Environmental groups have released details critiques of an oil-palm project in Cameroon being developed by a New York-based investment firm, Herakles Capital, through the company Herakles Farms. The critiques from WWF International, Greenpeace and the Oakland Institute can be found here: http://j.mp/CameroonPalm This is a response from the CEO of Herakles Farms, Bruce Wrobel.

1. This is the two-part response from Bruce Wrobel, chairman and CEO of Herakles Farms, to
criticisms of the company’s oil-palm project in Cameroon made by WWF International,
Greenpeace and the Oakland Institute:
Part One:
September 5, 2012
Andy Revkin
Dot Earth Blog
Dear Andy,
Thank you for the opportunity to respond to the statements made in the press release of WWF
Cameroon attached to your message to Delilah.
I would like to first state in the strongest terms that Herakles Farms is fully committed to the
ideals of sustainability and although it is true that we have recently withdrawn from RSPO it
remains our full intention to meet or exceed the standards of RSPO as well as the IFC
Performance Standards (World Bank) for commercial agriculture projects. Sustainability comes
from a company’s actions and not from membership in a voluntary organization and we are
confident our actions will prove our commitment to the principals of sustainability.
Then the obvious question becomes “why did we withdraw”. It is simply because RSPO as an
organization is still too young and is missing the key technical staff to carry out its mission to
assist stakeholders in vetting projects suitable for oil palm cultivation. We submitted an
application for approval of New Planting Procedures earlier this year. Such application
summarized the results of the environmental studies completed and per procedure were
published for public comment. As expected comments were raised and many of those were
good comments which have been taken into consideration by Herakles Farms. Unfortunately
many of the comments are subjective comments which are difficult to respond to such as not
enough of the area was studied. During this process the company responds to the comments
which generate additional responses and so on and so on. But with broad subjective comments
(and we believe with some parties whose ultimate intent is stopping the project regardless of
the merits) you quickly get to a situation where one side finally says enough work has been
done and then other disagrees. In a normal regulatory environment – such as with the EPA in
the United States – after ample opportunity for views to be expressed and evidence submitted
the regulatory body ultimately has the technical expertise to adjudicate the disagreement.
Such Is not the case with RSPO. They have limited staff, are a voluntary organization and
cannot possibly be expected to have the technical expertise necessary to cover issues specific
to every region of the world. So it becomes a process without end in those cases where the
respective parties continue to hold onto subjective views.
Our concession in Cameroon was provided with the expectation that our investment would

2. quickly generate employment in a region with some of the poorest demographics and that our
efforts would eventually help eliminate the importation of palm oil from Asia. Our concession
was granted in 2009 and we have yet to plant a single tree into the field. For the past three
years we have been performing environmental and social studies (we received all of our
needed environmental approvals in Cameroon a year ago) and yet have not delivered upon
many of the employment commitments as a result of our extended efforts (with no end in
sight) of trying to secure a decision with respect to our RSPO application. We have come to the
realization that the RSPO as an organization is still too young to deal with these type of
situations. You may recall that the Indonesian palm oil industry trade group also recently pulled
out for similar reasons
But we intend to follow the guidelines and standards of RSPO as well as the World Bank’s IFC
Performance Standards. In fact we are involved in some experimental initiatives that we
believe will allow us to exceed some of those standards and create new standards of “best
practices”. At the same time we are now reaching out to University’s in Cameroon and the
United States as well as some reputable environmental NGOs with respect to developing a set
of Sustainability Standards tailored to the specific characteristics (social and environmental) of
Cameroon. We are hopeful that the investment community will see these as a real effort to
implement Best Practices.
With respect to the land we have fully committed to preserving any stands of virgin forest
identified within the concession and we have already mapped out many of those particular
stands. The area we are developing is secondary degraded forest with much of the area
harvested for timber in the not too distant past. The government has examined the land and
determined it to be degraded secondary forest and we utilized an RSPO recommended assessor
to do the same. All of our studies confirm these assessments as well. While it is true that we
are surrounded by four large protected regions none of those are being managed and in fact,
the Korup National Park, one of the largest and potentially most valuable had less than 1 visitor
per day last year and a management budget of less than $20,000. It is part of our plan to add
the improved management of these resources to our CSR programs.
Andy, the internet is completely filled with misinformation regarding this project and
sometimes we feel like the little Dutch boy trying to plug all of the holes in the dike. For
example there are approximately 8500 residents within and near this concession, an extremely
low population density but one that allows the project to proceed without having to move
anyone off of their land. We have focused our efforts in the area of those communities which
are embracing the project and have spent a considerable effort on social development while
waiting for the RSPO process to move. For example this year we launched a four week program
of free health, medical interventions and minor surgeries to the communities at our expense
and as a result more than 3000 individuals took advantage of it. We also just recently awarded
27 full college scholarships to graduating youths from the area with guaranteed offers of
employment should they maintain a suitable GPA during the course of their degree work.
Finally as you may also be aware WWF is really an organization comprised of many individual

