Carbon Done Right
Carbon Done Right
NGO rebuttal and refutal statement of fact

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Rebuttal to NGO press statement

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Our in-depth analysis of the NGO report



This week, we were confronted with deception from an NGO that pledged to collaborate with us on its report, only to release it without further consultation. Their calculated timing aimed to undermine our listing on the London AIM and sow confusion among our shareholders. However, their report was a haphazard collection of poorly researched falsehoods easily debunked with independent legal opinions and other supporting evidence provided below. 

Our founders have dedicated 24 years to Sierra Leone, establishing the largest cooperative of smallholder farmers in Africa and employing over 2,000 staff across multiple operations, in a manner that is always honest and verifiable. However, their report conveniently neglects to mention this, instead casting negative aspersions and disregarding our decades-long commitment to Sierra Leone. See links that reflect our twenty years of commitment to best practice:

HEKS, a Swiss-based Protestant Church Non-Governmental Organization (NGO) with a complex structure, operates in Sierra Leone without actually being located there. It functions through a network of local NGOs. NGOs in West Africa historically deploy various nefarious one sided methods to engage and compete with each other for funding. The poorer the country, the more money is available for NGOs. Some, desperate for income, utilize a web of local agents and malign actors who, whether known to HEKS or not, may act unlawfully to offer incentives in order to influence communities and manipulate them into expressing desired opinions. Such actions have also incited arson attacks against our business by capitalizing on misinformation and sowing discontent among indigenous communities.

Sierra Leone is a very poor predominantly muslim country, still recovering from war, ebola and under utilisation of the agriculture sector. It is easy for religious activity to be readily misconstrude in a country in its post war infancy. NGOs are often funded by overseas foundations and lobby groups. The timing of these attacks, coinciding with our intended listing on the London Stock Exchange is not by chance. This activity sits alongside similar assaults on other companies in our sector by malign actors, demonstrating that there is substantial financial backing for these operations.

There are now ongoing criminal investigations into HEKS’ partner NGOs as a result of these attacks and inciting unrest. We vehemently deny their allegations and have engaged with the Government of Sierra Leone and Sierra Leonean legal experts to challenge the credibility of this Swiss-based Christian charitable NGO and its affiliates.

Carbon markets do require scrutiny, and they will continue to evolve purposefully and responsibly. Regulation is improving, and technology such as our AI models and Tree Counter will ensure transparent tracking and recording of the carbon we sell. While not yet perfect, carbon markets will endure if proper dialogue and collaboration are permitted. We are open and transparent operators, ready to learn and improve, with long standing African partners. We are also strong corporate citizens who are robust in our commitment to standing with our farmers and staff in Sierra Leone.

We urge all our partners to simply call us for a formal full and frank conversation at any time.  Anyone is welcome to visit our reforestation projects and meet our workers and farmers.


In response to the review conducted in Sierra Leone by HEKS and other NGOs, our company has been actively engaged in dialogue over a number of months, providing comprehensive responses to inquiries and queries. However, despite our efforts to provide accurate information, HEKS has published a report filled with unsubstantiated allegations and innuendo, all of which we vehemently refute. This appears to be part of an ongoing assault on Nature-Based Solutions (NBS) carbon projects, a pattern reflected in the similarity of findings to other reports by HEKS on unrelated projects.

We aim to address these misrepresentations and reaffirm our commitment to transparency and responsible environmental stewardship. Leveraging cutting-edge technology, our company will provide unrivalled levels of transparency, traceability, and accountability to substantiate our project benefits. Through our innovative solutions, stakeholders will have access to verifiable data, ensuring that our initiatives are grounded in integrity and credibility.

Moreover, the project does not lease and develop large contiguous blocks of land planted with monocultures, but instead, leases parcels of land directly from smallholders to be planted with indigenous species to allow ongoing community farming and maximum biodiversity benefits. This approach fosters sustainable agricultural practices and empowers local communities to participate actively in the project’s success.

The overwhelming support and appreciation from local communities further validates the positive impact of our projects. We also provide training and support for selected agricultural endeavours, further enriching the communities we serve.

