Committed To Sustainability

Feronia recognises that it operates in a highly complex socio-cultural environment and that in addition to bringing important development benefits and economic opportunities to local communities, the Company’s presence and activities may also generate security risks for Company personnel, Company assets and surrounding populations.

This Policy identifies Feronia PHC’s commitment to work in close collaboration with stakeholders to avoid or minimize security related risks and impacts, whilst maximising opportunities for mutually beneficial and positive change.

Overarching objectives of the Policy are:

• To anticipate and avoid adverse impacts arising from the use of security personnel on the health and safety of the Affected Community.
• To find mutually beneficial solutions to security related issues, wherever possible.
• To ensure that the safeguarding of Company personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.
• To protect Company personnel and assets and to ensure that the rule of law is recognised and respected.
• To embed the Security Management System into the Company’s on-going management and operations.

This Policy is based on Performance Standard 4 (Community Health and Safety) and RSPO Principles and Criteria (Roundtable on Sustainable Palm Oil) adjusted to reflect the circumstances of Company operations in DRC. It provides principles and commitments that the Company will refine and implement via its standard operating procedures (SOPs).

Feronia PHC Commitments

This Policy describes the Company’s commitment to:

1. Identify and assess security related risks as they may affect the Company in its concession and in the wider community as well as potential impacts of the Company’s use of security on Affected Communities.
2. Mitigate potential risks and impacts through alignment of community engagement activities and the security function.
3. Appoint security personnel (or commission third party services) who have appropriate skills, experience and aptitudes.
4. Actively manage the behaviour of all security personnel to ensure appropriate professional standards.
5. Use the Stakeholder Engagement and Community Grievance Mechanisms as key mechanisms for assessing the effectiveness of security personnel performance in the light of the objectives above.
6. Review and report on all security related incidents.

1 Identifying and Assessing Security Risks

Feronia will

• 1.1 Evaluate security related risks to the Company and potential impacts on Affected Stakeholders within and outside planation concessions.
• 1.2 Establish preventive and control measures consistent with good international industry practice.
• 1.3 Develop mitigation measures commensurate with the nature and magnitude of risks
• 1.4 Favour the avoidance of risks and impacts over minimization.
• 1.5 Evaluate whether risks change over time and will adjust the focus of this Policy as appropriate.

2 Mitigating Potential Risks Through Engagement and Management of Security Personnel

Feronia will:

• 2.1 Appoint security personnel (or commission third party services) who have appropriate skills and aptitudes.
• 2.2 Be guided by the principles of proportionality and good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such workers, and by applicable law.
• 2.3 Make reasonable inquiries to ensure that those providing security are not implicated in past abuses.
• 2.4 Ensure that those providing security are aware of this Policy and its requirements and that security personnel are aware of disciplinary action (including dismissal) that will be used to ensure professional standards are met.
• 2.5 Ensure that force is only used for preventive and defensive purposes in proportion to the nature and extent of the threat.

3 Actively Manage the Performance of all Security Personnel:

Feronia will

• 3.1 Ensure that all security personnel whether directly employed by Feronia or via third party sources under Feronia’s control, operate to the same standards.
• 3.2 Train security personnel under Feronia’s control so that they are able to discharge their duties in a safe manner, respecting the needs and wishes of local communities and protecting the rights and assets of the Company and acting within relevant laws and regulations.
• 3.3 Include human rights awareness and sensitivity in training programs (with specific reference to the UN Guiding Principles on Business and Human Rights).
• 3.4 Ensure that if armed security personnel are ever deployed by Feronia, that they have enhanced training in the use of force (and where applicable, firearms), and that their behaviour reflects the requirements of the Voluntary Principles on Security and Human Rights.
• 3.5 Implement a “Zero Tolerance” policy on the use of drugs and alcohol in the workplace.
• 3.6 Not sanction the use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat.

4 Use the Stakeholder Engagement Plan and Grievance Mechanism to Gauge the Impact and Efficacy of this Policy

Feronia will:

• 4.1 Provide a grievance mechanism for Affected Communities to express concerns about the security arrangements and the performance of security personnel in a way that does not create risks for individuals.
• 4.2 Proactively review grievances and wider community sentiment in order to understand impacts and concerns before they become serious or significant.
• 4.3 At least annually, review performance of this Policy at the ESG Management Committee.

5 Reviewing and Reporting Incidents

Feronia will investigate all allegations of unlawful or abusive acts of security personnel, take action (or urge appropriate parties to take action) to prevent recurrence, and report unlawful and abusive acts to public authorities.