November 5, 2023 update in response to Somo’s November 4th statement: HERE
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November 3, 2023
Dear friends and colleagues,
Early next week, a report is expected to be published by Dutch NGO Somo that details shocking allegations of sexual harassment at our Kasigau Corridor project.
At Wildlife Works, a deep relationship built on mutual trust with our community partners is the foundation of what makes our conservation projects work. I personally, and we as an organization, are shocked to learn that we have breached this bond of trust at the Kasigau Corridor project.
Our third-party investigation by an independent Kenyan firm into Somo’s allegations found many of the allegations were not substantiated. However, we identified that two individuals had engaged in deeply inappropriate and harmful behavior for which we have zero tolerance. This was heartbreaking for me to learn, and should never have happened. I am deeply sorry for the pain that has been caused.
We have already taken immediate steps to address the gaps in our processes and to ensure the strength and thoroughness of our policy and procedures.
We are also in the final stages of a disciplinary process against the individuals involved in accordance with Kenyan law. Once this process is completed, we will be able to share more information. Below is what we can share today. If you have any questions, please do not hesitate to contact me directly.
Wildlife Works Carbon
In August 2023, we received a letter from Somo containing shocking allegations of sexual harassment at our Kasigau Corridor REDD+ project in Kenya. Upon learning about these allegations perpetrated by senior male staff members of Wildlife Works, we took immediate action and commissioned an extensive third-party investigation by an independent firm of Kenyan legal experts in sexual harassment and discrimination whose investigators are trained in gender-based violence. We also suspended the two named staff members and an additional staff member we were able to identify pending the outcome of this investigation.
Below is a summary of the allegations made by Somo in their letter to us. Our resulting investigation, which has just been completed, found that many of these allegations were not substantiated. However, the investigation did reveal evidence of improper conduct by two individuals. We are in the final stages of a disciplinary process against the involved individuals in accordance with Kenyan law. Once this process is completed, we will be able to share more information.
The allegations made by Somo include:
That sexual harassment and abuse by senior male members of Wildlife Works staff and rangers was widespread
That male employees within Wildlife Works were able to exploit the company’s power as a large employer in an area marked by poverty, and that they abuse this power to coerce women into abusive sexual relationships
That perpetrators promised women benefits, such as preferential treatment and promotion, in exchange for sex, and/or used threats of demotion or dismissal to coerce their victims into submission
That women were subject to coercive and physical tactics including bullying and intimidation, unwanted sexual touching, groping, physical assaults and attempted rape
That a senior member of staff had tried to extort sex from the spouses of junior male rangers while they were at work
That Wildlife Works has allowed or enabled a culture of serious abuse to persist at Kasigau because of a fear speaking negatively about Wildlife Works could lead to retaliatory steps
Somo has yet to give Wildlife Works the right of reply as laid out in their Code of Conduct. However, we expect Somo to publish their report in the coming days, before our disciplinary proceedings against the named individuals are complete.
Improving Our Processes
Along with beginning the third-party investigation by an independent Kenyan firm, we took steps to examine and strengthen our HR policies and procedures where needed. These included making improvements to and increasing transparency within the grievance process, and associated checks and balances.
Furthermore, we are enrolling a Kenyan consultant on workplace gender-based equity harassment and sexual violence to do a full audit of and improvement plan for policies and procedures.
We are setting up a third-party managed whistleblower line which will be open for future grievance reporting.
We will also be conducting community listening sessions as soon as the disciplinary actions are completed.
We recognize this is a marathon - not a sprint - to make sure this is done right.
Our commitment to our employees and the local community
We remain steadfast in our commitment to ensuring the well-being and safety of both our team members and the broader community.
We are unwavering in our commitment to strengthen the trust of our employees and community. The strength of our projects is grounded in direct management, relying on the knowledge of our local community partners and the expertise of our local employees.
As part of our commitment to our employees and local communities and our organizational values, we are committed to ensuring that we have in place safe and trusted reporting channels that are open to all, but we must always strive to do better.
Wildlife Works has been an employer in the region for the past 25 years. Job creation is one of our core conservation strategies. Currently, the Kasigau Corridor REDD+ Project employs over 400 people, the vast majority of whom live and work directly within their local communities. We are dedicated to the ongoing effort of progress and adaptation, never at the cost of anyone's health and safety.
Engagement with Somo
Upon receiving Somo’s letter in August with the allegations, we promptly responded to them in writing letting them know that we have launched a third-party investigation with an independent Kenyan firm.
We are aware that SOMO has shared a draft investigation report with third parties and that it intends to publish it imminently. If true, this investigation report has never been shared for comment with Wildlife Works, thus violating section 8 of SOMO’s Code of Conduct which provides for a right of reply.
We will be submitting a formal complaint through their open grievance mechanism.
Response to Somo’s November 4th statement
November 5, 2023
1) Wildlife Works is in the disciplinary phase of our investigation which will soon be completed. Somo is aware that we have not completed this phase of our investigation, but they chose to publish their report in advance of learning the outcome of our investigation, which denies us the right to respond to the inaccuracies in their report, as their own published code of conduct “right of reply” requires.
2) Our investigation was conducted by independent, third-party experts. Wildlife Works selected Nairobi-based law firm Anjarwalla and Khanna (A&K) to conduct this investigation because they are recognized experts in sexual harassment. They were not our lawyers prior to this matter. A&K then employed an investigative company with specific expertise in gender-based abuse who actually conducted the investigation. No Wildlife Works personnel were involved in conducting any aspect of the investigation.
3) A&K’s investigation was extensive and thorough. A&K’s third-party, independent investigation interviewed 38 relevant people mostly from within the company, as this is an employment matter, but also within the broader community. From this group of interviewees, A&K’s investigative team were able to obtain findings that addressed all of the allegations in the Somo report, and no further allegations came to light. Somo’s criticism of the fact that we did not interview all of their interviewees seems inappropriate given A&K’s investigative team was not informed of who Somo interviewed (due to the need to maintain anonymity for all interviewees). However A&K’s independent investigators were able to interview people with direct knowledge of the allegations.
4) Protection and support for victims. Somo’s report, as well as our independent investigation, rightly protects the identities of any victims of the harassment. We are fully committed to working with our gender-based consultant to provide effective mechanisms for any victims to safely come forward to us, or anonymously and to provide support and remedies to those victims.
5) The sexual harassment misconduct that has been substantiated was perpetrated by one individual. Somo’s report attempts to indicate the widespread nature of this problem, yet in their letter to us they identified one perpetrator as responsible for the specific sexual harassment allegations, and one department as the place where all these allegations occurred; and A&K’s investigation also found that was the case.
6) Our existing grievance process did not identify this case of sexual harassment. Our existing grievance procedures have effectively resolved many types of issues raised by our employees and community members throughout our 25 year history. However the sexual harassment allegations in Somo’s report made against one of our senior staff members never surfaced through our grievance process. It is painfully clear to us now that we had gaps in our grievance process specific to sexual harassment issues, which must be treated differently and we are committed to fixing this issue.