill in Missouri are among
However, Canfor’s currently active         suppliers (primarily sawmills) in the      the P&G paper mills buying BC pulp.51
                                           southeast part of the province.43          These mills produce Bounty and

                                                                                                                             12
¯¯

                                                        Km
                                           0            Km
                                               50 100 150
                                           0   50 100 150

  MAP 1                            Canfor Pulp mills
           Canfor's                Canfor Pulp mills
  Canfor’s   Prince
          Canfor's
      Prince George
                                   Canfor Sawmill
                                   Canfor Sawmill
  George
     Prince
   Pulp     Pulp
          Mills   Mills
               George
                 sourcing
                                   Canfor Active & Pending Cutblocks
                                   Canfor Active & Pending Cutblocks
  sourcing
  PulpCanfor's
from     Millsfrom
                 sourcing
                    logging    Caribou Herd Risk Status
  Canfor’s
from         logging in
        Canfor's   logging
          in critical          Caribou Herd Risk Status
                                    Endangered
                                   Endangered
  critical
         incaribou
     cariboucritical habitat
                 habitat           Threatened
                                                          Data Sources:
                                                          BC Government
                                                          Data Sources:
    caribou habitat                Threatened
                                   Trace Occurrence       Data
                                                          BC    Catalogue,
                                                             Government
                                                          National Geographic
                                   Trace Occurrence       Data Catalogue,
                                                          National Geographic

    RESEARCH GROUP                                                              13
¯

                                                                                       Km
                                                                   0       25         50

