Uzbek Forum for Human Rights (formerly Uzbek-German Forum (UGF)) and CEE Bankwatch Network would like to draw attention to a number of concerns with regards to the proposed loans to Indorama Agro to support its capital expenditure and working capital needs: Indorama Agro Working Capital Loan (EBRD 51011) and Indorama Agro Capex Loan (EBRD 50879)...

- COVID-19 related restrictions in Uzbekistan may have limited the opportunities for meaningful public consultations, and the alternate approach introduced by the company may have undermined the affected communities’ engagement due to lack of accessible information and affordable mechanisms for providing feedback;

- The draft ESIA is characterised by significant gaps in assessment of the project’s impact on water, soil, climate change and human health resulting particularly from the use of pesticides;

- Some of the pesticides suggested for use by the project in Uzbekistan are restricted for use in the EU due to the risks they pose to the environment and human health; the use of glyphosate, in particular, is seriously questioned by the international community due to its carcinogenic and endocrine-disrupting properties;

- While Indorama has made significant progress in eradicating the use of forced labour on its farms, the broader Uzbek context, including continued government involvement in cotton production, a lack of fair and independent recruitment channels and weak accountability systems, continues to present a high-risk environment for cotton production, as documented by Uzbek Forum during the 2020 cotton harvest;

- Indorama was able to acquire 54,000 hectares of land from farmers through ‘voluntary’ terminations of land lease agreements. Farmers did not receive any compensation, either from the local authorities or from Indorama Agro; this questions the entire notion of ‘voluntary’ land acquisition in a situation where local officials wield disproportionate power over citizens with no land tenure security;

- The Livelihood Restoration Plan proposed by Indorama Agro to plant mulberry trees to support sericulture as a means of compensating for job losses in cotton farming does not take into account the nature of the sector, which remains entirely government-controlled and is also known to rely on the use of forced labour...