GLOBAL FORUM ON FOOD SECURITY AND...

1 Principles for Responsible Agricultural InvestmentsProceedings

Proceedings

Principles for Responsible Agricultural Investments

Collection of contributions received

Discussion No. 95 from 13 January to 20 February 2014

Global Forum on Food Security and Nutrition www.fao.org/fsnforum

http://www.fao.org/fsnforum


TABLE OF CONTENTS

Introduction to the topic................................................................................................................................................4

Contributions received...................................................................................................................................................6

1. Paul Rigterink, Potomac Technical Advisors, United States of America........................................................6

2. Katy Lee, International Agri-Food Network, Italy...................................................................................................6

3. C.Palanivelayutham Chokkalingam, India...................................................................................................................7

4. Alexander Sagaydak, State University of Land Use Planning , Russian Federation..................................8

5. Abdul Razak Ayazi, Afghanistan Embassy, Italy.......................................................................................................9

6. Botir Dosov, CACAARI, Uzbekistan..............................................................................................................................11

7. Luca Chinotti, Oxfam International, Italy..................................................................................................................12

8. Rahul Goswami, Centre for Communication and Development Studies / Economic Research Foundation, India (first contribution)...................................................................................................................................................... 12

9. Rahul Goswami, Centre for Communication and Development Studies / Economic Research Foundation, India (second contribution)................................................................................................................................................14

10. Serigne Sarr, Senegal (first contribution)..............................................................................................................17

11. Rahul Goswami, Centre for Communication and Development Studies / Economic Research Foundation, India (third contribution).....................................................................................................................................................19

12. Serigne Sarr, Senegal (second contribution)........................................................................................................22

13. Manuel Castrillo, Proyecto Camino Verde, Costa Rica......................................................................................24

14. Said Zarouali, Haut Commissariat au Plan, Morocco........................................................................................26

15. Christine Andela, Cameroon........................................................................................................................................27

16. International Food Security Network......................................................................................................................28

17. Riikka Sievänen, University of Helsinki, Finland................................................................................................39

18. Global Renewable Fuels Alliance, Canada..............................................................................................................40

19. Tina Goethe, Bread for all, Switzerland..................................................................................................................42

20. Bernd Steimann and Peter Schmidt, HELVETAS Swiss Intercooperation, Switzerland....................44

21. World Society for the Protection of Animals (WSPA)......................................................................................45

22. Kien Nguyen Van, Vietnam...........................................................................................................................................45

23. Kyungmee Kim, Stockhols International Water Institute, Sweeden..........................................................46

24. Senait Regassa, The Swiss Agency for Development and Cooperation, Ethiopia.................................46

25. Jean-Laurent Bungener, consultant, France.........................................................................................................47




26. Kjell Havnevik, Sweden..................................................................................................................................................48

27. ActionAid..............................................................................................................................................................................52

28. Subhash Mehta, Devarao Shivaram Trust, India.................................................................................................62

29. Groupe Interministériel sur la Sécurité Alimentaire, France.......................................................................65

30. Jean Paul Beens, Belgium..............................................................................................................................................72

31. Katy Lee, International Agri-Food Network, Italy..............................................................................................72

32. Cathleen Kneen..................................................................................................................................................................73

33. Glenn Ashton, Ekogaia Foundation, South Africa...............................................................................................74

34. Stefan Bringezu, Wuppertal Institut, Germany...................................................................................................76

35. Hans Morten Haugen, Diakonhjemmet University College, Norway.........................................................77

36. Renat Perelet, Russian Academy of Sciences, Russian Federation.............................................................78

37. CIDSE, Belgium.................................................................................................................................................................. 78

38. Lalita Bhattacharjee, FAO, Bangladesh...................................................................................................................79

39. Gitte Dyrhagen Husager, DanChurchAid, Denmark...........................................................................................81

40. Aksel Naerstad, Development Fund, Norway.......................................................................................................82

41. Helen Medina, US Council for International Business, United States of America.................................84

42. International Institute for Sustainable Development, France......................................................................85

43. Greenpeace International.............................................................................................................................................88

44. Pradip Dey, Indian Society of Soil Salinity and Water Quality, India.........................................................93

45. Institute for Agriculture and Trade Policy (IATP) and Grassroots International and International Development Exchange (IDEX), USA...............................................................................................................................93

46. Christina Blank, CFS RAI Open Ended Working Group Chair........................................................................98




Introduction to the topic

Dear Forum Members,

Investing responsibly in agriculture, and particularly in smallholder agriculture, is essential for reducing poverty, creating decent employment opportunities, enhancing food security and nutrition, and ensuring environmental sustainability. Agricultural investments can generate a wide range of developmental benefits. In order to do so, however, they need to be responsible and specifically directed towards the achievement of such benefits, while aiming at avoiding potential negative consequences.

To address these needs, the Committee on World Food Security (CFS) has launched a consultative process to develop and ensure broad ownership of principles for responsible agricultural investments (CFS-RAI). The CFS-RAI principles are expected to promote investments in agriculture that contribute to food security and nutrition, and that support the progressive realization of the right to adequate food in the context of national food security.

The principles are intended to provide practical guidance to governments, private and public investors, intergovernmental and regional organizations, civil society organizations, research organizations and universities, donors and foundations. They will be voluntary and non-binding and should be interpreted and applied in line with existing obligations under national and international law.

Consultations will be held from November 2013 to February 2014 and will include regional meetings as well as electronic consultations. The e-consultation aims to build on the feedback and input received in the regional consultations by providing an opportunity to individuals and organizations that have not yet been able to participate in the physical meetings.

All consultation outcomes will contribute to the preparation of the First Draft which will subsequently be negotiated by the CFS-RAI OEWG in Rome in May 2014. The resulting CFS-RAI principles will then be presented to the 41st Session of CFS in 2014 for endorsement by the Plenary.

We welcome your feedback on the Zero Draft following the questions below:

1. Are all relevant issues and areas related to fostering responsible agricultural investments adequately addressed in the Zero Draft? If not, what should be changed?

2. Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the principles? If not, what should be changed?

3. Does the Zero Draft achieve the desired outcome to promote investments in agriculture that contributes to food security and supports the progressive realization of the right to adequate food in the context of national food security? If not, what should be changed?

4. The principles are intended to provide practical guidance to stakeholders; therefore:

a) Are the current structure and language used clear and accessible for all relevant stakeholders to apply?



http://www.fao.org/fsnforum/sites/default/files/files/95_RAI/CFS_rai_Zero_Draft_01_August_2013_EN.pdf


b) What steps need to be taken for the CFS-RAI principles to be used and implemented by different stakeholders after endorsement by CFS?

We thank you in advance for your time and for sharing your knowledge and experiences with us.

Christina BlankCFS RAI Open Ended Working Group Chair




Contributions received

1. Paul Rigterink, Potomac Technical Advisors, United States of America


Farmers living on a small plot of land need better information and access to supplies.

For example,

Does an agriculture investment organization supply information on the right type of fertilizer, pesticide, herbicide, and seeds to use for a particular type of crop?

Does an agriculture investment organization insure that the appropriate supplies needed by a small farmer are available including tools, nursery stock, veterinary supplies, fencing, irrigation equipment, packaging, transport, marketing information, crop insurance, fertilizer, pesticides, herbicides, etc.

Without all the proper supplies and better information, small farmers will not be able to increase their cash crops and small animal production; Often they will not be able to pay back their investment if there is unusual weather. An agriculture investment organization needs to insure that all the supplies and information are available so that their investments are appropriate. This is currently not being accomplished.

2. Katy Lee, International Agri-Food Network, Italy

Dear Christina Blank,

Sincere thanks from the PSM for setting up this valuable E-consultation and the chance to give our views. It is an extremely good idea to reach out to try to get a full set of responses from stakeholders before we get into the nitty gritty of the text later in the year.

I was interested to read the comments of Mr. Rigterink - many thanks for kicking off the debate!

The Zero Draft we have seen is a good starting point but the big job now for those involved in the CFS principles is to create a document that everybody can work to and one that gets the best possible benefits from all types of investment.

As far as views from the International Agri-Food Network go, it is clear that agriculture has been undervalued for too long and all forms of investment in agriculture - public and private, foreign and domestic, small and large - will be needed to increase food production sustainably.




Investment is needed to foster food production, avoid waste, and create value added products. When it comes to assessing investments, this should take place not only at the local level but also at the national and regional level, taking into account potential food security impacts and potential trade offs. To pick up on Mr. Rigterink's points on smallholders, investments that support smallholders in moving from subsistence farming to creating surpluses are advantageous to help support food security through local, regional and international trade. On environmental impacts of investment projects, these should be assessed and measures should be taken to encourage sustainable resource use while minimizing the risk of negative impacts and mitigating them. Perhaps not stressed enough in the current draft, are the exciting and very positive prospects that investments in the transportation, storage, and handling of grains can bring. All of these things can help to minimize post harvest losses and increase overall food availability. There are many more specific aspects of the text that I could draw upon but I will throw the debate open to others for the time being! One final suggestion would be to shorten and clarify the draft, especially when it comes to roles and responsibilities. This is no doubt going to be an interesting debate when you consider all of the actors and countries involved in the CFS process, all with specific national contexts! For now, why don't we think about joining the roles and responsibilities into one section and perhaps putting it at the end? Looking forward to hearing from others. Katy

3. C.Palanivelayutham Chokkalingam, India

Dear sir,

I have read the zero draft on principles of responsible Agriculture investment.


In this topic I want to include some of the areas related to fostering responsible Agriculture investment.

1. The government organisation, or private public participation mode the investment should be focussed in the area of irrigated Agriculture. Investment towards the development of irrigation facilities, water




harvesting technologies, Drip, sprinkler irrigation, and improved agronomic practices are to be given primary importance.

2. Either private sector or ppp mode more investment are needed in the area of certified seed production which will pave the way for better production in this crop and sustainable income for Agriculture investment.

3. More investment should be added in formation of cold storage, supply chain management, retail marketing, door to door supply of farm products and value added service.

4.Future market in agriculture commodity (on line market) should be strictly prohibited for sustainable Agriculture investment.

4. Alexander Sagaydak, State University of Land Use Planning , Russian Federation

In my opinion, the Zero Draft of the RAI is a logical development of the VGGT. It establishes a comprehensive approach to responsible management of investments in agriculture. It is very important for Russia and other post-Soviet countries. As for the questions that can be answered as follows.

1. Almost all major aspects of the responsible agricultural investing are adequately described in the Zero Draft.

2. The roles, rights and responsibilities of the main parties involved in the investment process in agriculture are also described clearly.

3. The Zero Draft is quite perfect document, which I believe have a major impact on improving the efficiency of agricultural production, providing its sustainable development in the context of national food security.

4. The Zero Draft is written clearly, understandable and accessible.

I especially appreciate that the Zero Draft pays great attention to the environmental aspects of investment process in agriculture. This reveals the connection between the Zero Draft of the RAI and the VGGT.

However, in my opinion, it should be noted that investing in agriculture should be carried out on the basis of project analysis using international indicators to measure the effectiveness defined by using international accounting standards. This requirement is especially important for Russia and other post-Soviet countries. Implementation of the RAI should be started with the launch of the pilot projects in the different parts of the world. The experience should be scrutinized, disseminated and replicated.




5. Abdul Razak Ayazi, Afghanistan Embassy, Italy

I note that the four questions on which you wish to receive feedback from Permanent Representatives are not exactly the same that were posed to the Open Ended Working Group (OEWG) on 19 September, 2013. Nevertheless, I shall try to respond to all the four questions.

Question 1 : Are all relevant issues and areas related to fostering responsible agricultural investment adequately addressed in the Zero Draft? If not what should be changed?

As I understand it , the Zero Draft has a special intent, namely to elaborate the Principles that need to be observed when investment is planned for agriculture by all stakeholders. From this angle the Zero Draft adequately covers the main issues and areas in making agricultural investment responsible.

However, fostering responsible investment in agriculture at the national and local level, including for food security and nutrition, goes much beyond the 8 RAI Principles. Agricultural investment on a national scale hinges on such important consideration as macroeconomic environment, political stability, growth prospects in the sub-sectors of agriculture, suitable land and water resources, enhancing the productivity and competitiveness of agricultural commodities produced domestically, size of the internal market, choice of technology, institutional services, infrastructure, access to finance, tax and credit policies, incentives etc. At project level, the decision is based on social cost/benefit analysis in which it may prove difficult to factor in one or more of the 8 Principles into the analysis.

The notion that the eight Principles provide all the elements required for investment decision at national or project level would be an exaggeration.

Question 2 : Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the Principles? If not what should be changed?

The inclusion of a section on “Roles and Responsibilities” in part I, II and III is appreciated. The question is how detailed these role and responsibilities be spelled out. In Part I, it covers two full pages. Taking Part I, II and III together there are 35 bullet points on Roles and Responsibilities for States, 18 for Investors and 4 for others, making a total of 57 bullet points. We think that in order to avoid a shopping list, there should be few bullet points of high relevance. Given the wide range of capabilities and resource availability among states and given the diverse profile of investors, a short list will be more desirable. This is more so as RAI Principles are voluntary and non-binding as underlined on page 2 of the Zero Draft.




Question 3 : Does the Zero Draft achieve the desired outcome to promote investment in agriculture that contribute to food security and supports the progressive realization of the right to adequate food in the context of national food security? If not what should be changed?

This is a loaded question and therefore difficult to answer. The difficulty arises due to the fact that the promotion of investment in agriculture depends on several other things that are not part of RAI Principles. Therefore, I am not able to respond to this question.

Question 4 : The Principles are intended to provide practical guidance to stakeholders; therefore:

a. Are the current structure and language used clear and accessible for all relevant stakeholders to apply?

From the language point of view the Zero Draft is acceptable. With respect to structure, we have four comments to make.

First, each of the 8 Principles have bullet points, amounting to 17 bullet points for 8 Principles. Each bullet point touches on a different issue and can stand on its own. So one wonders if there are 8 or 17 Principles. We would prefer to merge the bullet points under each principle into a single concise text as was the case in the May, 2013 Session of the OEWG. It should be noted that the 7 Principles drafted jointly by FAO/IFAD/World Bank and UNCTAD at the request of G20 were also in the form of concise texts.

Second, there is considerable room for making the section on rationale for each RAI Principle crisp and short. For example, the rationale of Principle 1 could be reduced to read “Investment in agriculture and food systems contributes to the fulfillment of the four key dimensions of food security; availability, access, stability and utilization”. It is not necessary to define what food security is or explain the particulars of the four dimensions. They are well known to all stakeholders.

Third, under each Principle a number of Objectives are listed and these amount to 27 Objectives. We do not think this is the right approach because it amounts to the proliferation of RAI Objectives. We prefer that the Objectives under the 8 Principles be consolidated and shown in one place under the current title of “Objective, nature and scope” on page 1 of the Zero Draft.

Fourth, we recommend refraining of too much of subscription in the sections on Application, particularly for Principle 1 and 3.

b. What steps need to be taken for the CFS/RAI Principles to be used and implemented by different stakeholders after endorsement by CFS?

Once the Principles are approved, the next steps will be advocacy, implementation and monitoring. One would think the same route would be appropriate for RAI Principles as the one observed for VGGT, which is also voluntary and non-binding as the RAI Principles.




Advocacy should be done by all organization approving the Principles, with the three Rome-based agencies taking the lead.

The IFIs would need to internalize the RAI Principles in their investment policy for agriculture and rural development and adjust their lending and grant policies accordingly.

States should be encouraged to adjust their current legislation on domestic and foreign investment to make room for RAI Principles.

Implementation is the prerogative of the States and there is not much that CFS can do.

Monitoring the progress in the implementation of RAI Principles could be handled by CFS.

6. Botir Dosov, CACAARI, Uzbekistan

My feedbacks:


Yes, they are. Principles are well defined and formulated. Though ‘Food safety’ and ‘addressing risks emerging from food insecurity’ seen being implied in the part I, they should be highlighted in terms of existing situation and forecasting risks. I also miss the stressing on standards of accountability and reporting of food security at national level. Additionally, I found that principles are described in more generic style, but I acknowledge that this document is highlighting the ‘principles’ and does supposed to be detailed or specific. ‘Principles’ should not interpreted in multiple meaning, therefore should have shorter and wider versions. It would also be useful to readers to brief why principles are divided into groups / parts.


Yes, and not. Yes, because this document is stipulate ‘general’ principles, not a guiding ‘principles’ or framework or strategy or policy. Not, because, each case would have its own framework in kind of project or program, where actors of public and/or private sector would have different mandate and role. Additionally, each case could be different state by state. In the section “roles and responsibilities” the document states that ‘states’ are obligated…, are encouraged… . It is not clear will this assure the buy-in of principles by states and national partners.

While public and private sector is considered as horizontal dimension, a vertical dimension should also be considered, such as inter-sectoral institutions, regional and global bodies, and their roles and responsibilities.





Yes, it does, if the principles are recognized, adopted and implemented/followed by countries. I think first of all these principles should up-scaled as much as possible to make sure that they could be then out-scaled. The principles are very holistic, but still more efforts should be done in order assure ‘buy-in’ by national partners.

4. The principles are intended to provide practical guidance to stakeholders; therefore:

Are the current structure and language used clear and accessible for all relevant stakeholders to apply?

Yes, it is very clear and easy to read! But, I am not sure that all stakeholders would be communicated. An Institution in charge should be responsible for communicating the principles should be communicated to all stakeholder. The principles should be translated into local languages.

What steps need to be taken for the CFS-RAI principles to be used and implemented by different stakeholders after endorsement by CFS?

This is very critical. The principles are very holistic, but still more efforts should be done in order assure ‘buy-in’ by national partners. The CFS-RAI principles should be widely endorsed and adopted by development continuum, global initiatives and political bodies. Wide campaign should be implemented towards formal recognition of the principles by states. Global Standards on food security accounts/accounting should also be adopted globally for assuring the transparency and M&E of principles implementation. CFS-RAI principles should also be linked with MDGs.

7. Luca Chinotti, Oxfam International, Italy

Dear All,

Attached you can find some specific proposals to improve the structure as well as the wording of principles and concrete recommendations. In fact, we think that the draft 0 should be dramatically improved in order to be consistent with the agreed ToRs and ensure that the RAI contribute to achieve food security.

We hope that our contribution will be helpful in addressing major issues present in the draft 0.

http://www.fao.org/fsnforum/sites/default/files/resources/Oxfam%20input%20on%20the%20CFS%20e-consultation%20on%20the%20rai.pdf

Best regards,

Luca Chinotti







8. Rahul Goswami, Centre for Communication and Development Studies / Economic Research Foundation, India (first contribution)

Dear FSN Forum members,

My thanks to the administrators and facilitators of this subject who are guiding the consultative process. This note contains three sections. One that examines the rationale and background to the principles pertaining to 'responsible agricultural investment' (which is now referred to commonly by the 'RAI' short form); one that explains, from a point of view that is seated in a personal and regional perspective, the concepts about agricultural investment (or spending on agricultural activities) especially what are assumed and what are implied; and one that is critical of the RAI and the multi-lateral effort to find common ground with a set of principles.

(This is the first of two parts. References are included.)

1. Where the RAI has emerged from and where it may want to go

It will help if there is a willingness by the CFS to take a step back and review why we have, in 2014, a discussion about 'responsible agricultural investment' when in fact, in well balanced and thoughtful societies that are agrarian in nature, such a discussion would have been unnecessary. There is, in the prefatory material surrounding the principles up for discussion (and there is similar material to be seen for the last four years or so, over the life of this concept), a view on 'investment' and on 'responsible'. These are unlikely to be the view that one would find in a province or state, in a district or county, the majority of whose population is engaged in farming because there is undoubtedly such a variety of view about the nature of their activity. There is therefore a need to decide what degree of agnosticism can be acceptable (or tolerated, or welcomed) vis-à-vis the authority of the RAI concept. My advice is to be as realistic as possible and not turning a consultative consensus into a statement that has emerged from a deterministic process, as this shows a danger of becoming.

For that reason I would like to see in this consultation a fuller analysis of what is meant by 'investment' and by 'responsible'. That we have such concepts also means that we have conditions of irresponsible actions towards agricultural practice and agrarian societies, and that investment ought to include as thoroughly as possible a discussion about the public, social and private natures of investment. This is because investment tends to be given meanings that originate in finance and banking, in the financial and commodities markets, and from the sources of monetary and technological capital - whereas these views must not be allowed under any circumstance to dominate how the meaning of a term comes into acceptance. The investment made by generations of a community who have enriched a particular strain of traditional knowledge pertaining to the cultivation of a food staple is both implicit in the way their lives are led and implicit in their status as members of a community. In such a case (and there are fortunately still numerous such cases to be found) the term 'investment' becomes a vulgar one and is neither used nor translated.

Part of the rationale for declaring the need for RAI is the invoking of food security, of the banishment of hunger, and of the imperative to protect the biospheres while doing so. Unfortunately, the background and rationale for RAI does still not overtly and clearly enumerate what irresponsible actions or policies are when states pursue food security, seek to reduce hunger and to grow crops in ways that do not harm



http://www.fao.org/fsnforum/users/makanaka


the environment. Without clearly enumerated actions and policies that are irresponsible, it is then left to the states themselves, to private corporations and agencies, to the financial and commodity markets, to the traders and retailers, to adjudge themselves responsible (for they will not do the opposite).

The work of the CFS will be strengthened by the presence of a teleological guide to determining irresponsibility and its opposite - this goes well beyond the enunciation of principles, adherence to which comes at no loss of profit nor is it enforceable under national or local legislation. Moreover, in what way policies will be aligned with 'responsibility'? Countries produce food and biofuel stock for internal use, but also import portions of both. In what ways are 'responsible' and 'investment' defined under these circumstances (which are the circumstances demanded by a country following its World Trade Organisation 'responsibilities' as a member state of WTO)? Lacking such definitions, the CFS when considering RAI is in danger of accepting the production, distribution and consumption patterns that are commonplace in most countries because they are imposed by the 'market', but which are systemically flawed in environmental and social terms.

(Part 2 follows.)

References:Main page for Principles for Responsible Agricultural Investments - CFS-RAISummary of the international initiatives that provide guidance on responsible investment: key characteristicsComparative analysis of selected instruments on responsible investment: similarities, differences and gapsAnnotated list of international binding agreements that may have implications for the formulation of the rai principlesMatrix of Issues Covered by Related InitiativesKnowledge Exchange Platform for Responsible Agro-Investment (World Bank, FAO, UNCTAD, IFAD)Other guidelines, standard schemes or codes of conduct:Equator PrinciplesExtractive Industry Transparency Initiative (EITI)Santiago PrinciplesOECD Guidelines for Multinational EnterprisesThe Principles for Responsible Agricultural Investment (PRAI) - UNCTADReport to the G20 Development Working Group: Options for Promoting Responsible Investment in Agriculture (June 2011)Focusweb - why we oppose the principles of RAITransnational Institute - why so-called 'responsible agricultural investment' must be stoppedFarmlandgrab - We do not believe in responsible agriculture investmentOrganisations working on agrarian issues, farmers' rights, land rights, social justice and equity: Centro de Estudios para el Cambio en el Campo Mexicano (Study Centre for Change in the Mexican Countryside), FIAN International, Focus on the Global South, Friends of the Earth International, Global Campaign on Agrarian Reform, GRAIN, La Via Campesina, Land Research Action Network, Rede Social de Justiça e Direitos Humanos (Social Network for Justice and Human Rights), World Alliance of Mobile Indigenous Peoples (WAMIP), World Forum of Fisher Peoples



http://farmlandgrab.org/22454

http://www.tni.org/article/why-so-called-responsible-agricultural-investment-must-be-stopped

http://focusweb.org/content/why-we-oppose-principles-responsible-agricultural-investment-rai

http://unctad.org/sections/dite_dir/docs/diae_dir_2011-06_G20_en.pdf

http://unctad.org/sections/dite_dir/docs/diae_dir_2011-06_G20_en.pdf

http://unctad.org/en/Pages/DIAE/G-20/PRAI.aspx

https://www.responsibleagroinvestment.org/

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/Matrix_Initiatives_16_01_13.xlsx

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_RAI_Int_Binding_Agreements_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_RAI_Int_Binding_Agreements_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_RAI_Comp_Anal_Sel_Instruments_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_RAI_Comp_Anal_Sel_Instruments_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_RAI_Sum_Int_Init_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_RAI_Sum_Int_Init_EN.pdf

http://www.fao.org/cfs/cfs-home/resaginv/en/


9. Rahul Goswami, Centre for Communication and Development Studies / Economic Research Foundation, India (second contribution)


(Here follows the second of two parts. References and notes included.)

2. The idea of investment and how it influences policy

Definitions of 'responsibility' and of 'investment' are now informed from the ground. These definitions - by peasants' and farmers' groups and associations - recognise the behaviours of the many different actors who produce, handle and sell food. They are quite different in character and tone from a set of weak universal and consensual principles by being local, tied to legislation and enforceable, and whose structure and remit can be amended locally. When practiced by community and supported by local administrations, such definitions can halt the negative impacts of industrial- and 'market'-scale investments in agriculture. They can also control the irresponsibility of such investments dispossessing local communities of their land, of clear-cutting forests, sterilising the soil and polluting water.

In contrast the consultations (however well-intentioned) about RAI have little local basis and less community future. That is why they are very likely to be employed to obscure the power imbalances that exist to deepen industrial control of the means of agricultural production - and that is why these will not be acceptable as a measure of food growers' and food consumers' rights. The guiding of local responses is the need, which RAI does not recognise, and not an international or global charter that is fundamentally inapplicable to any actual food-growing region and therefore of no use.

Howsoever idealistic one or all of the eight principles in the zero draft are, to what extent will they be diluted or done away with entirely? Why should this happen? Because of the considerations of economic viability of agricultural (or land, or biotech) investment, of the expected profitability of a course of action that includes land grabs. My view is these principles will not be demonstrable in situ by any of its signatories in just the same way that market mechanisms that have been invented in the last 15 years as means to tackle serious inter-generational problems have proved (and continue to prove) to be instead mechanisms around which new industries profit.

These market inventions are the Clean Development Mechanism and the certified emission reduction schemes in all their hues which have contributed not at all to reducing CO2 and greenhouse gas emissions, Payment for Ecosystems Services which have been cynically refined recently in the form of 'nature offsets' (a gross perversion of an already destructive concept), reducing emissions from deforestation and forest degradation (REDD) which has become rather than a mitigating mechanism one through which forest-based communities are alienated from their living habitat and which has further endangered forests by financialising their benefits.

Mechanisms that have international sanction, principles that include inclusionary clauses and concepts (but which are not offered for amendment/objection to affected communities in their own languages and idiom), campaigns to promote the use of 'best practices' and to assure transparency are increasingly being invented and followed by the functionaries of monetary and finance capital. These mechanisms may accompany international trade between two countries but may also be present when internal consumption (private companies selling goods in a country, or newer forms of social welfare such as direct benefit transfers / cash transfers) takes place. These are deemed as being necessary and desirable





interventions to reduce hunger, reduce poverty, tackle inequality, increase access to service and so on, but are very likely not to result in processes and outcomes that advance the interests of project affected peoples and communities.

Investment to which a 'side-car' of moralistic mechanisms have been attached have only, in the last two decades, weakened local and indigenous control over crop choices and the uses to which primary crops are put (currently seen as raw material for an international or regional food retail industry). This phenomenon is amongst the reasons why social movements have warned (and continue to warn, more loudly than before) of a spectre of extensive dispossession and displacement of small farm producers and pastoralists [see GRAIN, 'Grabbing land for food', Seedling, January 2009]. On the other hand there also exist civil society technocracies which consider these investments as providing 'developmental' opportunities and hence they argue that the potential threat of dispossession can be mediated through internationally supervised guidelines on 'best practice', such as RAI which we are discussing.

In these circles - which includes a section of the proponents of RAI, which includes the international agricultural and crop science network (usually led by the CGIAR system in rather cozy partnerships with pliant national agricultural research systems, such as those of Brazil and India), and which includes the formidable armoury of the agbiotech industry - these land acquisitions are portrayed as a benign search for food security among countries destabilised by the world food price crisis (which shocked in 2007-08, and continued the shock from 2010-11 so that it remains current). At the same time, agriculture as being profitable enough to interest the enormously influential investments funds is now a sales pitch over five years old [see ' 'Land grabbing by foreign investors in developing countries: risks and opportunities', International Food Policy Research Institute (IFPRI) Policy Brief, 2009, and also see 'Rising Global Interest in Farmland: Can it Yield Sustainable and Equitable Benefits?', World Bank, 2011].

