Cargill

COMMENTS AND DETAILS

• 1This data has been pre-filled with Forest 500 data, from your public reporting. Please update if you have more recent or more relevant information.

COMMENTS AND DETAILS

• 1We have firmly upheld the Brazilian Soy Moratorium in the Amazon since 2006, when we partnered with industry and environmental organizations to implement this voluntary agreement to not purchase soy from lands in the Amazon biome that were deforested after July 2008.

COMMENTS AND DETAILS

• 1The Cargills Forests on Policy applies to all Cargill operating entities, all agricultural supply chains, including direct and indirect sourcing, processing, and physical trading.

• 2The Cargills Forests on Policy applies to all Cargill operating entities, all agricultural supply chains, including direct and indirect sourcing, processing, and physical trading.

• 3Applies to South America only

• 4The Cargills Forests on Policy applies to all Cargill operating entities, all agricultural supply chains, including direct and indirect sourcing, processing, and physical trading.

COMMENTS AND DETAILS

• 1Cargill is committed to transforming our supply chains globally to be deforestation- and conversion-free (DCF) by 2030. This includes taking action now to find solutions for soy from South America in the quickest and most effective way possible.

COMMENTS AND DETAILS

• 1Cargill has been publishing a Progress Report every six months, with the main advances of the Soy Action Plan in South America. In our stakeholder letter in our most recent progress report we call out interim milestones for the next six months, these are to • Work to complete polygon mapping of farms in the Matopiba region of Brazil • Support a next round of projects through the Land Innovation Fund • Increase direct farmer engagement in high-priority areas

COMMENTS AND DETAILS

• 1https://www.cargill.com/doc/1432136544290/cargill-policy-on-forests.pdf; https://www.cargill.com/doc/1432136544508/cargill-policy-on-south-american-soy.pdf

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1Cargill's Policy on South American Soy states that we commit to "respect and uphold the rights of workers, indigenous peoples and communities." The policy also states the following commitments: 3.1 Support the FAO's Voluntary Guidelines on the Responsible Governance of Land Tenure 3.2 Respect the rights of indigenous and local people. We support Free, Prior and Informed consent as a core to protecting those rights.

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1We are committed to building a deforestation- and conversion-free (DCF) supply chain as quickly as possible. To do this, we are mapping where our South American business buys soy from and analyzing what portion of it was grown on land that may have been converted from native vegetation in recent years. This analysis will be done for each of the five countries where our South American business sources soy, ultimately based on polygon mapping of farms.

COMMENTS AND DETAILS

• 1Traceability progress is reported through the Soft Commodity Forum - "Our work with the Soft Commodities Forum supports this company commitment. To achieve our goal of becoming deforestation- and conversion-free, we need to increase traceability, which is why we have been investing heavily in the process of mapping our supply chain. This work is a meaningful undertaking given we have thousands of suppliers in the region. We reached our goal of having 100% of the Brazil supply chain mapped with geo-referenced single points, six months ahead of schedule."

• 2This data has been pre-filled with Forest 500 data, from your public reporting. Please update if you have more recent or more relevant information. Traceability progress is reported through the Soft Commodity Forum - "Our work with the Soft Commodities Forum supports this company commitment. To achieve our goal of becoming deforestation- and conversion-free, we need to increase traceability, which is why we have been investing heavily in the process of mapping our supply chain. This work is a meaningful undertaking given we have thousands of suppliers in the region. We reached our goal of having 100% of the Brazil supply chain mapped with geo-referenced single points, six months ahead of schedule."

• 3Our businesses source soy from all of the major growing regions in the world. We are focused on South America as the highest-priority region for soy sustainability because it is home to vital landscapes such as the Amazon, Cerrado and Gran Chaco biomes that must be protected. Our approach rests on core concepts that supply chain traceability and mapping efforts should be risk-calibrated and prioritization should direct resources toward the highest-risk supplies from the highest-risk areas.

• 4Traceability progress is reported through the Soft Commodity Forum - "Our work with the Soft Commodities Forum supports this company commitment. To achieve our goal of becoming deforestation- and conversion-free, we need to increase traceability, which is why we have been investing heavily in the process of mapping our supply chain. This work is a meaningful undertaking given we have thousands of suppliers in the region. We reached our goal of having 100% of the Brazil supply chain mapped with geo-referenced single points, six months ahead of schedule."

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1Our CEO and Chairman is the owner of Cargill's Policy on Forests. Progress toward forest and land-use commitments is reviewed by our CEO and Chairman and reported to the board on a quarterly basis. Cargill's Chief Sustainability Officer and Corporate Senior Vice President is a member of the Executive Leadership Team and leads the company's integrated supply chain, research and development, and sustainability practices.

