Document 829Oxx1qm5qMdr4pGBjx32JaB

Monsanto Co. Industry: Chemicals Domicile: United States Marketcap.: 37,729 mm. USD Ticker: NYSE:MON SUSTAINALYTICS CONTROVERSY REPORT Updated: Employees: 08 July 2016 22,500 Controversy Summary Qualitative Performance - Controversies Highest Controversy Level Society & Community Incidents Social Impact of Products Low Product & Service Incidents Environmental Impact of Products Employee Incidents Health and Safety Customer Incidents Marketing Practices Public Policy Incidents Moderate Operations Incidents Emissions, Effluents and Waste Social Supply Chain Incidents Social - Supply Chain Customer Incidents Anti-Competitive Practices Significant Business Ethics Incidents Intellectual Property High Society & Community Incidents Social Impact of Products Severe Incidents Headquarters Distribution of Controversy Assessments Operations Incidents Environmental Supply Chain Incidents Product & Service Incidents Employee Incidents Social Supply Chain Incidents d** d3 d j- a d if if if & if Customer Incidents if if if if if Society & Community Incidents f' 3.AA3Aa? >d 3 Business Ethics Incidents / ^ J if if if if if Governance Incidents A A A <v> * d? 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Jp d if if if if if Public Policy Incidents i -v /v 3 > 3 J? d^ ^ P if if if if >>3 > 3 if if if if /V 3 > 3 Company Controversy Level Industry Controversy Level J' d? d? y^ if <f if if if >>3 > 3 if if if if 1 | 28 EX P-3584 Page 1 of 28 SVEC OLDMONS0570440 Controversies Environment - Qualitative Performance Operations Incidents Category 2 - Moderate Emissions, Effluents and Waste Environmental Supply Chain incidents No evidence of relevant controversies Product & Service Incidents Social - Qualitative Performance Employee Incidents Category 1 - Low Environmental Impact of Products Category 1 - Low Health and Safety Social Supply Chain Incidents Category 2 - Moderate Social - Supply Chain Customer Incidents Category 2 - Moderate Anti-Competitive Practices Marketing Practices Quality and Safety Society & Community Incidents Category 4-High Community Relations Social Impact of Products Weapons Governance - Qualitative Performance 0ut|ook Negat'Ve Business Ethics Incidents Governance Incidents Category 3-Significant Business Ethics Intellectual Property No evidence of relevant controversies / outlook \" | ) Positive Public Policy incidents Category 1 - Low Lobbying and Public Policy SUSTAINALYTICS 2 | 28 EX P-3584 Page 2 of 28 SVEC OLDMONS0570441 Environment Controversies Operations Incidents Category 2 Moderate Related Events Emissions, Effluents and Waste Conservation and Land Use None Energy Use and GHG Emissions None Water Use None Overall Controversy Level Based on our event level assessment of impact and risk as moderate, the company has been assigned an overall controversy assessment of category 2. Emissions, Effluents and Waste Category 2 ^ Moderate Locations: Montana, United States, United Kingdom r Tags: Discharges and Releases (Water), Emissions to Air, " Degradation & Contamination (Land) Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Water Pollution KPVI News -17 June 2012 Monsanto established the Upper Blackfoot River Initiative for Conservation together with JR Simplot Company, Agrium/Nu-West Industries, Idaho Conservation League and Trout Unlimited to improve the water quality in the Blackfoot River in Montana. Monsanto has previously been involved in water pollution charges, in which P4 Production LLC, a company wholly-owned by Monsanto, agreed to pay a USD 1.4 million civil penalty for alleged Clean Water Act violations at its South Rasmussen Mine by discharging selenium and heavy metal. Wales contamination clean-up payment The Guardian -14 July 2015 Monsanto, BP and Veolia agreed to pay for the contamination of the Welsh Brofiscin quarry with Agent Orange derivatives, dioxins and PCBs. The clean-up was completed by the Environment Agency in Wales in 2012. The clean-up targeted leakages from the containers with toxic waste that Veolia as the contractor of Monsanto and BP deposited at the site in the 1960s-1970s and which posed significant health risk for the neighboring communities. The clean-up cost the Environment Agency paid were around GBP 1.25m (USD 1.95m), but the amounts each company agreed to pay were not disclosed. Fine for failure to report toxic releases NBCNews.com - 26 March 2015 The Soda Springs facility, operated by P4 Production, a wholly-owned Monsanto subsidiary, has agreed to pay a USD 600.000 fine to the U.S. Environmental Protection Agency {ERA) for failing to report uncontrolled toxic chemicals releases. Officials stated that the company omitted to report emitting hydrogen cyanide, sulfur dioxide, nitrogen oxides and mercury between 2006-2009, despite the fact that the companies are required by law to report all such releases. ^ ^ SUSTAINALYTICS 3 | 28 EX P-3584 Page 3 of 28 SVEC OLDMONS0570442 Product & Service Incidents Category 1 Low Related Events Environmental impact of Products Overall Controversy Level o o Based on our event level assessment of impact and risk as low, the company has been assigned an overall controversy assessment of category 1. Environmental Impact of Products Category 1 Low Locations: Mexico, United States, Yucatan, Mexico, Mexico City, Federal District, Mexico Tags: Environmental impact of products Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: Injuction granted for GM soy seeds International Business Times - 05 November 2015 Mexico's Supreme Court granted an injunction against the country's agriculture ministry who had given the approval for the use of GM soy seeds in Mexican states of Campeche and Yucatan. The court argued that the ministry approval violated the rights of local indigenous communities, which were not consulted before the approval. The use of GM soy seeds will remain blocked until the affected communities will be consulted. Monsanto is one among the list of interested parties in the case. Update: Mexico ban on GM corn GMWatch - 05 December 2014 The Mexican Chapter of the Permanent Peoples' Tribunal, a human rights international opinion tribunal independent of state authorities, has demanded the Mexican government to prohibit the planting of GM maize in the country. The possible prohibition could affect several companies which have submitted applications to plant GM maize since 2012, including Monsanto. However, recent Mexican authorities' decisions seem to support the interests of the companies by filing legal claims against the suspension of GM crops. Update: Ban on GM soybeans cultivation La Opinion Diario - 30 July 2014 A Yucatan judge ruled to nullify permits originally given to Monsanto to plant genetically modified (GM) soybeans in the Yucatan state. The judgement came in respect of the right of "self-determination" for indigenous communities who had voiced their discontent with the authorisation of the permits, and the alleged threats of the GM soy to their honey production. The ruling followed a similar judgement in March 2014 in the region of Campeche, banning GM soybean from being planted in the state. Mexico ban on Monsanto's GM corn care2 -16 October 2013 According to the Environmental Food and Justice, the District Court for Civil Matters of Mexico City gave its final approval to a law that will prohibit the cultivation of any variety of genetically modified corn, due to alleged hazards to the environment. As a consequence, Monsanto's genetically modified seeds can no longer be sold and cultivated in Mexico. Monsanto appealed the decision and requested that the judge be removed from the court on grounds of having stated his opinion on the case before the sentence was pronounced. SUSTAINALYTICS 4 | 28 EX P-3584 Page 4 of 28 SVEC OLDMONS057Q443 Impact OOOOOOOOOO Risk OOOOOOOOOO Monarch butterfly biodiversity loss linked to Roundup Russia Today -10 February 2015 A statistics released by the U.S. Fish and Wildlife Service revealed that 90% of the population of monarch butterflies has vanished across the U.S. since the 1990s, as result of the forced eradication of milkweed plants. The study correlated the resulting biodiversity loss with the over-usage of Roundup herbicides. Roundup was introduced in the 1970s and is sold to farmers and homeowners as an effective method for eliminating broad-leaf weeds. SUSTAINALYTICS 5 | 28 EX P-3584 Page 5 of 28 SVEC OLDMONS0570444 Social Controversies Employee Incidents Category 1 Low Related Events Health and Safety Basic Labour Standards None Child Labour None Forced Labour None Labour Relations None Overall Controversy Level Based on our event level assessment of impact and risk as low, the company has been assigned an overall controversy assessment of category 1. Health and Safety Category 1 Low s*.Locations: Brazilia - Tags: Health and Safety j' Impact OOOOOOOOOO Risk OOOOOOOOOO Fine for lack of proper safety measures Reuters -18 May 2015 After a Brazilian safety inspector found four workers handling pesticide containers without proper safety measures, Brazilian authorities stated they would seek to impose a fine of USD 16.6 million on Inpev, an industry group established by producers to meet disposal rules, as well as on several manufacturers, including BASF, DuPont, Monsanto, Nufarm, Syngenta, Adama, FMC, and Nortox, for potentially exposing workers to toxic agricultural chemicals. According to Brazilian law, both producers and buyers are required to ensure proper mechanisms for the safe disposal of chemical containers. Social Supply Chain Incidents Category 2 Moderate Related Events Social - Supply Chain Overall Controversy Level Based on our event level assessment of impact and risk as moderate, the company has been assigned an overall controversy assessment of category 2. SUSTAINALYTICS 6 | 28 EX P-3584 Page 6 of 28 SVEC OLDMONS0570445 Social - Supply Chain Category 2 Moderate Locations: India Tags: Child Labour Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Customer Incidents Update: Child labour on Indian vegetables seeds farms India Committee of the Netherlands - 24 November 2015 A new report published by a Dutch NGO revealed that multi-national companies, including Monsanto and its partners, Mahyco (25% owned by Monsanto), and Seminis (wholly owned by Monsanto), sourced vegetables seeds from Indian farms associated with child labour and labour rights violations. According to the research, children under 14 accounted for about 16% of the total workforce on hybrid vegetables seeds production farms in India. The report, based on interviews with children and workers from 235 vegetables seeds farms in 20 villages of Karnataka and Maharashatra, also