Greenlighting abuse
2 April 2024

The Kasigau Corridor REDD + Project in Kenya ­is a high-profile carbon offsetting project that claims to ‘avoid’ emissions by protecting forests. When ‘Ernst Wood’ (a pseudonym)[1] arrived at Kasigau, his task was clear: to evaluate whether the project, which is run by US-based company Wildlife Works Carbon (Wildlife Works), met the environmental and social criteria needed to maintain its ethical certifications. 

Social and environmental auditors such as Ernst are rarely mentioned in the debate around forest-based offsetting schemes, yet the carbon credit market could not exist without them. That’s because many buyers of such carbon credits – often big polluters, such as fossil fuel companies and airlines – rely on ethical certifications as evidence that the offsetting projects on which these credits are based have real social and environmental benefits. Certificates give credibility to the impact claims that businesses such as Wildlife Works make about their forest protection or tree planting projects, and can boost the green credentials of their customers.

At the time of Ernst’s visit, Wildlife Works boasted not one but two certificates: the Verified Carbon Standard (VCS) and the Climate, Community and Biodiversity Standards (CCB), both issued and supervised by the Washington-DC-based organisation Verra. The VCS is, in theory, supposed to confirm whether offset schemes plant or save as many trees as they purport to do. The main promise of the more expansive and community-focused CCB is that offsetting projects carrying its label deliver positive socioeconomic outcomes, such as income generation opportunities for local people and greater gender equality.

Audits are the main tool used by carbon certification schemes like Verra to monitor the environmental, social, and human rights impacts of offsetting projects. Wildlife Works has long held up its CCB label as proof that its operations at Kasigau go well beyond basic social safeguards, by ‘empowering’ the local community – especially women – through jobs and various development initiatives, known as ‘co-benefits’. Many of its customers have repeated this claim, with Netflix going so far as to make and promote a short film about the Kasigau project. By emphasising how Wildlife Works supports women’s groups and employs female rangers –­ an occupation traditionally reserved for men – the film depicts Kasigau as an essentially feminist project that’s entirely beneficial for local people.

Even international development organisations, such as the United Nations Environmental Programme (UNEP), have held up Kasigau as a model of how to wed climate goals with community benefits.[2]

In 2023, an investigation into Kasigau by the Kenya Human Rights Commission (KHRC) and the Centre for Research on Multinational Corporations (SOMO) showed that Ernst’s concerns were well founded. Drawing on interviews with over 30 employees and community members, both victims and witnesses, KHRC and SOMO documented multiple allegations of predatory men within Wildlife Works who had exploited positions of power to sexually assault, harass, and extort sex from female staff and mistreated vulnerable women in the wider community. According to multiple sources, the abuses had been going on for a decade.

A decade of auditing failures

Ernst was not the only auditor to review Kasigau while egregious abuses were taking place. Between 2013 and 2022, four US-based auditing firms sent teams to the project site, with each of them reportedly interviewing dozens of employees and community members on topics such as working conditions, rights, and community impacts (see table). None of them reported finding any evidence of sexual harassment or abuse.

Auditing companies that have issued CCB verification on Kasigau (Phase II) since 2013

Yet, as community members told KHRC and SOMO, it was an open secret among employees and the wider community that, in the words of one interviewee, women were “treated as sex objects” at Wildlife Works, and that the perpetrators got away with it by “intimidat[ing] everybody”.

Instead, the auditors’ findings were reassuring and flattering towards Wildlife Works’ culture and project management. They found that the project had “overwhelmingly … positive impacts to the local communities”,[6] was “highly unlikely to result in any net negative impacts on local stakeholders”,[7] and was committed to “equal opportunity employment”.[8] “In conversations with staff,” one audit report noted, “it was learned that no negative comments or grievances were ever received.”[9]

The collective failure of these auditors is shocking but not surprising. This is because the auditing system­ – a largely unregulated web of private companies that compete for contracts from offset project developers – is set up in such a way that it’s nearly impossible for auditors to meaningfully investigate and report on abuses. What emerges as a result is a ‘paper reality’ that is at best incomplete, and at worst a fiction, replete with misleading reassurances around the wellbeing of some of the world’s most marginalised communities.