(A concluding part follows.)

References and notesGRAIN, 'Grabbing land for food', Seedling, January 2009' 'Land grabbing by foreign investors in developing countries: risks and opportunities', International Food Policy Research Institute (IFPRI) Policy Brief, 2009'Rising Global Interest in Farmland: Can it Yield Sustainable and Equitable Benefits?', World Bank, 2011'The global food crisis and what has capitalism to do with it', W K Tabb, International Development Economics Associates, Networkideas, 2008'Global capitalism, deflation and agrarian crisis in developing countries', U Patnaik, Journal of Agrarian Change, 2003'The resurgence of rural movements under neoliberalism', in Sam Moyo and Paris Yeros, 'Reclaiming the Land: The Resurgence of Rural Movements in Africa, Asia and Latin America', Zed Books'The Agrarian Question in the Neoliberal Era: Primitive Accumulation and the Peasantry', Utsa Patnaik and Sam Moyo, published 2011 by Pambazuka Press and the Mwalimu Nyerere Chair in Pan-African Studies, University of Dar es SalaamAn example of banking finance determining agricultural futures: Deutsche Bank"Agricultural production must double - To combat world hunger successfully, it is important to address the diverse, long term causes of underfeeding and malnutrition. The central task in agriculture involves producing higher amounts of food staples and providing additional healthy and affordable foodstuffs. Prognoses by the Food and Agriculture Organization (FAO) indicate that grain production alone will need to double by 2050 if everyone is to have enough to eat in the future.""Agriculture must change - To achieve this, we must turn our environmentally damaging industrial



https://www.db.com/cr/en/concrete-Agricultural-investments-for%20more-productivity-and-sustainability%20.htm

http://fahamubooks.org/book/?GCOI=90638100118640



http://zedbooks.co.uk/node/17105

http://zedbooks.co.uk/node/17105

http://onlinelibrary.wiley.com/journal/10.1111/(ISSN)1471-0366

http://onlinelibrary.wiley.com/journal/10.1111/(ISSN)1471-0366

http://www.networkideas.org/feathm/jul2008/ft18_Global_Food_Crisis.htm

http://www.networkideas.org/feathm/jul2008/ft18_Global_Food_Crisis.htm

http://go.worldbank.org/MJVQEKS4S0

http://www.ifpri.org/publication/land-grabbing-foreign-investors-developing-countries

http://www.ifpri.org/publication/land-grabbing-foreign-investors-developing-countries

http://www.grain.org/article/categories/19-seedling-january-2009


landscape into a food production and distribution system that is more just, more environmentally friendly and more sustainable. That calls for innovative models and new, intelligent technologies to increase productivity and efficiency. These range from irrigation systems and precision technologies to a market for sustainably produced food that models itself on consumers’ needs. We must also use resources more efficiently and waste less food."A short, representative list of 'asset managers' for whom agriculture is in 'investment class':Adveq, Allianz, Altima Partners, Barclays Capital, BlackRock, Bligh Agri, CAIA, Capital Partners Group, Ceres, Connexion Capital LLP, Cornish Consultancy, Dilworth Paxson LLP, Duxton Asset Management, ED Capital, Emergent Asset Management, Helvetica, InvestAg Savills, Kendall Court, Macquarie, Miro, Olympus Capital, Robeco, Societe Generale, Worldwide Aginvest

10. Serigne Sarr, Senegal (first contribution)

[English translation]

Hello everyone!

Land grabbing is progressing quickly and in several countries is reaching worrying proportions. We know all the reasons for this rush for the ‘green gold.’ The international markets have become more volatile and less trustworthy and the buyers of agricultural products, private companies or governments, want to ensure a stable supply. The demand for agro-fuels is growing, both in Europe and the United States and elsewhere and it is one of the main factors accelerating land grabs. In the end, all this contributes to land speculation: it is not strange that the investment funds buy large areas of land, solely in the expectation that their price will increase and without any development project.

I would like to make two comments.

- Firstly, the Voluntary Guidelines are not enough. It is also necessary that at regional level, the States combine to define the lines that may not be crossed. In particular, the right to food must be respected in full. The States will be violating the right to food if, when they are renting or selling land to investors (national or foreign), they deprive the local population of this right, of access to productive resources, essential for their livelihood. They will also do so if they negotiate sale or rental contracts without ensuring that they do not compromise food security, for example by creating dependence on foreign aid or dependence on the international markets, always unstable and unpredictable, given that a large part of the crops produced with the foreign investment will be exported to the country of the original investor or sold on international markets. It is necessary that at regional level, the States agree on a framework to protect the population against the risks of such violations. The regional level is, without doubt, the most appropriate, because the States in a region (for example, the ECOWAS or the EMUWA, see African Union) have a common interest in presenting a common posture to candidates for the acquisition of land.The African States are competing to attract investors: this should not be done at the expense of the population.

- Secondly, it is necessary to reject the ultimatum that is sometimes presented: either you accept large scale investments in agriculture or you deprive yourselves of all agricultural investment.


http://www.fao.org/fsnforum/users/emailregistrationxlxytvxrea



No. Investments are necessary. It is necessary to improve the access of small farmers to credit, to inputs and to information. It is necessary to improve the storage systems and the communication and, therefore, the access to markets. All these investments, in upstream and downstream production, do not have to impinge on land rights: they should and could leave untouched the access of users to the resources essential for their livelihoods. What is important is to guide investors towards what could best help family unit farming, for three reasons: investing in this family based farming is the best way to fight rural poverty, it supports the income of a large part of the population in rural areas, which today are too poor to buy goods and services from local producers, but which once their income increases could equally bring profit to other sectors with important multiplying effects on the local economy. In the end, family based farming is better equipped to foster diversity in the fields and to sustain ecosystems, which plays a vital role particularly given the threat posed by climate change.

This does not mean that agriculture may be neglected, because it is necessary to support it. However one cannot sustain it by destroying the peasant farmers in developing countries. Governments must understand that it is in their best interests to encourage the recovery of family based farming and that if one invests in agriculture, it is this recovery that the investments can and should help.

Nobody denies that international exchange creates winners but, it also creates losers, the men and women that are working in the least competitive sectors of the economy. As yet, developing countries do not have the redistribution mechanisms of the welfare state. And these losers, when they are small farmers, often do not have ways of mobilizing politically.

Finally, above all, the right to food must be accompanied by the democratic re-appropriation of a decision process too often taken away by a narrow elite, which exercises a disproportionate influence on political decisions while being the first to profit from the development of trades.

Yours,

[Original contribution in French]

Bonjour à tous,

l'accaparement des terres progresse rapidement et il prend dans plusieurs pays des proportions inquiétantes. Nous connaissons tous les raisons de cette ruée vers l'or vert. Les marchés internationaux sont devenus plus volatils et moins fiables et les acheteurs de produits agricoles, firmes privées ou gouvernements, veulent assurer un approvisionnement stable. La demande d'agrocarburants progresse, en Europe comme aux Etats-Unis et dans d'autres régions, et c'est un facteurs majeurs accélérant l'accaparement de terres. Enfin, tout ceci nourrit la spéculation sur les terres: il n'est pas rare que les fonds d'investissement achètent de larges surfaces de terres, simplement dans l'espoir que leur prix va monter et sans projet de développement.

Je voudrais faire deux commentaires.

-Le première commentaire est que les directives volontaires ne suffissent pas. Il faut aussi qu'au niveau régional les Etats se mettent ensemble et définissent les limites à ne pas franchir. Le droit à l'alimentation notamment doit être intégralement respecté. Les Etats porteraient atteinte au droit à l'alimentation si, en




louant ou en vendant des terres à des investisseurs (nationaux ou étrangers),ils privaient de ce fait les populations locales d'un accès à des ressources productives indispensables à leur subsistance. Ils le feraient également s'ils négociaient des contrats de vente ou de location sans s'assurer qu'ils ne compromettent pas la sécurité alimentaire, par exemple en créant une dépendance à l'égard de l'aide étrangère ou des marchés internationaux toujours instables et imprévisibles, étant donné qu'une grande partie des cultures produites dans le cadre de l'investissement étranger serait expédiée vers le pays d'origine de l'investisseur ou vendue sur les marchés internationaux. Il faut qu'au niveau régional, les Etats s'accordent sur un cadre qui protège les populations contre le risque de telles violations. Le niveau régional est sans doute le plus opportun, car les Etats d'une même région(par exemple, le CEDEAO ou l'UEMOA, voire l'Union Africaine) ont un intérêt commun à opposer aux candidats à l'acquisition de terres une position commune. Les Etats africains sont en concurrence pour attirer à eux les investisseurs: ceci ne doit pas se faire au détriment des populations.

-La deuxième commentaire, c'est qu'il faut refuser l'alternative qui nous est parfois présentée: soit vous acceptez les investissements à large échelle dans l'agriculture, soit vous vous privez de tout investissement dans l'agriculture. Non. Les investissements sont nécessaires. Il faut améliorer l'accès des petits agriculteurs au crédits, aux intrants et à l'information. Il faut améliorer les moyens de stockage et de communication, et donc l'accès au marchés. Mais tous ces investissements, en amont et en aval de la production, ne doivent pas affecter les droits à la terre: ils doivent-et ils peuvent-laisser intact l'accès des utilisateurs aux ressources indispensables à leur subsistance. Ce qui importe c'est d'orienter les investissements vers ce qui peut aider le mieux l'agriculture familiale, pour trois raisons: investir dans cette agriculture familiale, c'est le meilleur moyen de lutter contre la pauvreté rurale, c'est soutenir aussi les revenus d'une grande masse d'habitants des zones rurales, aujourd'hui trop pauvres pour acheter des biens et services aux producteurs locaux, mais qui, lorsque leurs revenus augmenteront, pourront bénéficier à ces autres secteurs également, avec d'importants effets multiplicateurs sur l'économie locale; enfin, l'agriculture familiale est mieux équipée pour favoriser la diversité dans les champs et soutenir les écosystèmes, ce qui a une fonction vitale notamment face à la menace que représente le changement climatique.

Il ne s'agit pas de négliger l'agriculture, car il faut la soutenir. Mais on ne la soutient pas en détruisant la paysannerie des pays en développement. Il faut que les gouvernements comprennent qu'il est dans leur intérêt de favoriser la relance de l'agriculture familiale, et si l'on investit dans l'agriculture, c'est à cela que les investissements peuvent et doivent servir.

Personne ne nie que l'échange international crée des gagnants, mais qu'il crée aussi des perdants, celles et ceux qu'emploient les secteurs les moins compétitifs de l'économie. Or les pays en développement ne disposent pas des mécanismes redistributifs de l'état providence. Et ces perdants, lorsqu’ils sont des petits paysans, souvent n'ont pas les moyens de se mobiliser politiquement.

Enfin, surtout, le droit à l'alimentation insiste sur la réappropriation démocratique d'un processus de décision trop souvent confisqué par une élite étroite, qui exerce une influence disproportionnée sur la décision politique en même temps qu'elle sera la première à bénéficier du développement des échanges.

Cordialement--Serigne Sarr




11. Rahul Goswami, Centre for Communication and Development Studies / Economic Research Foundation, India (third contribution)


(Here follows the conclusion based on the earlier two parts. References and notes included.)

3. A multi-lateral diversionary effort arranged around virtual goalposts

The adoption of RAI will aid, in any host country, the tailoring of all policies and strategies to fit investors (foreign and domestic, for the technological advantages are now common, as much as the conduits of capital flow for food and agriculture investment are many) so that they can be 'competitive' in the market. Instead of prioritizing a model of agricultural production where women, farmers/peasants, pastoralists and all small-scale food producers are at its core, in which agro-ecological forms of farming and raising livestock are supported, and through which local markets and economies are strengthened, the eight RAI principles listed here for discussion will if accepted legitimize policies that put the government and country at the service of such investors (both foreign and domestic, it must be noted). Moreover, from the point of view of human rights terms this is discriminatory; and will turn a parlous situation into a destabilizing one - already countries are falling short of their obligations related to realizing the right to adequate food (a foretaste of which was seen most recently during the World Trade Organization ninth ministerial conference in 2013 December which brought to the fore disagreements about governments' own procurement of food for public programmes as distorting world trade).Consider some of the examples presented to the public in recent months which are seen as exemplary of inclusive, sustainable development. An IFAD-supported project in Uganda has supported farmers who are now "able to send their children to school, pay for medical expenses and build better homes for themselves". The arrangement promoted (or facilitated) is perhaps too conveniently called "the type of public-private partnership that we need to see throughout Africa, with government, the private sector, civil society and smallholders all benefiting from working in partnership".

However, behind these homogenous labels are partners whose outlook and imperatives are usually contradictory, are often in competition and inimical to one another - realities in the districts and counties can be brutally but not surprisingly different from the umbrella assessments made at the regional level of international agencies. The manner in which these sharp-edged realities find voice is, for example, in the following way - "as investment in rural Africa grows, we must ensure that there are mutually beneficial partnerships between smallholders and other private sector investors. These can take many forms, including out-grower schemes, contract farming or joint share equity schemes" - here again investment is the locus of activity and outcomes, but self-determination and there is no giving way to any alternate conceptualization of an agrarian economy.

Less sophisticated in manner is this announcement concerning Ethiopia: "A new agency responsible for large-scale agricultural investments was officially launched two weeks ago.The Agriculture Investment Agency (AIA) was set up to oversee large-scale and mechanised agricultural investment on land belonging to the Ministry Land Bank. Its aim is to boost investment in agriculture." Blunt and to-the-point (when viewed on an interested investor's screen). Can we imagine that the eight proposed principles will, in any fashion or form, temper the ambitions of either the invited investors or the local actors in Ethiopia who have established this new agency? I would flatly say 'no'. Likewise, the Department of Foreign Affairs, Trade and Development of Canada has advocated "increasing private investment in Africa's agriculture sector will help lift millions of people in sub-Saharan Africa out of poverty. Canada is



http://www.acdi-cida.gc.ca/acdi-cida/acdi-cida.nsf/eng/FRA-6874617-FTG



http://www.capitalethiopia.com/index.php?option=com_content&view=article&id=3445:new-agriculture-agency-to-govern-federal-investment-&catid=54:news&Itemid=27



http://www.ifad.org/events/op/2013/ticad.htm





taking a leadership role, on behalf of G-8 countries, to support Senegal in joining the New Alliance for Food Security and Nutrition ... "

Moreover, governments supporting - via departments of trade, foreign ministries, alliances of industry networks and through a complex matrix of subventions - the private sector of their countries investing in the South (the erstwhile Third World, or "developing" countries or "emerging" economies) see agriculture as "a complex and risky undertaking; for that reason, many private firms don't feel comfortable investing in African agriculture as opposed to other economic opportunities". That is why, about two years ago, the New Alliance for Food Security and Nutrition, was said to have "leveraged" US $3 billion in private investment which USAID promised would be the beginning of the "much greater investment that Africa needs to achieve the growth targets of the African Union" - and of course to reduce poverty.These perspectives help dispel some of the fog, but principles such as RAI (and all multilaterally promoted 'voluntary guidelines' concerning land, water or forests, for example) cannot encompass in any meaningful way the alliances being formed - involving government, business, technology and finance capital - which have blurred the boundaries between primary crop that becomes food, animal feed and biofuels in what are now called vertically integrated agribusinesses.

To illustrate, the Indonesian palm oil trade is dominated by Cargill, ADM-KuckWilmar (the world's largest biofuels manufacturer), and Synergy Drive, a large Malaysian government company. This co-exists - particularly in finance capital terms - with both an 'ethanol alliance' involving the USA, Brazil and Argentina, and a sugar-soya alliance that brings together (often uncomfortably) India, China, Mozambique and South Africa in new production enterprises backed by European Union and American subsidies and trade preferences. Are they 'Northern' acquirers of 'Southern' agri-lands? That is too simplistic, for there are powerful South-South alliances, and a web of relationships between Northern and Southern actors, both public and private (including local elites and politicians). [See 'The new enclosures: critical perspectives on corporate land deals', The Journal of Peasant Studies (July-October 2012), by Ben White, Saturnino M. Borras Jr., Ruth Hall, Ian Scoones and Wendy Wolford.]

We have tied 'land' to being 'responsible', however the transfer of resources through extra-economic coercion or non-market mechanisms is equally prevalent. This is an issue that lies outside principles, commitments and voluntary guidelines because included here are mechanisms (other than outright violence) of expropriation such as cynical manipulation of the public debt, the exploitation of the designed biases in the international credit system, financial speculation, stock-exchange gambling (what has also been called 'casino capitalism'), restrictive practices in market transactions inclusive of price manipulation, and the like.

The powerful combination of multinational corporate alliances, biotechnology, bilateral trade agreements, commodities markets and exchanges, asset managing companies, banks and financial institutions, political classes in league with industry, and the retail food industry have foisted upon us an unnatural vocabulary. Hence we are led, quite unnecessarily, to fit the kaleidoscopic cultures of small cultivation into grey bins labelled 'investment', 'competitiveness', 'logistics', 'supply / value chain', 'efficiency' and so on. Textbook business school blather assumes oracular weight and an agribusiness-oriented vision for agriculture, with large-scale (or technologically-empowered farms at the core), even if linked through "outgrower" schemes to smallholders, is one that some see as the logical and inevitable extension of global capital into rural economies. This readymade argument has been adopted by national governments, investors and (unfortunately, some) donor agencies alike.



http://blog.usaid.gov/2012/08/investing-in-africas-smallholder-farmers/




Hence, concerning the questions raised for this consultation:Q1. Are all relevant issues and areas ...A. No longer a consideration as I advocate without reservation, condition or alternative the complete scrapping of the RAI.Q2. Are the roles and responsibilities of relevant stakeholders ...A. These are done locally and any international set of principles does not supercede local agreement in all its variations.Q3. Does the Zero Draft achieve the desired outcome to promote investments ...A. Does not arise as I advocate without reservation, condition or alternative the complete scrapping of the RAI.Q4. The principles are intended to provide practical guidance ... current structure and language ... principles to be used and implemented by different stakeholders ...A. The principles may or may not be acceptable to communities, which - as we have seen for a century now in the case of indigenous peoples and tribes, first nations and aborginal populations, who have drafted, enacted and implemented their own natural resource protection laws and exercise sovereignty - are very competent in defining their codes and (if required complementary legislations).

What else if not RAI? What I have outlined in the two preceding parts of this contribution and in this conclusion are the adverse outcomes of the market-driven neoliberal paradigm that has fostered what since 2007 we call the food crisis (itself a meta text for linked crises such as dispossession, urbanization and concomitant migration, the feminization of agriculture, the volatility in cost of cultivation and retail food prices both, the loss of agro-biodiversity, and a host of others). However, in the South there are many experiments with more development-driven local and community institutions that provide morally acceptable and culturally sound alternatives.

References and notes

'The agrarian question', volumes I and II, Karl Kautsky, Zwan Publications, 1988'Summary of selected parts of Kautsky's The Agrarian Question', Jairus Banaji, Economy and Society, 1976'Power, property rights and the issue of land reform: A general case illustrated with reference to Bangladesh', M H Khan, Journal of Agrarian Change, 2004'The land question: Special economic zones and the political economy of dispossession in India', M Levien, The Journal of Peasant Studies, 2012'The new enclosures: critical perspectives on corporate land deals', Ben White, Saturnino M. Borras Jr., Ruth Hall, Ian Scoones and Wendy Wolford, The Journal of Peasant Studies, July-October 2012"In the study area (and Bangladesh generally), land grabs by foreign governments and transnational agencies have not been particularly significant compared to those by domestic corporations, private interest groups and state agencies. However, alienation of land has been indirectly influenced by factors at the global level, inclusive of policy and development interventions promoted by international financial and donor agencies." - 'Land grabs and primitive accumulation in deltaic Bangladesh: interactions between neoliberal globalisation, state interventions, power relations and peasant resistance', by Shapan Adnan, The Journal of Peasant Studies, 2013"In recent years the government of Laos has provided many foreign investors with large-scale economic land concessions to develop plantations. Many have lost their agricultural and forest lands, or conditions of production, making it difficult to maintain their former semi-subsistence livelihoods, and thus compelling many to take up employment on the same plantations that displaced them, despite frequently having to work for low wages and under poor conditions." - 'Turning Land into Capital, Turning People into Labour:




Primitive Accumulation and the Arrival of Large-Scale Economic Land Concessions in the Lao People's Democratic Republic', by Ian G Baird, New Proposals: Journal of Marxism and Interdisciplinary Inquiry, November 2011Agri-business corporations involved either with the New Alliance for Food Security and Nutrition and/or are World Economic Forum partners:AGCO Corporation, Anheuser-Busch InBev, Archer Daniels Midland, BASF, Bunge Limited, Cargill, Carlsberg Group, Coca-Cola, Diageo, DuPont, Ecolab, General Mills, Heineken, Kirin Holdings, Kraft Foods, Metro AG, Mondelez International, Monsanto Company, Nestlé SA, Orkla, PepsiCo, SABMiller, Sinar Mas, Syngenta Crop Protection AG, The Coca-Cola Company, The Mosaic Company, Unilever, Wal-Mart, Yara International, Yum! Brands, Zhangzidao Group

12. Serigne Sarr, Senegal (second contribution)


The V0 version outlines the development and contents of the final document. It presents the roadmap to be followed as the work progresses. It is important to refer to certain experiences of countries in relation to the updating of small farming, in particular in Latin American countries (Brazil and Mexico), Korea, in Asia and Morocco in Africa. In the latter case, the framework of the Plan Maroc Vert [Plan for a Green Morocco] was established, in particular the Second Pillar, which concerns with small farming and how to strengthen and take forward this type of agriculture.

In general, it is important to establish a specific approach in order to manage these investments in small farming. This kind of farmer usually lacks training on financial aspects but has good technical know-how.

1. For the first question raised, it is relevant to mention the importance of external investments and how to attract providers of funds to small farming to invest in ventures little known at world level (niche markets) especially in origin-denominated products.

2. For the second question, the role and rights of each party are defined. But the main question is the implementation of these commitments.

3. For the third question, it is difficult to say that V0 has really reached its objective without truly having the parties (the countries) accepting the model proposed as well as the small farmers (targeted population), and how the small farmers profit from this opportunity, improve their standard of living and ensure a certain level of food, in quantity and quality.

4. It is clear that the draft is written in a simple style accessible to the recipients.


La libéralisation commerciale est généralement présentée comme un facteur de développement par le gain d'efficience que représente, pour chacun des pays concernés, une meilleure allocation de leurs


http://www.fao.org/fsnforum/users/emailregistrationxlxytvxrea



facteurs productifs, en fonction de leur avantage comparatif. Mais nous sommes nombreux à penser que l'agriculture n'est pas un secteur comme les autres. Pour beaucoup de pays en développement, il fait encore vivre une grande majorité de la population. Or cette agriculture est fragile: elle a souvent été négligée par les gouvernements, en même temps qu'elle a du notamment par des subsides importants. Le choc de la concurrence risque de lui être fatale si elle n'a pas les moyens de se protéger. En outre, les producteurs agricoles ne peuvent pas répondre aux signaux des prix-réorienter leur production en fonction de la demande-comme dans d'autres domaines: cela demande des conditions adéquates, cela demande des soutiens publics, et cela suppose que l'on détache l'activité agricole de la culture dont elle fait souvent partie intégrante pour les populations qui la pratiquent. Enfin, au sein même du monde agricole, le crible de la concurrence internationale risque de conduire à une dualisation forte: les plus grands producteurs-les plus mécanisés, qui ont les meilleurs les meilleurs terres et le meilleur accès au crédit et aux infrastructures-survivront et peut-être verront même s'accroitre leur part dans la production totale, alors que les plus petits paysans pourront être laminés. Or l'agriculture la plus "compétitive" en ce sens c’est-à-dire la mieux capable de répondre aux impératifs de l'agriculture "low cost" qu'on nous prépare n'est pas nécessairement la plus souhaitable. Car c'est elle qui contribue le moins au développement rural et à la création d'emplois, et qui et qui produit les couts sociaux et environnementaux les plus élevés.

C'est pourquoi, avant la conclusion d'un accord de libre-échange, il est essentiel d'étudier les impacts sur les droits de l'homme des différents groupes au sein de la population concernée: après, il risque d'être trop tard. Les études d'impacts visent à attirer l'attention-celle des gouvernements, et celles surtout de la société civile et des parlements nationaux qui contrôlent les gouvernements-,sur la situation des plus vulnérables, dont la situation peut encore s'aggraver même si les indicateurs macro-économiques-PIB ou revenus d'exportations pour le pays dans son ensemble-progressent.

Le droit à l'alimentation peut constituer un outil d'analyse puissant des impacts de la libéralisation commerciale. Il met l'accent sur les inégalités, et non seulement sur les gains d'efficience. Il s'intéresse aux groupes les plus vulnérables, et non uniquement aux valeurs agrégées. Il conduit à interroger si les évolutions qu'amène le développement du commerce international sont durables, ou bien si elles augmentent la vulnérabilité aux chocs des pays qui misent tout sur lui.

13. Manuel Castrillo, Proyecto Camino Verde, Costa Rica


Of course, aiming to establish principles and lines of action for states, companies and individuals involved in responsible agriculture (and "supportive" I would add) is praiseworthy. We are aligned with most of the actions and tasks to be developed, but assuming that certain stakeholders will actually implement them without clear international treaties or laws featuring certain type of incentive or commitment would be quite naive. Furthermore, most of managers of companies and corporations –and of states- have no real interest in creating fair conditions for land management and facilities for vulnerable groups such as women or ethnic minorities. Moreover, although there are currently no legal and policy instruments seeking many of the goals outlined in the principles, there has been no "willingness" to create those conditions. I quote:




The principles will be voluntary and non-binding and should be interpreted and applied in a way which is consistent with existing obligations under national and international law, and with due regard to voluntary commitments under applicable regional and international instruments. They should be interpreted and applied in accordance with national legal systems and their institutions.

Therefore, it is a blend of requests and desires raised by many people long time ago. In this respect, I ask: is in these scenarios where we should seek the change? Contemporary societies continue pursuing a balance that achieves equity for all. We cannot formulate absolute goals as we well know. Multinational agencies should strengthen the universal principles at national level for their subsequent integration into regional and global levels. With democratic, caring and cooperative nations in which citizens’ interests are aligned with the ones of its neighbours and fellows, there will be a broad range of possibilities for responsible investment in agriculture and other fields. We know that consumption patterns generated by “excessive” ambition lead to speculation and hoarding, exploitation and injustice. Paradigm shifts do not only take place at economic level, but also in the spiritual roots of human beings. Achieving this transformation is the challenge, the rest will come in addition. While this happens, we must move on acting beyond the expected and continuously improving our activities. We must have hope as many people are in need of it.

Greetings to all.

[Original comment in Spanish]

Bueno, es loable por supuesto pretender el establecer principios y vías de acción de estados y empresas e individuos en la agricultura de manera responsable y " solidaria " agregaría. Estamos de acuerdo en la mayoría de acciones y tareas a desarrollar, más resulta un poco ingenuo creer que sin tratados o leyes internacionales claras con algún tipo de incentivo o compromiso, ciertos actores , las realizarán. Aún más, muchos de los líderes de empresas y corporaciones - y estados-, no tienen interés real en crear condiciones justas para el ordenamiento de territorios y facilidades para sectores vulnerables como las mujeres o minorías étnicas. Además, a pesar de que actualmente hay instrumentos jurídicos y políticos que buscan muchos de los objetivos planteados en los principios no a habido "voluntad "para crear esas condiciones. Copio textualmente:

Los principios, que son voluntarios y no vinculantes, deberían interpretarse y aplicarse de conformidad con las obligaciones expresadas en el derecho nacional e internacional, y teniendo en la debida consideración los compromisos voluntarios asumidos en virtud de los instrumentos regionales e internacionales aplicables. Deberían interpretarse y aplicarse en consonancia con los sistemas jurídicos nacionales y con sus instituciones.

