Archer Daniels Midland Co.

"We will work throughout our supply chains to achieve the following: Respect Human Rights, according to the U.N. Guiding Principles for Business and Human Rights, • Respect Labor Rights as set out in the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work"[...]"In accordance with our Commitment to Respect Human Rights, we require that stakeholders in the ADM supply chain: Do not discriminate in employment-related decisions; Never use child labor, or forced and/or bonded labor;  Respect workers’ rights, including contract, temporary and migrant workers, to the freedom of association and the right to collective bargaining; Do not discriminate in employment-related decisions; Maintain systems and procedures designed to keep workers safe and protect them from occupational hazards, harassment and abuse

"Harassment and Discrimination – We prohibit discrimination in our operations and supply chain on the basis of race, color, religion, sex, gender identity, national origin, immigration status, disability, age, sexual orientation, marital status or any other status protected by local law. We prohibit harassment and abuse. These prohibitions extend to migrant workers. We expect our suppliers and business partners to implement the same practices."

"In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following: [...] Application of the principles of Free, Prior and Informed Consent (FPIC) to ensure protection and promotion of the rights of indigenous peoples and vulnerable communities. This includes but is not limited to respecting legal and customary land rights and prevention of land grabbing activities,"

"We will work throughout our supply chains to achieve the following: Respect country, state, municipal and local laws regarding environmental, safety, human rights and labor rights,... We require our suppliers to operate their businesses ethically - including land acquisition and land use - within all applicable laws and regulations, and to uphold our commitments... Regional and supply chain-based monitoring procedures will be established and updated to verify supplier compliance with this policy. If indicated by the supply chain assessment, remote sensing will be used to track where the commodity is being produced."

"ADM is working hard to develop supply chains that meet our Commitment to No-Deforestation and Human Rights Policy. To that end, we invite stakeholders who have concerns related to the implementation of our policies to email us at responsibility@adm.com."

"We will work throughout our supply chains to achieve the following: Respect Indigenous and Local Community rights to land and resources in accordance with the U.N. Declaration on the Rights of Indigenous Peoples, • Respect Human Rights, according to the U.N. Guiding Principles for Business and Human Rights, • Respect Labor Rights as set out in the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work"; "In accordance with our Commitment to Respect Human Rights, we require that stakeholders in the ADM supply chain: [...] Never use child labor, or forced and/or bonded labor; [...] Do not discriminate in employment-related decisions; [...] Respect workers’ rights, including contract, temporary and migrant workers, to the freedom of association and the right to collective bargaining"

"In Brazil, ADM partnered with theBrazilian Society for Wildlife Research andEnvironmental Education (SPVS) on a projectto promote sustainable farming practices andbiodiversity conservation. Focusing mainlyon smallholder farms, the project drew ontraditional agricultural knowledge and modernbiodiversity initiatives to provide guidanceon improving sustainability management,resistance to climate change and overallcrop yields. ADM trained approximately 300 smallholders located in the municipalities of São Domingos do Capim, Mãe de Rio andIrituia, located in the Northeastern state ofPará, which encompass highly biodiverseforests and rivers: ecosystems that are vitalto the conservation of biodiversity in theAmazon, as well as the socio-economicdevelopment of the local area."

"Harassment and Discrimination – We prohibit discrimination in our operations and supply chain on the basis of race, color, religion, sex, gender identity, national origin, immigration status, disability, age, sexual orientation, marital status or any other status protected by local law. We prohibit harassment and abuse. These prohibitions extend to migrant workers. We expect our suppliers and business partners to implement the same practices."

"In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following: ... Cooperate with ADM and all parties necessary to enable the provision of access to fair and just remediation."

"In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following:... Application of the principles of Free, Prior and Informed Consent (FPIC) to ensure protection and promotion of the rights of indigenous peoples and vulnerable communities. This includes but is not limited to respecting legal and customary land rights and prevention of land grabbing activities,.."

