Cargill

"We expect our Supplier Partners to: [...] Never use or tolerate the use of human trafficking,forced labor, or child labor as defined by theInternational Labour Organization (ILO);Foster an inclusive work environment that is free ofharassment and discrimination; Respect employees’ rights to organize and bargaincollectively"

"Cargill has helped morethan 16,500 of the 21,600smallholders around ourplantations and mills inSouth Sumatra and WestKalimantan to becomeRSPO certified. As a result,more than 10,000 hectaresof smallholder plantationland is now part of the sustainable palm oil supply." "Our plantations work with nearly 22,000 smallholder farmers (who have plantations of 2 hectares each)."

"Today, Cargill has partnerships with many diverse suppliers, including small businesses and we continue to grow our network of diverse supplier partners, especially in large and sustainable supply contracts and through business development opportunities. As a corporation, we strive to spend $1 billion with minority and women-owned businesses around the world."

"In our own operations and by engaging with our suppliers, Cargill is committed to: Require and partner with all suppliers to implement HCV and HCSA in their own operations andsupply chains [...] Development taking place without prior implementation of this methodology will be investigated through Cargill’s grievance process and may require remedial action."

"In our own operations and by engaging with our suppliers, Cargill is committed to: [...] Respect the rights of indigenous and local communities. We support FPIC as a core to protectingthose rights. Concerning the utilization of lands to which they hold legal, communal orcustomary rights, all new developments where appropriate, must undergo a social impactassessment and implement a FPIC process prior to commencement of activities, in a mannerthat is locally relevant to the affected communities."

"Issues related to deforestation and social exploitation often are not limited to a single supplier or sector, so we collaborate through landscape-level initiatives and platforms, such as the Tropical Forest Alliance (TFA), to address challenges that span physical and political boundaries and involve multiple commodities." [...] "actively participate in the Palm Oil Collaboration Group trialing the NDPE Implementation Reporting Framework as well as developing a collective approach and taking action on deforestation outside of concessions."

"Define Apply appropriate and measurable forest definitions to the individual supply chain and/or origination biome so that progress against our commitment can be measured, monitored and verified. Cargill sees that forest and land definitions are situational where the unique characteristics of each different supply chain and/or biome must be considered. Definitions should consider local social, rural economic factors and farmer considerations, as well as the broader issue of indirect land use change. [...] Forest definitions may include the High Carbon Stock Approach (HCSA) or conversion free approaches. [...]3. Quantify and Risk Assess Quantify the level of deforestation in the supply chain so that subsequent action can be taken for its reduction and elimination. Deforestation in a particular geography can be measured once the definition has been established in step 2, thereby allowing each business to annually report the percentage of the supply chain that complies with the deforestation-free commitment."

Compliance with law is set out in the supplier code of conduct which is a pilar within their Palm Policy - "The Cargill Code of Conduct, 1 Policy on Forests 2 , Commitment on Human Rights 3 and our Supplier Code of Conduct 4 are key pillars of our Palm Policy -[..] We will work with credible independent third parties to verify compliance of our suppliers with this Palm Policy, and to audit and evaluate the implementation and performance of this Policy across our supply chain."

" This Palm Grievance Process is developed as a part of our Palm Policy, April 2019 [...] Grievances can be expressed via any of the following channels: Via internet to Cargill Ethics Open Line By telephone to specific phone number for your country By fax to +65 6393 8797 ATTN: Stakeholder Engagement Manager In writing to Stakeholder Engagement Manager C/O Cargill Asia Pacific Holdings Ptd Ltd 138 Market Street #17-01, Capita Green Singapore 048946"

2018 ACOP indicates that Cargill sold 366,800 tons of palm oil (CSPO) in 2018.

In its palm oil policy, Cargill commits to "Conduct due diligence of new suppliers, assess risk, and proactively monitor our supply chains and sourcing landscapes using tools such as spatial assessments and social risk methodologies." This includes "All new developments where appropriate, must undergo a social impact assessment and implement a FPIC process prior to commencement of activities, in a manner that is locally relevant to the affected communities."

Cargill reported Cargill mills in the 2019 mill list.

Publishes a quarterly mill list, including direct and indirect suppliers- the most recent being Q4 2019.

"Our goal: Cargill-owned mills/ plantations (and smallholders supplying them) are compliant with our NDPE policy. [..] Our goal: NDPE compliance verified across the Cargill supply chain. We take a two-track approach to verification, including remote monitoring using satellite and radar technology to verify compliance with deforestation and peat commitments, and soon through our newly developed verification procedure" [...] "We have put in place or improved procedures to ensure continued compliance with our Policy on Sustainable Palm Oil and we regularly conduct internal audits of NDPE practices within our operations in addition to scheduled RSPO audits."