Es pues, un reflujo de instancias y deseos planteados hace mucho y por muchos. Planteo: es en estos escenarios dónde debemos buscar el cambio ? Las sociedades contemporáneas siguen persiguiendo un equilibrio y balance que logre la equidad para todos. No podemos plantearnos absolutos, y lo sabemos. Los organismos multinacionales deben buscar fortalecer los principios universales en la esferas nacionales, para buscarla integración regional y luego global. Partir de hechos en naciones con fundamentos democráticos, solidarios y de cooperación, dónde los ciudadanos, coincidan con los intereses del prójimo, de su vecino, de su conciudadano, nos permitirá abrir un ábanico de posibilidades para poner en práctica una inversión responsable en la agricultura y otros campos. Sabemos que los




patrones de consumo, generados por la ambición " desmedida ", nos llevan a especulación y acaparamiento, explotación e injusticias. Los cambios de paradigma no solo se dan en lo económico, sino en la simiente espiritual del ser humano. Lograr ésta transformación es el reto, lo demás vendrá por añadidura. Mientras esto acaece, debemos seguir adelante con llevar a la acción mucho de lo que ya está planteado, perfeccionarlo. Debe haber esperanza, pues muchos la necesitan. Saludos a todos.


Of course, aiming to establish principles and lines of action for states, companies and individuals involved in responsible agriculture (and "supportive" I would add) is praiseworthy. We are aligned with most of the actions and tasks to be developed, but assuming that certain stakeholders will actually implement them without clear international treaties or laws featuring certain type of incentive or commitment would be quite naive. Furthermore, most of managers of companies and corporations –and of states- have no real interest in creating fair conditions for land management and facilities for vulnerable groups such as women or ethnic minorities. Moreover, although there are currently no legal and policy instruments seeking many of the goals outlined in the principles, there has been no "willingness" to create those conditions. I quote:

The principles will be voluntary and non-binding and should be interpreted and applied in a way which is consistent with existing obligations under national and international law, and with due regard to voluntary commitments under applicable regional and international instruments. They should be interpreted and applied in accordance with national legal systems and their institutions.

Therefore, it is a blend of requests and desires raised by many people long time ago. In this respect, I ask: is in these scenarios where we should seek the change? Contemporary societies continue pursuing a balance that achieves equity for all. We cannot formulate absolute goals as we well know. Multinational agencies should strengthen the universal principles at national level for their subsequent integration into regional and global levels. With democratic, caring and cooperative nations in which citizens’ interests are aligned with the ones of its neighbours and fellows, there will be a broad range of possibilities for responsible investment in agriculture and other fields. We know that consumption patterns generated by “excessive” ambition lead to speculation and hoarding, exploitation and injustice. Paradigm shifts do not only take place at economic level, but also in the spiritual roots of human beings. Achieving this transformation is the challenge, the rest will come in addition. While this happens, we must move on acting beyond the expected and continuously improving our activities. We must have hope as many people are in need of it.

Greetings to all.

14. Said Zarouali, Haut Commissariat au Plan, Morocco


The V0 version outlines the development and contents of the final document. It presents the roadmap to be followed as the work progresses. It is important to refer to certain experiences of countries in relation to the updating of small farming, in particular in Latin American countries (Brazil and Mexico), Korea, in




Asia and Morocco in Africa. In the latter case, the framework of the Plan Maroc Vert [Plan for a Green Morocco] was established, in particular the Second Pillar, which concerns with small farming and how to strengthen and take forward this type of agriculture.

In general, it is important to establish a specific approach in order to manage these investments in small farming. This kind of farmer usually lacks training on financial aspects but has good technical know-how.

1. For the first question raised, it is relevant to mention the importance of external investments and how to attract providers of funds to small farming to invest in ventures little known at world level (niche markets) especially in origin-denominated products.

2. For the second question, the role and rights of each party are defined. But the main question is the implementation of these commitments.

3. For the third question, it is difficult to say that V0 has really reached its objective without truly having the parties (the countries) accepting the model proposed as well as the small farmers (targeted population), and how the small farmers profit from this opportunity, improve their standard of living and ensure a certain level of food, in quantity and quality.

4. It is clear that the draft is written in a simple style accessible to the recipients.

[Original in French]

La version V0 trace les grandes lignes de la démarche et le contenue du document final, elle présente la feuille de route à suivre au fur et à mesure d'avancement du travail. il est important de citer quelques expériences des pays dans le domaine de la mise à niveau de la petite agriculture, notamment dans les pays de l’Amérique latine (Mexique et Brésil), la Corée en Asie et le Maroc en Afrique. Pour ce dernier cas, dans le cadre du Plan Maroc Vert notamment le pilier II, dédié à la petite agriculture, et comment faire pour renforcer et aller en avant de ce type d'agriculture.

En général, il est important d'établir une approche spécifique pour gérer ces investissements dans la petite agriculture. Ce type d'agriculteur, en général, manquent de formation concernant le coté financière mais ils ont un bon savoir faire technique.

1- Pour la première question posée, il est important de soulever le poids des investissements extérieurs, et comment faire pour attirer les bailleurs des fonds vers la petite agriculture et investir dans des spéculation mal connu à l’échelle mondiale (niches) sur tout dans les produits de terroir.

2- Pour la deuxième question, le rôle et les droits de chaque partie sont définis. Mais la grande question c'est la mise en œuvre de ces engagements.

3- Pour la troisième question, il est difficile de dire que la V0 a bien atteint son objectif, sans avoir vraiment que les parties (les pays) accepter le modèle proposé ainsi que les payants (population ciblé). Et comment le petits agriculteur profite de cet opportunité et améliore son niveau de vie et assure un niveau d'alimentation en quantité et en qualité.

4- Il est claire que le projet est rédigé d'un style simple et à la porté des destinataires.




15. Christine Andela, Cameroon


My contribution

Principle 1 : it is necessary to focus on access to production factors, land and water in particular, for women and youth.

Principle 2 : a responsible investment respects legitimate land rights and ensures that holders of such rights will not be deprived: this formulation is weak and can lead to incorrect behavior especially where there are no legitimate land rights but family or community rights. A responsible investment has to know and respect land rights of individuals, territories and communities.

Principle 3 : to support sustainable use, development and regeneration of natural resources, specifically soil, water and biodiversity, first it is necessary to understand soils, to ensure its health; this is something that investments do not usually do.


Ma contribution

Principe 1 : il faut se concentrer sur l’accès aux facteurs de production - notamment la terre et l’eau - par les femmes et les jeunes

Principe 2 : Un investissement responsable respecte les droits fonciers légitimes et garantit que les titulaires de ces droits n'en seront pas dépossédés : cette formulation est faible et peut conduire à des errements surtout dans des régimes où il n’ya justement pas de droits fonciers légitimes mais des droits fonciers familiaux et/ou communautaire. un investissement responsable doit connaître et respecter les droits fonciers des individus , des territoires et des communautés

Principe 3 : pour favoriser une utilisation, un développement et une régénération durables des ressources naturelles, notamment les sols, l'eau et la biodiversité il faut d’abord comprendre les sols, pour s’assurer de la santé végétale ce que les investisseurs ne font pas généralement

Mrs Christine ANDELACOSADER and National Alliance against HungerFood policy and aid strategiesCOORDINATOR In ChiefPLANOSCAM representative

16. International Food Security Network




Dear members of the FSN Forum Team

Greetings from Dhaka.

We are happy to submit our comments on the zero draft of the Principles for Responsible Agricultural Investments (RAI) [below and linked here]

The document is based on the discussions organized by our national and regional networks of multi-stakeholders – peasants, fisherfolks, forest dwellers, women, indigenous people, landless farmers, from more than 31 southern countries of Asia, Africa and Americas. This also reflects our position on the present draft.

We hope this will contribute the ongoing discussions on this extremely important work.

For any further query and communication, please contact:

Alberta Guerra, Food Policy Advisor, IFSNAFM Shahidur Rahman, Global Coordinator, IFSN

Warmly

IFSN1 COMMENTS ON ZERO DRAFTOFTHE CFS - RESPONSIBLE AGRICULTURE INVESTMENT2 (RAI)

SUMMARY

IFSN strongly urges the CFS-rai to focus not just on the path towards food and nutrition security, but also food sovereignty. The CFS-rai must bring to the fore the role of small-scale food producers in championing agroecological approaches that support local food systems, which are socially just and ecologically sound, and in line with the national-level strategies towards the progressive realization of the right to food. This position stems from the understanding that food and agriculture are inseparable from the sociocultural, not just economic, continuity of rural lives and livelihoods, and hence investment in agriculture that primarily focuses on profits, corporate interests, and finance capital above all else is inadequate and irresponsible.

INTERNATIONAL FOOD SECURITY NETWORK (IFSN)

1 International Food Security Network

2 This document presents the position of the IFSN on the Zero Draft of the CFS-RAI, based on the consolidated comments on responsible agricultural investments received from its members.



http://www.fao.org/fsnforum/sites/default/files/resources/IFSN_Position_RAI.docx


IFSN i.e. International Food Security Network - a partnership of 1100+ civil society organizations (CSOs) from 31 countries across continents – strives to strengthen its regional food security networks to ensure food and nutritional security in southern countries. The network promotes south-south dialogues and knowledge dissemination and aims at influencing policies and programmes for increased food security at national, regional and international level. Six regional networks and twenty six national networks spanning across the globe form the core of IFSN with ActionAid International in the lead. The network - since its inception in 2004 - has been co-funded by the European Commission.

IFSN contacts for further information:Shahidur RahmanGlobal Coordinator, International Food Security Network (IFSN)[email protected] Guerra Food Policy Advisor, International Food Security Network (IFSN)[email protected]

CFS-RAI

The Committee on World Food Security (CFS)’ consultative process on the principles for responsible agricultural investment in the context of food security and nutrition (rai) stems from the limitations of the Principles of Responsible Agricultural Investment (PRAI) jointly developed by FAO, IFAD, UNCTAD and the World Bank. During the CFS in 2010, civil society actors blocked the endorsement of the PRAI on the basis that they were not developed through a participatory process including those who are most affected by investments on the ground, and that they do not necessarily safeguard against the “grabbing” of land and other natural resources, on which the local populations depend on for their livelihoods. In response the CFS-rai was initiated in 2012, and through a broad and inclusive consultative process, the final principles are to be endorsed by the CFS Member States in October 2014.

DEFINING THE PARAMETERS OF “RESPONSIBLE INVESTMENT”

WHAT KIND OF AGRICULTURAL ‘INVESTMENT?’

To IFSN, agricultural investments – whether public, private and/ or in the form of public-private partnership – are avenues through which food sovereignty can be realized. If governed, implemented, and monitored in ways that are in line with the visions of small-scale food producers, agricultural investments can support the socio-ecological sustainability and resilience of small-scale farming and local food systems. At the same time, they serve as platforms through which states can meet their obligations for the progressive realization of the right to adequate food.

IFSN recognizes 2.5 billion small-scale food producers worldwide as key investors in their local food systems. Accordingly, it recognizes their rights and agency to define and design their own food systems that are ecologically sustainable, and based on their cultural history, heritage, and knowledge. In turn, public investments and policies should foster the potential of small-scale food producers, before serving




the interests of corporations. States should also strengthen their legal institutions and regulatory frameworks to protect the right to food, and to guide, manage, and evaluate investment practices. The private sector should work together with the former to promote agricultural development that is fair and just.

WHAT COUNTS AS “RESPONSIBLE” INVESTMENT?

To IFSN, agricultural investments are deemed responsible when their processes and practices are:

1. Regulated by the state, so that they contribute to the progressive realization of the right to adequate food;

2. Grounded in international human rights laws and standards, including the right to free, prior, and informed consent (FPIC), the right to refuse unjust investment, and the right not to be deprived of their means of subsistence;

3. Accompanied by ex-ante human rights, socio-economic, and gender impact assessments;4. Cognizant of small-scale food producers as key investors in their local food systems, and

supportive of farmers’ organizations, cooperatives, and a variety of small and medium enterprises (SMEs).

5. Geared towards strengthening small-scale food producers’ access to a full range of financial services that are adapted to their needs, taking into account the particular challenges faced by women and youth;

6. Focused on agroecological approaches, and are deliberately planned with and accountable to small-scale food producers, as opposed to conventional industrial agriculture which serves corporate interests and profits;

7. Guided by ethics, and adhere to social and environmental sustainability, and international labour standards;

8. Not in violation of the rights of subsistence, and do not result in the “large-scale transfer of tenure rights to investors” as per Section 12.6 of the Voluntary Guidelines on the responsible governance of tenure of land, fisheries, and forests in the context of national food security (VGGT);

9. Participatory and do not exclude certain types of food producers based on their gender, sexual orientation, class, ethnicity, race, age, and disability; and

10. Monitored and evaluated for their compliance to the VGGT and the rai principles by state regulatory bodies AND civil society organizations.

While IFSN appreciates the Zero Draft as the starting point of an inclusive consultative process on the CFS-rai, there a number of interrelated gaps in the current version, which are outlined below:

1. Weak emphasis on the link between responsible agricultural investment and the right to food

The five short introductory paragraphs to the Zero Draft do not do justice to the background and rationale of the CFS-rai. The first paragraph alludes to the Malthusian notions of overpopulation, and the pressure of population growth on the environment, as well as changing consumption patterns in urban areas. Strangely, it does not build any connections to the second paragraph, which focuses on hunger and




malnutrition, and the role of agricultural investments in reducing them. Nor does the second paragraph address the structural causes of food insecurity before jumping to solutions.

Instead, the CFS-rai should begin with a clear and explicit recognition of the right to food, and the need for responsible agriculture investments that support the states’ efforts to comply fully with their human rights obligations. Without articulating the right to food at the outset, the CFS-rai overlooks the essential dimension of state accountability to its people. The right to food is not about charity, or merely reducing hunger and malnutrition through increased agricultural productivity. It is about protecting the right of all human beings to live and to feed themselves in dignity, and empowering small-scale food producers to meet their sustenance needs and to design their own food systems. In other words, the right to food cannot be realized by agricultural investments that focus on increasing the food supply alone, but also on improving food access, adequacy and stability (FAO 2006).

Box 1. Responsible public investment and policies in agriculture and the right to food – BrazilThe Zero Hunger (Fome Zero) programme, launched in 2003 is the most far-reaching food security initiative in Brazil. It started as a programme to fight hunger, but has progressively broadened to protect the right to food. Zero Hunger now involves 53 initiatives implemented by 11 different ministries and comprises four main issues: access to food; stimulating small-scale farming; income generation; and partnership promotion and civil society mobilization.

A key initiative of Zero Hunger is the National School Feeding Programme, which provides 47 million free meals a day at public schools to students aged up to 18. The Lula administration also created the Food Procurement Program (PAA) in 2003 to purchase food from small-scale farmers at fair prices, and to distribute them to schools, hospitals, and other families suffering from extreme food insecurity.

In 2006, a law was enacted to establish the National Food and Nutritional Security System (SISAN) and to reinstate the National Council on Food and Nutrition Security (CONSEA) to ensure the active participation of civil society in drafting policy recommendations to the government. Through Zero Hunger, the Brazilian government improved the coordination of policies around food and agriculture, as well as the accountability of agencies responsible for implementing its various programmes. The government also set up an interministerial taskforce that would develop a national policy on food and nutrition security.

The UN Special Rapporteur on the Right to Food notes that Brazil has made “remarkable progress in the realization of the right to food” (De Schutter 2009: 21) under the Zero Hunger programme, and that the country's success in combating hunger and malnutrition “bears witness to the contribution that such participatory strategies can make” (Ibid.: 16).

Further reading:IFSN. 2011. Success in Reducing Hunger: Lessons from India, Malawi, and Brazil. Dhaka: IFSN.Da Silva, J. G. 2009. “Zero Hunger and Territories of Citizenship: Promoting Food Security in Brazil's Rural Areas.” Pp. 367-374 in The Poorest and Hungry: Assessments, analyses, and actions: An IFPRI 2020 book, edited by J. von Braun, J., R. V. Hill, and R. Pandya-Lorch. Washington D.C.: IFPRI.

2. Definitional ambiguity on key terms, and how “responsibility” will be monitored and evaluated




The Zero Draft does not provide definitional clarity on “investment” – i.e. what type and form of investment, by whom, for whom, and for what purposes. More significantly, the eight principles outlined in the Zero Draft seem to assume a universal understanding of what is considered “responsible” investment, and does not clarify to whom the accountability falls. At the same time, it fails to provide how “responsibility” will be monitored and evaluated not only during the early stages of investments (involving consultations, negotiations, project design, impact assessments, and etc.), but also during implementation stages. For instance, are investments that claim to improve food security and support sustainable agricultural practices on paper, but in reality results in the dispossession of the current occupants/users of land deemed responsible? What are the mechanisms to monitor and evaluate their implementation and the implications for agricultural development, food and nutrition security, and rural poverty? When considering the fact that the majority of contemporary agricultural investments and land deals claim to be vital opportunities for development, the murky language of the CFS-rai can be easily exploited by powerful state and capital interests as loopholes to enclose lands and to displace and dispossess local populations. The rai principles should provide definitional clarity on what type and form of investment, by whom, for whom, and for what purposes can be considered responsible. The principles should also clarify to whom accountability falls, and how “responsibility” will be monitored and evaluated not only during the early stages of investments but also during implementation stages.

3. Lack of recognition of the (dispossessing) reality of agricultural investments and the need for policy coherence

In order to provide specific qualifications for what is considered responsible investment, the CFS-rai must be based on concrete evidence. In other words, the rationale and objectives described under each principle must be supplemented by on-the-ground evidence, wherever possible. Otherwise, the principles remain abstract, hollow, and impractical. For instance, nowhere in the Zero Draft is there a mention of forced population displacements and involuntary resettlement that may result from responsible/irresponsible investments. Nor does it discuss how the rai will be harmonized or reconciled with other policy mechanisms on involuntary resettlement. For example, while the VGGT suggests that agricultural production and investment practices should “not result in large-scale transfer of tenure rights to investors, and should encourage partnerships with local tenure rights holders” (Section 12.6), the operational policies on involuntary resettlement adopted by international financial institutions (IFIs), for instance the World Bank Operational Manual 4.12, and the International Finance Corporation (IFC) Performance Standard 5, treat population displacement as an unavoidable byproduct or externalities of development/investment practices (see Pearce 1999). Considering such contradictory objectives of policy frameworks surrounding agricultural investments, the rai principles should set the highest human rights based standards for investments that other policy instruments should align to and be coherent with.

4. No safeguards to prevent exploitative contract farming arrangements and the their impacts on food security and gender equity




Principle 2 of the CFS-rai refers to “decent job creation and equitable generation of local employment,” without defining what qualifies as decent work, or anticipating the type and conditions of jobs that may emerge from agricultural investments. Of particular concern to IFSN is the absence of discussion on contract farming, which has expanded in all regions of the world under corporate agriculture (UNCTAD 2009; IFSN et al. 2011; Prowse 2012). In fact, over 30% of soya in Brazil, 90% of cotton and fresh milk in Vietnam, and about 60% of tea and sugar in Kenya are now produced under contract farming arrangements (UNCTAD 2009). It has also been noted that contemporary large-scale agricultural investments often entail both plantations and outgrower schemes, particularly among biofuel initiatives (Cotula et al. 2009; Deininger et al. 2011).

While there are different business models, contract farming has largely been criticized as a labour regime replete with exploitations, manipulations, and abrogation of contracts due to the unequal power relations between contracting parties (Little and Watts 1994). Particularly in buyer-driven models, small-scale contract farmers’ lack of negotiating power and access to market information vis-à-vis agribusinesses, can depress prices and skew the distribution of income along the value chain (FAO 2003). Furthermore, export-oriented contract farming schemes can deteriorate household food security, except for a small percentage of households that earn high enough incomes to purchase food. Under contract schemes, small-scale food producers can afford little time and resources to invest in their farms and the local food systems.

More critically, contract farming has a number of gender implications, without adequate attention to which will result in the deterioration of women’s rights. While women’s direct engagement in contract farming may be circumscribed by their limited access to land and control over household division of labor, their participation in such schemes could exacerbate their time poverty in providing care work (in addition to farm work), and deepen intra-household conflict over the control of resources, such as land and cash income (Bülow and Sørensen 1993; Carney and Watts 1991; Dolan 2005). In this light, the CFS-rai must address the critical oversight of, and stipulate appropriate safeguards against the exploitative conditions of contract farming and gender implications of such labor arrangements in discussing employment opportunities associated with agricultural investments.

Box 2. Tobacco growers under contract farming – BangladeshIn Jhenaidah district in Southwestern Bangladesh, three tobacco companies are engaged in contract farming agreements with local producers: British American Tobacco Company (BATC), Dhaka Tobacco Company (DTC) and Abul Khair Tobacco Company (AKTC).

The primary motivation for farmers for entering contract farming arrangements is reliable market access. Despite the purchase agreement the contract farmers have with the tobacco company, their products are often rejected on the grounds that their products do not meet quality standards. The farmers have no other option but to sell their tobacco at below market prices to willing buyers in order to gain cash income to meet their sustenance needs; yet this is infeasible as the purchase agreement binds the farmers to sell only to the contracting company. Furthermore, if the supply of tobacco in the market is higher than the demands, the company may only purchase the highest quality tobacco, while rejecting the lower quality ones. This results in lost incomes and increased preservation and transportation cost for contract farmers.




Mr. Habibur Rahman from Bijoypur village in Jhenaidah district was a contract farmer for BATC for eight years. In 2009, his contract with the company was terminated arbitrarily on the grounds that he sold his product at a higher price to another non-contracting company, DTC. In 2010, he entered into a contract farming arrangement with DTC. However, at the time of the agreement, he did not realize the existence of brokers, with whom the company has had a hidden contract. Consequently, he could only sell his products to the brokers at the rate of Tk 80-90 (approximately USD 1), compared TK 120-130 or more initially agreed by the company. Such rampant corruption and exploitation is difficult for farmers like Mr. Rahman to resist, especially as local thugs are also involved in the brokering processes.

Further reading: IFSN, ActionAid Bangladesh, and Unnayan Dhara. 2011. Corporate Agriculture in Bangladesh and Alternative. Dhaka: IFSN.

5. Lack of discussion of the investment-trade nexus

Despite the long-standing debate on the relationship between investment (particularly foreign direct investment) and trade, and its implications for developing countries, the Zero Draft mentions ‘trade’ once in Part II, where it discusses the challenges of policy coherence. However, the bilateral, regional, and international trade agreements, which are legally binding and sanctionable, could have detrimental consequences for small-scale food producers in developing countries, who are vulnerable to adverse fluctuations and shocks in world markets. Furthermore, for agricultural products to be commercially traded, they have to be produced at scale, using high levels of agrochemicals and other external inputs. These inputs are inaccessible to small-scale food producers, and such industrial agricultural model is ecologically unsustainable. At the same time, agricultural commodities that are privileged in international trade will not be food crops, but agrofuels and cash and feed crops, which have far-reaching consequences for national food and nutrition security. Therefore, in order to avoid any loopholes that may jeopardize the progressive realization of the right to food, the CFS-rai must be more explicit about the “responsible” mode of agricultural production that is both socially and ecologically sustainable.

6. “Sustainable agricultural production” or “sustainable agricultural intensification” do not translate as smallholder-led agroecology

Throughout the Zero Draft, there are references to “sustainable agricultural production” or “sustainable and climate adapted agricultural intensification” (CFS 2013: 5, 6) as the mode through which agricultural investments should be promoted. However, ‘sustainable agriculture’ needs to be elaborated with appropriate qualifiers. Likewise, ‘sustainable agricultural intensification’ – i.e. increasing agricultural production with more efficient use of inputs – may be interpreted as the application of agroecological concepts and principles on one hand, and/or the use of patent-protected genetically modified varieties that entail intensive use of external inputs on the other.

In addition, while principles 3 and 4 suggest the need to value traditional knowledge and cultural heritage around local food production, it does not make explicit how such systems are better sustained through ecological agriculture led by small-scale food producers. The absence of reference to




agroecology in the Zero Draft overlooks a wide range of studies that highlight its importance in improving food and nutrition security; increasing production yields; reducing rural poverty; diversifying livelihoods; and building small-scale food producers’ resilience to shocks (De Schutter 2010; IAASTD 2009; see inter alia Petty 2006; UNCTAD 2013; UNEP-UNCTAD 2008; IFSN 2012).

Furthermore, the Zero Draft does not specify the roles and responsibilities of small-scale food producers in designing, experimenting with, and cooperating with private and public investors on promoting local food systems, which are based on agroecological principles. The CFS rai principles should recognize small-scale food producers as rightful actors who have invested in their farming systems for centuries and continue to do so on daily and generational basis, and not legitimize investments in ‘sustainable agriculture’ that remove people off their land, or put restrictions on land use for local populations.

Box 3. Local food systems driven by small-scale food producers based on agroecology – PakistanThe mountainous Allai Valley in northern Pakistan is characterized by high rates of poverty, food insecurity, and gender inequality. In 2005, the socioeconomic situation of the region was further exacerbated by an earthquake and the resultant environmental degradation. In response, the Partnership for Recovery and Development of Allai (PRDA), with the support of Sungi Development Foundation, initiated a village-based movement to reforest the valley, and to restore and diversity food security and livelihood options.

In order to do so, PRDA integrated a range of low-cost agroecological methods. Working through a network of 437 village committees, thousands of men and women smallholder farmers shared and experimented with organic farming techniques by setting up on-farm demonstration plots, farmer-to-farmer knowledge exchange programs, and seed banks of traditional varieties, managed by women. Specifically, farmers shared knowledge about manure and yeast-based bio-fertilizers, and tobacco and chili-based bio-pesticides to promote year-round production of organic vegetables in home gardens (e.g. broccoli, spinach, turnips, potatoes, tomatoes, okra, French beans and peas), and to supply them to the local market. They also established Sungi Organics, a private enterprise that sells certified horticultural and floricultural products through fair trade schemes. In addition to crop cultivation, they revived traditional livelihood activities, such as wild honeybee keeping, fruit orchards, agro-forestry, poultry rearing, among others.

As a result of these participatory innovations, the Allai Valley has transformed dramatically. Most significantly, thousands of previously poor and excluded women have started participating in local government and development planning processes. Through local food systems based on agroecological farming, farm profits and productivity increased, and food and nutrition security and health outcomes improved. Organic vegetable cultivation has expanded by 1,000 acres since 2005, and 80% of households are engaged in agroecological vegetable farming.

Further reading:IFSN. 2012. Fed Up: Now's the Time to Invest in Agro-Ecology. Dhaka: IFSN

7. Weak language around the role of states in prioritizing the needs, interests, and aspirations of small-scale food producers




The Zero Draft suggests that one of the roles and responsibilities of states is to “promote coherence and consistency of policies, laws and regulations shaping and affecting investments in agriculture and food systems” (CFS 2013: 9). The rai principles should make more explicit the multiple types of institutions that affect investments in agriculture and food systems and promote coherence among them. These include, at the national level, the constitutional guarantee of the right to adequate food, poverty reduction strategies, land policies, trade policies, rural development programs, employment and labor laws, climate change policies, agricultural extension services, seed policies, health and nutrition programs, gender equality policies, rural and urban planning, among many others. This is to highlight that in order to prioritize the needs, interests, and aspirations of small-scale food producers, states must pursue transformative reforms not just within the food and agricultural sector, but also across other sectors that shape the socio-economic, political, legal, and environmental basis for building local food systems.

8. Inattention to power inequalities among different stakeholders

The Zero Draft pays little attention to the politics of power that shape the relationships between states, private investors, civil society organizations, and small-scale food producers. First, while the document separates public and private investments, it does not deal with public-private partnerships and joint ventures, which are prevalent and are often funded by IFIs. Such collaboration can result in the disproportionate accumulation of power for states, capitalists and financiers, while deterring meaningful participation and influence of civil society.

Second, the Zero Draft seems to categorize “small-scale food producers and processors” (CFS 2013: 7) as one homogenous group, when in fact there is a wide range of individuals and communities involved – e.g. smallholder farmers, landless people, contract farmers, informal/casual farm workers, pastoralists, fisherfolk, among others. Similarly, there is a tendency to lump together “women, youth, and members vulnerable groups” (CFS 2013: 2) without differentiating them along the lines of gender, sex, class, ethnicity, race, age, and occupation among others. Being sensitive to these differentiations is key to understanding how certain social groups may or may not benefit from agricultural investments in the short, medium, and long-term.

Third, while the Zero Draft repeatedly refers to women, it does not politicize the patriarchal institutions and practices that lie at the root of gendered power inequalities. Changes to land use instigated by agricultural investments will necessarily alter the ways in which labour (both farm work and non-farm work, including domestic labor) is arranged and divided within households. This, in turn, has inevitable consequences for women, who bear the brunt of both agricultural work (both paid and unpaid) and unpaid care work in the home. Therefore, the CFS rai principles should address the socially vulnerable groups, while adequately discussing the deeply rooted power inequalities that continue to marginalize them.

