SUSTAINABILITY AND CAPITAL MARKETS IN : A QUARTERLY NEWSLETTER

Issue 2, July 12, 2019

Issue 2, July 12, 2019

Sustainability and Capital Markets in Brazil, a newsletter published by Climate Advisers, provides quarterly analysis of political and market developments that could increase ESG-related material risks for investors in soft commodities in Brazil.

Soft Commodity Risks and Spike Amid Policy Rollbacks

Deforestation in Brazil has gone from bad to worse in 2019, with political developments undermining enforcement of forest protection laws. Cattle grazing and soy cultivation have long been major drivers of deforestation in Brazil,1 despite the ambitious pledges made by key private sector players to stop fueling forest loss for profit.

This newsletter will cover President Bolsonaro’s anti-conservation push and the growing political backlash, the latest data on deforestation, and existing evidence of supply chain links to publicly traded companies. It argues that these sustainability setbacks, combined with ESG policy gaps, increase the business risks faced by companies sourcing or financing soft commodities in Brazil.

With reduced legal enforcement, companies’ effective implementation of strong zero-deforestation policies remains a critical line of defense to slow Brazil’s forest loss. Companies linked to deforestation also face financial, market access, competitive, reputational, and legal risks. The long-term financial performance of companies - and investors - tied to Brazil’s agricultural sector depends on achieving robust sustainability targets, including no deforestation pledges. These private sector actors must increase efforts to prevent their funds from fueling further forest loss, in order to bolster their own financial well-being and to limit connected to agricultural production.

Record-Setting Deforestation Rates in 2018 and 2019 In 2018, Brazil lost more primary forests than any other country on earth, according to Global Forest Watch, and now President is moving aggressively to further weaken the country’s environmental protections. Recent figures substantiate the country’s reversal, since 2015, of what had been a decade-long downward trend. The Brazilian government recorded 1.3 million hectares of - dense, old-growth forest lost last year,2 more than the next five worst-performing countries combined.3

Data from the Brazilian NGO Imazon shows a nearly 50 percent deforestation spike from August to October 2018, during the height of the presidential campaign, much of it for production in the Amazon.4 The correlation between Bolsonaro’s victory and the surge in land conversion is unlikely a

1 Piotrowski, Matt. “Nearing the Tipping Point: Drivers of Deforestation in the Amazon Region” (Inter-American Dialogue, 2019), https://www.thedialogue.org/wp-content/uploads/2019/05/Nearing-the-Tipping-Point-FINAL-2.pdf. 2 Weisse, Mikaela and Elizabeth Dow Goldman, “The World Lost a Belgium-Sized Area of Primary Rainforests Last Year,” Insights (blog), April 25, 2019, https://www.wri.org/blog/2019/04/world-lost-belgium-sized-area-primary-rainforests-last- year?utm_campaign=GFW&source=socialmediakit&utm_medium=gfwsocial&utm_term=2018tcl_4_2019. 3 These countries include the Democratic Republic of the Congo, Indonesia, Colombia, Bolivia and Malaysia. 4 Fabiano Maisonnave, “Desmatamento na Amazônia explode durante período eleitoral,” Folha de S.Paulo, November 11, 2018, https://www1.folha.uol.com.br/ambiente/2018/11/desmatamento-na-amazonia-explode-durante-periodo-eleitoral.shtml. coincidence, given similar trends during past elections in which major candidates pledge to ease forest regulations.5 Monitoring organizations have also documented recent land conversion for soy and cattle in 2019, which includes actions by suppliers to major, publicly-listed, soy traders.6 Since Bolsonaro took office in January, the Brazilian government’s own data reveals evidence that analysts’ alarming forest loss predictions are materializing.7 The Amazon experienced 285 square miles of illegal deforestation in May 2019, the largest single-month figure in a decade, and the acceleration continued in June.8