      Mercer Celgar Pulp Mill
MAP 2 Interfor Sawmill                            Mercer Celgar Pulp Mill
                                                        Mercer's Celgar Pulp Mill's
      Interfor Logging Tenure
Mercer’s Celgar pulp                              Interfor Sawmill
                                                    sourcing    from Interfor's logging
                                                                                                 M
 Caribou Herd Risk Status
mill’s sourcing from
     Recently Extirpated    Data Sources:               in Logging
                                                  Interfor  criticalTenure
                                                                     caribou habitat
Interfor’s logging in
     Endangered
     Trace Occurrence
                            BC Government
                                      Caribou Herd Risk Status
                            Data Catalogue,
                            National Geographic
                                                                                              sour
critical caribou habitat                          Recently Extirpated   Data Sources:            i
                                                                        BC Government
                                                  Endangered
                                                                        Data Catalogue,
                                              Trace Occurrence          National Geographic
  RESEARCH GROUP                                                                              14
Charmin brand tissue products. P&G          Approximately 85 percent of all            plantations in Indonesia’s protected
has not done enough to ensure that          palm oil comes from Indonesia              Forest Zone. More than 75,000
these brands do not source from             and Malaysia, where environmental          hectares of GAR’s plantations -- ,
high-risk supply chains. It matters very    devastation and attendant labor and        more than 15% of its total plantation
little if Bounty or Charmin is made         human rights abuses are common.55          area -- appears to be devoted to
from certified pulp, or if the pulp mills   Large, often shady companies set           unpermitted oil palm production.
that supply P&G claim to reduce their       fires to remove primary forests            Corruption and related governance
environmental harm because if we            and make room for increasing               issues also pose significant risks. In
pull focus from the just cutblocks that     numbers of huge monoculture                2019, three executives from GAR
are planned and look across all the         palm plantations. This process             subsidiaries were convicted and
harvesting that has already occurred,       warms the planet, destroys the only        imprisoned for bribing local officials
we see that there is very little left of    remaining habitat of endangered            to overlook the lack of permits and
mountain caribou habitat that has           Sumatran tigers, Sumatran rhinos and       extensive water pollution.59
not already been impacted, while the        orangutans, driving them towards
risks to their habitat and their future     extinction. Local people who have
continue to compound.                       been making a subsistence living for
                                            generations are kicked off the land
                                                                                       “THE USE OF FORCED
P&G SCANDAL IN                              without their consent, denied the
                                            right and opportunity to practice their
                                                                                       LABOR IN THE
SOUTHEAST ASIA                              traditional livelihoods, and threatened
                                            with violence—even killed.
                                                                                       PRODUCTION OF SUCH A
Palm oil is the world’s most widely
consumed vegetable oil and is used          Despite its no-deforestation policy,       UBIQUITOUS PRODUCT
in everything from food to cosmetics
and biofuels, including P&G’s Head
                                            P&G is among a host of consumer
                                            goods companies and palm oil               ALLOWS COMPANIES
& Shoulders shampoo and Gillette
shaving gel. More than 70 million
                                            traders that continue to purchase
                                            palm oil linked to illegal deforestation   TO PROFIT FROM THE
tons are produced annually, and             in Indonesia and Malaysia.56 P&G’s
                                            supply chains continue to be linked
                                                                                       ABUSE OF VULNERABLE
                                                                                       WORKERS…. ”
that number is predicted to more
than triple by 2050.52 Unfortunately,       to palm oil operations that have been
palm oil production is one of the           subject to court action, administrative
most poorly regulated and harmful           sanctions and other government              BRENDA SMITH, EXECUTIVE ASSISTANT
industries in the world, responsible        intervention, all of which have failed     COMMISSIONER OF CBP’S OFFICE OF TRADE
for massive deforestation of primary        to resolve the problems.                   HTTPS://WWW.CBP.GOV/NEWSROOM/
forests, upending healthy ecosystems
                                            INDONESIA                                  NATIONAL-MEDIA-RELEASE/CBP-ISSUES-
and destroying endangered animal                                                       DETENTION-ORDER-PALM-OIL-PRODUCED-
                                            P&G continues to source from as
habitat, exploiting workers, and
violating Indigenous Peoples and
                                            many as 22 palm oil producers              FORCED-LABOR-MALAYSIA
                                            and traders engaged in ongoing
local communities’ land rights.
                                            deforestation and peatland                 Astra Agro Lestari, another P&G
Deforestation driven by palm                destruction, at least six of which are     supplier, is implicated in ongoing land
oil production also releases vast           also facing government sanctions           conflicts in rural areas in West and
quantities of carbon into the               for their role in the massive 2019         Central Sulawesi. AAL’s subsidiaries
atmosphere. The tropical forests            fires that scorched Indonesia’s            have allegedly forcibly seized land
destroyed for palm oil plantations are      forests and peatlands.57                   from the local communities without
some of the most carbon-rich in the                                                    their consent and then felled
                                            Two specific cases from one
world. The slash-and-burn clearing                                                     forests to make way for oil palm
                                            Indonesian province serve to illustrate
and subsequent burning of forests                                                      plantations. Impacted communities
                                            the problem. As of late 2019, P&G
and the conversion of swamps                                                           allege that the company has
                                            continued to source palm oil from PT
releases large amounts of carbon                                                       criminalized local community
                                            Marita Makmur Jaya, which cleared
dioxide and methane. For example,                                                      members who have resisted the
                                            2,100 hectares of peat and peat
forest fires in Indonesia in 2019                                                      takeover of their lands, leading
                                            forest in 2019, and from Tunas Baru
released 708 million tons of CO2.53                                                    to the wrongful incarceration of
                                            Lampung, which cleared a reported
The wastewater from palm oil                2,900 hectares of peat forest in 2019,     several land defenders. More than 30
refineries is another huge source of        both in South Sumatra.58                   complaints have been made related
methane; the methane produced                                                          to intimidation and incarceration
                                            In Central Kalimantan, Golden Agri         of community members, as well as
by a single pond of palm refinery
                                            Resources (GAR), another P&G               regarding deforestation, flooding,
wastewater has the same annual
                                            supplier, unlawfully operates oil palm     and landslides as a result of the
climate impact as 22,000 cars.54

