Document 2Ma6ZKLVnO5LqraeKqGLbQ4g

MONSANTO COMPANY (MON) SPECIALTY CHEMICALS | US Increased focus on analytics and microbes a welcome change GOVERNANCE SNAPSHOT INDUSTRY RATING DISTRIBUTION B ESG RATING LAST UPDATE: March 30, 2016 A ESG RATING HISTORY B ccc B Feb-12 Feb-13 Feb-14 Feb-15 Feb-16 ESG SCORE CARD RATING COMMENT RATING DATE: February 25, 2016 WEIGHT SCORE QUARTILE Monsanto's rating is unchanged at'B'. Environment Toxic Emissions & Waste Opportunities in Clean Tech Water Stress Carbon Emissions Social Chemical Safety Health & Safety Labor Management Governance Corporate Governance 50.0% 4.0 21.0% 1.2 11.0% 4.4 11.0% 4.9 7.0% 10.0 21.0% 0.2 21.0% 0.2 0.0% 9.3 0.0% 7.2 29.0% 3.9 15.0% 5.3 Monsanto faces barriers to market growth due to concerns from consumers and regulators over genetically modified (GM) seeds. While the company's traits may offer crop yield benefits, consumer perception continues to work against the company. Monsanto also has not endorsed GMO labeling transparency, which has gained traction in the wake of labeling initiatives among certain U.S. states, and commitments by retailers and food products companies. However, Monsanto has taken steps to expand its market opportunities into crop analytics and microbe-based solutions through the BioAg Alliance, both of which have aggressive growth targets. In May 2016, Bayer AG launched an all-cash takeover bid for Monsanto, adding to the degree of consolidation in the ag chem industry. The bid coincides with a tenuous operating environment for Monsanto, which is balancing R&D funding needs with a downturn in the ag sector. The initial proposal was spurned by Monsanto's board as financially inadequate and shareholders are likely to view Bayer's continued pursuit as a part of a bargain-hunting strategy. Even if a revised offer is in the best interest of Monsanto shareholders, the deal entails significant execution risk due to anticipated regulatory scrutiny. Analyst: Cyrus Lotfipour MOST SIGNIFICANT RISKS Business Ethics & Fraud Anticompetitive Practices 14.0% 2.5 N/A 0.0% 5.0 N/A Chemical Safety - Score 0.2 February 25, 2016 View Corporate Governance Details Section -> Key Issues Bottom Quartile Top Quartile The company's product portfolio and the geographic distribution of its revenues suggest high exposure to regulatory risks and potential reformulation costs. Our analysis finds little evidence of mitigation capacity. The company therefore appears poorly prepared to manage this risk. In the context of global industry peers, Monsanto ranks below average. Issues that we determine do not present material risks or opportunities to companies in a given industry receive 0% weight and do not impact the overall ESG rating. Toxic Emissions & Waste - Score 1.2 February 25, 2016 The company's business activities suggest high exposure to potential costs associated with its discharges and waste. Our analysis finds little evidence of mitigation capacity. The company therefore appears poorly prepared to manage this risk. In the context of global industry peers, Monsanto ranks below average. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT EX P-3581 Page 1 of 48 SVEC OLDMONS0570505 MONSANTO COMPANY (MON) ESG RATING g MOST RECENT CONTROVERSIES (View Controversies Detail Section HEADLINE Roundup-related Injury Lawsuits WHO Agency Declares Glyphosate as "Probably Carcinogenic" to Humans Oakland City Lawsuit: Alleged Liability for San Francisco Bay PCB Contamination San Jose City Lawsuit: Alleged Contamination of Guadalupe River and San Francisco Bay with PCB San Diego City Lawsuit: Alleged Liability for San Diego Bay PCB Contamination CEO BOARD OF DIRECTORS Name Hugh Grant Tenure 13 Years Total Realized Pay USD 4,835,987.0 Total Summary Pay USD 11,928,836.0 1 Inside Directors o Outside related Directors ASSESSMENT Moderate Moderate Moderate Moderate Moderate TYPE Product Safety & Quality Product Safety & Quality Toxic Emissions & Waste Toxic Emissions & Waste Toxic Emissions & Waste DATE May 2016 May 2016 April 2016 April 2016 April 2016 SHAREHOLDERS 12 Outside Directors Majority Shareholder Control (%) N/A Insider Holdings (%) 0.0% 5% Holdings 11.6% % Held by Largest Shareholder N/A LARGEST 10 INDUSTRY PEERS (SPECIALTY CHEMICALS) ECO LAB INC. L'AIR LIQUIDE SOCIETE ANONYME POUR L'ETUDE ET L'EXPLOITATION DES PROCEDES GEORGES CLAUDE Givaudan SA Linde AG AIR PRODUCTS AND CHEMICALS, INC. Syngenta AG THE SHERWIN-WILLIAMS COMPANY PRAXAIR, INC. Shin-Etsu Chemical Co., Ltd. PPG INDUSTRIES, INC. MONSANTO COMPANY TOXIC EMISSIONS & WASTE OPPORTUNITIES IN CLEAN TECH WATER STRESS CARBON EMISSIONS CHEMICAL SAFETY N/A CORPORATE GOVERNANCE N/A N/A N/A QUARTILE KEY: RATING TREND KEY: Bottom Quartile Top Quartile maintain ^ upgrade TT two or more notch upgrade 4/downgrade TT two or more notch downgrade RATING AND TREND AAA AA AA o A o A T BBB o BBB T BBB O BBB T BBB O B MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 2 OF 48 EX P-3581 Page 2 of 48 SVEC OLDMONS0570506 MONSANTO COMPANY (MON) ESG RATING g TOXIC EMISSIONS & WASTE PERFORMANCE $ Top Quartile f Bottom Quartile Second Quartile Third Quartile KEY ISSUE SCORE DISTRIBUTION 20% 20% 0123456789 10 Key Issue Score TOP 5 INDUSTRY LEADERS ECOLAB INC. 8.9 Hitachi Chemical Company, Ltd. 7.5 KANSAI PAINT CO.,LTD. 7.3 NOVOZY MESA/S 7 Akzo Nobel N.V. 6.8 BOTTOM 5 INDUSTRY LAGGARDS ANALYSIS OCI N.V. 0.4 Producers of agricultural chemicals have a high risk of incurring environmental liabilities due to the hazardous nature of their products and potential for unintentional releases. Monsanto has environmental management systems to mitigate these risks and greatly improved its transparency in 2014, but increasing hazardous waste intensities reflect negatively on the effectiveness of its process changes. We measure exposure to the risk of incurring environmental liabilities based on the hazardous waste intensity, air pollutant intensity, and toxicity of releases from the company's lines of business. All of Monsanto's revenue is attributed to the production of crop protection chemicals and seeds, which have high hazardous waste intensities according to data from the U.S. Environmental Protection Agency. Producers of crop protection chemicals operate in a highly regulated industry, in which product labeling, storage, and transportation guidelines are strictly enforced. Although Monsanto does not have group-wide initiatives to reduce its hazardous emissions or waste, the company has made improvements to its environmental management system which could have a positive influence on its oversight of global operations. The company's environmental, health, and safety policy applies to all global operations and its Crop Protection operations are certified to the ISO 14001 standard for environmental management systems, which represents approximately 18% of the company's total employees, but is well below the industry average certification rate for the Specialty Chemicals industry (69%). Additionally, all manufacturing facilities, farms, and research facilities are covered under Monsanto's auditing program. However, the company does not commit to quantifiable targets and does not highlight process adjustments to reduce its environmental impact. ASHLAND INC. 0 CF INDUSTRIES HOLDINGS, INC. 0 FMC CORPORATION 0 W. R. GRACE & CO. 0 METHODOLOGY NOTE This issue evaluates the extent to which companies may face liabilities associated with pollution, contamination, and the emission of toxic or carcinogenic substances. Scores are based on operations generating toxic byproducts, air pollutants, or hazardous waste; strategy, targets, and programs to reduce emissions; quantified performance; and controversies. MSCI @ MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 3 OF 48 EX P-3581 Page 3 of 48 SVEC OLDMONS0570507 MONSANTO COMPANY (MON) ESG RATING g Relative to companies in the Fertilizers & Ag Chem industry, Monsanto's air pollutant intensity is lower than that of fertilizer producers. Additionally, between 2012 and 2014, the company reduced its SOx and VOC emissions intensities by 16% CAGR, while its NOx emissions intensity decreased by 2% CAGR. While this performance improvements reflects positively on the company's efforts to reduce air pollution, Monsanto's hazardous waste generation increased noticeable in the same time period. Between 2012 and 2014, Monsanto's hazardous waste intensity increased by 56% CAGR, which may indicate that the company's process changes have been ineffective. RISK EXPOSURE Risk Exposure Score 8.6 012345678 9 10 Low Moderate High Exposure Summary 2 Risk % of Operations by Segment Low 0.0% Medium 0.0% High 100.0% 1 This represents the portion of the company's revenues derived from lines of business that are High Risk (typically generate large amounts of toxic emissions), Medium Risk (typically generate moderate amounts of toxic emissions), and Low Risk (typically generate low amounts of toxic emissions). RISK MANAGEMENT Risk Management Score 2.8 012345678 9 10 Low Moderate High Governance and Strategy Existence of Environmental Management System (EMS): Percentage of sites with hazardous waste guidance that achieved HAZWOPER certification or follow ISO 14001 for waste management: Percentage of sites estimated or disclosed: Regular environmental impact audits: Audits cover the full geographic scope of operations: Audits occur on an annual basis: ISO 14001 or equivalent 18.0% Disclosed Yes Yes No Targets Aggressiveness of Toxic Emissions Reduction Target (0-10 Score, Q=worst, 10=best): Demonstrated track record of achieving its toxic emissions targets: 0 No previous targets Performance Toxic Releases Performance Relative to Peers (0-10 Score, 0=worst, 7.0 10=best): MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 4 OF 48 EX P-3581 Page 4 of 48 SVEC OLDMONS0570508 MONSANTO COMPANY (MON) Air Emissions: NOx Performance 3 Year Average Intensity: Average Annual % Change in Intensity: Air Emissions: NOx Performance Year Quantities Intensity 2009 2,431.0 0.21 2010 3,577.0 0.34 2011 3,026.0 0.26 2012 3,035.0 0.22 2013 3,770.0 0.25 2014 3,770.0 0.24 Air Emissions: SOx Performance 3 Year Average Intensity: Average Annual % Change in Intensity: Air Emissions: SOx Performance Year Quantities Intensity 2009 2,192.0 0.19 2010 2,371.0 0.23 2011 2,010.0 0.17 2012 690.0 0.05 2013 1,710.0 0.11 2014 1,610.0 0.1 Air Emissions: VOC Performance 3 Year Average Intensity: Average Annual % Change in Intensity: Air Emissions: VOC Performance Year Quantities Intensity 2009 106.0 0.01 2010 119.0 0.01 2011 120.0 0.01 2012 94.2 0.01 2013 78.0 0.01 2014 93.7 0.01 iuiq^I MSCI ESG 1 RESEARCH INC. 0.24 -1.83% 0.09 14.46% 0.01 -14.44% 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATING g ESG RATINGS REPORT | PAGE 5 OF 48 EX P-3581 Page 5 of 48 SVEC_OLDMONS0570509 MONSANTO COMPANY (MON) ESG RATING g Releases to Land: Hazardous Waste Performance 3 Year Average Intensity: Average Annual % Change in Intensity: Releases to Land: Hazardous Waste Performance Year Quantities Intensity 2009 4,928.0 0.42 2010 5,064.0 0.48 2012 3,303.0 0.24 2014 9,420.0 0.59 Controversies 0.44 36.01% All controversies are assessed as part of the annual review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. Controversy Cases Assessment Moderate Moderate Moderate Moderate Moderate Minor Minor Minor Minor Headline Status San Diego City Lawsuit: Alleged Liability for San Diego Bay PCB Contamination Ongoing San Jose City Lawsuit: Alleged Contamination of Guadalupe River and San Francisco Bay with PCB Ongoing Seattle City Lawsuit: Alleged Contamination of Local Water Sources with PCB Ongoing Oakland City Lawsuit: Alleged Liability for San Francisco Bay PCB Contamination Ongoing Personal Injury Claims Related to PCBs Ongoing Portland City Lawsuit: Alleged Contamination of Willamette River with PCB Ongoing Spokane City Lawsuit: Alleged Contamination of Local River with PCB Ongoing Berkley City Lawsuit: Alleged Contamination of Local Water Sources with PCB Ongoing Brofiscin Landfill, South Wales: Agreement to Pay for Cleanup of Former Quarry in the 1960s Concluded Last Updated April 2016 April 2016 April 2016 April 2016 April 2016 April 2016 April 2016 April 2016 July 2015 MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 6 OF 48 EX P-3581 Page 6 of 48 SVEC OLDMONS0570510 MONSANTO COMPANY (MON) Opportunities in Clean Tech OPPORTUNITIES IN CLEAN TECH PERFORMANCE Strong Management $ Top Quartile f Bottom Quartile Second Quartile Third Quartile ESG RATING g Score Change Quartile Weight (since rating) As of 4.4 n/a 11.0% Feb 25, 2016 V KEY ISSUE SCORE DISTRIBUTION 37% Moderate Management .MONSANTO COMPANY * Limited Management 1 2 Low Risk 5 6 Moderate Risk Key Issue Score TOP 5 INDUSTRY LEADERS JOHNSON MATTHEY PLC 7.8 UMICORE N.V. 7.5 Risk Exposure Hitachi Chemical Company, Ltd. 7 1 T1 8 9 10 Koninklijke DSM N.V. 6.9 High Risk NOVOZY MESA/S 6.9 BOTTOM 5 INDUSTRY LAGGARDS ANALYSIS THE MOSAIC COMPANY 3 While the company is actively involved in the development of stress-tolerant corn, including Droughtgard Hybrids, the lack of global acceptance of genetically engineered crops limits its market potential to GM-friendly markets in North and South America. However, Monsanto is hedging its GM bets by also investing in the growth of microbe-based crop solutions through the BioAg Alliance and setting aggressive targets for its crop analytics business. GRUPA AZOTY SPOLKA AKCYJNA 2,7 Potash Corporation of Saskatchewan 2.6 Inc. OCI N.V. 2,4 Our evaluation of clean tech takes into account the company's exposure to potential opportunities in clean tech markets, in addition to whether the company has capitalized on these opportunities through its product offerings and R&D strategy. Most of Monsanto's business is attributed to seed development and production, which does not have conventional applications in clean technology. However, companies involved in this line of business have opportunities in sustainable agriculture and drought-tolerant seeds. The size of Monsanto's research and development program is a key competitive advantage for the company. Relative to MSCI World constituents in the Fertilizers & Agricultural Chemicals sub-industry as of February 2016, Monsanto's three-year R&D/sales ratio is above average (10.6% vs. 2.2% industry average), but decreased by 2.1% CAGR between 2012 and 2015. Monsanto's opportunities in clean technologies are limited to markets that have embraced the use of genetically engineered crops, specifically those with drought-tolerant traits. However, within these markets, drought-tolerant seeds carry significant opportunity as farmers seek out ways to mitigate potential impacts associated with climate risk. In 2013, Monsanto launched the first drought tolerant corn seed to the US market in a partnership with BASF, which is expected to invest over USD 2.5 billion in the development of stress- UPL LIMITED 2.4 METHODOLOGY NOTE This issue evaluates the extent to which companies take advantage of opportunities in the market for environmental technologies. Scores are based on exposure to potential opportunities based on business model and policy incentives; innovation capacity and strategic development initiatives; and revenue derived from clean technologies. MSCI# MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 7 OF 48 EX P-3581 Page 7 of 48 SVEC OLDMONS0570511 MONSANTO COMPANY (MON) tolerant corn, soybeans, cotton, canola, and wheat. According to the International Service for the Acquisition of Agri-Biotech Applications, overall plantings of DroughtGard varieties increased by more than 500% since being introduced in 2014. While concerns over GMO crops from environmental groups and consumers will continue to impact the company, drought-tolerant traits have large market potential in the U.S., which is the world's largest producer of corn and is exposed to drought risks in the Plains. In addition to seed traits, Monsanto has also invested heavily in crop analytics and biologicals. The BioAg Alliance, a partnership between Monsanto and Novozymes, aims to develop microbe-based solutions that improve crop yield and productivity. While the deal entailed a USD 300 million payment from Monsanto to Novozymes, the partnership will leverage Novozymes1 existing technologies in microbe development and Monsanto's distribution network and field experience. The BioAg Alliance aims to achieve plantings of 250-500 million acres by 2025 (equivalent to 20-50% of US farmland) and is already seeing yield increases across its corn and soy field trials. Monsanto also has aggressive growth targets for its Climate Fieldview crop analytics platform, which it acquired through its USD 930 million acquisition of The Climate Corporation. The company plans to reach 300-400 million acres with its Fieldview platform by 2025. RISK EXPOSURE ESG RATING g RISK MANAGEMENT Strategy Targets to increase investment in clean tech: Programs & Initiatives R&D Expense Year Amount (USD million) R&D / Sales ratio 200S 980.0 8.62% 2009 1,098.0 9.39% 2010 1,205.0 11.47% 2011 1,386.0 11.71% 2012 1,517.0 11.24% 2013 1,533.0 10.31% 2014 1,725.0 10.88% MSCI MSCI ESG RESEARCH INC. Not disclosed 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 8 OF 48 EX P-3581 Page 8 of 48 SVEC OLDMONS0570512 MONSANTO COMPANY (MON) ESG RATING g Year Amount (USD million) R&D / Sales ratio 2015 1, 580.0 10.56% Performance Score: nature of involvement in clean tech activities: 0.0 Score: percentage of revenue derived from clean tech activities: 3.0 Sustainable Water Water Resource Management & Efficiency Drought-resistant seeds: Controversies Non-core involvement (revenues <20%) This key issue assesses how companies take advantage of their opportunities. Controversies are not covered under this heading. