Cargill Inc

"A key measure of our success is sending every employee and contractor home safe every day. We are committed to conducting all our business activities in a manner that protects the health and safety of our people. [...] We promote and respect human rights as outlined in the Universal Declaration of Human Rights and the UN Sustainable Development Goals. We are a participant in the UN Global Compact. We take guidance from the UN Guiding Principles on Business and Human Rights and the International Labour Organisation Fundamental Principles and Rights at Work."[...] "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 of harassment and discrimination; Respect employees’ rights to organize and bargain collectively" [...] "In line with RSPO standards conduct a living wage assessment, initially in our oil palm plantation operations, based on credible methodologies with the goal of ensuring workers have access to decent living wages [...] We will ensure that conditions of work - working hours, rest days and overtime comply with the law and collective agreements."

"Cargill has helped more than 16,500 of the 21,600smallholders around our plantations and mills in South Sumatra and West Kalimantan to become RSPO certified. As a result, more than 10,000 hectares of smallholder plantation land 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)." [...] "We promote the inclusion of smallholders in our supply chain and improvement of their livelihoods. Our approach includes:Collaboration with mills in our supply chain – We include smallholders in our high-priority mill field assessments and provide support to help mills deliver on their smallholder transformation plans. We develop tools to empower farmers through new technologies, training, access to fertilization and other resources.Landscape-level programs – We participate in programs focused on building smallholder capacity and promoting responsible farm development. These projects improve smallholder livelihoods and inclusion in three ways. First, through farmer training on business skills, good agricultural, environmental and social practices. Second, through farm development, including replanting, access to inputs and crop diversification. And third, by partnering with suppliers on strategic programs focused on helping smallholder farmers achieve RSPO certification, which results in higher yields, better access to markets, increased profitability and more reliable income streams."

"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."

"Labor practices We worked with Verité Southeast Asia to develop our human rights strategy focusing on due diligence, monitoring and remediation, including capacity building for Cargill employees."[...]"Some suspended suppliers choose to continue unsustainable practices and operate in “leakage markets” where they sell to customers that do not enforce NDPE standards. To address these challenges, Cargill is working to build incentive models to encourage these suppliers to pursue remediation."

"Cargill expects the process of Free Prior Informed Consent to obtained before commencement of activities and expects our suppliers to do the same. We also strongly encourage suppliers to conduct Social Impact Assessments"

"Cargill is guided by the SOP Land Dispute Settlement in dealing with land claims/dispute in our business operation license area. The company will ascertain and map the area first to ensure the land dispute is located inside the company’s own plantation, Inti or KKPA concession. The land claimant must meet at least 2 criteria: there is a written statement from the claimant and there is valid supporting documentation issued by the relevant authority held by the claimant. Settlement of land claims result in a legally accountable agreement, which becomes a valid record and evidence, to avoid reoccurrence of the issue on the same place or land objection in the future."

In their 2021 reporting, "100% Fresh fruit bunches originate from NDPE-compliant sources" [...] Proportion of RSPO certified volumes out of global volumes: 17% of all Cargill volumes physically certified (RSPO segregated and mass balance), 38%RSPO segregated sold in Europe, 10% RSPO mass balance sold in Europe and US" [...] In 2021 ACOP report Cargill state that 100% of their estates and mills are RSPO certified

"The scope of the palm oil policy includes all operations of suppliers - "We work with our direct and indirect suppliers across all their operations, smallholders, customers, governments, non-governmental organizations, industry associations and other stakeholders to implement this policy and continuously drive compliance."

"We have monitored conversion of natural ecosystems since specified cutoff date" specified as 2018 for own land in Indonesia.

"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 as issues related to deforestation and social exploitation often are not limited to a single supplier or sector.[...]We helped to convene the Production Protection Beyond Concession (PPBC) Action Group, part of the Palm Oil Collaboration Group, in 2020 to design and implement new approaches for addressing this deforestation and supporting rural livelihoods in Indonesia and Malaysia. That work continues in 2021.[...]Together, the industry must address the problem of “leakage” markets (buyers who do not enforce NDPE standards) by finding new ways to incentivize smallholders and other suppliers to follow NDPE guidelines. Cargill is evaluating ideas, including mentoring suppliers to help them pursue remediation and gain access to support services and financing to help them get on the path toward compliance."