                                                                                                                            15
conversion of intact forests to palm       they were harassed by authorities and    serious labor rights violations on
oil plantations.                           detained in government facilities. One   Malaysian palm oil plantations.67
In Jambi Province, AAL has cleared         of these companies was FGV Holdings      The U.S. Department of Labor has
forests for oil palm plantations           Berhad, one of Malaysia’s largest palm   highlighted the widespread use of
on lands traditionally owned,              oil companies and a joint venture        forced labor in the Malaysian palm oil
occupied and used by Orang Rimba           partner and major palm oil supplier      industry since 2010.
communities. Land expropriation            to P&G. The allegations against FGV
involved violence, intimidation,           were so egregious the U.S. Customs       FAILED CERTIFICATION SCHEMES
                                           and Border Protection banned the         As in Canada, P&G relies on third-
poisoning and forced evictions.60
                                           importation of FGV palm oil.65           party certification programs to
PT Setia Agrindo Lestari, one of
                                                                                    uphold its stated policies of no
the largest palm oil producers in
                                                                                    deforestation, the protection of
Indonesia, obtained a government
environment permit in 1995, which
was renewed in 2006 without
                                           “SUSTAINABILITY                          wildlife habitat and upholding the
                                                                                    rights of workers and Indigenous
any consultation and no prior              IS MUCH BROADER                          people. In particular, P&G requires
                                                                                    its palm oil suppliers to “ensure no
                                           THAN JUST SPECIES
agreement with the Orang Rimba.61
                                                                                    deforestation and no development
Deforestation and displacement
                                                                                    on peatlands” and to “protect,
by industrial palm monocultures
have undermined the Orang Rimba            PROTECTION.                              conserve, and enhance the habitats
                                                                                    for wildlife and endangered species
traditional way of life based on
gathering, hunting and small-              IT’S ABOUT PEOPLE’S                      that call forests their home.” It also
                                                                                    commits to “source our palm and
scale rotational farming. Some
communities have been displaced            LIVELIHOODS;                             palm derivatives in a manner that
                                                                                    respects workers and indigenous
onto their remaining ancestral forest
lands within Bukit Duabelas National       IT’S ABOUT THEIR                         peoples’ rights.”68
Park,62 while more than 750 remain
as landless squatters on their own         WELL-BEING;                              However, the overwhelming
                                                                                    evidence in Indonesia and Malaysia
land. Affected communities have
lost traditional sources of food and
                                           IT’S ABOUT                               indicates that these certification
                                                                                    schemes do not adequately regulate
income, and have lost their forests
and seen their sacred sites destroyed.
                                           GREENHOUSE GAS                           supply chain transparency for
                                                                                    sustainable palm oil, and continues
P&G has refused to meet with directly      EMISSIONS;                               to allow corruption, exploitation
                                                                                    of migrant labor, forced labor and
impacted communities and their
civil society supporters. Prominent        IT’S ABOUT CLEAN,                        human trafficking (i.e. human rights
                                                                                    abuses), as well as mass deforestation
Indonesian civil society groups have
repeatedly requested a meeting with        HEALTHY WATER;                           and the destruction of critical habitat
                                                                                    for endangered species.69
P&G -- without P&G’s main supplier
(Wilmar) present. P&G has refused,         IT’S ABOUT HAVING                        P&G has been a member of the
saying they would only meet with
impacted groups and communities            ACCESS TO A DECENT                       Roundtable on Sustainable Palm
                                                                                    Oil (RSPO) since 2010. The RSPO
with Wilmar present.
                                           WAGE.”                                   claims to have “developed a set of
                                                                                    environmental and social criteria
MALAYSIA                                   MATTHEW STRUEBIG, TROPICAL               which companies must comply
In Malaysia, palm oil plantations cover    CONSERVATION SCIENTIST AT THE            with in order to produce Certified
more than 15 percent of the country’s                                               Sustainable Palm Oil (CSPO). When
land area and occupy 63 percent of
                                           UNIVERSITY OF KENT IN THE UNITED         they are properly applied, these
the farmland.63 P&G’s palm kernel oil      KINGDOM HTTPS://WWW.LIVESCIENCE.         criteria can help to minimize the
supply chain is the company’s single       COM/PALM-OIL.HTML                        negative impact of palm oil cultivation
biggest supply chain.64 Here, P&G’s                                                 on the environment and communities
palm oil suppliers have been linked to                                              in palm oil-producing regions.” P&G
forced labor and human trafficking.        This is only the latest evidence in a    has committed to use only RSPO-
A September 2020 investigation by          long-standing saga of widespread,        certified palm and palm kernel oil in
the Associated Press found that more       ongoing forced labor conditions          its products by the end of 2021.70
than 100 current and former workers        on FGV plantations. In 2015, the
                                           Wall Street Journal exposed serious      In its latest annual report, P&G states
from two dozen palm oil companies                                                   it sourced a total of 188,034 tonnes
had been cheated, threatened, held         human rights and labor abuses
                                           on FGV’s plantations.66 In 2014,         of palm and palm kernel oil in 2019.
against their will or forced to work off                                            Despite a commitment to achieve
insurmountable debts. Others said          Finnwatch released a report finding