ADM reports 450,257 tonnes in 2020 certified by RTRS

"Transparency and Traceability – We have traceability for 100% of our direct and indirect soy suppliers in Argentina, Brazil and Paraguay. For direct suppliers, we map to the farm level using digital satellite mapping (polygons). This database enables measurement of Deforestation and Conversion Free (DCF) volumes, which in 2020 equaled 97%. For indirect suppliers, we trace to the first aggregation point and then monitor a radius around that location for indications of deforestation. In areas with a high risk of conversion to soy, indirect parties will also be required to show compliance with the company’s policies on the volumes sold to ADM"

"In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following: • No development of hotspot areas (High Conservation Value or High Carbon Stock), • No development on peatlands, regardless of depth2, and the utilization of best management practices for soils and existing commodity production on peatlands,.."; "This policy applies to ADM’s own operations and across all supply chains in which ADM operates, including all supplier tiers back to the origin from where commodities are sourced, and for all companies/JVs in which ADM holds an ownership stake."

"ASM changes cut-off date to 2008 to be in compliance with BR Forest Code"

"ADM is an active member of Grupo de Trabalho da Soja (Soy Working Group), a group of NGOs and industry companies, most notable for developing the Amazon Soy Moratorium. We are also a member of the spinoff group Grupo de Trabalho do Cerrado (Cerrado Working Group), which is working to address deforestation in the Cerrado Biome. And, we participate in the MATOPIBA Coalition, an initiative supported by the United Nations Development Programme (UNDP) Global Environmental Finance (GEP), which brings together different actors willing to find sustainable balance between agricultural production and conservation."

"ADM will do a risk-based assessment to define the type of traceability/monitoring that will be required geographically3 . ADM’s sourcing commitment in high-risk areas is especially focused on soybeans sourced in areas of South America, such as the Amazon, Cerrado, and Chaco biomes. - In low risk areas for deforestation, identify sourcing of the country of origin (ex: United States, Canada). - In medium risk areas for deforestation, identify the state/province of origin and where possible, the municipality level. - In high risk areas for deforestation, identify the percentage from indirect and direct sourcing. For direct supplier, the origin to farm of soy being sourced (e.g., obtain farm polygons), and for indirect suppliers obtain GPS coordinates."

"We will work throughout our supply chains to achieve the following: Respect country, state, municipal and local laws regarding environmental, safety, human rights and labor rights,... We require our suppliers to operate their businesses ethically - including land acquisition and land use - within all applicable laws and regulations, and to uphold our commitments... Regional and supply chain-based monitoring procedures will be established and updated to verify supplier compliance with this policy. If indicated by the supply chain assessment, remote sensing will be used to track where the commodity is being produced."

"ADM is working hard to develop supply chains that meet our Commitment to No-Deforestation and Human Rights Policy. To that end, we invite stakeholders who have concerns related to the implementation of our policies to email us at responsibility@adm.com."

450,257 tonnes are RTRS certified in 2020.

"Monitoring and Verification - Since 2018, specialized firms with GIS technology (satellite imaging) started cross-referencing planted areas within the polygons with historic land coverage to understand if the soy being sourced was compliant with our No Deforestation Policy. Farms are also verified to make sure there are no environmental issues (IBAMA embargos), encroachment into protected areas or Indigenous Territories,or labor issues which violated our No Exploitation Policy"

"The ADM Responsible Soybean Standard applies to select soybean suppliers. To ensure compliance, an annual inspection will be conducted by a third party inspection body with knowledge and accreditations for auditing of sustainability standards. The inspections will be done in groups, managed by ADM. ADM will be responsible for including and excluding farms belonging to the group; the farms shall go through a verification before becoming members. The members must agree to annual inspections, performed by a third party."

"Process to Manage Supplier Non-Compliance The actions to be taken to manage non-compliances will depend on the results of an investigation into the alleged non-compliance. Investigation results will determine the severity of the non-compliance...When a verified Major Non Compliance is identified, ADM will suspend the supplier and then there may be engagement to establish the corrective action plan. The corrective action must be implemented prior to the next contract. When a verified Minor Non-compliance is identified, ADM will suspend any commercial activity until the supplier presents an action plan to solve the issue. The corrective action must be implemented prior to the next contract. If ADM management decides to remain engaged commercially with the supplier that is the subject of an alleged non-compliance, then ADM will define in a written, time-bound action plan the actions expected to be taken by the supplier to achieve compliance. ADM will support, monitor and supervise the performance of the corrective actions or work through direct suppliers to support, monitor and supervise corrective actions for indirect suppliers until the issue is resolved."