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 9 OF 48 EX P-3581 Page 9 of 48 SVEC OLDMONS0570513 MONSANTO COMPANY (MON) ^ Water Stress ESG RATING g WATER STRESS PERFORMANCE $ Top Quartile f Bottom Quartile Second Quartile Third Quartile KEY ISSUE SCORE DISTRIBUTION 20% 012345678 9 10 Key Issue Score TOP 5 INDUSTRY LEADERS ECOLAB INC. 10 NOVOZY MESA/S 9.9 Givaudan SA 8.9 CRODA INTERNATIONAL PUBLIC 8.6 LIMITED COMPANY AXALTA COATING SYSTEMS LTD. 8.5 ANALYSIS BOTTOM 5 INDUSTRY LAGGARDS Monsanto's direct operations in research and glyphosate production are not particularly water intensive, but the company's indirect water usage through its contract growers raises its overall water intensity by over 20 times. However, the company has implemented new reporting standards for its contract growers and has a target to improve their irrigation efficiency by 2020. EMS-CHEMIE HOLDING AG 3.1 NIPPON PAINT HOLDINGS CO.,LTD, 3 GRUPA AZOTY SPOLKA AKCYJNA 2.3 Monsanto has a moderately low risk of being impacted by water shortages or limitations on water use. We assess water-related risk exposure based on the typical water intensity of the company's business activities as well as the percentage of the company's operations located in countries or regions with higher levels of water stress, according to the World Resources Institute's Aqueduct water risk tool. The company's primary lines of business, crop protection chemicals and research activities, are moderately water intensive, but most of Monsanto's water footprint is derived from its supply chain and contract growers. Approximately 70% of the company's assets are located in the United States, most of which is derived from highly stressed states such as Idaho and Wyoming according to WRI Aqueduct. Monsanto is also indirectly exposed to water stress through the locations of its customers. In 2015, the company recognized lower seed sales in Australia due to constraints on water availability that decreased total planted area. Such results may materialize in other water-stressed markets, including the U.S and Mexico. TAIYO NIPPON SANSO CORPORATION 2,3 CELANESE CORPORATION 1.5 METHODOLOGY NOTE This issue evaluates the extent to which companies may face water shortages affecting their ability to operate, lost access to markets due to stakeholder water conflicts, or higher water costs. Scores are based on exposure to water stressed basins and water intensive segments; water management strategy and targets; water use over time and vs. peers; and controversies. MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 10 OF 48 EX P-3581 Page 10 of 48 SVEC OL.DMONS0570514 MONSANTO COMPANY (MON) ESG RATING g Although Monsanto's water management strategy lags behind that of peers, the company has made significant improvements to its oversight and monitoring of water risks. In 2014, the company began tracking water withdrawals at its contract growers, which is a significant step forward in the seed production industry. Supply chain information in the agricultural products industry is typically opaque, but Monsanto has followed through on a commitment to measure and monitor water usage among its business partners. The company also has a target to improve the irrigation application efficiency of its owned and contracted global seed production fields by 25% between 2010 and 2020. Approximately 27% of Fertilizers & Agricultural Chemicals companies publicly commit to a water reduction target. However, taking the company's contract growers into consideration leads Monsanto to have the largest water intensity in the industry. Relative to MSCI ACWI constituents in the Fertilizers & Agricultural Chemicals sub-industry as of February 2016, Monsanto's water withdrawal intensity taking into account contract growers is the highest in the industry (60,827 m3/million USD sales vs. 15,021 industry average). However, its water usage from its owned operations is considerably smaller (2,739 m3/mi!iion USD sales). RISK EXPOSURE Risk Exposure Score T 4'4 0123456789 10 Low Moderate FSigh Exposure Summary Risk % of Operations by Segment 2 % of Operations by Geography Low 0.0% 37.19% Medium 100.0% 22.94% High 0.0% 39.87% 1 This figure represents the portion of the company's assets devoted lines of business that are High Risk (typically highly water intensive), Medium Risk (typically have a moderate level of water intensity), and Low Risk (typically have a low level of water intensity). 2 This figure represents the portion of the company's assets or key facilities located in water basins that are High Risk (where water stress levels are high), Medium Risk (where water stress levels are moderate), and Low Risk (where water stress levels are low). RISK MANAGEMENT Risk Management Score 2.3 01 2345678 9 10 Low M ode rate High Governance and Strategy Implementation of Water Efficient Production Processes (0-10 Score, 0=worst, 10=best); Percentage of water consumption from alternative water sources (i.e. grey water, rainwater, sewage): Evidence of Using Alternative Water Sources: 5.0 1.5% Yes MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 11 OF 48 EX P-3581 Page 11 of 48 SVEC OLDMONS0570515 MONSANTO COMPANY (MON) ESG RATING g Executive body responsible for water management strategy and performance: CSR or Sustainability Committees: Yes Targets Water consumption targets Baseline Year Target Year Target Description Target Reduction (%) 2010 2020 Reduce irrigation water intensity across global seed production 25.0% Performance Water Intensity Relative to Peers (0-10 Score, 0=worst, 10=best): 1.0 Water Withdrawal Year Water Withdrawal (Cubic Meter) Water Withdrawal Intensity (Cubic Meters/$1 million Sales) 2009 18,625,760.0 1,593.44 2010 20,356,223.0 1,938.32 2011 19,928,073.0 1,684.25 2012 22,500,000.0 1,666.91 2013 35,300,000.0 2,373.91 2014 964,000,000.0 60,827.86 Controversies All controversies are assessed as part of the annual review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. No major relevant controversies have been uncovered. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 12 OF 48 EX P-3581 Page 12 of 48 SVEC OL.DMONS0570516 MONSANTO COMPANY (MON) ESG RATING g CARBON EMISSIONS PERFORMANCE $ Top Quartile f Bottom Quartile Second Quartile Third Quartile KEY ISSUE SCORE DISTRIBUTION 29% Key Issue Score TOP 5 INDUSTRY LEADERS AXALTA COATING SYSTEMS LTD. 10 CHR. HANSEN HOLDING A/S 10 CRODA INTERNATIONAL PUBLIC 10 LIMITED COMPANY ECOLAB INC. 10 Givaudan SA 10 ANALYSIS Due to the low carbon intensity of its operations, Monsanto's exposure to rising energy costs and carbon pricing is low. Furthermore, the company has committed to a demanding greenhouse gas emissions reduction target and improved its transparency in 2014. Monsanto's risk of being impacted by carbon emissions regulations is low. The company is involved in business activities that are characterized by low emissions and low energy use, including seed production (80% of assets) and agricultural chemicals (20%). Additionally, most of the company's assets are located in regions that are not covered by emissions trading systems. BOTTOM 5 INDUSTRY LAGGARDS OCI N.V. 2.9 TAIYO NIPPON SANSO CORPORATION 2,7 EMS-CHEMIE HOLDING AG 2.4 CF INDUSTRIES HOLDINGS, INC. 1.5 GRUPA AZOTY SPOLKA AKCYJNA 0.5 Monsanto made significant improvements to its reporting, transparency, and commitments in 2014, including a demanding greenhouse gas emissions reduction target. The company has a target to improve its GHG emissions per ton of crop protection product by 22% between 2010 and 2020. As of 2014, the company had achieved a 19% reduction, placing it far ahead of schedule. Relative to MSCI ACWI Fertilizers & Agricultural Chemicals companies that commit to a carbon emissions reduction target (approx. 47% of companies), Monsanto's average annual reduction is above average (2.2% per year vs, 1.9% industry average). The company's carbon emissions intensity is below average (167 tC02e/million USD sales vs. 1,005 industry average) and decreased by 0.7% CAGR between 2011 and 2014, which outpaces the industry average increase of 7.2% CAGR in the same time period. Monsanto faces a low risk of being impacted by greenhouse gas emissions regulations or rising energy costs, which accounts for the company's relatively strong ranking in comparison to peers. METHODOLOGY NOTE This issue evaluates the extent to which companies may face increased costs linked to carbon pricing or regulatory caps. Scores are based on exposure to GHG intensive businesses and emerging regulations; carbon reduction targets and mitigation programs; and carbon intensity over time and vs. peers. MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 13 OF 48 EX P-3581 Page 13 of 48 SVEC OLDMONS0570517 MONSANTO COMPANY (MON) ESG RATING g RISK EXPOSURE Risk Exposure Score T 32 0123456789 10 Low Moderate High Exposure Summary 1 2 Risk % of Operations by Segment % of Operations by Geography Low 79.06% 0.0% Medium 20.94% 27.57% High 0.0% 72.43% This represents the portion of the company's revenues derived from lines of business that are High Risk {typically highly carbon intensive), Medium Risk (typically have a moderate level of carbon intensity), and Low Risk (typically have a low level of carbon intensity). 2 This represents the portion of the company's revenues derived from countries or regions that are High Risk (carbon regulations are either stringent or likely to strengthen), Medium Risk (carbon regulations are of moderate strength), and Low Risk (carbon regulations are of weak or nonexistent and unlikely to strengthen in the foreseeable future). RISK MANAGEMENT Performance Carbon Emissions Performance Relative to Peers (0-10 Score, 0=worst, 7.0 10=best): GHG Emissions - metric tons C02e Year 2008 Scope 1 Disclosed Scope 1 Estimate Key E.CSI Scope 2 Disclosed Scope 2 Estimate Key E.CSI Scope 1+2 Disclosed Scope 3 (upstream) Scope 3 (downstream) Scope 3 (undefined) 2009 2010 2011 2012 2013 2014 1,160,105 1,153,800 1,195,928 1,610,000 1,450,000 1,570,000 Reported Reported Reported Reported Reported Reported 661,934 661,900 827,066 539,000 1,040,000 1,080,000 Reported Reported Reported Reported Reported Reported 1,822,039 1,815,700 2,022,994 2,149,000 2,490,000 2,650,000 5,786 442,700 6,747 Scope 1 Estimated 1,179,660.0 Scope 2 Estimated 598,859.0 Scope 1+2 Estimated Scope 1+2 Estimate Key 1,778,519.0 E.CSI Reported Reported Reported Reported Reported Reported GHG Emissions Details Jan2016 Estimation Update GHG Emissions Intensity - metric tons C02e / USD million sales Year GHG Intensity GHG Intensity Details GHG Intensity - Reported GHG Intensity - Reported Details 2003 156.5 2009 155.9 2010 172.9 2011 171.0 MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 14 OF 48 EX P-3581 Page 14 of 48 SVEC OLDMONS0570518 MONSANTO COMPANY (MON) ESG RATING g Year GHG Intensity GHG Intensity Details GHG Intensity - Reported GHG Intensity - Reported Details 2012 159.2 2013 167.5 2014 167.2 Energy Consumption Year 2013 2014 Total energy consumption (reported) 22,300.0 25,100.0 Total energy consumption (MWh) 6,194,444.44 6,972,222.22 Energy intensity (reported) Reported intensity details Total energy consumption intensity 416.57 439.94 Energy consumption details Targets Aggressiveness of the company's reduction target in the context of its current performance: Demonstrated track record of achieving its carbon reduction targets: Aggressive target with a low base On pace to achieve current reduction target Carbon Improvement Targets Baseline Year Target Year Target Description Target Reduction (%) 2010 2020 GHG intensity of Crop Protection business (per unit production). 22.0% Mitigation Strength of Greenhouse Gas Mitigation Strategy (0-10 Score, 0=worst, 6.0 10=best): Programs or actions to reduce the emissions intensity of core operations Use of cleaner sources of energy: Capture GHG emissions: Energy consumption management and operational efficiency enhancements: CDP disclosure: Limited efforts / information No evidence Some efforts Yes Controversies This key issue assesses carbon intensity data to determine companies' environmental impact. Controversies are not covered under this heading. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 15 OF 48 EX P-3581 Page 15 of 48 SVEC OLDMONS0570519 MONSANTO COMPANY (MON) Chemical Safety t 4k CHEMICAL SAFETY PERFORMANCE $ Top Quartile f Bottom Quartile Second Quartile Third Quartile ESG RATING g Score Change Quartile Weight (since rating) As of 0.2 n/a 21.0% Feb 25, 2016 KEY ISSUE SCORE DISTRIBUTION 23% 0123456789 10 Key Issue Score TOP 5 INDUSTRY LEADERS NOVOZY MESA/S 7.8 NITTO DENKO CORPORATION 7 CRODA INTERNATIONAL PUBLIC 6.3 LIMITED COMPANY K+S Aktiengesellschaft 5.9 INTERNATIONAL FLAVORS & 5.3 FRAGRANCES INC. ANALYSIS BOTTOM 5 INDUSTRY LAGGARDS Persistent concerns over labeling transparency and the low-level presence of commercial biotechnology traits in conventionally grown products represent a long-term risk for Monsanto. Almost half of the company's total revenue is derived from GM seeds and traits, most of which are not approved for use in European markets and face consumer resistance in market strongholds. GM traits are highly embedded in the food supply chain of Monsanto's primary markets, but the company is likely to continue to face an uphill battle against stakeholders that have embraced GMO labeling initiatives. FMC CORPORATION 0 PPG INDUSTRIES, INC. 0 Syngenta AG 0 THE SHERWIN-WILLIAMS COMPANY 0 Approximately 32% of Monsanto's revenue is derived from crop protection chemicals, which are coming under increasingly stringent registration requirements in Europe (10% of sales). The EU has been implementing a revised pesticide regulation that will likely result in several substance bans over the next ten years. Substances that are classified as carcinogenic, mutagenic, or reprotoxic (CMRs), persistent organic pollutants (PoPs), persistent, bioaccumulative, or toxic (PBT), or as endocrine disrupters will be taken off the market once their initial ten year approval expires. Crop protection chemicals commonly utilize substances that are classified as hazardous to human health. However, most of the company's sales are derived from markets with less stringent chemical safety regulations, including the U.S (57% of sales) and Latin America (17%), which lessens Monsanto's risk of being impacted by substance bans or regulatory action. However, Monsanto's largest business, Seeds and Genomics (68% of sales), produces and licenses conventionally-bred and genetically-modified seeds, which has attracted significant opposition due to the lack of transparency on potential