alleged poor labour conditions and wages below the minimum living wage. The percentage of child labourers on Monsanto's Seminis, Bayers's Nunhems and Syngenta's farms together was less than 2.5 in Karnataka and less than 2% in Maharashatra. The report acknowledged Monsanto's efforts in reducing child labour in its farms but urged all companies to further improve their practices. Child labour on Indian cotton farms India Committee of the Netherlands - 23 July 2015 A report published by a Dutch NGO revealed that multi-national companies, including Monsanto and its cottonseed partner Mahyco (25% owned by Monsanto), sourced cotton from Indian farms associated with child labour and labour rights violations. Hybrid cotton seeds production is said to have the highest number of child labourers among all industries in India. According to the research, children under 14 accounted for about 25% of the total workforce on cottonseed farms in India. The report, based on interviews with children and cotton workers from 396 cottonseed farms in 72 villages of six Indian states, also alleged poor labour conditions and wages below the minimum living wage. Mahyco and Monsanto work with a total of 84 farms in the area and the percentage of child labourers on Monsanto's and Bayer's farms together was less than 2%. The report acknowledged Monsanto's efforts in reducing child labour in its farms but urged all companies to further improve their practices. Category 2 Moderate Related Events o o Anti-Competitive Practices Quality and Safety Marketing Practices Privacy None Overall Controversy Level Based on our event level assessment of impact and risk as moderate, the company has been assigned an overall controversy assessment of category 2. SUSTAINALYTICS 7 | 28 EX P-3584 Page 7 of 28 SVEC OLDMONS0570446 Anti-Competitive Practices Category 2 Moderate Locations: India, Brazil Tags: Anti-competitive Practices Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO T Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: Three more Indian companies file complaints alleging anti-competitive practices Hindustan Times -16 June 2016 India-based companies Kaveri Seeds, Ankur Seeds and Ajeet Seeds filed three more complaints with the Competition Commission of India alleging that Mahyco Monsanto Biotech (a 50:50 joint venture between Maharashtra Hybrid Seeds Company and Monsanto) abused its dominant position on the Bt cotton market. The CCI will investigate the companies' claims as part of the probe it launched in February following a complaint from the agriculture ministry. Update: Indian government cuts cotton seed royalties Bloomberg -10 March 2016 Following a dispute over licensing fees between the Indian government and Monsanto, the agriculture ministry capped the company's cotton seed royalties at INR 49 {USD 0.73) per 450-gram pack of Bt cotton seeds, a reduction of 70 percent compared to the previous margin. Monsanto had previously stated that it would consider withdrawing from the Indian market if the government made significant cuts to its seed royalties. The company did not release a statement following the ministry's decision. Investigation into anti-competitive seed pricing allegations Reuters -17 February 2016 India's antitrust regulator has opened an investigation into the alleged anti-competitive practices of Mahyco Monsanto Biotech (MMB), a local joint venture between Monsanto (50% ownership) and Mahyco Seeds. Local farmers and associations claim that Monsanto used its dominant position in the Indian market to set unreasonably high prices for its GM cotton seeds, which were introduced in India in 2002. Aside from selling the seeds directly, MMB also licensed its pesticide-producing gene to a number of local producers at a cost. Thus, MMB reportedly controls 90% of the cotton seed market. MMB stated that it intends to cooperate fully with the investigation and is confident that the allegations will be dismissed. Legal action against high royalties Economic Times -15 October 2015 Nine out of 25 (36%) Indian hybrid seed producers, under the National Seed Association of India (NSAI), sought the intervention of the Agriculture Ministry to urge the Competition Commission of India (CCI) to take measures against Monsanto's dominant market position. They argue that Monsanto is using its dominant position to charge high royalties far above the limits prescribed by various state governments. The seed producers are seeking adequate compensation. Restrictive Agreements Bloomberg - 09 December 2013 In October 2013, a Brazilian judge blocked Monsanto's demands that farmers sign a restrictive agreement as a precondition to buying Roundup-ready soybeans (Intacta RR2). The judge opined that Monsanto was taking advantage of its favorable position in the market as the only technology provider of Intacta RR2, to force farmers "to comply with clauses that are burdensome, if not illegal". In addition, the judge said that Monsanto's agreement may contravene Brazilian consumer law. SUSTAINALYTICS 8 | 28 EX P-3584 Page 8 of 28 SVEC OLDMONS057Q447 Quality and Safety Category 2 Moderate Locations: France Tags: Product Quality and Safety Impact OOOOOOOOOO Risk OOOOOOOOOO Marketing Practices Category 1 Low French farmer intoxicated with Lasso weedkiller Reuters -11 September 2015 A French court confirmed a 2012 ruling in which Monsanto was held accountable for the intoxication of a farmer who inhaled the company's Lasso weedkiller. The farmer claimed he suffered from neurological problems following the incident, and blamed Monsanto for failing to include proper warnings on the label. The court ordered the company to fully compensate the farmer. Lasso is an herbicide used since the 1960s, which was banned in France in 2007 and previously in Canada Belgium and Britain, due to links to a range of health problems. Locations: South Africa, Brazil Tags: False or Deceptive Marketing impact OOOOOOOOOO Risk OOOOOOOOOO Withdrawal of GMO advert in South Africa allAfrica-19 March 2014 The Advertising Standards Authority (ASA) of South Africa ordered Monsanto to withdraw a radio advertisement as the company's claims regarding the benefits of GM crops were "unsubstantiated and misleading." According to ASA, the South African advertising law requires that claims are confirmed by independent and credible experts. Nevertheless, Monsanto was only able to provide the authority with links to company documents available on its website. impact OOOOOOOOOO Risk OOOOOOOOOO Controversial Advertising Practices Agence France Presse - 22 August 2012 A Brazilian court fined Monsanto USD 250,000 for misleading advertising on genetically modified soy. The court ruling states that there was no scientific evidence for the company's advertising that genetically modified seeds benefited the environment. Society & Community Incidents Category 4 High Related Events Outlook Negative Social Impact of Products . -o Community Relations Weapons Complicity in Human Rights None Sanctions None Overall Controversy Level Based on our event level assessment of impact and risk as high, the company has been assigned an overall controversy assessment of category 4. .1 u SUSTAINALYTICS 9 | 28 EX P-3584 Page 9 of 28 SVEC OLDMONS0570448 Social Impact of Products Locations: United States, Missouri, USA, Missouri, India, France, Germany, Hartford, CT, USA, St Louis, MO, USA, California, USA, Colombia, Massachusetts, CA, USA, San Jose, CA, USA, Argentina, India, United States, Brussels, Belgium, Portland, OR, USA, St LOUIS, Seattle, VVA, USA, Oregon, USA, Sustainalytics' outlook for this controversy is Neutral for the next 12 months, because: The reputational risk poses ongoing concerns, since Monsanto faces significant opposition in many countries from the civil society, NGOs, government officials, and part of the scientific community, generating negative headlines in the international media. Monsanto has yet to demonstrate that it has adopted a strong approach regarding product stewardship challenges, as outlined in its policies and commitments. If it fails to do so, it risks being confronted with increased levels of resistance and stands to lose access to important markets. The fact that some lawsuits are still ongoing, poses continued financial risk for the company. Should courts rule in the plaintiffs' favour, the controversy level could be downgraded to a Category 5. Furthermore, the fact that the World Health Organization report from March 2015 listed glyphosate as a potential carcinogenic, lead to a re-evaluation in Europe in July 2016. The results are expected to be published in Q3 or Q4 2017. Dependent on the study results, a potential re-classification of the herbicide by regulatory agencies may occur. While several organisations, such as the European Food Standards Agency (EFSA), classified glyphosate as safe, a potential re-classification could lead to lower dosage limits in certain regions or even to temporary or permanent bans of the Roundup herbicide. Assessment Monsanto is involved in several controversies related to the potential health hazards posed by its two main product categories: glyphosate herbicides and genetically-modified (GM) seeds. In March 2015, the World Health Organization (WHO) classified glyphosate, Roundup's active substance, as potentially carcinogenic. The WHO's decision lends weight to previous studies which have linked glyphosate and Roundup to birth defects, endocrine disruption, damage to DNA, reproductive and developmental toxicity, neurotoxicity, and cancer. Following the WHO's report, several countries and chain stores banned glyphosate products. Other organisations, such as the European Food Standards Agency (EFSA), classified glyphosate as safe. Furthermore, several countries have either directly banned the company's products or the use of GMOs for human consumption. Additionally Monsanto faces legacy lawsuits related to its former production of Polychlorinated Biphenyls (PCBs). In 2016 and 2015, several US cities filed lawsuits against Monsanto accusing it of polluting the waters with PCBs. In 2016, three related plaintiffs were awarded USD 46.5 million damages. Monsanto produced 99% of all PCBs used in the US and according to some allegations, although the company was aware of the human health dangers, it disregarded them marketing PCBs were as safe until their ban in 1979. Sustainalytics assesses this controversy as a Category 4, due to the potentially severe risks posed by the company's products on human health. Monsanto's practices stand out in terms of their severity, broad stakeholder impact and recurrent nature indicating a structural inability to address related risks. The