                                                                                                                             16
100 percent RSPO certification of all      It gets worse. “The vast majority of
palm oil processing facilities by 2016,    palm oil is traced only as far back
less than 10 percent of its palm and       as the mill where it’s processed, not
palm kernel oil sourced in 2019 was        to the field where it’s produced.
RSPO certified.71 And it is far from       Eyes on the Forest, a coalition of
likely that the other 90+ percent will     Indonesian NGOs that includes the
be certified by 2022.                      WWF – the same organization that
Even if P&G does achieve its goal          spurred palm oil certification – said
of sourcing 100 percent RSPO-              in a 2016 report that ‘mill traceability
certified palm and palm kernel oil,        [on its own] wastes time and money
this alone will not allow it to meet       without offering a solution to the
its stated policy objectives. After all,   issues of illegal products entering the
Golden Agri Resources, one of P&G’s        supply chains.”73
Indonesian palm oil suppliers that         It’s clear that P&G can’t rely solely on
unlawfully operated in protected           the RSPO to ensure that its stated
forests and bribed local officials to      sustainability goals—no deforestation,
look the other way, is a member of         protecting critical wildlife habitat for
RSPO.                                      endangered species, respecting the
Numerous investigations and                rights of working and Indigenous
allegations indicate that RSPO-            people—are achieved. Instead, it
certified suppliers continue the           must conduct its own due diligence
unlawful and unethical practices that      and take a more proactive role
it’s “environmental and social criteria”   in ensuring that it’s suppliers and
are supposed to curtail. In 2016, the      supply chains are not involved in
Environmental Investigation Agency         deforestation and human rights
concluded that RSPO is “woefully           abuses.74
substandard” and “in some cases …
colluding … to disguise violations”.
The Guardian reported in 2019
that “a product can earn a ‘certified
sustainable’ label even if 99% of the
palm oil it includes came from freshly
deforested land.”72

                                                                                      17
P&G MISLEADS ITS CUSTOMERS
                                 Despite all the evidence to the contrary, Procter & Gamble likes to portray itself as a
                                 sustainable company that cares about people and the environment. But instead of
                                 holding their suppliers accountable, P&G relies on misinformation to convince its
                                 investors and customers that its products don’t cause deforestation, destroy wildlife
                                 habitat or infringe on the rights of local and Indigenous people.

            P&G SPIN THE TRUTH
   Wood pulp and water are       The wood pulp P&G uses
                                                                             P&G SPIN THE TRUTH
                                                                     100% of our wood pulp        P&G outsources
“ingredients found in nature”    for its Charmin, Bounty and          is certified by a leading   responsibility for social and
  and “sourced from forests.”    Puffs products is sourced            third-party certification   environmental impacts by
                                 from logging 100 percent        system ensuring forests are      hiding behind third-party
                                 virgin primary forests.                responsibly managed       certification schemes
                                 Instead of using recycled                                        that do not guarantee
                                 fiber, P&G promotes                                              sustainability or responsible
                                 logging that destroys and                                        sourcing. Some of these
                                 degrades wildlife habitat,                                       certification schemes do
                                 threatens the land and                                           not provide adequate
                                 way of life of Indigenous                                        protections for intact
                                 peoples, and robs the                                            primary forests, critical
                                 planet of one of its more                                        habitat of threatened
                                 important defenses                                               caribou populations, or
                                 against climate change.                                          ensure the free, prior
                                 The alternative is to use                                        and informed consent of
                                 recycled fiber, which has                                        Indigenous peoples.
                                 the least impact on forests,
                                 water, climate and wildlife,
                                 which P&G has so far
                                 refused to do.

            P&G SPIN THE TRUTH
         P&G ensures all our     P&G sources all its palm
                                                                            P&G SPIN THE TRUTH
                                                                 We’re Acting with Urgency        P&G recently announced
          suppliers have the     and palm kernel oil from             to Reduce Emissions         its “Climate Transition
      necessary policies and     Malaysia and Indonesia,                                          Action Plan” to make P&G
      procedures in place to     and relies on the                                                emissions “Net Zero” by
ensure responsible sourcing      Roundtable on Sustainable                                        2040. Yet their climate
 of palm oil, palm kernel oil,   Oil Palm certification                                           targets exclude emissions
        and their derivatives.   scheme to ensure                                                 from their tissue and
                                 responsible sourcing.                                            paper towel products,
                                 However, only a small                                            selectively excluding
                                 portion of its products                                          them from the products
                                 are RSPO certified, and                                          their targets apply to. By
                                 the RSPO has proven                                              comparison, Kimberly-
                                 incapable of ensuring that                                       Clark has indicated that
                                 palm oil production does                                         it will expressly include
                                 not result in deforestation,                                     greenhouse gas emissions
                                 destruction of wildlife                                          from natural forest fiber
                                 habitat, and human rights                                        into its scope 3 supply
                                 abuses.                                                          chain target