"In the Siak and Pelalawan districts of Indonesia, a coalition formed by Cargill and eight other companies working together with CORE (Daemeter and Proforest) conducted the first year of implementation activities to advance the Siak and Pelalawan Landscape Program. We continued with training stakeholders on key topics, including certifications and inclusion of women. We plan to continue engagement with local government agencies and other stakeholders to support them in implementing the Pelalawan Sustainable Palm Oil District Action Plan. As described in our Palm Oil Policy, these engagements are in support of Cargill’s commitment to protect environmentally, socially, and economically important resources for the benefit of current and future generations; transforming the supply chain helps us meet our environmental goals."

"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."

"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 includes adhering to all applicable and relevant local and national laws, and international human rights principles"

"Cargill is committed to sustainable palm oil production and sourcing. We believe it is critical that all parts of our palm oil supply chain – plantations, processing and trading operations and all third-party suppliers – act in an environmentally sustainable and socially responsible manner. Cargill's Palm Grievance Procedure was formally established in December 2015 to provide a transparent, open, and predictable process for dealing with grievances.Cargill’s policy extends to all parts of our palm supply chain and requires plantations, processing and trading operations, and all third-party suppliers to act in an environmentally sustainable and socially responsible manner. Any grievance, complaint or concern from external parties concerning the implementation of our palm supply chain commitments may be submitted in writing, online or by phone through Cargill’s Ethics Open Line."

In the 2022 Forests CDP report: 3228514 tons consumption (19% verified deforestation/conversion free), 582096 tons production (45% verified deforestation/conversion free)

"To support suppliers in addressing and resolving grievances, we have engaged experts from the Global Environment Centre Foundation (GEC), Fair Labor Association (FLA), Proforest and Landesa to develop guidance documents that provide a structured, consistent and transparent approach for determining expected actions and timelines. The guidance includes information about how to verify grievances, identify causes, develop action plans, minimize further noncompliance and communicate progress to stakeholders. The guidance covers key topics, including peat development, deforestation, wages, forced labor, child labor and land rights."

"Cargill has and continues to make improvements in its processes where there is interaction with our surrounding communities. Focusing on the land acquisition and land dispute settlement process, Cargill has developed a land acquisition SOP (ID Dokumen ISKSOPPSS/LA.01-R-0) and Land Dispute Settlement SOP (ID Document HSL-SOP-PSS.02-R.03) in May 2005, which promotes the principle of prudence and respect for rights communities on land. There remain some longstanding land claims moving toward resolution regarding PT HSL."[...]"Cargill is guided by the SOP Land Dispute Settlement in dealing with land claims/dispute in our business operation license area. The company will ascertain and map the area first to ensure the land dispute is located inside the company’s own plantation, Inti or KKPA concession. The land claimant must meet at least 2 criteria: there is a written statement from the claimant and there is valid supporting documentation issued by the relevant authority held by the claimant. Settlement of land claims result in a legally accountable agreement, which becomes a valid record and evidence, to avoid reoccurrence of the issue on the same place or land objection in the future"

"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 outlines in a mill list the names of their mills, their parent company (including Cargill), the country, province, latitude/longitude and RSPO status.

Cargill outlines in a mill list the names of their mills, their parent company (including Cargill), the country, province, latitude/longitude and RSPO status.

