- The Forestry Stewardship Council, a voluntary global certification was established in 1993 by environmentalists, Indigenous groups, human rights advocates and the timber industry to help ensure sustainable forestry practices.
- A recent report has raised alarm over the implementation of the remedy framework, which allows companies to reclaim certification if they redress past environmental and social harms.
- Mongabay interviewed FSC’s new director-general, Subhra Bhattacharjee, who stressed Indonesia’s role in how the remedy framework will be implemented worldwide.
- “When you think of Indonesia, you think of these lush natural tropical forests. You think of the breadth of the biodiversity … sometimes it takes my breath away, the kind of biodiversity we have. The world depends on these natural tropical forests,” she says.
Forestry companies, including pulp and paper producers, have a long history of deforestation and social conflict in tropical countries like Indonesia.
In Indonesia, millions of hectares of rainforest and peatland have been cleared to make way for industrial forest plantations, displacing thousands of communities from their customary lands in the process.
To help ensure sustainable forestry practices, a voluntary global certification organization, the Forest Stewardship Council (FSC), was established in 1993 by a coalition of environmentalists, Indigenous groups, human rights advocates and timber industry players.
Since then, FSC has grown into the world’s most recognizable ethical wood certifier. Its logo — a green checkmark and stylized tree — is widely used to assure consumers that forestry products are sourced sustainably.
In 2022, Mongabay spoke with then-FSC director-general Kim Carstensen, who emphasized the need to strengthen the credibility and accountability of forest certification. Two years later, his successor, Subhra Bhattacharjee, is leading the FSC through one of its most ambitious reforms to date: the remedy framework.
Adopted in 2023, the framework allows companies previously disassociated from FSC, including some responsible for major deforestation, to regain certification if they undertake credible efforts to redress past environmental and social harms.
Indonesia, home to some of the most protracted and complex forestry conflicts in the tropics, is now the testing ground for this framework. Two of the world’s largest pulp and paper producers, including APRIL, are currently undergoing the remedy process.
But a recent report by a coalition of NGOs — including Forest Peoples Programme (FPP), Yayasan Masyarakat Kehutanan Lestari and Bahtera Alam — has raised alarm over how the process is being implemented. The report identifies serious shortcomings in APRIL’s social baseline assessment, including a flawed methodology, the lack of free, prior and informed consent (FPIC), the exclusion of customary communities and limited transparency.
Against this backdrop, Mongabay sat down with FSC’s new director-general, Subhra Bhattacharjee, during her recent visit to attend the FSC Remedy Forum, a two-day dialogue discussing the remedy framework, in Jakarta. Bhattacharjee stressed Indonesia’s central role in shaping how the remedy framework will be implemented worldwide, saying the country “will teach us first where our limitations are, how we need to operate better and how we need to customize to local conditions.”
She also responded to criticisms of the process, outlined FSC’s next steps and reflected on the lessons emerging from Indonesia’s implementation of the framework.
The following interview has been lightly edited for clarity and length.
Mongabay: How is FSC navigating the implementation of the Remedy Framework so far, particularly in complex social and environmental contexts like Indonesia?
Subhra Bhattacharjee: We know forests are complex, not just ecologically, biologically, but for the very nature of forests, the relationship between forests and people and communities and governments.
Those are intensely complex and there’s a history to it. You cannot take a snapshot and understand the nature of relationship between forest communities and forests. In that context, it makes the remedy process complex, sensitive and politically charged.
Which means the easy thing to have done is stay away from controversial issues. We could have worn the white shirt and FSC could have said that we don’t engage in this. But our membership told us it is important enough to engage.
It is important enough to engage because globally, millions of hectares of land are in need of restoration. That’s at stake. Hundreds of thousands of communities have suffered social harm.
That restitution is at stake. We could say, OK, let’s play safe, not engage in this. Those have suffered harm, that’s in the past; but harm that is suffered affects generations, right?
The life path is affected. So, that’s why we feel it’s very important to engage. That is why I’m here for four days engaging in these conversations.
Because of the complexity of the issues. First, the remedy framework is our normative document that has been extensively consulted on and approved by the membership. That we cannot change without going through the whole process.
Under that, it’s a very rigorous pathway that lays out what steps need to be taken to assess harm, to make restitution and to restore degraded forests. So, the social and environmental aspects. Involved in these conversations are communities, and we’ve heard, you’ve seen in the room, there are the representatives from the communities, local CSOs and NGOs, international NGOs, businesses, trade organizations, private sector companies, and you’ve also seen the government of Indonesia was there, and of course, we as FSC.