Figure 1: Deforestation (km2) in the Brazilian Amazon, September 2017 and 2018

State Sept 2017 Sept 2018 Change (km2) (km2) (%) 7 51 629 Amazonas 54 107 98 Mato 66 103 56 Grosso Pará 41 86 110 Rondônia 69 89 29 5 9 80 - - - Amapá - - - TOTAL 242 445 84

Source: Sistema de Alerta de Desmatamiento (SAD)

Lack of Supply Chain Transparency Creates Deforestation Risks While the overall drivers of forest loss are well-established, proving the link between specific cases of deforestation and the products sold by a given company can be challenging. However, without a traceable supply chain, companies have difficulty guaranteeing a deforestation-free product. In many regions, illegal logging and land speculation by multiple, successive actors often take place on a given property before agricultural producers take possession of it.9 For buyers or investors, the difficulty in

5 Branford, Sue and Torres, Maurício, “Bolsonaro Pledges Government Shakeup, Deregulation, Amazon Development,” Mongabay, November 19, 2018, https://news.mongabay.com/2018/11/bolsonaro-pledges-government-shakeup-deregulation-amazon-development/. 6 Brazilian NGO Imazon collaborated with journalists in June 2019 to document links between cattle expansion and ongoing deforestation in the state of Pará. See Paulo Cabral, “Data Show Rise in Amazon Deforestation under President Bolsonaro,” CGTN America, June 18, 2019, https://america.cgtn.com/2019/06/17/data-show-rise-in-amazon-deforestation-under-president-bolsonaro. See also: Mighty Earth, “Rapid Response - Soy and Cattle: Report 1,” June 2019, http://www.mightyearth.org/wp-content/uploads/Rapid-Response_Soy-and-Cattle_Report- 1.pdf. 7 INPE, “DETER Registra Na Amazônia Em Maio 1.102,57 Km2 de Alertas,” Coordenação-Geral de Observação da Terra, June 10, 2019, http://www.obt.inpe.br/OBT/noticias/deter-registra-na-amazonia-em-maio-1-102-57-km2-de-alertas. See also: Kepp, “Brazil’s New President Awakens Fears for Amazon, the Environment”; “Bolsonaro’s Presidency to Increase Deforestation Risk in Brazil,” Chain Reaction Research, November 2, 2018, https://chainreactionresearch.com/bolsonaros-presidency-to-increase-deforestation-risk-in-brazil/. 8 Boadle, Anthony and Paraguassu, Lisandra, “Satellite Data Shows Amazon Deforestation Rising under Brazil’s Bolsonaro,” Reuters, June 4, 2019, https://www.reuters.com/article/us-brazil-environment-deforestation-idUSKCN1T52OQ. See also: Nandika Chand, “Deforestation Accelerates In The Amazon, We Are Slowly and Steadily Losing The World’s Largest Rainforest,” International Business Times, July 3, 2019, https://www.ibtimes.com/deforestation-accelerates-amazon-we-are-slowly-steadily-losing-worlds-largest-2804499.

9 Mauricio Torres and Sue Branford, “Amazônia, terra sem lei: Grileiros comandam avanço da fronteira agropecuária sobre a floresta,” The Intercept Brasil, April 24, 2017, https://theintercept.com/2017/04/24/grileiros-comandam-avanco-da-fronteira-agropecuaria-sobre-a-floresta/. tracing product origin may not absolve companies of potential liabilities, and for this reason, the adoption of robust traceability and transparency practices is key.10 Recent advances in monitoring technology, combined with land title data, are making it easier to compile compelling evidence in certain cases, a trend with important implications for companies’ reputations, despite reduced legal enforcement.