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1The 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 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

• 2Cargill's Policy on Sustainable Soy - South American Origins commits to work with parties to resolve complaints and conflicts in the South American soy supply chain through an open, accesible, transparent and consultative process. Under this framework, where suppliers' practices regarding sustainability raise concerns among our stakeholders, we have created a grievance procedure to address these in a timely, transparent, equitable and participatory manner. The process serves as a guide to review, address and monitor the outcome of any grievance concerning the Soy Policy across Cargill's South American supply chain. It aims at providing a clear, predictable and effective path of action. We engage and suppor our suppliers in addressing non-compliances through time-bound action plans. If a supplier does not engage in this Grievance Process in good fath, Cargill will cease doing business with that supplier. If cases of illegal activity are confirmed, we take immediate action in line with our forest and sustainable soy policies, global Supplier Code of Conduct and soy grievance process.

• 3see grievance process file

• 4Summary provided in each Soy Progress Report - twice per year

• 5The 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: 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 – 6th 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.

COMMENTS AND DETAILS

• 1As we map all the sources of our soy, we must also understand the risks of deforestation or other land conversion in local areas across our supplier network. Getting a more granular assessment helps us identify the full scope of risks involved and opportunities to mitigate them. In August 2019, we published our first risk assessment methodology, laying out how we would examine the high-risk biomes of the Amazon, Cerrado and Gran Chaco. We then set to work conducting this risk assessment across a large portion of South America at a pixel level of 30 meters. We used data from several sources – including Global Forest Watch, the University of Maryland, MapBiomas,various government agencies, and others – as well as our own proprietary data. The assessment segmented current land use across all high-risk regions, broken down into the categories of cultivated agriculture, pasture and native vegetation (including forests). It also identified areas that would be suitable for future soy cultivation based on rainfall, soil and terrain, while setting aside protected regions. It then prioritized areas that are suitable for soy and that still currently have higher concentrations of native vegetation – in other words, areas that could be at risk of deforestation or other land use conversion. We also used historical information to inform our risk assessment. We looked at areas of forest cover loss since 2008 laid side-by-side with areas where soy is currently in regular crop rotation. This analysis is helping us identify past patterns of soy growth that can be used to predict future trends. We are continuing to gather insights from this risk assessment and our supplier mapping in order to inform our next steps. We are currently identifying the locations of the farms for all of our direct suppliers and the points of procurement for our indirect suppliers in the countries that contain the high-risk biomes of the Amazon, Cerrado and Gran Chaco, as well as Uruguay, using georeferenced single points.

• 2PowerPoint Presentation (cargill.com)

COMMENTS AND DETAILS

• 1We obey the law. Obeying the law is the foundation on which our reputation and Guiding Principles are built. As a global organization privileged to do business all over the world, we have the responsibility to comply with all of the laws that apply to our businesses.

• 2Cargill Government Relations function assesses potential future changes to regulatory frameworks. For example, we are participating in various forums for discussion and engaging with European Union institutions that are in the process of establishing a policy framework to help protect the forests of trading partners like the countries of South America.

COMMENTS AND DETAILS

• 1We have built a robust system of controls to keep soy produced by farming operations accused of illegal deforestation or slave labor from entering our supply chains in Brazil. 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. Our system also consults lists of non-compliant farms 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 either in the local area or the entire country, depending on the violation involved. 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 an affiliated operation. They are re-evaluated with each new crop season to ensure that they are still complying. Our commercial teams are fully trained on how these processes operate.

• 2as above

COMMENTS AND DETAILS

• 1as above

COMMENTS AND DETAILS

• 1We engage and support our suppliers in addressing non-compliances in timebound action plans

• 2as above

COMMENTS AND DETAILS

• 1Certification programs --> Today, we provide a number of products that are deforestation-and conversion-free (DCF) and can help fulfill our customers’ sustainability needs. This is also an important part of accelerating transformation of the soy sector in South America. Because to encourage farmers to invest in sustainable practices that meet the criteria of various certification programs, we must reassure them that there will be market demand for certified products. RTRS, Triple S, 2BS, FEMAS and Proterra are today part of our sustainable soy portfolio in South America. Soja Plus –-> a program organized by the Brazilian Association of Vegetable Oil Industries (ABIOVE) – farmers receive important training materials and other technical guidance at no cost. That includes education on regulatory compliance and the economic, social, and environmental aspects of their operations. Our funding support for Soja Plus is helping reach farmers in important regions like the state of Maranhão.