                                                                                                                             18
P&G SPIN THE TRUTH
All forest certification   P&G promotes the logging
                                                                    P&G SPIN THE TRUTH
                                                            For every tree we use, at   Replanting trees does not
schemes adequately         industry’s misleading                least one is regrown.   fully compensate for the
   protect forests and     greenwash about forest                                       environmental impact
   Indigenous people       certification programs.                                      of cutting down primary
                           Not all forest certification                                 forests. Clearcutting does
                           schemes are created                                          permanent damage to
                           equal. P&G “prefers” to                                      forests that replanting
                           use Forest Stewardship                                       does not fix—scarring
                           Certified wood pulp, the                                     the landscape and
                           most credible and effective                                  changing the fragile
                           certification scheme, but                                    balance of organisms and
                           less than 50 percent of                                      microorganisms in the soil,
                           its pulp is FSC chain of                                     which reverberates all the
                           custody certified. Instead, it                               way up the food chain.
                           relies on other certification                                Boreal trees grow very
                           schemes, such as the                                         slowly, and it takes decades
                           Sustainable Forest Initiative                                to centuries for newly
                           and the Programme for                                        replanted trees to capture
                           the Endorsement of Forest                                    the carbon that mature
                           Certification systems,                                       trees do. Clearcutting in
                           which do not adequately                                      the boreal forest allows
                           protect high conservation                                    the release of enormous
                           forests, wildlife habitat, or                                amounts of greenhouse
                           the rights of Indigenous                                     gases stored in the boreal’s
                           peoples. Even FSC is an                                      carbon rich soils. In much
                           imperfect and inconsistent                                   of the boreal, replanting
                           tool to protect forests and                                  operations are not proving
                           people’s rights. P&G must                                    successful at replicating
                           commit to ensuring that                                      forests that resemble the
                           suppliers adhere to 65%                                      biodiverse, carbon-rich
                           habitat range intactness                                     ancient forests that were
                           thresholds for caribou and                                   removed and research
                           additional due diligence                                     in Ontario shows that
                           to provide an assurance of                                   deforestation in this key
                           responsibly sourced wood                                     boreal forest province is
                           products.                                                    happening at a rate that is
                                                                                        seven times greater than
                                                                                        the reported deforestation
                                                                                        rate by forestry for all of
                                                                                        Canada - underscoring
                                                                                        that deforestation in other
                                                                                        provinces is also likely
                                                                                        being under-reported.75

                                                                                                                 19
P&G SPIN THE TRUTH
   We’re committed      Some of the energy
                                                                 P&G SPIN THE TRUTH  In October 2020, the
                                                        We are committed to the
 to purchasing 100%     Procter & Gamble is             responsible management       world’s largest asset
renewable electricity   sourcing to meet its goal       of the world’s forests and   managers, including
    globally by 2030.   is from biomass. Biomass         our conscientious use of    BlackRock and State Street,
                        means burning forests                    forest products.    voted overwhelmingly
                        to create energy. P&G                                        to urge P&G to eliminate
                        partnered with Exelon to                                     deforestation and intact
                        build a new 50-megawatt                                      forest degradation from
                        biomass facility in Albany,                                  its supply chains, making
                        GA, one of the largest                                       it the first ever forest-
                        biomass energy plants                                        related shareholder
                        in the U.S. P&G is telling                                   proposal to pass. Instead
                        its customers that this                                      of taking the necessary
                        is part of its renewable                                     action to improve
                        energy portfolio, but                                        its sourcing of forest
                        environmental benefits                                       products, the company
                        from burning biomass                                         doubled down on selling
                        instead of coal depends                                      a myth of sustainability
                        on the specifics of the                                      to consumers. Though a
                        feedstock sourcing and                                       recent Charmin ad touts
                        how the facility is operated.                                the brand’s commitment
                        It is improbable that this                                   to “Protect, Grow, and
                        facility’s feedstock will                                    Restore” forests, P&G’s
                        consist entirely of sawmill                                  recent announcements
                        residuals and forestry                                       and PR campaigns have
                        waste. The carrying                                          more closely resembled
                        capacity of forests in the                                   a “Deflect, Distract, and
                        area is approximately 25                                     Ignore” approach, once
                        tons/acre: at least 400                                      again choosing spin over
                        acres of Georgia forests                                     meaningful action to
                        must be cut daily to feed                                    protect climate-critical
                        this plant. The volume                                       forests.
                        alone is troubling enough,
                        but burning green wood
                        chips can produce as
                        much pollution and carbon
                        as coal. This facility is, at
                        best, questionable in terms
                        of sustainability.76 Burning
                        trees to produce electricity
                        releases up to 50 percent
                        more carbon dioxide per
                        kilowatt hour than burning
                        coal.77, 78, 79