Backlash as Bolsonaro Boosts Environmental, Social Risks

Environmental fines and seizures of illegal timber have hit record lows under President Bolsonaro as environmental officials report fears of retaliation for doing their jobs.11 He has used his executive power to delivered quick victories for Brazil’s “ruralista” bloc, undermining the authority of key institutions by reorganizing them, firing key officials, leaving dozens of posts unfilled, and installing leaders who are openly hostile to their agencies’ missions. A convicted environmental criminal now heads the Ministry of the Environment, and over three-quarters of state-level leadership posts for its enforcement arm, Ibama, are vacant. 12 Increased impunity for forest crimes is likely inevitable under these conditions.

Figure 2: Number of ICMBio Inspection Actions in the Brazilian Amazon

Source: ICMBio (The Chico Mendes Institute), via Mongabay13

Bolsonaro has also weakened indigenous land rights, a widely condemned move with significant negative implications for forest protection, given the high conservation success rates on legally

10 “Operational Guidance on: Reporting, Disclosure, and Claims,” Accountability Framework, June 2019, https://accountability- framework.org/contents-of-the-framework/reporting-disclosure-and-claims/?guidance_topic=3. 11 Sue Branford and Thais Borges, “Brazil Guts Environmental Agencies, Clears Way for Unchecked Deforestation,” Mongabay, June 10, 2019, https://news.mongabay.com/2019/06/brazil-guts-environmental-agencies-clears-way-for-unchecked-deforestation/. 12 Jake Spring, “Brazil’s Incoming Environment Minister Found Guilty of Improper Conduct,” Reuters, December 20, 2018, https://www.reuters.com/article/us-brazil-politics-minister/brazils-incoming-environment-minister-found-guilty-of-improper-conduct- idUSKCN1OJ2VE. recognized native lands.14 On his first full day in office, the president issued an order known as MP 870, which moved FUNAI, the entity responsible for demarcating indigenous land, from the Ministry of Justice to the Ministry of Human Rights, and reassigned its land oversight authority to the Agriculture Ministry.15 A fierce inter-governmental battle has since been waged over this matter. The president issued a new decree after Congress rejected MP 870,16 but on June 25, 2019, Brazil’s Supreme Court temporarily halted its implementation while it considers a final ruling.17 In the midst of this ongoing struggle over FUNAI, the agency’s head was fired.18

Meanwhile, the administration has announced plans for major infrastructure projects that would require rainforest destruction in indigenous territories,19 and violent attacks on land rights defenders have increased over the past year.20 In this context, an annual mobilization for indigenous rights drew 4,500 people to Brasilia in April. The global visibility of the encampment and march, whose demands included restored independence for FUNAI, 21 may have helped pressure legislators to challenge Bolsonaro.

Potential Market Impact of Local and International Pressure

Pushback on Bolsonaro Policies Includes Private Sector The opposition to Bolsonaro’s anti-environment actions comes from across Brazilian society, including the private sector. The potential reputational impact of Bolsonaro's policies and his withdrawal from multilateral sustainability initiatives concerns some in the country’s business community. Many agricultural exporters do worry that Brazil’s deteriorating international image on environmental and human rights issues, combined with perceived political volatility, could eventually hurt their bottom line.

While significant damage is still ongoing, the pushback has achieved some short-term wins. Bolsonaro was forced to back down on a radical proposal to merge the Ministry of the Environment with the Ministry of Agriculture before he even took office,22 following outcry by civil society, academics, current and former Ministers of the Environment, and much of the agricultural sector (support for the measure