"Cargill's Policy on Sustainable Palm Oil, released in July 2014, calls for no deforestation of high conservation value (HCV) lands or high carbon stock (HCS) areas, no development on peat, and no exploitation of land or labor rights. During the reporting period, Cargill achieved a combined average of 93 percent traceability to the mill and 48 percent traceability to plantations for the palm oil and palm kernel oil it purchases and trades. Each mill is analyzed through desktop research and satellite mapping to identify potential environmental and social risks in its supply shed. Risk indicators include forest cover loss, peat, proximity to protected areas, fire alerts and certification status. Cargill is also aiming to co-create means for identifying and monitoring labor and land rights issues. Where high-risk areas are identified, the company will carry out on-the-ground field assessments in partnership with third parties. As we progress from traceability to supply chain transformation, we will work with mills and third-party suppliers to deepen our engagement with smallholders to uphold our policy and implement best practices. Focus to date has been on it's business units that are the primary producers, traders and processors of palm and have the greatest material risk. Results are reported to the company's palm business leadership team. Future efforts may include additional food and feed supply chains to be assessed. [...] . For our own operations, we have improved procedures to verify continued compliance with our policy, and regularly conduct internal audits on NDPE practices in addition to scheduled RSPO audits."

Indonesia: "Area of natural ecosystems converted since specified cutoff date (hectares) 532.82" Cut-off date is specified as 2018. This is just for their own operations, figure not given for smallholder suppliers. They only have plantations in Indonesia. They also report 19 ha in the past year, and 2738 ha over the past 5 years.

Cargill "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. [...]Work with parties to resolve complaints and conflicts relating to non-compliance of this Palm Policy through an open, accessible, transparent and consultative process. [...] 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 Policy applies to all the physical palm oil products that Cargill produces, trades and processes. We work with our direct and indirect suppliers across all their operations, smallholders, customers, governments, non-governmental organizations, industry associations and other stakeholders to implement this policy and continuously drive compliance."

Indonesia: "Area of natural ecosystems converted since specified cutoff date (hectares) 532.82" Cut-off date is specified as 2018. This is just for their own operations, figure not given for smallholder suppliers. They only have plantations in Indonesia. They also report 19 ha in the past year, and 2738 ha over the past 5 years. Figures not available for smallholders.

"Our zero-tolerance policy means that any verified instances of deforestation will result in the supplier’s suspension and removal from our supply chain. Prior to reengagement, suppliers must not only have an action plan, but also show evidence of implementation." [...] "To support suppliers in addressing and resolving grievances, we have engaged experts from the Global Environment Centre Foundation (GEC), Fair Labor Association (FLA), Proforest and Landesa to develop guidance documents that provide a structured, consistent and transparent approach for determining expected actions and timelines. The guidance includes information about how to verify grievances, identify causes, develop action plans, minimize further noncompliance and communicate progress to stakeholders."

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

"A key measure of our success is sending every employee and contractor home safe every day. We are committed to conducting all our business activities in a manner that protects the health and safety of our people. [...] We promote and respect human rights as outlined in the Universal Declaration of Human Rights and the UN Sustainable Development Goals. We are a participant in the UN Global Compact. We take guidance from the UN Guiding Principles on Business and Human Rights and the International Labour Organisation Fundamental Principles and Rights at Work."[...] "We expect our Supplier Partners to: [...] Never use or tolerate the use of human trafficking, forced labor, or child labor as defined by the International Labour Organization (ILO);Foster an inclusive work environment that is free of harassment and discrimination; Respect employees’ rights to organize and bargain collectively"

"Cargill and the Instituto Biosistêmico (IBS) have partnered since 2011 to bring no-cost training to Brazil’s smallholder farmers to help them grow their soybean crops using more sustainable methods. Technical visits to farms by IBS specialists analyze soil, erosion, crop rotation and fertilizer applications. In addition to greater productivity and protecting the natural resources of their farms, farmers also receive a premium for their soy. Across six states in the 2019-2020 crop season, the family farming program benefitted more than 1,700 farmers directly and 700 farmers within cooperatives."

"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."

"Labor Practices: 3.3 Prohibit the use of human trafficking, illegal, abusive, forced or child labor within our operations anywhere in the world and work with our suppliers to prevent and address such practices across the supply chain. In cases where exploitative practices are identified, we will determine remedial actions to ensure appropriate and transparent responses"

"Cargill expects the process of Free Prior Informed Consent to obtained before commencement of activities and expects our suppliers to do the same. We also strongly encourage suppliers to conduct Social Impact Assessments"

"Since 2006, Cargill has partnered with industry and environmental organizations to uphold the Brazilian Soy Moratorium in the Amazon – a voluntary agreement to not purchase soy from lands in the Amazon biome that were deforested after July 2008 – that has contributed to the 80 percent decline in deforestation in the Amazon in the last decade."