Now, FSC is a platform for dialogue. That makes us uniquely suited to create the space for all of these actors to engage, talk to themselves and define the agenda. Of course, there will be differences of opinion.
Of course, there will be contentious issues. But we are a consensus-based organization, which means we set the table, we enable communities to talk. And it is our commitment that this is difficult, but we will do everything we can to make it work.
Mongabay: From the recent FSC Remedy Forum in Jakarta and your stakeholder engagements, what key concerns have been raised by different parties involved in the process?
Subhra Bhattacharjee: So, in the room, plus in my conversations with the various stakeholder groups, what I hear is a broad-based support for the remedy framework. In addition, I’m hearing concerns about the specific elements of it. Some of them include, for instance, from the NGOs about things like, say, the baseline assessments.
How are they going? Are they detailed enough? Are they comprehensive enough?
Has the FPIC process worked? These are questions that have come up. From the companies, we are hearing, “OK, is there an end in sight? How long is this taking? What else is necessary? Are we moving the goalposts?”
Those are things we are hearing. I was also told that among the communities, there is this sense that anticipation of restitution, but again, how much time it will take? When is this coming?
So, there is a mix of a degree of impatience on one hand to get on with it and actually see results. On the other hand, there are also questions and concerns about the rigor of the process.
Mongabay: How does FSC balance the need for a rigorous, participatory process with stakeholders’ expectations for timely restitution and visible outcomes?
Subhra Bhattacharjee: Impact orientation. It combines optimism and hope on one hand, the big ideals. On the other hand, pragmatism.
Yesterday, when I spoke to the group, I clarified that the harm that has been done, the rights that have been violated, the time, the years that have been lost, they cannot be fully restituted no matter what. You do not make up with money where the life of a whole family has changed. At the same time, we need to hear every voice on the table.
Not everyone will get everything they want. That’s by definition the nature of compromise. So, we are not looking to go back into an ideal state in the past.
Because Indonesia, things have changed on the ground. What we need is a practical process so that we are not taking up time and effort of the communities who have to make their living, taking up their time in meeting after meeting after meeting, delaying the process. But we are getting them restitution quickly.
At the same time, being very transparent about things, being very clear about the methods. And undertaking a robust, high-integrity process.
Mongabay: Do you believe it will be possible for the remedy process to return land rights to affected communities, especially those with longstanding land disputes?
Subhra Bhattacharjee: That’s exactly why we need a robust process that we can rely on. That’s why we need the baseline assessment, which will be done not by the company, not by FSC, not by the community itself. It has to be done by a third party.
Once that independent assessment is done, we need another third-party verifier to say that the process has been robust, clean, high integrity. And then comes the question of what is acceptable or not.
But this has to be a locally led, owned and driven process. It is not for me or for anyone from outside Indonesia to say what should be the end goal. In some cases, there will be agreements.
In other cases, there will not be. The one thing we should be able to guarantee is a high integrity process. The outcome, we cannot guarantee.
Mongabay: A recent NGO report raises concerns about gaps in the baseline assessments, particularly regarding engagement with affected communities. How does FSC respond to those findings?
Subhra Bhattacharjee: I could give you a response, or I could say scroll down and read the response in Remark Asia’s responses there in the annex. Read it. And what’s more, let’s not stop there. The response is there. Again, it won’t be me choosing the NGO version or the Remark version, because I’m sitting in one.
There will be a third-party verifier who will come and look through all of this and tell us if what has happened is robust or not. And that’s what I mean by a high-integrity process.
But where I stand, or where you stand, it’s important to look at both sides of the story. You’ve talked about the allegations. Look at the response, which is there in the annex.
And if there is doubt, let’s wait till the third-party verifier checks it and tells us.
Mongabay: One of the criticisms centers on the lack of transparency, especially the limited access communities and civil society have to the full results of the social baseline assessments. Why is only a summary made available?
Subhra Bhattacharjee: So, if you look at the language of our remedy framework, which, by the way, was extensively, extensively consulted, including consulted with the NGOs and technical experts, who understand this far better than, say, I would. If you look at the language of the remedy framework, it says a summary of the baseline assessment will be published, not the full one. So, the question is, why not the full one?
So, first is, our hands are tied by the remedy framework. OK. It’s our normative framework.
But, ‘hands are tied’ is even not the exact way to say it. Because there’s a question, why the summary, why not the full report? A lot of the baseline assessment might have corporate information, which is business intelligence that a company might not want to share with its competitors with the greater world, right?