14 Victoria Tauli-Corpuz, Janis Alcorn, and Augusta Molnar, “Cornered by Protected Areas: Replacing ‘Fortress’ Conservation with Rights- Based Approaches Helps Bring Justice for Indigenous Peoples and Local Communities, Reduces Conflict, and Enables Cost-Effective Conservation and Climate Action” (Rights and Resources Initiative, June 2018), https://rightsandresources.org/wp- content/uploads/2018/06/Cornered-by-PAs-Brief_RRI_June-2018.pdf. 15 Marian Blasberg et al., “The Brazilian President’s Attack on the Amazon Forest,” Spiegel Online, January 17, 2019, https://www.spiegel.de/international/world/the-brazilian-president-s-attack-on-the-amazon-rain-forest-a-1248102.html. 16 Karla Mendes, “Brazil’s Congress Reverses Bolsonaro, Restores Funai’s Land Demarcation Powers,” Mongabay, June 5, 2019, https://news.mongabay.com/2019/06/brazils-congress-reverses-bolsonaro-restores-funais-land-demarcation-powers/. 17 “Brazil Judge Blocks Transfer of Control over Indigenous Land,” Al Jazeera, June 25, 2019, https://www.aljazeera.com/news/2019/06/brazil- judge-blocks-transfer-control-indigenous-land-190625080628133.html. 18 “Brazil Indigenous Affairs Head Fired amid Push to Develop Amazon,” Al Jazeera, June 12, 2019, https://www.aljazeera.com/news/2019/06/brazil-indigenous-affairs-head-fired-push-develop-amazon-190612052546978.html. 19 Jan Rocha, “Bolsonaro Government Reveals Plan to Develop the ‘Unproductive Amazon,’” Mongabay, January 28, 2019, https://news.mongabay.com/2019/01/bolsonaro-government-reveals-plan-to-develop-the-unproductive-amazon/. 20 Sue Branford and Thais Borges, “3 Massacres in 12 Days: Rural Violence Escalates in Brazilian Amazon,” Mongabay, April 8, 2019, https://news.mongabay.com/2019/04/3-massacres-in-12-days-rural-violence-escalates-in-brazilian-amazon/; Anthony Boadle, “Emboldened by Bolsonaro, Armed Invaders Encroach on Brazil’s Tribal Lands,” Reuters, March 3, 2019, https://www.reuters.com/article/us-brazil- indigenous/emboldened-by-bolsonaro-armed-invaders-encroach-on-brazils-tribal-lands-idUSKCN1QK0BG. 21 XV ACAMPAMENTO TERRA LIVRE, ARTICULAÇÃO DOS POVOS INDÍGENAS DO BRASIL (APIB), and MOBILIZAÇÃO NACIONAL INDÍGENA (MNI), “Documento final do XV Acampamento Terra Livre,” Mobilização Nacional Indígena (blog), April 26, 2019, https://mobilizacaonacionalindigena.wordpress.com/2019/04/26/documento-final-do-xv-acampamento-terra-livre/. 22 Jenny Gonzales, “Merger of Brazil’s Agriculture and Environment Ministries in Limbo,” Mongabay, November 12, 2018, https://news.mongabay.com/2018/11/bolsonaro-merger-of-brazil-agriculture-and-environment-ministries-in-limbo/. from cattle ranchers was a notable exception).23 In particular, opposition by importers demonstrated the political power of the industry’s demand-side actors. Similarly, recent attempts to significantly weaken Brazil’s forest code fell short as pressure grew on legislators to abandon the effort.24 The multi-stakeholder group known as the Brazil Climate, and Agriculture Coalition, whose 200 members include the Brazilian Association of Agribusiness (ABAG), , Carrefour and Unilever, publicly opposed the changes.25

Outside of Brazil, various coalitions of NGOs and academics have gained media attention for hard- hitting reports,26 advocacy tours by indigenous leaders, and high-profile joint letters, including one signed by 340 groups demanding an end to EU-Brazil trade negotiations.27 The long-term impact of these and other international advocacy tactics is still unclear, but the various sources of pressure on public and private sector actors to deliver on their forest-related ESG responsibilities, and the corresponding reputational risks, will likely grow.

Soy Sector Faces Risks Despite No-Deforestation Commitments Brazil’s biggest soy traders, in particular, have faced ongoing calls to publish up-to-date information on their suppliers in order to demonstrate that their no-deforestation policies effectively exclude “rogue” growers from their supply chains (as many have pledged to achieve by 2020)28.