"The Land Innovation Fund for Sustainable Livelihoods – which Cargill launched with a commitment of $30 million – supports projects that will help protect forests across South America. Administered by Chemonics International, the fund is employing an active and integrated approach to selecting projects.[...] CIMATEC has begun work with AIBA, the producer association in Brazil’s state of Bahia, to develop a system for AIBA’s farmers that monitors land use, water resources and good agricultural practices.[...] A project led by think tank Agroicone is working with the four state governments in Matopiba to develop policies and fiscal incentives to restore native vegetation on privately held lands. [...] • Brazil-based innovation hub AgTech Garage successfully launched a first challenge for startups that will develop new technologies and approaches to reduce deforestation in the Cerrado."

In the CDP Cargill refer to a jurisdicational approach called "Produce, Conserve and Include (PCI)". Also ""Cargill participates in the Brazilian Coalition on Climate, Forests, and Agriculture, in a working group that helps the government advance the implementation of a low carbon economy and the Forest Code. In 2016, Cargill joined the Green Commodities Programme in Paraguay, a multi-stakeholder initiative to improve sustainable production and regulatory compliance, which includes United Nations Development Programme, the government and other companies."

"Regarding risk assessment overall, land conversion is our primary filter in order to protect natural landscapes [...] In order to identify the risks in our supply chain and direct our interventions as effectively as possible, we must understand the sources of the soy we buy and how it was produced. That’s why mapping our soy supplies has been one of our most significant areas of focus during the past two years. [...] Identifying the sources of all our soybeans in South America and the risks of deforestation in those areas, through mapping and analysis"

"We have internal processes and controls to prevent purchases from embargoed areas and confirm the sale of products originated from properties that are in compliance with Brazilian law. To help ensure soy does not enter our supply chains from farming operations accused of illegal deforestation or slave labor in Brazil, we have built a robust system of controls. On a daily basis, this system consults government lists of embargoed farms and blocks them so they are not eligible to sell soy to us"

"This Soy Grievance Process is deployed by Cargill to handle any grievance identified and raised by internal or external parties, including individuals, employees, contractors, suppliers, and civil society organizations, concerning compliance of the Soy Policy. This includes recording grievances, verifying claims, rectifying confirmed issues, reporting key performance indicators, delivering responses to stakeholders and managing and monitoring follow-up actions. When a report regarding a third-party supplier is submitted to Cargill, we will engage the grievance raiser and the grievance subject to discuss the issues raised in accordance with this procedure, with the objective of resolving the issues where they have been confirmed. Cargill prohibits harassment, intimidation and the use of violence by any employee, supplier, third party and contractor throughout engagement in the Soy Grievance Procedure. Cargill will not tolerate retaliation against anyone who, in good faith, raises a concern or participates in an investigation or whistleblowing."[...]"5. PROCEDURE a) The grievance may be raised by any external stakeholder or Cargill employee through three channels available to receive grievances. These are listed below. - Via internet or phone through Cargill Ethics Open Line: In this case, the grievance is received through Cargill’s Global Ethics & Compliance Office (GECO) and then forwarded to 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 the South America Soy Sustainability Grievance Coordinator, located in Brazil headquarters Av. Dr. Chucri Zaidan, 1240 – 6 th floor – Diamond Tower – São Paulo – SP – Brazil Contact details are required to seek further clarification on the grievance. The party reporting the grievance (grievance raiser) may request that their identity remain confidential. Any party may appoint a third-party to submit their grievances provided that the third-party follows the procedure."

Cargill does not provide overall volumes of soy, it only provides the volume of soy certified by RTRS.

"This approach to building a sustainable, deforestation- and conversion-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."