And, FSC is not law enforcement. We are a voluntary compliance mechanism, and we respect that. So, that is why, when the NGOs, when the technical experts and our membership sat around the table and negotiated the remedy framework, they put in their summary of baseline assessment for a reason.
Until it gets approved, once it gets approved by FSC membership, and there’s a way, our framing of our normative documents, there’s a very detailed process. And, something like the remedy framework, do you know how long it took to negotiate and get that, the various stages? The process started in 2017, with two separate remedy-related procedures.
And then came a point after the first consultation, where FSC secretariat was given the mandate to merge them, because they both dealt with remedy. And then came the second consultation, where it was the merge procedure, which took place in early 2022. And then, at the General Assembly in 2022, we had to have the policy to address conversion passed by our membership.
Only once that happened could we present the board the final version of the remedy framework in November 2022. So, over five years.
So, literally, each word has been thought through in that remedy framework.
It’s not just that everyone needs to agree, it needs to be technically sound. So, all our normative documents have a technical component, where subject matter experts come in and tell us what it should be. Then, social, economic and environmental chamber members — they weigh in.
Because all of these working groups have to have representation. Otherwise, you might end up with something that is lopsided, ignores one in favor of the other. So, these are chamber-balanced working groups, they then go over it.
So, it’s multiple layers of scrutiny and approval that needs to happen.
Mongabay: In addition to concerns about flaws in the baseline assessments, civil society groups have raised alarms over ongoing deforestation and reported intimidation of Indigenous communities in Indonesia. One of the focal points is PT Toba Pulp Lestari (TPL), a pulpwood company in North Sumatra that is a key supplier to APRIL and whose operations have long been the subject of land conflict allegations.
In May 2025, hundreds of TPL workers held a protest demanding the expulsion of Indigenous rights organizations from the region, and days later, a prominent environmental activist reportedly received a terror package — a dead bird — at her home.
In light of these events, and the wider concerns around intimidation and unresolved social harms, is there any possibility that FSC might pause the remedy process to ensure a safe and credible environment for communities to participate?
Subhra Bhattacharjee: There are two different issues here. One is the technicality of the baseline assessments that we’ve been discussing, so that’s separate. On these allegations of threats of violence and intimidation, these are extremely serious threats.
And we take it very seriously. First, if there’s proof, credible allegations and proof, we will take it up. It hasn’t come through so far in the complaints mechanism.
There’s a mechanism for reporting this. So far, it hasn’t come through. If it comes through, there will be an investigation.
That said, we want to be very careful about what we are talking about. Because there seems to be a perception that the remedy framework is for the companies. No, the primary target of the remedy framework is the people who will receive restitution and the restoration of the land.
That is too important to just say let’s pause it until we figure it out. No, we have to learn in the process of doing, iterate and improve. Of course, there are challenges.
But the answer to that is improving on the go. It’s not that we stop the process and sit down and figure things out. Because these are not things you figure out around the table.
These are things you figure out on the ground while implementing. And then keep improving. We really count on the expertise of the NGOs because they are here on the ground.
They really know the ground-level realities. We count on their expertise to keep us informed, to help us improve the process. And some of these conversations that you are seeing, that’s exactly the purpose.
When there’s an allegation, it is important that that needs to be substantiated. And the source needs to be understood. What is the root cause?
Who made the threat? And where did it come from? And it needs to be investigated.
So I don’t take it lightly. It’s extremely serious. And my expectation is that collectively, with all of these years on the ground, we will figure out our processes, improve our processes.
Mongabay: If communities or civil society groups face threats or intimidation, how can they raise complaints within the Remedy Framework? What mechanisms are in place to ensure those concerns are addressed promptly and independently?
Subhra Bhattacharjee: So within the remedy framework, there’s scope for first a grievance mechanism. Now the grievance mechanism sits with the company. So the first complaint will go to the company.
Then, meanwhile, we keep tabs whether the company is responsive or not. If the company doesn’t respond, half the time we hear about it. And that’s part of our conversation with the company.
If the grievance mechanism is not working, then we will say that you’re not observing the remedy framework right. So that’s one element. But our policy of association lists six unacceptable behaviors.
Among them are violation of customary rights and human rights. If there’s a policy of association-related complaint, that comes straight to FSC. That doesn’t go to the company.
Remedy framework-related grievances go to the company. Policy for association-related complaints come straight to FSC and we investigate.
Mongabay: Is there any circumstance under which FSC might launch its own investigation into potential violations, even if no formal complaint has been lodged through the company’s grievance mechanism?
Subhra Bhattacharjee: If there is a policy for association violation complaint, then it’s up to us. For instance, there are ongoing policy for association investigations, different ones are ongoing at any point of time.