                                                                                                             20
RECOMMENDATIONS
The following actions by P&G will       HUMAN RIGHTS
begin to address the environmentally    • Respect the human rights of First        halt expansion into Intact Forest
and culturally unsustainable and          Nations and frontline communities.       Landscapes and primary forests.
unethical controversies linked to its
                                        • Require suppliers commit to obtain      • Embrace FSC forest certification:
products, and eliminate the financial
                                          free prior, and informed consent          Any virgin forest fiber in tissue
risks posed by the significant gap
                                          (FPIC) from Indigenous Peoples and        products must be responsibly
between its current choices and its
                                          frontline communities.                    sourced, but also certified by the
stated values.
                                        • Publically commit to only source          Forest Stewardship Council (FSC),
• Address the concerns of                                                           the only acceptable third-party
                                         from suppliers that adhere to the
  shareholders, impacted                                                            certification system. Commit to
                                         practice of obtaining free, prior, and
  communities, and organizations                                                    work with Canadian suppliers to get
                                         informed consent (FPIC).
  representing millions of concerned                                                all of their management units FSC
  citizens.                             • Require all suppliers to prove            certified and in compliance with the
                                          that adequate policies, standard          new FSC Canada standard in a way
• Adopt and publish aggressive, time-
                                          operating procedures and                  that excludes ranges with a 35% or
  bound leadership commitments.
                                          independent verification                  greater disturbance level.
                                          mechanisms are in place to prove
                                          that Indigenous Peoples and             THREATENED SPECIES: PROTECT CARIBOU
                                          traditional communities’ rights to      • Protect boreal caribou habitat.
                                          free, prior, and informed consent         Publicly commit to avoid sourcing
                                          (FPIC) are respected in existing          from Canadian boreal caribou
                                          and new forest-risk commodity             ranges with a 35% or greater
                                          production operations on their            disturbance level. Commit to
                                          lands and traditional territories.        responsible, caribou-safe fiber
                                        • Commit to Zero Tolerance                  sourcing that doesn’t put caribou
                                          for Violence, Harassment and              and First Nations at risk.
                                          Intimidation, as proposed by The        • Eliminate all suppliers that
                                          Geneva Declaration.80                     degrade or destroy critical caribou
                                        • Accept all requests to meet one-          habitat. Replace or establish an
                                          on-one with communities affected          exit plan for P&G’s suppliers that
                                          by irresponsible palm oil and fiber       continue to aggressively log
                                          suppliers.                                intact Canadian boreal forests
                                                                                    and who are not compliant with
                                        PROTECT FORESTS                             65% habitat intactness thresholds
                                        • Stop sourcing from primary forests.       that threatened caribou (reindeer)
                                                                                    populations require for long-term
                                        • Publicly support new protected areas.
                                                                                    survival, as defined by Canadian
                                        • Continue to invest in alternative         Federal scientific analysis.
                                          fibers and work with credible
                                                                                  • Adopt a clear standard that P&G
                                          third parties such as Closed Loop
                                                                                    will, within 6 months, no longer do
                                          Partners to help drive system
                                                                                    business with logging companies
                                          change as a pathway to reduce
                                                                                    that harvest in critical caribou range
                                          virgin forest fiber. Commit to
                                                                                    habitat beyond 35% disturbed.
                                          reduce forest fiber in tissue
                                          products by 50% by 2025. Replace        • Require suppliers to qualify by
                                          virgin fiber with recycled81 and          having plans that meet or beat
                                          alternative fiber and invest in           Canadian federal caribou science
                                          research to overcome any technical        standards within 1 year.
                                          or cultural barriers.82                 • Require suppliers provide proof
                                        • Adopt and implement mandatory             every quarter that they are not
                                          policies and enforcement                  harvesting in any remaining critical
                                          protocols for P&G’s pulp and              caribou habitat.
                                          palm oil supply chain that prohibit
                                          deforestation and conversion of
                                          natural ecosystems as well as