"We will work throughout our supply chains to achieve the following: Respect Human Rights, according to the U.N. Guiding Principles for Business and Human Rights, • Respect Labor Rights as set out in the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work"[...]"In accordance with our Commitment to Respect Human Rights, we require that stakeholders in the ADM supply chain: Do not discriminate in employment-related decisions; Never use child labor, or forced and/or bonded labor;  Respect workers’ rights, including contract, temporary and migrant workers, to the freedom of association and the right to collective bargaining; Do not discriminate in employment-related decisions; Maintain systems and procedures designed to keep workers safe and protect them from occupational hazards, harassment and abuse

"Palm LAB - Labor Assessment Builder Program in Colombia: In 2020, ADM supported a multi-stakeholder alliance coordinated by Solidaridad aimed to build an inclusive palm oil value chain between Colombian smallholders, processors and international markets. The project is developing and implementing a data driven tool that will enable around 500 farmers and processors to plan, monitor and verify the uptake of labor practices as defined by the VSS and ADM’s corporate policies."[...]"Development of trainings for smallholders on workplace discrimination, harassment and abuse as well as on the importance of maintaining and conserving HCV area, minimizing humanwildlife conflict, and recognizing rare, threatened and endangered species and important ecosystems."

"Harassment and Discrimination – We prohibit discrimination in our operations and supply chain on the basis of race, color, religion, sex, gender identity, national origin, immigration status, disability, age, sexual orientation, marital status or any other status protected by local law. We prohibit harassment and abuse. These prohibitions extend to migrant workers. We expect our suppliers and business partners to implement the same practices."

"In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following: [...] Application of the principles of Free, Prior and Informed Consent (FPIC) to ensure protection and promotion of the rights of indigenous peoples and vulnerable communities. This includes but is not limited to respecting legal and customary land rights and prevention of land grabbing activities,"

"Traceability to Mill: Improve traceability of palm oil (PO) and palm kernel oil (PKO) to mill to maintain high visibility into ADM’s palm supply chain and reduce deforestation risk: In progress Palm Oil 99.90%"[...]"We are engaging with 100% of our direct suppliers on a responsible sourcing program"[...]"Number of indirect mills: 1.666" - Therefore unclear proportion of compliant commodity volume disclosed as unclear whether also engage with these indirect mills and therefore what the traceability status of these indirect mills is.[...] "Palm Oil traceable to mill 99.9%... traceable to plantation* 43.1%[...] Palm Kernel Oil traceable to mill 98.6%... traceable to plantation* 44.8% *Traceable to Plantation: self-reported information from suppliers that has not been verified"

"We aim to eliminate deforestation from all of our supply chains by 2025. [...] In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following: • No development of hotspot areas (High Conservation Value or High Carbon Stock), • No development on peatlands, regardless of depth2, and the utilization of best management practices for soils and existing commodity production on peatlands [...] This policy applies to ADM’s own operations and across all supply chains in which ADM operates, including all supplier tiers back to the origin from where commodities are sourced, and for all companies/JVs in which ADM holds an ownership stake."

"Since 2018 , ADM has supported the Conservation International (CI) Singapore program implementation in North Sumatra . At the heart of the program is a train -the -trainer approach to educating farmers . The training sessions teach methods to improve productivity while conserving critical forest areas, with a focus on palm oil . In addition to farmer training, the program also educates community members about the importance of sustainable production and post -harvest handling best practices to maximize the economic impact of local farming [...] ADM’s support will enable facilitation of agroforestry training, environmental education, and progress monitoring for up to 150 smallholder farmers, protecting up to 10 ,000 ha of forested land , indirectly benefiting a population of up to 500 in Binasari ."