The dubious tactics, including incitement and enticement to elicit negative responses from “informants” and community members, were confirmed during interviews by news reporters and other independent observers. These actions by the NGOs are irresponsible and unethical, leading to manufactured claims that do not align with the positive feedback received from the company’s daily interactions with community members and other stakeholders. It is unclear if the community members interviewed by the NGOs were even part of the first phase of our project, but what is clear is the result was to sow discontent within the communities. This was confirmed by strongly worded statements reproduced below from the Paramount Chiefs addressed to HEKS. The NGOs’ actions were also the likely reason for a recent arson attack on the project.

The company is preparing a detailed and comprehensive response to all the claims, allegations, and insinuations, and this will be posted on our website in the coming days. However, we feel it is important to highlight some of the statements and provide substantiated and evidence-based replies.




The truth about a smallholder reforestation carbon project using indigenous tree species.

The upfront investment is significant including:

  • Feasibility studies; to assess the project for eligibility, climatic conditions, soil conditions, carbon stock baseline, land availability, and much more. This is a very comprehensive study and is the starting point of a potential project.
  • Environmental and Social Impact Assessments are completed to understand all aspects of the potential project area. In addition an Environmental and Social Management Plan is drafted.
  • Biodiversity studies are undertaken to understand what impact a project can have, both positive and negative. This also forms the baseline to measure against future gains.
  • Social and community surveys to better understand the communities and the households. This is important information to assist with the theory of change analysis, shaping the project strategy and also to understand the most dire needs of the communities.
  • Theory of change analysis to understand permanence and  potential leakage that may result from the project as well as other unintended consequences and how that will impact the project and the ER estimate. In addition it will inform action required to minimise leakage as a result of the project.
  • Emission Reduction estimation is completed using peer reviewed allometric data applicable to the area and the species to be included in the project.
  • Control plot studies now required for the latest ARR methodology.
  • Land Use Change analysis is undertaken as part of the feasibility study and the development of the PDD.
  • Land surveys, demarcation and GPS mapping is undertaken to ensure only land that comply with the regulations will be included in the project.
  • Participatory mapping to establish land ownership. This is a time consuming and cumbersome process and involves landowners, their neighbours, chiefdom members and others stakeholders to confirm land ownership. It also involves walking the boundaries and producing maps that will eventually form part of the lease agreements.
  • Participatory mapping and Free, Prior and Informed Consent process. Again a drawn out and well documented process to ensure it will stand up to scrutiny. In the case of this project the landowners approached an international land rights legal NGO to represent them though the leasing process, physically attending all the important engagements between the company and the landowners.
  • Nursery establishment. For this project a combination of own nursery and contracted nurseries are used for the production of seedlings.
  • Planting operations where all functions are manually performed. This to ensure maximum local employment opportunities are generated.
  • Maintenance operations are again all manual and extensive during the first years of the project until a canopy is formed.

Fire prevention operations. The area is prone to fires during the dry months and through active community engagements and collaboration, investment in equipment, and training and employment of fire marshals and crew, this risk is managed and mitigated.

This sits against a backdrop of:

  • Uncertainty in the carbon market as it matures.
  • Ever changing registry methodologies changes to ensure the highest level of efficacy and transparency.
  • Country level carbon legislation continues to be established to ensure equitable distribution of the benefits.
  • NGO and media attacks that are based on preconceived and funding aligned views. These articles are published without a full understanding of the industry and more importantly the specific project. 
  • Income from the sale of carbon credits only commencing many years after the project was started, and significant investment made up to that point. Similar to a tree crop investment.

But what is indisputable is the community uplift as many of the early project costs incurred by investors then flow directly to the communities. These include:

  • Local employment. The project in Sierra Leone employs 50 management, supervisors, team leaders and other skilled and semi-skilled staff. Employs on a season basis 250 monthly paid staff. This is for the dry season to maintain the plantation. In the height of the planting season the staff numbers peak at up to 1,000 indigenous people from within the wide project area.
  • Annual land lease income per the agreements entered into. These are periodically reviewed per the agreement entered into.
  • Local procurement of material required of large amounts of tools and equipment for the field operations. This includes cutlasses, hoe, shovels, head pan, picks, pick axes, water drums, poles for fencing, palm fonts and many more. This is required as the land preparation and maintenance are mostly non-mechanised. The artisanal methods deployed ensure minimal soil disturbance, erosion risk and existing biodiversity disturbance. They are also designed for maximum local employment.
  • One of the biggest single costs for the project is the purchase of seedlings. This is done from local nurseries, where more indigenous people are employed.