The reasons the auditing system failed so spectacularly at Kasigau appear inherent in the system. These include: the power imbalance between local people (both employees and other members of communities) and carbon project developers; the limitations placed on auditors, restricting the scope of their reviews; the auditors’ bias in favour of the project developers who are their clients; and the conflict of interest in the relationship between auditors and project developers. We consider each of these reasons in turn below.

SOMO wrote to the auditing companies listed in the table above. Only SCS Global responded, telling us that its assessment team had not heard or received any “allegations about sexual harassment or assault”.[10]

The power imbalance

Ernst’s suspicion that things were not as they seemed was triggered by his discussions and informal chats with Wildlife Works’ local staff. During these conversations, Ernst heard disturbing stories of what women at the company were put through by more senior male colleagues. For example, he learned about an incident where a female employee asked for an advance on her salary and was told that “she had to ‘earn it’ by providing sexual favours”. In another incident, a woman had allegedly been “pressured repeatedly to sleep with a more senior colleague”.

Ernst said he had tried, but failed, to get interviewees to speak about these and other problems on the record, but that staff members and especially junior staff seemed unable to speak freely. I had the impression that they had been told what to tell us and were afraid to defy these instructions. While I tried to convince them that they could share problems with me, I left those interviews feeling they were afraid to open up.

Project employees were not the only group Ernst believed to be holding back during interviews. Community members, he explained, “who benefit from project carbon revenues are less likely to share [problems], as doing so may risk the continuation of project benefits”.

As a result of these power asymmetries, and the apparent lack of trust in the audit process on the part of Ernst’s interviewees, none of his concerns made it into his audit report.

The barriers Ernst ran into during his audit shine a light on how the power imbalance between offset project developers, on the one hand, and their staff and local communities, on the other, shapes audit outcomes. In theory, the interviews used to monitor the social impacts of an offsetting project are more straightforward than the messy and discredited methods used to calculate carbon emission reductions. But in practice, local employees and communities have good reasons to keep concerns to themselves.

Staff might, for example, have been told by their boss what to tell (or not tell) the auditors, as Ernst suspected had happened at Kasigau. In other cases, auditors might conduct interviews accompanied by a manager from the project developer. Ernst, based on his experiences, believes this to be “common practice”, despite the obvious limiting effect that such managerial presence can have on the ability of staff to speak openly about problems.

Limitations placed on auditors

As Ernst also noted, audits can be manipulated, particularly if the verification system limits the scope of inquiry. SCS Global appears to agree, telling SOMO: “[A]dequate consultation with communities may require numerous engagements over a lengthier period of time than has sometimes been afforded to the validation and verification body. Indeed, some of our requests for added time are met with great resistance.”

The power asymmetries between companies like Wildlife Works and communities, then, combine with the limitations the system places on auditors, in ways that fundamentally disadvantage workers and communities. Companies have a responsibility and, increasingly, a legal obligation, to account for and report on the impact of their activities on people and the environment. While some see social and environmental audits as a tool to deliver on this responsibility, the flaws of such processes have been repeatedly exposed by civil society organisations.

Bias in favour of clients

In 2020, one or more community members living around Kasigau chose to remain anonymous when they tried to report concerns to S&A Carbon, which audited Kasigau that year. These concerns related to the allegedly “unfair hiring practices” of Wildlife Works’ Human Resources Department. According to S&A’s audit report, the written complaint called for the “removal” of Wildlife Works’ HR Manager at Kasigau and for people “to be treated with respect and dignity”.[11] Although the audit report is vague on the exact content of the complaint, it suggests it also raised unfair termination practices as an issue.[12]

More concerningly, S&A accepted, seemingly without any attempt at verification, Wildlife Works’ assertion that the complaint was “based in personal conflict between the individual(s) and the project and that therefore the discrimination accusations have no merit”.[13] The auditors reported that Wildlife Works “believes they know the identity or at least the family who raised the comment” and “is confident that the letter originated from [location redacted by SOMO]”.[14] To respond to the issue, the auditors go on to explain, Wildlife Works planned to hold community meetings in the location it assumed the grievance stemmed from. [15]

One obvious problem with S&A’s handling of this complaint is how its apparent bias towards Wildlife Works’ version of events led it to largely disregard the concerns of one or more community members. Equally troubling is how S&A chose to include in its public report a presumed characteristic of the anonymous complainant(s) ­­– the name of their location ­– that could very well lead to identification. It is not difficult to see how S&A’s handling of this complaint could have a chilling effect on employees or other members of the community, who might think twice before reporting concerns.

