While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The proposed project is essentially supporting existing farming and processing facilities together with a significant increase in the number of contract/pre-financed growers. Existing SFR operations are regulated by national implementation of comprehensive European Union (EU) legislation, including E&S and animal welfare requirements. Likewise, all future contract growers are likely to be sourced from countries governed by EU law and internal policy requirements of Smithfield Foods: please see PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources for further details.

The key E&S risks considered were SFR’s corporate EHS management system and technical capacity for its effective implementation, monitoring and performance to date in terms of EHS and social management; raw material, water and energy use and efficiency (focus on feedmills and plant); solid waste management and disposal (slurry handling and disposal at farms), wastewater treatment (focus on processing plant); opportunities for energy recovery (heat exchangers, biogas recovery); labor and working conditions; animal husbandry, disease control and other aspects of animal welfare, biosecurity and assurance of food safety, certification to sustainable management practices and management of third-party contractors and primary suppliers.

The project has been classified as category B according to IFC’s 2012 Policy on Environmental and Social Sustainability. Such projects are defined as those which have business activities with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures.

The project was assessed against all Performance Standards and the following determined as non-applicable at this time: PS5 on Land Acquisition and Involuntary Resettlement as no land purchase is anticipated; PS7 on Indigenous Peoples as none were identified as being impacted by the project and PS8 on Cultural Property as none is known to be associated with existing operations. Through PS1 on Assessment and Management of Environmental and Social Risks and Impacts, SFR will map any future projects against the Performance Standards and where gaps are identified, implement mitigation and monitoring plans accordingly. PS3 on Resource Efficiency and Pollution Prevention lists applicable WBG guidelines for the project.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

E&S Assessment and Management System. SFR’s code of business conduct includes an environmental policy statement, together with policies on occupational health and safety, animal welfare, employment practices, social responsibility and quality – hence it is also referred to as the Integrated EHS Management System Policy. Animal welfare policy and implementation is addressed in the section for PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.



Identification of Risks and Impacts. All greenfield operations (those constructed since Smithfield purchased Comtim in 2004) were subject to environmental impact assessment in conformance with national implementation of the European Union (EU) Directive on such. Informational data is compiled annually and submitted to the Romanian authorities (Environmental Protection Agency within the Environment Ministry). All operations are subject to an annual, internal environmental audit in compliance with Smithfield’s environmental policy and a legal compliance audit is undertaken every three years by an international consultancy group as part of parent company (Smithfield Foods) assurance program. Both the plant and the farms are certified to ISO 14001 for environmental management systems, which includes a requirement for identification of significant ‘aspects’ (risks/impacts). Surveillance audits to maintain certification are undertaken annually. All but two SFR facilities (a boar stud and isolation farm) are regulated under national implementation of the Integrated Pollution Prevention and Control (IPPC) Directive, which includes assessment, management and monitoring requirements. Further details are provided in the section for PS3: Resource Efficiency and Pollution Prevention.



Management Programs. As described in the preceding sections, SFR operations are certified to ISO14001 and this defines requirement for establishing sector-specific management programs, with formalized working procedures (including action plans to address audit findings), CAPEX and other programs to improve E&S performance, annual environmental training plans for staff (which are also extended to contractors) and use of key performance indicators across environment (see PS3 section) and health and safety (see PS2 section). ISO18001 certification is addressed in PS2 and ISO22000 in PS4.



Organizational Capacity and Competency. SFR has dedicated professionals to lead work on E&S management. At the plant, there is an Environment Management System Manager who joined the company in 2008. For the farms, there is an Environmental Department Manager, who joined in 2006. Both report directly to the respective General Managers of the businesses and documented job descriptions for both positions were provided to IFC. Beneath these dedicated and full time positions identified in SFR’s organogram, there are environmental and OHS teams and committees to support full implementation of the integrated po
licy and related management program.



Training. An extensive range of E&S training opportunities are provided each year to build staff competency, including induction training (hygiene, animal welfare, biosecurity and legislative requirements), waste management, water protection, chemical management, spill response and management system components and responsibilities. Additional training detail is provided in the PS2 (health and safety) and PS6 (animal welfare) sections of this document.