9. Need to highlight the role of the CFS in the global governance of food security




The Zero Draft concludes with one sentence, which urges the CFS to be the “global platform” The Zero Draft concludes with one sentence, which urges the CFS to be the “global platform” where various stakeholders involved in agricultural investments learn from each other. However, there needs to be a stronger emphasis on the role of the CFS in guiding and monitoring the implementation of the principles. Considering the role of the CFS in the global governance of food security, specifically in: promoting convergence across various policies, institutions, and initiatives around food and agriculture, supporting and advising national and regional level approaches to ensuring sustainable food systems, and promoting shared learning opportunities, the CFS should develop an innovative monitoring mechanism to ensure progressive implementation of these principles.

This document has delineated IFSN’s understanding of the responsible agricultural investments, and highlighted nine areas of improvement in the Zero Draft of the CFS-ra. To reiterate, the CFS-rai should:

1. Recognize explicitly the link between responsible agricultural investments and the right to food, and the role of the state in complying with human rights obligations;

2. Clarify the definition of “responsible” investment, to whom the responsibility falls, and how it will be monitored and evaluated;

3. Should set the highest human rights based standards for investments and foster policy coherence so as to prevent the impoverishment and dispossession of local populations;

4. Stipulate appropriate safeguards against exploitative labor practices related to agricultural investments;

5. Address the link between agricultural investment and international trade, and the socio-ecological implications thereof;

6. Recognize and support small-scale food producers and their organizations as key investors in building agroecological food systems at the local level;

7. Make explicit the national-level reforms required not just in the food and agricultural sector, but also in other sectors that shape the socio-economic, political, legal, and environmental basis for achieving food and nutrition security;

8. Address the gendered power inequalities that mediate relations between stakeholders of agricultural investments;

9. Highlight the role of the CFS in developing innovative monitoring mechanisms to ensure the implementation of the rai principles;

10. Take due account of the recommendations of small-scale food producers and civil society organizations when negotiating the final draft in October 2014.

References

Bülow, von, D., and A. Sørensen. 1993. “Gender and Contract Farming: Tea Outgrower Schemes in Kenya.” Review of African Political Economy 20(56):38–52.Carney, J., and M. Watts. 1991. “Disciplining Women? Rice, Mechanization, and the Evolution of Mandinka Gender Relations in Senegambia.” Signs 16(4):651–81.CFS. 2013. Principles for responsible agricultural investment (RAI) in the context of food security and nutrition. Zero Draft. (Online) Available:




http://www.fao.org/fileadmin/templates/cfs/Docs1314/RAI/CFS_RAI_Zero_Draft_01_August_2013_EN.pdf CFS. 2013. CFS Brochure. (Online) Available: http://www.fao.org/fileadmin/templates/cfs/Brochure/cfs_brochure_EN.pdf.Cotula, L., S. Vermeulen, R. Leonard, and J. Keeley. 2009. Land Grab or Development Opportunity? London, Rome: IIED, FAO, IFAD.Da Silva, J. G. 2009. “Zero Hunger and Territories of Citizenship: Promoting Food Security in Brazil's Rural Areas.” Pp. 367-374 in The Poorest and Hungry: Assessments, analyses, and actions: An IFPRI 2020 book, edited by J. von Braun, J., R. V. Hill, and R. Pandya-Lorch. Washington D.C.: IFPRI.De Schutter, O. 2009. U.N. Human Rights Council, 13th Session. Report of the Special Rapporteur on the right to food, Olivier de Schutter. Addendum. Mission to Brazil. (A/HRC/13/33/Add.6). 19 February 2009. De Schutter, O. 2010. U.N. Human Rights Council, 16th Session. Report submitted by the Special Rapporteur on the right to food, Olivier de Schutter (A/HRC/16/49). 17 December 2010. Deininger, K. et al. 2011. Rising Global Interest in Farmland: Can It Yield Sustainable and Equitable Benefits? Washington, D.C.: The World Bank.Dolan, C. S. 2005. “Benevolent Intent? The Development Encounter in Kenya's Horticulture Industry.” Journal of Asian and African Studies 40(6):411–37.FAO. 2006. Food Security. Policy Brief. Rome: FAO. (Online). Available: ftp://ftp.fao.org/es/ESA/policybriefs/pb_02.pdf.FAO, IFAD, UNCTAD and the World Bank. 2010. Principles for Responsible Agricultural Investment that Respects Rights, Livelihoods and Resources. Extended Version. (Online). Available: http://siteresources.worldbank.org/INTARD/214574-111138388661/22453321/Principles_Extended.pdf . IAASTD. 2009. Agriculture at a Crossroads. Synthesis Report. Washington D.C.: International Assessment of Agricultural Knowledge, Science, and Technology for Development.IFC. 2012. Performance Standard 5: Land Acquisition and Involuntary Resettlement. Washington D.C.: IFC, World Bank Group.IFSN. 2011. Success in Reducing Hunger: Lessons from India, Malawi, and Brazil. Dhaka: IFSN.IFSN, ActionAid Bangladesh, and Unnayan Dhara. 2011. Corporate Agriculture in Bangladesh and Alternative. Dhaka: IFSN.IFSN. 2012. Fed Up: Now's the Time to Invest in Agro-Ecology. Dhaka: International Food Security Network.Little, P. D., and M. J. Watts. 1994. LIving Under Contract: Contract Farming and Agrarian Transformation in Sub-Saharan Africa. Madison: University of Wisconsin Press.Petty, J. 2006. Agroecological Approaches to Agricultural Development. Background Paper for the World Development Report 2008. Santiago: Rimisp-Latin American Center for Rural Development.Prowse, M. 2012. Contract Farming in Developing Countries - A Review. A Savor 2. Paris: Agence France du Développement.UNCTAD. 2009. World Investment Report 2009. Transnational Corporations, Agricultural Production and Development. New York and Geneva: UNCTAD.UNCTAD. 2013. Wake Up Before It Is Too Late. Make Agriculture Truly Sustainable Now for Food Security in a Changing Climate. Geneva: UNCTAD.



http://siteresources.worldbank.org/INTARD/214574-1111138388661/22453321/Principles_Extended.pdf

http://siteresources.worldbank.org/INTARD/214574-1111138388661/22453321/Principles_Extended.pdf

ftp://ftp.fao.org/es/ESA/policybriefs/pb_02.pdf

http://www.fao.org/fileadmin/templates/cfs/Brochure/cfs_brochure_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_rai_Zero_Draft_01_August_2013_EN.pdf

http://www.fao.org/fileadmin/templates/cfs/Docs1314/rai/CFS_rai_Zero_Draft_01_August_2013_EN.pdf


UNEP-UNCTAD. 2008. Organic Agriculture and Food Security in Africa. New York and Geneva: UNEP-UNCTAD.World Bank. 2001. Operational Manual (OP) 4.12 - Involuntary Resettlement. Washington D.C.: World Bank.

17. Riikka Sievänen, University of Helsinki, Finland

Dear recipient,

thank you for giving the possibility to comment on these principles. I’m currently working as an Advisor in KPMG, in Responsible Investment, Climate and Sustainability Business in Helsinki. In addition, I’m conducting post-doc research in University of Helsinki, Faculty of Agriculture and Forestry, Department on Economics and Management. My area of specialisation is drivers of responsible investment by institutional investors.

My comments for the Zero Draft are the following:


It appears to me that the principles are thoroughly prepared. However, I would like to pay your attention to two other sets of principles for responsible agricultural investment that already are in use: comparing the principles you are preparing to the existing ones would ensure that they do not become overlapping. The links are here:http://unctad.org/en/Pages/DIAE/G-20/PRAI.aspxhttp://www.unpri.org/areas-of-work/implementation-support/the-principles-for-responsible-investment-in-farmland/


I think the roles and responsibilities are clearly defined. However, I think that the principles do not account for the way investors (that are in a central role to get more investments to agriculture) have to make their investments. Taking this into account would be a major contribution. This would mean that the principles would be modified to be implementable from the asset class point of view. In other words, how to invest in agriculture in the asset classes of equities, bonds, commodities, farmland? If this is not explained, the majority of investors will not have the resources to find this out. I think that you would have a great opportunity here to make agriculture accessible for mainstream institutional investors.


Yes, if the principles explained how investors can invest in agriculture (via the different asset classes). One of the central findings of my PhD is that responsible investment is difficult to define and implement, i.e. institutional investors need support with it.



http://www.unpri.org/areas-of-work/implementation-support/the-principles-for-responsible-investment-in-farmland/

http://www.unpri.org/areas-of-work/implementation-support/the-principles-for-responsible-investment-in-farmland/

http://unctad.org/en/Pages/DIAE/G-20/PRAI.aspx


4. The principles are intended to provide practical guidance to stakeholders; therefore:Are the current structure and language used clear and accessible for all relevant stakeholders to apply?

I recommend that you would include clear guidance for institutional investors that make the decisions for their investments. To reach this, you are of course welcome to contact me. In my current work, we make responsible investment accessible for institutional investors. Another idea could be to include a finance professional to the team that is preparing the principles.


I think it is important to promote the principles for the different parties that are involved in investment decisions and in creating the “environment” for it, i.e. institutional investors, asset managers, service providers, authorities at national and international levels.

Kind regards,

Riikka Sievänen

18. Global Renewable Fuels Alliance, Canada

Please find below and attached a letter from the Global Renewable Fuels Alliance on the zero draft of the Principles for Responsible Agricultural Investments (RAI).

---

Dear Ms. Blank,

I am writing to you today in response to the Committee on World Food Security’s (CFS) Principles for Responsible Agricultural Investments V0 draft report. I would like to introduce the Global Renewable Fuels Alliance (GRFA) and open a dialogue to ensure that the principles included in the report foster the growth of the global biofuels industry.

The Global Renewable Fuels Alliance is a non-profit organization dedicated to promoting biofuels friendly policies internationally. Through the development of new technologies and best practices, Alliance members, who represent over 65% of global biofuels production from 44 countries, are committed to producing renewable fuels with the smallest possible footprint.

The global biofuels industry has recently been cited by the FAO and proven in studies to have the ability to support agriculture and rural development. Consequently, the GRFA’s position on the report is that future drafts must include principles that encourage biofuel investment as part of responsible agriculture investment.



http://www.fao.org/fsnforum/forum/discussions/RAI


The GRFA has long stated that investing in biofuels supports agricultural investment and rural development. This was supported by the FAO’s recent “Bioenergy and Food Security (BEFS) Analytical Framework” report that stated;

“…Investment in bioenergy could spark much-needed investment in agricultural and transport infrastructure in rural areas and, by creating jobs and boosting household incomes, could alleviate poverty and food security.”

Bioenergy and Food Security project leader, Heiner Thofern went on further to say;

"FAO has been saying for years that under-investment in agriculture is a problem that seriously handicaps food production in the developing world, and that this, coupled with rural poverty, is a key driver of world hunger. Done properly and when appropriate, bioenergy development offers a chance to drive investment and jobs into areas that are literally starving for them."

A recent GRFA study reaffirmed the FAO’s position, finding that global biofuel production supported nearly 1.4 million jobs in all sectors of the global economy in 2010. These jobs not only include direct biofuels production, but also jobs in agriculture, other supplying industries, and other sectors such as retail and wholesale trade that benefit from the economic activity generated by biofuels. The largest share of employment for ethanol occurs in the U.S. and Brazil, although the fastest growth is projected to be realized in the developing Asian and African producing countries. As the biofuels industry expands, the employment impact is projected to grow to more than 2.2 million jobs by 2020.

Days ago, FAO Director-General José Graziano da Silva launched the African Year of Agriculture and Food Security, stating that agriculture must become the engine for growth that Africa needs to eradicate hunger and boost sustainable food production. The GRFA feels that investing in and expanding Africa’s biofuels industry can be a significant part of the solution to eradicating hunger in Africa.

The World Bank agreed with this strategy in 2011 in a report titled, “Biofuels in Africa: Opportunities, Prospects, and Challenges.” It found that biofuels offer new opportunities for African countries and can contribute to economic growth, employment, and rural incomes while becoming an important export for some countries and providing a low-cost fuel for others.

Principles 1 and 2 of the draft report, “Responsible investments in agriculture and food systems enhance peoples food security and generate positive socio-economic impacts for all, men and women,” certainly coincide with the GRFA’s position. The importance of biofuels to agriculture is particularly notable since feedstocks produced by the world’s farmers provide significant revenue and stimulate future agricultural production that will enhance food security on a global basis.

The GRFA would welcome feedback about how we could further assist the RAI Open Ended Working Group further develop this report and build on Principles 1 and 2 so the report fosters investments with the best benefits, like biofuels.

Please feel free to contact me at [email protected] or visit www.globalrfa.org.

Sincerely,Bliss Baker



http://www.globalrfa.org/

mailto:[email protected]


PresidentGlobal Renewable Fuels Alliance

19. Tina Goethe, Bread for all, Switzerland

Dear Christina Blank, dear all

in the name of the Swiss NGO-Coalition on FAO/CFS issues: Alliance Sud, Berne Declaration, Biovision, Bread for all, Lengthen Fund, HEKS, Helvetas Swiss Intercooperation, SWISSAID I would like to share with you our joint comments on the rai Zero Draft (according to the guiding questions for the regional consultations):

1. Are all relevant issues and areas related to fostering responsible agricultural investment adequately addressed in the Zero Draft ? If not what should be changed ?

The importance of small-scale producers, their contributions and particular needs are missing in the Zero Draft. In fact, the document is drafted from the perspective of large investors, while small-scale producers are added on as needing safety-net type protections. Also, in this draft, small-scale producers are grouped in the same category as other “private investors,” who include large investors and companies. This is not acceptable. Small-scale producers need to be recognized as important investors for social and ecological sustainable food production. They should therefore be prioritised, their particular needs addressed appropriately and imbalances of power among small scale producers, corporations, governments, financiers, be acknowledged and addressed—especially in the sections on Roles and Responsibilities in Parts I and II.Similarly, the rai principles need to better distinguish between public and private investors in agriculture, and their respective rights and responsibilities.The document should provide a clear condemnation of land and resource grabbing. After having referenced the VGGT as one of the baselines for the rai principles, the rest of the document remains almost completely silent on the issue of safeguarding legitimate tenure rights. The reference to the VGGT as an important complementary document needs to be much more explicit.There is no reference to agro-ecology. Agricultural systems should primarily be based on the use of local resources and natural interactions of ecosystems rather than external inputs. There is a strong need for supporting farmer-led bottom-up processes to make the best use of local farmers’ traditional knowledge, know-how, experimentation and innovation. This has also been stated by the UN Special Rapporteur on the right to food in his report to the UN General Assembly (December 2010), to which the new Zero Draft should explicitly refer.The draft focuses excessively on increasing productivity, market mechanisms (such as incentives) and integrating small-scale producers into value chains. Markets need to be established in a way that they benefit small scale food producers and poor consumers. The draft should reflect existing power relations and ensure that fair share of value addition remains with small-scale producers and rural economies.Women food producers are rather treated as an add-on. The rai principles need to acknowledge women as major food producers, as well as those processing and marketing food. The wording on women’s right to food is still weak and needs substantial improvement.Language on regulating contract farming and public-private partnerships are also missing in the current draft.


http://www.fao.org/fsnforum/users/emailregistrationtgalhth6uf



In relation to Indigenous Peoples, the rai principles must make reference to the ILO convention no.169.The document fails to address adequately the concerns of agricultural and food workers in relation to responsible investment in agriculture. As they make up 40% of the agricultural workforce and work on all sizes of enterprises – small, medium and large, their views, requirements and concerns should be much more fully reflected.

2. Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the principles? If not, what should be changed ?

There are major gaps in mechanisms, laws and regulations to discipline large-scale investors who violate the rights of small-scale producers and who fail to comply with the Voluntary Guidelines and the rai principles. Also missing is language on regularmonitoring of large investments and renegotiating investment contracts and agreements that undermine the capacities and rights of small-scale producers.The concept of accountability has been included in a rather vague manner. Particularly the sections on roles and responsibilities need to be more explicit about who is accountable to whom and for what.

3. Does the Zero Draft achieve the desired outcome to promote investment in agriculture that contributes to food security and supports the progressive realization of the right to adequate food in the context of national food security? If not, what should be changed ?

The state as investor: We see major gaps in the roles and responsibilities of the state in relation to public investment, provision of public goods and services, public policy, and regulatory and legal frameworks that address the interests and priorities of small-scale producers.A change of perspective is needed: Across the document, language about enabling investment favours large-scale investors and not small-scale producers, and local food systems that link producers and consumers. It is not enough that agricultural investment generates co-benefits for concerned communities; small-scale producers and their communities must be the principle beneficiaries of agricultural investment. Furthermore, the interests of large investors are protected by ‘hard law’—including international agreements and investor protection – whereas small-scale producers and workers are only protected by ‘soft law’ such as voluntary norms, corporate social responsibility, mediation, conflict resolution, etc.

4. a Are the current structure and language used clear and accessible for all relevant stakeholders to applyGiven that the current document primarily focuses on large-scale producers and fails to distinguish between different roles and responsibilities for small and large, private and public investors, the document remains unclear and cannot provide clear guidance for most of its target groups. In addition, the principles per se are formulated in a pretty short manner, leaving room for interpretation and contestation.

4.b What steps need to be taken for the CFS-rai principles to be used and implemented by different stakeholders after endorsement by CFS?In its current form, the CFS-rai principles must not be endorsed at all. At a later stage, it will be essential that involved stakeholders at all levels use these principles in practice and declare their observation a prerequisite for collaboration with all types of development partners.




20. Bernd Steimann and Peter Schmidt, HELVETAS Swiss Intercooperation, Switzerland

Dear Christina Blank, dear all

Thanks for the opportunity to comment on the RAI Zero Draft. Please find our comments and observations below:

The fundamental limitation of the RAI is that they are voluntary.

The RAI build on FAO’s definition of “food security”. The more fundamental critique of the “food sovereignty” school of thought are not really taken into consideration.

The RAI lack a clear definition of “Investments”. Nevertheless the underlying understanding of “investments” in most parts of the text are “financial investments”. I think this is a limitation as it undervalues the role of small scale farmers who usually rather invest labour, skills and knowledge than capital. I therefore suggest to add a definition of “investment” that includes knowledge, skills, labour and capital.

The understanding of the Civil Society is limited to its “watchdog function”. But the civil society is a development actor itself and an investor too. For example community based organisations (e.g. running a seed bank), producer cooperatives and their umbrella organisations are development actors and not only their to defend the interests of their constituencies. (this refers to principle 4, last para). My recommendation would be to separate the strange group of “others” namely “Research and educational institutions, CSO, Intergovernmental and regional organisations and bilateral donors and foundations” and keep the CSO as an own independent actor. Their role is NOT only “complementary” as mentioned at the end of Principle 4.

The role of consumers and their organisations is undervalued. Consumer can and should demand for a responsible behaviour of producers and investors. Now consumers are mentioned at the beginning only (p 2., top, last bullet point) where “communities, consumers and food insecure people” are thrown into one strange pot.

Post-harvest and food loss are now mentioned in principle 3 which is the principle addressing “ecological concerns” (p.5, application, first bullet point). To my mind this aspect should go to principle 1 and deserves an own bullet point.

The recognition of the value of indigenous knowledge is now mentioned in principle 3 only while it is important for all principles. This has to do with the missing definition of “investments”. I would include it there.

Sincere regards,

Bernd Steimann, Development Policy Coordinator, HELVETAS Swiss Intercooperation


http://www.fao.org/fsnforum/users/emailregistration4e8xybfjjn



Peter Schmidt, Co-Head Advisory Services, HELVETAS Swiss Intercooperation

21. World Society for the Protection of Animals (WSPA)

Dear all,

Please find WSPA's comments in the attached document, which focus on the importance of including animal health and welfare - inter alia because enhancing animal health and welfare increases productivity, particularly in systems with current low productivity, thus improving food security and livelihoods for the world’s poorest billion people that depend on livestock for food, fertilizer, transport, income and as social safety net. Moreover, animal health and welfare are important from a public health perspective.

Best regards,

Dirk Verdonk

http://www.fao.org/fsnforum/sites/default/files/resources/WSPA%20comments%20zero%20draft%20CFS%20rai.pdf

22. Kien Nguyen Van, Vietnam

Dear Sir/Madam,

I think that principles for responsible agricultural investment should be under globalization, health of consumers, producers, environments and profits to stakeholders. In my opinions, principle No1 is opening market mechanism in agriculture sector, where every governments should cut down and remove out their subsidies to the sector.Why globalization? because, it help agricultural products become goods under kinds of industry and help completion of the sector under comparative advantages like technology, cheap labour sources, natural conditions, etc. And the most important, it will promote agriculture production as well as distribute fresh, safe food and nutrition to consumers with cheapest cost. Health of consumers and producers, if this is guaranty, I believe that environment will be protected and profits of stakeholders will be ensure. Best regards,

KIEN

23. Kyungmee Kim, Stockhols International Water Institute, Sweeden

Dear Chairperson and colleagues,






I would like to welcome the Principles for Responsible Agricultural Investments (RAI) to establish a global guideline for agricultural investment. Agricultural investments have a great potential for improving productivity of agricultural sector and contributing to eradicate poverty. At the same time, such investment deals affect people's livelihoods and use of natural resources required such as water. Freshwater is a finite resource that is essential for human well-being and development. In agricultural investment, there is no doubt that water is one of the most critical factors. The water requirement for all the investment deals made on agricultural sector is tremendous. This indicates more irrigation facilities and intense water use which alter both quantity and quality of water resources in areas where investment projects take place. The competition for water in land investment is already high, and we are already seeing a number of local conflicts around water.

It is also worth noting that irrigation will be demanding less than 40% of global water demand by 2050 (projected by OECD Environmental Outlook to 2050). Other industries and sectors will demand more and more water. It can be simply put, where all the agricultural investors find water? It is a great concern for both population who will be affected by agricultural investments and investors. In RAI, water is only mentioned as part of "natural resources" under Principle 3. Under Principle 3, a clause addressing water can lead to reach a global guideline for the investors what is the water requirement of project and how the water will be managed. From water perspective, it can be more clearly stated under principle 3 'how' water can be better valued and considered in agricultural investments by suggesting a separate water clause.

It would be great to see how this consultation will contribute to the development of RAI and look forward to follow-up on implementation of RAI. Keep up the good work!

With best regards,

Kyungmee Kim, Stockholm International Water Institute, Sweden

24. Senait Regassa, The Swiss Agency for Development and Cooperation, Ethiopia

Dear Sir/Madam,

First of all, I would like to appreciate the team for the very well written and comprehensive document on principles for responsible agricultural investment (rai). My contribution with regard to the principle is as follows.

All the stakeholders listed in the document have roles and responsibilities designated to them in the process of implementing the Principles of Responsible Agricultural Investment. There is, however, one group which seems to be treated as a subject with no clear role or responsibility. This group is the community or indigenous people. Civil society organizations are supposed to defend the cause of marginalized communities/indigenous people. However, in many cases, there are not strong civil society organizations that can meaningfully represent their constituencies and make the voices of the people heard particularly in the global south. The principle of RAI must provide guidance as to how meaningful consultation and participation of communities/indigenous people can be ensured.




Best Regards,

Senait Regassa, PhDNational Program Officer

The Swiss Agency for Development and Cooperation

Embassy of SwitzerlandEthiopia, Djibouti, South Sudan, African UnionP.O. Box 1106, Addis Ababa

25. Jean-Laurent Bungener, consultant, France

Sorry, but as a little farmer in france in don't see any practical guidelines for investments in your document.To implement food security there are for me three main principle given by the responsabilities of farmer to manage a common.The first one is a security principle:

-implement grain storage capacity at the farm level to secure farmer food access and theire ability to control market risks

- invest on middle to long term production to protect the country side from climate change and provide energy supply (forest and water management)

- developp and identify potentially useful new crops and animals. this will help to continuously adapt crop production to climate change (biodiversity management) this include farmer formation in botanic and zoology at the village schoolsThe second one is based on ecological principle:

- manage the existing biodiversity to ensure that on a long term farmer could use this biodiversity for small scale business and benefit of fully efficient ecosystem services

- invest in short term technics like aquaponie and biochar that provide farmer with food and energy apart from seasonal fluctuations

- developp microclimate using ecoengeniring techniques to give the way to a larger amount of ecological niches including artificial onesThe third one is a socially based principle for farmer workforces

- invest in techniques that gives the farmer the possibilities to developp production with higher level of capital gain.those techniques would be between handwork and industry managed at the farm or the village level. Farmer could by this way benefit from higher prices issued from product transformation. In this techniques we could find aloso food conservation practices like freezing, lyphillisation or pasteurization.


http://www.fao.org/fsnforum/users/nmgimn3anb



- ensure that villager benefit from all the natural ressources including medicinal plant and that theire knowledge are well protected at the international level. This knowledge must also be transmitted from one generation to another including during school time.

- villagers as the first responsible for natural capital management must have the possibilities to edict particular laws for protecting theire commons. States, in that way, must provide the police or military forces necessary to reinforce the villagers decision.

26. Kjell Havnevik, Sweden

Please find below a contribution which is a summary of a report discussing the rai process to be launched on March 14 2014.SincerelyKjell Havnevik

Summary of discussion paper by Kjell Havnevik, ”How to make the ’responsible agricultural investment’ (rai) principles and guidelines effective – Agriculture, investments, scale and food security in developing countries”. Presented to the Swedish FAO Committee, Stockholm.

This discussion paper attempts to contribute to how to make future investment in agriculture responsible and efficient. Investment in agriculture is critical for global food provision, but in future it will have to compete with investment in land for raw materials and energy, such as various feedstocks for biofuel and biodiesel production. The competition for water will also increase in connection with large-scale investment in agriculture. In the context of a scarcity of water, the emerging competition between investment in land for food and for energy is linked to attainment of “peak oil” and the growing global concern with climate change. These developments are also reflected in the rise of food security and energy security to become primary global political priorities. This policy shift over the last decade is also mirrored by a rapid increase in large-scale land and agricultural investment, with sub-Saharan Africa at the centre. On the African continent , smallholder farmers (most of them women) contribute the major share of food production. In parallel, this process described above has triggered global consultations, initiated in 2008/9, which aim to formulate both voluntary principles and guidelines for improving agricultural investment.

The urge to develop principles and guidelines for agricultural investment also reflects the concern of global, national and local stakeholders with managing land responsibly since this had emerged as a contentious issue globally over the last decade. In the most recent global attempt to formulate voluntary, responsible agricultural investment principles (rai), the aims are to promote agricultural investments which simultaneously enhance food security, nutrition and sustainable development – hence the reference to responsibility Sustainability implies that agricultural investments must address economic, social and environmental/climatic concerns, which will have to be integrated in the discussions and consultations surrounding rai. In order to address the potential for employing the rai principles as a basis for strategy and policy, this discussion paper argues that a need exists for for transforming the rai principles into more concrete guidelines for responsible investment in agriculture so that they can provide the basis for policies and strategies that can prepare for concerted actions and activities.




The rai process relates to all types of agricultural investments globally, and it will include all major stakeholders. A global approach to responsible agricultural investments, however, will need to be based on the insights and understanding of the particular constraints and opportunities existing and anticipated in different groups of countries/regions, e.g. developed countries, emerging economies and developing countries and the relations between them. This is the broad mandate of the World Commission for Food Security (CFS) and which is the basis for the current global negotiations. The Zero Draft of the rai, published on August 1 2013, although indicating consensus about the broad rai principles, also showed clear disagreement among different stakeholders relating to the concretisation of rai. The CFS, through its Zero Draft, also requested inputs into the further rai process. To this effect a number of studies have been carried out by the High Level Panel of Experts (HLPE) connected to and set up to support the CFS and the rai process.

The Swedish FAO Committee, managing a limited budget, wished to contribute to this process by commissioning a desk study focusing on some of the most critical and discussed aspects of current agricultural investments, i.e. land related investments in developing countries. A particular objective of the study was also to inform about and mobilise discussion around these issues in Sweden. This study is thus structured as a discussion paper and focuses primarily on rai in the context of land related investments in developing countries, primarily Africa. Since challenges to promote agricultural investments which also enhance food security, nutrition and sustainability are of particular concern to Africa and developing countries, such a study would also contribute to the broader analysis of the rai process. The discussion paper also aims at informing about and mobilizing interest for the rai process among the Swedish concerned public. Three cases relating to large scale land investments were thus selected for inclusion in which the investors or the co-investor are of Swedish origin. The choice of a case of large scale investments in agriculture in Brazil also makes possible for the discussion paper to reflect on differences of conditions for the rai process in emerging economies (Brazil) and developing countries in Africa (Sierra Leone and Mozambique).