One year later, Aster Global visited Kasigau for Wildlife Works’ 2021 audit. The auditors, who were aware of the anonymous complaint filed the previous year, should have had additional cause for concern around Wildlife Works’ hiring and termination practices. Three similar complaints had been made through Wildlife Works’ grievance system.[16] Yet despite this additional evidence of problems related to human resources practices, Aster Global’s audit report does not mention the new complaints, and there is no evidence the auditors investigated the issues. [17]

The apparent failure to investigate such signals about potential problems more deeply may help explain why a decade of auditing failed to uncover any of the abuses that KHRC and SOMO have exposed.

This seeming tendency of auditors to give clients the benefit of the doubt is no anomaly in the carbon offsetting world. Recent research by the Goldman School of Public Policy, University of California, Berkeley, has shown such auditors’ bias to be pervasive in the industry. The Berkeley researchers reviewed project descriptions and audit reports on Kasigau and 17 other forest-based offsetting projects. They found that safeguarding compliance appears to be “systematically rubber-stamped despite evidence of noncompliance”.[18]

“Time and again,” the Berkeley researchers explain, “projects received positive verifications despite woefully inadequate consultation, evidence of contested land claims, and even violent evictions.” Auditors accept problematic community engagement practices and consistently give their clients “the benefit of the doubt”, “while doing minimal due diligence” on their claims.

Conflict of interest

The commercial relationships between auditors and the developers that run carbon offsetting projects have a profound impact on how auditors engage with employees and communities, and interpret the testimonies given to them. Like offsetting more broadly, auditing is a profit-driven industry, where firms compete for contracts from companies such as Wildlife Works. Auditors receive payment for their services from the very same company whose behaviour and impacts they are supposed to scrutinise.

As an auditor, asking tough questions on community relations, and digging deeper than your rivals on issues like working conditions, is therefore unlikely to make you popular with a clientele whose ability to sell credits hinges on having positive outcomes highlighted by their audit reports. This creates an inherent conflict of interest at the heart of the audit system, which can undermine the confidence that local staff and community members have in the auditors in whom they are expected to confide.

This does not mean that auditors deliberately ignore problems, but it presents them with an incentive to give clients the benefit of the doubt. As Ernst explained, the market reality imposes pressures on auditors that “limit the level of investigation” they can apply.

Conclusion

Sexual harassment and abuse, and a culture of fear created by a HR manager, were a reality at Kasigau. Audit firms repeatedly failed to identify or report on this reality. These firms operate within a system and to a standard that made it seem impossible for at least one auditor to raise their serious concerns about women’s safety at Kasigau.

Ernst Wood spoke to KHRC and SOMO because he worries that the people who end up paying the price for the structural shortcomings of the auditing system are those who are often already marginalised. They want he wants to see the damage done by the system repaired.

Individuals like Ernst play a critical role in bringing the truth to light, but it is not easy for them to do so. This is because both the carbon offsetting industry and the carbon certification industry are exactly that: industries, governed by competitive pressures, profit objectives, and private interests.

An irreconcilable and dangerous tension exists between such business pressures, on the one hand, and the rights of communities and workers on the other. And this means that even auditors such as Ernst, who are willing to ask tough questions, lack the tools and means to protect and support communities.


Research note

SOMO contacted Aster Global Solutions, SCS Global and S&A Carbon for comments on the sexual harassment and abuse at Kasigau and their failure to identify it. Only SCS Global responded.

SCS Global said:

We stand behind the audit procedures implemented during this assessment. SCS GHG audits are conducted following standard auditing operating procedures in accordance with the rules and requirements of our International Standards Organization (ISO) accreditation under the ANSI National Accreditation Board (ANAB). Above all, SCS employed the standard of care of Validation and Verification Bodies (VVBs) at the time. 