Soy traders are particularly exposed to risks in the state of Tocantins, which is located in the and has lost 50 percent of its original area as a result of agriculture development.29 From 2009-2018, Tocantins lost the most forest compared to other states in the Cerrado. The large commodity traders, such as ADM, Bunge, Cargill, Louis Dreyfus, and Cofco, have been active in Tocantins. The traders and cattle ranchers shifted activity to the Cerrado when zero-deforestation agreements last decade curbed forest loss in the Amazon. While forest loss did fall in the Cerrado last year,30 approximately 666,000 hectares were still deforested. What is worrisome is that none of the traders have yet signed the Cerrado Manifesto, which calls on signatories to take efforts to curb deforestation in beef and soy supply chains in the Cerrado savannah. For traders to reduce their deforestation risks in Tocantins, they need to increase transparency with data on their supply chains, track indirect procurement of products, enforce compliance, and proactively monitor shifts in land use.

In the Cerrado soy market, one recent development may bring a new level of necessary transparency. The Soft Commodities Forum (SCF), part of the World Business Council for Sustainable Development (WBCSD), published new details in early June on the soy market in the Cerrado, with input from big

23 Eduardo Bresciani, “Bancada ruralista vê com ‘preocupação’ fusão de Agricultura e Meio Ambiente,” O Globo Brazil, October 31, 2018, https://oglobo.globo.com/brasil/bancada-ruralista-ve-com-preocupacao-fusao-de-agricultura-meio-ambiente-23201492. 24 Gerson Freitas Jr, “The Amazon Rain Forest Burns Again,” Bloomberg, May 30, 2019, https://www.bloomberg.com/news/articles/2019-05- 30/amazon-rainforest-deforestation-in-brazil-on-the-rise-for-years. 25 Coalizão Brasil Clima, Florestas e Agricultura, “Em Defesa Do Código Florestal,” May 28, 2019, http://www.coalizaobr.com.br/home/index.php/emdefesadocodigoflorestal. 26 Andres Schipani, Anna Gross, and Bryan Harris, “Report Accuses Companies of Aiding Amazon Destruction,” Financial Times, April 25, 2019, https://www.ft.com/content/4205c694-66a2-11e9-9adc-98bf1d35a056. 27 “340+ Organizations Call on the EU to Immediately Halt Trade Negotiations with Brazil,” Pressenza International Press Agency, June 23, 2019, https://www.pressenza.com/2019/06/340-organizations-call-on-the-eu-to-immediately-halt-trade-negotiations-with-brazil/. 28 Anna Gross, “Green Activists Push Soya Traders on Brazil Deforestation,” Financial Times, March 4, 2019, https://www.ft.com/content/3de35892-39c0-11e9-b856-5404d3811663. 29 “About the Cerrado,” Farm Animal Investment Risk and Return (FAIRR), 2018, https://cerradostatement.fairr.org/about/. 30 Jake Spring, “Deforestation in Brazil’s Cerrado Savanna Falls to Record Low,” Reuters, December 11, 2018, https://www.reuters.com/article/us-brazil-deforestation-idUSKBN1OA1RQ. traders operating in the region.31 See the table below for the percentage of how much of their soy volumes sourced in Brazil come from the Cerrado.

Figure 2: Company Exposure to Cerrado

Company % of Brazilian Soy Volumes in Cerrado ADM 39 Bunge 39 Cargill 37 Cofco 29 LDC 26 Glencore 22 Source: Company reports to SCF

The trading companies have committed to a new framework to produce details on how much soy they source from 25 high-risk municipalities in the Cerrado. These reports are expected to indicate where traders need to identify improvements in balancing forest preservation, economic growth for local communities, and soy production.

