This Human Rights Risk Assessment (“HRRA”) has been prepared by Nomogaia. Equatorial Palm Oil has failed to respect several human rights pertinent to labor standards, livelihoods, health and property rights and is putting rights at risk in the future. Based on NomoGaia’s on-site observations, multiple interviews, and data supplied by EPO, labor rights at the Palm Bay Estate are not respected...A severe negative human rights impact results from the distinction between employees and subcontractors. EPO hires subcontractors as a lower cost alternative to the “employee” status, which confers benefits, such as holidays with pay, annual leave, medical care, housing, education for dependents, social group insurance. Two-thirds of EPO’s workforce have the status of subcontractor, even though they are engaged year-round on work essential to the plantation’s operations...Even for direct employees, working conditions are substandard, including lack of adequate personal protective equipment...Supplied company housing adversely impacts privacy rights, as two families are assigned to each small company house designed for a single family. Houses have no safe potable water. 

There were repeated, credible accounts of child labor among the subcontractors. These were based on employees seeing people they knew, and whose ages they knew, working as subcontractors…EPO has responded to the reports of child labor as follows: “EPO has numerous systems in place to prevent child labour and illegal employment…