In late December 2025, LLF decided to continue funding the Odzala-Kokoua legacy landscape program managed by African Parks. This decision comes with conditions.

In response to the findings of the international law firm Omnia Strategy LLP, LLF had previously decided to maintain support for the landscape while completing a new Environmental and Social Due Diligence (ESDD) study and a milestone review by the end of 2025. These assessments were intended to provide LLF with a more comprehensive basis for decisions on future funding for Odzala-Kokoua. A non-technical summary of the updated environmental and social action plan (ESAP) and the milestone review and its recommendations will be published shortly on LLF’s website.

LLF is firmly committed to the highest ethical and operational standards. Accountability, along with the protection of Indigenous Peoples, local communities, and ecosystems, are central to all conservation efforts we support.

LLF’s decision to continue funding

After carefully reviewing the results of both studies, LLF has concluded that recommendations provided by both the ESDD and the milestone review will further strengthen environmental and social safeguards, governance, and human rights compliance in Odzala-Kokoua National Park. African Parks and the park management have agreed to adopt these recommendations.

Both assessments show that management of Odzala-Kokua National Park has made clear progress over the past years, with the ESDD evidencing an improved risk profile resulting from actions already taken. This progress has been confirmed by the milestone review, which finds that over 80% of the environmental and social action plan (ESAP) has been delivered. In addition, since July 2025, African Parks’ Board had already strengthened its oversight and accountability mechanisms, including establishing a Rights and Safeguards Subcommittee. African Parks further adopted an integrated management plan called Project Bomoko (Conservation Built on Human Rights | African Parks). Through this management plan, African Parks is mainstreaming safeguards measures and embedding a human rights-based approach to conservation to drive compliance with international safeguards standards across all its programs. LLF’s continued funding is intended to sustain this momentum and support the full implementation of the remaining recommendations for the benefit of local communities.

LLF believes that the steps taken since the Omnia report provide the necessary framework and action plan to guide Odzala‑Kokoua National Park in the implementation of its conservation strategy in a way that is aligned with international human rights standards and best practices. These include measures such as the set-up of the Independent Panel for Grievance Resolution, the development of a remedy framework, the implementation of the Odzala Indigenous Peoples plan and a strengthened collaboration with local human rights NGOs.

Conditions that are attached to continued funding into Odzala‑Kokoua National Park are the following:

LLF will continue to closely follow the implementation of further improvements in the park management by African Parks. On the ground, this means intensifying its on-site monitoring of the program. This includes increasing the frequency of its site visits to monitor and evaluate the implementation of the actions plans agreed with and proposed to African Parks and Odzala‑Kokoua National Park through the recently conducted ESDD, the milestone review and the Project Bomoko.

A minimum of 30% of LLF’s funding to Odzala-Kokoua will support the significantly increased investment in community development and strengthened safeguards around engagement with Indigenous Peoples and local communities. This includes prioritizing the land use planning and related zoning of the park within the next year.

LLF is convinced that continued funding into Odzala-Kokoua National Park will deliver positive and critical impacts for improving the human rights situation in the Congo Basin, especially for the Indigenous Peoples and local communities in the program area. African Parks as an institution is taking important steps in order to shift towards a human rights-based conservation approach. LLF’s support, particularly through its environmental and social safeguards system, has contributed to this shift and can further support African Parks and the park management on their path towards equitable and inclusive conservation.

Legacy Landscapes Fund (LLF) deeply regrets that the recently concluded investigation by leading international law firm Omnia Strategy LLP has confirmed certain allegations of human rights abuses involving ecoguards at Odzala‑Kokoua National Park. LLF takes these matters with the utmost seriousness and remains firmly committed to the highest ethical and operational standards. Accountability, along with the protection of Indigenous Peoples, local communities, and ecosystems, is central to all conservation efforts we support.