company's poor response and the societal backlash generated are exceptional within the industry, as are the reputational, regulatory, litigation and financial risks the company faces. The socio-environmental impact of Monsanto's product-related controversies is considered high, because: Scientific studies linked Roundup and GM Roundup resistant seeds to endocrine disruption, DNA damage, reproductive toxicity, neurotoxicity, and cancer in humans. Monsanto's products are banned in several countries due to health concerns. Genetic contamination is hard to contain due to cross-pollination and as such companies involved in genetic research are expected to demonstrate strong risk management. The impact on society of PCB contamination is severe. Scientific evidence established a link between PCB exposure and cancer in humans and evidence suggests the company was aware of the danger posed by PCBs, but chose to disregard it. Monsanto never recognized this connection, but admitted that all people have trace amounts of PCBs in their systems. The Missouri District Court of Appeals ruled that Monsanto can be held liable for PCB-related Non-Hodgkin's Lymphoma cases. While the nature events is not uncommon in the industry, the impact of Monsanto's products exceeds that of its peers. The company's reputational risk is high, because: SUSTAINALYTICS 10 | 28 EX P-3584 Page 10 of 28 SVEC OLDMONS0570449  Bans and protests related to GM products are not always directly targeted at Monsanto. However, glyphosate was invented and brought to the market by the company, who remains one of the main producers, therefore it can be held directly accountable. Moreover, international coverage of these events has been consistently high, including attention from prominent media sources. Criticism has ranged from moderate to severely critical. Product quality and safety constitute a key ESG issue for the industry and is of great importance to stakeholders. As such, negative publicity regarding product safety is difficult to overcome, and the trust of regulators, consumers and society may take years to repair. Monsanto has a poor historical track record in terms of company ethics, given previous allegations of disregarding scientific evidence in order to downplay the health risks posed by PCBs, as well as ongoing debates on glyphosate's carcinogenic effect. This undermines the credibility of the company's claims with respect to the safety of its products. Monsanto's management systems are considered moderate, because: The company has an adequate product stewardship programme, environmental and health and safety policies and programmes, and regulatory compliance programme. Monsanto states that it takes a precautionary approach, committing to "use sound and innovative science and thoughtful and effective stewardship to deliver high-quality products that are beneficial to our customers and to the environment". However, there is little disclosure regarding the actual implementation of these aspirational goals. Moreover, although the company states that it engages in community dialogue worldwide, there is no evidence of a formal community engagement programme. Social Impact of Products Incidents Incidents Timeline Highest of Impact or Risk o Main Incident Main Incident Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Update: European Commission proposes glyphosate extension St. Louis Public Radio - 28 June 2016 The European Commission proposed a 12 to 18 months' extension of the authorization for glyphosate, in order to give the European Chemicals Agency time to conduct a health assessment of the chemical. The proposal follows a failed vote by member state on whether to extend the license, which had also been postponed twice beforehand. Glyphosate's authorization was set to expire on 30 June 2016. Update: EU postpones vote on glyphosate renewal again Deutsche Welle -19 May 2016 The European Commission postponed for a second time the vote on whether to renew the license for glyphosate, the key ingredient in Monsanto's Roundup weed killer, due to conflicting scientific studies on its carcinogenic properties. France was opposed to the re-authorization and Germany said that it would abstain from the vote due to internal disagreements between parties. The European Glyphosate Task Force, which includes Monsanto, stated that it considered the situation "discriminatory, disproportionate and wholly unjustified". The sales license for glyphosate is due to run out on 30 June 2016. The new license would have been granted for another nine years. Update: Nebraska farmers file lawsuit against company alleging Roundup caused their ca Wisconsin Ag Connection -17 May 2016 Three farmers and an agronomist from Nebraska filed a lawsuit against Monsanto, alleging that the company purposely misled the public regarding the safety of glyphosate, the active ingredient in its Roundup weed killer. The suit also claimed that Monsanto concealed or systematically sought to discredit all research that revealed the chemical's carcinogenic properties. All four plaintiffs had been diagnosed with non-Hodgkin's lymphoma, which they believed was caused by exposure to glyphosate. The plaintiffs were seeking unspecified damages. The company did not comment on the lawsuit. SUSTAINALYTICS 11 | 28 EX P-3584 Page 11 of 28 SVEC OLDMONS0570450 Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: WHO study finds glyphosate unlikely to cause cancer through diet Deutsche Welle -17 May 2016 The UN's joint meeting on pesticides residues (JMPR) gave glyphosate, the active ingredient in Monsanto's Roundup weed killer brand, a clean bill of health. The decision followed a co-analysis by the UN's Food and Agriculture Organisation {FAO) and World Health Organisation (WHO) that determined that glyphosate was "unlikely to pose a carcinogenic risk to humans from exposure through the diet". The analysis reportedly analyzed quantities ingested strictly through diet, as opposed to a previous WHO study that found that glyphosate was a potential carcinogen by assessing high levels of exposure. EU member states were expected to vote on whether to re-license the chemical on 19 May 2016. Update: EU commission postpones vote on glyphosate license renewal Bloomberg - 08 March 2016 The European commission postponed the vote on whether to renew the license for glyphosate for the following 15 years. The decision came after France, Sweden, Italy and the Netherlands opposed the extension due to the World Health Organization's International Agency for Research on Cancer's classification of the chemical as a potential carcinogen, which Monsanto contested in court in the US. The commission would reportedly continue the discussion in another session on 18-19 May 2016 or earlier. Update: FDA to test glyphosate levels in foods Medlndia - 03 March 2016 The US Food and Drug Administration (FDA) stated that in 2016 it would begin testing for glyphosate residue in foods sold in the US. Soybeans, corn, milk, and eggs were reportedly among the foods that would be tested. The FDA's decision followed the United Nations' International Agency for Research on Cancer's labeling of glyphosate as a potential carcinogen and the development of new, more streamlined methods to test for the chemical. A Monsanto representative declared that the company is confident in the safety of its product. Update: Lawsuit against the state of California Western Farm Press - 21 January 2016 Monsanto filed a lawsuit against the California Office of Environmental Health Hazard Assessment and the agency's acting director, Lauren Zeise, seeking to prevent the listing of glyphosate, the main ingredient in its Roundup herbicide, as a known carcinogen. The regulator had planned to add the substance to the list following the World Health Organization's International Agency for Research on Cancer's classification of glyphosate as a probable human carcinogen. Monsanto disputed the agency's findings and its authority, argued that the listing and subsequent mandatory product labeling would violate its right to procedural due process and its First Amendment rights under California and US law. Update: EFSA and IARC to meet for clarification of discrepancies Reuters Africa -19 January 2016 EFSA Executive Director Bernhard Url responded to an open letter that urged the European Commission to disregard EFSA's findings regarding the safety of glyphosate. Url stated that he disagreed with the allegations of the authority's lack of openness and objectivity and that representatives of EFSA and IARC would meet in early 2016 to discuss the differences between the two organisations' findings. The meeting was said to take place in Brussels in mid-February. Update: EFSA and IARC classification debated in EU parliament 4 Traders -12 December 2015 On 1 December 2015, the European Parliament held a debate over the disagreement between the European Food Standards Agency (EFSA) and the World Health Organization (WHO) regarding glyphosate's carcinogenicity. Before the plenary session, 96 scientists from 25 countries had criticized EFSA's classification as "probably not carcinogenic" in an open letter addressed to the EU Health Commissioner. SUSTAINALYTICS 12 | 28 EX P-3584 Page 12 of 28 SVEC OLDMONS0570451 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO -> Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Update: EFSA found glyphosate unlikely to cause cancer in humans Reuters -12 November 2015 The European Food Safety Authority (EFSA), in collaboration with experts from EIJ countries, found that glyphosate is unlikely to cause cancer in humans, and proposed that a higher level of consumption should be deemed safe for humans. According to EFSA, the assessed evidence does not support lARC's classification of glyphosate as a potential carcinogenic. EFSA said that its assessment used more evidence and studies regarding glyphosate whereas IARC assessed groups of related chemicals. EFSA's glyphosate assessment will be one of the assessments used by the European Commission in its decision whether to renew existing approval for glyphosate use in the EIJ. Update: Glyphosate found in sterile and personal hygiene products Russia Today - 23 October 2015 A new study released by researchers from the Socio-Environmental Interaction Space (EMISA) of the University of La Plata in Argentina, found traces of glyphosate in 85% of the sterilized tampons, cotton and sanitary products tested. As such, concerns were raised regarding the safety of sterile and personal hygiene products, which are contaminated with a potentially carcinogenic substance. The main purpose of the research was to determine the chemical