Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium

 
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Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
Case Report 2019

       Land Grabbing
       for Palm Oil in
       Sierra Leone

Analysis of
the SOCFIN
Case from
a Human
Rights
Perspective
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
Authors: Michael Phoenix, Florence Kroff and Manuel Eggen – FIAN Belgium

Cover, typesetting, layout and illustrations: Cécile Van Caillie (Carambolage)
Proofreading: Katie Whiddon
Printing: Manufast
Photos (unless otherwise noted): © FIAN Belgium
Cover photo: © Maja Hitij
Some of the pictures used in this report are from the photographic reportage made by Maja Hitij in 2015 in
Sierra Leone under the title: Palm oil in Sierra Leone. Thank you.

Publication date: February 2019

This publication has been produced with the financial support of the Belgian Development Cooperation and the Wallonia-
Brussels Federation (Fédération Wallonie-Bruxelles). The content of this report does not reflect the official opinion
of these institutions. Responsibility for the information and views expressed in the report lies entirely with the authors.

Reproduction
© Contents of this publication may be quoted or reproduced, provided that the source of information is
acknowledged. The publishers would like to receive a copy of the document in which this report is used or quoted.

Responsible editor: Priscilla Claeys, FIAN Belgium, Rue Van Elewijck, 35, 1050 Brussels
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
Land Grabbing
for Palm Oil in
Sierra Leone
Analysis of the SOCFIN
Case from a Human Rights
Perspective
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
Table of
Contents
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
LIST OF ACRONYMS                                                                   6

FIAN’S MANDATE                                                                     7

EXECUTIVE SUMMARY                                                                  8

1. INTRODUCTION                                                                   14

1.1. FOOD AND AGRICULTURE IN SIERRA LEONE                                         15

1.2. GOVERNANCE AND LAND GRABBING IN SIERRA LEONE                                 16

2. THE MALEN CASE                                                                 18

2.1. THE MALEN CHIEFDOM                                                           19

2.2. THE ARRIVAL OF SOCFIN                                                        20

2.3. COMMUNITY OPPOSITION                                                         25

2.4. FAILED DIALOGUE                                                              26

2.5. CONTEXT FOLLOWING THE 2018 ELECTIONS                                         27

2.6. CONFLICT ESCALATION THROUGHOUT 2019                                          28

3. HUMAN RIGHTS ANALYSIS                                                          30

3.1. HUMAN RIGHTS OBLIGATIONS                                                     31

3.1.1. The Right to Food and Access to Land and Natural Resources                 32
3.1.2. The Right to a Healthy Environment                                         36
3.1.3. The Right to Water                                                         39
3.1.4. The Right to Decent Work and Fair Employment                               43
3.1.5. The Right to Education                                                     50
3.1.6. The Rights of Women                                                         51
3.1.7. Civil and Political Rights and the Protection of Human Rights Defenders    52

3.2. OBLIGATIONS ARISING FROM THE TENURE GUIDELINES                               56

3.2.1. Participation, Consultations and Free, Prior and Informed Consent (FPIC)   57
3.2.2. Transparency and Corruption                                                60
3.2.3. Compensation, Resolution and Restitution                                   62
3.2.4. Responsible Investment                                                     65

4. CONCLUSIONS                                                                    72

5. RECOMMENDATIONS                                                                74

BIBLIOGRAPHY                                                                      80
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
List of Acronyms

                         ACHPR - African Charter on            FFM - Fact-finding mission         NGOs - Non-governmental
                         Human and Peoples’ Rights                                                organizations
                                                               FPIC - Free, prior and informed
                         CEDAW - UN Convention on              consent                            NLP - Sierra Leone National Land
                         the Elimination of Discrimination                                        Policy 2015
                         Against Women                         GOSL - Government of Sierra
                                                               Leone                              OSD - Special Operations Unit
                         CESCR - UN Committee on                                                  of the Sierra Leone Police for the
                         Economic, Social and Cultural         HRC - Human Rights Commission      Malen Chiefdom
                         Rights                                of Sierra Leone
                                                                                                  SAC - SOCFIN Agricultural
                         CFS - UN Committee on World           ICCPR - UN International           Company Sierra Leone Ltd
                         Food Security                         Covenant on Civil and Political
                                                               Rights                             SLIEPA - Sierra Leone Investment
                         CRC - UN Convention on the                                               and Export Promotion Agency
                         Rights of the Child                   ICESCR - UN International
                                                               Covenant on Economic, Social       Tenure Guidelines - Voluntary
                         CSR - Corporate social                and Cultural Rights                Guidelines on Responsible
                         responsibility                                                           Governance of Tenure of Land,
                                                               LUC - Local Unit Commander of      Fisheries and Forests in the
                         EIA - Environmental Impact            the Sierra Leone Police            Context of National Food Security
                         Assessment
                                                               MAFFS - Sierra Leone Ministry of   UN - United Nations
                         EISHIA - 2011 Environmental, social   Agriculture, Forestry and Food
                         and health impact assessment          Security                           UNDP - United Nations
                         carried out by STAR Consult on                                           Development Program
                         behalf of SOCFIN                      MALOA - Malen Affected
                                                               Land Owners and Land Users         UNESCO - United Nations
                         EPA - Environmental Protection        Association                        Educational, Scientific and
                         Agency of Sierra Leone                                                   Cultural Organization
                                                               MoU - Memorandum of
                         FAO - Food and Agriculture            Understanding and Agreement 24     YASAC - Youth Affected by SAC
                         Organization of the United Nations    September 2012
                                                                                                  WFP - World Food Program
Land Grabbing for Palm
Oil in Sierra Leone
6
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
FIAN’s Mandate

FIAN international is an               In pursuit of this vision, FIAN          In view of the involvement of
international human rights             follows a case-based human               a Belgian non-state actor in
organization that has advocated        rights approach by documenting           their case, and the clear and
for the realization of the right to    and analyzing concrete violations        legitimate request for support
adequate food for more than 30         of the right to food. FIAN identifies    from organized communities, FIAN
years.                                 and addresses human rights               Belgium has closely followed the
                                       violations, interviews people            Malen case since 2012.
FIAN’s mission is to expose            threatened or affected by
violations of people’s right to        violations of their right to food,       This support has taken the form
food wherever they may occur.          and verifies the facts of a situation.   of three fact-finding missions
We stand up against unjust and         Face-to-face contacts with local         in the Chiefdom, an in-depth
oppressive practices that prevent      counterparts are established and         and updated human rights-
people from feeding themselves.        serve as a basis for trustful co-        based analysis, raising human
The struggle against gender            operation.                               rights violations and abuses
discrimination and other forms                                                  with authorities in Sierra Leone,
of exclusion is integral part of       On the request of those affected,        Belgium and Europe, support
our mission. We strive to secure       FIAN reacts quickly, analyses            for affected communities in
people’s access to the resources       cases, and mobilizes members             their claims, media work, the
that they need in order to feed        and supporters worldwide.                organization of advocacy tours in
themselves, now and in the future.     Violations are also followed-up          Europe, and close cooperation
FIAN envisions a world free from       in long-term casework. In close          with relevant local, national and
hunger and malnutrition, in which      co-operation with the affected           international organizations working
every person fully enjoys all human    communities, FIAN persistently           on the case.
rights, particularly the human right   approaches the responsible
to adequate food and nutrition,        authorities and identifies breaches      This report forms an integral
alone, in association with others,     of obligations flowing from the          part of this support. It is
or as a community, in dignity and      right to food.                           based both on FIAN Belgium’s
self-determination.                                                             investigative work, and on existing
                                       In 2011, FIAN Belgium was                reports and publications from
                                       approached by communities                intergovernmental organizations,
                                       in the Chiefdom of Malen, a              academics, journalists, NGOs and
                                       Southern province of Sierra Leone,       local organizations.
                                       with a request for support.
                                                                                                                      Land Grabbing for Palm
                                                                                                                      Oil in Sierra Leone
                                                                                                                      7
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
Executive
                         Summary
                         Since the arrival of multinational      of transparency and non-
                         agribusiness company SOCFIN             implementation of corporate
                         in 2011 as part of a large-scale        social responsibility promises by
                         investment in palm oil in the           SOCFIN.
                         Southern Province of Sierra
                         Leone, social conflict has raged        The report paints a grim picture
                         in the Malen Chiefdom. SOCFIN           of a profound, multi-faceted
                         is controlled by a Belgian              decline in the enjoyment of rights
                         businessman (Hubert Fabri) and          by local communities as a direct
                         the French group Bolloré, which         result of the shift in control over
                         has developed a business empire         land in Malen, and the subsequent
                         in many parts of Africa.                development of SOCFIN’s
                                                                 activities in the Chiefdom.
                         This report found that affected
                         communities who have lost               The report is based on three fact-
                         access to and control over their        finding missions carried out by
                         land have been exposed to               FIAN Belgium in collaboration with
                         serious human rights violations         local and national organizations,
                         and abuses since 2011. Several          in 2012, 2016 and 2018. It
                         issues emerged, spanning from           analyses the land conflict in
                         the rights to land, food, water and     Malen Chiefdom from a human
                         a healthy environment, to workers’      rights perspective, exploring
                         rights, women’s rights, the rights      the extent to which human rights
                         of the elderly and the right to         are respected, protected and
                         education. Added to this are            fulfilled, and the extent to which
                         serious violations and abuses of        states and non-state parties
                         civil and political rights, including   have upheld obligations arising
                         the rights to peaceful assembly         from international human rights
                         and association, physical integrity     instruments. It also draws on
                         and clear cases of criminalization      existing reports and publications
                         of human rights defenders. The          from international human rights
                         report also points to serious           experts, local and international
Land Grabbing for Palm

                         allegations of corruption, lack         NGOs, academics and journalists.
Oil in Sierra Leone
8
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
© Maja Hitij
BACKGROUND                             the communities organized
                                       themselves into the Malen
                                                                                conditions on the SOCFIN
                                                                                plantation;
                                       Affected Land Owners and Land         -- The destruction of the livelihood
On 3 March 2011, SOCFIN signed         Users Association (MALOA), and           of landowners in the area;
a lease agreement with the             continuously called on the State
government of Sierra Leone to                                                -- The destruction of the area’s
                                       of Sierra Leone and SOCFIN to
acquire 6,500 hectares of land                                                  ecosystems and the negative
                                       recognize and counteract the
in the rural chiefdom of Malen,                                                 impact on its biodiversity.
                                       negative impact of the land deal
in southern Sierra Leone. This         and the company’s activities          In response, different state
followed a prior agreement             on their human rights. Their          authorities took several initiatives
signed by the local Paramount          grievances include:                   in an attempt to find a solution
Chief and 26 landowners to cede                                              to the conflict. These efforts,
their land to the government           -- A lack of consultation with        however, proved unsuccessful,
through the Ministry of Agriculture.      landowners prior to the            largely due to a lack of political
These agreements marked the first         agreement of the land lease;       will. The change in government
step in the large-scale seizure        -- Pressure, intimidation and         following the 2018 elections
of land by SOCFIN in Malen. In            threats aimed at coercing          brought renewed hope for
subsequent years, following two           landowners to sign over their      the conflict’s resolution since
other lease agreements, the               land;                              the resolution of Malen’s land
company has taken control of a                                               conflict was part of the new
                                       -- A lack of transparency and
total of 18,473 hectares of the                                              president’s electoral promises.
                                          high levels of corruption in the
Chiefdom’s 27,000 hectares of                                                A new mediation process was
                                          land acquisition process and
land, transforming over 12,000                                               initiated under the auspice of the
                                          afterward;
hectares into industrial palm oil                                            Vice-President. Unfortunately,
                                       -- Inadequate compensation for        the conflict has escalated
plantations. This concerns more
                                          land leasing and crops and         following a recent violent incident
than 32,000 people living in
                                          non-payment or irregularities of   involving security forces, leading
52 villages located within the
                                          annual rental payments;            to the killings of two villagers
concession area.
                                       -- The failure of SOCFIN to mark      and the consecutive arbitrary
From the outset, the communities          boundaries of family land before   arrests of community people
denounced the agreement                   its clearing, which prevents       and MALOA leaders. This report
as illegitimate, insisting on             communities from reclaiming        aims to contribute to solving this
the absence of their active,              their land at the end of the       conflict by applying the lens of
free, meaningful and informed             lease;                             international human rights law to
                                                                                                                    Land Grabbing for Palm

