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Responding department: Sustainability / Communications

Stock exchange symbol: (ADM:US)

Does your company have a publicly available commitment to respect human rights?

It is a stand-alone "human rights" policy. [link] Please visit [link] for a copy of our Code-of-Conduct and ADM Way.

How are human rights governed in your company?

Any violation of ADM’s human rights policy could constitute a risk to our supply chain, and therefore to our business more broadly. For these reasons, human rights issues ultimately fall under the auspices of our company’s board of directors, which is responsible for risk oversight, focusing on our company’s overall risk management strategy. While the board as a whole maintains the ultimate oversight responsibility for risk management, committees of the board can be assigned responsibility for risk management oversight of specific areas.

 The Audit Committee currently maintains responsibility for overseeing our company’s enterprise risk management process and regularly discusses our company’s major risk exposures, the steps management has taken to monitor and control such exposures, and guidelines and policies to govern our company’s risk assessment and risk management processes. The Audit Committee periodically reports to our board of directors regarding significant matters identified with respect to the foregoing. The Nominating/Corporate Governance Committee has the authority to assign oversight of risk areas to specific committees as the need arises.

How are human rights managed within your company?

Any violation of ADM’s human rights policy could constitute a risk to our supply chain, and therefore to our business more broadly. Human rights issues fall under the auspices of ADM’s Integrated Risk Management Committee, which consists of personnel from multiple functional and regional areas within our company, with broad oversight of the risk management process.

The committee’s responsibilities and objectives include: ensuring implementation and maintenance of a process to identify, evaluate and prioritize risks to achievement of our company’s objectives; ensuring congruence of risk decisions with our company’s values, policies, procedures, measurements, and incentives or disincentives; supporting the integration of risk assessment and controls into mainstream business processes and decision-making; clearly identifying roles and responsibilities across our company in regard to risk assessment and control functions; promoting consistency and standardization in risk identification and controls across our company; ensuring sufficient information capabilities and information flow to support risk identification and controls and alignment of technology assets; regularly evaluating the overall design and operation of the risk assessment and control process,including development of relevant metrics and indicators; and reporting regularly to senior management and our board.

ADM adopted its Human Rights Policy in May 2014. We are currently working with a 3rd party stakeholder to develop an appropriate implementation plan, which will include specific guidance on our process for handling any negative human rights impacts, development of metrics and Key Performance Indicators and details on our plans for reporting any possible supply-chain impacts.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

The company communicates with a wide range of stakeholders, including company shareholders, government agencies, NGOs, trade associations and private citizens to effectively address concerns/risks/issues.  ADM strives to respond to all inquiries about our policies and practices with respect to human rights, and our Human Rights policy is available to the public online.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health
  • Forced labour & human trafficking (including in supply chains)
  • Children (including child labour)
  • Indigenous peoples

Actions on 'other' issues

ADM is a signatory to the National Agreement to Eradicate Slave Labor in Brazil, a commitment to refrain from negotiating with companies included in the List of Slavery Work maintained by the Brazilian Ministry of Labor.  Since 2009, ADM has worked with Aliança da Terra, a Brazilian NGO founded by farmers, to advance a program known as Doing It Right, or Produzindo Certo.

Doing It Right works to train farmers on agronomically and socially sound cultivation practices and emphasizes fair labor conditions as part of its overall focus on sustainable, responsible operations that meet or exceed environmental laws and regulations.  In our cocoa supply chain, ADM has developed a variety of programs aimed at improving the lives and livelihoods of growers in western Africa and Indonesia. ADM has offered an HIV/AIDS education and prevention program for all full-time staff members, their families and retired employees in Côte d’Ivoire. And in Ghana, ADM collaborates with Gesellschaft für Internationale Zusammenarbeit, a German development organization, on a workplace health program for ADM employees, their families and local community residents.

At the same time, Our Socially and Environmentally Responsible Agricultural Practices program, or SERAP, promotes ethical and responsible social practices, and recognizes and supports the pivotal roles women play in cocoa cultivation and rural development. SERAP also promotes vocational education and helps to fight tropical diseases, such as malaria, through preventative health training, and by creating awareness of the importance of clean drinking water, proper sanitation and good nutrition. The ADM Cocoa Technical Training Program works through cooperatives in Côte d'Ivoire to teach cocoa growers about labor practices, farm safety, HIV/AIDS prevention, operational transparency, bean quality and environmental stewardship.

We are a member of the International Cocoa Initiative (ICI), an organization created to combat illegal child labor in cocoa production. ADM’s managers and commercial teams in Côte d’Ivoire have also been trained by ICI to identify and address inappropriate labor practices. Please see our Respect for Human Rights policy for more information. [link]

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

These areas are addressed externally through our Corporate Social Responsibility report and internally via our ADM Code of Conduct, as well as via content on ADM Inside, our corporate intranet.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

ADM has a hotline employees can use to call or email anonymously to report grievances or concerns. Additionally, contract employees can work through their union representatives. ADM also participates in certification systems that include dispute resolution procedures.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

ADM partnered with select stakeholders to develop its Respect for Human Rights policy and is currently developing an implementation plan. This commitment to respect human rights is informed by international law and by the principles of liberty and dignity enshrined in the United Nations Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights. This statement applies to all employees, officers, directors, contract workers and agents of ADM, our divisions and our affiliates in all countries. ADM expects that, when working on our behalf, our suppliers, business partners, agents and consultants will uphold the principles of this commitment.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Our Adoption of a stand-alone human rights policy in May 2014 served as a guidepost as we worked with stakeholders to craft our commitments and the document in which they are contained.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

ADM is currently developing its implementation plan for its Respect for Human Rights policy. We are working with key stakeholders to develop the plan.