If we get one of those, yes, then we do it. But with the remedy framework, if this piece of the baseline assessment is not working, their FPIC didn’t work, that first goes to the company.
Mongabay: Greenpeace recently released a report alleging Royal Golden Eagle (RGE), APRIL’s parent group, has undisclosed control over 257 shadow companies. Has FSC reviewed these claims, and how are they being incorporated into the current due diligence process?
Subhra Bhattacharjee: Yes, FSC reviewed that and we provided our response. Any company is going through its day-to-day business, and as part of the remedy framework, there are certain actions being taken.
Now, it could have acquired some processes after the remedy framework process started. So within the remedy framework, we have a built-in mechanism periodically to review the scope of the company. Say it started with five subsidiaries or five associated companies.
Over time, it has acquired three more. Sometime during that periodic review, those three will come into the ambit. They’ll be dissociated from FSC and come into the ambit of the remedy framework.
And then over time, there’ll be others. So this check is built in. Right now, such a review is ongoing for our GE.
And when the Greenpeace report came through, it’s very detailed. We’ve passed it on to our third party, which is doing the review right now. Once we have those, then we will take action on that.
So this is an ongoing process because, say, two years from now, there’ll be other companies in the ambit. So the next review will pick those up. So it’s a kind of iterative process.
We contract someone to do the review. We don’t do it in-house because it takes a very specific skill in corporate governance.
Mongabay: If FSC’s ongoing review of RGE’s corporate structure confirms the Greenpeace findings, will the scope of entities under the Remedy Framework be expanded accordingly?
Subhra Bhattacharjee: Yes. So that is a regular process. That won’t be anything extraordinary.
Mongabay: What has FSC’s engagement with the Indonesian government been like? Is there a plan to collaborate more closely to ensure land restitution and justice for impacted communities?
Subhra Bhattacharjee: The presence of the Minister of Forestry’s yesterday [during the first day of the FSC Remedy Forum in Jakarta] was very encouraging. And the support he verbalized towards the remedy framework, the remedy process, that was very encouraging. So that was really great.
The way it will affect our engagement in the process is to make sure that everything we do aligns with Indonesia’s development goals, development aspirations, those have to be taken into account. Because ultimately, it’s the people of Indonesia who should be benefiting. So that is an important part.
You mentioned whether the land will be returned. Again, like I told you earlier, that is not something I can say, that is not something any outsider will say. We will set up a process.
National actors will determine how and what restitution is done. At the same time, you have to remember that the government of Indonesia is, by national law, the custodian of forest lands. That is my understanding of national law.
So that is not something FSC will have a say in. What’s more, it’s not Indonesia specific. If tomorrow we do a remedy process in another country, it will be honoring the laws of the country.
And the whole process will empower local actors to adopt a remedy solution that is tailored to their specific national and local context.
Mongabay: Can you tell me more about the remedy framework’s work plan?
Subhra Bhattacharjee: Remember I told you that we cannot change anything in the remedy, language of the remedy framework. But how we implement it, there is flexibility there. The purpose of these two days have been to gather all the stakeholders have them sit around the table, talk to each other, understand each other’s positions and help us, you know, air these concerns that have been coming.
And really, not just in vague ways, but really parse into them what it means. So, we’ve gathered all those inputs. We go back and then we devise a work plan of how to implement what we need to do in addition to what’s ongoing, what needs tweaking.
So, that plan of action will be formulated. We will get back to the participants here. So, there’ll be a bit of back and forth.
And the idea is that between now and the General Assembly, we will work on that. At the General Assembly, there are two side events happening on the remedy framework, and that’s where we put it, the result of this work.
Mongabay: How important is Indonesia to FSC’s broader strategy, both in terms of forest conservation and the rollout of the Remedy Framework globally?
Subhra Bhattacharjee: I could not overstate how important it is. And, you know, when you think of Indonesia, you think of these lush natural tropical forests. You think of the breadth of the biodiversity.
When I think of it, sometimes it takes my breath away, the kind of biodiversity we have. The world depends on these natural tropical forests in Indonesia, in the Congo Basin, elsewhere, as its lungs, as we are navigating the climate crisis and biodiversity crisis. At the same time, it is unfair to say that a developing country must keep its forests standing, thriving and resilient.
But hey, it’s entirely your problem. We depend on it, but we are not going to fund it. That doesn’t work.
What we need, and that’s why I keep stressing, we have to adapt to local realities. Local livelihoods have to be supported, jobs have to be supported, the development aspirations have to be supported. And if we want to keep these forests thriving, we’ll have to figure out ways for supporting these communities, bringing in the finance to keep the forests standing.
