CARGILL’S ADDITIONAL SUBMISSION to the PUBLIC CONSULTATION on STEPPING up EU ACTION AGAINST DEFORESTATION and FOREST DEGRADATION February 2019

CARGILL’S ADDITIONAL SUBMISSION to the PUBLIC CONSULTATION on STEPPING up EU ACTION AGAINST DEFORESTATION and FOREST DEGRADATION February 2019

CARGILL’S ADDITIONAL SUBMISSION TO THE PUBLIC CONSULTATION ON STEPPING UP EU ACTION AGAINST DEFORESTATION AND FOREST DEGRADATION February 2019 Cargill: provider of food, agricultural, financial and industrial products Cargill is a family owned company over 150 years old. Our purpose is to nourish the world in a safe, responsible and sustainable way. We connect farmers with markets, customers with ingredients, and people and animals with the food they need to thrive. We combine our experience with new technologies and insights to serve as a trusted partner for food, agriculture, financial and industrial customers in more than 125 countries. Cargill moves a variety of raw materials around the world, from places of surplus to places of deficit. The company processes many of them – rapeseeds, sunflower seeds, or soybeans into oil and meal, cocoa beans into cocoa butter, powder and paste - and then sells the subsequent ingredients to many food and feed manufacturers of branded foods, as well as into food service. For more information please visit Cargill.com. Cargill purchases agricultural commodities from more than 9,000 farmers and more than 500 cooperatives and private dealers across the different EU member states. We work with approximately 20,000 suppliers in the EU and engage with them to achieve continued innovation and improved efficiencies. With our strong European1 footprint in 18 countries, 154 sites, four centres of excellence in innovation and over 14,000 employees, we are interested in engaging with policy makers and contributing to responding to major societal challenges. Cargill is committed to applying its global knowledge and experience to help meet economic, environmental and social challenges. The private sector has an important role to play in finding solutions to the world’s most pressing challenges and achieving the Sustainable Development Goals – from addressing climate change, to protecting natural resources and improving food security. We are working with farmers, governments, industry groups, customers and consumers to make the future of food more sustainable. Cargill is contributing by adhering to core commitments of operating responsible supply chains, working to feed the world efficiently and sustainably, conducting business with integrity and supporting local communities. 1 Europe and Norway 1 Protecting forests and promoting sustainable agriculture Cargill, its customers and the public are concerned about agriculture’s role in contributing to deforestation, particularly of the world’s rainforests. Forests are crucial to life on the planet. They support four-fifths of terrestrial plant and animal life, and capture and store greenhouse gases that contribute to climate change. Forests also provide food, water, fuel, medicine and livelihoods to billions of people. The complexity of the combat against deforestation is linked to population increase and its corollary of food security and nutrition. This is why forests and farming must coexist. This is possible if development is managed responsibly, providing both a healthy environment and a secure food supply for a growing, more affluent global population. Furthermore, if deforestation is a global issue, it is a local challenge. What works in one part of the globe doesn’t necessarily work somewhere else. As many industry players have accelerated their efforts to combat deforestation, companies such as Cargill cannot combat deforestation alone, but need partnerships with farmers, governments, customers, environmental groups and others in industry to shape diverse and lasting solutions. As one of the world’s largest buyers of soy, palm oil, cocoa and other crops, we are aware of our role in promoting sustainable development. This is the reason why Cargill has committed to transform our agricultural supply chains to be deforestation-free through prioritized supply chain policies and time-bound plans. For more information on our approach, you can read our updated Policy on Forest and our new Policy on Sustainable Soy. Tackling deforestation is complex, and we must ensure we meet the needs for all stakeholders - including farmers and local communities- balancing forest protection with inclusive growth and sustainable development. Comments on potential EU actions to combat deforestation and forest degradation For the reasons set out above, Cargill welcomes the European Commission’s consultation on stepping up EU Action against deforestation and forest degradation. The EU has an important role to play in tackling deforestation, including ensuring that there is a consistent and harmonized approach in addressing the challenge at the Member State level, together with leading the way for actions at international level in the framework of global commitments on climate change. General remarks Lasting solutions to tackling deforestation require long-term cooperation and joint efforts between governments and public administration in producer countries and in destination markets. With the involvement and active support of authorities of both producer and destination countries, private players’ initiatives reach more comprehensive and lasting results and benefit from a multiplier effect, achieving better visibility and gaining momentum. In addition, more than 10 years of active participation in the soy moratorium in Amazonia has demonstrated that action plans need to include key stakeholders such as NGOs, farmers communities and consumers. 2 In producer countries, this implies enacting the right legislative instruments for the implementation of best agricultural production practices, sustainable production and economic development while protecting natural habitats. This also requires legislation to be set-up and enforced and for the governments to have the power to do so, the public services and tools to act effectively against offenders. Actions in this respect, go hand in hand with the need for farmers to have effective and enforceable land rights and land titles which are vital to ensuring strong agricultural economies that support the livelihoods of millions of farmers around the world. Accordingly, transparent and secure land rights are the foundation of sustainable farming. In destination markets, close cooperation of all players in the value chain including governments is necessary, particularly around shared objectives and responsibilities, but also political support to create and sustain the commitments to change. This would include technical assistance and public service capacity building in countries with the greatest risk of deforestation and facing challenges on land and human rights. This requires continued engagement with different supply chains and actors to influence their behaviour rather than exclude those without the technical and financial capacity to achieve sustainable agricultural practices at any given point in time. In this respect, policies that recognize global trade flows and are geared at improving livelihoods for farmers of all sizes should be promoted. Farmer and rural prosperity is key for a safe, secure and affordable food supply. For any action to endure in preventing deforestation, it must include actions that address the local social and economic issues. Specific consideration should be given to the inclusion of smallholders. Cargill works alongside smallholders in a number of geographies and we have seen the value of providing technical and financial support on the ground. For instance, through Cargill Cocoa promise we have reached over 100.000 smallholder farmers in Cote d’Ivoire and Ghana. However, in a market where there are millions of smallholders, support from member states and the EU to bring these interventions to scale is critical. Overall, EU action should build on and reinforce existing initiatives as well as governments’ and private sector actions in producer countries. More specifically we would like to emphasize: • The need to build consensus around definitions and standards of measurement recognised internationally- There is an urgent need for locally relevant definitions and metrics on deforestation, land conversion and forest conservation. Such geographic specific definitions should reflect latest data sources, the unique context of different biomes and their different socio-economic and environmental challenges. For example, we support the work of the Cerrado Working group2 as this group considers the specific and different context of the Cerrado biome and what is feasible from an environmental, social and economic perspective. • The importance of further dialogue and cooperation between producing and consumer countries and government to government discussion, which can take place bilaterally and at international level, around an agenda adapted to the national/regional/local circumstances. 2 The GTC is a stand-alone entity that is responsible for agreeing terms of an agreement between producers, industry, consumer organizations and civil society, as well as an action plan for eradicating deforestation in Brazil’s Cerrado biome. The GTC is composed of industry members, NGOs, producer organisations, government and financial institutions and well as Brazilian consumer goods companies 3 • Promoting trade in sustainable commodities through international trade and investment agreements should be further explored at EU and multilateral level. • Certification is a tool to begin building sustainable supply chains, and Cargill is pursuing certification in a number of our value chains. Effective certification frameworks,

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