consent. In the years that followed    -- Extremely poor working             the situation.
                                                                                                                    Oil in Sierra Leone
                                                                                                                    9
Land Grabbing for Palm Oil in Sierra Leone - Case Report 2019 - FIAN Belgium
KEY FINDINGS:                           The Right to a Healthy
                                                                 Environment: The land lease
                                                                                                       The Right to Water: SOCFIN’s
                                                                                                       agro-industrial activity poses
                                                                 changed the way in which land         a serious threat to water in the
                         The Right to Adequate Food              in the Chiefdom was used,             Chiefdom, risking pollution of
                         and Nutrition: Communities have         transforming a traditional bush-      water sources and interference
                         lost their access to farmland,          fallow agricultural system into a     with water use, including for
                         preventing them from growing            large-scale industrial palm oil       future generations, with concerns
                         their own food and other cash           monoculture. This has had serious     stemming from an agreement
                         crops. Following the arrival            impacts on the biodiversity of        between the company and the
                         of SOCFIN, the diversity and            fauna and flora in the chiefdom,      Government allowing SOCFIN to
                         quality of food consumed by the         leading to a drastic decline in       draw unlimited quantities of water
                         Malen communities dramatically          mammal species and medicinal          to service its activities in Malen,
                         decreased. In many households,          plants in particular. Communities     and to do so at a heavily cut price
                         the number of meals consumed            also report that the use of           ($0.00012 per cubic meter). In a
                         daily dropped from between              chemicals and fertilizers in          complaint to the EPA in 2013, local
                         2-3 per day to 1-2. In the              SOCFIN’s operations have made         communities reported high levels
                         absence of cash crop sales,             swamps in the plantation area         of pollution of the Malen River,
                         higher commodity prices on              unsuitable for cultivation. Further   along with large numbers of dead
                         local markets, and increased            independent investigation and         fish. Despite repeated attempts
                         expenditures on food, a decrease        chemical analysis is necessary        by MALOA, no public report or
                         in household income has resulted        in order to assess whether the        conclusions were shared with
                         in lower purchasing power.              use of chemical substances by         communities.
                         Promises of mitigation measures         SOCFIN complies with national
                         made by SOCFIN to ensure food           law and international standards.      The Right to Decent Work and
                         security are not adequate or            Unfortunately State agencies          Fair Employment: 32,842 villagers
                         simply not respected. Villagers are     tasked with environmental             are estimated to be affected by
                         complaining about the following:        protection – in particular            SOCFIN’s activities in the Malen
                         the ‘buffer zones’ (or ‘green belts’)   the Environmental Protection          Chiefdom, yet SOCFIN only offers
                         between plantation and villages         Agency (EPA) – lack the human         1,178 permanent job positions.
                         are not sufficient for gardening        and financial resources to            What’s more, only a few members
                         and are usually under the 500m          conduct such investigations.          of the Chiefdom communities
                         promised; inland valley swamps          As recently raised by the UN          are employed in management or
                         let out to communities are              Special Rapporteur on hazardous       supervisory positions. In addition
                         unsuitable for cultivation because      substances and wastes in              to permanent contracts, SOCFIN
                         of chemical pollution; the              September 2018: “This lack of         claims to offer another 2,500 job
                         smallholder out-grower scheme           detail fundamentally obstructs        opportunities for casual workers,
                         (budgeted at $2,608,000) was            the ability of the EPA to perform     all working under very precarious
                         never implemented; and other            its duties under human rights law,    employment conditions. They
                         alternatives financed by the            and fails to respect the rights of    usually do not have a proper
                         company’s corporate social              workers and local communities         contract and can be laid off at
                         responsibility program (namely          to information, participation         any time. Pay is dependent on the
                         the 600-acre rice project and           and remedy. Despite these             completion of daily tasks, which
                         construction of fish ponds) do          concerns, Socfin received             are described as very difficult
                         not allow communities to feed           an EIA [Environmental Impact          to accomplish. Evaluation of
                         themselves adequately.                  Assessment] licence”.                 completion is left to the discretion
                                                                                                       of supervisors, and workers report
Land Grabbing for Palm
Oil in Sierra Leone
10
© Maja Hitij
frequent cases of corruption. As a      Civil and Political Rights and         were decisive in convincing
result, average salaries for seasonal   the Protection of Human Rights         some chiefs and landowners,
local workers at the company            Defenders: Opposition to the           have never been respected
were between approximately              land lease agreement has been          or even implemented. These
150,000 and 250,000 Leones              systematically criminalized and        range from annual payments,
per month, which is far below the       repressed by local security            and the respect of buffer zones
minimum wage in Sierra Leone            services, many times using             to the establishment of an out-
(500,000 Leones per month).             violence. Acts of arbitrary            grower scheme, and long-term
Elderly community members               detention and judicial harassment      employment opportunities.
are completely overlooked for           against MALOA and other
employment. Workers’ strikes            community members have been            Transparency and Corruption: A
increased in 2018, leading to more      denounced by international             profound lack of transparency has
tension and further human rights        human rights organizations,            accompanied the development
violations and abuses.                  including UN Special Rapporteurs.      of SOCFIN’s activities in Malen,
                                        National and international civil       seriously restricting the capacity
The Right to Education:                 society organizations supporting       of local communities to assert
Subsequent to the land lease            local communities have faced           their rights and seek remedies
agreements, family sources of           continuous acts of intimidation        to the conflict. From the outset,
income either became insufficient       by the company and local               communities have demanded
to cover education expenses or          authorities. The escalation of         increased transparency and
– in most cases – ceased entirely.      tension in the chiefdom and            access to key documents
Families were left with little choice   recent violent repression by the       relating to the leasing of
but to remove their children from       police in January 2019 led to the      land, including the land lease
school, with girls commonly the         death of two people, dozens of         agreements themselves. In
first to be withdrawn.                  wounded and the arbitrary arrest       parallel, irregularities in the
                                        of several people, including one       compensation payment process
The Rights of Women: Prior to the                                              and unjustified payments to
                                        leader of MALOA, and MALOA’s
arrival of SOCFIN, the agricultural                                            official representatives and others
                                        former spokesman, a member of
activity of women was of chief                                                 have led to repeated accusations
                                        Parliament.
economic importance within                                                     of corruption.
communities. As the basis of much       Participation, Consultations and
of the social interaction within        Free, Prior and Informed Consent       Compensation, Resolution and
villages, it also played a key social   (FPIC): All available evidence         Restitution: The form and levels
role. The changes in access to          indicates that the conditions          of compensation and payment
and control over land following         under which the land lease             due to the land owners by the
the lease agreement removed             agreement was made did not             company in accordance with
the base materials of this activity     allow for communities to give          the lease agreement, along with
from local women, creating a            their free, prior and informed         the process for making these
wide economic and social gap in         consent. Allegations of coercion       payments, have raised serious
communities. Women, especially          aimed at gathering signatures          concerns from the outset. Firstly,
elderly women, are mostly deemed        for the agreement, including           the lease agreements provided
unfit for the tasks demanded of         through bribes and the presence        compensation to landowners
workers on SOCFIN’s plantations,        of armed guards at a meeting to        for their loss of palm oil crops.
and thus frequently face barriers       sign the contract, raise significant   This was fixed as a single lump
when it comes to work in all its        doubts as to the agreement’s           payment of $570/ha. This is very
forms.                                  legality. Some promises, which         low considering that SOCFIN
                                                                                                                     Land Grabbing for Palm
                                                                                                                     Oil in Sierra Leone
                                                                                                                     11
itself valued the price of one       accused of withholding payments        (which almost exclusively benefit
                         hectare of palm trees at $57,120.    and engaging in inequitable            the company) for more than 1/3 of
                         Landowners also denounced            distribution. Despite the many         the total budget, as well as several
                         that the size of land plots were     requests by MALOA and others to        expenses with no social interest,
                         undervalued, and that the loss       both SOCFIN and local authorities      or which could be related to
                         of other cash crops was not          to obtain lists of payments made       corrupt practices. No investment
                         compensated for. Secondly, it        in compensation and annually,          has been made to implement the
                         was agreed that a recurring yearly   the communities have never had         smallholder out-grower scheme,
                         rental payment would be paid by      access to these lists.                 one of the company’s primary
                         SOCFIN. This was set in the lease                                           promises.
                         agreement at $5 per acre per         Responsible Investment: A major
                         year ($12.5 per hectare), of which   gap has emerged between                Based on these findings,
                         landowners would only receive        the promises made by the               the report makes a series of
                         50% (20% goes to the chiefdom        company in its corporate social        recommendations aimed at
                         authorities, 20% to the district     responsibility action plan, and the    ending ongoing human rights
                         and 10% to the government).          projects actually implemented,         abuses and violations in Malen,
                         This sum is considered a meager      their respective budget and            and finding a peaceful solution
                         amount. Moreover, substantial        ultimate impact on the ground.         to the conflict. Indeed, it can
                         problems have been identified        The corporate social responsibility    be concluded that immediate
                         throughout the payment process,      plan formulated by SOCFIN in           steps by all actors must and can
                         leading to strong accusations        2011 foresaw an expenditure of         be taken to provide remedies
                         of corruption, particularly          $16,433,375 for the benefit of         for harm suffered by local
                         at the level of the chiefdom         communities between 2011 and           communities since the initial land
                         authorities. SOCFIN is paying        2017. Only $2,583,784 was actually     lease agreement, and that such
                         the amount that was targeted         spent for this purpose. This figure,   steps, along with others aimed
                         for landowners (supposedly           which represents a mere 16%            at providing a stable ground for
                         $115,456) to the chiefdom            of the budget planned for the          local communities to enjoy their
                         authorities who supposedly act       social benefit of the communities,     rights, are essential to finding a
                         as intermediaries, but these are     includes expenditure on roads          resolution to the conflict.
Land Grabbing for Palm
Oil in Sierra Leone
12
Land Grabbing for Palm
13   Oil in Sierra Leone
                              © Maja Hitij
© Maja Hitij
     Land Grabbing for Palm
14   Oil in Sierra Leone

     1. Introduction
Introductory comment:

In accordance with FIAN’s
policy on publications
involving non-State actors,
the relevant extracts from
this report were sent to
SOCFIN in December
2018, before finalization.
The objective is to enable

                                                 1.1. Food and
the company to provide
explanations and details on
the elements included in this
report.

While the company did
not substantively respond
                                                 Agriculture
                                                 in Sierra Leone
to similar requests in the
past, on this occasion
SOCFIN responded in some
detail1 for the first time in
seven years. The relevant
information provided by
SOCFIN has therefore been                        The West African country of                                 whom land is the main economic
included in this report, either                  Sierra Leone is one of the world’s                          and social asset.
by improving the accuracy                        poorest nations.2 Over 70% of
of information or by adding                      its six million people live below                           The promotion of large-scale
comments in footnotes.                           the national poverty line of $2 a                           foreign investment in the
                                                 day. As of 2015, approximately                              agricultural sector has been
                                                 one out of every two households                             made a priority by consecutive
                                                 was food insecure, amounting                                governments in the country,
                                                 to almost half of the country’s                             in the hope that increased
                                                 population.3 These households                               agricultural production may
                                                 have insufficient access to food                            lead to a decrease in poverty.
                                                 in sufficient quantity, quality and                         This has been accompanied
                                                 diversity to lead a healthy life.                           by support from international
                                                                                                             partners since the world food
                                                 Sierra Leone’s economy is                                   crisis of 2007/2008 (see Box
                                                 primarily agricultural. As much as                          1). Nonetheless, rural poverty,
                                                 60% of the population depend                                in particular, has remained
                                                 on farming for their livelihood and                         widespread,5 and the food
                                                 food needs.4 These are mostly                               situation has not improved.
                                                 small-scale rural farmers, for                              Between 2010 and 2015, total
                                                                                                             food imports primarily coming
                                                                                                             from wealthy nations increased
                                                 2   Sierra Leone ranks 179th out of 185 countries in a
                                                     recent human development index. UNDP. 2016              from $151 million to $387 million.6
                                                     Human Development Index. p. 204. Available at: hdr.
                                                     undp.org/sites/default/files/2016_human_develop-
                                                     ment_report.pdf
                                                 3   World Food Programme. State of Food Security in
                                                     Sierra Leone 2015. p. 45. Available at: documents.
                                                     wfp.org/stellent/groups/public/documents/ena/
                                                     wfp288316.pdf?iframe. The WPF uses a “consolidated
                                                     approach for reporting indicators of food security”
                                                     (CARI). Within this, households are classified into
                                                                                                                                                                         1. Introduction

                                                     one of four categories: food secure, marginally food    5   See IndexMundi. Sierra Leone – Rural Poverty Gap
                                                     secure, moderately food insecure, and severely              at National Poverty Lines (%). Data from World Bank
                                                     food insecure. According to the 2015 report, 49.8%          Global Poverty Working Group, compiled from
                                                     of Sierra Leone’s households are moderately or              official Government sources. Available at: www.in-
                                                     severely food insecure.                                     dexmundi.com/facts/sierra-leone/indicator/SI.POV.
                                                 4   International Food Policy Research Institute. 2012          RUGP.
1   SOCFIN. “SOCFIN’s response to FIAN’s Draft       Global Hunger Index - The challenge of hunger:          6   United Nations Conference on Trade and Develop-
    Report extracts made available to SOCFIN         ensuring sustainable food security under land, water,       ment. State of Commodity Dependence 2016. p.
    before publication”. Letter sent to FIAN         and energy stresses. p. 35. Available at: www.ifpri.        107. Available at: unctad.org/en/PublicationsLibrary/
    Belgium. 09 January 2019.                        org/publication/2012-global-hunger-index.                   suc2017d2.pdf.
                                                                                                                                                                         15
1.2. Governance and Land
                         Grabbing in Sierra Leone
                         According to the FAO, 75% –                                 There have been several attempts                           Several factors including the
                         5.42 million hectares (ha) – of                             to reform the system of land law                           historic peculiarities of the land
                         Sierra Leone’s land is arable.                              in the country.9 The most recent                           governance system in Sierra
                         Officially, less than 15% of this                           came in 2015, with the adoption of                         Leone, a rising population, and
                         land is currently under cultivation.                        a new National Land Policy (NLP). It                       the use of the bush-fallow system
                         The Sierra Leone Investment and                             was launched in 2017 along with a                          in rural areas have combined with
                         Export Promotion Agency (SLIEPA)                            ten-year implementation plan.                              governmental policies aimed at
                         (See Box 1) has maintained that:                                                                                       increasing foreign investment
                         “Sierra Leone has significant                               If fully implemented, the NLP                              in agriculture in the country
                         amounts of arable land, most of                             would have transformative                                  to create a situation of land
                         which remains uncultivated, with                            potential. It seeks to guarantee                           competition and land scarcity. It is
                         up to 4 million hectares of arable                          equal rights to and control over                           estimated that between 2009 and
                         land still available for cultivation.”7                     land for women, enable access                              2012, foreign investors contracted
                                                                                     to independent legal services                              long-term leases of 50 years with
                         In contrast with these claims, as                           for communities negotiating with                           possible extensions on 1,154,777
                         early as 2011, studies indicated                            investors, and secure the tenure                           hectares of land in Sierra Leone
                         that the concept of ‘unused’                                rights of individuals, families and                        – approximately 21.4% of the
                         or ‘uncultivated’ land was                                  communities through a system of                            country’s total arable land – for
                         controversial in Sierra Leone. It                           mapping and title registration,10                          large-scale industrial agriculture
                         was argued that:                                            although this last provision is not                        projects.12 This should be
                                                                                     without its problems.11 It envisions                       considered as part of the wider
                         “At the level of large commercial                           changes to the systems for                                 pattern of land grabbing which
                         farm investments, there could                               surveying and registering land; the                        has taken place across Sub-
                         be bankable economic                                        introduction of land commissions;                          Saharan Africa since the 2008
                         opportunities in biofuels, palm                             the creation of land banks; and                            food crisis, and as being directly
                         oil and commercial cocoa                                    limiting land acquisitions by                              connected to increased global
                         plantations, yet, there is no idle                          foreign enterprises to areas of                            demand for biofuels produced
                         productive land that could easily                           5,000 hectares.                                            from sugar cane and palm oil.
                         be made available for commercial
                         investment under the current                                The importance of such changes
                         patterns of smallholder upland                              bears upon the links between
                         cultivation and fallow rotation.”8                          access to land, control of land,
                         Under the bush-fallow agricultural                          and food needs of individuals,
                         system traditionally used in                                families and communities in the
                         Sierra Leone, land may be left                              country.
                         uncultivated for long periods
                         whilst nevertheless remaining in
                         use for purposes beyond crop
Land Grabbing for Palm

                         cultivation.
Oil in Sierra Leone

                                                                                     9  Such as the adoption of the Sierra Leone National
                                                                                        Land Policy in 2005, which was never implemented.
                                                                                     10 See Aidara and Pemagbi. Agriculture Policy in Salone
                                                                                        - Sierra Leone Green Revolution: Prospects for suc-
                                                                                        cess. 2017. Available at: www.osiwa.org/publication/
                                                                                        agriculture-policy-salone/.
                         7   SLIEPA. “Unique Selling Points of the Agricultu-        11 See Bonanno, A. ““Formalizing Freedom: Land
                             re Sector”. Available at: sliepa.org/investment/           Tenure Arrangements from the Perspective of Social
                             agriculture/.                                              Modes of Production”” in Ndi, B. F, Fishkin, B. H and
                         8   Bald, J and Schroeder, P. Study on rural and agricul-      Ankumah, A. T (Eds.) Living (In)Dependence: Critical    12   Baxter, J. Who Is Benefiting? The Social and Econo-
                             tural finance in Sierra Leone: product innovation and      Perspectives on Global Interdependence. 2018. pp.            mic Impact of Three Large-Scale Land Investments in
                             financial access. 2011. p. 12.                             115-118.                                                     Sierra Leone / A cost-benefit analysis. 2013. p.14.
16
BOX 1.                                                                                                            LAND ADMINISTRATION
                                                                                                                  IN SIERRA LEONE IS
THE SIERRA LEONE INVESTMENT AND                                                                                   GOVERNED BY A DUAL
EXPORT PROMOTION AGENCY - SLIEPA                                                                                  SYSTEM OF LAW.