Emergency Preparedness and Response. Emergency preparedness and response is extensively governed by national legislation and the company’s commitment to various ISO certifications (see above). At the slaughterhouse, fire, ammonia release, carbon dioxide release and wastewater treatment failure are key emergency scenarios. The ammonia bulk tank has level sensors, odor detection and fully automated monitoring. The carbon dioxide bulk tank has sensors that are maintained by the supplier. A fire water bulk storage tank is maintained, fed by water from the wells. One major simulation exercise is undertaken annually, together with fire protection authority. Quarterly drills are undertaken at specific areas of the plant to test procedures e.g. ammonia storage, fire in the packaging warehouse. At the farms, fire is the highest risk scenario. Hand held extinguishers are located approximately every 20m in the pig housing units, plus a fire ring main. There are quarterly emergency drills to test the response procedure. The two feed mills have dedicated life and fire safety officers. At the Padureni feedmill, pipework is routed on the exterior where possible, including blow out panels in order to reduce the fire and worker injury risk. For analysis of risk from emergency situations to the public, please see section on PS4: Community Health, Safety and Security.



Monitoring and Review. E&S performance review meetings are held monthly. Both environmental leads are also members of the Smithfield Foods corporate compliance committee, which requires quarterly E&S data submissions by all businesses globally and there is typically an annual meeting so that best practices can be shared. There is also a Smithfield Foods corporate award for environmental initiatives, for which the plant (specifically the slaughterhouse) was recognized in 2012 for water reduction initiatives.



Additional monitoring and review occurs through ISO 14001 surveillance audits and the monthly veterinarian inspections that are detailed in the PS6 section of this document. The National Environmental Guard – the inspection agency of the Environment Ministry - typically visits SFR facilities one or two times per annum.



Stakeholder Engagement. Due to the zoning/minimum distance regulations specified under Romanian law for pig livestock operations (including processing plants) and Smithfield’s own biosecurity protocols, SFR operations do not generate any adverse environmental risks
to surrounding communities. As such, there is no directly affected community. There are a handful of exceptions to this (e.g. for renovated farms constructed before zoning rules were strengthened), but these tend to be isolated houses rather than a community per se that could be considered as affected. SFR however makes significant efforts to communicate with potential stakeholders, including the documentation provided on its website and the numerous community outreach initiatives that it undertakes (also described on the website).



External Communications and Grievance Mechanism. SFR provides a number of contacts on its website to facilitate communication with external parties. The public can also use the Smithfield hotline, as described in the PS2 section of this document. Rather than make a complaint to the company directly, complainants have contacted the relevant regulatory agency instead. The nature of the most recent complaints for the plant and the farms in the last twelve months were both odor related. In both cases, the National Environmental Guard scheduled inspection visits shortly after the complaints were received. No follow up actions were requested and there are no outstanding complaints at the time of the IFC visit.

Working Conditions and Management of Worker Relationship

As of June 2014, SFR employed 687 workers at the plant and 1,064 at the farms. Approximately 22% of current plant workers are engaged through a third party (employment agency). See Workers Engaged by Third Parties for further details.



Human Resource Policies and Procedures. SFR has a mature set of human resource policies and procedures, based on its parent company protocols for this issue. Key documents include a company code of business conduct and an ‘internal regulation’ that assures compliance with the Romanian Labor Code (which in turn conforms to EU expectations). This is underpinned by four core procedures for payment/salary; recruitment; training and development (including performance evaluation). The standard working week is forty hours (5x8hours) with a maximum of eight hours overtime. SFR employees average 170 hours/month. All workers are provided with the code of business conduct and also employment specific information that documents their rights, hours of work, benefits and other employment aspects.



Working Conditions and Terms of Employment. The internal regulation and a collective work agreement for the plant define the working conditions and terms of employment, including principles of non-discrimination, minimum age and grievance processes. These are reviewed and renegotiated every two years.



Sourcing labor in the Timisoara area is highly competitive, with regional unemployment currently at 2%. This also increases staff turnover rates for all regional businesses. New recruits enter on two month probationary periods at the plant. Once they have entered the mainstream workforce, employees engage in a formal review process which includes volunteering and/or selection for skills training or different responsibilities within the plant or farm. Salaries are competency based (see PS6 section for further details on how this operates at the farm level).



As of June 2014, SFR employed seven migrant workers (six from India and one from Moldova). Romanian law requires that migrant workers are paid based on the average national (not regional) salary, which is higher.



SFR does provide some accommodation for plant workers. It comprises a single dormitory, typically four beds to a room and 90 person capacity. Eligibility depends on distance travelled from home – the longest gaining priority. There is approved CAPEX to upgrade the structure in the current fiscal year. SFR is also looking to source additional accommodation associated with vocational training schools in the region, where enrollment numbers have declined drastically. SFR will ensure that all the minimum services specified for worker accommodation by this Performance Standard will be met.