As a benefit corporation, SCS is fully committed to driving positive change toward greater governmental and corporate environmental and ethical responsibility. We share your interest in preventing human rights abuses around the world.

In August 2023, SOMO raised the issue of deliberate action to mislead validation and verification bodies in a letter to Wildlife Works. We informed the company:

SOMO received testimony that, prior to auditors coming to inspect the project, Wildlife Works has instructed or coached staff on how to behave and respond. This coaching appeared to be intended to provide a partial, and therefore misleading, picture of the work conditions to the social auditors. 

Wildlife Works did not respond to us on this issue.


ENDNOTES

[1] We refer to this person as 'Ernst Wood’ to protect their anonymity.

[2] Since the Kenya Human Rights Commission (KHRC) and the Centre for Research on Multinational Corporations (SOMO) released their report on Kasigau (Offsetting Human Rights, 2023, www.somo.nl/offsetting-human-rights), UNEP has added a disclaimer to its article on Kasigau, stating that it doesn’t officially endorse individual projects; yet the article continues to uncritically repeat Wildlife Works’ claims about Kasigau’s impacts.

[3] SOMO interviewed Ernst between 10 and 20 March 2024 by phone. This article includes quotes from these conversations, as well as quotes from interviews done with Ernst in 2023 for the KHRC and SOMO report, Offsetting Human Rights.

[4] Wildlife Works Statement, Updates from the Kasigau Project, November 20, 2023, https://www.wildlifeworks.com/post/update-on-kasigau

[5] The division of Environmental Services that used to provide forestry carbon audits spun off in 2019 when their principal employees purchased this division and began operations as Aster Global https://www.asterglobal.com/about-us/

[6] S&A Carbon, Verification report for the Kasigau Corridor REDD+ project phase II – the

community ranches, 2020, p. 54 https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=47114&IDKEY=kkjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909j64970206

[7] Environmental Services Inc, Climate, Community, and Biodiversity Alliance Project Annual Verification Report, 2013, p. 33  https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=41997&IDKEY=j0e98hfalksuf098fnsdalfkjfoijmn4309JLKJFjlaksjfla9857913863

[8] SCS Global Services, Final CCBA Project Verification Report, 2015, p. 24, https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=42218&IDKEY=9kjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909958218622

[9] Environmental Services Inc, Climate, Community, and Biodiversity Alliance Project Annual Verification Report, 2013, p. 18

https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=41997&IDKEY=j0e98hfalksuf098fnsdalfkjfoijmn4309JLKJFjlaksjfla9857913863

[10] See ‘Research note’ below.

[11] S&A Carbon, Verification report for the Kasigau Corridor REDD+ project phase II – the

community ranches, 2020, p. 16, 81-85 https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=47114&IDKEY=kkjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909j64970206

[12] S&A Carbon, Verification report for the Kasigau Corridor REDD+ project phase II – the

community ranches, 2020, p. 83-85  https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=47114&IDKEY=kkjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909j64970206

[13] S&A Carbon, Verification report for the Kasigau Corridor REDD+ project phase II – the

community ranches, 2020, p.82 https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=47114&IDKEY=kkjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909j64970206

[14] S&A Carbon, Verification report for the Kasigau Corridor REDD+ project phase II – the

community ranches, 2020, p.82-83  https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=47114&IDKEY=kkjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909j64970206

[15] S&A Carbon, Verification report for the Kasigau Corridor REDD+ project phase II – the

community ranches, 2020, p.83 https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=47114&IDKEY=kkjalskjf098234kj28098sfkjlf098098kl32lasjdflkj909j64970206