The discussion paper consists of several parts. The introduction addresses voluntary principles and guidelines in relation to legal pathways, in order to create a framework for responsible agricultural investment. The concept of responsibility is also discussed. Subsequently, the paper presents the background and evolution of global land investment, as well as an analysis of the role of foreign direct investment in relation to economic growth and spill-over effects. Empirical studies cited show that it is difficult to discern any direct connection between foreign direct investment, economic growth and the various spill-over effects, in particular as regards agriculture. This part of the discussion paper thus puts major emphasis on the relations between developed and developing countries, with particular focus on investments and reflections about the constraints and opportunities of investments versus trade.

Since Africa is a major focus for global agricultural land investment, the discussion paper also sets out an understanding of land, land investment and rural organisation on the continent. In addition, there is a description and analysis of smallholder agricultural production regimes and farming systems. This provides an assessment of the potential for smallholder or small-scale agriculture through their investments, and with support from their governments, to contribute to food security, nutrition and sustainable development.

The next sections of the paper present descriptions and different views, featuring the three case studies of large-scale investment in agriculture and forestry: biofuel investment in Sierra Leone by Addax Bioenergy, tree plantations in Niassa, Mozambique led by Swedish and Norwegian church organisations, and large-scale agricultural investments in Brazil by the Second Swedish National Pension Fund, AP2.




The implicit model in the evaluation of the case studies is to focus on pre-conditions, processes and planned and unintended outcomes, and the relationships between these elements. The character of the outcomes may be explained by a weak/strong understanding of the pre-conditions of the investment and/or a weak/strong process in relation to its implementation in terms of consultations, mobilisation, training etc. Such a model makes it possible to distinguish between the impacts of pre-conditions and processes for the outcomes, e.g. a project with a good analysis of the pre-conditions may still have negative and unintended outcomes, if the implementation process is flawed. For all assessments of investments, however, there has to be a strong reliance as well on contextual aspects.

This investigation, as explained above, is a desk study and thus does not include any visits to the sites of the investments analysed. The World Bank (World Bank 2008 and Deininger et al. 2011) and the FAO (2013b), are among the few institutions with resources and outreach to conduct field studies with broad coverage. This discussion paper relies on secondary sources of various characters and some interviews with knowledgeable persons about the investments and contextual factors (see acknowledgements). All these sources of knowledge have been helpful for the implementation of the study. The numerous comments on the first draft of the study, have as well been important for its final phase.

The author had, however, to a large extent to rely on his experiences as a researcher and consultant in identifying and analyzing relevant empirical material relating to the broad topic of the study, including various evaluations and monitoring activities of the large scale agricultural investments chosen for inclusion in the study. As emerges from the study and its reference list knowledge and insights of a number of researchers and institutions have been very helpful for the analysis.

The large-scale investments evaluated relate to different countries and continents (Africa and Latin America), different crops/commodities and different types of investors – a large corporation, church organisations and a pension fund. Hence there are large variations in contextual factors to take into account. The analysis of these large-scale investments attempts to present empirical material, representing different perspectives that can capture economic, organisational, social and environmental/climatic aspects. The paper attempts to identify views and perspectives on the investments, based on research but as well on available studies and evaluations organised by the investor(s) and NGOs that often pursue an alternative understanding.

The empirical material analysed show that different notions exist regarding large-scale agricultural investment. Investors emphasise the potential for win-win outcomes, while NGOs to a larger extent are biased towards win-lose or lose-lose outcomes. In fact, the discussion paper shows that all investors claim the potential for win-win outcomes, i.e. that investors, host states and rural communities, producers and workers will all gain from the investment.

It is hard to substantiate these claims, since one of the investments – that of Addax Bioenergy in Sierra Leone – has not yet initiated production of sugar cane/ethanol. The Addax case shows, however, that it is highly relevant to discuss the pre-condition, process, impacts and outcomes of a large-scale agricultural investment even before production gets under way. This is because the identification of and access to land and the consultation processes surrounding the investments often generate uncertainties and insecurity among part of the local population and as well offer some understanding about the host government’s and investor’s perceptions of pre-conditions for and the implementation process connected with the investment. Such insecurity is documented among the local population in both the




African based investments, and in particular among people living inside or adjacent to the investment sites.

Such a scenario can emerge in spite that lots of efforts are expended by the investor in the planning and early phase of implementation, as was done by Addax Bioenergy. When investments not only cross spatial, but as well cultural boundaries, the potential for misunderstanding is also great. In most projects of such character it leads to problems of ‘managing expectations’ on the ground, as this report will show. For the case of Addax Bioenergy’s investment in Sierra Leone, NGOs that evaluated it, say that the investment is one of the best (probably the best) that they have investigated, but problems still occur. This discussion paper attempts to present different perspectives on these problems and how to address them.

In some cases problems related to the initial phases of the investment can lead to conflict in later stages. This happened with the large-scale forest plantation in Niassa in northern Mozambique. Here the empirical studies show that the investment by GSFF and the Chikweti company did not pay sufficient attention to potential problems relating to land access and the consultation processes associated with the investment. This discussion paper primarily analyses the failed developments of this investment until 2011, when the diocese of Västerås, the lead investor, was forced to write down the value of its investment by 25 per cent and to start afresh with new leadership at both board and management level. Information about the post-2011 process of the investment shows that it has taken a more constructive path and that relationships with people in the adjacent communities have improved. The win-win notion of the investor, however, remains.

The large-scale agricultural investment in Brazil by the Second Swedish National Pension Fund, AP2, has been difficult to assess, since, for commercial reasons, AP2 refuses to disclose the locations of the investment made through the international investment company TCGA and with assistance from the Brazilian company Radar. The analysis contained here thus has to take a more general and contextual pathway, and try to gain an understanding of the conditions, processes and potentials/problems of the sector in which AP2 is investing, in particular the biofuel/energy sector. The argument here is that AP2 and most stakeholders would probably gain from AP2 being more transparent about its investments – after all, it is the management of Swedish pension funds we are talking about.

The three case studies of large-scale investment addressed here reflect similar discussions and findings to those from recent case study research by the FAO in Africa, Asia and Latin America on the trends and impacts of foreign investment. The FAO suggests that, for investments involving large-scale acquisitions in countries where land rights are unclear and insecure, the disadvantages often outweigh the few benefits to the local community, especially in the short run. It is further stated that this outcome is even more likely when the land acquired was already being utilised by local people, either on a formal or an informal basis. Consequently, the acquisition of already utilised land to establish new large farms or investments should be avoided, and other forms of investment should be considered (FAO 2013b). The FAO study also concludes that, even from the investor’s perspective, business models that do not involve the transfer of land control are likely to be more profitable (FAO 2013b).

The next section of the paper brings out the recent history of guidelines for agricultural investment. This history goes back to 2008/9, when rapidly increasing food prices, triggered by the global financial crisis, coincided with a rise in the global interest in land-based food and energy investments and a growing concern for the climate. An overview of the stakeholders involved and of the various voluntary guidelines that were developed offers a better understanding of why there was a need for new consultations and




negotiations connected to the current rai process. The final sections of the discussion paper present the objectives and principles, including the different parts of the rai principles. This is done with reference to the rai Zero Draft, which was published in August 2013. The rai Zero Draft outlines four major parts and a total of eight principles within these parts. The parts include: (i) food security, nutrition and sustainable development and the progressive realisation of the right to adequate food in the context of national food security, (ii) policy coherence and sector development, (iii) governance, grievance mechanisms and accountability and (iv) review and accountability.

There is no sequencing of the parts and principles in terms of their importance for achieving the overall objectives of rai. The discussion paper goes on to suggest that relevant experience and knowledge should be used more consciously in order to arrive at rai principles that could become more efficient. A set of critical questions and answers to the rai process is developed, which leads to a suggestion about how rai principles could be made more responsible and efficient. In so doing, the discussion paper adds more substance and offers a better option for sequencing the principles, so that they may achieve their overriding objectives. It is hoped that the stakeholders at all levels who are involved in the current discussions and consultations about rai will read and analyse these suggestions with an open mind as to how the ideas presented could inform the rai process.Likewise, the discussion paper, with reference to the discussion and suggestions for modification of the rai principles presented in the Zero Draft, takes a step in the direction of suggesting more concrete guidelines for the implementation of rai principles. The rai and the associated guidelines could thus inform strategies and policies relating to the promotion of land based agricultural investments that could assist in the rural transformation in developing countries that also enhances food security and nutrition in a sustainable way. The discussion paper concludes that concrete guidelines to this effect will provide important inputs into the broader rai process so that its outcome makes a difference for people “on the ground” and not just add weight to the book shelves in the offices of the various stakeholders involved.

27. ActionAid

Introduction

The international community, backed by authoritative research since the food crisis in 2007/8, has recognized the need to reverse the negative trend of investment in agriculture, and that agricultural investment is the key to economic growth, improved livelihoods, and food security for millions of people.

The international community has taken a further step in recognizing that smallholder agriculture plays a critical role in achieving food security and that increased investment should flow to smallholders to support their already substantial investments 3

Despite authoritative references for this, the question of which model of farming system best supports smallholders livelihoods and the achievement of food security is still under discussion. Smallholders are viewed by some as those that, if given the adequate means and policies can most contribute to food security. They should primarily benefit from public investment and prioritized by public policies thorugh

3 High Level Panel of Experts, who in their 2013 report to the Committee on World Food Security (CFS)




supporting measures, incentives, and infrastructure that support their own investment, secure their access to natural resources, and enhance their access to local and domestic market.

Others view smallholders as the central productive units with great potential that can be upgraded providing them with better connection to the global market, better integration in the global value chain, and improved technologies for their enhanced productivity. This vision is interlinked with the current structure of the global food system, where major companies invest in large-scale land investment for cash crop production, hold the control of the value chain, and operate mostly in the international market. Given the budget constraints that many Governments are facing, and the fact that private sector can supply the resources that states need to let the sector flourish, private sector investments are more than often considered the solution, with the capacity to reverse trend in agriculture investment and supply the necessary resources for the required change.

This reveals two contradicting visions for the development of the agricultural sector, one with the smallholders at the centre with their own rights and autonomy in designing the systems that better benefit them, the other with them at service of companies and Governments’ led vision for agricultural development, with the strong focus on profit often undermining potential for livelihoods and food security.

In this vision, the impact that large scale private investments are having on smallholders and their families and communities cannot be ignored, and has to be considered when taking a stand of which vision we want to support and promote. At this moment in time, the reality is that many smallholders, women, indigenous people are driven off their land, are deprived of the control and use of their resource base, victims of human rights abuses and forced into a life without house, food, dignity. When they are integrated into new farming systems as a result of contract arrangements with large companies, they often become waged workers whose standard labor rights are not respected and their livelihoods and future prospects are not improved at all. In many cases large tracts of land are sold or leased to private and foreign investors depriving communities of their resource base, getting back just unfulfilled promises and dramatic changes in their livelihoods. Women are often the most severely affected.

In this context, the development of principles to guide the international community towards responsible investment that deliver on the right to food, that clearly condemn land and resource grabbing, that identify which farming system public investment should support and that clearly regulate private investors and guide them in their business to complement public efforts towards responsible investment is urgently needed.

The Committee on world food security has embarked on this process of consultation for the development of principles for responsible agricultural investment, launched in 2012 and due to conclude in 2014 with endorsement of the principles. The Committee on world food security represents the legitimate and appropriate place to conduct this process, being the major and most important multistakeholder platform for food security where the most affected can have a voice. All the different actors should commit to this process and work for a positive outcome.




ACTIONAID KEY PRINCIPLES ON RESPONSIBLE AGRICULTURAL INVESTMENT

1. Priority to smallholders farmers

“Approximately 2.5 billion people in poor countries live directly from agriculture – farming crops and livestock or relying on forestry or fisheries8 – and 1.5 billion people live in smallholder households. Of an estimated 525 million farms worldwide, about 404 million are small farms with two hectares of land or less…. Small-scale producers provide more than half of the world’s food supply. They contribute over 90% of Africa’s agricultural production, and the majority of the maize, beans and potatoes for domestic consumption in Latin America…. Smallholders feed poor communities – including themselves – and small increases in yields on their farms could have a profound impact on poverty and access to food at the local and regional levels. Despite these contributions they are the most neglected one facing numerous challenges ranging from research to extension and from hindering policies to exploitation by many of the market forces. ” Responsible investment are centred on the need to improve livelihood opportunities for smallholder farmers.

2. Special focus on rural women and their specific needs, including unpaid care work

Rural women account for 43% of agricultural labor force, and lie at the heart of local crop production and household food systems around the world. Yet, women face particular struggle to claim their rights (e.g. to productive resources, equal pay), are often not recognised as farmers in their own right, and receive no recognition for their unpaid care work. They also make up a substantial proportion of the world’s poor and hungry. Furthermore, women farmers receive very little formal support, with less than 5 per cent of agricultural extension services worldwide targeted at women. Responsible investments address the specific issues facing women farmers (and smallholder farmers in general) and implements policies that enhance their rights and meet their needs.”4

3. Rights based approach

The existence of poverty, hunger and discrimination is the failure for governments (primarily) and other stakeholders (international bodies, other governments, corporations) to respect, protect and fulfill the basic economic, social, cultural and political rights of their citizens. Therefore, investment is generally only meaningful when coupled with actions that strengthen women’s ability to strengthen their position in terms of economic (e.g. access to land, water), socio-cultural (e.g. position in the home vis-à-vis men) and political rights (e.g. freedom of association and participation in governance structures.Responsible investments related decisions include the participation from organizations of smallholder women and men farmers and should apply a right-based approach including farmers rights as stipulated in the International Treaty on Plant Genetic Resources for Food and Agriculture and guide towards investment empowering small holders, especially women, by recognizing and ensuring them the means to fully enjoy their rights.

4. Women’s land rights

4 ActionAid International, April 2011.




“By assessing the processes and outcomes of large scale land investments, ActionAid found a serious‐ threat to women’s access to land and communal resources in situations where female property rights are not legally recognized in their multidimensional nature. Moreover, while establishing a legal basis for female entitlement to the land is a necessary condition for the interests of women to be respected, the outcomes of investments also depend greatly on whether the state has both the will and the capacity to act in the interest of women land users. In the majority of cases private land investments had an adverse negative effect on women’s livelihoods and more often than not increased local food insecurity “ 5 The adoption of the Voluntary Guidelines on responsible governance of tenure of land, fisheries and forests is an unprecedented achievement for respect and protection of legitimate tenure rights. Deeply anchored in human rights language and principles, the Tenure Guidelines recognize the responsibility of corporations or non-state actors to respect human rights and existing or legitimate land rights, and recognize that investment in smallholder farmers and by smallholder farmers is preferable to large scale land acquisitions.

Responsible investments follow clear parameters for agricultural investments so that private sector activities are in line with international human rights principles, including the right to food. Furthermore, the parameters should reflect the needs of diverse stakeholders and ensure the access to and control over land by smallholder farmers particularly women, fisher folk, pastoralists and forest dwellers who depend on land for their livelihoods and food security. Responsible investments respect, protect and fulfill the legitimate tenure rights of small holders, and fully comply with the standards set in the Voluntary Guidelines on responsible governance of tenure of land, fisheries and forests, particularly the free, prior and informed consent of indigenous communities, the principle of participation and consultation with local affected communities, the respect of commons, the introduction of safeguards, the ex-ante and ex-post human rights impact assessments as a specific criteria for projects approval aside from environmental and social impacts, grievance mechanisms in case of land rights violations and adequate and appropriate compensation in case of loss of tenure rights for public purpose.

5. Sustainable agriculture

Investments that contribute to the achievement of right to food should prioritize climate resilient sustainable agriculture, whatever form it may take (agro-ecology, agro-forestry, organic agriculture) which proved to deploy multiple benefits such as increased farm production, reduced impact on environment, climate change mitigation, enhanced resilience and diversity for smallholders, improved livelihood and nutrition. Responsible investment should respect the sustainable use of natural resources as agreed in the International Treaty on Plant Genetic Resources for Food and Agriculture, reflect a re-orientation of public spending in agriculture towards agro-ecology and ecological agriculture and towards the provision of public goods, such as small-scale focused extension services, agricultural research and rural infrastructure.”6

6. Market and value chain

5 Colosio, et. al. April 2012.

6 IFSN/ ActionAid. June 2012.




International markets and global value chains have been problematic for the majority of smallholders who suffer from power unbalance in contract arrangement, loss control over their resource base and investment decisions, increased vulnerability due to dependence on external market and food prices volatility, and deterioration of their living conditions. ActionAid focuses on facilitating smallholder women (and men) farmers to engage mainly with local and national markets that most benefit and empower them, with skills and capacities to get better prices with the safeguard of their rights. Responsible investments build smallholders capacities to engage better in local, national and regional markets, paying particular attention to strengthening the role of women in local market systems, and better local infrastructure (storage facilities, farm-to-market-roads, information systems)

7. Implementation and Monitoring and Accountability

Following a rights based approach, investors have to account for their conduct and transparency and public monitoring should be strengthened for better accountability. Applied to investment, all private investments in agriculture must be subject to public monitoring to ensure that they do not violate human rights or negatively affect food security and sovereignty and environmental sustainability objectives. Governments have the responsibility to ensure adequate frameworks for this and take all action in their power to prevent violations and ensure accountability of investors.

Responsible investments provide the adequate space and means for monitoring their impacts by all those affected.

Comments on the zero draft1) The principles are intended to provide practical guidance by stakeholders; therefore:

a) Are the current structure and language used clear and accessible for all relevant stakeholders to apply?

Numbering instead of bullet points to assist referencing for this process will be useful when the principles are adopted.

Language should be clear enough to be understood by a wide range of actors, including grassroots associations

Language on human rights should be harmonized throughout the text When dealing with human rights, state and other investors have obligations. This should reflect

in a more assertive language the draft still keeps an excessive focus on increasing productivity as a solution to eradicate

food insecurity. The draft should start from the assumption that production of food is not the only component for feeding people. Although in some areas increasing productivity may be necessary for specific climate/soil/capacity gaps conditions, but overall the principles cannot ignore the market failures, and the need of policies/strategies/frameworks to correct the unfair and distorted functioning of market or the challenging conditions many producers face and that impede them to foster their production capacity. Unfair distribution of resources is another cause of food insecurity that should be redressed by adequate investment policies.




In order to contribute to the progressive realization of the right to food, investments are responsible when they enhance food security and nutrition, and contribute to the progressive realization of the right to food. The principles should unpack and detail when, how, and what needs to be done to make it happen, and include a clear condemnation of land grabbing as irresponsible investment.

The draft fails to recognize the centrality of small food producers. Small scale food producers do not play just an important role, the play the most important role being those that produce 70% of food consumed and those that undertake the bulk of investment.

The language is confusing when putting all the investors at the same level. Here the centrality of small food producers should be explicated more clearly, and the different scale of relevance of all investors should be clarified depending on the extent of their actual investment, and the impacts they have on food security. As big investors invest just 1% of total amount, and often have a greater negative social, human rights and economic impact on communities, this cannot be ignored if we want the principles to address and reverse negative effects of investment.

The reference to human rights and to the Voluntary Guidelines on responsible governance of tenure of land, fisheries and forests should be more assertive. Respecting human rights should be at the top of the principles and should be given the right consistence and formulation, they are obligations that states and all investor must comply with. Same weak language on human rights is in paragraph sixth, when again national legal systems and their institutions set the scene for human rights compliance. National legal systems should strive to comply with human rights obligation, not the other way round.

b) How can the rai principles be used and implemented by different stakeholders after endorsement by the CFS?

Extensive awareness raising will be needed to unpack and clarify the Principles and incorporate them into practices.

States have the duty to revise their investment policies and strategies accordingly with the principles

Donors should also use these principles to reorient their investments in agriculture Issues of unpaid work will need much awareness raising and clear commitments from policy

makers. This will also include reviewing policies on labour, social services The state must be obliged to report on a periodic basis on progress made on the principles and

also addressing existing inequalities on gender. Develop specific national sex-disaggregated indicators for progress based on existing baseline

data. Civil society must have a monitoring role. Advocacy work will also be required to influence funding and policy priorities of governments

and donors, and to ensure that the rights of activists are recognized and protected. All investors should follow the principles when developing their business plans, with active

participation of stakeholders impacted by their investment Every investment should be scrutinized against the principles to verify compliance CFS should discuss and receive complaints about lack of implementation of these principles.




2) Are all relevant areas related to fostering responsible agricultural investments adequately addressed in the zero draft?

The current zero draft doesn’t adequately address the following areas:Women’s role and unpaid care work

Recognition of existing gender inequalities regards food and nutrition security

Women face systematic prejudice and discrimination in access to land, water, agricultural inputs and other productive resources as well as participation in social and political movements that have a bearing on their farming activities. This negatively impacts on their abilities to feed themselves, their families and to contribute to the national economy. However, the draft rai principles do not acknowledge the different ways in which women and marginalised groups are affected and do not specify measures to address these existing inequalities. In fact in most cases they give the impression that men and women are already enjoying equality in all respects.

Women and paid work in the agricultural sectorThe principles recognise the right to international core labour standards and aim to contribute to decent job creation and equitable generation of local employment. Under this section, the principles should also note that lack of child care facilities in workplaces, often leads to women with young children not enjoying their right to employment. There is also need for social security benefits that can support care provision such as maternity benefits, sick leave, health care schemes and pension. Finally, women also sometimes do not enjoy the right to rest and leisure as part of the international core labour standards. Women often do not enjoy this right because they must balance their paid work and their unpaid care work when they return home.

Women, unpaid work, unpaid care work and food security

The draft rai principles do not include unpaid work and unpaid care work which consumes much of women smallholder farmers time. Unpaid care work includes all those activities that go towards caring for a household such as cooking, cleaning, collecting water and firewood, and caring for the ill, elderly, children and voluntary community work. This work is not reflected in national statistics or economic analyses and is perceived to be less valuable than paid work. Many of the women in Africa are not in formal employment and would thus require measures to address the unpaid work and unpaid care work which consumes most of their time. Action Aid studies in 2012 revealed that men spent more time on paid work than women. The same studies also revealed that women spent more time on child care and housework.7 In some countries, Uganda, Kenya, Nigeria and Nepal, the studies also found that women had no time for paid work and only shared their time between subsistence agricultural and unpaid care work. Other studies indicate that in sub-Saharan Africa 71 per cent of the burden of collecting water for households falls on women and girls, who in total spend 40 billion hours a year collecting water 8. Such gender inequalities are not unique to the studied areas and reflect a common pattern in many African

7 www.actionaid/unpaid care work



http://www.actionaid/unpaid


countries. Unpaid cares work if not addressed can limit the amount of time that can be invested in agricultural activities. It can also be a hindrance for women to enjoy their rights to paid work, participate in local governance and decision making in farming and participation in other agricultural activities such as marketing outside the home.

Responsible agricultural investments must therefore adopt a holistic approach which recognises paid work, unpaid work, unpaid care work as well as specific forms of discrimination that women face in regards to access to productive resources. This should be reflected in Principle 2 with the inclusion of women’s empowerment among the objectives and detailed measures to address women’ specific needs and constraints.

Increased investment in climate resilient sustainable agriculture:

ActionAid and many other NGOS and farmer organisations have frequently emphasised the links between building on local knowledge, biodiversity and seeds as crucial strategy for successful investment in agriculture, with particular advantages for women farmers. Investments in smallholder agriculture must be hardwired to build both sustainability and climate resilience, by adopting “Sustainable approaches that aim to maintain healthy soils while reducing reliance on external ‘inputs’ such as fertilisers, pesticides and herbicides. Sustainable agriculture encompasses approaches such as agro-ecology, low external input, agro-forestry, organic agriculture, integrated crop and pest management and water harvesting in dry land areas… As it relies on local renewable resources and locally-based innovation, sustainable agriculture is particularly well-suited to poor, remote or marginalised communities… High-input farming, largely based on chemical fertilisers and pesticides, accounts for an estimated 15% of global emissions of greenhouse gases (GHG) such as carbon dioxide, nitrous oxide and methane. At the same time climate change is projected to have a devastating impact on food production and food security. Agro-ecological techniques can significantly cushion the negative impacts of climate change and develop resilience in the farming system.” 9

Responsible agricultural investment should support agro-ecology principles and practices, and the need to increase investment into agro-ecology on various aspects of agricultural system including research and extension, is thus another distinctive feature of its policy principles. Responsible investment should provide guidance for policy action to re-orient public agricultural research systems towards sustainable and climate resilient farming systems. Hence, the existing global, regional and national research systems should be reformed to shift their focus to sustainable methods and technologies. Farmers’ knowledge and experience, and the work of CSOs and non-governmental think tanks should be respected and integrated into the research systems. Their rights should be safeguarded against land use

8 12 The Millennium Development Goals Report 2012 (United Nations publication, Sales No. E.12.I.4).

9 ActionAid International. June 2011a.




changes that have negative ecological impact. The outcomes of research and the innovations should be freely available to smallholder farmers without any constraints of copyrights or patents.” 10

Priority to local markets and farmers rights throughout value chain

Given the inequalities in power that exist within the global food system between (particularly small) producers and commodity buyers, food manufacturers, processors and retailers, ActionAid is largely critical of the dominant model of commercial agriculture production and trading. The organisation has concerns about the documented lack of benefits that can accrue to smallholders engaging in international value chains via arrangements such as contract farming and outgrower schemes.

ActionAid recognizes that under certain prerequisite conditions which set a high bar, smallholders and women may benefit from engaging in global supply chains as contractors/ outgrowers. These conditions include formalisation of women’s land tenure rights, and/ or joint titling/ community titling, government-backed efforts to encouraging sustainable crop production, securing women’s control over incomes, legal enforcement of contracts, ensuring access to credit, markets and extension services, and increased institutional capacity for collective action. There are examples around the world where such requirements have been fulfilled (often but not exclusively in fair trade schemes), and thus where smallholders are genuinely benefiting.

Indeed, there seems to be mounting evidence from around the world that investing in alternatives to the mainstream agri-food system offers enormous potential for smallholders in general to earn a better livelihood from farming. This was noted by the recent report on agricultural investments by the High Level Panel of Experts and the CFS, who remarked:

“Through the construction of new infrastructures and new institutional arrangements that link producers and consumers, new market segments are being created that are nested in the general markets…. This occurs, for example, for high-quality food products, regional specialties, fresh and local products, agro-tourism services, “green energy”, care services, maintenance of landscapes and nature, and the production of biodiversity. By carefully “nesting” the corresponding flows and transactions, a wide range of mutual benefits can be generated. According to a comparative European research programme (IMPACT), the estimated extra net added-value generated through these new markets amounted in 2000 to some 6 billion euro for Ireland, the United Kingdom, the Netherlands, France, Germany, Italy and Spain together. Nested markets also abound in China… Brazil also offers some very interesting forms, some created by smallholder movements (like ECOVIDA), others created by the state (PAA)”.11 Finally, the United States Government is also supporting regional food markets known as "food

10 ActionAid International. June 2011a.

11 HLPE. 2013.




hubs" for small farmers12, which represent the kind of public investment in smallholder marketing that should be supported in other countries as well.

The principles should therefore aim at removing perverse incentives for unsustainable, unjust and inequitable agricultural systems; e.g. via reorienting agriculture ministry budgets, scrapping tax breaks for big agribusiness, redirecting subsidies for agrichemicals to more sustainable forms of farming, enhancing of alternate market access and value chains where smallholders are in greater control and their rights are secured.

Land rights

Investment should respect legitimate tenure rights of women, smallholders and indigenous communities as pre-condition for them being responsible. In addition to recognize the free, prior and informed consent for indigenous communities, the principles should clearly demand States to introduce provisions which prohibit large-scale appropriation of land, water and other natural resources, and impose maximum limits on the quantity of these resources that private investors (domestic and foreign) can control or own…”13. Challenging governments to prove that any new land acquisitions will do no harm and are the best long term option before giving them the going ahead, and to enshrine the rights of vulnerable groups to land first and foremost.The rai principles should discourage large-scale land acquisitions by international investors; recommend careful public scrutiny and screening of potential human rights abuses for all new land investments; and ensure that land investments do not compromise access to land for smallholders, women, fisherfolk and forest dwellers.

3) Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the principles?