Workers Organizations. There is one main collective work agreement serving the SFR workforce at the plant, with three workers representatives. There have been no court cases or other industrial action up to d
ate. Outside the routine negotiation of the collective bargaining work agreement described above, the most recent company negotiation with the group was focused on paying higher premiums for week-end work and the preceding one focused on premiums to be paid for those routinely lifting greater than 25kg in their jobs; these were agreed and implemented.



Non-Discrimination and Equal Opportunity. The business code of conduct (see Human Resource Policies and Procedures) clearly lays out principles on non-discrimination and equal opportunity. Gender balance in the workforce is 30% women in the plant and 34% at the farms. Woman are eligible to apply for all roles/tasks, including those involving heavy labor (see heavy lifting premium reference in Workers Organizations for example), but SFR management stated that in spite of full implementation of an equal opportunities policy, the majority of persons applying for operational work at SFR are men.



Grievance Mechanism. Grievance is covered by the code of business conduct, with SFR employees able to express grievances through five routes: direct to supervisor; direct to the supervisor’s boss; to the human resources department (most common); to the Smithfield Food hotline (free of charge and staffed by the internal audit department) or via anonymous drop box. SFR management reported no unfair dismissal cases to date, nor any unresolved grievances. At the time paychecks are delivered, staff from the human resources are readily available to employees and have easy access to them for any questions regarding salary, benefits and deductions.



Protecting the Workforce. The minimum work age is eighteen. No forced labor is associated with SFR operations. 

Occupational Health and Safety. SFR has formalized policies and procedures for occupational health and safety (OHS), which address both corporate and legislative (EU) requirements. These are summarized on the SFR website. In 2012, both the plant and the farms (including feedmills) were certified to OHSAS 18001 (the farms being a group level certification). Both plant and farms operate OHS committees which meet quarterly to review overall performance, including near misses, incidents and accidents. The committee structure includes worker representatives. The safety management systems in operation across SFR operations include hazard identification and workplace risk assessment, prevention planning, procedures for higher risk activities (e.g. lock out-tag out, work in confined spaces), accident and near miss investigation and occupational health monitoring. Safety audits are held on a minimum monthly basis. These are reinforced by surveillance audits for the 18001 certification. Full time Safety Officers are in post for the plant and for the farms. All staff is evaluated two times a year for OHS risk, with more detailed assessment undertaken for higher risk activities. Health and safety training is provided to employees and contractors upon induc
tion and thereafter on a monthly/refresher basis.



Accident records for 2013 indicate three incidents in production: two cuts (one in deboning, one on the killing floor) and one ‘slip and trip’ in meat processing. At the farms, there were four recorded lost time accidents, one of which was serious (eye injury from a high pressure hose). The incident was investigated (internally and by the Romanian Labor Authority) and the root cause identified as non-compliance to an established procedure (on tasks that require protective eyewear). The incident was subsequently used in refresher training to farm employees on the use of personal protective equipment.



At the feedmills, the most significant risk is from vehicle (tanker) movements in peak delivery season. Silos are fitted with pyramid/auger bases to reduce the volume of residue and in doing so, reduce the frequency of restricted workspace cleaning. The overall lost time incident frequency ratio for SFR in 2013 was 2.3 per million hours worked, well below the international benchmark for the animal production sector (10.0).



Workers Engaged by Third Parties

Due to worker scarcity in the region, SFR’s plant uses two employment agencies to help recruit staff (as the agency have effective networks at village level in the region). Contracts and payroll remain with the agencies, but employees receive the same employment terms as directly hired staff, with the exception of notice period (for retrenchment scenarios). This is in line with the requirements of this Performance Standard.



Supply Chain

The SFR supply chain is not considered to be at risk from child labor, forced labor or significant safety issues, given that the principal raw materials purchased are corn and wheat (from Romanian farms subject to national implementation of EU Directives) and soy through well-established international commodity brokers.

Three World Bank Group (WBG) guidelines are referenced in relation to this investment: those for Mammalian Livestock Production (farms and feedmills); Meat Processing (processing plant) and the General EHS guideline (all operations).



Resource Efficiency

SFR maintains detailed records of energy, water and other resource use. The dominant energy sources are electricity (from grid) and natural gas (plant) and LPG (farms). No biogas is generated from the slurry at farms: the potential for such will be assessed in collaboration with IFC and concluded as part of the first annual monitoring report submission.



The main electrical energy consumers in SFR operations include lighting, machinery and refrigeration at the plant and lighting and heat at the farms. The Padureni feedmill, as a relatively recent design, includes process energy recovery/pre-heating for the boiler water, thus reducing the fuel demand to raise steam.