long-term environmental and health risks. UPL LIMITED 0 METHODOLOGY NOTE This issue evaluates the extent to which companies may face lost market access or product reformulation costs due to the presence of chemicals of concern. Scores are based on exposure to products known to contain substances of high concern, exposure to evolving regulations; chemical phase-out plans, transparency, and development of viable alternatives; and controversies. MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 16 OF 48 EX P-3581 Page 16 of 48 SVEC OLDMONS0570520 MONSANTO COMPANY (MON) With regards to Monsanto's Agricultural Productivity segment, which produces Roundup-branded glyphosate products, the company is faced with considerably lower chemical safety risks than more diversified peers in the agricultural chemicals industry. Monsanto's Agricultural Productivity segment is strategically positioned to leverage growth in its Seeds and Genomics segment, which cuts down on the complexity of its pesticide business. While competitors such as Syngenta offer more than 50 different chemical groups in their pesticide business, Monsanto is only focused on glyphosate products. While glyphosate is the most widely used crop protection chemical in the world, a March 2015 ruling by the World Health Organization to classify glyphosate as "probably carcinogenic" to humans brings additional scrutiny to Monsanto's primary line of business. However, WHO's classification is unlikely to have a noticeable impact on glyphosate applications, especially given the European Food Safety Authority (EFSA) and the US EPA have both disagreed with the conclusion and note the classification does not take a risk-based approach. Our largest concerns stem from Monsanto's Seeds and Genomics business (67% of sales). Approximately 54% of its total revenue is derived from the US, where consumer sentiment around GM seeds is mixed but regulation is unlikely to tighten and play against the company in the near term. GM seeds are already entrenched in the US food chain, so we do not foresee any significant shift in the market. However, a movement to increase transparency in the supply chain and require GMO labeling on food products is gathering momentum, and has the potential to push consumer awareness over a tipping point that can impact the demand for GM seeds. In 2014, the US states, Maine and Vermont, passed the first GMO-labeling laws in the country. Although we estimate that 30% of Monsanto's seed revenue is derived from conventionally-bred varieties, the company is highly exposed to shifts in consumer demand and its reluctance to adopt a stance of transparency reflects negatively on its long term business strategy. -- GM Seed Producers Face Uphill Battle in Europe, Pressures in the US -- The company continues to face opposition from regulators in Europe and environmental groups that are concerned with potential negative environmental effects associated with GMOs. We estimate that sales and royalties from GM seeds and traits account for 70% of the company's Seeds and Genomics revenue {47% of Monsanto's total revenue). Most EU member states have banned the cultivation of GM seeds for human consumption, which has led GM seed producers to focus on more GM-friendly markets in the US, Argentina, Brazil, India, and Canada - the top 5 largest markets according to the International Service for the Acquisition of Agri-Biotech Applications (ISAAA). Despite the high level of growth in these markets, consumer sentiment and skepticism from environmental groups have contributed to the steady opposition to genetically modified foods, which have spawned initiatives to introduce GMO labels and have supported the growth in organic agriculture. To date, only one GM product has been approved for cultivation in the EU - Monsanto's MON810 maize, which is approved for use in animal feed. Despite the approval from the European Commission, nine member states, including France and Germany, have banned MON810 entirely due to negative public sentiment on GM crops. Similar to other companies that are involved in the development of GM seeds, including BASF, Monsanto has stopped applying for approvals and is focusing its efforts on high growth markets in South America and Africa. RISK EXPOSURE Risk Exposure Score 6.8 012345678 9 10 Low Moderate High ESG RATING g MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 17 OF 48 EX P-3581 Page 17 of 48 SVEC OLDMONS0570521 MONSANTO COMPANY (MON) ESG RATING g RISK MANAGEMENT Risk Management Score 0.0 01 234567S 9 10 Low Moderate High Strategy Scope of chemicals: Scope of chemical phase-out plan: Programs & Initiatives Company discloses substance registrations and use: Small number of high profile chemicals identified No evidence of plan for phasing out chemicals of concern Not disclosed Chemical Producers Demonstrated track record of introducing viable alternatives to high concern substances: Company conducts hazard assessments of its substances or products: Controversies No evidence Conducts hazard assessments for new substances Ail controversies are assessed as part of the annual review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. Controversy Cases Assessment Very Severe Moderate Moderate Moderate Moderate Moderate Headline Environmental Concerns over GMO Crops Roundup-related Injury Lawsuits WHO Agency Declares Glyphosate as "Probably Carcinogenic" to Humans EPA Investigation into Human Health Effects of Herbicides Monsanto Guilty of Chemical Poisoning Monsanto Challenges Moratorium on Cultivation of GMO Crops in Maui Hawaii Status Ongoing Ongoing Ongoing Ongoing Ongoing Concluded Last Updated March 2016 May 2016 May 2016 March 2016 March 2016 July 2015 MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 18 OF 48 EX P-3581 Page 18 of 48 SVEC OLDMONS0570522 MONSANTO COMPANY (MON) ESG RATING g Corporate Governance Score Change Quartile Weight (since rating) As of 5.3 n/a 15.0% Feb 25, 2016 ANALYSIS Pay policies at Monsanto raise concerns over the degree of alignment between pay and performance. The CEO's pay in 2015 was more than three times the median of other executives and excessive perks that are not linked to performance may not be an effective use for shareholders. Additionally, the company restricts cumulative voting and prevents shareholders from convening meetings, which serve to promote representation by small shareholders. Additional details and data available in the Corporate Governance Details section. Home Market: 0 METHODOLOGY NOTE This issue evaluates the extent to which companies' corporate governance practices may pose risks to investors. The score is an absolute assessment of a company's governance on a universally applied 0-10 scale. Each company starts with a "perfect 10" and points are deducted based on the triggering of Key Metrics across Board, Pay, Ownership, and Accounting. ISSUES & RANKING 1 Global Pctl Rank Overall 45th (Average) Board 75th Pay 50th Ownership & Control 55th Accounting 2nd Home Market Pctl Rank 58th (Average) 74th 59th 96th 3rd KEY ISSUE SCORE DISTRIBUTION* 37% 18% 14% 7% 4% 0% 0% mum1 10% 0 12 3 4 5 6 7 8 9 10 Key Issue Score TOP 5 INDUSTRY LEADERS UMICORE N.V. 8.5 JOHNSON MATTHEY PLC 8.4 CHR. HANSEN HOLDING A/S 8.1 CRODA INTERNATIONAL PUBLIC LIMITED COMPANY 8.1 GRUPA AZOTY SPOLKA AKCYJNA 7,8 MSClf MSCI ESG RESEARCH INC. BOTTOM 5 INDUSTRY LAGGARDS NIPPON PAINT HOLDINGS CO.,LTD. 3.5 Sociedad Quimica y Minera de Chile S.A. 3.5 TAIYO NIPPON SANSO CORPORATION 3.4 PRAXAIR, INC. 2.5 Shin-Etsu Chemical Co., Ltd. 1.1 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT PAGE 19 OF 48 EX P-3581 Page 19 of 48 SVEC OLDMONS0570523 MONSANTO COMPANY (MON) ESG RATING g Board Global Percentile Rank 75t!l (Average) Home Market Percentile Rank 74th (Average) ANALYSIS The policies and practices of the Monsanto Company board fail within the average scoring range relative to global peers. Flagged concerns include the presence of certain related party transactions. BOARD PERFORMANCE VS. Global Home Market 0 10 20 30 40 50 60 70 SO 90 100 Worst Average Best RISK MANAGEMENT Indicators Board Independence Outside related directors: Total directors: Outside directors: Board independence: Board Leadership CEO Name: Chair / CEO roles combined: Company lacks an independent lead director: Board Skills & Diversity Female directors: Female directors as percent of total: 0 13 12 92.31% Hugh Grant Yes No 3 23.08% MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 20 OF 48 EX P-3581 Page 20 of 48 SVEC OL.DMONS0570524 MONSANTO COMPANY (MON) ESG RATING g Global Percentile Rank SO1" (Average) Home Market Percentile Rank 59th (Average) ANALYSIS Executive pay practices at Monsanto Company fall into the average scoring range relative to global peers. Areas of particular concern include early vesting provisions in share based awards which offer a poor alignment with shareholder interests- PAY PERFORMANCE VS. Global Home Market Y Y 0 10 20 30 40 50 60 70 SO 90 100 Worst Average Best RISK MANAGEMENT Indicators Pay Figures Total Annual Pay: Total Realized Pay: Company fails to disclose specific pay totals for executives: CEO total summary compensation: CEO total summary compensation (currency): Pay Performance Alignment Significant vote against pay practices: Severance & Change of Control Company lacks a clawback policy: 4,835,987.0 4,835,987.0 No 11,928,836.0 USD No No MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 21 OF 48 EX P-3581 Page 21 of 48 SVEC OL.DMONS0570525 MONSANTO COMPANY (MON) ESG RATING g Ownership & Control Global Percentile Rank 55th (Average) Home Market Percentile Rank 96th (Best In Class) ANALYSIS The company's ownership structure and shareholder rights at Monsanto Company fall within the average scoring relative to global peers. OWNERSHIP & CONTROL PERFORMANCE VS. Global Home Market T 0 10 20 30 40 50 60 70 SO 90 100 Worst Average Best RISK MANAGEMENT Indicators Committee Structure Company lacks a fully independent audit committee: Company lacks a fully independent compensation committee: Ownership Structure Insiders (Officers & Directors) % Held: Five % Shareholders % Held: Top Shareholders: Controlling shareholder: Shareholder Rights Company has failed to adopt majority voting standards: Ownership structure deviates from one share one vote: Takeover Provisions Poison pill: No No 0.87% 11.61% There is no principal shareholder at this firm. No No No No MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 22 OF 48 EX P-3581 Page 22 of 48 SVEC OL.DMONS0570526 MONSANTO COMPANY (MON) ESG RATING g Accounting Global Percentile Rank 2nd (Worst In Class) Home Market Percentile Rank 3rd (Worst In Class) ANALYSIS Based on the company's disclosures and other public information accounting and financial reporting practices at Monsanto Company raise concerns regarding their overall effectiveness. Flagged concerns include extreme values on revenue recognition ratios, and recent history of restatements or special charges. ACCOUNTING PERFORMANCE VS. Global Home Market W 0 10 20 30 40 50 60 70 SO 90 100 Worst Average Best RISK MANAGEMENT Indicators Accounting Figures Non-audit fees: Audit fees: Audit fees (currency): Total auditor fees: Total auditor fees (currency): Audit related fees: Audit related fees (currency): Accounting Risks Restatements or special charges in last two years: Accounting investigations in last two years: Qualified auditor opinion, most recent period: Late filings: Material weakness in internal controls: 19.23% 11,600,000.0 USD 15,600,000.0 USD 1,000,000.0 USD Yes No No No No MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 23 OF 48 EX P-3581 Page 23 of 48 SVEC OLDMONS0570527 MONSANTO COMPANY (MON) ESG RATING g CORPORATE GOVERNANCE CONTROVERSIES Controversies All controversies are assessed as part of the annual review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. Controversy Cases Assessment Moderate Headline USD 80 Million Settlement over Alleged Accounting Violations Related to Roundup Rebates Status Concluded Last Updated February 2016 MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 24 OF 48 EX P-3581 Page 24 of 48 SVEC OL.DMONS0570528 MONSANTO COMPANY (MON) ESG RATING g BUSINESS ETHICS & FRAUD PERFORMANCE A chart is not available because we do not measure exposure on this key issue. TOP 5 INDUSTRY LEADERS AIR PRODUCTS AND CHEMICALS, 5 INC. AIR WATER INC. 5 ALBEMARLE CORPORATION 5 ASHLAND INC. 5 AXALTA COATING SYSTEMS LTD. 5 BOTTOM 5 INDUSTRY LAGGARDS YARA INTERNATIONAL ASA 5 OCI N.V. 4.2 Syngenta AG 4.2 ICL-ISRAEL CHEMICALS LTD. 3.7 MONSANTO COMPANY 2.5 ANALYSIS METHODOLOGY NOTE Monsanto is involved in lawsuits alleging the violation of competition laws, excessive royalty payments in Brazil, and has attracted significant opposition for its aggressive patent enforcement methods. Monsanto monitors the use of its patented seeds and seeks legal prosecution of farmers that the company alleges have used the seeds illegally. Farmers who purchase seeds from Monsanto are required to sign a Technology Use Agreement and pay the company a fee based on acreage planted in addition to the cost of the seeds. The agreement gives the company a right to inspect the fields and take samples for three years after the seeds are purchased. Despite the negative public perception of these practices, the company has emerged victorious in numerous lawsuits emphasizing the company's ability to protect its intellectual property. While Monsanto states that it does not sue farmers whose fields inadvertently contain patented traits, the company refused to agree to a request from the Organic Seed Growers and Trade Association to never sue their farmers, a position that was upheld by U.S courts in January 2014. This issue evaluates the extent to which companies may face regulatory or legal risks or loss of investor confidence due to ethics issues such as fraud, executive misconduct, or insider trading. Companies successfully avoiding incident score "5", while companies that have faced controversies in the last three years score lower, based on the severity and type of controversy. Additionally, in April 2012, a court in Rio Grande do Sul, Brazil, ordered Monsanto to pay at least USD 2 billion for allegedly collecting excessive crop royalties from seed harvests of its GM soybeans after ruling that the company's patents on Roundup Ready seeds expired in 2010. However, in August 2013, Monsanto and Brazil's largest soybean cooperative came to an agreement ending the legal dispute Mcri . I MSCI ESG fgp I RESEARCHING. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 25 OF 48 EX P-3581 Page 25 of 48 SVEC OL.DMONS0570529 MONSANTO COMPANY (MON) over royalty payments. In exchange for promising not to sue the company for royalties collected after the patent expiration, Brazilian soy farmers were given a 16 percent discount on Intacta soybean seeds. As a result of these developments, Monsanto has transitioned into a point-of-delivery payment model that enrolls traders and distributors as the collectors of royalties from farmers in Brazil (11% of sales). The company is beginning to roll out a similar sales model in Argentina (6%) and Paraguay. RISK MANAGEMENT ESG RATING g 2'5 0123456789 10 Low Moderate High Controversies All controversies are assessed as part of the annual review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. Controversy Cases Assessment Severe Severe Moderate Headline Patent Enforcement Practices Brazilian Soy Farmers Royalty Lawsuit USD 80 Million Settlement over Alleged Accounting Violations Related to Roundup Rebates Status Ongoing Ongoing Concluded Last Updated March 2016 November 2015 February 2016 MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT PAGE 26 OF 48 EX P-3581 Page 26 of 48 SVEC OLDMONS0570530 MONSANTO COMPANY (MON) Health & Safety ESG RATING g HEALTH & SAFETY PERFORMANCE $ Top Quartile jf: Bottom Quartile Second Quartile Third Quartile KEY ISSUE SCORE DISTRIBUTION* 27% 0123456789 10 Key Issue Score TOP 5 INDUSTRY LEADERS CHR. HANSEN HOLDING A/S 10 CRODA INTERNATIONAL PUBLIC 10 LIMITED COMPANY FMC CORPORATION 10 NOVOZY MESA/S 10 Koninklijke DSM N.V. 9.9 ANALYSIS This issue does not present significant risks or opportunities to the company and with the assigned weight of 0% does not contribute to the overall ESG rating for the company. BOTTOM 5 INDUSTRY LAGGARDS AXALTA COATING SYSTEMS LTD. 6 EMS-CHEMIE HOLDING AG 5,9 MSCI ESG Research provides additional scores on a select set of ESG Issues for all companies on the ICL-ISRAEL CHEMICALS LTD. 4.5 MSCI World Index. Every company on the index receives scores for the following ESG Issues, regardless of whether they contribute to the overall Company ESG Rating: Carbon Emissions, Water Stress, Toxic Symrise AG 4,5 Emissions, Labor Management, Health & Safety, Business Ethics, and Anti-Competitive Practices. Each of these issues is researched and analyzed according to ESG Research methodology regardless of K+S Aktiengesellschaft 3.2 assigned weight. Hence, scores for these Issues are fully comparable across all companies or industries. METHODOLOGY NOTE This issue evaluates the extent to which companies may face employee accidents that can lead to production disruptions, litigation, and liabilities. Scores are based on exposure to businesses and geographies facing high accident rates; H&S targets and oversight; and accident rates and fatalities over time and vs. peers. MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 27 OF 48 EX P-3581 Page 27 of 48 SVEC OLDMONS0570531 MONSANTO COMPANY (MON) ESG RATING g RISK EXPOSURE Risk Exposure Score 2.6 01 234567S 9 10 Low Moderate High Exposure Summary 1 2 Risk % of Operations by Segment % of Operations by Geography Low 79.06% 0.94% Medium 20.94% 95.18% High 0.0% 3.88% This represents the portion of the company's revenues derived from lines of business that are High Risk {typically have high worker injury rates), Medium Risk (typically have moderate worker injury rates), and Low Risk {typically have low worker injury rates). 2 This represents the portion of the company's revenues derived from countries or regions that are High Risk {with high rates of worker injuries), Medium Risk {with moderate rates of worker injuries), and Low Risk (with low rates of worker injuries). RISK MANAGEMENT Risk Management Score T 4-9 01 234567S 9 10 Low M ode rate High Governance and Strategy There is some Evidence of Recognized Certification: Yes What executive body is responsible for H&S strategy and performance? CSR/Sustainabiiity Committee/H&S task force or risk officer is Yes responsible for H&S strategy: Health & safety policy H&S policy is group-wide: Targets Has the company set a target to improve H&S performance? : Performance Performance on Health & Safety Metrics Relative to Peers (0-10 Score, 0=worst, 10=best): Yes There is some evidence the company has targets 0.0 MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 28 OF 48 EX P-3581 Page 28 of 48 SVEC OLDMONS0570532 MONSANTO COMPANY (MON) ESG RATING g Total Recordable Injury Rate Year Total Recordable Injury Rate 200S 0.63 Total Recordable Injury Unit per 200,000 hours 2009 0.71 per 200,000 hours 2010 0.66 per 200,000 hours 2011 0.7 per 200,000 hours 2012 0.58 per 200,000 hours 2013 0.58 per 200,000 hours 2014 0.59 per 200,000 hours 2015 0.6 per 200,000 hours Details total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors total recordable rate (TRR) - Employee and Supervised Contractors Total Recordable Injury Rate (per million hours) 3.15 3.55 3.3 3.5 2.9 2.9 2.95 3.0 Fatalities Year Fatalities Contractor Fatalities Employee Fatalities Details 2011 2 2012 2 Controversies All controversies are assessed as part of the annua! review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. No major relevant controversies have been uncovered. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 29 OF 48 EX P-3581 Page 29 of 48 SVEC OLDMONS0570533 MONSANTO COMPANY (MON) ESG RATING g Labor Management OIO OKOTLQ GKOILOKO QQQQ LABOR MANAGEMENT PERFORMANCE $ Top Quartile f Bottom Quartile Second Quartile Third Quartile Score Change Quartile Weight (since rating) As of 7.2 A 1.0 0.0% Mar 23, 2016 KEY ISSUE SCORE DISTRIBUTION* 23% 23% 7% 0% 0 9 10 Key Issue Score TOP 5 INDUSTRY LEADERS YARA INTERNATIONAL ASA 9.6 Givaudan SA 9.2 JSR Corporation 9 TAIYO NIPPON SANSO CORPORATION 8.9 Hitachi Chemical Company, Ltd. 8.2 BOTTOM 5 INDUSTRY LAGGARDS ANALYSIS W. R. GRACE & CO. 4.3 This issue does not present significant risks or opportunities to the company and with the assigned Symrise AG 4,2 weight of 0% does not contribute to the overall ESG rating for the company. AXALTA COATING SYSTEMS LTD. 4 MSCI ESG Research provides additional scores on a select set of ESG Issues for all companies on the MSCI World Index. Every company on the index receives scores for the following ESG Issues, regardless Linde AG 3,6 of whether they contribute to the overall Company ESG Rating: Carbon Emissions, Water Stress, Toxic Emissions, Labor Management, Health & Safety, Business Ethics, and Anti-Competitive Practices. Each OCI N.V. 0.5 of these issues is researched and analyzed according to ESG Research methodology regardless of assigned weight. Hence, scores for these Issues are fully comparable across all companies or industries. METHODOLOGY NOTE This issue evaluates the extent to which companies may face workflow disruptions due to labor unrest or reduced productivity due to poor job satisfaction. Scores are based on exposure to regions facing labor unrest, size of workforce, and corporate restructuring / layoffs; workforce policies, benefits, training, and employee engagement; and labor-related controversies. MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 30 OF 48 EX P-3581 Page 30 of 48 SVEC OL.DMONS0570534 MONSANTO COMPANY (MON) ESG RATING g RISK EXPOSURE Risk Exposure Score Y^ 6'3 0123456789 10 Low Moderate High Exposure Summary 1 2 Risk % of Operations by Segment % of Operations by Geography Low 0.0% 0.0% Medium 20.94% 77.73% High 79.06% 22.27% This represents the portion of the company's revenues derived from lines of business that are High Risk (typically experience high levels of labor unrest, work stoppages, or related disputes), Medium Risk (typically experience moderate levels of labor unrest, work stoppages, or related disputes), and Low Risk (typically experience low levels of labor unrest, work stoppages, or related disputes). 2 This represents the portion of the company's revenues derived from lines of countries or regions that are High Risk (where there is a high incidence of labor unrest such as work stoppages), Medium Risk (where there is a moderate incidence of labor unrest such as work stoppages), Low Risk (where there is a low incidence of labor unrest such as work stoppages). Additional Exposure Indicators Layoffs Events Major Layoffs: No Size and Composition of Workforce Number of employees: 22,500 Number of Employees Year Number of employees Part time workers (%) Contract or temporary workers (%) Estimated Part time/contract % 2008 21,700 2009 22,900 2010 21,400 2011 20,600 2012 21,500 2013 21,900 2014 22,400 2015 22,500 MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 31 OF 48 EX P-3581 Page 31 of 48 SVEC OLDMONS0570535 MONSANTO COMPANY (MON) RISK MANAGEMENT ESG RATING g Strategy Percentage of total workforce covered by collective agreements: Percentage of workforce estimated or disclosed: Evidence of collective agreements: Non-compensation benefits including pension and retirement: 15.0% Disclosed Yes Benefits cover all permanent employees (excluding part-time and contractors) Labor-reiated policy/code of conduct covers the following for its own workforce Anti-Discrimination/ Diversity and inclusion: Yes Child Labor: Yes Forced Labor: Yes Freedom of Association: Yes Performance External recognition as employer of choice (last three years): Yes, more than one award in the last year External recognition - details Year Awarding authority name Title of the Award 2014 Great Place To Work #8 World's Best Multinational Workplaces 2014 Monsanto #6 Top Employers 2014 Corporate Responsibility Magazine 100 Best Corporate Citizens for 2014 2014 Fortune Magazine 2014 list of "World's Most Admired Companies." 2015 Newsweek Green Rankings 2015 Corporate Responsibility Magazone 100 Best Corporate Citizens for 20105 2015 Golden Peacock Award Sustainability 2015 Malaysian International Chamber of Commerce Malaysian International Corporate Ethics Award 2015 DOLE, Philippines DOLE Awards Controversies All controversies are assessed as part of the annual review of a company's ESG rating. MSCI ESG Research tracks controversies for all companies on a regular basis. No major relevant controversies have been uncovered. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 32 OF 48 EX P-3581 Page 32 of 48 SVEC OLDMONS0570536 MONSANTO COMPANY (MON) Anticompetitive Practices ESG RATING g ANTICOMPETITIVE PRACTICES PERFORMANCE TOP 5 INDUSTRY LEADERS A chart is not available because we do not measure exposure on this key issue. AIR WATER INC. 5 ALBEMARLE CORPORATION 5 ASHLAND INC. 5 AXALTA COATING SYSTEMS LTD. 5 Agrium Inc. 5 BOTTOM 5 INDUSTRY LAGGARDS Hitachi Chemical Company, Ltd. 4.2 AIR PRODUCTS AND CHEMICALS, 3.7 INC. L'AIR LIQUIDE SOCIETE ANONYME 3.7 POUR L'ETUDE ET L'EXPLOITATION DES PROCEDES GEORGES CLAUDE Linde AG 3.7 ANALYSIS PRAXAIR, INC. 3.7 This issue does not present significant risks or opportunities to the company and with the assigned weight of 0% does not contribute to the overall ESG rating for the company. MSCI ESG Research provides additional scores on a select set of ESG Issues for all companies on the MSCI World Index. Every company on the index receives scores for the following ESG Issues, regardless of whether they contribute to the overall Company ESG Rating: Carbon Emissions, Water Stress, Toxic Emissions, Labor Management, Health & Safety, Business Ethics, and Anti-Competitive Practices. Each of these issues is researched and analyzed according to ESG Research methodology regardless of assigned weight. Hence, scores for these Issues are fully comparable across all companies or industries. METHODOLOGY NOTE This issue evaluates the extent to which companies may face regulatory risks relating to anti-competitive practices. Companies successfully avoiding incident score "5", while companies that have faced controversies in the last three years score lower, based on the severity and type of controversy. RISK MANAGEMENT MSClf MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 33 OF 48 EX P-3581 Page 33 of 48 SVEC OLDMONS0570537 MONSANTO COMPANY (MON) ESG RATING g Controversies All controversies are assessed as part of the annual review of a company's ESG rating. MSG ESG Research tracks controversies for all companies on a regular basis. No major relevant controversies have been uncovered. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 34 OF 48 EX P-3581 Page 34 of 48 SVEC OLDMONS0570538 MONSANTO COMPANY (MON) ESG RATING g OTHER RISKS & OPPORTUNITIES Growth of Glyphosate-Resistant Weeds Threatens Sales of Flagship Roundup Product, Adds to Subsidy Costs: Roundup Ready crops account for 90% of the soybeans and 70% of the corn and cotton grown in the US. However, concerns over Roundup-resistant weeds have escalated in recent years and could potentially reduce sales of Roundup Ready crops and glyphosate-based herbicides. In an annual survey conducted by Stratus Agri-Marketing, approximately half of all U.S. farmers reported the presence of glyphosate-resistant weeds on their farm in 2013, which is up from 25% in 2010. The company's Roundup Ready Plus Weed Management Solutions program provides incentives to offset extra herbicide costs for farmers, but the growth of such weeds has the potential to increase costs down the line and reduce the economic benefits of using Roundup Ready seeds. Although the cost and duration of the program is unclear, we do not view this as a sustainable solution to weed-resistance. However, in January 2015 the USDA approved Monsanto's dicamba-resistant soy and cotton, which may reduce the company's vulnerability to the emergence of glyphosate-resistant weeds. As a long term solution, Monsanto is researching alternatives in the form of an RNA interference spray that would deactivate the plant gene responsible for glyphosate resistance. Nevertheless, the presence of tolerant weeds could have a long-term impact on the company's competitive position in these markets. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 35 OF 48 EX P-3581 Page 35 of 48 SVEC OLDMONS0570539 MONSANTO COMPANY (MON) ESG RATING g CONTROVERSIES DETAIL Here you will find the narratives for all controversies relevant to the ESG Ratings issues covered for the company in addition to those controversies that do not map to the ESG Ratings issues. CONTROVERSY CARD NUMBER OF CONTROVERSIES BY PILLAR 15 13 Environment Social Governance 20 CONTROVERSIES Very Severe: Indicates an action by a company that results in a very large impact on society and/or the environment. Severe: Indicates an action by a company that results in a large impact on society and/or the environment. Moderate: Indicates an action by a company that results in a moderate impact on society and/or the environment. Minor: Indicates an action by a company that results in a low impact on society and/or the environment. None: There is no evidence that a company is involved in any controversy. NUMBER OF CONTROVERSIES BY ASSESSMENT 16 Very Severe Severe Moderate Minor ENVIRONMENTAL CONTROVERSIES Very Severe Controversies Date: March 2016 Assessment: Very Severe Status: Ongoing Environmental Concerns over GMO Crops Monsanto has been heavily criticized over its continued development of genetically modified (GM) crops. Claims regarding the damage to biodiversity brought about by the company's GM products have been prevalent. Environmentalists have alleged that the sustained cultivation of Monsanto's herbicide-resistant crops contributed to the significant decline of the population of natural pollinators, including certain species of bees and butterflies. In addition, local farmers have expressed concerns regarding GM crop contamination, alleging that the exposure of non-GM crop fields to strains of genetically engineered crops have resulted in the decline and eradication of indigenous and local crops. Monsanto's GM products continue to face opposition from communities worldwide, as well as local and international NGOs in more than 50 countries. Regulatory bodies in Europe and the US have also challenged the company's promotion of the controversial crops. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 36 OF 48 EX P-3581 Page 36 of 48 SVEC OLDMONS0570540 MONSANTO COMPANY (MON) ESG RATING g NGO and Community Opposition As of March 2016, numerous international and local non-governmental organizations had active campaigns against Monsanto. These included: the Organic Seed Growers and Trade Association, People's Health Network, Save Our Crops Coalition, Biodiversidadla, Combat Monsanto, Organic Consumers Association, March Against Monsanto, GM Watch and the Non-GMO Project, among others In May 2013, international group March Against Monsanto (MAM) launched a global protest against Monsanto's GM crops. The demonstration ensued in approximately 400 cities in 57 countries with participants numbering to hundreds of thousands. Protesters highlighted concerns, including the mandatory labeling of GM products; the alleged negative health effects resulting from the consumption of GM crops; as well as the purported damage to biodiversity and ecological disruption the controversial products cause with their entry into local agriculture in various countries. In October 2013, MAM launched a second protest, which gathered a number of supporters at the same level as in May 2013. The organization had scheduled a third protest for May 2014. In August 2013, the Save Our Crops Coalition, a group of farmers based in Indiana, filed a comment with the U.S. Department of Agriculture urging a more in-depth review of Monsanto's genetically modified soybeans and cotton. In 2011, NGO opposition to the planting of GM crops in Mexico continued. Monsanto was given authorization from the Mexican government to plant GM yellow corn resistant to the herbicide glyphosate as a part of a pilot program in Tamaulipas, a region home to 16 of the 59 remaining strains of native corn. According to environmental groups, Monsanto had engaged in intense lobbying in favor of the introduction of GM corn in Mexico. In addition, a former president of Monsanto allegedly held meetings with the governor of Chaco, Argentina, to promote the use of GM food in the province. According to a representative of the NGO People's Health Network, this led to less criticism from authorities regarding the allegedly harmful effects of pesticides. According to the Commission of Investigation of Contaminants of the Chaco Water, child cancer rates had tripled and malformation in newborn babies had increased by 400 percent in the Leonesa area due to the pesticides used in conjunction with the GM crops. In March 2011, a group of U.S. organic agricultural organizations, headed by the Organic Seed Growers and Trade Association, filed a lawsuit in a federal district court in Manhattan, New York against Monsanto to challenge its patents on genetically modified seeds. The plaintiffs launched the legal action preemptively to protect themselves from being accused of patent infringement should they become contaminated by Monsanto's GM seeds. The district court dismissed the case in January 2012 ruling that the farmers lacked legal standing regarding the concerns over the potential contamination and consequential economic impact. The court also declared that the decision was made on grounds that the complainants' crops were not yet contaminated despite recognizing that some contamination was "inevitable." The plaintiffs subsequently brought the lawsuit to the Court of Appeals for the Federal Circuit in Washington, which also dismissed the case in June 2013 on the same grounds. In the proceeding, the appeals court highlighted that the company, "made binding assurances that it will not 'take legal action against growers whose crops might inadvertently contain traces of Monsanto biotech genes (because, for example, some transgenic seed or pollen blew onto the grower's land)."' In September 2013, the plaintiffs appealed to the US Supreme Court to get full protection from potential infringement. In January 2014, the court refused to hear the case. Regulatory Opposition According to the NGO Non-GMO Project, more than 60 countries including Australia, Japan, and all the members of the European Union have partial if not absolute restrictions on GM crops. As of March 2016, approximately 19 European countries have opted out from cultivating GMO crops. These include: Austria, Belgium for the Wallonia region, Britain for Scotland, Wales and Northern Ireland, Bulgaria, Croatia, Cyprus, Denmark, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland and Slovenia. In September 2015, France declared that it will exercise its opt-out rights under the EU's revised legislation for GM cultivation. The country has declared opposition to the cultivation of approximately nine GM maize strains manufactured by Monsanto, Du Pont and Syngenta. In the same month, Russia also declared a ban on the use of genetically modified organisms in food production. As of February 2015, seven European countries have imposed a complete ban on Monsanto's genetically modified strain of maize called MON810: France, Britain, Germany, Bulgaria, Austria, Luxembourg, Poland, Italy and Romania. In January 2015, the European Parliament passed a legislation allowing EU member states to individually decide on restricting or prohibiting the cultivation of GMO crops in their territory. The law also allows national governments to opt out from growing GMO crops that have already been authorized by the EU. In May 2013, the United States Department of Agriculture (USDA) announced that it would not allow the production of Monsanto's dicamba-resistant cotton and soybeans, as well as Dow Chemical's corn and soybeans until at least 2015. The department stated that the products could damage the environment and that it would need to produce complete environmental assessments prior to issuing approval. In September 2009, a federal judge ruled that the USDA had unlawfully approved Monsanto's Round-up Ready sugarbeets for use by farmers. The judge ruled that a full environmental assessment of the sugarbeets had not been completed at the time that the sugarbeets were approved. The case was brought to trial by the Center for Food Safety, a consumer and environmental advocacy group that sought to ban GM sugarbeets. The group's primary concern was cross-pollination of the GMO beets with native species. Monarch Population Decline In February 2015, environmental group Center for Food Safety (CFS) released a report on the purported negative impact of the cultivation of herbicide-resistant genetically modified crops on the monarch butterfly. According to the report, the monarch population has decreased by as much as 10 percent in the last 20 years due to the eradication of milkweed, the primary food source and larval host plant for the butterfly species' caterpillar. Glyphosate which is used in conjunction with GM corn and soybeans is particularly lethal to milkweed. The CFS report stipulated that the sustained use of the herbicide resulted in the loss of approximately 99 percent of milkweed in the Midwestern crop lands in the U.S. which is the main breeding habitat of monarchs. In light of the findings, CFS, the Center for Biological Diversity, the Xerces Society for Invertebrate Conservation along with biologists specializing in the study of monarchs, filed a legal petition with the U.S. Fish and Wildlife Service to protect monarchs as threatened under the Endangered Species Act (ESA). In December 2014, the institution announced that the ESA listing may be warranted. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 37 OF 48 EX P-3581 Page 37 of 48 SVEC OLDMONS0570541 MONSANTO COMPANY (MON) ESG RATING g Moderate Controversies Date: April 2016 Assessment: Moderate Status: Ongoing Date: April 2016 Assessment: Moderate Status: Ongoing In May 2015, Monsanto pledged to donate USD 4 million to initiatives aimed at preserving the monarch butterfly. According to the company, USD 3.6 would be donated to the National Fish and Wildlife Foundation's Monarch Butterfly Conservation Fund and USD 400,000 will be contributed to experts and groups working to protect the butterfly. As of March 2016, Monsanto has been collaborating with various environmental NGOs and academic institutions in launching initiatives aimed at protecting the monarch and restoring its habitat. The company has pledged to participate in several environmental programs including the expansion and improvement of more than 10 million acres of land by 2025 as part of a habitat distribution for the butterfly species; as well as the provision of funding to conservation groups to further restore sustainable quality milkweed and pollinator habitat across the critical range for monarch breeding and migration. Bee Population Decline Monsanto continued to face allegations of its contribution to the worldwide decline in bee population. NGOs and environmental experts have identified the company's herbicide-resistant genetically modified crops and the pesticides used to treat them as among the causes of colony collapse disorder (CCD) - a phenomenon which causes the death of a colony due to the disappearance of majority of the worker bees in a hive, leaving behind a queen and food reserves but a few nurse bees to care for the remaining immature bees and the queen. CCD has been attributed to neonicotinoids which are commonly used to treat GM corn and soybeans. Environmental scientists who have conducted studies on bee population in the U.S. and Europe have claimed that the substances attack the central nervous system of insects, resulting in memory impairment, damaged navigational capabilities and paralysis. Also associated with bee fatalities are GMO crops engineered to produce natural insecticides. Such GM varieties manifest the harmful substances in proteins within plant pollen and nectar during cultivation and cause poisoning to adult bees and their larvae. Studies conducted on Monsanto's Mon810 corn revealed that the insecticide Bacillus thuringiensis (Bt), which it produces, allegedly damages the digestive and immune system of bees. Bt purportedly reduces bees' capacity to eat then destroys their intestinal wall, eventually exposing the insect to spores and bacteria that would have been contained within the digestive tract. As of March 2016, Monsanto has launched various initiatives aimed at improving honey bee health. These include: allocation of resources for land development to establish and expand healthy pollinator habitats; establishment of Honey Bee Advisory Council to facilitate honey bee health research; formulation of a seed treatment insecticide stewardship plan to manage risks to beneficial insects such as bees; collaboration with academics, environmental NGOs, and farmers to identify issues and development pathways for honey bee health. Source: 18 Mar 2016_GMO-Free Europe; 09 Feb 2016_Company Communication; 05 Oct 2015_EcoWatch; 20 Sep 2015_The Moscow Times; 17 Sep 2015: _Reuters; 13 Jan 2015_BBC News; 31 Mar 2015_ASSOCIATED PRESS STATE & LOCAL; 24 Feb 2015_GMOfree Europe (website); 04 Feb 2015_Monarchs in Peril (Consumer Food Safety);; 13 May 2014_Business Insider; 04 Mar 2014_GuardianLV; 2014/3/15_RFI; 2014/3/15_Reuters; 2013/10/14_The Asheville Citizen-Times (North Carolina); 2013/10/12_Naples Daily News; 2013/10/12_FOX-2 KTVI (St. Louis); 2013/10/11_0range County Register (California); 2013/10/04_Progressive MediaCompany News; 2013/07/28_The Hawk Eye (Burlington, lowa);2013/05/ll_The New York Times; 01 Apr2013_Greenpeace; 2011/08/ 31_Reuters, 20ll/09/06_Greenpeace Luxembourg, 2011/08/17_biodiversidadla.org, 2011/03/31_radiomundoreal.fm, 2011/03/ 29_cipamericas.org, 2011/03/10_www.pagi na 12.com.ar Oakland City Lawsuit: Alleged Liability for San Francisco Bay PCB Contamination Monsanto has been named a defendant in a lawsuit filed by the City of Oakland for alleged contamination of the San Francisco Bay. The plaintiff claimed that the company was liable for polluting Oakland's stormwater and the bay with polychlorinated biphenyls (PCB). Oakland City representatives stressed that the company should bear the burden of the cleanup. UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016: MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 03 Feb 2016: CITIES SEEK MULTIDISTRICT LITIGATION FOR NOVEL PCB SUITS AGAINST MONSANTO. (ENVIRONMENTAL POLICY ALERT) 10 Nov 2015: Oakland sues Monsanto for allegedly polluting the San Francisco Bay. (SAN JOSE MERCURY NEWS (CALIFORNIA)) Source: 25 Apr 2016_SUPERFUND report San Diego City Lawsuit: Alleged Liability for San Diego Bay PCB Contamination Monsanto along with two chemical manufacturers have been named defendants in a lawsuit filed by the City of San Diego and the San Diego Unified Port District for alleged contamination of the San Diego Bay. The plaintiffs claimed that the companies were liable for the release of polychlorinated biphenyls PCB) into the bay. The complainants also accused Monsanto of continuing to manufacture and market PCBs despite having the knowledge that it was hazardous to the environment. The lawsuit included the request for a jury trial, punitive damages, compensation for cleanup as well as damages for San Diego's purported natural resource utility decrease. UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016: MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 03 Feb 2016: CITIES SEEK MULTIDISTRICT LITIGATION FOR NOVEL PCB SUITS AGAINST MONSANTO. (ENVIRONMENTAL POLICY ALERT) 17 Mar 2015: San Diego sues Monsanto over PCB pollution. (ST. LOUIS BUSINESS JOURNAL) Source: 25 Apr 2016_SUPERFUND REPORT MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 38 OF 48 EX P-3581 Page 38 of 48 SVEC OLDMONS0570542 MONSANTO COMPANY (MON) ESG RATING g Date: April 2016 Assessment: Moderate Status: Ongoing Date: April 2016 Assessment: Moderate Status: Ongoing Date: March 2016 Assessment: Moderate Status: Ongoing Date: March 2016 Assessment: Moderate Status: Ongoing Seattle City Lawsuit: Alleged Contamination of Local Water Sources with PCB Monsanto and three of its subsidiaries have been named defendants in a lawsuit filed by the City of Seattle for allegedly contaminating the city's drainage system and the Duwamish River with polychlorinated biphenyls (PCB). According to the plaintiff, PCB contamination was detected in 20,000 acres that drain to the Lower Duwamish, a federal Superfund site, and in areas that drain to the East Waterway adjacent to Harbor Island, a separate federal Superfund site. UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016; MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 03 Feb 2016: CITIES SEEK MULTIDISTRICT LITIGATION FOR NOVEL PCB SUITS AGAINST MONSANTO. (ENVIRONMENTAL POLICY ALERT) 26 Jan 2016: City Sues to Hold Monsanto Accountable for Toxic PCBs. (TARGETED NEWS SERVICE) Source: 25 Apr 2016_SUPERFUND report San Jose City Lawsuit: Alleged Contamination of Guadalupe River and San Francisco Bay with PCB Monsanto has been named a defendant in a lawsuit filed by the City of San Jose for alleged contamination of the Guadalupe River and San Francisco Bay. The plaintiff claimed that the company was liable for polluting San Jose's local river and the bay with polychlorinated biphenyls (PCB). UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016: MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 03 Feb 2016: CITIES SEEK MULTIDISTRICT LITIGATION FOR NOVEL PCB SUITS AGAINST MONSANTO. (ENVIRONMENTAL POLICY ALERT) 06 Aug 2015: San Jose Sues Monsanto over Pollution in San Francisco Bay. (San Jose Inside) Source: 25 Apr 2016_SUPERFUND report Opposition over Use of GMO Seeds in Nepal Since 2011, protests against the controversial entry of Monsanto into Nepal's seed industry have been ongoing. Local civil society organizations, NGOs, and farmer groups have demanded that the government ban imports of the company's genetically modified (GM) seeds into the country. Activists claimed that the inflow of the GM seeds would drive local varieties into extinction, which would in turn lead to the company's monopoly in Nepal's seed market. In December 2013, an environmental advocate filed a writ petition at Nepal's Supreme Court to prohibit the imports. The petition argued several points including: the produce from GM seeds have potential negative health effects on people and animals; introduction of GM variety of crops may wipe out local crops; the use of GM seeds would only increase local farmers' dependence on foreign companies for seeds due to the one-time-use patents of such seeds. The petition named the Office of the Prime Minister and the Council of Ministers, Ministry of Agriculture and Cooperatives, Department of Agriculture, Nepal Agriculture Research Council, Food Technology and Quality Control Department, Seeds Quality Control Center as defendants. As of January 2014, the Supreme Court had issued an interim order on the importation to the country's government to temporarily prohibit the importation of Monsanto's GM seeds.The company appealed the ruling in February 2014. Source: 2014/2/15_EKantipur.com; 2014/l/26_The Himalayan Times; 2014/l/8_Ekantipur; 2014_Aljazeera: 2013/12/29_Republica; 2013/12/20_Republica; 2011/12/13_My Republica; 2011/ll/12_My Republica Lawsuits over Alleged Contamination of Pacific Northwest Fields with Genetically Modified Wheat Monsanto has agreed to pay approximately USD 2.4 million to settle litigation related to the alleged contamination of wheat fields in certain U.S. Pacific Northwest states by its genetically modified (GM) wheat. The GM wheat variant was not approved by the United States Department of Agriculture (USDA) for cultivation. After the crop was discovered in Oregon and Washington in 2013, affected wheat farmers launched legal action. Subsequently, all related lawsuits were consolidated under one case in the Federal District Court of Kansas. The settlement does not resolve contamination claims in Arkansas. As of March 2016, these remained ongoing. UPDATES: [accessed on Mar 7 2016]: Newsroom. (Monsanto website) As of March 2016, litigation on the grain contamination claims in Arkansas was ongoing. 