Soon after the SCF announcement, however, Cargill faced criticism of a new Soy Action Plan from NGOs for lacking details on implementation,32 and for an open letter it sent to Brazilian soy producers on June 24. 33 The letter re-stated Cargill’s opposition to a Soy Moratorium in the Cerrado. It also questioned whether companies pledging to exclude deforestation-linked producers from supply chains could actually reduce deforestation rates, despite several studies demonstrating that a Soy Moratorium has done just that in the Amazon.34

Given that the SCF’s transparency measures are new and will continue to be a work-in-progress for some time, and as major players like Cargill send mixed signals to producers, it is unclear how significantly the measures will impact deforestation rates.

Deforestation-Related Financial Risks for ADM, Bunge, Cargill and SLC Agricola A June 2019 report by NGO Mighty Earth documented land conversion as recent as April 2019 in and states, on properties where Cargill, ADM and Bunge (among others) have made prior soy purchases.35 Bunge and Cargill are currently disputing fines levied against them by Brazil in April

31 “Soft Commodities Forum Members Publish First Common Reports on Soy Supply Chains,” World Business Council for Sustainable Development (WBCSD), June 6, 2019, https://www.wbcsd.org/Programs/Food-Land-Water/Food-Land-Use/Soft-Commodities- Forum/News/members-publish-first-common-reports-on-soy-supply-chains. 32 Cargill, “South American Soy Action Plan,” June 2019, https://www.cargill.com/doc/1432142481523/soy-action-plan.pdf 33 “Cargill divulga carta aos produtores brasileiros e se diz contrária à...,” Notícias Agrícolas, June 25, 2019, https://www.noticiasagricolas.com.br/noticias/agronegocio/237742-cargill-divulga-carta-aos-produtores-brasileiros-e-se-diz-contraria-a- moratoria-no-cerrado.html#.XRzHaOhKg2w. 34 Jude H. Kastens et al., “Soy Moratorium Impacts on and Deforestation Dynamics in Mato Grosso, Brazil,” PLOS ONE 12, no. 4 (April 28, 2017): e0176168, https://doi.org/10.1371/journal.pone.0176168; H. K. Gibbs et al., “Brazil’s Soy Moratorium,” Science 347, no. 6220 (January 23, 2015): 377–78, https://doi.org/10.1126/science.aaa0181. 35 Mighty Earth, “Rapid Response - Soy and Cattle: Report 1.” June 2019, http://www.mightyearth.org/wp-content/uploads/Rapid- Response_Soy-and-Cattle_Report-1.pdf. 2018, allegedly for purchasing soy linked to land conversion in the Cerrado biome.36 Mighty Earth’s report names the property owners in 12 land clearance cases, and in all cases names the owners of commodity warehouses within 50 kilometers (including the aforementioned traders). Among the owners named in Mighty Earth’s report is SLC Agrícola, Brazil’s top soy producer and a recently documented deforester.

SLC Agrícola cleared land from the beginning of March to early May 2019 at its Fazenda Parceiro fam in the Formoso do Rio Preto municipality.37 Even though the company’s action is legal under Brazil’s Forest Code, the company faces market access risks from this activity, as a number of SLC Agrícola’s buyers and investors have made commitments to curb deforestation. These include Amaggi LD Commodities, Cargill, and subsidiaries of retailer Lidl.

The company has grown significantly in recent years, but its upside could be limited by deforestation risks. It’s market capitalization is just under 4 billion (USD 1 billion), more than double 2016 levels. Soy now makes up approximately 39 percent of SLC Agrícola’s revenue, second behind cotton. The company – and Brazil’s soy market in general – has benefitted from the U.S.-China trade war, a weaker Brazilian real, and a rebound in Brazilian soy prices. Chain Reaction Research estimates that SLC Agrícola’s revenue-at-risk may be as high as USD 290 million from the possibility of sales being cut off by certain buyers.38