Following the end of the civil war that took place in Sierra Leone                                                The Western Area and the capital
between 1991 and 2002, a change occurred in the approach to                                                       Freetown, constituting the area of
agricultural development in the country’s rural provinces. In 2007,                                               the former British colony, operate
with the support of the World Bank13 and the European Union, the                                                  under a composite system of pre-
Sierra Leone Investment and Export Promotion Agency (SLIEPA) was                                                  independence English common
established.14 Its purpose was to facilitate direct foreign investment                                            law and post-independence
and export development in the country, with a priority placed on                                                  statutory law. Land is either
agribusiness.15 The Agency positioned itself as a facilitating body                                               publicly or privately owned.
between investors, the government and local stakeholders.16 It also
advertised land available for large-scale cultivation of crops such as                                            The Provinces, to the North, East
palm oil and sugar cane.                                                                                          and South, previously a British
                                                                                                                  protectorate, operate under a
SLIEPA’s creation was accompanied by explicit calls for direct                                                    dual system of general law and
foreign investment in the country’s agricultural sector. In 2009, at the                                          customary law, of which the
Sierra Leone Trade and Investment Forum in London, the previous                                                   latter dominates. The region is
President of Sierra Leone, Ernest Koroma, declared: “Our soils are                                                comprised of 149 chiefdoms.
fertile and our land under-cultivated, offering ideal conditions for                                              Local administration is coordinated
new investments in rice, oil palm, cocoa, coffee and sugar”.17                                                    through Paramount Chiefs and
                                                                                                                  chiefdom councils, with section-
The call was heard, and bilateral negotiations over land-based
                                                                                                                  or sub-chiefs. Paramount Chiefs
investment began between Sierra Leone and several states,
                                                                                                                  are endorsed by the President
including Belgium.18 In 2009, SLIEPA contacted SOCFIN directly to
                                                                                                                  and rule for life, although they may
see if they would be interested in an oil palm plantation project.19
                                                                                                                  be removed. Customary laws vary
SLIEPA further offered its services to help identify available land,
                                                                                                                  between the chiefdoms, and are
and to facilitate the land agreement between SOCFIN and the
                                                                                                                  mostly unwritten.
Government.

                                                                                                                                                         1. Introduction

13 United Nations Conference on Trade and Development. Investment Policy Review: Sierra Leone. 2010. pp. 29
   and 61. Available at: unctad.org/en/pages/PublicationArchive.aspx?publicationid=491.
14 Through the Sierra Leone Investment and Export Promotion Agency Act 2007. Available at: www.sierra-leone.
   org/Laws/2007-3.pdf.
15 Oakland Institute. World Bank’s Bad Business in Sierra Leone. 2014. Available at: hwww.oaklandinstitute.org/
   world-banks-bad-business-sierra-leone.
16 Ochiai, T. Customary Land Tenure, Large-Scale Land Acquisitions and Land Reform in Sierra Leone. 2017. p. 9.
17 Ibid.
18 Ibid.
19 SOCFIN. Supra Note 1.
                                                                                                                                                         17
GUINEA

                                                              2. The Malen
                                    SIERRA LEONE
   FREETOWN

                                          BO
                                   MALEN
                                   CHIEFDOM

                                         PUJEHUN

                                                   PUJEHUN
                                                   DISTRICT

                                                          LIBERIA

                          SIERRA
                          LEONE
Land Grabbing for Palm
Oil in Sierra Leone
18
2.1. The Malen
       Chiefdom
       Malen is one of twelve Chiefdoms                          agriculture. Farming of diverse
       in the Pujehun District in the                            food crops, with rice as the
       Southern Province of Sierra                               staple, has been combined with
       Leone. It is a rural area of                              fishing from local streams, and
       approximately 27,000 hectares                             foraging and hunting in fallow
       situated to the west of the district                      bush areas. Other crops, including
       capital, Pujehun Town. A recent                           palm oil, coffee and cacao, either
       population boom has seen its                              wild or planted, have also been
       numbers grow from 22,090                                  harvested, with their produce sold
       inhabitants in 2004 to 49,263 in                          by households on local markets
       2015.20 The majority of the people                        to generate small cash incomes.
       in the Chiefdom belong to the                             Testimonies gathered by FIAN
       Mende ethnic group, one of the                            Belgium in fact-finding missions
       two major ethnic groups in the                            to the Chiefdom indicate that
       country.                                                  under these conditions Malen was
                                                                 in a stronger position in terms of
       The Chiefdom is overwhelmingly                            food self-sufficiency compared
       agriculturally focused, both                              with other chiefdoms. These
       economically and socially.                                findings are supported by studies
       Historically, the local population                        and reports examining the food
       practised low external input                              situation in the Chiefdom.21
Case

                                                                                                                            © Maja Hitij

                                                                                                                                           2. The Malen Case

                                                                 21   Melsbach, G and Rahall, J. Increasing Pressure for
       20 Statistics Sierra Leone. 2015 Population and Housing        Land: Implications for Rural Livelihoods and Deve-
          Census, Summary of Final Results. 2015. pp. 42-43.          lopment Actors. A Case Study in Sierra Leone. 2012.
          Available at: www.statistics.sl/images/StatisticsSL/        p. 23. Available at: www.fian.be/IMG/pdf/whh_stu-
          Documents/final-results_-2015_population_and_               dy_land_investment_sierra_leone_october_2012.pdf.
          housing_census.pdf.                                         Baxter. Supra Note 19. pp. 5-6.
                                                                                                                                           19
2.2. The Arrival
                         of SOCFIN
                         On 5 March 2011, a lease of                           On the same day, the land was
                         over 6,500 hectares of land                           sub-let by the Ministry to SOCFIN
                         in the Malen Chiefdom was                             Agricultural Company Sierra
                         signed between the Minister of                        Leone Ltd. (SAC), a subsidiary
                         Agriculture, Forestry and Food                        of the Belgo-Luxembourgish
                         Security (MAFFS) of Sierra Leone                      company SOCFIN (See Box 2).
                         and the Chiefdom’s traditional
                         authorities. The lease was for a
                         period of 50 years, renewable
                         for an additional 25 years. It was                                    The lease was for a period
                         signed by the Paramount Chief of
                         the Malen Chiefdom, BVS Kebbie,                                    of 50 years, renewable for an
                         and 28 landowners.22
                                                                                                      additional 25 years.
Land Grabbing for Palm
Oil in Sierra Leone

                         22 Head Lease Agreement (Zone A) between the Go-
                            vernment of Sierra Leone and the Malen Chiefdom
                            authorities. 15 October 2012. Available at: www.
                            fian.be/IMG/pdf/2012-communities-sl_head-
                            lease_15oct2012-zone_a_completed.pdf.
20
BOX 2
  WHAT IS SOCFIN?
  SOCFIN is an agro-industrial group specialized in the production of palm oil and rubber The company dates                                              .
  back to the colonial era, when it was heavily involved in the exploitation of rubber in the Belgian Congo. With
  a 54% share, the Belgian businessman Hubert Fabri is the main shareholder in the Group, followed by the
  Bolloré Group, headed by French businessman Vincent Bolloré, who holds a 38.75% share.23 Since 2011, the
  Bolloré Group has also been a heavy investor in the port of Sierra Leone’s capital Freetown.24

  Globally, SOCFIN controls more than 400,000 hectares of land in a dozen African and Asian countries. In
  recent years, the group has acquired new plantations in Guinea, Kenya, Sao Tome and Principe, Liberia,
  Cambodia and Cameroon. Between 2009 and 2017, its plantation land increased by approximately 48%, from
  129,658 to 192,072 hectares.25 The expansion of the group’s operations has repeatedly been criticized for
  abuses of the rights of local populations.26

                                                         59%                                                                                                   58%
31/12/2017                                                                                             SOCFIN
                                                                                                              Luxembourg

                                                SOCFINAF                                20%                                      80%
                                                                                                                                                               SOCFINASIA
                                               Luxembourg                                                                                                                   Luxembourg
                                                                                                     SOCFINDE
                        100%
                                                                                                                Luxembourg
       LAC                        93%
                                                                                                                             19%
              Liberia                               SAC                                 33%                                                                                              100%
  35%                                                     Sierra Leone                                TERRASIA                   48%                           SOCFIN KCD
                                                                                                               Luxembourg                                                   Cambodia
                         65%     87%
                                                                                                                                 35%
       SRC                                 BEREBY-FINANCES                             30%
                                                                                                                                                  100%
             Liberia                                     Ivory Coast                               INDUSERVICES                  35%                                                     100%

                                    70%                                73%
                                                                                                              Luxembourg
                                                                                                                                 20%
                                                                                                                                               SETHIKULA                      VARANASI
                        100%                                                           20%                                                                   Cambodia                     Cambodia
       PSG                              SCC                      SOGB                         MANAGEMENT ASSOCIATES              20%
              Ghana                       Ivory Coast                  Ivory Coast        15%                 Luxembourg
                                                                                                        15%                                                                            100%
                                                                                                                                                                 PNS LTD
                        66%                                                             50%                                      50%
                                                                                                                                                                          Luxembourg
  OKOMU                                       SOGESCOL CAM               100%                      SOGESCOL FR
              Nigeria                                     Cameroon                                                  Switzerland
                                                                                                                                                 90%                                     100%
                                 100%                                                                                            50%
                        100%                       SAFA                                50%         SOCFINCO FR                                  SOCFINDO                     COVIPHAMA
STP INVEST                                        69%        France                                                Switzerland                                Indonesia                   Cambodia
          Belgium                                                                       50%                                      50%
  88%
                                                SAFACAM                                         SOCFIN GREEN ENERGY
                                                            Cameroon
AGRIPALMA                                                                                                            Switzerland
                                                                                       50%                                     50%
             São Tomé
                                                CAMSEEDS                 0,5%                   SOCFIN RESEARCH
                        100%                                Cameroon                                                Switzerland
                                                99,5%
 BRABANTA                                                                               50%                                   50%
                                 67%                                                            INDUSERVICES FR
          Congo (DRC)                          SOCAPALM                                                             Switzerland
                                                            Cameroon                    50%                                      50%
                                                 100%
                                                                                                    SODIMEX FR
                                                                                                                    Switzerland
                                                   SPFS
                                                                                       50%                                       50%
                                                            Cameroon                             IMMOB. PEPINIERE
                                                                                                                   Belgium
                                                                                       50%                                       50%                                    Holding Companies
                                                                                                     CENTRAGES
                                                                                                                   Belgium                                                  Operating
                                                                                        50%                                      50%                                        companies
                                                                                                       SODIMEX
  ORGANISATION CHART                                                                                              Belgium                                               Plantations Africa
                                                                                        50%                                      50%
  AVAILABLE ON THE SOCFIN                                                                             SOCFINCO
                                                                                                                                                                          Plantations Asia
  WEBSITE (WWW.SOCFIN.COM)                                                                                        Belgium
                                                                                                                                                                                                     2. The Malen Case

  translated by the author

  23   See SOCFIN webpage. Available at: www.socfin.com/en/socfin.
  24   See Bollore Ports webpage. Available at: www.bollore-ports.com/reseau-mondial/afrique/port-de-freetown-sierra-leone.html.
  25   SOCFIN. Sustainable development report 2017. p. 14. Available at: www.socfin.com/sites/default/files/2018-12/RAEB19~1.PDF.
  26   See United Nations. Human Rights in Liberia’s Rubber Plantations: Tapping into the future. 2006; FIDH. Land cleared for rubber, Rights bulldozed – The impact of rubber planta-
       tions by Socfin-KCD on indigenous communities in Bousra, Mondulkiri, 2011; Sherpa et al vs SOCAPALM/SOCFIN/SOCFINAF. “Complaint for breach of OECD Guidelines for Mul-
       tinatioal Enterprises”. Available at: www.oecdwatch.org/cases-fr/Case_202-fr; Bread for all. Struggle for Life and Land: Socfin’s Rubber Plantations in Liberia and the Responsibility
       of Swiss Companies, Bern, February 2019. Forthcoming.
                                                                                                                                                                                                     21
From the outset, local
                         communities denounced the
                         lease agreement as illegitimate.
                         Organizing themselves into the
                         Malen Affected Land Owners and
                         Land Users Association (MALOA),
                         they detailed their concerns in
                         a letter to the Pujehun District
                         Authorities on 2 October 2011.
                         Their grievances included:

                         -- A lack of consultation with
                            landowners prior to the
                            agreement of the land lease;
                         -- Pressure, intimidation and
                            threats aimed at coercing
                            landowners to sign over their
                            land;
                         -- A lack of transparency and high
                            levels of corruption in the land
                            acquisition process;
                         -- Inadequate compensation
                            and the non-payment of
                            compensation;
                         -- The failure of SOCFIN to mark
                            boundaries of family land
                            before its clearing;
                         -- Extremely poor working
                            conditions on the SOCFIN
                            plantation;
                         -- The destruction of the
                            livelihood of landowners in the
                            area;
                         -- The destruction of the area’s
                            ecosystems and the negative
                            impact on its biodiversity.27

                                                                                      From the outset, local
                                                                                          1

                                                                                   communities denounced
                                                                                    the lease agreement as
Land Grabbing for Palm

                                                                                                illegitimate.
Oil in Sierra Leone

                         27 MALOA. Grievances of land owners in Malen
                            Chiefdom. 2 October 2011. Letter to Pujehun District
                            Officer. Available at: www.fian.be/IMG/pdf/ma-
                            loa_grievances_of_land_owners_october_2011.pdf.
22
2011                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             2013                                                                                                                                                      2014

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              © Google Maps
                                                        MAP SAC PROJECT
In April 2012, more than a year                         18,473 HA                                                                                                                                                                                                                                                                                                          MAP SAC PROJECT
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       2016
after the initial lease agreement, a
Memorandum of Understanding                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         2                 C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               C             C           C