3. country based franchises none of which are required to coordinate with any particular head
office with respect to the positions they take. If you have a contact with WWF Washington I
would encourage you to reach out to them and ask whether they are in agreement with the
position of WWF Cameroon taken in their press release (though I assume they will be quite
concerned about our withdrawal from RSPO).
Part Two:
I guess my Dutch boy plugging the dike still holds!
The report is certainly full of inaccuracies, false statements and incendiary commentary. But
being an activist myself I certainly admire their tenacity and resolve and I do recognize that
their efforts are driven by their beliefs.
But some key responses.
We are not proceeding with any activities in an illegal manner. If you think about it for a second
do you believe that the Government of Cameroon would sit by and allow us to operate illegally?
We have many expats residing in the country and we would certainly never jeopardize their
safety by operating contrary to the laws of Cameroon. Our Agreement with the government
identifies in a schedule every permit and authorization required to proceed with the project.
We have obtained all of those permits and approvals.
Even the references to the court cases are misleading. The court case was not an action
initiated by the government but an action by a local NGO in a local court. The court did identify
four things that the Company had to comply with prior to proceeding. As soon as the company
satisfied the court that those steps had already been taken the case was dismissed and the
court issued its position that we were in compliance with the law.
The report expresses shock at our right to arrest and detain. We do not have the right to arrest
but we do have the right to detain. This is no different than the right of a security guard in
Macy’s to detain a shoplifter and to turn him over to authorities. The project has extremely
valuable equipment and unfortunately theft (due to the extreme poverty) is endemic in the
region. There is also a scarcity of police stations so the ability to detain someone within the
project and caught stealing is necessary and is really no different than any other international
or domestic company in Cameroon has the right to. Although I would have to check to be
certain I do not believe we have ever had to use this right yet.
The report criticizes our economic deal with the government of Cameroon and suggests that
the rental rate per hectare is low. This ignores the fact that in addition to any central
government payments we must invest in water, transportation, health and education
infrastructure as well as assist in providing suitable housing for our workers. No agriculture
project in the developed world has to carry the cost of education or building roads or schools.

4. So the rental rate does not reflect the true value to the government of this investment. In
addition the government pushed this project to encourage rapid employment in a severely
underemployed region. It is expected that we will ultimately provide more than 8000 jobs
leading to economic and social stability in the region.
Suggestions made that this is a large project is also misleading. At 60,000 hectares we would be
approximately a quarter of the size of Sime Darby’s Project in Cameroon and this would rank as
one of the smaller commercial scale palm oil plantations in Malaysia or Indonesia or proposed
by the big industry players in West Africa. But I believe that being an American based company
makes us a much more suitable target precisely because we do care about our reputation and
US investors do care about the impacts of their investments on the environment.
Much is made in the report of problems at a village called Fabe. There was an altercation at the
nursery there which we believe was instigated by the same NGO who filed suit in the local court
and took advantage of a number of local disgruntled workers who had been fired for theft from
the nursery. We maintain a zero tolerance policy among our workers with respect to theft .
After the incident we shifted a shipment of seedlings to an alternative nursery which prompted
a visit from the village chief, the village youth leader and the village women’s group leader to
the company’s headquarters where they wished to hand deliver a written apology for the
incident together with assurances that such an incident would no longer occur if we would
reconsider the intent to divert the seedlings.
The upshot is that the Oakland Institute is concerned about a real issue. There are some
massive land grabs taking place across Africa under some nefarious conditions and I do believe
that the deals need to be examined in the context of governmental and societal objectives and
benefits. Unfortunately we believe that they are attacking one of the few which has the
potential for being a poster child for responsible and sustainable development.