spread of glyphosate when aircraft-sprayed on a vast cropland areas. Update: AAP ends its partnership with Monsanto Huffington Post -19 October 2015 The American Academy of Pediatrics (AAP) decided to cease its corporate partnership with Monsanto by the end of 2015. The AAP whose mission is to work towards attaining the well-being of young people, reached its decision after Monsanto was criticized over the potentially severe health impacts posed by its glyphosate-based products. Update: Glyphosate to be listed as a carcinogen in California chemistry world -11 September 2015 The Californian Office of Environment Health Hazard Assessment (OEHHA) initiated a notice of intent to list glyphosate as carcinogen. California is the first US state which announced it will label and list glyphosate as carcinogen under the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). The Proposition demands that chemicals found to cause cancer, birth defects and other reproductive problems be listed as such. Update: France bans the sale of glyphosate from garden centers The Independent -15 June 2015 Due to the classification of glyphosphate, an ingredient in Monsanto's Roundup, as "probably carcinogenic to humans" by the UN's International Agency for Research on Cancer (IARC), the French Ecology Minister asked garden centers to stop selling Roundup from self-service aisles. Update: Coop and Migros chains stopped selling glyphosate products Fresh Plaza - 04 June 2015 Swiss biggest supermarket chains, Coop and Migros, will stop selling products that contain glyphosate. Their decision followed German giant retailer REWE Group's decision. The retailers, who sell a dilluted, ready-to-use herbicide to hobby gardeners, stated that this is a preventive measure. Update: Sri Lanka bans glyphosate imports Examiner.com - 24 May 2015 Sri Lanka's president and government approved a ban on the import of glyphosate, due to alleged hazards to the environment and human health. The decision followed the recent World Health Organization announcement that glyphosate is potentially carcinogenic, and two scientific studies by local researchers which showed that high concentrations in drinking water and direct exposure to glyphosate through spraying, increased the risk of deadly chronic kidney disease (CKDu). In Sri Lanka, CKDu affects 400,000 people with an estimated death toll of around 20,000 per year. SUSTAINALYTICS 13 | 28 EX P-3584 Page 13 of 28 SVEC OLDMONS0570452 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO -> Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: German stores ban glyphosate products PrisonPlanet -12 May 2015 More than 350 Toom Baumarkt DIY stores belonging to the REWE Group, one of the biggest in Germany, will no longer commercialize giyphosate-containing products as of 30 September 2015, Baumarkt stores began removing products that contain the endocrine disrupting herbicide in 2013. Update: Columbia to propose a ban of glyphosate use for coca fumigation Morningstar.com -12 May 2015 Columbia's Health Minister Alejandro Gaviria and the Prosecutor General stated that glyphosate, RoundUp's active ingredient, should no longer be used to fumigate illicit coca crops, because of its potential health risks for neighboring communities. Glyphosate is used in Colombia to destroy coca cultures in order to reduce narco-trafficking, but the International Agency for Research on Cancer (IARC) classified glyphosate as a potential cancerigen. The officials stated they would propose a ban of glyphosate in the next meeting of the National Council of Narcotics. Update: Roundup lawsuit Global Research - 23 April 2015 Three individuals filed a class action lawsuit against Monsanto claiming injunction and false and misleading advertising of Roundup as safe for humans.The plaintiffs alleged that glyphosate, the active ingredient in Roundup, kills gut bacteria important for human and animal digestion, metabolism, and vital immune system functions. The class action is ongoing and seeks to include anyone as a plaintiff who purchased Roundup or Roundup-related products. Update: WHO classifies glyphosate as a potential carcinogen Forbes - 21 March 2015 The World Health Organization (WHO), via the International Agency for Research on Cancer (IARC), has classified glyphosate, the active substance in Roundup, as a potential carcinogenic. The analysis reveals limited evidence to support a link to non-Hodgkin's lymphoma and lung cancer in humans and a convincing evidence of cancer in laboratory animals. The decision is based on exposure studies, mostly agricultural in the US, Canada, and Sweden published since 2001. Previously, in 1985, US Environmental Protection Agency (EPA) classified glyphosate as a potential carcinogenic to humans, but changed this classification in 1991 to non-carcinogenic, Monsanto considers the WHO's decision as inconclusive, stating that it draws upon old data. Update: Genetic and cellular damage of soybean workers Asian Journal - 27 January 2015 A study published in the Mutation Research journal has identified the presence of glyphosate in the cells of 81 workers tested at a soybean plant in Brasil who were working in the fields where Monsanto herbicides were used. According to the study, the toxins compromise soil health, food security, damage workers' DNA and human body cells. Update: Feeding tube liquid tested for glyphosate Toronto Sun -16 January 2015 Moms Across America initiated a testing process and collected samples for the identification of glyphosate in the feeding tube liquid from hospitals. The samples contained GM corn syrup, soy, and sugar considered to be sprayed with glyphosate during the growing season and at harvest as a drying agent. The researchers of MIT Computer Science and Artificial Intelligence Laboratory found the substance in amounts of up to 1100 times higher than normal and have deemed the liquid from feeding tube not safe. Update: Criticism related to herbicide Roundup Toronto Sun - 02 January 2015 The Monsanto herbicide Roundup was criticised in the Brazilian Journal of Microbiology. According to the study, the herbicide may contribute to the enhanced growth of the pathologic bacteria Pseudomonas Aeruginosa in the environment. The bacteria can cause dangerous infections and is resistant to antibiotics. SUSTAINALYTICS 14 | 28 EX P-3584 Page 14 of 28 SVEC OLDMONS0570453 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO @ Impact OOOOOOOOOO -> Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO Update: Genetically modified soy in infant formula Human Rights Watch - 23 October 2014 Testing coordinated between the U.S. Centre for Food Safety and the U.S. Environmental Protection Agency (ERA) scientists confirmed the presence of soy that had been genetically modified (GM) by Monsanto to survive high levels of chemical pesticide exposure, in infant formula sold in Oregon. The findings raised concerns about the exposure of infants to controversial chemical pesticides. Advocates for GM labeling cited the finding as rationale for labeling GMO products, which the company has fought against. Update: Roundup banned from sale to individuals in the Netherlands Sum of Us -16 October 2014 Following a decision by the Dutch Parliament, the sale of giyphosate-based herbicides to individuals was prohibited. The company's product, Roundup, is one such pesticide affected by the ban The prohibition was only in effect for non-agricultural use of the product, and as the ban was only on the selling of the product, its use is still allowed under EU regulations. Glyphosate has been linked to cancer, infertility, birth defects, nervous system damage, and kidney disease, as well as soil and water pollution. Update: Roundup linked to cancer Truth Out - 06 October 2014 An article highlighted numerous studies linking glyphosate, the main ingredient in Roundup, to increased incidents of cancer in areas where the herbicide is heavily sprayed. Studies were conducted in countries such as the US, Canada, Argentina, Australia and New Zealand, as well as places in Europe, and linked the herbicide to many types of cancer, including lung, breast, prostate, and brain cancer. Several studies also demonstrated that the herbicide may cause damage to human DNA. Update: Roundup 125 times more toxic than glyphosate Global Research And Data Services Industry -11 July 2014 A new study published in the journal Biomedical Research International revealed that agrochemicals, such as Monsanto's Roundup herbicide, are more toxic than regulators had previously revealed. The study claimed that initial tests tended to analyze isolated ingredients, such as glyphosate, and issued a toxicity assessment based on these individual tests. However, according to the report, if the Roundup herbicide is analyzed in their totality, its toxicity level may be 125 times higher than that of its active ingredient (i.e., glyphosate). Update: Seralini's paper republished Forbes - 25 June 2014 Environmental Sciences Europe agreed to republish the paper of French scientist Seralini and his colleagues claiming that Roundup resistant GMO crops gave lab rats cancer in a long-term feeding experiment. Furthermore, Seralini has won two court victories defending his work. The paper was retracted in November from FCT Journal do to inconclusiveness. Update: Glyphosate found in breast milk Greenpeace Canada - 27 May 2014 Two environmentalist groups, Moms Across America and Sustainable Pulse, conducted a pilot study according to which high levels of glyphosate herbicide were found in breast milk. The study further states glyphosate bio-accumulates in the human body, a finding so far refuted by regulatory authorities and biotech companies. The environmentalist groups are demanding a ban on the use of glyphosate in food crops. Update: Study links Roundup to Celiac disease BILD (DE) -01 April 2014 The Journal of Interdisciplinary Toxicology study linked Monsanto's Roundup herbicide to Celiac disease in humans. The study shows that approximately 5% from the population in North America and Western Europe suffers from the disease and postulated that fish exposed to glyphosate develop digestive problems that are similar to Celiac disease. Symptoms include diarrhea, skin rashes, depression, macrocytic anemia and nausea. SUSTAINALYTICS 15 | 28 EX P-3584 Page 15 of 28 SVEC OLDMONS0570454 Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: Roundup found in 75% test samples Greenpeace Canada -10 March 2014 The US Geological Survey revealed in a recent study called "Pesticides in Mississippi air and rain: A comparison between 19S5 and 2007" that in 2007, Monsanto's Roundup herbicide was the most commonly