(MoU) (See Box 3) was signed
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  D                     6I                 5                                                                                                                                           5                                                                                       5             5           5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          36H                                                                                                                       5                                                                       C              5                  33E           33G
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  2                    D                                                                                                                          C                                   34A                                                                                                               33I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          C                                                                                        34C                                                                                    33C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            Bendu_Junction33A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 6G                    2                                                                                                                          5                                                                                         5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   D                                                                                      5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    D               2                     D            6J                                                                                                                        34E                                                                                                                                                 C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          2                                                              36F                                                                                                                                                                                                                 C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    2              6E                                                                                                                                                                                                                                                                                       C                        5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   D                                       D             6H                                            C                                                           C                                                                                                                                       C                                 5                                      D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   6C                                                                                                                                                                                                                                                                     C                                 5                       33J
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              D                                     2                         D             2                                                          5                                                           5                                                                          C                                                            5                                                                        3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          5                                33F              33H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              2                                    6A        D                2                                                                       36G                                                         36D                                                                         5                                                           33D                                                                      11A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 D                            D                                                            6F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             4G                              D                2                                                                                                                                                                                                                                                                          33B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 2                             2                                             6D                                                                                                                                                                                                   C          34B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              2              6B                                                                                                                                                      C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 4I                           4F                                                                                                                                                                                                                                                  5                                                                                                                  D                        D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             4E                                                                                                                                                                      5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 34D                                                                                                                 3                        3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         D                                                                                                                                             C                                                            36A                                                                                                                           D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     C                                                                                                                                                                                                              11B                      11C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         2                                                                                                                                             5                                                                                                  C                                                                                       3
                                                                                                                                                                                                                                                                                                                                                                                                                                                    D                                                                                                                                                                                                 36E                            5                                                                    5                                                                                      10A
                                                                                                                                                                                                                                                                                                                                                                                                                                 D                                                                      4H
                                                                                                                                                                                                                                                                                                                                                                                                                                                     2                 D                                                                                                                                                                                                            36B                                                                                                                  C                                                                                                                                                        D
                                                                                                                                                                                                                                                                                                                                                                                                                                  2                                                                                                                                                                                                                                                                                                                      34F                                                                                                                                             D                              D
                                                                                                                                                                                                                                                                                                                                                                                                                                                    4K                 2                                                                                                                                                                                                                                                       C                                                                         5                                                           D                                                                                            3
                                                                                                                                                                                                                                                                                                                                                                                                                                 4L                                                    D                                                                                                                                                                                                                                       5                                                                        35H                                                                                              3                              3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                       4J                                                    D                      D                                                                                                                                                                                                                                                                                       C                        3                                                                                           12A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       2                          D           2                                                                                                                                                                                               39F                                                                                                                                                                       11D                            11E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     2                                                                                                                     C                                        C                                                                                                                       4                       10B                                                                                                      D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      4D                          2          4B                                                                                                                                                                                                                                                                                                                                                                                                                             D                3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    4A                                                                                                                     5                                        5                         C                                                                                            35B
                                                                                                                                                                                                                                                                                                                                                                                                  D                                                                                                              4C                                                                                                                                                                                                                                                                                                                                                                                            D                    D                       3               12C
                                                                                                                                                                                                                                                                                                                                                                                                                   D                                                                                                                                                                                                                                                      36C                                      39E                        5
                                                                                                                                                                                                                                                                                                                                                                                                  2                             D                                                                                                                                                                                                                                                                                                                               C                                                                                                          D                                   3                    3                      12B                             D
                                                                                                                                                                                                                                                                                                                                                                                                                   2                                                                                                                                                                                                                                                                                                                         39G
                                                                                                                                                                                                                                                                                                                                                                                                                                2                                                                                                                                                                                                                                                                                                                               5                                                                                                          3                                  11F                  11G                                                     3             D
                                                                                                                                                                                                                                                                                                                                                                                                 4O               4N                                                                                                                                                                                                                                                                                                     C
                                                                                                                                                                                                                                                                                                                                                                                                D                              4M                                                                                                                                                                                                                                                                                                                              39H                                                                                                        10C                                                                                          D                  12E            3               D
                                                                                                                                                                                                                                                                                                                                                                                                                  D                                                                                                   D                                                                                                                                                                                                  5
                                                                                                                                                                                                                                                                                                                                                                                                 2                                                                                                                                           D                                                                                                                                                                                                                                   C                                                                                                                                                                                     3                                                 3
                                                                                                                                                                                                                                                                                                                                                                                                                   2                                                                                                                                                                                                                                                                                                    39D                                                                                                          C                                                                                                                                                                  12G
                                                                                                                                                                                                                                                                                                                                                                                                                                     D                                                                                2                      2                                                                                                                                             C                                            C                                        5                                                                                                                              D                        D                            12D                                               12I      D
                                                                                                                                                                                                                                                                                                                                                                                                5F                5E                                                                                                                                                                                                                                                                                                                                                                                                       C         4                                               D                                                                                              D
                                                                                                                                                                                                                                                                                                                                                                                                                                     2                                                                               3W                     3X                                                                                                                                             5                                            5                                       39I                                                                                                                             3                        3                                                                                       3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           4        35D                                              3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        Bendu                                                                                                                                                                                                                                                                                                                                                                                       3

between SOCFIN and the
                                                                                                                                                                                                                                                                                                                                                                                                                                    5D                                                                             D                        D                                                                                                                                             38G                                          39C                                                                                                                                                                     11H                      11I                                                                                             D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                           D            2                                                                                                                                                                                                                                                                                               C                                 35F                                                       10D                                                                                                          D                              12K
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   2                         2                                                                                                                                                                                                           C                                                                                                                                                                                                                         12F                                                  3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                            2                                                                                                                                                   C                                                                                                                                                                                                                       C                                                                                                                                        3                                              D
                                                                                                                                                                                                                                                                                                                                                                                               D                                                                                       5A                                                                                                                                                                                                                                                                5                              5                                                                                                                                    D                                                                                                         12M
                                                                                                                                                                                                                                                                                                                                                                                                                                                                           5B                                     3U                        3V                                                                                  5                                                                     C                                                                                                                                                 4                                                                                       D                                               12H                                             3
                                                                                                                                                                                                                                                                                                                                                                                               2                                                                                                             D                                                                                                                                                                                                                                          39B                            39J            C                                  C                                                                                   3
                                                                                                                                                                                                                                                                                                                                                                                                              D                                       D                                                                                                                                                                        38A                                                                    5                                                                                                                                                35A                                                                                      3                                                                                              12O
                                                                                                                                                                                                                                                                                                                                                                                               5I                                 D                                                                           2                         D                     C                                                                                                                                                                                                                                       4                                  4                                                                                  11J
                                                                                                                                                                                                                                                                                                                                                                                                              2                                       2                                                                                                                                                                                                                                                                                                                                                                     C                                                                                                                  11K                                                       D
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                                                                                                                                                                                                                                                                                                                                                                                                             5H                   2                  5C                                                                                                                                                                                                                                                                                                                                C                                    4                                                                                                                                                                            3
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  Zone C Fertilzer depot/Quimical center
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               1                                                                                                                                                                       3

foreseeing the development of
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        6
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palm oil plantations by SOCFIN
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     C                                                                                        18A                            19D                               7                                    19K
                                                                                                                                                                                                                                          1                                                                                                             03C                                                                                                                                                                                                                                                                                                                                                                                                                             27E                          6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     3                                                                                                                                                        19H
                                                                                                                                                                                                                                         01K                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 C                                                                      27F                                              C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    18V                                                                                                                                                                                                                                                                                              6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         C                  C                                                                                                7                                           C
                                                                                                                                                                                                                                                                                                                                                          C                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         27G
                                                                                                                                                                                                                                              C                                                                                                                                                                                                                                                                                                                                                                          3                  3                                                                                               19J                                          6                     C
                                                                                                                                                                                                                                                                                                                                                          1                                                                                                                                                                                                                           C                                                                  C                C
                                                                                                                                                                                                                                              1                                                                                                                                                                                                                                                                                                                                                                         18P                18Q                                       C                                                                         C                        27H                    6
                                                                                                                                                                                                                                                                                                                                                         03D                                                                                                                                                                                                                          3                                                                  3                7                                                                                                                                                               C
                                                                                                                                                                                                                                             01J                                                             C                                                                                                                                                                                                                                                                                                                                                                       7                                                                         7                                              27I                                                C
                                                                                                                                                                                                                                                                                             C                                                                                                                                                                                                                                                                                       18U                                                                18R              16A                        C                                                                                                                                     6
                                                                                                                                                                                                                                                                                                             1                                                                                                                                                                                                                                                                                         C                                                                            16B                                                                       19L                                                                                                6
                                                                                                                                                                                                                                                                                             1                                                                                                                                                                                                                                                                                                                                                                                                      7                                                                                        C                                           27N
                                                                                                                                                                                                                                                                                                            04A                                                                                                                                                                                                                                                                                        3                                                                                                            C                                                                                                                      C                    27P
                                                                                                                                                                                                                                                                                            01H                                                                              C                                                                                                                                                                                                                                                                                                                     16C                                                                                       6
                                                                                                                                                                                                                                                    C                                                                                                                                                                                                                                                                                                                                                 18T                                                                                                           7
                                                                                                                                                                                                                                                                                                                                                                             1                                                                                                                                                                                                                                                                                                                                                                                                              27J                      C                      6
                                                                                                                                                                                                                                                    1                                                                                                                                                                                                                                                                                                                                                                                                   C                                                          16D
                                                                                                                                                                                                                                                                                                  C                                                                         03E                                                   C                                                                                                                                                                                                                                              C                                                                                                                                   6                    27O
                                                                                                                                                                                                                                                   01I                                                                                                                                                                                                                                                                                                                                                                                                  3                                                                         C                                                                                                                                  C
                                                                                                                                                                                                                                                                                                  1                                                                                                                               2                                                                                                                                                                                                                                              7                                                                                                            C                     27K
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  C                                                                                   C                                                                                                                                                           7                                             C                                                                        C           6
                                                                                                                                                                                                                                                                                                 01G                          C                                                                                                  03F                                                                                                                                                                                                                   18S                      16I                                                                                                           6                            C
                                                                                                                                                                                                                                                                                                                                                   C                                                                                                                              2                                                                                   2                                                                                                                                                          16E                C                           6                                                                        6          27R
                                                                                                                                                                                                                                                                                                                              1                                                                                                                                                                                                                                                                                                                                                                                 C                                    7                                       27L                           6
                                                                                                                                                                                                                                                                                                                                                   1                                                                                                                             03H                                                                                15B                                                                                                                                                         C                                              27T                                                                      27Q
                                                                                                                                                                                                                                                                                                                             04B                                                                                            C                                                                                                                                       C                                                                                                                                           7                                  16F                                                                    27M
                                                                                                                                                                                                                                                                                                                                                  04C                                                                                                                                                                                                                                                                                                   C                                                                       7

over an area of 12,000 hectares
                                                                                                                                                                                                                                                                                                                                                                                                                            2                                                                                                                                       2                                                                                                                                          16L
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        7                                    C                                 16M                    C
                                                                                                                                                                                                                                                                                                                                                         C                                                                 03G                                                         C                                                                           15A                                                                       C
                                                                                                                                                                                                                                                                       C                                                                                                                                                                                                                                                                                                                                                                               16H                                   7                                                        7
                                                                                                                                                                                                                                                                                                                                                         1                                                                                                                             2                                                                                                                                                     7                                              16J
                                                                                                                                                                                                                                                                       1                                                                                                                                                                                                                                                                                                                                                                                                                                                                            16N
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              Panguma
                                                                                                                                                                                                                                                                                                                                                        04D                                                                C                                                          03I                                                                                                                                                   16G
                                                                                                                                                                                                                                                                      01F                                       C
                                                                                                                                                                                                                                                                                                                1
                                                                                                                                                                                                                                                                                                                                                                                                                           2
                                                                                                                                                                                                                                                                                                                                                                                                                          04E                                                                                                                                  C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              Gboyama                                                                                                                                                                                                                                              C                                                                                                             C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             C
                                                                                                                                                                                                                                                                                                               01E                                        C                                                                                                                       C                                                                                                                                                                                                                                                                                                                                                                8                                                                                                             8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               2                                                                                                                                                                                                                                                                                                                                                                                                             8
                                                                                                                                                                                                                                                                                                                                                          1                                                                                                                       2                                                                 C                                                                                                                                                                                                                                                                                             28A                                                                                                           31J
                                                                                                                                                                                                                                                                                                                                                                                                              C                                                                                                                                               14B                                                                                                                                                                                                                                                                                                                                                                                                           31K                                           C
                                                                                                                                                                                                                                                                                                                                                         04G                                                                                                                     04F                                                                2                                                                                                  C                                                                                                                                                                                                                                                                                                   C
                                                                                                                                                                                                                                                                                                             C                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    C                       8
                                                                                                                                                                                                                                                                                                                                                                                                              2                                     C                                                                                                                                                                                                  7                                                                                                                                                                                                     C                                                                                             8           C
                                                                                                                                                                                                                                                                                                             1                                                                                                                                                                                                                                     14A                                                                                                                                                                                                                                                                                                                                                                                                                                            8                      31A
                                                                                                                                                                                                                                                                                                                                                                                                             04H                                    2                                                                                                                                                                                                 16K                                                                                                                                                                                                    8                                                                                            31L          8
                                                                                                                                                                                                                                                                                                            01D                                                C                                                                                                                                                        C                                                                                                                                                                                                                                                                                                                                                              C                                                                                                         31C                                     C
                                                                                                                                                                                                                                                                                                                                                                                                                                                   04I                                                                                                                                                                                                                                                                                                                                                                     C                                28C                                                                    C                                  31M                                      C
                                                                                                                                                                                                                                                                                                                                                               1                                                                                                                                                        2                                                                                                                                                                                                            C                  C                                                                                                                              8                                                                                                                                                 8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           8                                                                   C                                   8                                                       C                   8
                                                                                                                                                                                                                                                                                                                                                              04K                                            C                                                                                                         04J                                                                                                                                                                                         C                 7                  7                                                                                                                             28E                                                                 C       C                                                                     31I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          28B                                                                  8                                  31R                                                      8                  31B
                                                                                                                                                                                                                                                                                                                                                                                                             2                                  C                                                                                                                                                         B                                                                    C                                   7                17G                17H                                                                                                                                                                                                8       8
                                                                                                                                                                                                                                                                                                                              C                                                                                                                                                                                                                                                                                                                                                                       C                                                                                                                                                                                       28G                                                                                         31E
                                                                                                                                                                                                                                                                                                                                                                                                            04M                                 2                                                                                                                                                         1                                                                     7                                 17F                                                                                                                                                                                                                                    31N     31O               C
                                                                                                                                                                                                                                                                                                                              1                                      C                                                                                                                                                                                                                                                                                                                                7
                                                                                                                                                                                                                                                                                                                                                                                                                                               04O                                                                                                                                                       02A                                                                   17                                                                                                                                          C                                                                                                                                                       8
                                                                                                                                                                                                                                                                                                                             01C                                     1                           C                                                                                                                                                                                                                                                             C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     17E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      C C
                                                                                                                                                                                                                                                                                                                                                                                                 2                                                                                                                                                                                                                                                                                                                                                                                                                         8                                                                                   C                                                                  31G                              C
                                                                                                                                                                                                                                                                                                                                                                    04L                                                                                                                                                                                                                                                                          C             7                                                                                                                                                                                                                  C                                                                   8
                                                                                                                                                                                                                                                                                                                C                                                                                                                                                                                                       C                                                                  B                                                                                                                                                                                                                              28D                                                                                  8                                          8                                                        8
                                                                                                                                                                                                                                                                                                                                                                                                04N                                                                                                                                                                                                                                              7            17C                                                                                                                                                                                                                 8                                                 C                31Q 31P
                                                                                                                                                                                                                                                                                                                1                                                                                                                                                                                                       2                                                                  1                                                                                                                                                                                                                                                                                                                  28K                   8                                                                             31D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   C                                                                                                                                            C               17B                                                                                                                                                                                                                              28H
                                                                                                                                                                                                                                                                                                               01B                                                                                                                                                                                                     04Q                                                                02B                                                                                                                                                                                                                                      C
                                                                                                                                                                                                                                                                                                                                                          C
                                                                                                                                                                                                                                                                                                                                                          1
                                                                                                                                                                                                                                                                                                                                                                                                                     B
                                                                                                                                                                                                                                                                                                                                                                                                                     1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   2
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  04P                                                               B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               17A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   8                           C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   28N
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     Manowo_2                                C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   B                                                                                                                                                                                                                                              28F                          8                                                                                                                                             8
                                                                                                                                                                                                                                                                                                                                                         01A                                                        01F                                                                                                                             1                              1
                                                                                                                                                                                                                                                                                                                                                                                                                                     B                                                                                                                                                                                                                                                                             C                                                                                                                                          28I                                                            C                                                                              31F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   02C                            02D                           B                                                                                                                                                                                                                                                    C                                           C
                                                                                                                                                                                                                                                                                                              B                                                                                                                      1                                                                                                                                                                                                                                                                             7                                                                                                                                                                                                         8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                1                                                                                                                                                                                                                                                    8                                           8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      Sembehun