"Discussions with critical stakeholders on the topics of land conversion from forest to plantations, human-wildlife conflict, peat protection, and the Leuser ecosystem were carried out to support the Subulussalam City Government in producing an essential government planning procedure: The Strategic Environmental Assessment. This project empowered the village governments and local communities in two villages, Singgersing and Bawan, to protect their natural resources through two main activities in 2021: participatory land-use planning (PLUP) and an oil palm replanting scheme for smallholders, including an alternative livelihood program. The stakeholders in these two villages had completed the PLUP process of the villages and agreed to protect 8,059 hectares of forest area outside concessions. The result of PLUP allowed the Subulussalam District Land Agency to identify potential company-community conflicts and discuss the solutions under the government's different schemes, such as conflict resolution, land registration, and social forestry. This project provides technical support to improve farmers’ resilience through alternative livelihoods during replanting. 74 farmers with 209 hectares old oil palm plantations were trained to cultivate durian and banana identified as supplementary livelihoods to support them during the first four years after replanting when oil palms are not productive. Following a signed MOU with an oil palm plantation company, EF supported the company to implement actions in line with NDPE commitments, such as HCV-HCS assessments and participatory land-use planning. Based on an HCV-HCS assessment, the company identified and planned the management of 3,700 hectares of conservation area within their concession. "

"In addition to the principles and commitments of our Policy to Protect Forests, Biodiversity and Communities, we expect our direct and indirect palm oil suppliers to commit to the following: Conduct of Social and Environmental Impact Assessments (SEIA) prior to new plantings or after operations"

"We will work throughout our supply chains to achieve the following: Respect country, state, municipal and local laws regarding environmental, safety, human rights and labor rights[...]We require our suppliers to operate their businesses ethically - including land acquisition and land use - within all applicable laws and regulations, and to uphold our commitments."

"We welcome correspondence from any external parties, including individuals, government organizations and non-governmental organizations, regarding the implementation of and compliance with our Commitment to No-Deforestation and our Human Rights Policy. Please send any concerns to responsibility@adm.com. When making an inquiry and/or raising a grievance, please make sure to provide us with the following information: 1) Your full name (optional) 2) The name of your organization (if applicable) 3) Mailing address / email address 4) Phone, fax or email 5) Detailed description of the concern 6) Evidences to support the issue We will respond as quickly as possible once we have received your communication. Please see the Issues and Resolutions workflow on the next page."

In the 2020 RSPO ACOP report, ADM report 45008 tonnes of CPKO Crude Palm Kernel Oil and 309378 tonnes of Crude Palm Oil CPO.

ADM provides a "List of supplying mills This represents the complete list of mills in ADM´s global supply chain, which are sourced indirectly through third-party refiners January 2021 - June 2021"

"Supplier Engagement – We use the Palm Scorecard implemented by a third-party assessor to evaluate the performance of our direct palm suppliers. Our findings for 2021 show that we nearly reached our target to have 100% of our volumes from suppliers with a publicly available NDPE policy, a grievance management system, a responsible sourcing implementation plan, and a human rights due diligence process in place. The scorecard tool provides valuable insight of past performance data and provides us feedback on how to make better decisions in the future. We have identified the need to create an additional supplier assessment tool to enable proactive screening of suppliers prior to sourcing from them to ensure they align with our sustainability criteria and standards. Monitoring and Verification – ADM continues to participate as an active member in the No Deforestation, Peat or Exploitation (NDPE) Integrated Reporting Framework (IRF) Active Working Group to drive progress on reporting against NDPE criteria. ADM has engaged with all its direct suppliers on the provision of their respective NDPE IRF profiles. A total of 94.3% of volumes are covered under the reporting. In July 2021, we completed verification of each individual site profile by an independent third-party. We also report certified sustainable palm oil supplies using the volumes of PO and PKO certified by the Roundtable for Sustainable Palm Oil (RSPO). Certified supplies are driven by market demand."

"Process to Manage Supplier Non-Compliance The actions to be taken to manage non-compliances will depend on the results of an investigation into the alleged non-compliance. Investigation results will determine the severity of the non-compliance...When a verified Major Non Compliance is identified, ADM will suspend the supplier and then there may be engagement to establish the corrective action plan. The corrective action must be implemented prior to the next contract. When a verified Minor Non-compliance is identified, ADM will suspend any commercial activity until the supplier presents an action plan to solve the issue. The corrective action must be implemented prior to the next contract. If ADM management decides to remain engaged commercially with the supplier that is the subject of an alleged non-compliance, then ADM will define in a written, time-bound action plan the actions expected to be taken by the supplier to achieve compliance. ADM will support, monitor and supervise the performance of the corrective actions or work through direct suppliers to support, monitor and supervise corrective actions for indirect suppliers until the issue is resolved."

In their grievance log, ADM report a list of suppliers they engage with regarding non-compliance with their deforestation policy.