"We will work with credible independent third parties to verify compliance of our suppliers withthis Palm Policy, and to audit and evaluate the implementation and performance of this Policyacross our supply chain."

"When instances of deforestation in particular are identified and validated, we immediately suspend suppliers and work with them to define an action plan with clear timelines and milestones. Our supplier suspension process is outlined in our Palm Grievance Procedure."

Mill list includes suppliers (both direct and indirect) who have been 'struck off' the list, indicated by strikethrough - "Mills that have been struck off from our mill list are those which our suppliers formerly purchase from but have been suspended from our supply chain. We will continue to reflect these changes as they get updated" . Elsewhere, they report that 30 "mills in Cargill supply chain [are] engaged in Siak/Pelalalwan Landscape Program" and that it has a "Mill prioritisation for engagement", with 303 mills identified as high risk, 459 as medium risk, and 524 as low risk.

"We expect our Supplier Partners to: [...] Never use or tolerate the use of human trafficking,forced labor, or child labor as defined by theInternational Labour Organization (ILO);Foster an inclusive work environment that is free ofharassment and discrimination; Respect employees’ rights to organize and bargaincollectively"

"Empowering Soy FarmersWe work with soy farmers at all levels of production to help them achieve commercial success while growing crops more sustainably. [...] (for example) [...] Cargill works with more than 15,000 soy farmers with varying levels of production capacity in Brazil to help them adopt agronomic best practices and achieve compliance with regulations. Our focus includes helping smallholder soy farmers find commercial success. We work with more than 5,300 smallholders, offering them free agronomic analysis and other technical support while also paying them a premium on their crops. "

"Today, Cargill has partnerships with many diverse suppliers, including small businesses and we continue to grow our network of diverse supplier partners, especially in large and sustainable supply contracts and through business development opportunities. As a corporation, we strive to spend $1 billion with minority and women-owned businesses around the world."

"Respect and uphold the rights of workers, indigenous peoples and communities. [...] Land Tenure: 3.1 Support the FAO’s Voluntary Guidelines on the Responsible Governance of Land Tenurev . 3.2 Respect the rights of indigenous and local people. We support Free, Prior and Informed Consent as a core to protecting those rights"

"Cargill uses external registration and monitoring programs combined with internal processes to ensure that we do not buy soy produced from areas deforested after 2008"

"Soy Working Group and MoratoriumCargill actively participates in meetings of the Soy Working Group (GTS), formed by members of the Brazilian Association of Vegetable Oil Producers (ABIOVE), the Brazilian Association of Cereal Exporters (Anec), the Ministry of the Environment, Banco do Brasil and other civil society organizations, such as Greenpeace and WWF-Brazil. The Soy Moratorium is an industry agreement signed by the group in 2006 whereby companies pledged not to market or finance soybeans produced in areas in the Amazon that have been deforested post-2008. Cargill has been audited annually since then and our 2017 report was positively assessed by the group." [...] "Created in 2017, the Cerrado Working Group (GTC) brings together Brazilian and international NGOs, companies, governments, banks and consumers. In its first year, it was led by Cargill in partnership with WWF-Brazil. The multisectoral group aims to eradicate deforestation in the Cerrado and to reconcile soybean production with environmental, economic and social interests. To achieve this, the WG has explored a variety of solutions and options to address existing problems."

"This Soy Grievance Process is deployed by Cargill to handle any grievance identified and raisedby internal or external parties, including individuals, employees, contractors, suppliers, and civilsociety organizations, concerning compliance of the Soy Policy [...] The grievance may be raised by any external stakeholder or Cargill employee through threechannels available to receive grievances. These are listed below.- Via internet or phone through Cargill Ethics Open Line: In this case, the grievance isreceived through Cargill’s Global Ethics & Compliance Office (GECO) and then forwardedto the member of the Sustainability team responsible for the grievance process- E-mail: Ideally directed to the e-mail soy_grievancecoordinator@cargill.com- Letter: Handed out in person to members of the Sustainability team or addressed to theSouth America Soy Sustainability Grievance Coordinator, located in Brazil headquartersAv. Dr. Chucri Zaidan, 1240 – 6th floor – Diamond Tower – São Paulo – SP – Brazil"

"Building a sustainable, deforestation-free supply chain for soy in South America is anchored in The Soy Toolkit created by Proforest, adapted for the specifics of our business and what we have learned doing similar work in other geographies and supply chains. Regarding risk assessment overall, land conversion is our primary filter in order to protect natural landscapes "[...] "This engagement prioritization process / risk assessment methodology is applied to section 3 of our Soy Action Plan for the Cargill Policy on Sustainable Soy – South American Origins. • The approach incorporates both a historical lens of past land conversion that has soy cultivation today and a future lens of examining existing land status on land that is suitable for future soy cultivation [...] This methodology is applied to the Amazon, Cerrado and Gran Chaco biomes of Brazil, Argentina, Paraguay, Uruguay and Bolivia."