This part is probably the weakest one as it doesn’t address properly the different roles and responsibilities of the different stakeholders, without taking into account the power imbalances among different factors such as smallholders and foreign companies for example. When entering into the terrain of market environment, we cannot ignore this power imbalances and states have the responsibility to create the fair conditions for the most vulnerable. We also recommend one single part on roles and responsibilities. Here the different investors should be differentiated in their different roles and responsibilities. We recognize that roles and responsibilities should be grouped by actor and not by principles, to avoid repetition and redundancy.

Under the section in which states are encouraged to take specific actions, this particular concern should be addressed in the following way:

12 http://www.ams.usda.gov/foodhubs

13 Cited in: HLPE, 2011.




by adding a recommendation at the top to develop national regulatory and institutional frameworks to facilitate and promote small holder farmers and regulate private investors so as to improve both local and global food security and nutrition

taking into account power imbalance when the state is encouraged to provide service and incentives, non-discriminatory access to investment opportunities and productive resources, to promote a competitive and transparent market environment “for all investors”, and encourage investment policies that promote smallholders investment first, and regulate and channel foreign investment consistent with these principles.

by putting major emphasis in agroecology as the viable solution already practiced by many smallholders to foster productivity while preserving the environment and the natural resources base.

Under the section dealing with investors responsibilities, the principles cannot ignore the different impacts irresponsible investment by larger companies are having on tenure rights and livelihoods of communities. In addition to the respect of human rights obligations, private investors, especially large companies, should apply the standards set by the Voluntary Guidelines on responsible governance of tenure of land, fisheries and forests with regard to investment, and these standards should be spelled out more clearly such as :

ensuring transparency of negotiations and contracts and adequate access to information related to investment.

assessing the positive and negative effects of the investment through impact assessments introducing appropriate safeguards such as parliamentary approval for investment exceeding a

certain scale engaging in a proper process of participation and consultation with those affected under the

guidance of the national state and apply the principle of free, prior and informed consent for indigenous communities.

28. Subhash Mehta, Devarao Shivaram Trust, India

A policy for agriculture and rural investment:

This policy brief on agriculture and rural development is aimed to make agriculture and rural producer communities sustainable in the long term. It would not only avert the impending food,nutrition and health crisis but also improve security, climate risks whilst increasingly reduce the subsidies of the Governments in the next one decade.

In the light of the increasing evidences from across the world in support of integrated ecological agriculture for sustainability, the policy in line with the best of understanding of making agriculture and rural communities sustainable. It is also substantiated by various practices, policies and declarations from different national and international organizations. A few of them are cited below:




1. According to FAO,http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Factsheet_SMALLHOLDERS.pdf,Smallholder family producer communities,http://www.un.org/en/development/desa/policy/wess/index.shtml, 50 percent women, provide up to 80 percent of the food supply in South Asia, are productive, drivers of change and given the resources could increase farm production by 20 – 30 %. They mostly follow their low cost ‘Agro Ecological, climate-resilient agriculture’, primarily for meeting the producer communities own ‘Food, Nutrition, Health andCash’ needs. A few examples are cited below:

1. Nava Jyoti, Orissawww.navajyoti.org,2. One village. 60 millionaires, the miracle of Hiware Bazar, Maharashtra, the suicide State of India,http://www.tehelka.com/story_main54.asp?filename=Ne201012VILLAGE.asp3. Panchavat Academy, Kuthambakkam (34 miles from Chennai),Website: www.modelvillageindia.org4. The System of Crop Intensification (SCI) -http://independentsciencenews.org/un-sustainable-farming/how-millions-of-farmers-are-advancing-agriculture-for-themselves/,now being followed by millions of prosperous farmers worldwide,5. Protect Water Quality, Replenish Aquifers and Saves the Soil:http://www.i-sis.org.uk/How_Farmers_Can_Protect_Water_Quality.php,6. Increasing ‘Cropping System Diversity’ balances productivity, profitability and environmental health, a USDA and Univ of IOWA case study,http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0047149,These systems ensures the producer communities’ access to nutritious food, reduces hunger, malnutrition, poverty, suicides and the effects of climate change, whilst improving rural livelihoods, increasing net incomes and purchasing power, thus making their country sustainable in the long term and the key to agriculture contributing substantially to the country’s security and economic growth, Coventry report as attached. Thus, the emphasis should be on low cost economies of scope integrated agriculture system, as applicable to the soil and agro climatic condition of each area (cereals, horticulture, animal husbandry, aquaculture, water harvesting, etc.), water harvesting, producing seed, energy, inputs on farm /locally and minimizing demand for water, energy, etc., over the years.In contrast, as we know, that the green revolution technologies require increasing quantities of the high cost seeds, agro chemicals, water, etc., year after year, reducing the net incomes/purchasing power of the producer communities and which have and will continue to have disastrous effects on climate change/drought, the soil and their long term sustainability. Briefly: a. Agriculture Policy: needs to take a clear direction towards sustainable agriculture for minimizing the risks of the farmers and increasing risks of climate change .Some of the key areas of intervention that the policy needs to cover are on farm/agro forestry, kitchen garden, fodder cultivation, cattle shed, kitchen gardens, in-situ water conservation, bio-villages, action research and codification of science of sustainable agriculture, facilitate training of sustainable agriculture with the help of locally successful sustainable agricultural farmers. This also means that policy should develop a clear time plan to exit from the external input based industrial agriculture. (Nayak. 2014. Baseline Study on Sustainable Agriculture in India)



http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0047149

http://www.i-sis.org.uk/How_Farmers_Can_Protect_Water_Quality.php

http://independentsciencenews.org/un-sustainable-farming/how-millions-of-farmers-are-advancing-agriculture-for-themselves/

http://independentsciencenews.org/un-sustainable-farming/how-millions-of-farmers-are-advancing-agriculture-for-themselves/

http://www.modelvillageindia.org/

http://www.tehelka.com/story_main54.asp?filename=Ne201012VILLAGE.asp

http://www.navajyoti.org/

http://www.un.org/en/development/desa/policy/wess/index.shtml

http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Factsheet_SMALLHOLDERS.pdf

http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Factsheet_SMALLHOLDERS.pdf


b. Institutional Architecture: To make the sustainable agricultural policy work among the smallholder producer communities, an appropriate institutional architecture needs to be set up to deliver both ecosystem services and effectively deal with the pre harvest and post harvest needs of the small and marginal farmers (Nayak, 2014. Baseline Study on Sustainable Agriculture in India). c. Following Integrated Agriculture System of the area shall be given the predominant role it deserves in our agrarian society, with the emphasis on self sufficiency for the producer communities’ meeting their own nutrition, food, health and cash requirements. Adequate land area shall be identified & reserved for agriculture and allied activities, and such lands shall not be diverted to any other activities except under very rare circumstances for which the consent from the concerned state legislature and the parliament shall be obtained after due diligence in establishing the critical national need for such a diversion.

d. With more than 60% of the population in the country being smallholder rural producer communities, depending on activities associated with agriculture, but contributing only about 16% of GDP from agriculture, there is an urgent need to refocus on fundinginnovative agriculture research for development (IAR4D) and meeting all their needs, making this the backbone of our economy and thus substantially increasing agriculture’s contribution to the national economy.

e. Adequate funding, support and encouragement for converting to the integrated agriculture system and allied activities ( producing inputs, value addition to increase the shelf life of the produce, storage and minimizing post harvest losses) shall be ensured in order to produce enough nutritious food (horticulture, grains, dairy produce, etc.,) for their own and the growing requirements of the people in the vicinity on a long term sustainable basis and thus minimize the cost of transportation and pollution (climate change), eradicating import of food grains. In order to develop and implement sustainable practices the effective involvement of various stake holders such as CSO/ NGOs, successful farmers following their low cost integrated agriculture system and agricultural institutions should beensured in the policy/decision making levels.

f. Focus on low cost economies of scope staple crop of the area such as ragi and other millets and following the integrated agriculture systems which are suitable for dry/ arid regions of the country should be encouraged, not just the high cost economies ofscale mono crops like rice and wheat green revolution technologies, which requires increasing quantities of water, seed, fertilizer and other agro chemicals each year and closely associated with Climate Change/ Global Warming as is the case now.

g. Vast varieties of native fruit species such as banana, jack fruit, mango, guava, pomegranate, orange etc. have huge potential to reduce the dependence on water intensive agricultural crops, and hence should be encouraged fully and as part of the integrated agriculture system.

h. Many varieties of tree species which can become perennial source of fodder, bio mass, etc., additional income to our farmers through bio-fuel and/or timber value potential, and which are also environmentally friendly should be encouraged as fencing crops, andalso on barren lands and as an integral part of their integrated agriculture system.

i. In view of large areas of arid and semi arid areas in many parts of the country, widespread use of water harvesting for scientific dry land farming practices such as millets, horticulture, perennials, etc., should become an important part of agrarian economy.




j. In order to make agriculture a viable/ attractive option in rural India, human and institutional capacity should be developed adequately in women and educated youth being trained to become general practitioners in agriculture to shoulder the entrepreneurial risks and responsibilities, with good roads, telecommunication, health, andeducation facilities.

k. Agricultural produce/ products should be produced primarily for meeting the nutritious food needs of the rural producer communities, accessible to them at farm gate price, value addition for storage and release when prices peak, if we are to make the rural life meaningful through the intervention of the producer communities setting up their producer org/ company (PC) but staffed with professionals, to manage the ‘cash to cash cycle’ of each member.

Mainstreaming Agroecology: Implications for Global Food and Farming Systems Discussion Paperhttp://www.fao.org/fsnforum/sites/default/files/resources/Agroecology%20Coventry%20report%202013_WEB_0.pdf

Veuillez trouver ci-joint la réponse du Groupement interministériel sur la sécurité alimentaire (Gisa, http://www.gisa-france.fr/presentation-du-gisa) à la consultation électronique sur l'avant-projet pour des investissements agricoles responsables.

Cordialement,

Please find attached comments of the French Interministerial group on Food security (Gisa, http://www.gisa-france.fr/presentation-du-gisa) to the e-consultation on Principles for Responsible Agricultural Investments.

Best regards,

Ségolène HALLEY des FONTAINESConseillère agricole, Représentation permanente France

29. Groupe Interministériel sur la Sécurité Alimentaire, France

[French version]

Réponse à la consultation électronique portant sur le draft zéro des Principes pour des investissements agricoles responsables

Le GISA tient tout d'abord à rappeler ses travaux déjà conduit sur la question (cf papier de juin 2010« appropriation de terres à grande échelle et investissement agricole responsable pour une approche garante des droits de l'homme, de la sécurité alimentaire et du développement



http://www.gisa-france.fr/presentation-du-gisa

http://www.gisa-france.fr/presentation-du-gisa

http://www.fao.org/fsnforum/sites/default/files/resources/Agroecology%20Coventry%20report%202013_WEB_0.pdf

http://www.fao.org/fsnforum/sites/default/files/resources/Agroecology%20Coventry%20report%202013_WEB_0.pdf


durable»), dont les principes énoncés restent d'actualité. En particulier :

le respect des droits des usagers du foncier qu'ils soient formels ou informels doit être un préalable aux investissementsla compatibilité des usages privés avec l'intérêt général se doit d'être assurée dès lors que la sécurité alimentaire est considérée comme un bien public mondial.

Concernant l'avant projet (« draft zero »), il soulève les commentaires généraux suivants :

S t ruc t ure du docum e nt : Plusieurs propositions intéressantes de restructuration du document ont été faites au cours des consultations (UE, MSC, Oxfam...). Le GISA partage l'idée que la structure devrait en effet être revue afin de faciliter la lecture et l’utilisation du document. La nouvelle structure devrait faire ressortir les deux axes suivants :

mettre davantage en valeur les principes énoncés, qui devraient être plus expliciteset d'autre part mieux préciser les rôles et responsabilités des acteurs, en les

détaillant non pas selon chaque principe mais selon les différentes catégories d’acteurs.

Les aspects de mise en œuvre et de redevabilité doivent être dûment inclus, y compris le suivi par le CSA. L'inclusion de quelques définitions (en reprenant les définitions utilisées notamment dans les Directives volontaires) serait également utile.

Les p r i nc i pes én o ncés : Le langage utilisé est souvent trop faible en comparaison d'autres textes déjà agréé (VGGT, Principes directeurs des Nations Unies relatifs aux droits de l’homme et aux entreprises et les principes directeurs de l’OCDE à l’intention des entreprises multinationales). Le texte doit être renforcé dans son niveau de langage, en intégrant au besoin directement le langage utilisé dans les textes de référence (droits humains, VGGT…) :

L'avant projet ne mentionne pas suffisamment clairement pour chaque principe ce qu’un investissement responsable « n’est pas » (responsible investment « should not harm »....). Par exemple un investissement responsable

ne devrait pas porter atteinte aux droits des populations locales et tout particulièrement au droit à l’alimentation, et aux droits fonciers légitimes.

ne devrait pas avoir d’impacts négatifs sur les ressources naturelles(assurer la sécurité alimentaire dans la durée)

ne devrait pas alimenter les conflitsne devrait pas transiter via des paradis fiscaux et

judiciaires

Un principe devrait clairement être dédié au respect des droits des usagers du foncier qu'ils soient formels ou informels comme préalable aux investissements. Il conviendrait de reprendre pour cette question essentielle les principes agréés dans les VGGT– en particulier au point 3.2 et dans l’ensemble de la section 12 relative aux investissements –A savoir :

reconnaître et respecter tous les détenteurs de droits fonciers légitimes et leurs droits.Assurer la transparence des négociations et des contrats, ainsi qu’un accès aux informations relatives à l’investissementÉvaluer les impacts positifs et négatifs de l’investissement au travers d’études d’impact




Inviter à introduire des garanties supplémentaires comme un vote par le parlement pour tout investissement dépassant une certaine surfaceMettre en place une consultation sur la base d'une participation libre, efficace, utile et en connaissance de cause (et veiller au respect du principe FPIC pour lescommunautés indigènes)

Il conviendrait d'intégrer les principes inscrits dans les nouvelles normes qui ont vu le jour depuis 2010 en matière de conduite responsable des acteurs économiques.◦ En particulier, tous les textes (à la fois les normes publiques et privées) convergent sur la

notion de diligence raisonnable, à savoir le devoir qu‘ont les entreprises d’identifier, prévenir et remédier aux impacts réels ou potentiels découlant de leurs activités.

◦ Les Nations unies, l’OCDE et l’ISO vont même plus loin, en intégrant la notion de« relation d’affaire » et de « sphère d’influence » : ces principes instaurent une coresponsabilité de l’entreprise en cas de violations aux droits humains ou àl’environnement provoquées par une autre entités mais en lien avec les activités de l’entreprise.

◦ A signaler également l’appel des textes internationaux pour que les Etats jouent pleinement leur rôle de protection des citoyens des atteintes pouvant découler des activités du secteur privé, y compris en adoptent des textes législatifs visant à instaurer des sanctions et les mesures nécessaire à garantir l’accès à la justice par les victimes.

L'avant projet, conformément aux termes de référence, devrait aller plus loin et fournir des conseils sur les objectifs supplémentaires que devraient poursuivre les investissements« responsables » à savoir, au delà de la rentabilité économique, contribuer à la sécurité alimentaire et nutritionnelle, au développement social, économique, respecter les normes detravail de l'OIT, encourager les investissements qui promeuvent l’égalité hommes/femmes

Dans le même ordre d'idée, les investissements responsables doivent permettre la diffusion de modèles innovants, d’alternatives répondant à l’ensemble de ces enjeux.

En matière de production agricole, l’agroécologie devrait dans ce sens être explicitement mentionnée dans ce document et encouragée.

De même, il conviendrait d'introduire l'idée de contractualisation, en insistant sur la nécessité de veiller à l'existence de contrats équilibrés entre les agriculteurs (ou leurs Organisations Professionnelles) et les autres opérateurs, en particulier d'aval, pour limiter le pouvoir de marché et répartir les risques entre les différents acteurs : un investissement responsable ne devrait pas rendre les agriculteurs dépendants des investisseurs, ni faire porter l’intégralité des risques sur les agriculteurs.

Il convient d'appeler plus clairement à la mise en place d'un environnement favorable aux investissements responsables, qui soit à la fois régulé, sécurisé, et stable : sécurisation et stabilité des cadres juridiques, politiques publiques adaptées (notamment agricoles, fiscalité, formation, renforcement des capacités... Ainsi, le texte devrait être mettre un accent plus fort sur l'importance de la sécurisation juridique, notamment la transparence et la stabilité des procédures légales, essentiels pour encourager les investissements responsables, ainsi que la lutte contre la corruption.




La mise en place d'un environnement favorable aux investissements responsables, et la stabilité et la sécurisation des cadres juridiques ne doivent pour autant pas se traduire par un

statu quo mais bien par l'intégration d'un cadre de responsabilité des investisseurs dans la législation nationale. Il convient ainsi de souligner que favoriser les investissements ne devrait pas conduire à mettre en place des cadres législatifs (fiscalité, foncier...) assouplis au profit de certains acteurs et qui remettraient en cause in fine les droits des populations locales et les principes d'équité.

La fiscalité mérite d'être davantage traitée : des cadres fiscaux incitatifs au plan économique doivent également permettre une rentrée fiscale pour les Etats et garantir une équité. La transparence fiscale est aussi essentielle.

Concernant le principe 5, les principes rai devraient très clairement énoncer le principe de« cohérence des politiques pour le développement ».

Rôles et responsabilités des acteursL'avant projet ne distingue pas suffisamment les rôles et responsabilités relatives des différents acteurs. Il conviendrait en particulier d'inclure une différenciation des différents types d’investisseurs (publics, privés, différenciation parmi les privés). Les textes internationaux reconnaissent aujourd’hui différentes catégories d’acteurs au sein du « secteur privé » :◦ Les multinationales (avec des principes directeurs des NU et de l’OCDE qui leurs sont

spécifiques)◦ Les petits producteurs, (cf la Table Ronde du CSA 2013 « Investing in smallholder

agriculture for food security and nutrition, dont les recommandations spécifiques pour ces acteurs pourraient nourrir cette partie).

De la même manière, l'avant projet élude la question de l'articulation des investissements (notamment publics et privés, et entre privés de différentes types et taille). Un des objectifs visés devrait ainsi être de promouvoir des approches assurant que l’investissement contribue à la sécurité alimentaire des populations locales : les différents types d'investisseurs peuvent utilement articuler et coordonner leurs interventions (à titre d'illustration l'Etat a besoin des entreprises, des agriculteurs, des agences de services, de formations..., qui ont quant à eux besoin de l'Etat).

Les investissements directs dans la production par les producteurs familiaux peuvent bénéficier d'investissements d'acteurs de plus grande taille ailleurs dans la chaine de valeur (fourniture d'intrants, transformation...) qui à la condition de s’inscrire dans un cadre de responsabilité claire, peuvent permettre de fournir des débouchés ou de limiter les pertes. Tous les types d’investissement ne doivent pas être encouragés de la même manière. Le rôle des exploitations familiales doit être dûment reconnu, et ceux ci doivent être dûment encouragés en tant que premiers acteurs de la sécurité alimentaire.

Les Etats devraient être appelés à mettre en place des cadres juridiques sécurisés et des politiques appropriées. Le rôle de l’Etat est donc essentiel en tant que régulateur. Il l'est également en tant qu’investisseur public.




Le rôle du secteur bancaire (crédit, en particulier au profit des petits investisseurs). Il est également important de noter le rôle que peut avoir ce secteur en matière d’investissement irresponsable (notamment fonds d’investissements spéculant sur du foncier agricole, paradis fiscaux et judiciaires,…)

L'importance des acteurs en charge de la formation/vulgarisa

[English version]

GISA would first like to recall the work which it has already carried out on this issue (see the June 2010 position paper “Large-scale land-acquisition and responsible agricultural investment: for an approach respecting human rights, food security and sustainable development”), the principles of which remain relevant. In particular:

respect for land users’ rights, whether formal or informal, must be a precondition for investments

compatibility of private uses with the general interest must be ensured as food security is deemed to be a global public good.

The preliminary draft (“Zero Draft”) raises the following general points:

Document structure: Several interesting proposals to restructure the document were made during consultations (EU, International Food Security and Nutrition Civil Society Mechanism (CSM), Oxfam). GISA agrees that the structure should indeed be reviewed to help make the document easier to read and use. The new structure should focus on the following two areas:

place greater emphasis on the stated principles, which should be more explicit and define more clearly the actors’ roles and responsibilities, not by detailing them

according to each principle but based on the different categories of actors.

Implementation and accountability aspects must be featured, including the monitoring by the Committee on World Food Security (CFS). It would also be useful to include some definitions, especially those used in the Voluntary Guidelines.

The stated principles: The language used is often too weak compared to other texts which have already been approved (VGGT, United Nations Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises). The text must be strengthened in terms of its level of language by directly including where necessary the language used in the reference texts (human rights, VGGT):

The preliminary draft does not explain sufficiently clearly for each principle what responsible investment “should not do”: For example, responsible investment

o should not harm the rights of local populations, in particular the right to food and legitimate land rights.

o should not negatively impact natural resources (ensure long-term food security) o should not fuel conflicts




o should not use tax and legal havens

A principle must clearly focus on respecting land users’ rights, whether formal or informal, as a precondition for investments. For this essential issue, we should recall the principles agreed in the VGGT - particularly in point 3.2 and throughout section 12 regarding investments - i.e. :

o Recognize and respect all legitimate land rights holders and their rights. o Ensure the transparency of negotiations and contracts as well as access to investment-

related informationo Assess the positive and negative impacts of investment via impact studieso Propose introducing extra safeguards such as a parliamentary vote for all investments

exceeding a certain scaleo Put in place consultation based on free, prior and informed consent (FPIC) (and ensure

that the FPIC principle is observed for indigenous communities)

We should include the principles included in the new standards created in 2010 regarding the responsible conduct of economic actors.

o in particular, all the texts (both public and private standards) agree on the notion of due diligence, i.e. companies' duty to identify, prevent and resolve the real or potential impacts of their activities.

o The UN, OECD and ISO go even further, including the notion of “business relationship” and “sphere of influence”: these principles instil co-responsibility in companies in the event of human rights or environmental violations caused by another entity but linked to the company's activities.

o We must also highlight the appeal in international texts for States to play a full role in protecting their citizens from abuse which can arise from private-sector activities, including by adopting legislative texts aiming to impose sanctions and the necessary measures to ensure that victims have access to justice.

The preliminary draft, in accordance with the terms of reference, should go further and provide advice on the extra objectives which "responsible" investments should pursue, i.e. beyond economic profitability, contributing to food and nutritional security, social and economic development, respecting the ILO’s labour standards, encouraging investments which promote gender equality.

In the same vein, responsible investments must enable innovative models and alternatives which meet all these issues to be distributed. As regards agricultural production, agro-ecology should to this end be encouraged and explicitly mentioned in this document.

Similarly, we should introduce the idea of contractual arrangements, emphasizing the need to secure balanced contracts between farmers (or their professional organizations) and the other operators, in particular those downstream, in order to limit the power of the market and spread




the risks among the various actors: a responsible investment should not make farmers dependent on investors, nor make them carry the full weight of the risks themselves.

We should make clearer appeals to create an environment which is conducive to responsible investments, which is both regulated, secure and stable: safeguarding and stability of legal frameworks, suitable public policies (in particular agricultural, tax, training, capacity building, etc.). In that way, the text should place more emphasis on the importance of legal safeguards, including the transparency and stability of legal procedures, which are essential to encourage responsible investments, as well as the fight against corruption.

The creation of an environment conducive to responsible investments and the stability and safeguarding of legal frameworks must not, however, lead to maintaining the status quo but rather to the inclusion of an investor responsibility framework in national legislation. We should also highlight that encouraging investments should not lead to the establishment of relaxed legislative frameworks (tax, land, etc.) for the benefit of certain actors, which would ultimately call into question the rights of local populations and the principles of equity.

More attention should be paid to taxation: economic tax-incentive frameworks must also produce tax revenue for States and ensure equity. Tax transparency is also essential.

As regards principle 5, the Principles for Responsible Agricultural Investment (RAI) should very clearly state the principle of "Policy Coherence for Development".

Actors’ roles and responsibilities The preliminary draft does not sufficiently distinguish between the roles and relative

responsibilities of the various actors. In particular, we should include a differentiation of the different types of investors (public, private, differentiation among the private ones). The international texts today recognize different categories of actors within the "private sector":

o Multinationals (with their specific UN and OECD Guiding Principles and Guidelines)o Smallholders (see the Committee on World Food Security (CFS) 2013 Policy Roundtable

on Investing in Smallholder Agriculture for Food Security and Nutrition, whose specific recommendations for these actors could fuel this part).

Similarly, the preliminary project sidesteps the issue of linking investments (especially public and private, and between private investments of different types and sizes). One of the objectives should thus be to promote approaches ensuring that the investment contributes to the food security of local populations: the different types of investors can effectively link and coordinate their work (e.g. the State needs companies, farmers, service agencies, training, etc. and they in turn need the State).

Direct investment in production by family producers can benefit from investments from larger actors in other parts of the value chain (provision of inputs, processing, etc.) which, provided that they are part of a clear accountability framework, can help to provide openings or limit losses.




Not all types of investment should be encouraged in the same way. The role of family farms must be duly recognized and they must be encouraged as the primary actors in food security.

States should be asked to establish secure legal frameworks and suitable policies. The State thus has an essential role to play as a regulator and public investor.

The role of the banking sector (credit, in particular for the benefit of small investors). It is also important to note the role which this sector can have as regards irresponsible investment (including investment funds speculating on farmland, tax and legal havens, etc.).

The importance of actors responsible for training/outreach is not sufficiently highlighted.

30. Jean Paul Beens, Belgium

As member of the Private Sector, I welcome the clear objective of this zero draft i.e. the promotion of responsible investments in agriculture and food systems, contributing to food security and nutrition. These principles for responsible agricultural investments, irrespective of their voluntary character, already are and certainly will become a cornerstone document upon which the foundation of an enabling environment for improved agriculture, meeting the challenges and achieving the objectives ahead, will be build. Such construction will require the efforts of all stakeholders involved, beit operative within the whole agricultural supply chain itself as well as those surrounding it. Inclusion of all stakeholders contributing through their size, age, gender, authority, culture, experience and expertise will mitigate the risks of failure and as teamwork enable sustainable success. The private sector is engaged and committed to provide its best skills and expertise and calls upon all other stakeholders to join in a similar way.

Whereby the sheer magnitude, diversity and width of the food security challenge and its mitigating agricultural investments would scare away and confuse any single stakeholder on his/her own, the structure of this zero draft in clear issues, rationale, objectives and first application advice as well as indicative role and responsibility/capability allocations, provide a roadmap and first necessary guidance for combined stakeholders’ approach. Like with any trip planner or navigation tool, regional and local implementation of the roadmap will require all stakeholder’s dialogue and agreement on how to overcome road blocks and prioritize the waypoints, all in compliance with local laws and regulations. Despite this complexity, the Zero Draft is there to provide overall orientation and guidance on issues, assuring movement in the right direction.

31. Katy Lee, International Agri-Food Network, Italy

Dear all,




I originally made a contribution on 13th Jan and I have been moved to write again given the richness of the debate that has ensued!

Great to read others echoing thoughts on the importance of grain transportation and storage as a focus for investment. Likewise, there have been comments on innovation too, which will be important.

In particular I liked Jean-Paul Been's analogy of a 'trip planner or navigation tool', as this gets to the heart of the potential of the document to provide real guidance to a great many actors.

As we are in the final few days of the E-consultation, with the Latin American and Caribbean regional meeting taking place in Panama, I would like to include some final thoughts from the IAFN position paper (http://www.agrifood.net/wp-content/uploads/IAFN_PositionOnRAI.pdf)

Economic and social impacts:

- Investment, foreign and domestic, should be encouraged as a vital source of capital as well as a driver for increased productivity in the national market, and as a source of significant secondary job creation. Investments should be assessed against their potential to deliver these economic benefits.

- Investors should ensure that projects respect the rule of law, reflect industry best practice, and result in durable shared value. (Principles of Responsible Agricultural Investment)

- Investments should generate desirable social and distributional impacts and should not increase vulnerability. (Principles of Responsible Agricultural Investment)

Cultural impacts:

- Consumers should have choice in their food and should have access to a diverse, nutritious diet. - Projects that add value to food in-country are advantageous. - Principles in support of enabling environment

Governance structures, review mechanisms and decision making processes to enable and facilitate responsible agricultural investment (based on VG GT section 3A, 3B,4 and 7):

- Domestic markets and foreign investment require the same conducive operating environment, including: peace and stability, the rule of law, good governance with accountability and transparency, the absence of corruption, adequate infrastructure, an educated workforce, clear property rights, open markets and trade, and enforceable contracts.