18 Mar 2015: Monsanto to pay $350K to settle more wheat-related lawsuits. (ASSOCIATED PRESS FINANCIAL WIRE) In addition to the settlement amount the company pledged to make donations of USD 50,000 to agricultural schools at land grant colleges in Kansas, Missouri, Illinois, Oklahoma, Texas, Louisiana and Mississippi. Monsanto also declared that as of March 2015, there is one active wheat contamination lawsuit in Arkansas that remains pending. 18 Mar 2015: Monsanto to pay $350K to settle more wheat-related lawsuits. (ASSOCIATED PRESS FINANCIAL WIRE) In addition to the settlement amount the company pledged to make donations of USD 50,000 to agricultural schools at land grant colleges in Kansas, Missouri, Illinois, Oklahoma, Texas, Louisiana and Mississippi.Monsanto also declared that as of March 2015, there is one active wheat contamination lawsuit in Arkansas that remains active. 21 Jan 2015: Monsanto reaches $2.4M settlement with wheat farmers in Pacific Northwest in. (CANADIAN GOVERNMENT NEWS) BACKGROUND In May 2013, a farmer from northeastern Oregon filed a report to the USDA stating that he discovered a strain of genetically engineered, herbicide-resistant wheat after using Monsanto's Roundup Ready pesticide on his field. After conducting an investigation, the USDA announced that the wheat discovered by the farmer was identical to the wheat variant which underwent testing as part of Monsanto's research from 1998 to 2004. However, the genetically modified wheat was not approved by the USDA. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 39 OF 48 EX P-3581 Page 39 of 48 SVEC OLDMONS0570543 MONSANTO COMPANY (MON) ESG RATING g Minor Controversies Date: April 2016 Assessment: Minor Status: Ongoing Date: April 2016 Assessment: Minor Status: Ongoing Date: April 2016 Assessment: Minor Status: Ongoing Date: July 2015 Assessment: Minor Status: Concluded The Japanese and Korean Government restricted the shipment of Western White wheat following the May 2013 announcement. In response to the Oregon discovery, Monsanto claimed that it had discontinued its research on the genetically modified wheat in question and that the re-emergence of the variant was unusual, as all the seeds involved in its research could not have survived in the soil for more than two years. Further, the company stated that its research was not conducted in northeastern Oregon, and that wheat pollen only moves approximately 30 feet from its source. In June 2013, as part of a larger investigation into the genetically modified wheat previously found in northeastern Oregon, Monsanto tested 30,000 seed samples of 50 different wheat varieties in Washington and Oregon. The company concluded that none of the wheat varieties it tested proved to be genetically modified, and that the discovery of genetically modified wheat in northeastern Oregon was an isolated incident. The discovery of GM wheat in Oregon sparked numerous lawsuits from farmers. In June 2013, two class action lawsuits were filed against Monsanto at the United States District Court in Spokane alleging that the discovery of genetically engineered wheat in Oregon negatively affected their businesses. The first lawsuit was filed by farmers representing two wheat farms in Eastern Washington, Wahl Ranch in Adams County and Dreger Enterprises in Lincoln County. The damages of this lawsuit would be determined by the court. A separate lawsuit was filed by the Center for Food Safety on behalf of Northwest wheat farmers. Clarmar Farms and another wheat farmer were also named as plaintiffs of the lawsuit. Later in the month, a wheat farmer from Kansas filed a lawsuit seeking class action status against the company. The lawsuit alleged that the company's genetically modified wheat infiltrated non-genetically engineered wheat. Since genetically engineered wheat was not approved by the USDA, the cost of producing wheat increased and prices plummeted. Monsanto reported that as of November 2013, the USDA's investigation on the claims with regard to the specific GM crop remains ongoing and the agency indicated that civil and criminal penalties could be imposed if circumstances warranted. According to the company, lawsuits filed against it concerning the wheat variety in question have been consolidated in the Federal District Court of Kansas. Source: 07 Mar 2016_Monsanto Website; 18 Mar 2015_ASSOGATED PRESS FINANCIAL WIRE; 21 Jan 2015_CANADIAN GOVERNMENT NEWS; 2013/ll/30_Monsanto 2013 10-Q Report; 2013/06/06_The Seattle Times; 2013/06/05_The Wall Street Journal; 2013/06/04_RT; 2013/06/03_The Wall Street Journal Berkley City Lawsuit: Alleged Contamination of Local Water Sources with PCB UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016: MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 03 Feb 2016: CITIES SEEK MULTIDISTRICT LITIGATION FOR NOVEL PCB SUITS AGAINST MONSANTO. (ENVIRONMENTAL POLICY ALERT) 07 Jan 2016: Berkeley City Council voted unanimously to sue Monsanto over PCB cleanup costs. (SAN JOSE MERCURY NEWS (CALIFORNIA)) Source: 25 Apr 2016_SUPERFUND REPORT; 28 Mar 2016_SUPERFUND REPORT; 03 Feb 2016_ENVIRONMENTAL POLICY ALERT; 07 Jan 2016_SAN JOSE MERCURY NEWS (CALIFORNIA) Spokane City Lawsuit: Alleged Contamination of Local River with PCB UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016: MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 03 Feb 2016: CITIES SEEK MULTIDISTRICT LITIGATION FOR NOVEL PCB SUITS AGAINST MONSANTO. (ENVIRONMENTAL POLICY ALERT) 04 Aug 2015: Spokane, Washington, sues Monsanto over PCBs in polluted state river. (Reuters) Source: 25 Apr 2016_SUPERFUND REPORT; 28 Mar 2016_SUPERFUND REPORT; 03 Feb 2016_ENVIRONMENTAL POLICY ALERT; 04 Aug 2015_Reuters Portland City Lawsuit: Alleged Contamination of Willamette River with PCB UPDATES: 25 Apr 2016: JUDGES REJECT CONSOLIDATION OF WEST COAST CITIES' PCB TORT CASES. (SUPERFUND REPORT) 28 Mar 2016: MONSANTO ARGUES WEST COAST PCB CASES TOO DIFFERENT FOR CONSOLIDATION. (SUPERFUND REPORT) 16 Mar 2016: Portland To Join Suit Against Monsanto. (EARTHFIX (OREGON)) Source: 25 Apr 2016_SUPERFUND REPORT; 28 Mar 2016_SUPERFUND REPORT; 16 Mar 2016_EARTHFIX (OREGON) Brofiscin Landfill, South Wales: Agreement to Pay for Cleanup of Former Quarry in the 1960s UPDATES: 14 Jul 2015: Monsanto, BP and Veolia agree to pay for cleanup of contaminated Welsh site ; Five decades after toxic waste from a Monsanto plant was dumped at Brofiscin quarry in south Wales, companies agree to pay towards cleanup costs. (THE GUARDIAN) Source: 14 Jul 2015 THE GUARDIAN MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 40 OF 48 EX P-3581 Page 40 of 48 SVEC OL.DMONS0570544 MONSANTO COMPANY (MON) ESG RATING g SOCIAL CONTROVERSIES Severe Controversies Date: March 2016 Assessment: Severe Status: Ongoing Date: March 2016 Assessment: Severe Status: Ongoing Patent Enforcement Practices Monsanto is known for monitoring the use of its patented seeds and for taking a tough stand against farmers the company alleges have used the seeds illegally. The company has been criticized for its practice of hiring private investigators to monitor farmers. It has filed lawsuits against several farmers in the U.S. and Canada alleging patent infringement. As March 2016, the company continued to be involved in such litigation. In February 2013, the United States Supreme Court heard arguments for a case against Monsanto filed by a 75-year old farmer who purchased Monsanto's soybeans and subsequently used the resulting seeds from his crop to plant more crops. Previously, lower courts had already ruled in favor of Monsanto. Separately, non-governmental organizations, Center for Food Safety and the Save Our Seeds campaign, released a study tracking Monsanto's 142 patent infringement suits filed against 410 farmers and 56 small businesses across approximately 27 states. The company clarified in a statement that it has filed lawsuits against farmers 145 times since 1997. Monsanto has stated that it aggressively enforces its seed patents in order to protect its intellectual property and to ensure that it is compensated for its research and development activities. Further, the company reports that it donates any profits from seed enforcement lawsuit penalties to charity. Monsanto's patent protection measures conflict with farmers' traditions of reusing seeds from a previous season's crops. Farmers who purchase seeds from Monsanto are required to sign a "Technology Use Agreement" and pay the company a fee based on acreage planted in addition to the cost of the seeds. The agreement gives the company a right to inspect the fields and take samples for three years after the seeds are purchased. The company has set up a controversial toll-free tip line for farmers to report on those who violate the agreement. In March 2011, a group of US organic agricultural organizations headed by the Organic Seed Growers and Trade Association filed a lawsuit in a federal district court in Manhattan, New York Court against the Monsanto to challenge its patents on genetically modified seeds. The plaintiffs launched the legal action preemptively to protect themselves from being accused of patent infringement should they become contaminated by Monsanto's GM seeds. The district court dismissed the case in January 2012, ruling that the farmers lacked legal standing regarding the concerns over the potential contamination and consequential economic impact. The court also declared that the decision was made on grounds that the complainants were not yet contaminated despite recognizing that some contamination is "inevitable." The plaintiffs subsequently brought the lawsuit to the Court of Appeals for the Federal Circuit in Washington which also dismissed the case in June 2013 on the same grounds. The June 2013 appeals court decision highlighted the fact that "Monsanto has made binding assurances that it will not 'take legal action against growers whose crops might inadvertently contain traces of Monsanto biotech genes (because, for example, some transgenic seed or pollen blew onto the grower's land).'" In September 2013, the plaintiffs appealed to the US Supreme Court to get full protection from potential infringement. In January 2014, the Supreme Court refused to hear case. That ruling supports the appeals court's verdict and bars the reinstatement of the case. Source: 23 Mar 2016_Monsanto Website; 31 Aug 2015_2015 10-K; 2013/02/22_Huffington Post;2014/l/23_GM0 Journal; 2014/1/ 14_OSGATA Press Release; 2011/3/29_OSGATA Press Release; 2014/l/13_RT.com; 2013/02/13_Huffington Post Lawsuits Concerning Agent Orange Monsanto has faced lawsuits in the U.S., Europe, Canada, South Korea, and Vietnam following widespread public health issues raised by war veterans and civilians who came in contact with the herbicide known as Agent Orange. U.S., South Korean, and Vietnamese veterans and their families have attributed various illnesses to the defoliant, including miscarriages, birth defects, cancers, and nervous disorders. Vietnam claims that about a million of its people suffer from Agent Orange-related illnesses. UPDATES: Nitro, West Virginia Lawsuit 07 Jul 2015: MONSANTO CO: Parties in "Allen" Case Perform on Settlement. (CLASS ACTION REPORTER) Jan 2013: The Putnam County Circuit Court approved Monsanto's proposed settlement. Subsequently, certain plaintiffs objected to the settlement and brought the case to the West Virginia Supreme Court. The Court dismissed the appeal in November 2013 in favor of Monsanto. Feb 2012: Monsanto proposed a settlement wherein it agreed to pay approximately USD 93 million in resolution of the allegations. The agreement stipulated a 30-year medical monitoring program consisting of approximately USD 21 million and an additional fund of approximately USD 63 million over the life of the program, and a three-year property remediation plan amounting to approximately USD 9 million. Dec 2004: 15 plaintiffs filed a purported class action lawsuit against Monsanto, (its former parent) Pharmacia, and seven other defendants alleging that the companies' production of Agent Orange in Nitro, West Virginia resulted in the release of dioxins at unsafe levels that contaminated the area. The complainants comprised of current and former residents, workers, and students who, between 1949 and the present, were allegedly exposed to dioxins/furans contamination in counties surrounding the site. The plaintiffs also claimed that members of their community contracted illnesses and conditions including cancer, birth defects, learning disabilities, endometriosis, infertility, and suppressed immune functions, due to exposure to dioxin pollution. The plaintiffs sought damages for property cleanup costs, loss of real estate value, funds for property contamination testing, funds for human exposure testing, and medical monitoring costs. Monsanto previously reached an agreement with the EPA to clean up the Nitro site in 1983 and again in 1985. However, in a 2000 report, the EPA stated that the nearby Kanawha River contained unsafe and illegal levels of dioxin. In 2002, state regulators discovered seepage of dioxin into the Kanawha River allegedly from a plant where Monsanto used to manufacture Agent Orange. The dioxin reportedly settled in the river and nearby surroundings. MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 41 OF 48 EX P-3581 Page 41 of 48 SVEC OLDMONS0570545 MONSANTO COMPANY (MON) ESG RATING g MSCI Claims by U.S. Veterans 10 Mar 2016: Researchers call for more study of Agent Orange's effects on Vietnam veterans and their kids. (The Virginia-Pilot) The committee of researchers established in 1991 to investigate the negative health effects of Agent Orange has declared that more than two decades of study has not produced a concrete understanding as to how the toxic herbicide has harmed Vietnam veterans and possibly their families. The committee declared that there are still significant gaps in their findings and that additional research is necessary. 08 Feb 2016: Veterans Affairs again denies Agent Orange benefits to Navy vets. (The Virginia-Pilot) The U.S. Department of Veterans Affairs (VA) has again rejected the efforts of Vietnam Navy veterans to claim compensation for possible exposure to Agent Orange. For over a decade, advocates for approximately 90,000 Blue Water Navy veterans who served off the coast of Vietnam have been requesting the VA to expand its benefits policy to include them. The veterans group claimed that they were exposed to Agent Orange because their ships harnessed potentially contaminated water and distilled it for drinking, cooking, bathing and laundry. Experts have reported that the distillation process could have actually concentrated the harmful substance. 18 Jun 2015: VA Expands Disability Benefits for Air Force Personnel Exposed to Contaminated C-123 Aircraft. (Department of Veteran Affairs) In light of the Institute of Medicine's January 2015 findings, the Department of Veterans Affairs implemented a new regulation in June 2015 that expanded the benefits eligibility for certain Air Force Veterans and Air Force Reserve personnel who were exposed to the herbicide Agent Orange during their service inside the contaminated C-123 aircraft. 