Community Development Action Plan; through the social surveys undertaken during the early stages of the project, the most pressing needs of communities are assessed and a plan developed to address them. This could include support for school programs, provision of drinking water through boreholes or water wells, agricultural support, training, energy efficient cookstoves, biodiversity education, and many others.

Significant and ongoing community engagement:

  • The company pays for and employs Community Liaison Officers (CLO). These individuals work for the community, live in the community, are of a high stature and liaise with the company to bring any concerns or grievances to the company. The CLOs are a critical part of a healthy community relationship. The company acknowledges that without community support the project would struggle as it is so strongly integrated within these communities.
  • Women and the youth are always included in discussions and employment. It should also be noted that these are not large communities and for the level of employment the project requires it is important to include as many community members in the project as possible.
  • Paramount Chiefs and chiefdom structures are core to the community makeup and the company ensures regular and open communication with these stakeholders.
  • Central and regional engagement with ministries and other government structures is an ongoing and important process.


  • An advisory committee of scientists, academics and practitioners provide input to the species that would be most adapted to the conditions and environment, and that will create maximum biodiversity benefits.
  • The aim is to attract and re-establish animals native to the area. The biodiversity study identified endangered species common to the region and these will be monitored and reported during the project period.
  • A natural spinoff of this will be improved livelihood benefits to the communities, as long as there is training and awareness created.
  • The forests, as a result of the selected species, will re-establish some of the original fauna and flora in the area and will be monitored and reported.

Technology and science:

Trees play a critical role in mitigating climate change through the process of photosynthesis. During photosynthesis, trees absorb carbon dioxide from the atmosphere and, using sunlight, water, and chlorophyll, convert it into carbohydrates and oxygen. This process not only removes carbon dioxide (a greenhouse gas) from the atmosphere, but also releases oxygen back into the air. In essence, trees act as natural carbon sinks, sequestering carbon in their biomass and soil, while simultaneously replenishing the atmosphere with oxygen. This symbiotic relationship between trees and the atmosphere underscores their significance in combating climate change.

Our Tree Counter technology provides high-resolution, accurate monitoring of forested ecosystems for various stakeholders, from governments to carbon market participants. It addresses the oversight of smallholder farms in landscape restoration efforts by quantifying tree-level biomass and carbon stocks using remote sensing and deep learning. In partnership with Bext 360, it sets a new standard in forest and carbon monitoring, essential for successful carbon market participation. By offering real-time verification of co-benefits and monitoring environmental risks, it ensures equitable participation and drives sustainable forest management worldwide.

The reality is that this is not an easy project to implement for a variety of reasons:

  • The fire risk is real in this area and needs constant and intensive management. The senior staff are experienced in this discipline but community support is key and is ongoing trailing and sensitisation is undertaken.
  • Community structures and dynamics are complex and require ongoing engagement. The CLO’s play a vital role in this regard as does the active engagement approach the company follows.
  • Law changes may affect the project and in this regard we engage and assist government and policy makers on an ongoing basis.
  • Climate change is real and weather patterns are changing. The project needs to take this into account in species selection and operational implementation.
  • Funding partners for difficult jurisdictions like Sierra Leone are not easy to secure.
  • Operations are costly and extensive but the community benefits are significant.
  • The carbon registration process is cumbersome and methodology changes cause delays, as happened late last year with the change to Verra’s VM0047 protocol. It is however important for the company to use the latest and most transparent methodologies to ensure quality carbon credits are produced. 
  • Government engagement is cumbersome and many actors are involved. Forming industry forums to speak with one voice is a strategy that ensures input is coordinated and informed.

The alternative land use for smallholder farmers is limited:

  • The landowners simply don’t have the means to use all their land productively. The approach should always be to do both farming and carbon in turn generating income from the carbon project AND smallholder farming. The project is designed to encourage and support this.
  • With their limited resources, the yield to farmers from their smallholder farming activity is very low. We assist in increasing yields through training and agricultural support.