found chemical, being present in 75% of air and rain test samples. Previous research has linked diseases such as Parkinson or cancer with the Roundup herbicide. Moreover, in an Argentinian region, where the herbicide is regularly used, 80% of children struggle with a variety of health problems. Update: Research links Roundup to kidney disease Charleston Gazette - 27 February 2014 A report by the International Journal of Environmental Research and Public Health linked Monsanto's Roundup herbicide to chronic kidney diseases in humans. The report postulated that glyphosate, the active ingredient found in Roundup can become toxic when mixed with nephrotoxic metals and "hard water". This type of water exists either naturally in the soil or can be artificially created through fertilizer usage, and contains elements such as calcium, magnesium, strontium and iron. Update: Seraiini study dismissed Forbes - 30 November 2013 The editor of The Food and Chemical Toxicology, required French scientist Seraiini to withdraw his paper claiming that Roundup resistant GMO crops gave lab rats cancer. The request specifies that the article will be removed. Seraiini threatened to sue the journal and demand "financial compensation for the huge damage" to the CRIIGEN research group. Update: Roundup Studies and GM Bans Bloomberg - 25 September 2013 As of September 2013, Russia was considering a total ban on GM imports. The Russian government had temporarily suspended importing GM corn as a result of the latest GM studies on Roundup ready seeds toxicity on human health and environment. Previously, in November 2012, the government of Kenya banned all GM crops. Update: Seraiini Roundup Experiment Earth Open Source - 01 November 2012 A study led by Gilles-Eric Seraiini, a French scientist, claimed that Monsanto's RoundUp-tolerant NK603 genetically modified maize, affect the liver and kidney functions. The research was conducted on rats, who were fed GM seeds as well as glyphosate. The study advocates for longer and more elaborate toxicology tests; however, Monsanto, the biggest producer of GM seeds, claims its products are safe and have undergone extensive testing. The results of the study were criticized by parts of the scientific community as they were reportedly based on insufficient data. Concerns over Roundup and glyphosate toxicity Environmental Sciences - 01 June 2011 According to a report co-authored by several scientists and published by Earth Open Source, glyphosate, commercialized by Monsanto under the name Roundup, can cause birth defects as well as "endocrine disruption, damage to DNA, reproductive and developmental toxicity, neurotoxicity, and cancer" at amounts equivalent to residues found on produce. Glyphosate is widely used herbicide. The report concludes that the new generation of babies born near fields of Roundup Ready (RR) soy in Argentina suffer from an increased rate of birth defects. Update: St. Louis jury rules that company must pay damages for PCB exposure St Louis Business Journal - 26 May 2016 Three plaintiffs were awarded USD 17.5 million in damages and USD 29 million in punitive damages in a jury trial which alleged that the PCBs manufactured and released by Monsanto and three other companies caused them non-Hodgkin lymphoma. According to the suit, the companies had been aware of the dangers of the PCBs for decades and misled the public regarding their safety. Monsanto stated that the evidence did not support the verdict and that it intended to immediately appeal it. The same plaintiffs' claims had been rejected by four previous juries SUSTAINALYTICS 16 | 28 EX P-3584 Page 16 of 28 SVEC OLDMONS0570455 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO ->! Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Update: Long Beach files federal lawsuit for waterway contamination Long Beach Post - 20 May 2016 The City of Long Beach filed a federal lawsuit against Monsanto for polluting its storm water, port waters, and other bodies of water with the chemical PCB. The city claimed that Monsanto continued to produce PCBs after it knew the chemicals were dangerous to human health and is seeking compensation for the cleanup of the Port of Long Beach, Colorado Lagoon and Dominguez Watershed. Long Beach is also seeking punitive damages, as well as litigation costs and attorney's fees, and pre-judgment and post-judgment interest. The company did not comment on the suit. Update: Lawsuit for PCB contamination of Portland city's waterway Herald and News -16 March 2016 The City of Portland filed the seventh lawsuit against Monsanto for manufacturing and polluting its water with the chemical PCB. The city claims that Monsanto continued to produce PCBs long after it knew the chemicals were dangerous to human health and is seeking compensation for the cleanup of the Willamette River and the Columbia Slough, which cost more than USD 1 billion. The company stated that it was not responsible for the clean-up, as it had been focused on agriculture for the previous ten years and it had divested the company that produced and, implicitly, would be liable for the PCBs. Update: Lawsuit for PCB contamination of Seattle city's waterway Oregon Public Broadcasting - 26 January 2016 The City of Seattle filed the sixth lawsuit against Monsanto for manufacturing and polluting its water with the chemical PCB. The city claims that Monsanto continued to produce PCBs long after it knew the chemicals were dangerous to human health and is seeking compensation for the cleanup of its Duwamish Waterway. The company claimed that the third parties that purchased the PCBs and used them in their manufacturing processes were liable for the clean-up. Update: Lawsuit for PCB contamination of Berkeley city's stormwater CNBC - 06 January 2016 The City of Berkeley has filed the fifth PCB-related lawsuit against Monsanto for contaminating the city's stormwater and the San Francisco Bay. The city intends to hold the company responsible for the cost of cleaning up the PCB contamination, while also seeking compensatory and punitive damages for the presence of the chemical in the stormwater and in the bay. Monsanto denied the city's claims, stating that the third parties which purchased the chemical and used it in their products were responsible for properly disposing of the resulting waste. Update: Lawsuit for PCB's clean-up costs Harford courant - 23 October 2015 The Hartford city and school board of Clark Elementary School from Hartford filed a federal suit against Monsanto, and its spin offs Solutia and Pharmacia, alleging disregard for the safety of consumers and users of PCBs and PCB-containing products. They require full costs of clean-up and relocation expenses. The lawsuit followed an environmental testing which found PCB levels up to 1,940 times higher than the federal limit. Overall, the state Department of Energy and Environmental Protection has identified more than 100 school buildings in Connecticut that have reported PCB issues, including Clark school. Most of them were built between 1950 and 1979 in constructions, before PCBs were banned for being toxic. Update: Lawsuit for polluting Spokane river Reuters - 04 August 2015 Spokane, Washington, city attorneys claimed that Monsanto, the lead producer of PCBs in the U.S. from 1930s-1970s, is responsible for the Spokane river contamination with carcinogenic PCBs. The lawsuit claimed unspecified compensatory damages and requested that Monsanto take responsibility for the clean up costs. The city's utilities spokesperson stated that the clean up cost will exceed USD 100 million. Monsanto denied any liability and stated that the third parties which incorporated PCBs into their products should bear responsibility for clean up costs. SUSTAINALYTICS 17 | 28 EX P-3584 Page 17 of 28 SVEC OLDMONS0570456 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO 0 Risk OOOOOOOOOO @ Impact OOOOOOOOOO T Risk OOOOOOOOOO @ Update: Lawsuit for polluting San Francisco Bay with RGBs CNBC-09 July 2015 San Jose authorities filed a lawsuit against Monsanto for contaminating the San Francisco Bay with carcinogenic PCBs, which the company incorporated into a variety of products from the 1930s to 1970s. Even though PCBs were banned 30 years ago, the State Water Resources Control Board determined that their presence in stormwaters still threatens water, fish, marine life in the bay and the well-being of people in the state of California. The lawsuit also charges Monsanto with concealing nformation that demonstrated the toxicity of PCBs so that the company could continue to profit by their use. Update: Lawsuit for water pollution with carcinogenic PCBs in San Diego Sott.net -17 March 2015 San Diego City alleged that Monsanto is one of the contributors to the pollution of the bay with carcinogenic Polychlorinated Biphenyls (PCBs), which were primarily manufactured by Monsanto. Previously, in 2012, the city and the port were found guilty of polluting the bay with PCBs by the Regional Water Control Board. Fines were imposed on the shipbuilders BAE and NASSCO that used it in the manufacturing process. Even though PCBs were banned 30 years ago, they are still found in bay sediments, water, fish, and other marine life in the bay. Update: PCBs and Non-Hodgkin's Lymphoma RIA Novosti - 24 July 2013 The Missouri District Court of Appeals rejected Monsanto's claim that it cannot be held liable for causing Non-Flodgkin's Lymphoma in people who had been exposed to polychlorinated biphenyls (PCBs). Plaintiffs Ruth Nishida, Alison Tucker and Nicholas White are the first from around 600-700 plaintiffs with allegations of high PCB levels and Non-Hodgkin's Lymphoma against Monsanto. PCB related liabilities The Boston Globe - 04 September 2012 Local schools in Lexington, Massachusetts, filed a lawsuit in federal court against Monsanto and its divisions Pharmacia and Solutia, alleging that the companies failed to communicate the health and environmental risks of polychlorinated biphenyls (PCBs), despite allegedly being aware of the dangers. Reportedly, PCBs were used in the construction of schools from the 1950s until the 1970s. Scientific studies have shown that people exposed to PCBs are significantly more likely to develop Non-Hodgkin's Lymphoma. Monsanto produced most of the PCBs used in the USD under the names Aroclor and Santotherm, until they were phased out In 1977. EPA banned PCBs in the USD since 1979, stating that they cause cancer in animals are probably carcinogenic in humans. Update: EU Parliament opposes import of herbicide-resistant soybeans Greenpeace EU - 03 February 2016 The European parliament voted against the import of GM soybeans MON 87705xMON 