09 Jan 2015: Post-Vietnam Dioxin Exposure in Agent Orange-Contaminated C-123 Aircraft. (Institute of Medicine) In January 2015, the Institute of Medicine (IOM) released a report entitled "Post-Vietnam Dioxin Exposure in Agent Orange-Contaminated C-123 Aircraft." The report was based on an evaluation conducted by the IOM on the 1,500 to 2,100 Airforce Reserve personnel who trained and worked between 1972 and 1982 on the C-123 aircraft that had been used to spray herbicides, including Agent Orange (AO), during Operation Ranch Eland in the Vietnam War. The Department of Veteran Affairs requested the IOM to conduct the assessment to determine if the AF Reservists were exposed to herbicides at levels harmful to their health. The lOM's findings indicated the following: the presence of herbicide residues on the interior surfaces of the C-123 aircraft; herbicide residue levels based on internal surface samples fall in or above the cautionary range for adverse health outcomes as defined by international guidelines; AF reservists would have been exposed to the herbicides during their service inside the C-123; plausibility that reservists' chemicals exposure exceeded health guidelines which increases the likelihood of increased risks of adverse health outcomes. Vietnamese Veterans Lawsuit 08 Jan 2016: First argument session in Agent Orange lawsuit in France slated for March. (Vietnam Plus) The Crown Court of Evry scheduled in March 2016, the first argument session for the 2014 Agent Orange lawsuit launched by Tran To Nga. 15 Jun 2015: EXCLUSIVE: Agent Orange Victims to Sue U.S. Firms Again for Damages. (JIJI PRESS TICKER SERVICE) Advocacy group, Vietnam Association of Victims of Agent Orange (VAVAO), declared that it will launch another lawsuit against 26 companies, including Monsanto to seek damages for negative health effects caused by defoilants used during the Vietnam War. The group stated that it had learned many lessons from their failed legal action which was launched in 2004. VAVAO declared that timing of the new lawsuit's filing has not been decided but a shortlist has been established for which courts they will initiate the litigation in. 15 Jun 2015: EXCLUSIVE: Agent Orange Victims to Sue U.S. Firms Again for Damages. (JIJI PRESS TICKER SERVICE) Advocacy group, Vietnam Association of Victims of Agent Orange (VAVAO), declared that it will launch another lawsuit against 26 companies, including Monsanto to seek damages for negative health effects caused by defoilants used during the Vietnam War. The group stated that it had learned many lessons from their failed legal action which was launched in 2004. VAVAO declared that timing of the new lawsuit's filing has not been decided but a shortlist has been established for which courts they will initiate the litigation in. 21 April 2015: Agent Orange trial launched by French-Vietnamese woman opens. (VAVA.org) In May 2014, French-Vietnamese, Tran To Nga filed a class action lawsuit in the Crown Court of Evry in France against 26 U.S. companies for producing the toxic substances sprayed by the U.S. armed forces during the war in Vietnam. Nga and her legal representatives claimed that the chemicals, and therefore their manufacturers, were responsible for the serious health issues inflicted on her, her family and Vietnamese communities. Mrs. Nga was purportedly exposed to Agent Orange during her service for the Liberation News Agency in the late 1960s. Working as a correspondent, she travelled to the most heavily dioxin-contaminated areas in southern Vietnam including Cu Chi, Ben Cat and along the Ho Chi Minh Trail. According to Mrs. Nga her first born died of heart defects and her second child suffered from a blood disease, which were purportedly caused by her earlier exposure to the harmful chemicals used during the war. In April 2015, the trial for her 2014 lawsuit was launched. Oct 2008: The plaintiffs brought the lawsuit to the US Supreme Court to request that it be reviewed again. The request was denied in February 2009. Nov 2004: The defendants filed a motion to dismiss the case on grounds of jurisdiction and the plaintiffs' failure to prove that the defendants violated international laws. In March 2005, the District Court dismissed VAVAO's lawsuit. The judged presiding over the case ruled that the use of the dioxins during the war, although they were toxic, did not fit the definition of "chemical warfare" and therefore did not violate international law. The court also declared that the chemical manufacturers as US government contractors had the same immunity as the US government from litigation. Subsequently, the plaintiffs filed appeals to reinstate the case in the Second Circuit Court of Appeals and the Federal Court of Appeals in Manhattan. Both were denied Jan 2004: VAVAO filed a lawsuit in the District Court of the Eastern District of New York against Monsanto, Dow Chemical, Pharmacia and other chemical produces involved in the manufacturing of Agent Orange. By virtue of the Alien Tort Claims Act, the plaintiffs alleged that the companies that produced the toxic herbicides used in the Vietnam war were in "violation of international law and war crimes, and under the common law for products liability negligent and intentional torts, civil conspiracy, public nuisance and unjust enrichment, seeking many damages for personal injuries, wrongful death and birth defects and seeking injunctive relief for environmental contamination and disgorgement of profits." South Korea Court Rulings Jul 2013: The South Korea Supreme Court ordered Monsanto and Dow Chemical to compensate 39 Vietnam War veterans a total of approximately USD 415,000. The Court recognized the complainants contracted certain skin diseases such as chemical acne due to exposure to the toxic defoliants manufactured by the two companies. Dow Chemical contested the ruling and argued that the verdict was not supported by clear evidence. MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 42 OF 48 EX P-3581 Page 42 of 48 SVEC OLDMONS0570546 MONSANTO COMPANY (MON) ESG RATING g Date: January 2016 Assessment: Severe Status: Ongoing Jan 2006: A South Korean court ordered Monsanto and Dow Chemical to pay compensation to approximately 6,800 people, including South Korean Vietnam War veterans and their families, who allegedly suffered health problems due to Agent Orange exposure. Total compensation was estimated at USD 61 million. Three separate damages suits were filed against the two companies on behalf of approximately 20,000 South Koreans. Two were upheld by the court while one case was dismissed. Federal courts have ruled that Vietnam veterans who missed a 1994 deadline for seeking compensation for Agent Orange-related illnesses could sue Agent Orange manufacturers, including Monsanto, for damages. As part of a 1984 settlement the manufacturers agreed to pay into a USD 180 million compensation fund for Vietnam veteran victims in exchange for release from any future liability. However, plaintiffs have alleged that those who discover illnesses after 1994 should be eligible for payments. Pending Lawsuit in Canada Sep 2007: A lawsuit filed by the Canadian government against Monsanto and Dow Chemical in April 2007 was pending. The lawsuit sought compensation for any injuries plaintiffs may have suffered as the result of the spraying of Agent Orange chemicals in 1967 and 1968 at Canadian Forces Bases. At an earlier time, individuals who lived near a base in New Brunswick filed a class action lawsuit against the Canadian government alleging that they suffered injuries from being exposed to various chemicals used for 30 years to control weeds at the base. Source: 10 Mar 2016_The Virginia-Pilot; 08 Jan 2016_Vietnam Plus; 08 Feb 2016_The Virginia-Pilot; 07 Jul 2015_CLASS ACTION REPORTER; 15Jun 2015JIJI PRESS TICKER SERVICE; 18Jun 2015_Department of Veteran Affairs; 15Jun 2015JIJI PRESS TICKER SERVICE; 21 April 2015_VAVA.org; 09 Jan 2015_lnstitute of Medicine; 2013/ll/30_Monsanto 10-Q Report; 2013/8/31_Monsanto 2013 10-K; 2013/l/25_Bloomberg Businessweek; 2013/2/l/_lndiana Public Media; 2012/2/2_lndiana Public Media; 2012/2/l_NPR; 2013/l/29_lnsurance Journal; 2013/7/12_Fox News; US Department of Justice Department Court Documents 2004-2009; Agent Orange Record; 2012/l/2_Chemical Week; 2011/08/10_Thai Newsservice Protests Against Cordoba Plant Monsanto has faced opposition from residents of Malvinas Argentinas in Cordoba, Argentina over its proposed construction of a treatment plant for genetically modified (GM) corn in the area. The project involves the construction of over 200 silos and the use of agrochemical substances for the containment and treatment of GM maize seeds. Locals and activist groups lead by the Malvinas Lucha por la Vida (Malvinas Lucha por la Vida (Malvinas Assembly Fighting for Life), since June 2013, have conducted protests and raised concerns regarding the negative health impacts that may result from the potential release of chemicals from the facility. UPDATES: 20 Jan 2016: Argentine Social Movements Strike Back Against Monsanto. (teleSUR) In December 2015, a local court in Malvinas Argentinas released an order requiring activists, for 24 hours, to give free passage to company personnel and machinery at the construction site of Monsanto's GMO treatment plant. The order was immediately opposed by advocacy groups. Numerous NGOs called for their members to assemble at the encampment to reinforce the blockade. The groups further made a public announcement, declaring a state of "permanent alert" at the site. NGOs also launched protests in cities around Argentina in January 2016 to stress their opposition to the GMO treatment plant. 06 Mar 2015: Argentina takes a stand against Monsanto. (La Opinion) Despite the termination of construction at Monsanto's Argentina facility, the protesters' encampment was still in place. The Malvinas Assembly and other organizations declared that they will sustain their efforts and oppose Monsanto should it attempt to pursue the development of the plant. Apr 2014: The blockade at Monsanto's Argentina facility was still in place and demonstrations were ongoing. The Malvinas Assembly and other organizations declared that they will sustain their efforts until the project was completely shut down. Feb 2014: The government of Cordoba rejected Monsanto's EIA for failing to identify the relevant impacts and resulting mitigation measures of its treatment plant. The company subsequently appealed to the Environment Secretariat as well as the Ministry of Water, Environment and Energy but was denied approval by both. Jan 2014: A Malvinas Argentias court ruled in favor of the locals. The legal body ordered Monsanto to halt construction at Cordoba plant and prohibited the municipality from authorizing activities connected to the project until the company accomplishes the environmental impact assessment and undergoes public hearing or local referendum. Jun 2013: Malvinas Argentinas residents launched a protest against Monsanto's proposed Cordoba-based treatment plant for genetically modified maize seeds. The demonstration followed the company's announcement that the first stage of construction would be complete by the end of 2013 and the plant would start operating by April 2014. The protesters stressed the potential negative health effects that may result from the plant's operation byproducts. Locals declared that the facility poses another health risk on top of the already prevalent respiratory illnesses and birth defects in the area, which they alleged were associated with exposure to Monsantos's product. Roundup, used for the cultivation of soy in Cordoba. Dec 2013: Monsanto sought the assistance of local authorities to disperse the demonstrators. The company reported that masked protesters armed with sticks and stones attacked workers who tried to enter the facility. A violent confrontation ensued as riot police deployed at the site used rubber bullets and tear gas on the protesters. Approximately eight were injured from the clash. Nov 2013: Members of the Argentine Construction Union attacked the protest camp in Cordoba. The workers complained that the demonstration cut them off from their livelihood. Approximately 20 injuries resulted from the incident. Oct 2013: Operations at the site were halted when demonstrators disrupted the entry of supplies. Sep 2013: protesters set up a blockade in front of Monsanto's Cordoba plant. Subsequently, locals with the support of advocacy groups filed an injunction in a provincial court in Malvinas Argentinas against the company demanding the suspension of construction until the environmental impact study for the project was completed. Source: 20 Jan 2016_teleSUR; 06 Mar 2015_La Opinion; 2014/4/24_La Manana de Cordoba; 2014/4/5_Revolution News; 2014/3/ 26_The Argentina Independent; 2014/2/ll_The Wall Street Journal; 2014/l/25_IPS-lnter Press Service; 2014/1/9_RT; 2013/ll/28_The Associated Press; 2013/12/2_IPS-lnter Press Service; 2013/09/30_Cadena 3; 2013/09/30_lnfocampo; 2013/07/19_La Mana de Cordoba; 2013/06/27_La Manana de Cordoba; 20120831_organicbuenosaires.com MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 43 OF 48 EX P-3581 Page 43 of 48 SVEC OLDMONS0570547 MONSANTO COMPANY (MON) ESG RATING g Date: November 2015 Assessment: Severe Status: Ongoing Moderate Controversies Date: May 2016 Assessment: Moderate Status: Ongoing Date: May 2016 Assessment: Moderate Status: Ongoing Brazilian Soy Farmers Royalty Lawsuit In 2008, approximately five million large and small Brazilian soybean producers launched legal action against Monsanto for the alleged illegal collection of royalties on seed harvests of its genetically engineered Roundup Ready soybeans. The complainants claimed that the company demanded royalties not only for the initial harvested crop using the patented seed but also for subsequent crop harvests. The soy farmers argued that using seeds from previous harvests has always been a traditional practice and should not warrant crop royalties. Since 2003, Monsanto has allegedly demanded from Brazilian soy producers an annual crop royalty equivalent to twopercent of revenue derived from annual harvests. UPDATES: 30 Nov 2015: 10-Q 2015. (Monsanto) Litigation on the alleged illegal royalty collection on Roundup Ready seed harvests was ongoing. 31 Aug 2014: 10-K 2014. (Monsanto) Monsanto declared that it continued to face royalty-related legal actions in Brazil. The company stated that duration of patents for its Roundup Ready soybeans were under review in the country. Nov 2013: Monsanto continued to face the seed royalty lawsuit. The company might be liable for BRL 15 billion (USD 7.5 billion) if it were to lose the lawsuit. The Superior Tribunal of Justice, Brazil's second highest court, ruled that once a final decision was reached in the case filed in the state of Rio Grande do Sul, the decision could be applied across the country. Feb 2013: Monsanto offered a new contract to settle the lawsuit, but the offer was rejected by Brazilian soy farmers. The company told investors that it would defer royalty collection for first-generation Roundup Ready soybeans in Brazil until the matter was settled by the Brazilian court. Apr 2012: A court in Rio Grande do Sul ordered Monsanto to pay back at least USD 2 billion of the royalty payments it had collected. Monsanto subsequently appealed the ruling. Source: 30 Nov 2015_ Monsanto 10-Q 2015; 31 May 2015_ Monsanto 10-Q 2015; 31 Aug 2014_Monsanto 10-K 2014; 2013/11/ 30_Monsanto 10-Q report; 2012/6/13_Reuters; 2012/6/3_AFP Roundup-related Injury Lawsuits Monsanto continues to face personal injury lawsuits related to its Roundup product. Complainants have alleged the company is liable for their contraction of various illnesses due to exposure to Roundup. The influx of claims was triggered by the classification of glyphosate, Roundup's active ingredient, as a probable carcinogen by the International Agency for Research on Cancer. UPDATES: 17 May 2016: Monsanto slumps as its popular herbicide Round Up faces class action suit in the US. (THE ECONOMIC TIMES) 10 Mar 2016: Monsanto Lawsuit Claims Roundup Caused Cancer in Cambria Farmer. (NEWS RELEASE WIRE) 04 Feb 2016: Former coffee farm owners sue Monsanto. (HAWAII TRIBUNE-HERALD) 28 Jan 2016: Americans With Herbicide-Linked Cancer File Lawsuit Against Monsanto in California. (RIA NOVOSTI) 24 Dec 2015: MONSANTO CO: Faces "Giglio" Suit Over Roundup(R)-Related Damages. (CLASS ACTION REPORTER) 15 Oct 2015: U.S. lawsuits build against Monsanto over alleged Roundup cancer link. (REUTERS HEALTH MEDICAL NEWS) 29 Sep 2015: U.S. workers sue Monsanto claiming herbicide caused cancer. (REUTERS HEALTH MEDICAL NEWS) Source: 17 May 2016_THE ECONOMICTIMES WHO Agency Declares Glyphosate as "Probably Carcinogenic" to Humans In March 2015, the World Health Organization's specialized cancer agency, the International Agency for Research on Cancer (IARC), released an assessment of five organophosphate pesticides. Among the agricultu ral chemicals evaluated was glyphosate, which