in the Malen Chiefdom, creating
                                                                                                                                                                                                                                                                                                              2                                                                                                                     01G                                                                                                                                                                                                                                                                           17I                                                                                                               C                                                          C                            29H
                                                                                                                                                                                                                                                                                                             04A
                                                                                                                                                                                                                                                                                                                          B
                                                                                                                                                                                                                                                                                                                                                                                 B
                                                                                                                                                                                                                                                                                                                                                                                 1
                                                                                                                                                                                                                                                                                                                                                                                                                                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               03A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   28J
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    28L                        8                29F                                Manowo_1                                            C
                                                                                                                                                                                                                                                                                                                                                                                                                                                   1                                                                                                                                                                                                                                                                                                                                                                                                                             C            29D                                                                                                      8
                                                                                                                                                                                                                                                                                                                          2                                                     01A                                                                                                                                                              02E                                                                                                                                                                                  7                                                                                                                                                                                C
                                                                                                                                                                                                                                                                                                                                    B                                                                                                             01H                                                                                                                                                                                                                                                                                                    C                                                                                                                       8                                                                                                                    31H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       B
                                                                                                                                                                                                                                                                                                                         04B        2
                                                                                                                                                                                                                                                                                                                                   04C
                                                                                                                                                                                                                                                                                                                                           Njolahun                                          B
                                                                                                                                                                                                                                                                                                                                                                                             1                                                                  B                                                                             B                                                                        1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     17K                 7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        17L                                    C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                29A                                    8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     29G                 C
                                                                                                                                                                                                                                                                                                                                                                                            01B                                                                 1                                                                             1                                                                       03B                                          13A                                                          C                                                                                                             28M                                                   C                 C                  8                                  C
                                                                                                                                                                                                                                                                                                                                                                                                                                                               01I                                                                           02F                                                                                                                                                                                7                                                              8                                                                                                    8                 8                                         C           8
                                                                                                                                                                                                                                                                                                                                                                                                             B                                                                                                                                                                                                                                                             C                                                                                                                                                                            C                               C                                               29I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              10A                                                                                                  29E               11A                                        8          29K
                                                                                                                                                                                                                                                                                                                                                                                                             1                                                                                                                                                                                                                                                             7                                                   17J                                                                             C                                        8                               8                                                                                                                    C
                                                                                                                                                                                                                                                                                                                                 B                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             29J
                                                                                                                                                                                                                                                                                                                                                       B                                                    01C                                                       B                                                                                                               B                                                                                   13B                                                                                                                                  8                                       28O                C            29B                           C                                                                         C             8
                                                                                                                                                                                                                                                                                                                                 2                                                                                           B                                                                                                                                B                                                                             B
                                                                                                                                                                                                                                                                                                                                                       2                                                                                                              1                                                                                                               1                                                                                               C                                                                                                                       10B                                                         8                                          8                                                                         8            30G
                                                                                                                                                                                                                                                                                                                                04D                                                                                          1                                                                                                                                1                                                                             1
                                                                                                                                                                                                                                                                                                                                                      04F        B                                                                                                   01J           B                                                                                                 03E                                   B                                                          7                                                                                                                                                                                  29C                                        11B                                                                       30E
                                                                                                                                                                                                                                                                                                                                                                                                                            01D                                                                                                                              02G                                                                           03C                                                                                                                                                                                                                                                                                                                                     C
                                                                                                                                                                                                                                                                                                                                                                 2                                                                                                                 1                                                                                                                                       1                                                         13C                                                                                                                                                                                                           C                                                                               8                                     C
                                                                                                                                                                                                                                                                                                                                                                04G                                                                                                                                                                                                       B
                                                                                                                                                                                                                                                                                                                              B
                                                                                                                                                                                                                                                                                                                              2                                                                                                 B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  01K                  B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          1                                    B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          03D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           Tisana                                                                      C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  11C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      8           30C                    C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        30H
                                                                                                                                                                                                                                                                                                                             04E                                                                                                                                                                      01L                                                                03F                                   1                                                                                                                                                                  C                                    8                  C                                                                            11D                   11E                     30A C                               8
                                                                                                                                                                                                                                                                                                                                                                                                                                1                                                                                                                            02H                                                                                                                                                                                                                                    C                                                                                                                                                                                          C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              03L                                                                                                                                                                 8                                   10E                 8              C                                                                                                               8                              30F
                                                                                                                                                                                                                                                                                                                                                                                                                               01E                                                                                                                                                                                                                                                                                                                                                                  8                                                                                                                                                                                          8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 10C                                                     10F             8                                                                                                              30B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         B                                                                                                                                                                                                                         10D                                                               C                                                                              C                                         30D
                                                                                                                                                                                                                                                                                                                                                                           B                                                                                                                                 B                                                                                                                                                                                                                                                                                                                                          10G                                      C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         1                                      B                                                                             C                                                                                                                                                                      8                                                                              8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             1
                                                                                                                                                                                                                                                                                                                                                                           2
                                                                                                                                                                                                                                                                                                                                                                          05F                                                            Senehun                                                            01N                                                         03G                                     1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               03M
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             12B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    10H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                10I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   11F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                            B                                            B                                                                                                  03N                                                  C                                  12C                                                                                                                            C               C                           C
                                                                                                                                                                                                                                                                                                                                                                                             B                                                                                                                                                                                                                                                                      B                                                                12D                              C                                                                                                                                                                                   C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                            1                                            1                                                                                                                                                       7                                                                                                                                                                 9               9                           9
                                                                                                                                                                                                                                                                                                                                                                                             2                       B                                                                                                                                               B                                                                                              4                                                                                                 9                      C                                                                                                                                                            8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                           01M                                          01O                                                                                                                                                     12A                                                                                                                                                               09K             09L                         09M
                                                                                                                                                                                                                                                                                                                                                         B                                  05G                      2                                                                                                                                               1                                                                                             16A                                                                                               09A                     9                                                                                                                                                           11G
                                                                                                                                                                                                                                                                                                                                                         2                                                          05H                                                                                                                                             03H

a projected 2,414 jobs.28 A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        B                                                                                                                                                                                                                                                   09C
                                                                                                                                                                                                                                                                                                                                                        05E                                                                                                                                                                             1
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          B                                                                                            B                                                                                                              C                                  C                                                                                                            C
                                                                                                                                                                                                                                                                                                                                        B                                                                                                                                                                                              01P         B                                                                                                                                                                                                                                                                                                                                                                                C
                                                                                                                                                                                                                                                                                                                                                                                                                                              B                                                                                                           1                                                                                            4                                                                                                              9                                  9                                                                                                            9
                                                                                                                                                                                                                                                                                                                                        2                                                                                                                                                                                                          1 B                                                                                                                                                                                                                                                                                                                                                                              9
                                                                                                                                                                                                                                                                                                                                                                                                                                              2                                                                                                          03I                                                                                          16B                                                                                                                                               09D                                              C                              C                            09I
                                                                                                                                                                                                                                                                                                                                       05D                                                                                                                                                                                                        01Q 1                                                                                                                                                                                                              09B                                                                                                                                                           09J
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   B                                                                                                                                                                                                                                                                                                                                  C                  C               9                              9
                                                                                                                                                                                                                                                                                                                                                                                                                                             05I                                                                                                     03J                                                                                        B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   2                                               B                                                              B                              B                                                                                                           B                                                                        9                  9              09G                            09H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  05J                                                                                                             1                                             4                                                                  B                         4                                                                       09E                09F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   1                                                                                             4
                                                                                                                                                                                                                                                                                                                        B                                                                                                                                                                                                                                                                        03O                                           16C                                                                 4                        17A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  03K                                                                                           16D                                       B
                                                                                                                                                                                                                                                                                                                        2                                                                                                                                                                                                                                                                                                                                                                                         17B
                                                                                                                                                                                                                                                                                                        B                                                                                                                                                                                         B                                                                                                                                                                       4
                                                                                                                                                                                                                                                                                                                       05C                                                                                                                                                                                                                                                                                           B                                        B
                                                                                                                                                                                                                                                                                                                                                                           Jaluahun
                                                                                                                                                                                                                                                                                                        2                                                                                                            B                                                                            2                                                                                                                                                                      18A
                                                                                                                                                                                                                                                                                   B                   05B                                                                                                           2                                                                                                                                                                                               4                                        4                                                                                                                                     C
                                                                                                                                                                                                                                                                                                                                                                                                                                                            B                                    06A                                                                                              B                                                                                                                                                                                                                                                                                                                                                       C
                                                                                                                                                                                                                                                                                   2                                                                                                                                05K                                                                                                                                                                                             16E                                      18B                                                                                                                                    9
                                                                                                                                                                                                                                                                                                                                                                                                                                                            2                                                                                                                                     4                                                                                                                                                                               C                                                              C                                                                                                        9
                                                                                                                                                                                                                                                                                                                                                                 B                                                                                                                                     B                                                                                                                                                                                                                                                                                           05B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         Bumuvulahun
                                                                                                                                                                                                                                                                                  05A                                                                                                                                                                      07H                                                                                                                           B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 16F                                                                                                                                                                              9                                                              9                                                                                                       08F
                                                                                                                                                                                                                                                                                                                                                                 2                           B                                                                                                         2                                                                                 4                                                       B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 05A                                                            05D
                                                                                                                                                                                                                                                                                                                                                                07A                          2                                                                                                        06B                                                                               16G                                                      4
                                                                                                                                                                                                                                                                                                                                                                                            07F                                                                                                             Gandorhun                                                                                                                           18C                                                            B                                                                                                                                                                                                                              C

                                                                                                                                                                                                                                                                                                                                                                     B                                 B                                      B                                                                                                                                                                                                                                              B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               4
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              19B              B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    C                                           Sengema                                                       9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             08E
                                                                                                                                                                                                                                                                                                                                                                                                       2                                      2                                                                                                                                                                                                                                              4                                                                                                                                      9
                                                                                                                                                                                                                                                                                                                                                                     2                                                                                                                                                                                                                                                                                                                                                         4
                                                                                                                                                                                                                                                                                                                                                                                                      07G                                    07I                                                                                                                                                                                                B                                           19A                                                                                                                                    05C
                                                                                                                                                                                                                                                                                                                                                                    07B                B                                                                                                                                                                                                                                     B                                                                                                19C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                4
                                                                                                                                                                                                                                                                                                                                                                                       2                                                                                                                                                                                                                                                                                               B                                                          B                                                                                                                                                                         C
                                                                                                                                                                                                                                                                            Fakaba                                                                                                    07C
                                                                                                                                                                                                                                                                                                                                                                                                                                                           B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             4
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            18E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               18D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       4                                                          4                                                                          C                                                                                 C            9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           B                                                                                          19E                                                        19D                                                       C                 9                                                                                 9           08D
                                                                                                                                                                                                                                                                                                                                                                                                      B                                                    2
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            Giema
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           4                                                                                                     B                                                                                                         9                05E                                                                               08C
                                                                                                                                                                                                                                                                                                                        B                                                                             2                                                   07J                                                                                                                                                                                                                                                                                                                            C                                                                                                    C                                               C
                                                                                                                                                                                                                                                                                                                                                    B                                                                                                                                                                                                                                     18G                                                                                                                                                                                                             05F
                                                                                                                                                                                                                                                                                                                        3                                                                            07D                                                                                                                                      B                                                                                                                                                  4                                                                                       9                                                                                                    9                                               9

new version of the 2011 lease
                                                                                                                                                                                                                                                                                                                                    B               3
                                                                                                                                                                                                                                                           B                                                           10A                                                                                                                                                                                                                    2                B                                                                     B                                                          19F                                                                                     05G                                                                                                  08A                                             08G
                                                                                                                                                                                                                                                                                                                                    3              10C                                                                                                                                                                                                                                                                                                                                                         B
                                                                                                                                                                                                                                                           3                                                                                                                                                                                                                     B                                                           09C               2                                                                     4                                                                                                                                                                                                                                                                                                           C
                                                                                                                                                                                                                                                                                                                                   10B                                                                                                                                                                                       B                                                                                                                                                                                 4
                                                                                                                                                                                                                                                          11C                                                                                                              B                                                                                     B               2                                                                            09D                                                                   18F                                                                                               B                                                                                                                                                                                                          9
                                                                                                                                                                                                                                                                                                                                                                                                             B                                                                                           B                   2                                                                                                                                                                                19G
                                                                                                                                                                                                                                                                           B                 B                                                                             3                                                                                     2              08A                                                                                                                                                                                                                                                   4                                                                                                                                                                                                         08I
                                                                                                                                                                                                                                                                           3                                                                                              13C                                2                                                                                           2                  09B                                                                                                                                                                                                                                                                                                                                                      C                                                         C
                                                                                                                                                                                                                                                                                                                                                                                                                               Gbamgba 08B
                                                                                                                                                                                                                                                                                             3                                                                                                                                                                                                                                                                                     B                                                                                                                                                 19H                                               C                                                                                                                             C
                                                                                                                                                                                                                                     B                                    11D                                                                                                                               07E                                                                                         09A                                                                        2                                                                                                                                                                                                                                                                                                 9                                                         9
                                                                                                                                                                                                                                                                                            11E               B                                                                                                                                                                                                                                                                                                                                                                                                                                                                        9                                                                                                                             9
                                                                                                                                                                                                                                     3                                                                                                                                                                                                                                                                                                                                            09E                                                                                                                                                                                                                                                                                               06H                             08B       C               08J
                                                                                                                                                                                                                                                                                                              3                                                                                                                                                   B                                                                                                                                                    B                                                                                                                                                              05H
                                                                                                                                                                                                                                    11B                                                                                  B                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               C                                                    9
                                                                                                                                                                                                                                                                                                             11F                       B                                                                                                                          2                                                                                                                                                    4
                                                                                                                                                                                                                                                                                                                         3                                                   B                                                                                                     B                                                                                                                                                                                                                                                                                   C                                                                                                 9                                                   08H
                                                                                                                                                                                                                                                                                                                                    B 3                                                                                                 B                        08C                                                                                                                             B                    18H                                    B                                                                                                         9
                                                                                                                                                                                                                       B                                                                                                11G                                                  3                                                                                                     2                                                                                                                                                                                                                                                                                                                                                                       C            06G
                                                                                                                                                                                                                                                                                                                                    3 13A           B                                                                                   3                                                                                                                                                        2                                                           4                                                                                                        05I                                                                                                                                                               C
                                                                                                                                                                                                                       3                                                                                                                                                    13D                        B                                                                          08D                                                                                                                                                                                                                                                                                                                                                                      9
                                                                                                                                                                                                                                                                                                                                   12E              3                                                  3                               13I                                                                                                                                                      09F                                                         20A                                                                                                                                                                                                                                                        C                9
                                                                                                                                                                                                                      11A                                                                   B                                                                                                                                                                                                                                                                                                                                                                         B                                                                                                                                  C                                   C            06F                                                                                              C
                                                                                                                                                                                                                                                                                                                                                   13B                                                13G                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              9               07I                 9
                                                                                                                                                                                                                                                                                            3                                                                                                                          B                                                                                                                                                                                             B                                                4                                                                                                                                  9                                   9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        06B                                                                                                           07H                                 07J
                                                                                                                                                                                                                                                                                           12C                                                                                                                         3                                                                                      B                                                                                                      4                                               20B                                 B                                                                                                                                  06E
                                                                                                                                                                                                                                                                                                                                                                                  B
                                                                                                                                                                                                                                                                                                                                                                                  3                                   13H                                                                                     5                                                                                                     18I                                                                                  4
                                                                                                                                                                                                                                                                                                                                                                                                     B                            B
                                                                                                                                                                                                                                                                                                                                                                                 13E                                                                                                                         21A                                                                                       B                                                                               B                20E
                                                                                                                                                                                                                                                                                                                                                                                                     3                            3                                                                                            B                                                                                                                                                                                                                                                                                                  C
                                                                                                                                                                                                                                             B                                                                                                                                                                                                                                                                                                                                                         4                                                                               4                                                                                                                                                                                                                        C
                                                                                                                                                                                                                                                                       B                                                                                                                            13F                          13J                                                                                           5                                                                                                                                                                                         B                                                                                                        9                                                                                                     C
                                                                                                                                                                                                                                             3                                                                                                                                                                                                                                   B                                                                  B                                                 18J                                                                             20C                                4                                                                                                                                                                    C                 9
                                                                                                                                                                                                                                                                       3                                                                                                                                                                                                                                                      21B                                                                                                                                                                                                                                                             C                                  06D                                                                                                    9
                                                                                                                                                                                                                                            12A                                         B                               B                                                                                                                 B                                      2                                                                  5                                                                                                                                                                   20F                                                                   9                                                                                               9                07F                     07G
                                                                                                                                                                                                                                                                      12B                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             C
                                                                                                                                                                                                                                                                                        3                               3                    B                                                                                                                                  08E                                                                21C                                                                                                                                                                                                                                                                                                                            C          07E
                                                                                                                                                                                                                                                                                                                                                                                                                                          3                                                                                                                                                                                                                                                                                            B                                                     06A                      9
                                                                                                                                                                                                                                                                                       12D                             12F                   3                                                                                                                                                                                                                           B               B                                 B                                                                                                                                                                                                                                                      9
                                                                                                                                                                                                                                                                                                                                                                                                                                         13K                                                                                                                                                              B                                                                                                                            4                                                                             06C
                                                                                                                                                                                            A                                                                                                                                               12H                                                                                                          B                                         B                                                                     5               5                                 5                                                                                                                                                                                                                                                     07D
                                                                                                                                                                                                                                    A                                                                                                                                                                                                                                                                                                                                   21D                               5                             B                                                                                             20G
                                                                                                                                                                                            1                                                                                                                                                                                                                          B                                 3                                         5                                                                                    21E                               21G
                                                                                                                                                                                                                                    1                                                                                                              B                                                                   3                                13L                                                                                                                                              21F                            6
                                                                                                                   A                                                                       26H                                                                                                                                                                                                                                                                                                    22A
                                                                                                                                                                                                                                                                                                               B                                                                                                                     B