So, again, Indonesia is critical for the way we see forests of the world evolve, and also how forest management practices evolve.
Mongabay: And what about the importance of Indonesia in the context of the remedy framework itself?
Subhra Bhattacharjee: Very important, because with the first two remedy processes, we are learning, we are iterating. The challenges we face will teach us how to adapt. Somewhere down the line, our remedy framework will come up for revision.
Now, through the operational implementation process, we can do things, but I cannot change a word in the remedy framework. I have to observe that. We have to observe that.
But eventually, we collect the learnings like we did in these two days. This will tell us first how we operate better, but down the line, how we need to revise our remedy framework. We will take some of these lessons to inform remedy processes globally.
So, the Indonesian context will teach us first where our limitations are, how we need to operate better, also how we need to customize to local conditions, because what works in Indonesia won’t necessarily work in another country, but the processes will. So, we’ll have to figure out how to do that tailoring in another country.
Mongabay: Are you aware of any similar remedy processes being undertaken by other certification bodies or institutions in the forestry sector?
Subhra Bhattacharjee: Outside of FSC, I wouldn’t know. Not in the forestry sector, for sure. There are compensations, but not remedy.
Remedy means there is this whole process of engaging with the community, deciding together with the community, the whole social and environmental harm, remedying those. So, this is a much more participatory, much more detailed, rigorous process.
Mongabay: Has the environmental baseline assessment — as required under the Remedy Framework — begun for the APRIL case?
Subhra Bhattacharjee: I don’t think it has started. Well, in the remedy framework, it doesn’t say that you have to finish one before doing another, but what stage the other one is in or whether it has started, I don’t know yet.
Mongabay: So, there’s going to be a revision of the remedy framework in the future?
Subhra Bhattacharjee: All our entire normative framework gets periodically updated, revised. So, at some point, these two will get revised.
Mongabay: When can stakeholders expect the next revision of the Remedy Framework to take place?
Subhra Bhattacharjee: Five years. So, the remedy framework was published in 2023, January. It became effective in July 2023. So, five years from the day it became effective.
Mongabay: What aspects of the Remedy Framework or its implementation might be improved, based on your observations so far?
Subhra Bhattacharjee: See, we are just at the beginning of two processes. Till they go on a little more, till the processes advance a little bit more and we’ve collected some learnings, we’ve validated those learnings, I think it’s premature to comment on that.
Mongabay: Despite the challenges, what gives you confidence that the Remedy Framework will succeed in delivering justice to affected communities?
Subhra Bhattacharjee: Everyone that I’ve spoken to, everyone that I’ve heard from, recognizes the importance of this. Even those who are asking for it to halt, even those who are very critical of it, they deeply, deeply care for the fact that thousands and thousands of people have been harmed and their futures are at stake. That shared understanding gives me hope.
Mongabay: Is there anything else about FSC’s work or the Remedy Framework that you believe is important to highlight but hasn’t yet been discussed?
Subhra Bhattacharjee: The world is in the midst of an ongoing crisis. It’s not far away. It’s literally lives will be affected, current generations will be affected, negatively affected.
And billions of people will be affected. Forests are a critical line of defense against climate change. In other words, the entirety of the 8 billion people on Earth, their quality and the very existence of their lives depend on forests because they are a critical line of defense, which means that stakeholders from across the world, every kind of stakeholders across sectors need to come together to keep forests thriving, to keep forests resilient.
And that will not happen without looking at the forest-related communities, including Indigenous peoples. You will not be able to protect forests by locking out communities and Indigenous peoples. So, forests and forest-dependent peoples will thrive together or not at all.
That is at stake.
And that is why FSC does what it does: brings together economic, social and environmental interests around the table, around its 10 principles to make sure forests stay healthy and resilient.
So, you’ll see the principles that FSC works around. Actually, we are in the process of revising them.
CORRECTION 31/07/2025: FSC director-general Subhra Bhattacharjee was originally quoted as saying “because what works in Indonesia won’t work in another country — but the processes will.” The quote has been revised to say “because what works in Indonesia won’t necessarily work in another country — but the processes will.”
Citation:
Gaveau, D. L., Locatelli, B., Salim, M. A., Yaen, H., Pacheco, P., & Sheil, D. (2018). Rise and fall of forest loss and industrial plantations in Borneo (2000–2017). Conservation Letters, 12(3). doi:10.1111/conl.12622
Banner image: Forest Stewardship Council (FSC) director general Subhra Bhattacharjee. Image courtesy of FSC.
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