Monsanto markets under the Roundup brand. The IARC classified glyphosate as "probably carcinogenic" to humans. According to the agency's study, for the herbicide, there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma, and sufficient evidence of carcinogenicity in experimental animals. Glyphosate also purportedly caused DNA and chromosomal damage in human cells. The IARC cited studies of exposure to glyphosate in the U.S., Canada and Sweden since 2001. The lARC's findings have triggered the temporary ban of the chemical in certain parts of France and Colombia. Meanwhile, other food and substance safety agencies in certain nations like the German Federal Institute for Risk Assessment (BfR) have begun to conduct their own examination of glyphosate. The BfR found results opposite to the lARC's assessment but clarified that it has not conducted a complete review the WHO agency's report. In May 2016, the cancer assessment review committee of the U.S. Environmental Protection Agency (EPA) published online a preliminary report stating that glyphosate was not likely to be carcinogenic to humans. However, the EPA subsequently withdrew the report from the government website. Separately, the United Nations Food and Agriculture Organization published a study that found that glyphosate was "unlikely" to be carcinogenic when ingested orally through food. UPDATES: 16 May 2016: Dietary exposure to glyphosate unlikely to cause cancer, U.N. report says. (UPI) 13 May 2016: EPA faces second U.S. lawmakers investigation into glyphosate review. (Reuters) 12 May 2016: U.S. lawmakers put pressure on EPA over handling of glyphosate review. (Reuters) 03 May 2016: EPA takes offline report that says glyphosate not likely carcinogenic. (REUTERS HEALTH MEDICAL NEWS) 08 Apr 2016: French Government Moves to Ban Some Monsanto Glyphosate Weed Killers. (Environmental Working Group) 07 Mar 2016: EU to defer decision on safety of weed-killer ingredient - sources. (Reuters) MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 44 OF 48 EX P-3581 Page 44 of 48 SVEC OLDMONS0570548 MONSANTO COMPANY (MON) ESG RATING g Date: April 2016 Assessment: Moderate Status: Ongoing Date: April 2016 Assessment: Moderate Status: Ongoing 02 Mar 2016: Center for Food Safety Moves to Defend California from Monsanto Attack. (TARGETED NEWS SERVICE) 02 Mar 2016: NGOs sue Monsanto over pesticide safety. (The Local (Austria)) 17 Feb 2016: Key evidence withheld as 'trade secret' in EU's controversial risk assessment of glyphosate. (The Corporate Europe Observatory) 21 Jan 2016: UPDATE 1-Monsanto sues to keep herbicide off California list of carcinogens. (Reuters) 13 Jan 2016: EU food safety watchdog hits back at scientists in glyphosate row. (Reuters) 07 Dec 2015: Scientists assembled for Monsanto say herbicide not carcinogenic, disputing WHO report. (Reuters) 12 Nov 2015: EU watchdog approves new licence for controversial weedkiller; Herbicide approved for relicensing in EU, despite World Health Organisation assessment linking it to cancer in humans. (THE GUARDIAN) 12 Nov 2015: European scientists say weedkiller glyphosate unlikely to cause cancer. (Reuters) According to an independent study conducted by the European Food Safety Authority (EFSA) on glyphosate, it is unlikely that the substance is carcinogenic. The EFSA declared that it had conducted a thorough analysis of the substance and took into account the IRAC's findings. 21 Oct 2015: Monsanto pushes against California listing of herbicide as cancer cause. (YEREPOUNI DAILY NEWS) 22 Sep 2015: Herbicide scrutiny mounts as resistant weeds spread in U.S. (SAUDI PRESS AGENCY (SPA)) 10 Sep 2015: California Moves To Protect Citizens From Monsanto's GMO Weed Killer. (Environmental Working Group) California has expressed intentions to add glyphosate to the state's official list of known carcinogens. The state declared its plans to implement the policy through Proposition 65, a legislation that requires the registration and labeling of hazardous chemicals known to cause cancer or birth defects as determined by California's Office of Environmental Health Hazard Assessment. 20 Aug 2015: Scientists call for new review of herbicide, cite 'flawed' U.S. regulations. (NEWS POINT) 19 Aug 2015: Bill banning Roundup yanked. (HAWAII TRIBUNE-HERALD) 07 Aug 2015: PESTICIDES: European retailers yank Roundup from shelves. (GREENWIRE) 15 Jul 2015: Weedkiller suspected of causing cancer deemed 'safe'; A multi-billion dollar weedkiller used in British farms, parks and gardens has been linked to cancer by the WHO, but its European license could still be reapproved. (THE GUARDIAN) In an independent study, the BfR found "very limited evidence of carcinogenicity" in mice exposed to glyphosate. The agency stated that the acceptable daily intake of the substance was between 0.3 to 0.5 mg per kilogram of body weight per day. BfR has also recommended the re approval of glyphosate. 14 Jul 2015: Monsanto says panel to review WHO finding on cancer link to herbicide. (REUTERS HEALTH MEDICAL NEWS) 15 Jun 2015: France Bans 'Probably Carcinogenic' Monsanto Herbicide for Home Gardeners. (RIA Novosti) 15 May 2015: Colombia gov't confirms suspension of aerial coca spraying. (Reuters) 29 Apr 2015: HERBICIDE: CAMPAIGNERS SEEK BAN ON GLYPHOSATE IN LATIN AMERICA. (IPS - INTER PRESS SERVICE) 24 Mar 2015: Monsanto seeks retraction for report linking herbicide to cancer. (REUTERS HEALTH MEDICAL NEWS) 20 Mar 2015: Monsanto Disagrees with IARC Classification for Glyphosate. (Monsanto website) 20 Mar 2015: Health Agency Says Widely Used Herbicide Likely Carcinogenic. (Wall Street Journal) 20 Mar 2015: IARC Monographs Volume 112: Evaluation of Five Organophosphate Insecticides and Herbicides. (World Health Organization - International Agency for Research on Cancer) Source: 16 May 2016_UPI GM Cotton Banned in Burkina Faso Due to Short Fiber Length Burkina Faso announced that it would phase out Monsanto's genetically modified cotton by 2018 because the length of cotton fibers it produced were too short. The national cotton farmers' union, along with three cotton companies, filed a XOF 48 billion (USD 82 million) compensation claim against Monsanto for lost harvest. Monsanto stated that it was engaged in discussions with cotton producers in Burkina Faso. UPDATES: 22 Apr 2016: Monsanto GM cotton banned by top African producer. (DAILY NEWS (BOWLING GREEN, KENTUCKY)) Source: 22 Apr 2016_DAILY NEWS (BOWLING GREEN, KENTUCKY) CCI Investigation into Allegedly Unreasonable Royalties for GM Cotton Seeds in India In February 2016, the Competition Commission of India (CCI) announced that it launched an investigation into the suspected abuse of dominant market position of Mahyco Monsanto, a joint venture between Monsanto and Mahyco. The probe was prompted by a complaint filed by India's Ministry of Agriculture, on behalf of local farmers and their organizations, of unreasonably high royalties charged by the company for its genetically modified (GM) cotton seeds. The company allegedly overpriced its products, utilizing its position as supplier of GM seeds used in more than 90 percent of cotton cultivation in India. UPDATES: 21 Apr 2016: HC allows T to fix trait value of BT seeds. (TIMES OF INDIA (ELECTRONIC EDITION)) 12 Apr 2016: Won't allow firms such as Monsanto to exploit farmers: Radha Mohan Singh, Agriculture Minister. (THE ECONOMIC TIMES) 10 Mar 2016: Royalties paid to Mosanto cut by 70 pc. (BUREAUCRACY TODAY) 04 Mar 2016: Monsanto threatens to exit India over GM royalty row. (The Times of India) MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 45 OF 48 EX P-3581 Page 45 of 48 SVEC OLDMONS0570549 MONSANTO COMPANY (MON) ESG RATING g Date: April 2016 Assessment: Moderate Status: Ongoing Date: March 2016 Assessment: Moderate Status: Ongoing Date: March 2016 Assessment: Moderate Status: Ongoing Date: February 2016 Assessment: Moderate Status: Ongoing Minor Controversies Date: March 2016 Assessment: Minor Status: Ongoing 17 Feb 2016: Competition Commission of India suspects Monsanto abused dominant position. (The Times of India) Source: 21 Apr 2016_TIMES OF INDIA (ELECTRONIC EDITION) Personal Injury Claims Related to PCBs Monsanto, its former parent Pharmacia LLC, and the latter's former subsidiary, Solutia Inc. have been involved in numerous personal injury lawsuits filed on behalf of approximately 750 individuals in state courts in St. Louis, Missouri and Los Angeles, California. The plaintiffs claimed to have developed non-Hodgkin lymphoma due to exposure to polychlorinated biphenyls (PCB) manufactured by Monsanto from the 1930's to 1970's. The complainants claimed that the company's production of PCBs for decades resulted in high levels of air and water PCB contamination in areas surrounding the facilities that manufactured the chemical. Monsanto stopped manufacturing PCBs in 1977. As declared under Monsanto's indemnity agreements with Pharmacia (now a Pfizer subsidiary) in 2000 and Solutia (now an Eastman Chemical subsidiary) in 2008, it has assumed the defense of the personal injury claims. UPDATES: 05 Apr 2016: Company cleared after accusations of causing disease from PCB exposure. (CITY NEWS SERVICE) 01 Apr 2016: United States Courts Opinions: United States District Court Eastern District of Missouri: Case: 4:15-cv-00844-AGF. (US OFFICIAL NEWS) [accessed on Mar 7 2016]: Newsroom. (Monsanto website) As of March 2016, litigation on the PCB-related claims was ongoing. 09 Dec 2015: MONSANTO: School Board File Suit Over PCB Cleanup. (CLASS ACTION REPORTER) A St. Louis school joined the mounting claims against Monsanto for alleged PCB contamination. 02 Jul 2015: Plaintiffs' attorneys ask for up to $70M in PCBs case. (MISSOURI LAWYERS MEDIA) 05 Jun 2015: Residents from 7 states allege Monsanto chemical led to cancer. (ST. LOUIS BUSINESS JOURNAL) 02 Jul 2015: MONSANTO CO: Two Mass. Towns Lose in 1st Round of PCB Litigation. (CLASS ACTION REPORTER) 31 May 2015: 10-Q. 2015. (Monsanto) Litigation on the personal injury lawsuits was ongoing. Source: 05 Apr 2016_CITY NEWS SERVICE; 2013/ll/30_Monsanto 10-Q Report; 2013/07/0l_St. Clair County Circuit Clerk EPA Investigation into Human Health Effects of Herbicides In March 2016, the EPA's Office of Inspector General announced that it would launch an investigation into the spread of superweeds and the human health impacts of the herbicides used for weed control. Among the chemicals which will be examined is glyphosate, the active ingredient of Monsanto's Roundup, whose excessive use in farms allegedly triggered the emergence of superweeds. UPDATES: 28 Mar 2016: EPA Watchdog to Investigate Monsanto GMOs and Superweeds. (Environmental Working Group) Source: 28 Mar 2016_Environmental Working Group Monsanto Guilty of Chemical Poisoning In February 2012, a court in Lyon, France issued a guilty verdict against Monsanto for allegedly poisoning a French farmer. The plaintiff claimed that he had developed neurological problems after his exposure to the company's herbicide product. Lasso. The complainant also alleged that consumers were not fully informed of the dangers due to inadequate warnings on product labeling. Lasso had been banned in France since 2007. The company has declared that it will appeal the ruling UPDATES: 07 Mar 2016: no new information available. 10 Sep 2015: French court confirms Monsanto guilty of chemical poisoning. (Reuters) A French court upheld the 2012 ruling on the chemical poisoning lawsuit against Monsanto. 11 Feb 2014: Charente "out of the question to stop" its fight against Monsanto. (Sudouest) As of January 2014, the appeal proceedings were ongoing. Source: 10 Sep 2015_Reuters; 2012/2/13_Reuters; 2012/2/14_BBC News Inacta: Complaint by Argentinian Farmers over Royalties Allegedly Sought for Cultivation of Second Generation Seeds In February 2016, the Argentine Rural Society (SRA), a local organization representing medium to large scale farmers, filed a complaint against Monsanto before the Argentina's National Commission for the Defense of Competition. The SRA alleged that Monsanto abused its dominant position in the market by seeking compensation from farmers to plant second-generation seeds produced from its genetically modified (GM) soybean, Inacta. The SRA claimed that under local law farmers were only required to pay for the Monsanto technology at the initial purchase of the GM seeds. UPDATES: 12 Feb 2016: Argentine farmers take Monsanto seed complaint to regulators. (Reuters) Source: 12 Feb 2016 Reuters Purported Class Action over Alleged False Advertisement of Glyphosate-Containing Product UPDATES: 23 Mar 2016:: No new information available. 27 Aug 2015: MONSANTO CO: Removes "Mirzaie" Suit to California District Court. (CLASS ACTION REPORTER) MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 46 OF 48 EX P-3581 Page 46 of 48 SVEC OLDMONS0570550 MONSANTO COMPANY (MON) ESG RATING g 06 Jul 2015: MONSANTO CO: Faces False Advertising Class Action in California. (CLASS ACTION REPORTER) Source: 27 Aug 2015_CLASS ACTION REPORTER; 06 Jul 2015_CLASS ACTION REPORTER GOVERNANCE CONTROVERSIES Moderate Controversies Date: February 2016 Assessment: Moderate Status: Concluded Date: July 2015 Assessment: Moderate Status: Concluded USD 80 Million Settlement over Alleged Accounting Violations Related to Roundup Rebates In February 2016, the Securities and Exchange Commission (SEC) announced that Monsanto agreed to pay USD 80 million in penalties to settle charges of its alleged violation of accounting rules and misstatement of its earnings for its product, Roundup. An SEC investigation revealed that the company had insufficient internal controls to account for millions of dollars in rebates it offered to Roundup distributors and retailers. The rebates were a component of a promotion Monsanto implemented after the sales of a generic version of its product undercut its business in 2009. According to the agency, Monsanto booked substantial revenue from the scheme from 2009 to 2011 but failed to recognize the accompanying costs, which resulted in its misstatement of consolidated earnings over a three-year period. UPDATES: 09 Feb 2016: Monsanto Paying $80 Million Penalty for Accounting Violations. (US Securities and Exchange Commission) Source: 09 Feb 2016_US Securities and Exchange Commission Monsanto Challenges Moratorium on Cultivation of GMO Crops in Maui Hawaii In November 2014, a moratorium on the planting and cultivation of genetically modified (GM) crops in Maui County in Flawaii was approved through local referendum. GM manufacturers Monsanto and Dow Chemical opposed the ordinance and subsequently filed a lawsuit against the local government to challenge the decision. In June 2015, a Maui District Court judge struck down the GMO ban. UPDATES: 01 Jul 2015: BIOTECH: Judge tosses Maui's GMO ban. (GREENWIRE) A district court judge nullified Maui County's ban on GMO cultivation, saying that the county does not have authority to enforce such an ordinance. Representatives from the local government declared that the county will abide by the ruling. Meanwhile, members of anti-GMO advocacy groups have declared the intention to appeal the court's decision. 16 Jun 2015: Maui GMO case judge focuses on county authority to regulate. (ASSOCIATED PRESS FINANCIAL WIRE) 10 Mar 2015: Federal judge considers delaying Maui GMO ban hearings. (ASSOCIATED PRESS FINANCIAL WIRE) 16 Dec 2014: Maui group wins ability to intervene in GMO case. (Associated Press State & Local) 18 Nov 2014: Washington: Monsanto, Dow Chemical File Lawsuit to Destroy Maui County's GMO Ban. (US Official News) Source: oiJul 2015 greenwire MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 47 OF 48 EX P-3581 Page 47 of 48 SVEC OLDMONS0570551 MONSANTO COMPANY (MON) ESG RATING g Corporate Governance Details Included in this section is the MSCI ESG GovernanceMetrics report, providing in-depth corporate governance data and analysis SECTION CONTENTS COMPONENTS DIRECTOR VOTES SHAREHOLDER/MANAGEMENT PROPOSALS RELATED PARTY TRANSACTIONS GOVERNANCE STANDARDS DIRECTOR BIOGRAPHIES MSCI MSCI ESG RESEARCH INC. 2016 MSCI INC. ALL RIGHTS RESERVED. ESG RATINGS REPORT | PAGE 48 OF 48 EX P-3581 Page 48 of 48 SVEC OLDMONS0570552