- Governments should prioritise putting those elements of a conducive operating environment in place to help attract quality domestic and foreign investments. - Guidelines and rules for investment should be clearly stated and easily available to encourage

transparency and accountability.



http://www.agrifood.net/wp-content/uploads/IAFN_PositionOnRAI.pdf


- States should ensure that all actions are consistent with their existing obligations under national and international law, and with due regard to voluntary commitments under applicable regional and international instruments (VGGT 12.1)

32. Cathleen Kneen

1) Responsible investment needs to be clearly defined. Rather than saying that responsible investment results in certain positive outcomes, as in the first Principle, it needs to be stated that “investment is responsible when it [fulfills certain criteria]”. This should be repeated for all of the criteria mentioned in the Principles.2) The elements of responsible investment include:a) Consultation with, and the free, prior and informed consent of, the people and communities affected before any investment is implemented.b) Inclusion of women, indigenous, farm workers, migrants, and food harvesters as full participants in all negotiation processes, with respect for their perspectives and knowledge.c) Focus on sustainability and resiliency over productivity, particularly as measured by market norms.d) Promotion of positive environmental impacts and resilience in relation to climate changee) Privileging investment by families and communities in their own food systems with the goal of increasing their own long and short-term food security, as opposed to those made by outside bodies whether state or corporate.f) Respect for the rights conferred on traditional people by their commitment to take responsibility for their territories, even where legal title is in dispute or does not exist.3) The protocol must apply equally in wealthy “developed” countries along with poor countries, regardless of the source of the investment.4) Since the protocol is voluntary and non-binding, there must be stringent monitoring and effective sanctions for non-compliance.5) These principles must be respected and upheld in the trade and investment agreements signed by states with other states as well as with private entities.(I might add that, as was pointed out in the North American consultation, the graphic logo, with a smokestack coming out of the globe, is an indication of the industrial, productivist mindset.)

33. Glenn Ashton, Ekogaia Foundation, South Africa

Dear Christina and the CFS-RAI team,

I write as an independent consultant and researcher on food security.

I thank you for the work you have undertaken to date in collating and drafting the Zero Draft principles.




I think you capture the essence of the major concerns regarding the relationship between responsible agricultural investment and food security - and sovereignty - the latter's principles which are not really reflected in this document.

I agree with many of the comments of those who have taken the time to compile quite comprehensive and lengthy contributions to this discussion.

However due to time constraints I really just want to cover one brief but central aspect of this discussion - the proverbial elephant in the room; power and money, the two being essentially indivisible.

It is fine and well compiling an excellent analysis of the state of play and requirements for future food security in the face of growing populations, threatened by climate change and other pressures. However the framing of the discussion skirts the issue of how the important and vulnerable groups - women, indigenous peoples and so on - are proposed to protect themselves in the face of power being wielded against them.

These concerns are writ large in Africa at present (and I am certain are equally embedded in other developing nations around the world) with the expansion of large agricultural land holdings across the continent being supported by both national political players, international agencies and of course the major financial interests that are keen to speculate and control as much fertile land as possible, at minimum outlay.

We can set in place as many MOUs on responsible investment in agriculture as we like but there is an inherent problem that the institutional powers that be - governments and corporate interests - have been led to believe that large scale industrial agriculture remains the solution to international food security. While the zero draft acknowledges the realities of the majority of smallholder and emerging farmers, it does not adequately speak to the challenges of capacity in enabling them to not just be heard and acknowledged as far as their requirements are concerned, but more importantly it fails to take due cognisance of the continued inequity of the positions of often isolated smallholders versus that of those who impose structures, like the privatisation of large land holdings on their traditional lands, usually decided upon in distant boardrooms and legislatures. Even many aid programmes are dominated by large scale, externally driven, technocratic solutions that are often imposed rather than absorbed and adopted by local communities in a truly participatory manner. These inequalities in power and more importantly the projection of power must be addressed if a programme such as this is to have any hope of success.

Certainly this policy document cannot solve these fundamental and systemic challenges at their roots, but it should certainly address them more closely than it presently does. I have a few suggestions that may suggest some ways to provide mechanisms to facilitate ways around this inequity.

Firstly I would suggest that an international clearing house be instituted in order to provide an oversight mechanism. While this would not have any legislative power, it would be able to place problems firmly into the public sphere simply by making them visible. It would be logical to place such an institution




within a body such as the UNFAO or a sub-committee such as this. Such an office could be accompanied with a rapporteur or secretariat that ensures that important information is raised to suitable levels so that it can be properly facilitated, in co-operation with the parties which require assistance.

Secondly readily accessible channels should be made available for reporting to this entity. These would encourage and enable whistle blowing and information sharing about due process, either being followed, or not. This is especially important in the case of nations where governments may lack the will, experience or means to facilitate proper public facilitation such as appears to be occurring in areas in Africa where massive dams and agricultural schemes are being imposed on small, isolated but culture rich populations. The challenges around dealing with the dynamics around these tensions could be facilitated with the assistance of increasing internet and cell phone technology penetration or through other reporting methods that allow greater anonymity, possibly through third party reporting.

Thirdly, these mechanisms of oversight and reporting and assistance, where need be, should be facilitated. Such facilitation should be made able to assist vulnerable populations in navigating these challenges. These could be assisted through already present civil society organisations or again, through institutional linkages with neutral bodies such as the UNFAO.

If these sorts of steps are not put in place the same vulnerable, voiceless communities and sectors - women, marginalised groups, migrants, etc. - will not gain the benefits that this initiative is envisaged to bring, compromising the goals for which it is designed. This is why we need these sorts of linkages - to protect, assist and empower the otherwise silent and powerless.

Excuse me not distilling this down to a shorter bullet point presentation but time constraints force me to submit an unedited version!

RegardsGlenn Ashton

34. Stefan Bringezu, Wuppertal Institut, Germany

Dear colleagues,

I congratulate you to the zero draft. Under principle 3 one could explicitely include under application that it should amongst other issues contribute to "the regeneration of degraded soils".In the accompanying documents you may be interested to include a recent report of the IRP "Assessing Global Land Use: Balancing Consumption with Sustainable Supply." You can download full report, summary and fact sheet here:http://www.unep.org/resourcepanel/Publications/AreasofAssessment/AssessingGlobalLandUseBalancingConsumptionw/tabid/132063/Default.aspx



http://www.unep.org/resourcepanel/Publications/AreasofAssessment/AssessingGlobalLandUseBalancingConsumptionw/tabid/132063/Default.aspx

http://www.unep.org/resourcepanel/Publications/AreasofAssessment/AssessingGlobalLandUseBalancingConsumptionw/tabid/132063/Default.aspx


In the key portfolio of measures the report recommends to develop an investment programme for the regeneration of degraded soils.

Best regardsStefan BringezuProf. Dr. Stefan Bringezu Director Material Flows and Resource ManagementWuppertal Institute P.B. 100480, 42004 Wuppertal, GERMANY

Professor for Sustainable Resource ManagementUniversity of KasselCenter for Environmental Systems Research (CESR)Wilhelmshöher Allee 47, 34117 Kassel, GERMANY

35. Hans Morten Haugen, Diakonhjemmet University College, Norway

I have three comments:

1) The reference to "broader principles and values, including respect for human rights, understood as universal, indivisible, interrelated and interdependent, equity and non-discrimination, gender equality, social inclusion and good governance" on p 2 should be improved.By this wording, the potential of human rights principles are undercommunicated. Human rights principles established minimum standards of conduct in any decision-making process, and this potential is not communicated by the term "broader principles and values". The term "values" should be avoided, and the terms "universal, indivisible, interrelated and interdependent" are more accurately describing the nature of internationally recocnized human rights.My proposal is to use the approach communicated by FAO in several documents and in the Right to Food Methodological Toolbox. For one recent example, see Background Paper 3 to the 2013 International Conference on Forests for Food Security and Nutrition, listing on p 3 "seven human rights principles (known collectively as PANTHER): participation, accountability, nondiscrimination, transparency, human dignity, empowerment, and the rule of law."

2) There should be a reference to the UN Special rapporteur's Guiding principles on human rights impact assessments of trade and investment agreements; A/HRC/19/59/Add.5. These Guiding principles should be much more known and applied.

3)It is positive that there is a reference on p 10 to "Participatory policy- and decision-making based on meaningful consultations and ensuring active, free, effective, meaningful and informed participation of




those who are primarily affected are prerequisite to enable responsible agricultural investments." I have analysed the difference between the terms "effective participation" and "meaningful participation".Moreover, there should be a specification of how to ensure that the most affected are adequately brought into the decision-making process, which might be a problem in cases where local customary law does not provide for the participation of women and young persons. This is addresses in Article 8.2 in ILO Convention 169: These peoples shall have the right to retain their own customs and institutions, where these are not incompatible with fundamental rights defined by the national legal system and with internationally recognised human rights. Procedures shall be established, whenever necessary, to resolve conflicts which may arise in the application of this principle.I refer to my article Deciding on Land and Resources: How to Increase the Influence of the Most Affected Within Communities?’ Human Rights and International Legal Discourse Vol 7, No 2, 260-288, which is attached in a word document (the issue is just out; has not been received)http://www.fao.org/fsnforum/sites/default/files/resources/HRILDAffectedMinoritiesREV.doc

36. Renat Perelet, Russian Academy of Sciences, Russian Federation

Dear Colleagues,

I hasten to sketch out some quick remarks and suggestions that might be useful for you. Here are some of them. I would be prepared to discuss them and some others later if your time permits:p.2, line 2 to add: Communities, consumers, indigenous, and food insecure people.p.4. Principle 2, Rationale, last para to add: Well-defined and duly enforced rights with easements to get access to food resources can encourage...In the section ‘ENVIRONMENT, NATURAL RESOURCES AND CLIMATE CHANGE’, an attitude towards GM food produce should be clearly spelled out.p.6. add to the section “States are encouraged to” the following: - pursue a policy of green procurement, requiring, as a minimum, participation in agricultural tenders companies having ISO 14001 certificates. It is possible that a similar statement could appear in the section beginning with “Investors are encouraged to:”p.7 The section “Research and educational institutions are encouraged to:• place sustainable development of agriculture and food systems, including sustainable productionand processing of nutritious food and nutrition-sensitive agriculture and exploring replacement of traditional edible species with adequately nutritional other ones.In addition, one more principle should be added that would stress a need in international cooperation and mutual enrichment: from bilateral one with neighbouring countries to sub-regional, regional and global one. Here, such areas as international food footprints, virtual water exchanges (imports and exports) could be embarked upon, as well as debt-for-nature swops, burgeoning farm outsourcing activity, cash crops in the developing countries.

Environmentally yours,



http://www.fao.org/fsnforum/sites/default/files/resources/HRILDAffectedMinoritiesREV.doc


Dr Renat PereletResearch Leader, Institute for Systems Analysis,Russian Academy of Sciences, Moscow

37. CIDSE, Belgium

To whom it may concern,

CIDSE, the international alliance of Catholic development agencies (http://www.cidse.org) hereby submits its inputs to the consultation on the Principles for Responsible Agricultural Investments (RAI). Please find the document attached (pdf). http://www.fao.org/fsnforum/sites/default/files/resources/CIDSE%20Submission_CFS%20Zero%20Draft%20Principles%20for%20rai_Feb%202014.pdf

Thanks for acknowledging receipt of this email.

We remain at your disposal for any further information,

Kind Regards,Giulia Bondi Advocacy AssistantClimate Justice and Food, Agriculture and Sustainable Trade

38. Lalita Bhattacharjee, FAO, Bangladesh

Background and rationale

Poor diet affects the poor, middle class and the rich alike. To this end, one of the goals of responsible agriculture investments is producing healthy foods that contributes to sustainable diets and health of individuals, households and the community at large. One of the keys to achieving this is a policy environment in which nutrition is better understood and valued.

Objective, nature and scope

The principles would also need to recognize the role of updated, science- based dietary guidelines that are contextually appropriate and that need to be widely promoted for the renewed attention of policy makers, programmers, private sector, media and the consumers.

This is one of the essential pre requisites to enhance the supply and demand for good food choices from what is locally available and accessible.



http://www.fao.org/fsnforum/sites/default/files/resources/CIDSE%20Submission_CFS%20Zero%20Draft%20Principles%20for%20rai_Feb%202014.pdf

http://www.fao.org/fsnforum/sites/default/files/resources/CIDSE%20Submission_CFS%20Zero%20Draft%20Principles%20for%20rai_Feb%202014.pdf


To this end, dietary assessment including ‘total diet studies’ can help influence food policy, while nutrition education using the results of these studies can stimulate a demand for judicious food choices.

Food Security and Nutrition and the progressive realization of the right to adequate food in the context of national food security: Principle 1

The objectives are well outlined. In addition to improving access to and availability of sufficient, safe and nutritious foods…. there is a need for an explicit focus on improving the diets and nutritional status of young children (6 to 23 months of age), adolescent girls and women in addition to household members and communities on the whole.

Applications would need to also encompasses technical principles such as knowledge, skills, technology and confidence at the farmer’s levels to produce/process foods and reach out to markets; awareness and ability to understand how nutrition-linked investment can have substantial health and financial returns at the trader’s levels; and behavior change strategies for improving food and nutrition on a sustainable basis at the consumer levels.

Scientific documentation and nutrient analysis of indigenous and underutilized foods, seldom used parts of plants and functional foods are warranted.

Economic and social issues: Principle 2

A renewed responsibility is needed among agricultural planners and policy makers to strike a balance between nutrition-linked value chains and an enabling environment for incentives in agriculture investments.

Improved market structures in many of the fast developing countries are changing the way in which people access food. Some of the nutritious crops (millets, whole grains), legumes, horticulture produce, small fish species and beneficial indigenous foods that used to feature in traditional dietaries, are now losing their place in markets in favor of some few and largely produced/ processed foods that are possibly more affordable but potentially less healthy. This is impacting on the diversity and nutritional quality of what is purchased, processed and consumed.

Agriculture investments from private and public sectors can therefore play a more significant role in enhancing a nutritious food supply in the market, which should be initiated right from primary production across the whole chain.

Investments should explicitly address healthy eating habits among children and adults; create access and demand for nutrient/micronutrient-rich local foods, increase vegetable and fruit intake, promote safe and environmentally friendly produce and packaging, nutrition education and enable better nutrient returns for the money spent.

Cultural Issues: Principle 4

Investments should also encompass storage and conservation of seed banks, strengthening/building upon appropriate processing technologies, local small livestock breeds, small fish species and indigenous food systems unique to agro ecological and cultural contexts

Farmers, notably women farmers or women farmer groups should be mobilized as part of mainstream institutional arrangements and mechanisms for both income and nutrition relevant ventures

Consideration should be given to household allocation of resources, capital, knowledge, local agricultural technologies and time.




Policy Coherence and Sector Development: Principle 5

Policy capacity strengthening would be a foremost priority that needs sustained attention. Policy principles and tools that reinforce the nutrition mandate of food and agriculture sectors,

bridge the interface with health sectors, prioritize nutrition sensitive investments[1] with coordinated institutional arrangements for analysis and monitoring policy implementation[2] will need to be developed and elaborated according to country contexts.

This should in turn serve to mobilize and enhance commitment for funding and resource allocation for agriculture investments from governments, development partners and the private sector so as to impact nutrition improvement on a truly sustainable basis.

Lalita Bhattacharjee, Nutritionist, National Food Policy Capacity Strengthening Programme, Food and Agriculture Organization of the United Nations, Bangladesh.

[1] Bangladesh Country Investment Plan for Agriculture, Food Security and Nutrition (2010 -2015)[2] National Food Policy Plan of Action and Country Investment Plan, Monitoring Report 2013, FPMU, Ministry of Food.

39. Gitte Dyrhagen Husager, DanChurchAid, Denmark

This contribution is submitted on behalf of DanChurchAid (DCA); a development NGO working on the right to food with the overall goal to increase access to sustainable food and adequate nutrition for rights-holders.

In response to the overall questions on the Zero Draft of the CFS-RAI principles, DCA would like to underline the following points:

1) Relevance of issues and areas:

DCA welcomes the fact that the right to adequate food is considered a founding base of principles, as mentioned in Principle 1. States’ obligation to protect, respect and fulfill the right to adequate food should continue to be at the core of the principles. In accordance with the VGGT, a key objective of the RAI should be the prevention of land grabbing. The text should therefore include specific wording on the obligations and responsibility of duty bearers, including business enterprises, to prevent violations on the right to adequate food and to prevent illegal land acquisitions. The set of minimum principles and measures on large-scale land acquisitions, formulated by the UN Special Rapporteur on the right to food, may provide some useful language in this regard.

Under Principle 3 (Environment, Natural Resources and Climate Change), it should be added that “Responsible investments in agriculture and food systems: respect the criteria and safeguards for social



http://www.fao.org/fsnforum/forum/contributions/re-principles-responsible-agricultural-investments-33#_ftnref2

http://www.fao.org/fsnforum/forum/contributions/re-principles-responsible-agricultural-investments-33#_ftnref1

http://www.fao.org/fsnforum/forum/contributions/re-principles-responsible-agricultural-investments-33#_ftn2

http://www.fao.org/fsnforum/forum/contributions/re-principles-responsible-agricultural-investments-33#_ftn1


and environmental responsibilities, in accordance with international standards and frameworks.” Furthermore, a new bullet point should be added under “Application” stating the following:

Investments in low carbon development, energy efficiency, and renewable energy solutions, should be favored and encouraged

The effects of climate change on investments should always be considered.

Investments in fossil fuels, and fossil based technologies, should be avoided and phased out

2) Roles and responsibilities:

DCA recommends that the principles recognize that investments must comply with international standards, require open dialogue with those affected (based on principles of Free, Prior and Informed Consent) and adhere to the Voluntary Guidelines on Governance of Land Tenure and monitor its implementation.

The corporate responsibility to protect human rights for business enterprises, as stipulated in the UN Guiding Principles on Business and Human Rights, should be explicitly mentioned in the principles. This should apply to effects which are both upstream (production) and downstream (sale). Under “Investors” in “Roles and Responsibilities for Part 1”, investors should be called to: “respect the corporate responsibility to protect human rights and to exercise due diligence” in accordance with this framework.

3) Desired outcome:

For the RAI to be responsible and sustainable, the principles for need to meet the overarching objectives of poverty eradication, human rights protection, elimination of inequalities, gender equity and environmental sustainability.

4) Implementation/information sharing:

While many of the existing frameworks are voluntary and non-binding in nature, including the VGGT, the RAI should acknowledge the obligations that States have to protect, respect and fulfill the binding human rights standards enshrined in international treaties, which they are signatory to (including the right to adequate food).

For the principles and existing frameworks to be used and implemented, they first of all need to be known. An analysis of the EDFI or DFI websites showed that there appeared to be no mentioning of the Voluntary Guidelines on the Governance of Land Tenure (APRODEV study 2013: http://aprodev.eu/files/Trade/aprodev_policy_brief_dfi_and_landgrabs_final_may2013.pdf)



http://aprodev.eu/files/Trade/aprodev_policy_brief_dfi_and_landgrabs_final_may2013.pdf


40. Aksel Naerstad, Development Fund, Norway

Principples for responsible investments in agriculture.

Comments from Aksel Naerstad, coordinator of the More and Better Network (www.moreandbetter.org) and Senior policy advisor in the Development Fund (www.utviklingsfondet.no)These comments are made with inputs from discussions with members and nonmembers of the More and Better Network. The do not necessarily represent the views of all members of the network. Many important points are raised in the regional consultations and by inputs from organizations and individuals. The comments and inputs below will only highlight a few important issues, not repeat most of the comments and inputs from others which we agree in.

Some general comments

It is very important to develop and get agreements on principles for responsible investments in agriculture. The principles should aim atIncreasing responsible investments in sustainable agriculture, with the primary focus to support the majority of the farmers and those who produce most of the food in the world – the small scale food producers.Guide all kind of investors in agriculture – farmers, governments, institutions and private investors – so they will invest in responsible ways in sustainable agricultural production. Being a tool for governments, institutions and civil society to stop irresponsible investments, including investments in landgrabbing and in non-sustainable agriculture. The principles should focus on the small scale food producers, with a special focus on the role and needs for women.There should be underlined the need for clear public policies and actions for small scale farmers to enable them to invest in agroecological and other forms of sustainable food production.Agricultural production need to be sustainable. Investments in non-sustainable agriculture are not responsible investments. The principles need to be clear on this.Human rights need to be the base for the principles. Food sovereignty which includes the right to food and farmers’ rights should be supported and promoted by the principles.‘Do not harm’-approach should be included in the principples. 1. Are all relevant issues and areas related to fostering responsible agricultural investments adequately addressed in the Zero Draft? If not, what should be changed?

There is a need to clearly define responsible investments.The central role of small scale food producers should be more clear in the principples.There should be a clear distinction between different kind of investors – farmers, governments, foundations, private investors …The draft focus too much on increasing production. Enough food is produced today to nourish more than 10 billion people. There is a need to focus in losses and waist, food used for other purposes (biofuel etc) and on the quality and nutrition of food – not only on the quantity.The multifunctioning role of agriculture should be underlined. Food production is the core, but agriculture plays a major role also when it comes to economy, employment, environment, health and culture.



http://www.utviklingsfondet.no/

http://www.moreandbetter.org/



The role of women should be highlighted more.Local markets should be highlighted as the most important, then national markets. International markets play an important role in many contexts, but less than 15 % of the food cross borders.There is a need to distinct more clear between different actors.The role of governments to provide public policies en create an enabling environment for sustainable and responsible investments with a focus on the need of small scale food producers should be underlined.It might be good to make a reference to the CFS report and decisions on small scale farmers and investments.The role and responsibilities of governments to stop landgrabbing and investments in unsustainable agriculture should be clearly spelt out. 3. Does the Zero Draft achieve the desired outcome to promote investments in agriculture that contributes to food security and supports the progressive realization of the right to adequate food in the context of national food security? If not, what should be changed?

The different roles and responsibilities of different actors should be more clearly outlined.There should be clearly stated that sustainability and resilience of agricultural production systems is a clear goal and guidelines for responsible investments.

A clear emphasis should be put on the importance of investments in agroecological and other forms of sustainable agriculture. 4. The principles are intended to provide practical guidance to stakeholders; therefore:

Are the current structure and language used clear and accessible for all relevant stakeholders to apply?

The document will be more clear and accessible for all relevant stakeholders to apple if the the proposals and recommendations above are included in the principles.


Inclusive national processes should be encouraged in all countries to implement the principles and to monitor how they are being implemented.

Government should regularly report to CFS on how the principles are implemented.

International evaluation of the principles and the implementation should take place with participation of all stakeholders every 3-5 years – and whenever needed. Aksel NaerstadSenior policy adviser, The Development Fund, Norway (www.utviklingsfondet.no)International coordinator of the More and Better Network (www.moreandbetter.org)



http://www.moreandbetter.org/

http://www.utviklingsfondet.no/


41. Helen Medina, US Council for International Business, United States of America

With regards to RAI as they are being developed at the moment, the US Council for International Business (USCIB) has the following comments:

The private sector has concerns with regards to monitoring and evaluation as well as roles and responsibilities. I would like to stress that it is important to create an environment that encourages investment. Otherwise, the private sector actors that you are trying to work with may be deterred from the RAI principles. We heard this not only during the US meeting but several Canadians have also expressed this.

Furthermore, we have some questions about the role of monitoring and evaluation. Who should do what and to whom should be clarified and be made more explicit. I understand that at the moment, there is no method for monitoring and implementing the roles defined. What entity will keep an eye on the companies and countries that commit to implementing the principles?

Finally I would like to highlight again that in general the roles and responsibilities should not be too prescriptive as it is a voluntary document.

Thank you in advance for accepting my comments and for providing me the opportunity to comment. I look forward to working with you as the RAI Principles develop.

Helen Medina,Senior Director, Product Policy and InnovationUSCIB

42. International Institute for Sustainable Development, France

The International Institute for Sustainable Development (IISD) is grateful for the opportunity to contribute to the Committee on World Food Security’s e-consultation for the zero draft of the principles for responsible agricultural investment (CFS-RAI). We are also participating in the process through the Civil Society Mechanism. The zero draft covers an impressive range of issues. It is a useful contribution to creating a normative framework for investment in agriculture. We strongly support the process and believe the zero draft achieves many of the objectives set out by the CFS. Please find below some comments.





Principle 1 focuses on investment in food production as the means to achieve food security and realize the right to adequate food. IISD believes that achieving these objectives goes beyond investment in food production and can include investment in non-food crops, such as cotton, rubber, and biofuel crops, which are also an important source of livelihood for small-scale producers. Linked to this point, the zero draft uses the term “small-scale food producers and processors.” IISD believes the principles are also relevant for small-scale producers and processors of non-food crops. You may want to consider the term “small-scale agricultural producers and processors” or “small-scale producers and processors.”

Importantly, the zero draft integrates water issues throughout. Reference to water could be strengthened under principle 3. The reference to “more sustainable and efficient production,” could also include water efficiency (alongside energy efficiency).

In principle 3, IISD recommends adding other elements for sustainable agricultural production including:

▪ Reducing end-exposure to chemicals, pesticides and fertilizers,▪ Controlling soil erosion,▪ Increasing use of agricultural by-products, ▪ A commitment by investors to continuous improvements in production methods

and use of modern technology throughout the duration of activities.

Principles 2, 4 and 5 refer to “legitimate tenure rights.” It would be useful to include or refer to the definition of legitimate tenure rights from the Voluntary Guidelines on the Responsible Governance of Tenure of Land, Forests and Fisheries, to make it clear which tenure rights are recognized.

Principle 6 refers to free prior and informed consent for indigenous peoples. You may want to consider expanding this to include other affected communities where the investment takes place. In addition, the objectives section of principle 6 could also include a reference to “monitoring and evaluation” to make sure that after the investment takes place there is a process to monitor and evaluate the investors commitments (for now there is only reference to review and accountability).

Principle 8 does not specify on what issues the impact assessment should be. IISD recommends referring to social, environmental and human rights impact assessments. It is also important to specify which type of investor is required to undertake an impact assessment. These usually apply to large, commercial investors (foreign or domestic), and would not typically apply to small-scale producers.

Linked to the impact assessments, the objectives of principle 8 refer to “remedial actions or remedial changes if negative impacts or shortcomings are identified.” IISD believes it is important for investors to use the results of the impact assessments to develop plans to manage and mitigate the identified impacts. The management and mitigation plans should be binding and enforceable on investors, as are the impact assessments. All impact assessments and management plans should be verified by independent third parties and made publicly available. Wherever impact assessments are referred to in the zero draft, this can be accompanied by reference to management and mitigation plans.


Stakeholders should not only ensure policy coherence by harmonizing their efforts and activities (principle 5, rationale), they should also promote a shared vision for what




constitutes responsible agricultural investment. International organizations, financial institutions and other actors can give different and sometimes contradictory recommendations to developing countries in terms of how to attract and regulate investment in the agriculture sector.

There could be a role for regional organizations to ensure their members act in accordance with the principles when developing agricultural investment policies or concluding investment treaties and contracts. Regional organizations can also encourage the harmonization of laws and policies in the regions, according to the principles, to reduce competition between states to attract foreign investment.

There could also be a responsibility for international financial institutions to respect and implement the principles when deciding what types of agricultural projects to finance and promote.

The roles and responsibilities between different types of investors are unclear. It seems that in most cases the roles and responsibilities apply to large investors (foreign or domestic) and not to small-scale producers. This is especially the case under part III. It might be useful to distinguish roles and responsibilities for different types of investors.

The text calls on States to “develop, establish and implement transparent and predictable policies, laws and regulations … .” We suggest deleting “predictable” as this may suggest a need to constrain responsible policy-making by “freezing” the development of laws and policies.

The roles and responsibilities for part II could include a separate section for “States of origin of transnational investors.” The text says “States are called to respect, adhere to, apply and promote their respective obligations under international law, including when negotiating investment treaties with other countries” This sentence could also include a reference to contracts since states of origin could promote responsible contracting to their investors. Linked to this, the zero draft can also encourage States to include clauses in investment treaties and contracts that emphasize the right of States to introduce policies, laws and regulations for responsible agricultural investment.