The annual greenhouse gas emissions associated with SFR operations are estimated in excess of 100,000mtpa. As for all IFC investments where emissions exceed 25,000mtpa, the client will quantify GHG emissions on an annual basis and in accordance with an internationally recognized methodology and good practices. The data will be submitted as part of the annual monitoring report. Smithfield Foods already undertakes GHG assessment at the corporate level, with a global target to reduce GHG emissions by 10% over (normalized) 2008 figures by the end of fiscal year 2016.



Raw water for the plant is sourced from five wells around the site, each with an abstraction permit. There are no other known users of the source aquifers and no restriction on SFR’s use of the aquifers has occurred to date (i.e. no periods of water stress). In 2013, the wells provided just below 350,000m3 of water – or 3.95m3/mt of final product, which is in the mid-range of the benchmark specified in the WBG meat processing guideline (1.6 – 8.3m3/mt). SFR has an internal target to reduce the volume of water used to process one pig from 360l to 300/l (i.e. a 17% reduction). The farms also typically have their own wells, with cumulative use around 1.9 million m3 per annum.



In 2009, SFR started to implement a utilities consumption management program which focuses on water, electricity and gas usage. The program is target driven, with quarterly reviews of program performance.



Pollution Prevention. As described in PS1, all but two SFR facilities (a boar stud and isolation farm) are regulated under national implementation of the IPPC Directive, which specific emission limits in line or below those specified in the applicable WBG guidelines .The annual IPPC report submission includes data across all emission types (air, water, solid, hazardous). SFR management stated that to date, no facility had failed to meet its permit conditions for pollution prevention. The boar stud and isolation farm have local permitting requirements.



Key point sources
for air emissions are boilers (plant, including rendering plant and feed mills), carcass incinerators (farms – LPG fuelled) and slurry tanks (farms). During the site visits, no visible air emissions or strong odors were noticeable and SFR management stated that only a small number of complaints around odor had ever been received - primarily from residents of recently constructed, individual housing units constructed close to the plant boundary where the waste water treatment plant (WWTP) is located.



The plant is served by WWTP that uses biological treatment and a bio-filter to treat effluent and related odor. There are three types of routine monitoring – internal, by a third party accredited laboratory (a permit requirement) and unannounced by authorities. SFR management reported that the only parameter that the WWTP has difficulties in meeting was phosphorus, but the introduction of ferric chloride dosing had resolved the issue. The IPPC annual reports that were reviewed verify this statement. Approximately 18m3 of sludge is removed from the WWTP on a daily basis: once centrifuged to remove water content, the solid fraction is disposed to licensed landfill. Treated water from the WWTP is discharged to surface water (river). The capacity of the WWTP is sufficient to handle an increase in the annual number of pigs being processed.



At the farms, slurry drains from under the pig housing units and is pumped into steel storage tanks (5,000m3 and 10,000m3 capacities). The tanks have concrete bases to reduce seepage risk to soil. In application season (mid-January to the end of October), tankers transport the slurry for spreading on local farmland as soil conditioner.



Very little solid waste is generated at the plant. Due to the rendering facility, there is close to zero loss from the processing of the pigs, with solid waste therefore limited to packaging, domestic wastes and the sludge from the WWTP (see above). At the farms, additional solid waste streams include ash from the incinerators (approximately 190mtpa) and packaging related to medicines.



Hazardous wastes are primarily associated with the farms and include medical waste (catheters, spent or out-of-date medicines, needles) and asbestos cement roofing tiles (approximately 52mt in 2013). Medical waste is incinerated by a licensed contractor. The asbestos cement tiles – present on the older farms - are removed and stored and disposed of by appropriately authorized contractors, with replacement tiles being cement composition only.



The main refrigeration system at the plant uses ammonia and glycol (in internal areas to minimize risk to workers). The majority of other smaller chiller systems use R404A. A bulk tank of carbon dioxide is also present at the plant. All bulk tanks are constructed and alarmed in accordance to the requirements of the IPPC Directive.

Community Health and Safety. Aside from some recently constructed individual housing units close to the plant (see WWTP description in PS3), the SFR facilities (plant, feedmills and farms) are not associated with affected communities, due to zoning/minimum distance regulations specified under Romanian law and Smithfield’s own biosecurity protocols. The most significant potential threats to communities from the plant are ammonia and carbon dioxide bulk storage at the plant: these are subject to strict monitoring and emergency response protocols developed in collaboration with the emergency and fire protection authorities. In case of WWTP failure, the plant also has an emergency retention pond in order to avoid discharge to the river.