"Government agencies in Brazil play a key role in protecting native vegetation. The country’s 2012 Forest Code established mechanisms for addressing illegal deforestation and stipulated that between 20% and 80% of native vegetation on agricultural properties must be preserved, depending on the region. Meanwhile, the federal government maintains lists of farming operations accused of illegal deforestation and slave labor. On a daily basis, our commercial system consults these government lists of embargoed farms and blocks them so they are not eligible to sell soy to us. Our system also consults lists of non-compliant producers managed by the Soy Working Group (GTS) based on the Amazon Soy Moratorium, as well as voluntary programs managed by the state of Pará such as the Green Grain Protocol. When a farm is blocked in our system for being on one of these lists, we also block other farms registered to the same person or entity in the local area (or in the case of a farm that shows up as a labor violator, we block all other associated farms across Brazil). These affiliated farms are only unblocked once we have conducted an analysis to ensure that soy from the violating farm is not being rerouted and sold to us through the affiliated operations. This helps ensure that the soy flowing into our supply chains was produced responsibly. Our local commercial teams have been fully trained on these tools and procedures [...] Cargill uses external registration and monitoring programs combined with internal processes to ensure that we do not buy soy produced from areas deforested after 2008. These programs continue to function robustly. Meanwhile, the latest report on the Soy Moratorium shows that in 95 municipalities across seven states representing 98% of soy production in the Amazon biome, just 1.4% of the total soy grown in the biome during the last crop failed to comply with the no-deforestation requirement. Cargill does not buy from any of these noncompliant producers."

"Ending legal deforestation will require more detail on where, when and why it occurs. Our new system will use data from sources like the University of Maryland and Global Forest Watch to identify legal land conversion as it is happening in our supply chain. Then, our commercial teams will be able to engage with the relevant farmers. As other incentive mechanisms for conservation are developed, we will be able to offer these as alternatives to those farmers so they can protect both their livelihoods and the forest resources on their land."

"In the second half of 2019, 75 farms were blocked"

"We expect our Supplier Partners to: [...] Never use or tolerate the use of human trafficking,forced labor, or child labor as defined by theInternational Labour Organization (ILO);Foster an inclusive work environment that is free ofharassment and discrimination; Respect employees’ rights to organize and bargaincollectively"

"Today, Cargill has partnerships with many diverse suppliers, including small businesses and we continue to grow our network of diverse supplier partners, especially in large and sustainable supply contracts and through business development opportunities. As a corporation, we strive to spend $1 billion with minority and women-owned businesses around the world."

"Define Apply appropriate and measurable forest definitions to the individual supply chain and/or origination biome so that progress against our commitment can be measured, monitored and verified. Cargill sees that forest and land definitions are situational where the unique characteristics of each different supply chain and/or biome must be considered. Definitions should consider local social, rural economic factors and farmer considerations, as well as the broader issue of indirect land use change. [...] Forest definitions may include the High Carbon Stock Approach (HCSA) or conversion free approaches. [...]3. Quantify and Risk Assess Quantify the level of deforestation in the supply chain so that subsequent action can be taken for its reduction and elimination. Deforestation in a particular geography can be measured once the definition has been established in step 2, thereby allowing each business to annually report the percentage of the supply chain that complies with the deforestation-free commitment."

" If you see or suspect any conduct or business practices that you think could violate our Supplier Code, please contact Cargill directly. You may raise a concern or get help by: [...] Calling our secure Cargill Ethics Open Line." This includes a link to Cargill's EthicsPoint address, which allows third parties to submit a report online or by phone.

"Our commitment is to work with suppliers who are committed to helping us achieve our sourcing targets, engaged in continuous improvement practices, and making efforts toward adherence to our policy.  When Cargill acquires a new business, a milestone-based implementation plan will be developed to ensure compliance with our policy within two years of acquisition."

"When Cargill acquires a new business, a milestone-based implementation plan will be developed to ensure compliance with our policy within two years of acquisition.  Packaging suppliers who are considered out of compliance with our policy will be evaluated and may be suspended if they are confirmed, through a credible source, audit or verification process, to be in violation of our fiber-based packaging policy."