89788 and MON 87708xMON89788, developed by Monsanto, and and FG72, developed by Bayer CropScience. Parliament members stated that the authorization would not be consistent with EU law, as only 13 out of 28 Member States voted in favour of allowing the import of the soybeans into the EU. The soybeans had been engineered to tolerate glyphosate, the pesticide that raised concerns when the World Health Organization classified it as a potential carcinogen. The Parliament's vote is not binding for the Commission, as the final decision regarding the seeds' authorization has not been taken. Update: More countries opt out of EU deal for GMOs Russia Today - 05 October 2015 As of October 2015, 19 EU states had filed requests to the European Commission to be excluded from the list of countries that cultivate and import genetically modified (GM) seeds in the European Union. The full opt-out was requested by Austria, Bulgaria, Croatia, Cyprus, Denmark, France, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, and Slovenia. Belgium and the UK required opt-out mechanisms on several of their territories, while Germany requested a partial opt-out. ^ ^ SUSTAINALYTICS 18 | 28 EX P-3584 Page 18 of 28 SVEC OLDMONS0570457 Impact OOOOOOOOOO @ Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO 0) Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO 0 Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Update: France decides to opt out of EU-wide deal for GMOs Reuters -17 September 2015 France filed a request to the European Commission to be excluded from the list of countries that cultivate and import genetically modified (GM) seeds in the European Union. The EU legislation allows its member states to individually decide whether to allow the import of GM food and animal feed. Monsanto's MON810 maize is the only GM product authorized for cultivation and human consumption in the EU. Around 60 other GM products have been cleared for import, mainly for cattle feed. Update: Latvia and Greece decide to opt out of EU-wide deal for GMOs Latvian Television - 28 August 2015 Latvia and Greece requested to be excluded from Monsanto's application to grow genetically modified (GM) crop across the European Union (EU). Under the new EU opt-out law, individual members of the European Union have the possibility of deciding on their own whether to accept or decline the use of GM food and animal feed in their countries. Monsanto's MON810 maize is the only GM product authorized for cultivation and human consumption in the EU. Update: GM field trial blocked in India Motley Fool Discussion Boards -12 May 2015 Eight Indian states currently allow field trials of GM crops including transgenic tests, but more than 20 states and territories have rejected open trials of genetically modified seeds. Between March and July 2014, the Genetic Engineering Appraisal Committee (GEAC), part of India's environment ministry, granted permission for 80 field-trial applications, but the permission was blocked until the government develops proper regulatory and safety mechanism. Also, the Supreme Court Technical Expert Committee recommended an indefinite moratorium on the field trials of GM crops. GMO bans BLOOMBERG News - 07 May 2014 The French Parliament gave its final approval to a law that will prohibit the cultivation of any variety of genetically modified (GM) corn, due to alleged hazards to the environment and human health. The company's product MON 810, will not be cultivated and sold anymore in France. It is worth noting that the product is the only GM crop allowed for cultivation in the European Union. Update: Turkey GMO Ban Bloomberg First Word -13 December 2013 The Turkish Council of State has cancelled the import of two of Monsanto's GM corn varieties (MON810 and MON810x88017),because of scientific uncertainty, following a lawsuit filed by the "No to GMO Platform". Greenpeace Turkey has allegedly requested that, in light of this ruling, all GMOs approved for import be re-evaluated and their approval revoked. Previously, in April 2013, Turkey's Biosecurity Board banned a total of 26 GMOs. scientific uncertainty. Update: GM field trial still baned Motley Fool Discussion Boards - 09 November 2015 Monsanto's and Mahyco's request for field trial of herbicide-tolerant crops in India continues to be blocked until the government develops proper regulatory and safety mechanism. Given the farmer organisations opposing to the GM trial the last time field trials were held was in 2011-12. GM Field Trial Ban in India Greenpeace - 04 July 2011 The government of the Indian state Karnataka decided to ban field trials of genetically modified (GM) crops. The decision came as a result of public opposition from farmers and civil society groups against GM field trials, prompted by allegations that Monsanto had violated the Genetic Engineering Approval Committee (GEAC) bio-safety regulations, while performing GM-corn trials in a farmer's field in Northern Karnataka. ^ ^ SUSTAINALYTICS 19 | 28 EX P-3584 Page 19 of 28 SVEC OLDMONS0570458 Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO @ Impact OOOOOOOOOO 0 Risk OOOOOOOOOO @ DDT linked to breast cancer PAN NORTH AMERICA - 09 July 2015 The Endocrine Society published a study in the Journal of Clinical Endocrinology & Metabolism linking dichlorodiphenyltrichloroethane (DDT), a pesticide previously commercialized by Monsanto, to breast cancer risk. The researchers found that risk of breast cancer is four time higher for daughters whose mothers were exposed to high levels of DDT during pregnancy in the 1960s. Monsanto produced DDT in the US along with 14 other companies. DDT has been banned in the US since 1972 due to classification as an endocrine disruptor. The International Agency for Research on Cancer classified DDT as "possibly carcinogenic to humans" (Group 2B). Concerns regarding new herbicide mix of acetochlor and fomesafen Times of India - 28 May 2015 The EPA approved Monsanto's Warrant herbicide, a mix of acetochlor and fomesafen, although the European Food Safety Authority (EFSA) found acetochlor highly toxic to all aquatic organisms and the US Environmental Protection Agency (EPA) labelled fomesafen as a potential human carcinogen. The herbicide is to be used on soy and cotton for the eradication of giyphosate-resistant weeds, even if no safety testing were done on the mixture of the two herbicides. Update: Third global march against Monsanto ABC Online-24 May 2015 Millions of activists, from more than 40 countries, marched against Monsanto and its controversial GMO and crop protection products. The main request of the protesters was a ban on giyphosate, an ingredient which was recently classified as potentially carcinogenic to humans by the World Health Organisation. The first global march against Monsanto took place in 2013 and has since become an annual event. Global march against Monsanto Toronto Sun - 24 May 2014 Millions of activists, from 400 cities and 52 different countries, participated in a global march against Monsanto. The activists called for a permanent boycott of GMOs, claiming that the company's GMO products pose threats to human health. Update: Settlement with seven states ABC -18 March 2015 Monsanto agreed to settle for USD 350 million the contamination issue with farmers from seven states. The cost associated with the case and donations of USD 50.000 to agricultural schools and grant colleges in the seven states will also be supported by the company. The seven states are: Kansas, Missouri, Illinois, Oklahoma, Texas, Louisiana and Mississippi. Additionally, Monsanto stated that the lawsuit involving farmers in Arkansas is still active. Update: Settlement with Pacific Northwest farmers ABC News -18 November 2014 The company agreed to a USD 2.1 million settlement with farmers in Washington, Oregon, and Idaho who had sold who soft white wheat between May and November of 2013, after the company's unapproved genetically modified wheat had been discovered in Oregon. The discovery had prompted Japan and South Korea to temporarily suspend some wheat orders, and the EU had asked for stricter testing. The company was also to pay USD 250,000 to wheat growers associations. Update: Unapproved GM wheat found in Montana Bloomberg - 26 September 2014 Genetically modified (GM) wheat that had never been approved for commercial sale was discovered in Montana, approximately ten years after field tests of the crop had occurred there. Regulators stated that they did not know how the crops escaped the field tests. The company reported the discovery of the crop to the U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service, and stated that it was cooperating fully with the investigation. The announcement came at the same time that the USDA closed the investigation regarding the GM wheat previously discovered in Oregon, stating that there was no evidence of the GM wheat in commerce. ^ ^ SUSTAINALYTICS 20 | 28 EX P-3584 Page 20 of 28 SVEC OLDMONS0570459 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Weapons Category 2 Moderate Update: GM-Wheat Contamination Lawsuit Reuters - 03 June 2013 From June until September 2013, wheat farmers sought class-action status from several U.S. states, including Washington, Idaho and Kansas, and sued Monsanto for alleged financial losses due to disruptions on the international wheat market, following the discovery of an unapproved strain of genetically modified wheat in an Oregon field, in May 2013. Monsanto is accused of failing to conduct due diligence to ensure the unapproved variety didn't contaminate regular wheat through cross-pollination or mixing of seeds GM-Wheat Contamination Bloomberg - 29 May 2013 Monsanto came under fire due to the fact that a strain of genetically modified wheat, which was not approved for use by the U.S. Department of Agriculture (USDA), was found in an Oregon field. According to the deputy administrator of USDA's Animals and Plant Health Inspection Service, exposure was limited and posed no threat to human health. However, a senior scientist at the Consumers Union in New York expressed his concern. Japan and South Korea temporarily suspended U.S. imports of western-white wheat and feed wheat, Taiwan asked for wheat to be labelled by state of origin, while the E.U. recommended that member states test all imported U.S. wheat. Update: Petition for Writ of Certiorari Amazon Watch -12 February 2014 Some objectors to the class action settlement regarding Monsanto's Agent Orange herbicide lawsuit filed a petition to review the case with the US Supreme Court. Their primary argument is that the settlement did not provide benefits for up to 62% of the property