Figure 1: SLC Agricola’s Soy Revenue, 2009-2018

Source: Bloomberg

36 Karla Mendes, “Brazilian Companies Illegally Degrading the Amazon Continue to Operate With Impunity,” Pacific Standard, May 6, 2019, https://psmag.com/environment/brazilian-companies-continue-to-degrade-amazon-with-impunity. 37 “The Chain: SLC Agrícola Clears 1,355 Hectares of Cerrado Vegetation Despite Customers’ Zero-Deforestation Commitments,” Chain Reaction Research, May 9, 2019, https://chainreactionresearch.com/the-chain-slc-agricola-clears-1355-hectares-of-cerrado-vegetation- despite-customer-zero-deforestation-commitments/. 38 Ibid. Financial Institutions Under Greater Pressure on Climate and Deforestation In addition to producers, traders, and consumer goods companies, financial institutions that lend to or have invested in companies linked to deforestation in Brazil have come under greater scrutiny. International advocacy initiatives related to , deforestation, and Bolsonaro’s environmental and human rights policies have increasingly sought to influence top asset managers.39

A May 2019 report by the NGO Amazon Watch, “Complicity in Destruction II,” received widespread media attention. The report lists banks that have provided credit and loans to Brazil’s meat producers and soy traders and highlights investors that have purchased the most shares in these companies over the past five years.40 The main commodity traders in Brazil – ADM,41 Bunge,42 Cargill,43 and Louis Dreyfus – have received more than USD 1 billion in credit from thirteen banks, while HSBC and Banco Santander are top financiers to Brazilian beef exporters.44 Amazon Watch is part of a coalition campaign known as “BlackRock’s Big Problem,” which argues that the world’s top investor shares responsibility, along with governments and companies, in enabling a climate crisis, including by funding “Amazon destruction” amid Bolsonaro’s policy rollbacks.45

Transnational pressure by private, public and nonprofit actors is building broader awareness of the companies and investors tied to deforestation. It is probable that advocacy campaigns will accelerate their demands that financiers reduce their exposure to deforestation and push companies to strengthen ESG policies. Deforestation-related climate risks will continue to exist in Brazil’s soft commodity sectors until companies, including the major traders, implement strong zero-deforestation policies that include full supply chain traceability, monitoring, and compliance enforcement measures.

39 Geoff Dembicki, “BlackRock Claims Sustainability But Is Profiting from Climate Change,” Vice, May 24, 2019, https://www.vice.com/en_us/article/j5wdvg/blackrock-profiting-from-climate-change. 40 Amazon Watch, “Complicity in Destruction II: How Northern Consumers and Financiers Enable Bolsonaro’s Assault on the Brazilian Amazon,” April 2019, https://amazonwatch.org/assets/files/2019-complicity-in-destruction-2.pdf. 41 “ADM: Matopiba Sourcing Could Link Company to Deforestation,” Chain Reaction Research, September 21, 2018, https://chainreactionresearch.com/report/adm-matopiba-sourcing-could-link-company-to-deforestation/. 42 “The Chain: Bunge’s Updated Sustainability Policy Does Not Address Legal Deforestation,” Chain Reaction Research, December 19, 2018, https://chainreactionresearch.com/the-chain-bunges-updated-sustainability-policy-does-not-address-legal-deforestation/. 43 “The Chain: Cargill May Still Face Reputation, Business Risks Despite Updated Zero-Deforestation Policy for Soy,” Chain Reaction Research, March 7, 2019, https://chainreactionresearch.com/the-chain-cargill-may-still-face-reputation-business-risks-despite-updated-zero- deforestation-policy-for-soy/. 44 “The Chain: Soy Traders Adopt Key Transparency Measures to Counter Deforestation Risks,” Chain Reaction Research, February 25, 2019, https://chainreactionresearch.com/soy-traders-adopt-key-transparency-measures-to-counter-deforestation-risks/. 45 Christian Poirier, “Terra Livre Mobilization Propels Brazil’s Indigenous Movement to the Forefront of Resistance to Bolsonaro,” Amazon Watch, May 9, 2019, https://amazonwatch.org/news/2019/0509-terra-livre-propels-brazils-indigenous-movement-to-the-forefront-of- bolsonaro-resistance.