Our response to TotalEnergies on the Papua LNG project

TotalEnergies recently published a short response to our formal 60-page complaint to the Equator Principles (1) detailing urgent concerns about the potential climate, biodiversity and human rights impacts of its proposed Papua LNG project in Papua New Guinea. In the interest of all stakeholders, including financial institutions who have signed the Equator Principles and who may be approached to finance the project, the authors of the complaint outline the gaps in TotalEnergies’ response about the Papua LNG project. (2) 

Co-signed by CELCOR, JACSES, Jubilee Australia, Market Forces and Reclaim Finance

The Papua LNG project, (3) operated by TotalEnergies EP PNG with co-venturers Exxon Mobil, Santos and ENEOS, would contribute to emitting 220 million tonnes of CO2; it would affect at least 12,700 Indigenous Peoples in the Gulf Province of Papua New Guinea; (4) and it would have potentially irreparable impacts on some of the 100 species unknown or undescribed by science as well as at least 27 species facing a high or extreme threat of extinction. (5)

Its reported financial advisor, Japanese megabank Mitsubishi UFJ Financial Group (MUFG), is currently seeking to raise finance for the project including through contacts with seven export credit agencies and more than 30 commercial banks, according to TotalEnergies. (6) In December 2025, our organizations filed a detailed 60-page complaint raising concerns about the apparent lack of adherence of the upstream part of the project with six of the ten Equator Principles, (7) a set of financial industry standards, signed by MUFG.

In January 2026, TotalEnergies published a short response to the complaint. Yet this does not adequately address the concerns raised. (8)

While maintaining our call for the Equator Principles governing body to initiate an investigation into the concerns raised in the complaint, we highlight the gaps in TotalEnergies’ response for the benefit of any financial institution that may be considering financing the project. (9)

TotalEnergies indicates that the project has been engaging with local communities, but still has not provided any evidence of clear and accessible community information materials about the project’s risks and impacts. For example, it has not provided materials that explain what gas condensate is; the risks and impacts of pipelines; what hazardous materials may be used on the project site; or the ecological impacts of river dredging etc.

The project’s newsletters describe processes – such as timelines, milestones, studies being undertaken and information about how the project supports charities – but they do not provide information about such risks and impacts or details of any provisions to respect indigenous people’s rights under international law and standards.

The project’s own advisory panel, chosen by TotalEnergies, raised concerns about how information about the project has been communicated (10) and a previous partial Human Rights Impact Assessment found low community understanding of the project. (11)

Providing clear information about risks and impacts is a simple, basic provision necessary according to the Equator Principles – and more broadly – without which it is impossible for stakeholders, including Equator Principles signatories, to establish whether local communities have been properly informed about the project.

TotalEnergies says that it has designed a Free, Prior and Informed Consent (FPIC) process in alignment with international standards. Yet in addition to a lack of evidence that Indigenous People affected have been thoroughly “informed” about the project, the company has not provided any evidence that they have been informed of their rights under the United Nations Declaration on the Right of Indigenous Peoples to refuse the project, or to refuse it unless certain conditions are met. (12) Under such circumstances, the criteria of “consent” is not fulfilled.

Similarly, the “Prior” in FPIC means that a meaningful role in decision-making must be achieved before major project decisions are made and authorisation given. (13) The standard of “prior” cannot be met if meaningful involvement in decision-making has not been achieved before a Final Investment Decision, which TotalEnergies says it will announce in 2026.

Finally, TotalEnergies says that “communities are assisted by third-party legal advisors, which (…) ensure that community members fully understand their rights and obligations”. (14) In its 2019 Environmental Impact Statement TotalEnergies noted that it would “engage an independent trusted third party to raise awareness, provide legal advice and assistance to customary landholders” (15) on land access or land compensation. This suggests that the legal advisors are contracted to TotalEnergies. Affected communities should have access to independent legal advice of their own choice.

We are also aware of at least one case of Purari delta residents trying to access urgent legal assistance over concerns about approvals for waste disposal into the Purari river system. (16)

TotalEnergies says that a Climate Change Risk Assessment (CCRA) has been performed, yet has not made that document public which appears likely to breach the Equator Principles 2, 3, 4, 5 and 10. This prevents communities affected by the project, as well as other climate-affected communities in Papua New Guinea, and any other stakeholders, from scrutinizing the project’s assessment and claims regarding climate impacts.

This is of particular concern, given that TotalEnergies faces numerous current or recent legal and regulatory cases that relate to allegations of misleading climate claims or hiding known climate impacts. In October 2025, a Paris Court ruled that TotalEnergies misled consumers in its advertising by giving the impression that it is part of the solution to climate change despite continuing to promote and sell more fossil fuels. (17) TotalEnergies has also recently lost other cases regarding misleading information about its commitments to sustainable development and climate in Germany, South Africa and the UK. (18) ExxonMobil – a key co-venturer – is also facing legal actions related to its climate claims. (19)

TotalEnergies does not appear to have disclosed information about these legal and regulatory cases to affected communities – which could materially  influence how people assess information provided by the project.