                                                                                                                        21
• Actively and publicly advocate on       • Disclose independent verification      These actions will enable P&G to
  behalf of forest protection and           mechanisms that are in place to        step into a leadership role and
  indigenous sovereignty with the           ensure that suppliers can prove        demonstrate that it is making
  Canadian government.                      fulfillment of FPIC rights.            progress on implementing a suite
• Inform the Canadian Federal             • Create a grievance process that        of credible actions, against clear
  and Provincial governments that           provides a clear method for            timelines, which have been designed
  their lack of action on boreal            individuals and organizations to       to immediately address its impacts on
  caribou recovery and caribou              file complaints over violations of     primary forests and endangered and
  science standards outlined by             P&G’s supply chain policies and        threatened species habitat; uphold
  their own government scientists           procedures and timelines within        human rights; and hold suppliers
  is now putting P&G’s continued            which P&G will respond to credible     who do not comply with P&G’s no
  business relationship with logging        complaints. This program should        deforestation and human rights
  companies in Canada at risk.              include a publicly accessible          policies accountable.
                                            grievance tracker with a minimum
ADDRESS THE CLIMATE IMPACTS OF PULP
AND PALM SUPPLY CHAINS
                                            of 60 months history.
                                          • Disclose names and contact
                                                                                   CONCLUSION:
• Analyze, disclose and cut                 information for P&G pulp suppliers,
  greenhouse gas emissions from                                                    We share Procter & Gamble (P&G)’s
                                            and publish the results of a forest    goal of minimizing the company’s
  land use impacts (including forest        footprint analysis for its pulp
  sourcing) by 50% by 2025.                                                        impacts on globally important
                                            supply chain and palm oil and          forests, the climate, and human
                                            palm kernel oil supply chains in
BE TRANSPARENT AND ACCOUNTABLE              Malaysia and Indonesia.
                                                                                   rights. We believe progress is
• Stop outsourcing 100% of supply                                                  possible at P&G, as is true corporate
  chain oversight of fiber and palm       • Publish a regular progress report on   leadership. The current context of the
  oil supply chains to third-party          the enforcement of P&G’s policy        climate emergency, the biodiversity
  certification systems. Implement          to prohibit deforestation and Intact   crisis, and ongoing human rights
  a publicly transparent in-house           Forest Landscape and primary           violations associated with high-risk
  process to evaluate and manage            forest degradation in its pulp and     commodities in P&G’s supply chains
  suppliers, including robust non-          palm oil supply chains including:      requires the company to act with
  compliance protocols with clear         • The pulp and palm oil suppliers that   urgency and deliver auditable results.
  metrics that trigger suspension or        have been independently verified as
  termination of bad actors and sub-        compliant with P&G’s policies and
  standard suppliers.                       No Deforestation, No conversion
• Immediately replace irresponsible         and degradation of natural
  suppliers that fail to meet P&G’s         ecosystems and Peatlands, and No
  standards or that use violence,           Exploitation production practices.
  intimidation or coercion against        • Fulfillment of P&G’s commitment to
  local communities. The measure            eliminate pulp supply from critical
  of any commitment, policy or              caribou habitat
  protocol is the extent to which it
                                          • An update on the implementation
  results in P&G taking action against
                                            of its deforestation and forest
  irresponsible suppliers and replacing
                                            degradation policy, as well as the
  them with those that are aligned
                                            company’s progress toward its
  with P&G’s values and policies.
                                            commitment to reducing forest
• Publish the steps P&G will take           fiber in its tissue products.
  to consult affected communities
  and to manage allegations and
  complaints. Immediately sever
  relationships with suppliers that
  use violence or intimidation against
  local communities.

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