"Cargill monitors the percent of DCF volumes (Sectorial Approach – Methodology is in our Soy Action Plan Report) using datasets based on satellite monitoring, such as the USGS and University of Maryland. For areas inside Brazil’s Amazon biome, every purchase is independently audited to help ensure it complies with the Amazon Soy Moratorium. Cargill also uses a strong system of controls to help ensure the integrity of our soy supply chain in Brazil. Every day, our automated system consults lists managed by various agencies and organizations. When a farming operation appears on one of these lists, it is blocked so it is not eligible to sell soy to us. Cargill’s Policy on Sustainable Soy – South American Origins commits to work with parties to resolve complaints and conflicts through an open, accessible, transparent and consultative process.[...] Cargill monitors compliance on an annual basis via our DCF analysis. Our action levers are based on our beliefs regarding the most effective means to protect forests and natural vegetation while enabling rural economic development. Agriculture has an important effect on social and human rights issues such as rural economic development and the rights of workers, communities and indigenous peoples. We recognize that farmers may have legal rights concerning land conservation and agriculture. To positively influence land conversion practices, we promote the development of economic alternatives for farmers. We believe that sector-wide transformation is the best pathway to success. We will continue to use suspension as a lever when necessary, including suspending any suppliers who violate pre-existing embargoed or protected areas, who appear on government lists related to forced labor practices, or who engage in illegal operations. Anytime a grievance or monitoring detects noncompliance that is then confirmed, we take action to address the non-compliance. No known non-compliance remains in the supply chain. Our strengthened grievance process lays out a transparent mechanism for us to review, address and monitor any concerns as they are raised in relation to compliance with our soy policy. Cargill's Code of Conduct and Guiding Principles, Commitment on Human Rights cover our direct operations. Our local commercial teams have been trained on these tools and procedures."

"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 procedure[...]Our strong system of controls helps ensure the integrity of our soy supply chain in Brazil. Every day, our automated system consults lists managed by various agencies and organizations (see table to the right). When a farming operation appears on one of these lists, it is immediately blocked so it is not eligible to sell soy to us. We also block other farms registered to the same person or entity in the local area of the country, depending on the violation involved. These affiliated farms cannot be unblocked until we conduct a thorough analysis to help ensure that soy from the violating farm is not being rerouted and sold to us through the affiliated operation. These affiliated farms are re-evaluated each new crop season to confirm they are still complying."

" Every day, our automated system consults lists managed by various agencies and organizations. When a farming operation appears on one of these lists, it is immediately blocked so it is not eligible to sell soy to us. We also block other farms registered to the same person or entity in the state, as well as those with whom they have a close commercial relationship. These affiliated farms cannot be unblocked until we conduct a thorough analysis to help ensure that soy from the violating farm is not being rerouted and sold to us through the affiliated operation. These affiliated farms are re-evaluated each new crop season to confirm they are still complying."

Second half of 2021 491 farms were blocked

"A key measure of our success is sending every employee and contractor home safe every day. We are committed to conducting all our business activities in a manner that protects the health and safety of our people. [...] We promote and respect human rights as outlined in the Universal Declaration of Human Rights and the UN Sustainable Development Goals. We are a participant in the UN Global Compact. We take guidance from the UN Guiding Principles on Business and Human Rights and the International Labour Organisation Fundamental Principles and Rights at Work."[...] "We expect our Supplier Partners to: [...] Never use or tolerate the use of human trafficking, forced labor, or child labor as defined by the International Labour Organization (ILO);Foster an inclusive work environment that is free of harassment and discrimination; Respect employees’ rights to organize and bargain collectively"

"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."

"Policy Requirements To measure and prove progress on our commitment, commercial and business functions must: 1. Map Map the origin of goods in the supply chain to the appropriate level of granularity required to define supply chain risk and to assess compliance with Cargill’s deforestation-free commitment and land use operating guidelines. Appropriate levels of granularity will be interpreted according to the supply chain but may include mapping to the producer, aggregator/intermediary or the jurisdiction levels. 2. 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. Businesses will work through multi-stakeholder channels and/or consult with multiple stakeholders to align on a sufficient definition of forest. 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."

"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.  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."