remediation class or to 94% of the medical monitoring class. Agent Orange liabilities Reuters - 24 February 2012 Monsanto settled a long-running legal battle with residents of Nitro, West Virginia, who suffered health problems due to dioxin pollution, a by-product of Agent Orange production at Monsanto's plant in Nitro between 1949 and 1971. The company committed to USD 93 million in clean-up, remediation and medical monitoring to resolve the series of class action lawsuits. Furthermore, it plans to install a fund of USD 21 million for medical testing, with up to USD 63 million in additional funding available. Monsanto and Dow Chemical were the main producers of Agent Orange in the U.S. Philippines' Bt-Eggplant Ban Greenpeace - 24 May 2012 The Philippines' Supreme Court banned field trials of Monsanto's Bt-eggplant, a genetically engineered variation of an indigenous eggplant species which produces its own insecticide. The product was found to allegedly violate "the constitutional rights of individuals to a healthy environment". In June 2013, The Philippines' Court of Appeals upheld the previous decision, ruling that all Bt-eggplant field trials must cease, existing plantings must be destroyed, and no further propagation allowed. ^ , Locations: Palestine r Tags: Controversial Weapons Impact OOOOOOOOOO Risk OOOOOOOOOO ^ ^ SUSTAINALYTICS . * s' Monsanto's white phosphorous linked to Gaza conflict Sputnik - 23 June 2015 An investigation carried out by the Current Events Inquiry blog revealed that Monsanto allegedly supplied the US government with white phosphorous used in the production of incendiary weapons. Reportedly, the activity had been going on for twenty years, with the company having full knowledge of the military use of its product. Weapons containing Monsanto produced white phosphorous were allegedly deployed during the 2008-2009 Gaza War, in which many civilians lost their lives. Although the Israeli government acknowledged that white phosphorous was used by the Israeli military during the conflict, there was no evidence linking the product to civilian victims. 21 | 28 EX P-3584 Page 21 of 28 SVEC OLDMONS0570460 Community Relations Category 2 Moderate Locations: Malvinas Argentinas, Buenos Aires Province, Argentina, Poland Tags: Conflicts with Local Communities Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO impact OOOOOOOOOO Risk OOOOOOOOOO Update: Community continues protests La Nacion - 09 October 2014 Construction of the company's facility in Argentina had been halted since September 2013, and members of the surrounding community continued to protest the establishment of the facility. Reportedly, Monsanto threatened protesters with criminal punishments, and, along with the government and a construction union, at times violently attempted to stop the demonstrations. According to a representative of the protesters, up to 60 people have been injured in the conflicts. Update: Project halted in Argentina BosinessJournals -12 February 2014 Monsanto's USD 192 million project related to the construction of a corn seed production plant has been halted because the Argentinian local authorities dismissed Monsanto's environmental-impact assessment. The company accepted the rejection and stated that it will try to align the project to the new environmental requirements. Protests against Monsanto plant in Argentina Terraamerica -18 September 2013 Monsanto's plan to build its biggest seed factory in Malvinas Argentinas, a poor community of 15.000 people is facing protests that started in September 2013. The construction was halted in October 2013 through legal action by protesters and local residents. The locals are worried about respiratory problems or allergic reactions that are caused by the spraying of transgenic soy with weed-killer glyphosate, one of the company's products. Medical specialists noticed a rise in cases of cancer and birth defects. Polish farmers protest against GMO crops Global Research - 27 February 2015 Polish farmers held protests in over 50 locations across the country to bring attention to the dangers of GMOs and the alleged land grabs by Monsanto and other GM seed producers. The farmers' ultimate aim is to ban GMOs production in Poland, demanding that legislators protect smallholder farmers from exploitation by monopolizing companies. This is considered one of the largest organized farmers' protests in the country. SUSTAINALYTICS 22 | 28 EX P-3584 Page 22 of 28 SVEC OLDMONS0570461 Governance Controversies Business Ethics Incidents Category 3 Significant Outlook Positive Related Events Intellectual Property -o Business Ethics Accounting and Taxation None Animal Welfare None Bribery and Corruption None Overall Controversy Level Based on our event level assessment of impact and risk as significant, the company has been assigned an overall controversy assessment of category 3. Intellectual Property Category 3 Significant Locations: United States of America, Europe, St. Louis, Ml, USA, New York, India, United States Tags: Intellectual Property Outlook Positive Sustainalytics' outlook for this controversy is positive for the next two years, because: Monsanto has adequate policies and programmes in place; however, it has consistently denied allegations of wrongdoing. Monsanto's commitment to upholding human rights is salutary, given the company's involvement in patent cases which have been linked to food security and access to seeds issues. Furthermore, since the lawsuits filed by the US Public Patent Foundation on behalf of the Organic Seed Growers and Trade Associations (OSGTA) have been resolved in the company's favour, Sustainalytics assigns a positive outlook to this Event category. Assessment Monsanto has been repeatedly criticised for its aggressive patent enforcement practices. In October 2011, Monsanto was sued by the government of India for contravening the country's Biological Diversity Act. The company was accused of taking an indigenous aubergine species and creating a genetically modified (GM) version without permission. While it is legal in India to develop GM seeds from indigenous plants, in this case the government had placed a moratorium on the use of aubergines following negative reactions from farmers. It is the first time a country has sued a multinational company for what has been labelled as biopiracy. Monsanto denied all accusations, blaming its Indian counterpart from the Mahyco-Monsanto joint venture for the illegal activities. In a different patent case, in March 2011, a group of US organic farmers filed a preemptive lawsuit against Monsanto in a bid to protect themselves against patent-infringement claims, should their crops become contaminated with Monsanto's seeds. Though dismissed in January 2014, the lawsuit points to stakeholder concerns regarding the company's intellectual property practices. The controversies Monsanto is involved in can be considered significant. The company's aggressive patenting practices are deemed to be of concern as they can have a large impact on the livelihood of agricultural producers around the world. The Indian biopiracy case stands out in the industry and poses both reputational as well as potential financial risk to Monsanto. SUSTAINALYTICS 23 | 28 EX P-3584 Page 23 of 28 SVEC OLDMONS0570462 Intellectual Property Incidents 10 Highest of Impact or Risk Main Incident (3 Incidents Timeline Score " _ Main Incident Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO 0 Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO Bio piracy allegations in India Forbes - 09 March 2013 The government of India sued Monsanto for violating the country's Biological Diversity Act, after the National Biodiversity Authority (NBA) of India filed a lawsuit against the company on similar claims, Monsanto was accused of having taken an indigenous aubergine species and used it to create a genetically modified version without permission. Melon patent revoked by European Patent Office AgroPages.com - 25 January 2016 The European Patent Office revoked a melon patent held by Monsanto due to technical reasons. Allegedly, the company was claiming melons with a natural resistance to plant viruses were its own invention. It was also discovered that the patent was granted despite the fact that European law does not allow patents on plant varieties and processes for conventional breeding. The company's patent was strongly opposed by the Indian government and various NGOs from Germany and Switzerland. Tomato patent withdrawn by Monsanto Sustainable Pulse - 22 December 2014 Monsanto's patent for tomatoes resistant to botrytis, a fungal disease, was revoked by the European Patent Office (EPO) following a request for withdrawal by the company. Previously, in May 2014, the Nunhems and No Patents on Seeds! coalition complained that the tomatoes used for the new product development were taken from an international gene bank in Germany and are, therefore, not an invention of the company. Update: Supreme Court Lawsuit Dismissed PR Newswire: U.S. -13 January 2014 The U.S. Supreme Court upheld the federal appeals court decision, which had ruled in the company's favour, pointing to Monsanto's promise not to sue farmers whose crops contain trace amounts of Monsanto's products. Monsanto has filed more than 140 lawsuits against farmers for planting the company's seeds without paying royalties and settled 700 other cases without suing. Update: OSGTA Lawsuit Supreme Court Reuters - 05 September 2013 The Public Patent Foundation filed a petition in September 2013 on behalf of the Organic Seed Growers and Trade Associations, with the U.S. Supreme Court challenging the decision of the U.S. Court of Appeals. The plaintiffs claim that farmers risk contamination with genetically modified (GM) seeds in amounts greater than 1%. Furthermore, the plaintiffs seek to overturn Monsanto's patents as invalid on the grounds they cause more harm than good. Update: OSGTA Lawsuit Dismissed Reuters -10 June 2013 The U.S. Court of Appeals ruled that organic farm owners lacked standing for a declaratory judgment regarding the contamination of conventional crops with GM seeds. The court stated that organic growers have to rely on Monsanto's assurance that no charges will be pressed so long as less than 1% of GM-crops are found in the fields. ^ ^ SUSTAINALYTICS 24 | 28 EX P-3584 Page 24 of 28 SVEC OLDMONS0570463 Impact OOOOOOOOOO Risk OOOOOOOOOO Business Ethics Category 2 Moderate OSGTA Lawsuit The Ecologist - 29 March 2011 Organic farm growers and supporting organisations filed a preventive class action lawsuit to protect themselves against legal action for inadvertently growing Monsanto genetically modified seeds