Complainant:Asian Peoples’ Movement on Debt and Development (APMDD), Centre for Environmental Law and Community Rights (PNG), Japan Center for a Sustainable Environment and Society, Jubilee Australia Research Centre, Market Forces, Reclaim Finance
Date filed:09/12/2025
Location/Country:Papua New Guinea
Sector:Oil and Gas Extraction, LNG Terminal
Project status:Agreement
Banks involved:MUFG Bank, Ltd
Focus of complaint:Inadequate consultation / lack of consent, Impact on community / livelihood / land rights, Impact on nature / water / air / soil, Impact on climate
Focus explanation:Concerns raised include: *A lack of community information materials that clearly describe specific aspects of the project, its risks, impacts or alternatives. *A lack of evidence that communities have been informed of provisions for their rights under: 1) the Equator Principles; 2) the French Duty of Vigilance Law; 3) the EU Corporate Sustainability Due Diligence Directive; 4) the UN Guidelines on Business and Human Rights or 5) the OECD Guidelines on Multinational Enterprises. *A lack of verifiable evidence of Free, Prior and Informed Consent (FPIC) or that Indigenous Peoples have been informed of their right to FPIC under international law, including their right to refuse the project. *A lack of a public Climate Change Risk Assessment (CCRA). Public scrutiny of a CCRA is particularly key, given that two courts - in France and Germany - have found against TotalEnergies in "greenwashing" cases over climate claims. *A lack of a full, public and up-to-date Human Rights Impact Assessment. *A lack of an upstream decommissioning plan. *A lack of economic modelling. There is no systemic cost-benefit analysis of the economic impacts of the Papua LNG project on Gulf Province or PNG. *A lack of discussion of financial crime risks and related impropriety. The international Financial Action Task Force has put PNG on notice of potential grey-listing due to risks related to corruption, environmental crime and politically exposed persons. *Very severe biodiversity risks. The project area covers 100 new-to-external science or undescribed-by-external science species and multiple threatened species on the IUCN Red List as well as the CITES Appendix I. The project has excluded the Bulmer's Fruit Bat - one of the world's 100 most at-risk species - from its consideration of biodiversity risks, contravening the advice of its initial baseline assessment, without providing studies or any materials to explain this position. *A lack of robust consideration of gender risks. *Failure to post the project's Environmental Impact Statements and other key materials online. The Upstream EIS Addendum refers to underlying studies that are not included in its annex. *Concerning approach to the potential resettlement of a small community living within 700m of the proposed Central Processing Facility. *A lack of consideration of the cumulative impacts of some other proposed fossil fuel projects in Gulf province, such as Pasca A and a proposed floating LNG facility linked to the Pandora and Urama gas fields. *A lack of effective grievance mechanism, given the lack of proper community information.