agreement was subsequently
                                                                                                                                                                                                                                   26N                                                                                                             3                                                                  14A                                       B                                                                                                                                                                      27A         B                                                                                                                                                                                                 C               C
                                                                                                                   1
                                                                                                                  26E
                                                                                                                                                                                                                              A
                                                                                                                                                                                                                              1
                                                                                                                                                                                                                                                                                                               3
                                                                                                                                                                                                                                                                                                              12G
                                                                                                                                                                                                                                                                                                                                                  12I               Banale                                                           3
                                                                                                                                                                                                                                                                                                                                                                                                                                    14B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                3
                                                                                                                                                                                                                                                                                                                                                                                                                                                               13M
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  27B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             4                                                    B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 B                                                                   9               9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    07C
                                                                                                                                                       A                                                                     26M                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 6                                                  C               07B
                                                                                                   A                                                                                                                                                                                                                                                                                                                                                                                                                  22B                                                                                                                                                                   20D                                                   4
                                                                      Gbomgboma26A                                                                     1                                                                                                                                                                                                                                              B                                                                          B                                                                                                                                                                                                                                                                                              28A                                                 9
                                                                                1                                                      A                                        A                                                                                                                                                                                                                     3                                                                                                                                                                                                                                                                                                                                          20H
                                                                                                                                                      26F                                                                                                                                                                                                                                                                                                                        3                                                                                                                                                                           B                                                                                                                                                                     07A
                                                                                                                                       1                                        1                                                    A                                                                                                                                                               14C                   B                B
                                                                                                                                                                                                                A                                                                                                                                                                                                                                               B               13N                                                                                                                                                                          6
                                                                                                                                      26D                                      26G                                                   1                                                                                                                                                                                     3                3
                                                                                                                                                                                                                1                                                                                                                                                                                                                                               3
                                                                                                          A
                                                                                                          1
                                                                                                                            A
                                                                                                                            1                                                                                  26K
                                                                                                                                                                                                                                    26L                                                                                                                                    B                                              14D              14E                 14F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 3           B                               B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           Basale                           27C       B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      6                 B                                                                     B
                                                                                                                                                                                                                                                                                                                                                                           3                                                                                                                 5                                          B                                                                                                                            27D                6                                                                     6
                                                                                                                           26C                                                                                                                  A                                                                                                                                                                                                                               14G                                          5                                                     24C                                                                                                                       B
                                                                                                         26B                                                                                                                      A                              A                                                                                                        15A                                                                                                               23A                                         5                                                                                                                                              27E                                  B                                28B          B
                                                                                                                                                                                                                                                1                                                                                                                                          B                                                                                                                                23F                                                                                                                                                                              6
                                                                                                                                                                                 A                                                1                              1                                                                                                                                                                                                                                                                     23G                                                                                                                                                                                  6                                             6
                                                                                                                                                                                                                                               27K                                    A                                                                                                    3                                                                                                                                                                                                                                                                                                                27F                                                                          B
                                                                                                                                                                                 1                                               26Q                            27J                                                                                                                                                                                                                                                                                                                                                                                                                                                        27G                                           28C                               B
                                                                                                                                                                                                                                                                                      1                                                                                                   15B                                                                                                                                                                                                                                                                                                                                                                                            6
                                                                                                                                                                                26J                                                                                                                    A                            A                                                                      B                                                                                                                                                                                                                                                                                                                                                                                               6
                                                                                                                                                                                                                                                                                     27I                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                28D
                                                                                                                                                                A
                                                                                                                                                                1
                                                                                                                                                                                                                                                                                                       1
                                                                                                                                                                                                                                                                                                      27H
                                                                                                                                                                                                                                                                                                                     A
                                                                                                                                                                                                                                                                                                                     1
                                                                                                                                                                                                                                                                                                                                    1
                                                                                                                                                                                                                                                                                                                                   27F
                                                                                                                                                                                                                                                                                                                                                                                                           3
                                                                                                                                                                                                                                                                                                                                                                                                          15C                                                         Kanga                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          28E              B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           6
                                                                                                                                                               26I                                           A                 A                                                                                    27G                                  A                                                                                                                                                                                                                                           5
                                                                                                                                                                                                             1                 1                                                                                                                         1       A                                                   B            B                                                                                                                    24A              24B                                                                                                                                                                      27H                                                                      28F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    25A
                                                                                                                                                                                                            26O               26P                                                                                                                       27E      1                                                   3            3                                                                                                                                                                                                               B
                                                                                                                                                                                                                                                                                                                                                                27D                                                                                  B                                                                                                                                                                                            6

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      Legend
                                                                                                                                                                                                                                                                                                                                                                                                                    15D          15E
                                                                                                                                                               A                                                                                                                                                                                                                                                                                     3                                                                                                                                                                                                                                                                                                               B                                                                B
                                                                                                                                             A                 1
                                                                                                                                                                            Potain                              A
                                                                                                                                                                                                                                                      Kassay                                                                                                                                                                                        15F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 30A          B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           6                                                          B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     6                                                                6
                                                                                                                                             1                25G                                                                                                                                                                                                                                                                                                B                                                                          23E                                                                   25B                                        30B                              B                                                                     29A                                                              28G
                                                                                                                                                                                                                1                                                                                                                                                                                                                                                                                                             B                                                                                                  25C                                      30C                                                         6                                                                                             B
                                                                                                                                            25F                                                                                                                                                                                                                                                                                                                  3                                                                                                                                                                                                                            6
                                                                                                                                                                                                               26R                                                                                                                                                                                                                                                                                                            5                                                                                                                                                                                                      27I                                                                                            6
                                                                                                                                 A                                                                                                                                                                                                                                                                                                                              15G                                                                                                                                                                                                                          30D                                                         B
                                                                                                                                 1                                                                                                                                                                                                                                                                                                                                                                                           23D                                                                                                                                                                                                                                                B                  B                               29G

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  ZONE
                                                                                                                                                                                                                                                                                                                                             A                  A                                                                                                                                                                                                                                                                                                                                                                                        6                                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        B                                                                                                                                                                                                                                                                           B           6

signed between the MAFFS and
                                                                                                                                25E                                                                                                                                                                                        A                 1                                                                                                                                                                                                                                                       B                                                                                                                                                  29B                                        6
                                                                                                                                                                                                                                                                                                                                                                1                                                                                                                       5                                                                                                                                                                                                                                                                           6          29D                                                                     8
                                                                                                                  A                                                                                                                                                                                                        1                27B                                                                                                                                                                                                                                                      5                                                                                                               Zone B Fertilizer depot                                                      29E
                                                                                                                                                                                                                                                                     A                                                                                         27A                                                                                                                     23B             B                                                                                 B                                                                                                                                                                         29C                                               B                                36A
                                                                                                                  1                                                                      A                              A                                                                                                 27C                                                                                                                                                                                                                                                                       24E                                                                                                        B
                                                                                                                                                                                                                                                                     1                                                                                                                                               A                                                                                 5                                                                                 5                                                                                                                                                                                                                           6
                                                                                                                 25D                                                                     1                              1                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      6
                                                                                                                                                                                                                                                                    24N                                                                                                                                              2                                                                                23C                                                                               24D                                                                                                                                                                                                                         29F

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 A
                                                                                                                                                                                        24I                            24J                                                                                                                                                                                                                                             B                                                                                                                                                                          B                                                           30F
                                                                                                           A                                                                                                                                                A                                                                                                                                                       8D                                                                                                                             B                                                                                                                                    B                                                                                                                                                              B
                                                                                                                                                                                                                                                            1              A                                                                                                                                                                                           3                                                                                                                                                                          5
                                                                                                           1                                                                                              A                                                                                                                                                                                                                                                                                                                                        5                                                                                                                                    6                                                                                                                                                              8
                                                                                                                                                                    A                                                                                      24M             1                                                                                   A                                                                                                      15H                                                                                                                                                                        25D                                                                                                                                                                                B
                                                                                              A           25C                                                                                             1                                                                                                                                                                      A                                                                                                                                                                23H                                                                                B                                                 30E                                                                                                                                                            36C
                                                                                                                                                                    1                                                                                                     24L                                                                                   2                                                                                                                                                                                                                                    B                                                                                                                                                                                                                              8                                                                B
                                                                                  A           1                                                                                                          24H                                                                                                                                                                     2                                                                                               B                                                                                                                                                   5                                                                                                                                                                                                                                   B
                                                                                                                                                                   24A           A                                                                                                                                                                             8B                                                         A                                                                                                                                                                          5                                                                                                                      B               B                                                                                      36B                                                               8

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 B
                                                                                  1          25B                                                                           A                                                                                                                                                                                                    8C                                                                                               3                                                                                 B                                                                25E                                                                                                                                                                                                                                  8
                                                                                                                                                                                 1                                                                                                                                                                                                                                         2                                                                                                                                                                        25G                                                                                                                     6               6                                                                                                                                                       36H
                                                                                 25A                                                                                       1                                                                                                                                                                                                                                                                                                                                                                                       5
                                                                                                                                            Taninahun24B                        24C
                                                                                                                                                                                        A              A           A                                A                                                                                        A
                                                                                                                                                                                                                                                                                                                                                                                                                          8E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                15I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  23I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       B                    B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           30G             30H         Naiahun                                                                                           B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        36E

                                                                                                                                                                                                                                                    1                                                                                                                                                                                                                                                                                                                                                                  5                    6                           31H                                                                                                                        B                               B
                                                                                                                                                                                        1              1           1                                                                                                                          2                                                                                       A                                                                                                                                                           24F                                                                                                                                                                                                           B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      25F                  31F                                                                                                                                                     8                               8                    36D

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                C
                                                                                                                                                                                       24D                        24G                              24K                                                                                       8A                                                                                        2                                                                                                                                                                                                                B                                                                                                                                                       8
                                                                                                                                                                                                    A 24F
                                                                                                                                                                                                    1
                                                                                                                                                                                                                                                                                                                                                                                                                                      8F                                              Jombuhum                                                                            B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  37A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               37B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  37C

                                                                                                                                                                                                   24E                                                                                                                                                                                                                                                                                                                                                                                            B                                                    31G
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          5
                                                                                                                                                                                                                                                                                             A                                                                                                                                                            A                                                                                                                                       5                                                                                                                                               B
                                                                                                                                                                                                                                                                                 A                                            A                                                                                                                           2                                                                                                              24G                                                                                                                 B                 B                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                D
                                                                                                                                                                                                                                                                                             7                                                                                                                                                                                                                                                                                                   25H                                                                                                                           B                  7                         B
                                                                                                                                                                                                                                                                                 7                                            7                                                                                                                          8G                                                                                                                                                                                                                                  7                 7                                                                             8                                                                                   B
                                                                                                                                                                                                                                                                                            23E                A                                                                                                                                                                                                   B                                                                                                                                                                                                           7                 32H                        8
                                                                                                                                                                                                                                                                                23D                                          23G                                                                                                                                                                                                                                                                                                                              B                             32D               32F                           B                                               37E                                                                                  8
                                                                                                                                                                                                                                                                                                               7                                                                                                                                                                                                   5                                                                                                                                                     B                                                    32G                                          37D
                                                                                                                                                                                                             A                                                                                                                                                                                                                                                                                         B                                                                                                                              B                       7                                                                             7                                                            B                                   B                                  36G
                                                                                                          A                                                                           A                                                                                                                       23F                                                                                                                                                                                                 26B                                                                                                                                                    7
                                                                                                          7      A                                                                    7                      7
                                                                                                                                                                                                                                                                                                                                                                                A                                                                         Mornogo                                      5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      26A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     31E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             32A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        32C                      B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           32I                                                           8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        37G
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            37J
                                                                                                         28E     7
                                                                                                                28F
                                                                                                                                                                                     22L                    22N          A
                                                                                                                                                                                                                         7
                                                                                                                                                                                                                                                                                                                                   Kpombu                                        2
                                                                                                                                                                                                                                                                                                                                                                                7A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         5
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                32E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           37I
                                                                                        A                                                                                                                                                                                                                                                                                                                                                                                                                                               26C                                                                      31D                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Fertilizer depot
                                                                                                                                                                                                                        22Q                                 A                                                                                                                                                                                                                                                                                                                                  6

SOCFIN in October 2012.29 This
                                                                                        7                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     B                                                                                                              B                                                                                          B   B                                                                                                 B
                                                                                A                                                                                    A                                                                                      7                                                                                                                                                                                                                                                                                                                                 31C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       7                                                                                                                                                                                             B
                                                                                                                                 A                                                                                                                                                                             A                                                                                                                                                                                                                                                              6                                                                                                              7                                                                                          8   8                                                                                                 8
                                                                                7      28B                                                                           7                                                                                     23C                                                                                                                                                                                                                                                                                                                                                                                        32B                                                                                                                                                                                            8
                                                                                                                                 7           A                                                                                                                                                                 7                                                                                                                                                                                                                                                             31B                                                                                                            33A                                                                                        37F 37H                                                                                               36I
                                                                               28A
                                                                                                                                28G          7
                                                                                                                                            28H
                                                                                                                                                                    22I
                                                                                                                                                                                                     A
                                                                                                                                                                                                     7
                                                                                                                                                                                                                                              A
                                                                                                                                                                                                                                              7
                                                                                                                                                                                                                                                                                                  A           21F                                                                                                                                                                                                       Maca                                                                                                                                                                                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    37M
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             B