on their plantations. Between 1997 and 2010, Monsanto filed around 800 patent cases against farmers who were found to be growing GM-crops in their fields without paying due royalties. Locations: United States Tags: Business Ethics - Other Impact OOOOOOOOOO Qi Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: Suspicions regarding the independence of pro-GMO scientists Bloomberg - 02 October 2015 The Genetic Literacy Project, a nonprofit group, was criticized after it was revealed that it received funding from Monsanto despite failing to publicly acknowledge this fact. E-mails obtained under the Freedom of Information Act revealed that five out of eight scientists contacted by Eric Sachs, Monsanto's Scientific Outreach Lead, ended up writing articles allegedly intended to influence GMO public policy. In addition, according to email messages obtained by the Boston Globe, Harvard professor Calestous Juma had undisclosed connections with Monsanto. Allegedly, one of Juma's papers was promoted with help from Monsanto's PR firm. Media also alleged that Monsanto suggested the summary and headline of a paper published by Juma. Corporate funds used to manipulate public opinion New York Times -12 September 2015 E-mail obtained by the US-based Right to Know NGO under the Freedom of Information Act (FOIA), revealed that Monsanto compensated allegedly independent collaborators for promoting GM seeds and biotechnologies. In 2014, Kevin Folta, the chairman of the horticultural sciences department at the University of Florida, received a USD 25,000 grant for his biotech outreach programme. While the money did not go towards his personal account, it did help fund his trips to various conferences and industry events. Previously, in 2013, David R. Shaw, the vice president for research and economic development at Mississippi State University was allegedly paid by Monsanto to intervene with the Department of Agriculture for the approval of GM soybean and cottonseed produced by Monsato. In 2011, Bruce M. Chassy, a professor at the University of Illinois also received funds to support "biotechnology outreach and education activities. According to the e-mails, Chassy lobbied with the EPA against the tightening of the regulation on pesticides. SEC settlement over accounting charges The Wall Street Journal -10 February 2016 Monsanto agreed to settle the Securities and Exchange Commission's (SEC) claims that it misstated its earnings by improperly disclosing the costs of a rebate program. The USD 80 million settlement resulted from a 2011 SEC investigation into Monsanto's customer incentive programmes related to its Roundup product from 2009 through 2011. The irregularities were corrected upon discovery. As part of the settlement, Monsanto agreed to hire a consultant to conduct a review of its disputed financial reporting. Three company executives paid individual fines ranging from USD 30,000 to 55,000. Moreover, Monsanto's CEO paid back to the company around USD 3 million in bonuses based on the overstated results despite no findings of misconduct on his part. SUSTAINALYTICS 25 | 28 EX P-3584 Page 25 of 28 SVEC OLDMONS0570464 Public Policy Incidents Category 1 Low Related Events Lobbying and Public Policy Overall Controversy Level o o Based on our event level assessment of impact and risk as low, the company has been assigned an overall controversy assessment of category 1. Lobbying and Public Policy Category 1 Low Locations: United States, California, Washington, DC, USA Tags: Lobbying and Public Policy Vermont, USA, Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO ) Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Update: Rally against DARK Act 4 Traders -18 October 2015 The Food Justice Coalition and March Against Monsanto NGOs announced a two-day event in Washington to raise awareness regarding the the Safe and Accurate Food Labeling Act, which blocked mandatory labeling of foods containing genetically engineered crops. The two NGOs stated that they expected hundreds of thousands of people to join the event, but no detailes about the exact numer of participants was available The Safe and Accurate Food Labeling Act is yet to be voted by the USE Senate. Update: US states supporting GMO labelling Before It's News - 21 September 2015 In total eight US states (i.e. Connecticut, Flawaii, Illinois, Maine, Maryland, Massachusetts, New Hampshire, and Washington) have filed a court brief in the US Court of Appeals, in support of Vermont's GMO labeling law. Vermont's intent to put forth a GMO labeling bill is facing resistance from Monsanto and other interest groups, such as the Grocery Manufacturer's Association. Update: Divest Monsanto Now campaign Charleston Gazette -13 May 2014 Food Democracy Now, together with organic farmer coalitions and consumer groups have launched a one-day campaign, calling on investors to divest from Monsanto. The campaign follows after Monsanto and the Grocery Manufacturers Association expressed their intentions to stop the bill from being implemented by suing the state of Vermont. Update: Vermont approves GMO labeling law Toronto Sun - 25 April 2014 Despite Monsanto's and other companies' lobbying activities against the labelling of GMO food products, the state of Vermont passed a bill which requires mandatory food labels for GMO products. The bill is due to go into effect on 1 July 2014. Update: Protests at shareholders' meeting Charleston Gazette -11 February 2014 During Monsanto's shareholders' meeting that took place in January 2014, the company repealed a minority shareholder's resolution stating that is had no intention to change its position regarding the labelling of genetically modified seeds.The company was criticised for investing in lobbying activities backing an anti-labelling campaign in order to persuade Washington state voters to change their mind about the labelling of genetically modified food. Protests against the company escalated and the police arrested ten participants. SUSTAINALYTICS 26 | 28 EX P-3584 Page 26 of 28 SVEC OLDMONS0570465 Impact OOOOOOOOOO @ Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO @ Impact OOOOOOOOOO Risk OOOOOOOOOO Impact OOOOOOOOOO Risk OOOOOOOOOO Update: Coalition against GMO labelling Bloomberg Industry Research - 06 February 2014 29 seed and food companies, including Monsanto were criticised for forming the Coalition for Safe Affordable Food and lobby against the labelling of genetically modified food. The coalition urged the Congress to pass a bill obstructing future GMO-labelling initiatives. Companies opposing labelling initiatives argue that if successful, these could increase food costs and breed mistrust among consumers. Nevertheless, the industry Coalition for Safe Affordable Food has been criticised by various consumer groups for their anti-labelling stance. Update: Washington's Initiative 552 Medical Daily - 25 October 2013 DuPont, Monsanto and Dow, three of the biggest producers of bioengineered crop seeds, were criticised for investing USD 18.1 million in lobbying activities backing an anti-labelling campaign in order to persuade Washington state voters to change their mind about the labelling of genetically modified food. Washington joined 26 other states with proposals to mandate such labelling or to prohibit genetically engineered food. So far the proposals were rejected in all states. Lobby against GMO labelling criticised New Hampshire News - 28 November 2012 Monsanto among others was criticised for lobbying heavily against a proposed GMO labelling regulation. The "California Right to Know Genetically Engineered Food Act", which required the labelling of genetically modified foods by manufacturers, was rejected after 53.1% of voters in California voted against it. First hearing of pro-GMO bill in Congress OrganicConsumers -11 December 2014 About 600 people protested in front of the US Congress against bill H.R. 4432, which modifies the Federal Food Drug and Cosmetic Act by prohibiting US states from enacting GMO labeling laws.The protesters claimed that Monsanto and the Grocery Manufacturers Association were using unfair methods to prevent activists from participating in the democratic debate by, among others, paying students to come early and occupy the seats. ^ ^ SUSTAINALYTICS 27 | 28 EX P-3584 Page 27 of 28 SVEC OLDMONS0570466 Glossary of Terms Controversy An event or aggregation of events relating to an environmental, social and governance topic. Event A series of incidents which pertain to a common theme. An event assessment is based on the highest impact or risk score assigned to the related incidents, alongside a broader assessment of event trend and company preparedness and response. Category 5 - Severe (raw score of 0): Category 4 - High (raw score of 20): Category 3 - Significant (raw score of 50): Category 2 - Moderate (raw score of 80): Category 1 - Low (raw score of 99): Incident The event has a severe impact on the environment and society, posing serious risks to the company. This category represents the most egregious corporate behavior. The event has a high impact on the environment and society, posing significant risks to the company. This category often reflects structural problems in the company. The event has a significant impact on the environment and society, posing moderate risks to the company. The event has a moderate impact on the environment and society, posing minimal risks to the company. The event has a low impact on the environment and society, posing negligible risks to the company. Company operations and/or products and services that have a negative impact on the environment, society and external stakeholders. Outlook A forecast of how a controversy rating will change over the next 12 months. Negative Positive Neutral The event is likely to deteriorate within 12 months, leading to a downgraded rating of the corresponding indicator. The event is likely to improve within the next 12 months, leading to an upgraded rating of the corresponding indicator. The event is unlikely to change significantly within the next 12 months, and is not expected to undergo a change in rating of the corresponding indicator. Disclaimer Copyright 2016 Sustainalytics. All rights reserved. No part of this publication may be reproduced, used, disseminated, modified, published or otherwise furnished in any manner without the express written consent of Sustainalytics. Nothing contained in this publication shall be construed as to make a representation or warranty, express or implied, regarding the advisability to invest in or include companies in investable universes and/or portfolios. 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