[16] This audit required the Aster Global auditors to review the anonymous complaint raised earlier. See Aster Global Environmental Solutions, The Kasigau Corridor REDD+ Project Phase II – The Community Ranches, 2021, p. 51-52, https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=59529&IDKEY=f0e98hfalksuf098fnsdalfkjfoijmn4309JLKJFjlaksjfla9k82090491. A 2021 accuracy review by Verra of an audit by Aster Global Environmental Services of the Kasigau Corridor REDD+ project Phase II reveals (p.4)  that of all concerns filed through the Wildlife Works grievance system in the previous year, three “were identified as rising to the level of potential dispute between the project and communities or other stakeholders, with these three involving concern over hiring or termination practices”.  According to Verra’s report, which was still ‘pending’ at the time of writing, “[t]he short-term resolution identified for these [concerns] was for the community relation and HR department to organize HR employment and working procedures in the complainant's’ [sic]communities after the Covid pandemic abates”. Aster Global’s audit report does not give any details around the nature of the concerns raised through Wildlife Works’ grievance system. Aster Global Environmental Solutions, The Kasigau Corridor REDD+ Project Phase II – The Community Ranches, 2021, p. 17, https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=59529&IDKEY=f0e98hfalksuf098fnsdalfkjfoijmn4309JLKJFjlaksjfla9k82090491

[17]Aster Global Environmental Solutions, The Kasigau Corridor REDD+ Project Phase II – The Community Ranches, 2021, p. 17.  https://registry.verra.org/mymodule/ProjectDoc/Project_ViewFile.asp?FileID=59528&IDKEY=f097809fdslkjf09rndasfufd098asodfjlkduf09nm23mrn87m82089112

[18] ‘Quality Assessment of REDD+ Carbon Credit Projects’ (2023) by Berkeley Carbon Trading Project (2023), p. 177- 179.

Responses to the allegations of sexual abuse at the Kasigau carbon offset project run by Wildlife Works
21 March 2024

In November 2023, the Kenya Human Rights Commission (KHRC) and the Centre for Research on Multinational Corporations (SOMO) exposed serious allegations of sexual harassment and abuse at the Kasigau carbon offset project, run by Wildlife Works Carbon, in Kenya.

The allegations of abuse dated back at least a decade and affected current and former employees of Wildlife Works and women living in the nearby communities. The company, which failed to identify this long-standing abuse, set up an investigation based on our reporting, and this led to the dismissal of one individual “for gross misconduct, including conduct in violation of the company’s policy against sexual harassment.”

Wildlife Works also terminated its Human Resources manager because he “created a culture of fear and intimidation that, according to interviewed personnel, prevented reporting of sexual harassment incidents.”

Wildlife Works subsequently alleged that SOMO had paid individuals to come forward with testimony. This is a baseless claim. Neither KHRC nor SOMO have ever paid people to provide information. Our organisations have a combined eighty-year record of ethical research and human rights activism.

KHRC and SOMO are unable to disclose the names of those who provided testimony to us, as we guarantee the anonymity of individuals, which is of paramount importance in research involving survivors of sexual harassment and abuse.

Protecting the victims’ identities is one of the reasons why KHRC and SOMO enjoy the trust of victims of corporate harm and abuse. When women and men come forward, they should be able to do so with their privacy and dignity protected. For this reason, we went to lengths to protect the women who came forward to tell their stories.

It is clear that the company found that the allegations documented by KHRC and SOMO were manifestly correct. However, the company has not investigated all the information provided.

Our research makes evident that allegations of sexual abuse were not confined to one perpetrator or one department. Our report and correspondence with Wildlife Works have been clear about the scope of the allegations we documented.

The decision by Verra to temporarily suspend the Kasigau project appears to have created a situation where communities believe that reports of abuse can lead to a loss of (potential) benefits.

This is consistent with the testimony given to us by an auditor of Kasigau (cited in our report) who told us that “local communities who benefit from project carbon revenues are less likely to share such issues, as doing so may risk the continuation of project benefits”.

The risk is that people are left with a choice to either live with abuse or lose benefits.

Meanwhile, at Kasigau, we understand that individuals who asked for anonymity and got it from KHRC and SOMO are being identified. This deepens our concern that a culture is emerging whereby those who suffer abuse may hear the message – do not expose abuse because the whole community may lose their benefits. 

This case exposes the insidious core of the carbon offsetting industry: reporting abuse can threaten the profits of the carbon offset business. No community anywhere should have to choose between reporting abuse or losing benefits. Communities at Kasigau should not lose benefits due to a corporate failure to identify and prevent sexual harassment and abuse. Nor should any woman ever have to face the choice of silent acceptance of sexual harassment and abuse to preserve wider community benefits from a company.

https://youtu.be/Lgjvrr26iYY?si=qsfiK2NBipNl9Ty0

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