On human rights, TotalEnergies refers to a (second) Human Rights Impact Assessment (HRIA) performed in 2025 to update the 2017 initial HRIA, but has not published this document. Among other issues, this denies local people the chance to check the veracity of the document and the opportunity to be informed of potential adverse impacts on their human rights that may be identified in the assessment.

The 2019 Upstream Environmental Impact Statement (EIS) and the 2024 EIS Addendum, evaluating the biodiversity impacts of Papua LNG, are not available on the project website, or on any relevant government website. The project’s failure to include two of the three EIS summaries on its website is a clear breach of Equator Principle 10, making it impossible for stakeholders to assess the impacts on biodiversity. The only document available that is mentioned in TotalEnergies’ response regarding biodiversity is the Biodiversity and Ecosystems (BES) Policy, consisting of 1 page. (20)

TotalEnergies’ response does not address concerns that the project area contains around 100 species that scientists have never studied or described.  If nothing is known about these species – it’s impossible to understand, let alone mitigate risks, including the risk of extinction. It is not known what role these species play in safeguarding the habitat of a further 27 species that are on the IUCN Red List facing high or extreme risks for extinction. (21)

Finally, TotalEnergies does not address questions and concerns in the complaint regarding why the Bulmer’s Fruit Bat – one of the 100 most critically endangered species in the world with attendant obligations for its protection – was taken off the “sensitive species” list, (22) without explanation and without identifying who made this decision.

TotalEnergies states that the “EIS addresses the cumulative impacts with other industrial projects such as the Mayur mining project and the Ihu Special Economic zone”. However, the 2019 Upstream EIS states that the Ihu SEZ was “out of scope” (23) and the 2024 EIS Addendum did not update the chapter on cumulative impacts.

TotalEnergies considers that the cumulative impacts of the Papua LNG project and other oil and gas projects mentioned in our complaint cannot be assessed, because they “are still in a design phase”. This contradicts the Equator Principles 2022 guidance, which states that “cumulative impacts should consider existing, planned and/or reasonable anticipated future projects”, (24) in line with the 2013 International Finance Corporation (IFC) Performance Standards good practice recommendations on cumulative impact assessments.  (25)

Even so, the project has not considered the cumulative impacts of the Pasca A project, which submitted its first Environmental Impact Statement in January 2016, three years before Papua LNG’s first upstream EIS, (26) or the impacts of the floating LNG facility in the Gulf of Papua, for which Kumul Petroleum – the state-owned company – has signed a pre-FEED contract in 2024. (27)

TotalEnergies announced in its response that a “small group of families who have recently moved into the vicinity of the Project will be subject to specific resettlement measures”. IFC Performance Standard 5 advises to “avoid involuntary settlement wherever possible”. The 2024 EIS Addendum indicates that 42 people have been living in Pokore Hamlet since 2020. (28) This was years before the project’s downstream EIS or upstream EIS Addendum were submitted. The Addendum’s list of “key stakeholder engagement activities” makes no mention of Pokore Hamlet. This suggests that the project was not communicating with the local people. The EIS Addendum notes that “stakeholder acceptability” of the new Central Processing Facility location, approximately 700 metres from Pokore Hamlet, was “unknown”. (29) This suggests that their views were not sought, as required under the IFC Performance Standards.

TotalEnergies has not explicitly ruled out forced eviction of this community and we have not seen any statements from the project ruling out forced eviction, which is of concern given the history of forced evictions in PNG. The IFC advises that forced evictions should be avoided, and as recently as February 2025, the United Nations in PNG has expressed “deep concern” about forced evictions from the Baruni informal settlement in Port Moresby. (30) The lack of clarification raises particular concerns about the women and the children who will be moved.

Papua LNG will operate in a country and an industry that is extremely risky for women and girls. A recent study from the US Institute for Peace highlighted grave concerns regarding the gender impacts of ExxonMobil’s PNG LNG project, including domestic violence and rise in what they term a “sexual economy”. (31)

Yet TotalEnergies has not addressed the points raised in our complaint regarding gender impacts, including prerequisites on gender equality in hiring, evaluation of gender-differentiated impacts of the project and of the resettlement of the Pokore Hamlet, and consideration of gender inequality in negotiations and agreements with landowners. (32)

The complaint did not dispute that the project has a grievance mechanism, but that the lack of clear and accessible community information materials raises concerns about the effectiveness and equitability of the mechanism. If communities do not have full information about the project’s risks and potential impacts, or their rights under international law and standards, they are less likely to file grievances using TotalEnergies’ mechanism or other independent mechanisms. (33) TotalEnergies has not provided any evidence of community materials that would address this point.

The upstream Environmental Impact Statements does not consider corruption or bribery-related risks. This is of particular concern given that Papua New Guinea has just received its worst score in a decade under the Transparency International Corruption Perceptions Index (34) and has been grey-listed by the Financial Action Task Force for its inability to manage money-laundering and associated financial crime. (35)