LLF has been informed of the safeguarding constraints that prevent African Parks from releasing the full report by Omnia Strategy LLP — constraints that are intended to protect the rights to privacy of the persons concerned as well as to protect witnesses and ongoing legal proceedings. Nevertheless, as an obligation under the Environmental and Social Safeguards System (ESMS) of LLF, serious incidents which involve harm to people need to be shared with LLF by implementing partners.  African Parks has met its obligations by providing all serious incidents and updates in due time during the LLF funding period. LLF has monitored these cases closely and continues to follow up on their handling. It is LLF’s understanding that the majority of alleged cases which were described in the press happened before our funding period.

Despite not having access to the findings and recommendations of the Omnia investigation, multiple exchanges with African Parks have made it clear to LLF that African Parks is committed to addressing procedural gaps, particularly those evident during the early years of its management of Odzala-Kokoua National Park. LLF understands that all known cases have either been resolved or are currently being addressed. Depending on the nature and severity of each incident, appropriate sanctions have been imposed or are in the process of being imposed on individuals found responsible for misconduct. Where appropriate to do so, cases will be referred to the local courts.

In addition, African Parks has announced specific measures to ensure the protection of human rights in the program area and beyond through a dedicated action plan. These include:

• the establishment of an independent panel of African judges and human rights specialists who will handle investigations into all allegations of serious misconduct impacting local communities and other stakeholders living in and around all protected areas managed by African Parks;
• the development of a remedy framework for victims;
• the revision of the curricula for rangers and new staff for risk prevention and proceedings;
• the implementation of an organization-wide action plan to ensure that a structural human rights-based approach is anchored throughout African Parks and that international human rights standards are adhered to.

With the above-mentioned measures in place, the implementation of the action plan, and given that African Parks is embedding these safeguarding measures in its day‑to‑day operations, LLF will maintain support for Odzala‑Kokoua National Park while undertaking two reviews in 2025: an updated Environmental and Social Due Diligence and a milestone assessment. These studies will gauge how effectively human rights safeguards are integrated and will guide our decision on future funding at the end of 2025. A summary of the findings will be published in early 2026.

LLF’s funding is essential to ensure that key remedy actions can be implemented and that the human rights situation is further improving with those measures. African Parks will report to LLF on a quarterly basis on the status of implementation of the action plan, including on remedy actions.

Since the beginning of its grant, LLF has contributed to tangible improvements in the human rights situation in Odzala-Kokoua National Park through clear guidelines, targeted support, and institutional reforms. A key component was the 2021 Environmental and Social Due Diligence (ESDD) study on environmental and human rights risks, which led to a range of measures, including staff training, regular audits of standard operating procedure (SOP) implementation, and a strengthened partnership with the local human rights organization Cercle des Droits de l’Homme et du Développement (CDHD) and the Observatoire Congolais des Droits de l’Homme (OCDH) to provide independent oversight of investigations and assist in conflict resolution. Representatives of local communities participate in decision-making through their involvement on the park foundation’s board. Additionally, a protocol for Free, Prior, and Informed Consent (FPIC), a dedicated plan for Indigenous Peoples, and a gender equity action plan were developed. LLF also supported the strengthening of the grievance mechanism and the launch of a process carried out in collaboration with the Congolese government and local communities to review access rights and zoning for the use of natural resources within the park.

Legacy Landscapes Fund acknowledges the completion of the independent investigation report by Omnia Strategy LLP, commissioned by the board of African Parks and undertaken in response to deeply concerning allegations of human rights abuses.

We take these matters very seriously and remain committed to upholding the highest ethical and operational standards through our Environmental and Social Management System. Ensuring accountability and safeguarding the well-being of Indigenous Peoples and local communities and ecosystems is at the heart of our work.

LLF is in contact with African Parks and with our Supervisory Board to define next steps after the finalization of the report, in compliance with LLF’s Environmental and Social Management System. Once these consultations have been finalized, we will provide a more detailed response.