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Principles for Responsible Agricultural Investments

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:

  • 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?

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

Christina Blank

CFS RAI Open Ended Working Group Chair

This discussion is now closed. Please contact for any further information.

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.


Kjell 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.

Mr. 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 schools

The 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 ones

The 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.

- 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.

Senait Regassa The Swiss Agency for Development and Cooperation, Ethiopia
FSN Forum

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, PhD
National Program Officer

The Swiss Agency for Development and Cooperation

Embassy of Switzerland
Ethiopia, Djibouti, South Sudan, African Union

P.O. Box 1106, Addis Ababa

Ms. Kyungmee Kim Stockholm International Water Institute, Sweden

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

Kien Nguyen Van Plant Resources Center (PRC), Viet Nam

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,


Dr. Dirk-Jan Verdonk WSPA, Netherlands

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


Dr. Bernd Steimann 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:

  1. The fundamental limitation of the RAI is that they are voluntary.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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

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

Ms. 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.

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.

  1. 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 regular monitoring 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.

  1. 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 apply

Given 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.


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. 

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 or visit


Bliss Baker
Global Renewable Fuels Alliance

Dr. 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:

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?

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:

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?

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.

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?

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.

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.

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

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
tel. +358 400 653 640; +358 40 679 2632