Either under Principle 7 or under the roles and responsibilities for part III, the CFS could acknowledge the existence of investor-state dispute settlement and emphasize the importance of prioritizing domestic judicial mechanisms. The current practice under international investment agreements and contracts is to refer disputes to international arbitration. IISD recommends that in the event of a dispute between the government and foreign investors, domestic courts should be the first forums of choice for disputes. International arbitration should not be encouraged over domestic processes. In instances where international arbitration may be necessary, it should be preceded by an effort to settle the dispute amicably first, and through domestic processes prior to international arbitration. This ensures that a fair, balanced approach to the specific type of legal dispute at issue will take place.


The rai principles will be voluntary, so it will be vital for all stakeholders, particularly States to commit to implementation at the national level and to integrate them into national policies and priorities. Regional economic organizations will also have a role to play. Other mechanisms, such




as the Comprehensive African Agriculture Development Programme (CAADP), could provide a vehicle to integrate the principles in national and regional agricultural investment plans.

The role of different legal and policy frameworks for investment is crucial. The priority for States is the development of comprehensive national policies, laws and regulations that promote responsible agricultural investments. Domestic law will govern all issues that may arise in relation to foreign investment, including the issuing of licences and permits for agricultural operators, tax and other incentives, dispute settlement, etc. The zero draft could reinforce the importance of domestic legal and policy frameworks as the most effective tool to promote responsible agricultural investments.

Another mechanism to strengthen compliance with the principles is for the CFS to require States, the private sector and civil society to periodically report on how they are respecting and implementing the principles.

4. The principles are intended to provide practical guidance to stakeholders; therefore: Are the current structure and language used clear and accessible for all relevant stakeholders to apply? What steps need to be taken for the CFS-RAI principles to be used and implemented by different stakeholders after endorsement by CFS?

The CFS has a difficult task to produce, on the one hand, a short and concise document that will be read by a large group of stakeholders and, on the other hand, provide the necessary depth to give practical guidance. The longer document may need a short simple version to accompany it.

The language is clear and accessible. However, the language chosen is at a general level, so it might be difficult to apply in practice. Additional interpretation may be required for stakeholders to apply the principles in their specific contexts. A next step could be for the CFS to develop practical implementation guidelines that allow for context-specific application.

43. Greenpeace International

The RAI principles should not be adopted in their present state. A significant re-write is needed to ensure that investments in agriculture protect, sustain and restore the diversity of life on earth, respecting ecological limits; support equity and food sovereignty to ensure healthy food is grown to meet fundamental human needs; and ensure control over food and farming rests with local communities. And, although we welcome the opportunity of this e-consultation, these comments should be considered in addition to, but not in lieu of, the combined civil society comments submitted through the civil society mechanism (CSM).

The voluntary nature of these Principles is a fundamental weakness in Greenpeace´s assessment. Greenpeace believes in globally enforceable rules for global players. In our view, therefore, the RAI principles should be legally-binding to ensure that agriculture investments not only protect farmers, consumers, communities, and the environment, but actually lead to food security, poverty reduction, and enhanced ecological function.




In a constructive spirit, we do suggest the following concrete proposals to improve the RAI principles.

Reworking style and structure

The overall framing of the document needs to be changed. Despite mentioning other stakeholders at the beginning, the language throughout the document supports the perspective and interests of large-scale, external private sector investments. It focuses excessively on increasing productivity, promoting market mechanisms, and integrating small-scale producers into value chains. Yet, it is a globally accepted reality that food security is not an issue of quantity of production but food access for poor people. And, market mechanisms are largely designed to support corporations over small-scale producers, promoting purchase of polluting chemical inputs instead of supporting ecological farming approaches that sustain the natural resource base and build resilience to climate change and other external shocks. Value chain linkages generally only involve the top 2-10 % of small-scale producers who have the assets and access to capital, information, and infrastructure.i Furthermore, the framing of the current draft protects the interests of large-scale investors with ‘hard law’ international agreements while small-scale producers, workers, and the environment are only protected by ‘soft law’ voluntary norms.

The draft needs clarification and specificity. The draft is quite vague and confusing as it stands. The principles are overly simplistic and most of the detail is written outside of the principles themselves, leaving the door open to widely divergent interpretations. In its present state, almost any investment could be finessed to seem to adhere to these principles. For example, in Principle 1 it reads, “depending on context and in the presence of persistent food insecurity create an enabling environment for increased food production.” Critical questions arise from this sentence: create an enabling environment for whom? To grow what? In what way? For what markets? These are all critical questions with underlying issues impacting environmental sustainability and imbalance of power between stakeholders. Another example comes in the application section of Principle 3 where it reads, “strengthening capacity building for proper adaptation and uptake of best practices.” Again, critical questions are raised: building capacity of whom? Who defines what qualifies as ‘proper’ and ‘best practices’? Throughout the document these vague references need to be clarified. Also in Principle 3, “Achieving food security with simultaneous environmental benefits……requires a focus on: the use of traditional and scientific knowledge…appropriate technologies and practices”. Who gets to decide what is appropriate? For some people Genetically Modified Organisms (GMOs) constitute an ‘appropriate technology”; for others, including Greenpeace, GMOs undermine food security and entrench poverty. These are not the only vague references, but a representative sample of the clarifications needed to make the document valuable in achieving its stated aims.

The stakeholder groups and concurrent roles and responsibilities must be reworked . There is overlap in the stakeholder groups and distinctions between the groupings are unclear. Public and private investments must be clearly differentiated throughout the document, including in the layout of roles and responsibilities. In addition, the private sector as written is also too large and divergent of a group. Most importantly, small-scale producers should be considered separately from (multinational) corporations. Creating an ‘enabling environment’ for responsible small-scale agriculture investments is completely different from creating an ‘enabling environment’ for responsible corporate investments, particularly those of TransNationalCompanies (TNCs).ii Different private sector actors along the food chain should also be split out (input industry, traders, processors, retailers, financial sector) as they have different roles and influence on agriculture investments. Furthermore, the stakeholder groups are written to




recognize only small-scale food producers/processors in developing countries; yet, small-scale producers exist and deserve support in developed countries as well.

The document needs to be strengthened. Fundamentally, if an investment is deemed likely to have negative impacts on the environment and/or local communities even with remedial actions, implementation is unacceptable. Social and environmental impact assessments must be required prior to investment (excepting investments by small-scale producers on their own farms). Accountability and transparency are not only important in review mechanisms, but should be evident throughout the document. For example, in the roles and responsibilities of stakeholders for Part I, the responsibility of monitoring and evaluating the application of the principles is seen as the responsibility of civil society, when it should be the responsibility of host governments and donor governments as the elected bodies responsible for monitoring and mitigating the impact of investments on their populace.

Overall, the language needs to be more assertive. Language throughout the document, even when considering human rights, is weak. For example, words such as ‘request’, ‘encourage’, or ‘recommend’ should be changed to ‘require’ or ‘obligate’.

Filling major gaps

Explicitly include agroecology in Principle 3, with specific recommendations on promoting the scale up of uptake of ecological farmingiii approaches in the objectives, application, and roles and responsibility sections. Specific mention of soils, water, and biodiversity are needed. As the CFS Global Strategic Framework states, agroecology is critical “in improving agricultural sustainability as well as the incomes of food producers and their resilience in the face of climate change.”

Industrial agriculture has expanded at the expense of forests, grasslands, wetlands, coastal and marine areas; the conversion of natural ecosystems for large scale monocultures has picked up speed in recent years due to the increased demand for animal feed and bioenergy, creating competing land use pressures. Use of pesticides and chemical fertilizers is still increasing rapidly in developing countries and in North America with GMO cultivation, despite profound impacts on natural ecosystems and the health of farmers by the use of agrochemicals.iv Genetic engineering technologies undermine resilience, by creating farmer dependence on seeds and other inputs to a few global corporations, and threaten the diversity of our crop plants and the agro-ecosystems we depend on to meet future food needs. In a recent studyv, even KPMG ranked the food sector as the worst of all sectors in two respects: 1) it faces the “highest risk from sustainability mega forces” and it is the “least ready” to respond to them, 2) it is the worst actor in terms of care and handling of the environment. Ecological farming, based on biodiversity and utilizing resources that are affordable and locally available, can increase production and improve livelihoods where it is most needed, and without creating reliance on external actors, while protecting the natural resource base needed to sustain life on Earth.vi

Ecological farming is the most promising, realistic and economically feasible solution to the current destructive agriculture model. It is also ideally suited for poor and small-scale farmers, as they require minimal or no external inputs, use locally and naturally available materials to produce high-quality products, and encourage a whole systemic approach to farming that is more diverse and more resilient to adverse weather conditions, pests and diseases (UNEP and UNCTAD, 2008).




Additionally in Principle 3, a specific bullet point is needed to address prevention of environmental pollution, adverse affects on ecosystem services, and harm on farmers, farmworkers, and communities through contamination.

Revise the way research and development is approached. Principle 3 needs a bullet in the ‘application’ section about revamping extension and research and development to focus support on uptake of agroecology, gender equity, and building resilience of small-scale farmers to climate and economic shocks. This re-focusing on agroecology should be included in the

‘Roles and Responsibilities’ section of Part I for each of the stakeholders (particularly states, research institutions, intergovernmental organizations, and donors and foundations) and their relative role in reaching that overarching goal. Farmers are not simply passive recipients of technologies designed in a lab; all over the world they are already adapting to climate change with their own innovations. Thus, research and development should start with farmers’ own knowledge and innovations that are adapted to their local agro-climatic zone, and be an iterative process done in partnership between farmers and scientists. Some studies have shown that if more agricultural research were focused on sustainable methods, yield increases would rise.vii

Include farmers’ right to save seeds. Responsible investments must have agricultural biodiversity conservation and development as a cornerstone. In particular, investments should support seed systems that are resilient to climate change; strengthen farmers’ management of their seeds (allowing for seed saving, using, selling, exchanging and developing); secure seed supply (quality and quantity) in the community, ensuring that the community has the ability to replenish seeds in times of crisis; and is built around conservation of agriculture biodiversity and ecosystem intra-specific and inter-specific diversity and landscapes.

Explicitly include references to key environmental principles and agreements . Existing environmental regulations and other relevant policies have failed to adequately protect human health and the global environment. Therefore, corporations, government entities, organizations, communities, and scientists must act in accordance with theprecautionary principle and polluter pays principle in agriculture investments. Compliance with the Cartagena Protocol on Biosafety must also be included in the document, as it is an important step towards biosafety and the protection of biodiversity. Furthermore, in order to provide for the conservation and sustainable use of plant genetic resources for food and agriculture, the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA) must be referenced in the principles and countries should be encouraged to translate the ITPGRFA into national policy and legislation.

Explicitly delineate critical investment roles of the state: investment in public goods, policy frameworks that balance power among stakeholders, regulation of investments, and enforcement to uphold national sovereignty and democracy. It is the job of governments to ensure food security and long-term sustainability; history has shown us that profit-driven agencies and the market cannot be relied upon to serve the public good in the agriculture sector.viii The private sector does not have the mandate to deliver public services to small-scale producers, particularly the marginalized. Nor will they encourage uptake of ecological farming practices that rebuild soil health, water quality, and biodiversity. Thus, critical public investments - including agriculture services such as extension, R&D, storage, and access to information services (i.e. climate and price information) but also related services such as education, healthcare, and infrastructure - cannot and should not be replaced by private investments.




At the moment, the draft only suggests policy ‘carrots’ but not the equally necessary ‘sticks’. The state is responsible for holding other actors accountable for their investment impacts. Thus, the draft must state that adequate regulatory frameworks should be put in place to first ensure that investments have no negative impacts on farmers, farmworkers, communities or the environment; and then go one step further to ensure that investments have positive impacts towards achieving the goal of food security while building the natural resource base.

Currently the draft contains nothing on regulating public private partnerships and contract farming, although these forms of investment are on the rise. At a minimum, states must ensure that PPPs do not undermine ecological sustainability, food security (e.g. by growing monocultures of crops that drain aquifers) or farmer/community rights. Further, any public expenditure should be used directly to support ecological farming and the improving the livelihoods of small-scale farmers and building their resilience to climate and economic shocks.

And, while risk management is mentioned, there is no recognition in the document of varying risk assumption by different stakeholders and mechanisms to address that. Usually, lead companies that have market advantage take much of the profit while forcing the small-scale producer to take on much of the risk. The state’s role is to protect producers, particularly small- scale producers, from being forced to take on the lion’s share of the risk.

Fundamentally, the document needs to address the role of the state in balancing power differences between various actors. Current market dynamics and government policies favor large-scale industrial production over ecologically-sustainable small-scale production. The document must be clear that specific policies are required to level the playing field. Small-scale farmers cannot economically compete with large-scale farmers and companies. Governments have the responsibility to set in place policies that at the very least uphold the rights of vulnerable groups, such as small-scale farmers and women, and protect the environment. In addition to policies that rebalance power, small-scale farmers and civil society must be facilitated to participate in all decision-making processes that affect them and their livelihoods.

The role of donors, multilaterals and research institutions must be elaborated. Part I contains no role for donors and foundations; this is a major oversight. They are major investors in agriculture and have the power to influence the direction of investments, not just their own, but those of states and farmers as well. This power must not be wielded lightly and requires agreement by all CFS stakeholders on specific roles and responsibilities. They are often playing the ‘technical advisory’ role in large PPPs and are encouraging their propagation. They are also often driving the policy changes envisioned to create an ‘enabling environment’. Thus, their role is central and should be clearly outlined to be in support of the uptake of agroecology, gender equity, and building resilience of small-scale farmers to climate and economic shocks.

Similarly, the role for multilaterals and research institutions is not well laid out. Multilaterals like the World Bank, AfDB, CGIAR, FAO, etc. have an increasingly important responsibility to steer investments (particularly R&D and extension) towards small-scale ecological agriculture.

Adjust Principle 5 on policy coherence to include government responsibility to ensure investor conduct is consistent with environmental regulations and impact mitigation requirements. The way policy coherence is framed in the draft is solely to improve the ease of external investment. However, policy coherence is important for avoiding waste of public spending and ensuring that all investments




and policies that impact agriculture and food systems, including non-agriculture policies, support the principles in this document.

Include two new sections on implementation and monitoring/evaluation of the principles. The current principles are not able to provide practical guidance to stakeholders. These sections should recognize the leading role of the CFS, specific metrics/indicators, and established budget to carry implementation forward. We support the suggested mechanism of Oxfam International in their comments.

-------Vorley, Bill, Lorenzo Cotula, Man-‐kwun Chan, Tipping the Balance: Policies to shape agricultural investments and markets in favor of smal-‐scale farmers. December 2012. ii Ibid. iii Ecological farming is a food and agriculture system that follows the principles of agroecology and that is ecologically, economically, socially and culturally sound and holistic in its approach. iv Between one and three agricultural workers per every 100 worldwide suffer from acute pesticide poisoning, and adolescents are often the victims: http://www.who.int/ceh/publications/pestipoison/en/ v KPMG report "Expected the unexpected -‐ building business value in the changing world": http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/Documents/building-business-value-exec- summary.pdfvi UNEP & UNCTAD 2008. Organic Agriculture and Food Security in Africa. United Nations, New York and Geneva http://www.unctad.org/en/docs/ditcted200715_en.pdf.; D e Schutter, O. 2010. Agroecology and the right to food. UN Special Rapporteur on the right to food.http://www.srfood.org/images/stories/pdf/officialreports/20110308_a-‐hrc-‐16-‐49_agroecology_en.pdf; Bommarco, R., Kleijn, D. & Potts, S. G. 2012. Ecological intensification: harnessing ecosystem services for food security. Trends in Ecology & Evolution, 28, 230-‐238.; Tittonell, P. 2013. Farming Systems Ecology. Towards ecological intensification of world agriculture. Inaugural lecture upon taking up the position of Chair in Farming Systems Ecology at Wageningen University on 16 May 2013.http://www.wageningenur.nl/en/show/Feeding-‐the-‐world-‐ population-‐sustainably-‐and-‐efficiently-‐with-‐ecologically-‐intensive-‐agriculture.htm vii Badgely, C. et al, Organic Agriculture and the Global Food Supply’ Renewable Agriculture and Food Systems, 22 (2), 2007. viii House of Commons International Development Committee. DFID’s Agriculture Policy: Seventh Report of Session 2003-‐04. 15 September 2004.

44. Pradip Dey, Indian Society of Soil Salinity and Water Quality, India Dear Sir,

Good day!

Sorry for being late due to back to back Office tour. Kindly find below my feedback for needful at your esteem end please.


http://www.wageningenur.nl/en/show/Feeding-

http://www.srfood.org/images/stories/pdf/officialreports/20110308_a-

http://www.srfood.org/images/stories/pdf/officialreports/20110308_a-


http://www.unctad.org/en/docs/ditcted200715_en.pdf.%3B

http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/Documents/building-business-value-exec-

http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/Documents/building-business-value-exec-

http://www.who.int/ceh/publications/pestipoison/en/


Investments in agriculture (whether foreign or domestic, private or public) must consider varying local circumstances and proceed with extra caution in ecologically sensitive or biodiverse areas. Something which of course can be done by genuinely involving agro-ecological experts and local populations with traditional/local knowledge about their surroundings – which of course is just one of many rationales for promoting participation and consultation. The issues like environmental, gender, human resources development etc. are indeed crosscutting, which suggest that there could be positive synergies if all RAI Principles are implemented together.

With warm regards,

Sincerely yours,

Pradip Dey

45. Institute for Agriculture and Trade Policy (IATP) and Grassroots International and International Development Exchange (IDEX), USA

Thank you for this opportunity to provide input into the zero draft of the principles. We congratulate the HLPE in undertaking this study at a critical time, characterized by increasing interest in investing in agricultural development, and by financialization of natural resources. Climate related uncertainties and increasing investments in land simply as a commercial asset makes this initiative very relevant. We hope that the report in its preamble can recognize that land is a productive, rights fulfilling asset which is essential to the realization of many established human rights, including the right to water, the right to adequate housing, the right to health, the right to an adequate standard of living, and especially the right to food. This is especially important as investment laws tend to view land solely as a commercial asset, even though there are many kinds of non-‐commercial relations to land, including cultural identities, spiritual practices, and customary tenure and usufruct rights.

We hope this report will build on the work the HLPE has already done on food price volatility, land tenure and international investments, social protection for food security, biofuels and food security, and investing in smallholder agriculture for food security. They are all relevant to developing the principles for responsible agriculture investment. The CFS’s app r oved Vo l un t a r y Gu i de li nes on Respons i b l e Tenu re , the G l oba l S tr a t eg i c F r a m e w o r k , the Vo l un t a r y G u i de li nes on t he R i gh t t o Food as well as the I AAST D Reco mm enda ti on s are existing and critical tools that can help provide the basis for developing the principles that can help ensure the food and nutritional security of small- ‐scale food producers and workers in underinvested regions of the world, and guide responsible agriculture investments.

1. Framing of the issues and areas related to fostering responsible agricultural investments The report’s starting point is: ‘to enhance food security and nutrition, reduce poverty and inequalities, promote sustainable agricultural and food systems development and contribute to the progressive realization of the right to adequate food in the context of national food security, investments have to




be “responsible”’. However this emphasis on the progressive realization of the right to food as a goal, and responsible investment as a means is not evident in the rest of the document.

In keeping with the emphasis placed by the various CFS reports referred to in the paragraphs above, we hope that the normative framework for these Principles would emphasize (a) “the primary responsibility of governments and the central role of country ownership of programmes to combat food insecurity” (GFS), with the obligation of adhering to “existing human rights standards and the progressive realization of the right to adequate food in the context of national food security” (ToR to Develop Principles for RAI), and (b) the “due priority to enabling, supporting and complementing smallholders’ own investment” (GFS).

Principles: Even though the CFS Terms of Reference (to Develop Principles for RAI) included a request for the clarification of the term ‘responsible investment’, we were struck by the lack of clarity of the term in this draft. It is crucial that the framework of responsibility is clarified, especially given that it is not only large state investors and agribusiness but also Wall Street that is entering into investing in farmlands, exacerbating the existing potential for conflict and land grabs. Each of the 8 principles lists a set of objectives dealing with different aspects of agricultural investment, and covers a large number of issues. However it is not clarified what makes a particular investment responsible. Instead of framing each Principle with ‘Responsible investments in agriculture and food systems do . . . . ’ the Principles would be m ean i ng f ul if reworded in the following way: ‘Investments in agriculture and food systems are responsible only if they do . . . . .’. This will help establish them as the norms for differentiating responsible investment from irresponsible investment, rather than simply as optional descriptions attached to each principle.

2. Defining the Roles and Responsibilities of Stakeholders

Small-‐scale food producers and workers feed the largest number of mouths, as they mostly produce for local consumption, while large investors produce primarily for value-‐chains or for export. The report needs to recognize the small-‐scale food producers and workers (and their investments) as fundamental to the progressive realization of the right to food as a national project.

Yet, while the Zero draft report recognizes that these agricultural related investments are carried out by a multiple number of actors, it groups small-‐scale food producers and workers in the same category as large investors or as all private sector actors. The authors of the Zero draft seems to assume that small-‐scale food producers and workers simply occupy the ‘waiting room of history’ before they turn into effective participants in value chain, and thus contributors to global food security. But what about their own local food security?

The challenges for national and global food security (to reiterate what we have said in an earlier submission) today are not fundamentally about size of landholdings (though size is intrinsically part of it), nor just about improving resource use efficiency (though that is important), but about whole food systems that are distinct and includes its own processing, marketing and distribution systems, and each with its own consumers. Thus it is essential to situate small-‐scale food producers and




workers within this system and assess how they can be supported to strengthen their food sovereignty, and how they can thrive amidst these very real challenges. Those involved in small scale food production – including agricultural workers, landless, sharecroppers, tenant farmers, pastoralists, smallholder farmers, fisher communities, youth, rural women, indigenous communities, processors and cooperatives—all have specific priorities, strengths and constraints and their needs must be addressed as a distinct set of actors, separate from the private sector, and large investors.

Accordingly, any agricultural investment that is ‘responsible’ has a special obligation to empower small-‐scale food producers and food system workers, and especially women amongst them, acknowledging their substantial contribution to domestic food security, rather than treat them as cogs in the wheels of agri-‐business owned value-‐chains.

Moreover, public investment has a key responsibility and role in ensuring the viability of small food producer communities—through creating an enabling environment for: domestic food security, thriving local food markets (protected from adverse international market forces), and rural development that results in ecosystem restoration and regeneration.

3. Changes needed: Investments in agriculture that contribute to food security and support the progressive realization of the right to adequate food in the context of national food security

The decision to develop Principles for responsible agricultural investment was made in a context of ‘food crisis,’ rising hunger rates alongside persisting malnutrition, several decades of underinvestment in agricultural sectors and rural populations, increase in large-‐scale land acquisitions across the world, and growing recognition of genetic erosion. At the same time, there is an increased recognition that investments for agricultural renewal were critical to rural development, food security and for the restoration and sustenance of the ecosystems on which agriculture depends. Given the disproportionate role of small-‐scale producers and workers in feeding the world and working the land, and recognizing their exposure to unfair investment and trade rules, the rai initiative is an opportunity to refocus on the progressive realization of the right to food in the context of national food security by redirecting investment towards empowering small-‐scale producers and workers, enhancing ecosystem functions and rebuilding local food economies.

Thus we were surprised that the report is marked by the absence of any reference to investing in agroecology. Agroecology is an innovative approach to food security that is built on traditional knowledge and enhanced by scientific innovations. It combines the sciences of ecology and agronomy with the political economy of food production and consumption. Although it is concerned with increasing productivity, this approach equally seeks to ensure the achievement of the right to food at the household level including improved nutritional content. Agroecology is an integrated approach to

the entire agro-‐ecosystem (rather than individual plants, animals or humans) in specific socio-‐economic contexts.

We hope the report will build on and strengthen the commitment made by the CFS 40 to: “Promote access to and control (i.e. breeding, production, conservation, purchase, exchange, sale and use) by




smallholders -‐ in particular women farmers -‐ over the seeds they need, both for indigenous crops and modern varieties. Strengthen information and technology transfer related to practical on-‐farm implementation, including on provision of support in-‐situ and ex-‐situ conservation and development of agricultural biodiversity by smallholders themselves and by research and extension systems, in line with sustainable agricultural objectives and good practices, including agroecological approaches.” (Report on Investing in smallholder agriculture for food security)

Accordingly, any agricultural investment that is ‘responsible’ has a special obligation to help small-‐scale food producers and food system workers, and especially women amongst them, nourish themselves, and help realize their right to food and water, while enhancing ecosystem functions.

Moreover, public investment has a key responsibility and role in ensuring the viability of small food producer communities. It must create an enabling environment for the practice of agroecological approaches (protected from adverse international investments that promote agro-‐chemical intensive agriculture), and democratic decision making at the local level on food and water policies.

Investing in appropriate technology especially in relation to post harvest losses

From the V0 Draft of ‘Food Losses And Waste -‐ In The Context Of Sustainable Food Systems’, it is clear that if food/crop loss during postharvest phase could be averted (harvesting, storage, processing and distribution) it will substantially increase food availability for human consumption, and with appropriate handling and storage may even enhance the nutritional content of the food consumed. We hope that this report will build on the opportunities

identified for averting the losses by investing in and empowering small-‐scale food producers and workers help design and develop locally appropriate technology and reduce their postharvest losses.

Accordingly, any agricultural investment that is ‘responsible’ has a special obligation to acknowledge the substantial contributions of small-‐scale food producers and food system workers to local food security. It is imperative that substantial investments must help local communities design and develop locally appropriate technology owned and operated by them and thereby help retain wealth in their communities. Moreover, public investment has a key responsibility and role in ensuring the viability of such investments in small food producer communities—through creating an enabling environment for this to happen.

4. Steps to be taken for the CFS-‐RAI principles to be used and implemented

In conclusion, first, the draft fails to prioritize food production and investment for the realization of the right to food. It also fails to clarify the normative framework regarding responsible investments. We also note that small-‐scale producers and their communities must be the principal beneficiaries of agricultural investment. Public investment must complement and enable small-‐scale food producers’ investment.




Second, in a context where the interests of large investors are protected by ‘hard law’— including international agreements and investor protection—whereas small-‐scale producers and workers are only protected by ‘soft law’ such as voluntary norms, and corporate social responsibility, it is not enough that agricultural investment generate some co-‐benefits for concerned communities are considered ‘responsible’. Instead it is necessary that small-‐scale producers and workers are protected by the “P r o t ec t , Respec t , Re m edy” fr a m e w o r k under the International human rights law to mitigate any negative impact of their investments.

Third, the impacts of trade agreements (and partnership) and investment on progressive realization of the Right to food and national food security is absent. Given that trade and investment agreements are legally binding, the rai principles will be rendered ineffective unless states ensure that the principles are upheld in all trade-‐investment agreements, partnerships and initiatives.

Thank you for your attention.

For more information on these comments, please contact:

Shiney Varghese, Senior Policy Analyst, Institute for Agriculture and Trade Policy sva r ghese @ i a t p . o r g ;www . i a t p . o r g Karen Hansen Kuhn, International Program Director, Institute for Agriculture and Trade Policy khansenkuhn @ i a t p . o r g ;www . i a t p . o r g

Contact at Grassroots International

Sara Mersha, Director of Grantmaking & Advocacy s m ersha @ grassroo t son l i ne . org ;http: //www . grassrootsonli ne. org/

Contact at International Development Exchange Yeshica Weerasekera, Director, Program Partnerships yesh i ca @ i dex . org ;https : // www .i dex . org/

46. Christina Blank, CFS RAI Open Ended Working Group Chair

We would like to thank all contributors for taking their time to go through the CFS-RAI Zero Draft and participate in the forum.



100

Principles for Responsible Agricultural InvestmentsProceedings

The outcomes of this e-discussion, combined with the inputs received through the face-to-face global and regional consultations will guide us in preparing the First Draft to be released at www.fao.org/cfs/rai on 1 April 2014.

A CFS-RAI Open Ended Group Meeting will be held at FAO on 29 April with the objective of having a preliminary discussion before the official global negotiations take place between 19 and 23 of May 2014.

Thank you again for having brought your views and experiences to the discussion and I look forward to continuing this lively dialogue.

With best wishes,

Christina Blank, CFS RAI Open Ended Working Group Chair



http://www.fao.org/cfs/rai%20on%201%20April%202014

http://www.fao.org/cfs/rai%20on%201%20April%202014

Date post:	30-Apr-2020
Category:	Documents
Upload:	others
View:	2 times
Download:	0 times