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Mill
                                                                                                                                                                                                    22O                                                                                           7                                                                                                                                                                                                                                                       B                                                                                                                                                                                                                                                         37K                                      8
                                                                                                                                                                                                                                             23B                                                                                                                                                                                                                                                                                                                                                                                            B                                                                                 33B
                                                                                                                                                                                                                                                                                                 21E                                       A                                                                                                                                                                                                              6                                                                                                               B                                                                             B                                                                           B                       36F
                                                                                         A          A                                                                                                                                                                                                                                                                                A                                                                                                                                                                                                                                                      7
                                                                                                                                                                                                                                                                                                                                            2
                                                                                                                                                                                                                                                                                                                                                                                                                               Bobobu
                                                                       A A                                                                                                                                                                                                                                                                                                                                                                                                                                                                               31A                                                                                                              7                                                           B                 7                                                                           8
                                                                                         7          7                                                               A                                                                                                                                                                                                                 2                                                                                                                                                                                                                                                    34A                                                            B
                                                                       7 7                                                                                                                                                                                                                                                                 6A                                                                                                                                                                                                                                                                                                                            34B                                                          7                33D                                                                         37L
                                                                                        28C        28D                                                              7                                                                                                                                                                                                                7B                                                                                                                                                                                                                                                                                                                   7
                                                                     28K 28J                                                                                                                                                                                                                                                                       A                                                                   A                                                                                                                                                                                                                                                                                                             33C
                                                                     A
                                                                     7
                                                                                                                                                                   22J
                                                                                                                                                                                  A
                                                                                                                                                                                  7                                                                                                                                                         A
                                                                                                                                                                                                                                                                                                                                                    2
                                                                                                                                                                                                                                                                                                                                                   6B
                                                                                                                                                                                                                                                                                                                                                                                           A
                                                                                                                                                                                                                                                                                                                                                                                                                       2
                                                                                                                                                                                                                                                                                                                                                                                                                      7D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                            A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                             2
                                                                                                                                                                                                                                                                                                                                                                                                                                                                            9A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         34C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Zone A office
                                                                    28L           A                                                                                                               A                     A                                                                                                                   2                                                                                       A                                                                                                                                                                                  B                                                                                      7                                                                                           B                                                          B
                                                                                                                                                 A                               22M                                                                                               A                                                                                                       2                                                                                                                                                                                                                                                                                                                                                                 33E
                                                                                  7                                                                                   A                           7                                           A                                                                      A                                                                                                               2                                                                                                                                                                                 7                                                                                                                                                                                  8                                       B                  8
                                                                                                                                                 7                                                                      7                                                          7                                                       6C                                             7C                                                                                                                                                                                                                                                                                                                 34D
                                                                                 28I                                                                                  7                          22P                                          7                                                                      2                                                                                                                                                                                                                       B                                                                        35K                                                                                                                                                                                37O                      B               8                 38E
                                                                                                                                                                                                                       23A                                                                                                                                                                            A                             7E                                                                                                                                                               B

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  Roads
                                                                                                                                                22G                  22K                                                                                    A                     21D                                                                                                                                                                                                                                                        7                                                                                                                                                                                                                                                                                    8
                                                                                                                                                              A                                                                              21B                                                                    6D                                                                                                                                                                                                       A                                                                                                                                                                                                                                                  B                                                                38D
                                                                                                                                                                                                                                                            7                                                                         A                                                                2                                                                                                                                    35A                                                      7                                                       B                                                                                                                                            B
                                                                                                                                                              7                                                                                                                                                                                         A                                                                                                                                                                    3                                                                                                                                                                                                          B                                       7                                                38C
                                                                                                                                                                                                                                                           21C                                                                         2                                                              7F                                                                                                                                                                                          B 35J                                                      7                         B                                                                                                                  8                                                                          B
                                                                                                                                                             22H                                                                                                                                                                                         2                                                                                                                                                                  10H                                                                                                                                                                                                         7                                      33F
                                                                                                                                                                                                                                                                                                                                      6E                                                                                                                                                                                                                     B                                    7                                                         35N                        7                                                                                                                 37N                                      B                                  8
                                                                                                                                                                                                                                                                                                                                                        6F                                                                                                                                                                                                                                                                                                                                                                             34E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             7                                   35I                                                                                  34E                                                                                                                                                         8                                 38G
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Block
                                                                                        A                                   A
                                                                                                                                                                                                                                    A                                                                                                                                                                                                                                                        A                                                              35B                                                                            B                                                                                                                                                                          B                          38P
                                                                                         4                                  7                                                                                                                                                                                        A                                          A                                                                                                                                A                    A                                                                                                                                                                                                                                                    B                                                                                                   B
                                                                                                                                                                           A                                                        7                                                                                                                                                                                                                                                        3                                                                                                                                             7                                                                                   B                                                                                      8
                                                                                                                           22A                                                                 A                                                                                                                                                                                                                                                                                                 3                                                                  B                                                                                                                                                                                                                                B                                                                         8
                                                                                        1A                                                                                 7                                                       21A                                                                               2                                          2                                                                                                                           10L 10K                A 3                                                                                                     B                                                                                                   9                                           9
                                                                                                                                                                                               7                                                                                                                                                                                                                                                                                                                                                                    7                                                                     35M                                                                                                                                                        8               38B                                                      38F
                                                                                                                                                                          22B
                                                                                                                                                                                                                                                                                                                    6M                                         6G                                                                                                                                                  3 10G                                                                                                   7                                                                                                  39C                                         39F                                                                                                           B                B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    38A
                                                        Kotomahun                                                                                                                             22C
                                                                                                                                                                                                                                                                                            A
                                                                                                                                                                                                                                                                                                                                                         A
                                                                                                                                                                                                                                                                                                                                                                                                      A
                                                                                                                                                                                                                                                                                                                                                                                                      2
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  10I                                              35C                    B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          7
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          35L
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       38H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        38I                                                                                                                                      Main
                                                                                                                                                                                               A                                                                                            2           A                                                                                            7G                                                                                                                            A                                                                                                                                                 B
                                                                                                                                                                                                                                                                                                                                                                                                                     A                                                                                                                                                                                                                                                                                                                                                    B

was followed by a new lease
                                                                                                                                                                                                                                                                                                                                                         2                                                                                                                                                                                                           B                   35E                                                                                         9                       9                                                                                                                                       B
                                                                                                                                                 A                                             7                                                                                           6N           2                                                             A                                              2                                                                                                             3                                                                                                                                                                                                                                      9                                                         B
                                                                                                                                                                                                                                                                                                       6O                                               6H            2                                                                                                                                 A                                    A                       7                                                                                                              39B                     39D                                                                                                                                      8
                                                                                                                                                  4                                           22E                                                                                                                                                                                                                   7H                                                                                                            10F                                                                                                                         B                                                                                                          39G                                                        8
                                                                                                                                                                                                                                                                                                                         A                                            6I                                                                                                                                3                                    3                      35D                                                                                                                                                                                                                                                                             38K
                                                                                                                                                 2A
                                                                                                                                                                                       A                                      Semabu                                                                                      2
                                                                                                                                                                                                                                                                                                                         6P                                                     A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       10J                                  10D
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             39A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   38J
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 National
                                                                                                                                                                                                     A                                                                                                                                                                                                                                                                                 A                                                                                                          B             B                                                                                  9                                                                                                                                B
                                                                                                                                                                                       7                                                                                         A                                                                                                                                                                                                                                                                                       7                                                                                                                                                                               B
                                                                                                                                            A                                                        7                                                                                     A                                                                                    2                                                                                                      3                                                                                                          7                                                                                               39E                                                                                                                                                                8
                                                                                                                                                                                      22D                                                                                        2                                                                                                                                                                                                                                                                                                                              7                                                                                                        B                               9                      B                                                   8
                                                                                                                                             4                                                      22F                                                                                     2                  A                       A                                        6J                                                                                                                                                                                      35F                      35G                                                                                                                                                                                                                                                                38M
                                                                                                                                                                                                                                                                A               6R                                                                                                                                                                                                    10E A                                                                                                                    35O                                                                                                       9                              40B                     9                                                  38L
                                                                                                                                            2B                                                                                                                                                                 2                       2
                                                                                                                                                                                                                                                                 4                         6S     A                                                                                        A                                                                                              3                                                                                                                                                                                                                             40A                                                                                                                                    B
                                                                                                                                 A                                                                                                                                                                            6U                      6Q                                                                                                                                                                                                                                                                                                                                                                                                                                       39H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             B                                                                                                                                                                                                           B
                                                                                                                                 4
                                                                                                                                2C
                                                                                                                                                                           A
                                                                                                                                                                            4
                                                                                                                                                                                                                                                                5A                                 2
                                                                                                                                                                                                                                                                                                  6T     A
                                                                                                                                                                                                                                                                                                                                                                                            2
                                                                                                                                                                                                                                                                                                                                                                                           6K                       Sahn                                                                 10C                          A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      3                                                                  B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             7                                                                    B                                                 B                                                                                    8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               8
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              38O
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            35P                                                                   9                                                 9                                                                                   38N
                                                                                                                                                                           3A                                                                                       A                                     2
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   A 10B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Swamp
                                                                                                                                                                                                                                                                                                                                                        A                                                                                                                                                                                                                                7                                                                                                                                                         40C                                   B
                                                                                               Walleh                  A
                                                                                                                       4
                                                                                                                                                                                                            Sinjo                                                    4
                                                                                                                                                                                                                                                                    5B
                                                                                                                                                                                                                                                                                                         6V                                              2
                                                                                                                                                                                                                                                                                                                                                        6L     A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   3                                                                    35H                                                                                                      40D                                                                                     9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        40F
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  10A
                                                                                                                      2D                                                   A
                                                                                                                                                                                                                                                            A                                                                                                  6                           A                                                                                                                                                                                                                                                                                                             B                                                                                                                                    Sahun
                                                                                                                                                                            4
                                                                                                                                                                           3B                                                           A                   4
                                                                                                                                                                                                                                                                           A
                                                                                                                                                                                                                                                                                                                    A
                                                                                                                                                                                                                                                                                                                     4                                   A
                                                                                                                                                                                                                                                                                                                                                              11A                          6
                                                                                                                                                                                                                                                                                                                                                                                          11F                                                                                                                                                                       A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          7                                          Jumbu                                               9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        40E
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   9
                                                                                                                                                                                                                                        4                  5D                                                                                                                                                                                                                                                                       A                               3                                    35Q
                                                                                                                                                                                                                                                                                                                    5K                                   6                                                                                                                             A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Forests
                                                                                                                                                                                                                                                                           4                                                                                                          A                                                                                                                                                             A                                                                                                                                                                                                                                             40G
                                                                                                                           A               A                                                                                           5C                                                                                                               11B                                                                                                                                       A                A                3                              12A                                                                                                                           B
                                                                                                                                                                                 A                                                                                        5G       A                                                                                                  6                                                                                                3                                                            3                                                                                                                                                               B
                                                                                                                            4               4                                                                                                                                                                                                                                                                                                                                                     3                3               12C                                                                                                                                                           9
                                                                                                                                                                                 4                                                                                                 4                                                                                                 11G                                                                                              12F                                                          12B                                                                                                                           B                                  9
                                                                                                                           2E              2F                                                                        A                                           A                                                                                                                                                                                                                               12E              12D                                                      A                                                                                                                    41E
                                                                                                                                                                                3C                                    4                       A                                   5H             A                                                  A                                                                                                                                                                                                                                                                                                                            9                                 41F
                                                                                                                                                                                                                                                                  4                                                                                                                                                                                                                                                                                                        3
                                                                                                                                                                                                                     4A                        4                                                 4                                                  6                                                                                                                                                                                                                                                                                                                           41C
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Hydrography_region
                                                                                                                                                                                                                                                                 5F                                                                                                                                   A                                                                                                                                                                   17A
                                                                                                                                                                                                                       A                      5E                                                 5J                                                11C                           A                                                                                                                                                                                                                                                                                                                B                                                                   B
                                                                                                                                                                            A                                                                                                                                     A                                                                                   6
                                                                                                                                                                                                                       4                             A                                                                                                                           6                                                                                                                                A                                                                        B                                                                              B                       9                                                                   9
                                                                                                                                                                            4                                                                                                                                      4                                                                                 11I                                                                                                                                                                                                                                                                                                                                           B
                                                                                                                                                                                                                      4B                             4                                                                                                                          11H                                                                                                                               3          A                                             A               9                    B                                                         9                      41D                                                                 42D
                                                                                                                                                                           3D                                                                                                                                     5L                          A                                                                                                                                                                                                                                                                                                        B

for a further 6,269 hectares in
                                                                                                                                                                                                                                                     5I                                                                                                                                                                   A                                                                                      12J                                                       3                                                                                             41B                                                                       9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             3                                                            43A                   9
                                                                                                         Massao                                                                                                                                                                                                                               6                                                                           3                                                                                                              A                                                                                                             9

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 VillageArea_region
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          17B                                  43B                                                                                                                                42C
                                                                                                                                                                                                                                                                                                                                             11D                                                                         13E                                                                                                12I          3                                                                                                            41A
                                                                                                                                                                     A                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               B
                                                                                                                                                                     4                                           A                                                                                                                          A                                                                                             A                                                                                             12G
                                                                                                                                                                                                                 4                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          B                        9
                                                                                                                                       A
                                                                                                                                                                    3E
                                                                                                                                                                    A
                                                                                                                                                                                                                4C                     Sembehun                                                                                             6
                                                                                                                                                                                                                                                                                                                                           11E
                                                                                                                                                                                                                                                                                                                                                                                                                                          3
                                                                                                                                                                                                                                                                                                                                                                                                                                         13D                          A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               B
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            9                       42B

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 Greenbelt
                                                                                                                                       4                                                                                                                                                                                                                                                                                                                              3                                                                                                        17C                                                                                                                         42A
                                                                                                                                                                     4                                                                                                                                                                                                                                                                                                                                                        3                                                               43C
                                                                                                                       A              4D                                                                                                                                                                                                                                                                                                                             13C                                                                                                                                          B
                                                                                                                                                                    3F                                                                                                                                                                                                                                                                                                            A                                          12H                                                                                                                                                 B
                                                                                                                       4                                                                                                                                                                                                                                                                                                                                                                                           A                                                                                              9
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                A                                                                                  B             9
                                                                                                                                                                                                                                                                                                                                                 Ngeyhun
                                                                                                                                      A                                                                                                                                                                                                                                                                                                                                           3                                3
                                                                                                                      4D                                                                                                                                                                                                                                                                                                                                                                                                                                                        3           B                    43D
                                                                                                                                                                                        A                                                                                                                                                                                         A                                                                                              13B                              12K                                                                                                                                              9            44I
                                                                                                                                       4                                                                                                                                                                                                                                                                                                                                                                                                                                       17D          9
                                                                                                                                                                                         4                                                                                                                                                                                        6                                                                                                                                                                                                                                                                B              44G
                                                                                                                                      4E                                                                                                                                                                                                                             A                                                                                                                                                                                                                     43E
                                                                                                                                                                                        4F                                                                                                                                                                                       14A                                                                                                                                                                                                                                                               9
                                                                                                                                                                                                                                                                                                                                                                     6                                                                                                                  A                                                          A                               A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       A                                                                         B                                                44E                                              B
                                                                                                                                                                                                                                                                                                 A                                                                  14E                                                                                                                 3                                                          3                               3                                             B
                                                                                                                                                                                             A                                                                                                   5                         A                                                                                       A                                                                                                   3                                                                         9                                                                                                 9
                                                                                                                                                                                                                                                                             A                                                                                                                                                                                                         13A                                                        17G                             17E                        B                   9                                              B
                                                                                                                                                                                             4                                                                                                  15E                        5                                                                                       6                                                                                                  17F                                                                       43F                                                                                               44J
                                                                                                                                                                                                                                                           A                 5                                                                                                                                                                                                                                                                                                                               9                  44C                                             9
                                                                                                                                                                                            4G                                                             5                15D                                           15G                                                                                     14B                                                                                                                                                                                       44A
                                                                                                                                                                                                                                                                                                                                                                                                                                       A                                                                                                                                                                                                                 B                     44H
                                                                                                                                                                                                                                                          15C                                                 A                                                                                                                        6            A                                                                                                                                                                                      B
                                                                                                                                                                                                                                                                                                                                                                                                                                                    6                                                                                                                                                                                                    9
                                                                                                                                                                                                  A                                                                                                           5                                                                                                                       14C                                                                                                          A                                                            B                          9
                                                                                                                                                                                                                                           A                                                                                                                                                                                                       14D                                                             A                                                                                                                                    44F
                                                                                                                                                                                                  4                                                                                                                                                                                                                                                                                                                                                3          A
                                                                                                                                                                                                 4H
                                                                                                                                                                                                                              A            5
                                                                                                                                                                                                                                                                                                             15F                                                       A                                                                                                                                           3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  17H         3
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                9                         44D                                                                                                                                                                                                                                                                                                                                                                                                  Legend inside the parcel
                                                                                                                                                                                                                              5                                                                                                                                        6                                                                                                                                          17J                                                                                          44B
                                                                                                                                                                                                                                          15B                                                                                                                                                                                                                                                                                                                17I
                                                                                                                                                                                                       A                     15A                                                                                              A                                       16C                                                                                                                                                      A
                                                                                                                                                                                                       4
                                                                                                                                                                                                                                                           A                                                        A         5             A             A
                                                                                                                                                                                                                                                                                                                                                                                                 A
                                                                                                                                                                                                                                                                                                                                                                                                                 A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               3                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               Zone         X
                                                                                                                                                                                                       4I                      A                                                                                    5        15N            6                                                    6                                                                                                                            17K
                                                                                                                                                                                                                               5              A            5
                                                                                                                                                                                                                                                                                                                   15M                     16A
                                                                                                                                                                                                                                                                                                                                                          6
                                                                                                                                                                                                                                                                                                                                                                                                16D              6
                                                                                                                                                                                                                                                                                                                                                                                                                                  A                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            Section      X