• 2Certification programs --> Today, we provide a number of products that are deforestation-and conversion-free (DCF) and can help fulfill our customers' sustainability needs. This is also an important part of accelerating transformation of the soy sector in South America. Because to encourage farmers to invest in sustainable practices that meet the criteria of various certification programs, we need to reassure them that there will be market demand for certified products. RTRS, Triple S, 2BS, FEMAS and Proterra are today part of our sustainable soy portfolio in South America. Soja Plus –-> a program organized by the Brazilian Association of Vegetable Oil Industries (ABIOVE) – farmers receive important training materials and other technical guidance at no cost. That includes education on regulatory compliance and the economic, social, and environmental aspects of their operations. Our funding support for Soja Plus is helping reach farmers in important regions like the state of Maranhão.

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1Building 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.

COMMENTS AND DETAILS

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1We are currently identifying the locations of the farms for all of our direct suppliers and the points of procurement for our indirect suppliers in the countries that contain the high-risk biomes of the Amazon, Cerrado and Gran Chaco, as well as Uruguay, using georeferenced single points. The Cargill's grievance procedure for soy, applies to both our direct and indirect suppliers across Brazil, Argentina, Paraguay, Bolivia and Uruguay.

• 2see 2020 year-end Soy Progress Report

COMMENTS AND DETAILS

• 1We are currently identifying the locations of the farms for all of our direct suppliers and the points of procurement for our indirect suppliers in the countries that contain the high-risk biomes of the Amazon, Cerrado and Gran Chaco, as well as Uruguay, using georeferenced single points. The Cargill's grievance procedure for soy, applies to both our direct and indirect suppliers across Brazil, Argentina, Paraguay, Bolivia and Uruguay.

• 2see 2020 year-end Soy Progress Report

COMMENTS AND DETAILS

• 1We are currently identifying the locations of the farms for all of our direct suppliers and the points of procurement for our indirect suppliers in the countries that contain the high-risk biomes of the Amazon, Cerrado and Gran Chaco, as well as Uruguay, using georeferenced single points. The Cargill's grievance procedure for soy, applies to both our direct and indirect suppliers across Brazil, Argentina, Paraguay, Bolivia and Uruguay.

• 2see 2020 year-end Soy Progress Report

COMMENTS AND DETAILS

• 1Prior to our risk assessment metholdogy being published on our website, partners including The Nature Conservancy were consulted, as were our external advisory panel members. This engagement continues as we seek to continuously improve our monitoring approaches.

• 2Our risk assessment methodology and aggregated estimate

COMMENTS AND DETAILS

• 1Please see Soy Progress Report 2020 pages 5-6 for DCF % Brazil, Argentina and Paraguay and 9-11 for metholdology

• 2Please see Soy Progress Report 2020 pages 5-6 for DCF % Brazil, Argentina and Paraguay and 9-11 for metholdology

COMMENTS AND DETAILS

• 1See pages 9-11 in 2020 year-end Soy Progress Report

COMMENTS AND DETAILS

• 1This data has been calculated by Trase.earth, not disclosed by Cargill

• 2This data has been calculated by Trase.earth, not disclosed by Cargill

• 3This data has been calculated by Trase.earth, not disclosed by Cargill

COMMENTS AND DETAILS

• 1This data has been pre-filled with Forest 500 data, from your public reporting. Please update if you have more recent or more relevant information. Progress is reported through the Soft Commodities Forum progress report - "We reached our goal of having 100% of the Brazil supply chain mapped with georeferenced single points, six months ahead of schedule."

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1This data has been calculated by Trase.earth, not disclosed by Cargill

• 2This data has been calculated by Trase.earth, not disclosed by Cargill

• 3This data has been calculated by Trase.earth, not disclosed by Cargill

• 4This data has been calculated by Trase.earth, not disclosed by Cargill

• 5This data has been calculated by Trase.earth, not disclosed by Cargill

• 6This data has been calculated by Trase.earth, not disclosed by Cargill

• 7This data has been calculated by Trase.earth, not disclosed by Cargill

• 8This data has been calculated by Trase.earth, not disclosed by Cargill

• 9This data has been calculated by Trase.earth, not disclosed by Cargill

• 10This data has been calculated by Trase.earth, not disclosed by Cargill

COMMENTS AND DETAILS

• 1see 2020 year-end Soy Progress Report

• 2see 2020 year-end Soy Progress Report

COMMENTS AND DETAILS

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1This data has been pre-filled with Forest 500 data, from your public reporting. Please update if you have more recent or more relevant information. "Cargill commits to a transparent and sustainable South American soy supply chain that: Transforms our supply chain to be deforestation free while protecting native vegetation beyondforests." "Cargill is a member of Round Table on Responsible Soy (RTRS), a working group dedicated to implementing measures for making global soy production sustainable and responsible."

COMMENTS AND DETAILS

COMMENTS AND DETAILS

• 1Company's own certification

COMMENTS AND DETAILS

COMMENTS AND DETAILS

COMMENTS AND DETAILS