November 2013, and a third lease
                                                                                                                                                                                                                                                          15J                                                                                            16B                                                    16E
                                                                                                                                                                                                                              15H             5
                                                                                                                                                                                                                                             15I
                                                                                                                                                                                                                                                                                                                                                                                                                                  6                                                                                                     A                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      Block Parcel XX
                                                                                                                                            A                                                 A                                                                                  A                A                                                                                                                              16F                                                                                                    3
                                                                                                                                            5                                                 5                                                                                  5                5                                                                                                                                                                                                                                    17L
                                                                                                                                           20D                                               20A                                                                                15K              15L                                                                                                                                               A                                                                               A
                                                                                                                                                                                                                                                                                                                                                                                                                                                   6                                                                               3
                                                                                                                                                                                                                      A

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   1:31,000
                                                                                                                                                                                            A                                                                                                                                                                                                                                                     16G                                                                             17M
                                                                                                                                                                                            5                         5                                                                                                                                                                                                                                           A
                                                                                                                                                                                           20C                       20B                                                                                                                                                                                                                                          6
                                                                                                                                                                                                                                                                                                                                                                                                                                                                 16H
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       © Socfin

                                                                                                                                                                                       A                                                                                                                                                                                                                                          A
                                                                                                                                                                                       5                                                                                                                                                                                                                                          6
                                                                                                                                                                                      20E                                                                                                                                                                      A             A                                     A             16N
                                                                                                                                                                                                                                                                                                                                                               6                                 A
                                                                                                                                                                           A
                                                                                                                                                                                                                                                                 A
                                                                                                                                                                                                                                                                 5                                           Hinai                                 A
                                                                                                                                                                                                                                                                                                                                                              16J
                                                                                                                                                                                                                                                                                                                                                                             6
                                                                                                                                                                                                                                                                                                                                                                            16K
                                                                                                                                                                                                                                                                                                                                                                                                 6
                                                                                                                                                                                                                                                                                                                                                                                                16L
                                                                                                                                                                                                                                                                                                                                                                                                                   6
                                                                                                                                                                                                                                                                                                                                                                                                                  16M
                                                                                                                                                                           5                                                                                    20J                                                                                6
                                                                                                                                                                          20F
                                                                                                                                                                                                                                                                                                                                                  16I                                                                                     A
                                                                                                                                                                                                                                                    A                                                                                                                                                                                     6
                                                                                                                                                                                                                                                    5                                                                                                                                                                                    18D
                                                                                                                                                                                                                                                   20K
                                                                                                                                                                                                                                                                                                                                                 A
                                                                                                                                                                                                                                        A                                                                                                        5                                                                                                                           A
                                                                                                                                                                                                                A

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       0                         0.45                            0.9                                                             1.8                                                          2.7                                                         3.6
                                                                                                                                                                                            A                                           5                                                                                                       19D                                                                                                                          6
                                                                                                                                                                A                                               5
                                                                                                                                                                                            5                                          20L                                                                                                                                                                                                                                  18F
                                                                                                                                                                5                                              20M
                                                                                                                                                                                                                                                                                       A                                                     A                                                                         A                                       A
                                                                                                                                                                                           20G
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            Kilometers
                                                                                                                                                               20H                                  A                                                                                                                                        5                                                                         6                                       6
                                                                                                                                                                                                                                                                                       5

agreement at an unknown date
                                                                                                                                                                                                    5                                                                                                                                       19E                                                                       18C                                     18E
                                                                                                                                                                                                                                                                                      19A
                                                                                                                                                        A                                          20N
                                                                                                                                                        5

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  Ü
                                                                                                                                                       20I                               A
                                                                                                                                                                                         5                                                                                                                                A
                                                                                                                                                                                        20O                                                                                                                               5
                                                                                                                                                                                 A
                                                                                                                                                                                                               Hongai                                                                                                    19F
                                                                                                                                                                                                                                                                                                                                                                                                        A
                                                                                                                                                                                                                                                                                                                                                                                                        6                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           Socfin Agricultural Company
                                                                                                                                                                                 5                                                                                                                                                                                                                     18B
                                                                                                                                                                                20P                                                                                                                                  A
                                                                                                                                                                                                                                                                                                                     5
                                                                                                                                                                                                                                                                                                                    19G
                                                                                                                                                                                                                                                                                                                                                                                  A                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             SAC Project
                                                                                                                                                                                                                                                                                                                                                                                  6
                                                                                                                                                                                                                                                                A
                                                                                                                                                                                                                                                                5
                                                                                                                                                                                                                                                                             A
                                                                                                                                                                                                                                                                             5
                                                                                                                                                                                                                                                                                                                                                                                 18A
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              Sierra Leone
                                                                                                                                                                                                                                 Gangama 19B                                19C                                     A
                                                                                                                                                                                                                                                                                                                    5
                                                                                                                                                                                                                                                                                                                   19H
                                                                                                                                                                                                                                                                                                                   A
                                                                                                                                                                                                                                                                                                                   5                                                                                        Gambia
                                                                                                                                                                                                                                                                                                                  19I
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             Author: MARCO RODRIGUES

covering 5,628 hectares. All three
leases followed the same process
of a ‘head lease’ between the
MAFFS and the Malen Chiefdom,
and a sub-lease between the
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 SOCFIN’s
MAFFS and SOCFIN.30                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    concession is larger
                                                                                                                                                                                                                                                          BRUSSELS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          than the entire
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              2. The Malen Case

28 Memorandum of Understanding and Agreement. 24
   September 2012. Available at: www.fian.be/IMG/pdf/
   sac__memorandum_of_understanding_mou_and_
   agreement_with_rep._of_sierra_leone_24-09-2012_.
                                                                                                                                                                                                                                                          16,140 HA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       Brussels-Capital
   pdf.

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   Region.
29 According to SOCFIN the 2011 lease was amended
   in 2012 at the request of the Government of Sierra
   Leone following a change from the GPS data system.
   SOCFIN. Supra Note 1.
30 All requests by FIAN Belgium and MALOA for access
   to these lease documents have been rejected by
   SOCFIN.
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              23
As of December 2017, SOCFIN
                         claimed to hold 18,473 hectares
                         of land in concession in Sierra
                         Leone.31 Out of the total land
                         held by SOCFIN, between 12,349
                         hectares32 and 12,557 hectares33
                         have been converted into palm
                         oil plantations according to
                         SOCFIN’s own source, an area
                         in excess of the limit of 12,000
                         set by the Government of Sierra
                         Leone in the 2012 MoU.

                         Projections made by SOCFIN in
                         2010 on the basis of the 2004
                         national census estimated that
                         approximately 28,135 people
                         in the chiefdoms of Malen,
                         Bum, Lugbu and Bagbo would

                                                                                                                                                               © Maja Hitij
                         be affected by the project.34
                         However, of the four chiefdoms
                         identified only Malen is located
                         within the concession area.                                  BOX 3.
                         Testimonies gathered by FIAN
                         Belgium indicate that this may                               THE 2012 MEMORANDUM OF
                         be due to Paramount Chiefs in
                         other chiefdoms refusing to lease                            UNDERSTANDING (MOU)
                         their land to SOCFIN or posing
                         certain conditions that SOCFIN                               -- This MoU shall be construed in accordance with the laws of the
                         was unwilling to accept.35 On the                               Republic of Sierra Leone and is intended to be binding on the
                         basis of data from the new census                               parties (Article 7).
                         conducted in 2015, we estimate at                            -- This MoU shall be renewed after every five years in line with the
                         least two-thirds of the population                              land lease agreements (Recital I).
                         of Malen to be directly affected                             -- SAC intends to distribute the bulk of its future palm oil
                         by the project (32,842 people).36                               production to the local Sierra Leone market (Recital C).
                         It concerns about 52 villages.37
                                                                                      -- The Investor shall develop a Corporate Social Responsibility
                                                                                         (CSR) plan based on an assessment of community needs in
                                                                                         collaboration with local government officials, Paramount Chiefs,
                                                                                         representatives of land owning families, and the communities
                                                                                         themselves (Article 1, Investor’s Obligations).
                                                                                      -- The Investor shall develop a smallholder or out-grower scheme
                                                                                         as per the guidance of the Government of Sierra Leone
                                                                                         (GOSL). The aim of the scheme shall be to achieve food self-
                                                                                         sufficiency and ultimately food sovereignty (Article 4, Investor’s
                                                                                         Obligations).
                         31 SOCFIN. Sustainable Development Report 2017. p.
                            10.
                         32 Ibid. p. 167.
                                                                                      -- The Investor shall adhere to the Environmental Protection
                         33 SOCFIN. Sustainability Report 2015. p. 6. Available at:      Agency Act and other environmental regulations developed by
Land Grabbing for Palm

                            www.socfin.com/sites/default/files/2018-12/RAP-
                            POR~3.PDF.
                         34 Environmental Resources Management on behalf
                                                                                         the GOSL and in line with international best practices (Article 12,
                                                                                         Investor’s Obligations).
Oil in Sierra Leone

                            of SOCFIN. Sierra Leone Agricultural Company
                            (SAC), Sierra Leone: Environmental and Social Due
                            Diligence Assessment. 2015. pp. 10-11. Available at:
                            www.fian.be/IMG/pdf/socfin_esdd_sac_erm_re-               -- The GOSL agrees to enter into a water rights agreement with
                            port_final_v2.0_31jul15.pdf.
                         35 See FIAN Belgium. Minutes - Interviews Fact-finding          SAC, and SAC will be charged at a fixed rate of 3 Leone per
                            mission (FFM) 2016, Bo. 01 April 2016.
                         36 In the formula used in the SOCFIN assessment of              cubic metre of water. (…) There will be no restriction on the
                            2010 it was considered that 28% of the total popu-
                            lation of the chiefdoms of Malen, Bum, Lugbu and             volume of water extracted. (Annex 11).
                            Bagbo would be affected by the concession.
                         37 SOCFIN. Supra Note 1.
24
2.3. Community Opposition
Following the signing of the                          In December 2012, the                                     “We are convinced that the
MoU, local communities in the                         communities submitted a petition                          peaceful protest march will help
Malen Chiefdom continued                              to the Human Rights Commission                            to attract the government’s
to voice concerns over the                            of Sierra Leone (HRC).39 Following                        attention and further raise public
land acquisition process and                          this petition, the HRC dispatched                         awareness of human rights abuses
SOCFIN’s activities. They were                        fact-finding missions to the area                         and land grabbing in Malen
joined in their efforts by national                   and initiated a mediation process                         Chiefdom caused by the illegal
and international civil society                       engaging all relevant actors. A                           operations of SOCFIN Agricultural
organizations and NGOs,                               draft agreement was submitted                             Company.”41
including Green Scenery,                              to the parties in June 2013, and
Welthungerhilfe, the Oakland                          a follow-up meeting was held in                           On 16 October 2013, six MALOA
Institute and FIAN Belgium. Their                     November 2013. The mediation,                             executive members were
demands included:                                     however, could not be concluded                           arrested in various parts of the
                                                      due to the absence of the                                 Malen Chiefdom, allegedly in
-- A review of all agreements                         Paramount Chief, the Minister of                          connection with their advocacy
   concerning the land deal in                        Agriculture, Forestry and Food                            on behalf of local populations.42
   Malen;                                             Security and the Minister of                              They were charged with
-- An increase in the                                 Justice.40                                                “destruction of growing plants”,
   compensation paid to local                                                                                   “conspiracy” and “incitement”.
   communities;                                       Amidst this process, a protest
                                                      in Pujehun Town was organized
-- Involvement of landowners
                                                      for 30 August 2013. In a letter to
   unwilling to lease their land in an
                                                      the Pujehun Police several days
   out-grower farmer scheme;                                                                                              THE SIX MALOA EXECUTIVE
                                                      prior, MALOA expressed their
-- The provision of all relevant                                                                                            MEMBERS ARBITRARILY
                                                      continued concerns:
   agreements and documents to                                                                                               ARRESTED IN 2013 AND
   local stakeholders;                                                                                                          CONVICTED IN 2016.
-- Transparency in all future
   negotiations;
-- The proper demarcation
   and preservation of land for
   community agricultural activities;
-- Clarity around social and
   community commitments of
   SOCFIN.38
                                                                                                                                                                        2. The Malen Case

                                                      39 MALOA. Petition to the Human Rights Commission
                                                         of Sierra Leone: “Gross abuse of our fundamental
                                                         human rights by the Paramount Chief and Chiefdom
                                                         authorities of Malen Chiefdom, Pujehun District,       41 MALOA. Peaceful protest march against human rights
                                                         Southern Province of the Republic Sierra Leone”. 1        abuses and land grabbing in Malen Chiefdom. 27
                                                         December 2012. Available at: www.fian.be/IMG/pdf/         August 2013. Letter to Pujehun Police Station.
                                                         maloa_statement_1st_december_2012-2.pdf.               42 See Communication of the UN Special Rapporteurs
                                                      40 Sierra Leone Human Rights Commission. Annual              on Human Rights Defenders, Freedom of Expres-
                                                         report 2013. p.36. Available at: www.parliament.gov.      sion, and Freedom of Assembly and Association.
                                                         sl/Portals/0/2014%20DOCUMENT/COMMITTEE/                   AL SLE 2/2015. 17 December 2015. Available
38 MALOA. Grievances of land owners in Malen Chief-      HUMAN%20RIGHTS/THE%20STATE%20OF%20                        at: spcommreports.ohchr.org/TMResultsBase/
   dom. Supra Note 27.                                   HUMAN%20RIGHTS%202013%20MAIN.pdf.                         DownLoadPublicCommunicationFile?gId=21201.
                                                                                                                                                                        25
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