At the farm level, the bulk storage of slurry is the most significant risk but the most tanks are of steel and concrete construction except for 2 farms, fenced/secured, monitored and patrolled. If a tank was to breach, the slurry would pool in the area around the tanks (the boundary of the tank area is typically slightly raised to provide containment). No breach or overtopping has ever occurred and is considered highly unlikely. Drinking water aquifers are typically more than 150m below the surface and therefore pollution of such an aquifer from a breach is not considered likely. At farms where slurry stored in impermeable lagoons, farm managements monitor groundwater periodically against any contamination risk.



The PS1 section has further details on emergency preparedness and response.



SFR operates strict biosecurity protocols to safeguard the public, employees and the pigs from disease. Farms maintain a bio-barrier through physical isolation, with feed, fuel, other materials, staff, contractors, guests and pigs delivered or moved in ways to maintain the barrier (e.g. feed tankers can access delivery pipes from outside the bio-secure zone, shower-in, shower-out protocols for staff). Biosecurity audits are routinely undertaken by both SFR and veterinary inspectors.



SFR operates to a full food safety and traceability regime, with the plant and farms certified to ISO 22000 (HACCP). The plant is also certified to the International Food Standard (version 6). The National Sanitary Veterinary Agency audits monthly all pig farms for (1) vaccination; (2) animal health; (3) animal welfare, and (4) traceability.



All SFR facilities contract security services, which are limited to uniformed guards sourced from licensed companies. Guards are not armed and their security protocols are verified by both SFR and the local police.

Protection and Conservation of Biodiversity. SFR operations are a mix of existing farms (and one feedmill) and new (greenfield) developments. All have been established on modified (agricultural) land, with all greenfield sites subject to environmental impact assessment in accordance to EU standards. No areas of natural habitat, critical habitat or those subject to international recognition or legal protection are known to be have been adversely affected by SFR operations.



Similarly, no adverse impacts to priority ecosystem services for affected communities have been identified. For slurry application, SFR contracts local agricultural institutes to undertake soil analysis to ensure maximum application limit (170kg N/hectare) is not exceeded. Upper (perched) groundwater monitoring is also undertaken every six months to monitor for elevated nitrate concentrations.



Sustainable Management of Living Natural Resources. SFR is certified to a number of ISO related standards (see PS1) and also adheres to a number of internal and corporate policies that address sustainable management of living natural resources. The key policy framework is provided however by national implementation of EU legislation, including that for animal welfare (EU Council Directive 91/630/EEC (as amended).



SFR operates a group housing model for its farms, with sow crates limited to use for insemination, delivery and 28 days thereafter (before the piglets are weaned). SFR employees working at the farms are enrolled in a professional development program for animal husbandry, with four tiers available and a salary increase linked to certification to each successive level. Codes of conduct for good animal husbandry were observed at the farms visited, including posters and other aids to help identify illness, stress or other welfare issues.



The farms visited were a mix of renovated and new build, with natural light and ventilation and additional cooling measures available (misters, water hoses, fans and addition of betane to the sows’ diet to reduce heat stress). Due to the temperature variation experienced between summer and winter, the farm design has to compromise between the two. At all farms, detection of low temperature is automatic and triggers heating units; for high temperature, it is automatic at new farms (curtains, fans and misters at the sow farms) and manual at old (additional window and roof vents) SFR will monitor temperature range/trends in the regions where farms are concentrated on an annual basis to identify emerging trends (e.g. increased incidence of extreme weather events due to climate change). In due course, this may warrant changes to the design of pig housing. SFR will submit this regional temperature extremes analysis as part of its annual monitoring report to IFC.



As required by the EU Directive for animal welfare, the provision of ‘toys’ in group housing was evident (suspended wooden blocks, balls). Joint water and food dispen
sers are used extensively – which reduces waste (dropped pellets turn to mash in the catch tray of the dispenser and then consumed) and also provides a mental distraction. Noise levels were low, with no obvious signs of fear or other stresses exhibited by the pigs. Daily inspections identify sick or injured individuals, which are then isolated and treated or euthanized depending on the extent of individual suffering.



Pigs are transported to the plant (slaughterhouse) at times to avoid temperature extremes, whenever possible, and then rested in group housing targeting at least 2-4 hours. They are maintained in groups, including gondola loading for the stunning process (using carbon dioxide immersion).



As stated in PS4, EU requirements mandate monthly inspections (by independent veterinarians) at all pig farms for (1) vaccination; (2) animal health; (3) animal welfare and (4) traceability. This provides the independent verification process sought by this Performance Standard.



Supply Chain. The principal agricultural products purchased are corn, wheat and soy for the feed mills. Corn and wheat are sourced locally from long established farms on agricultural land. Soy is purchased through major commodity traders with whom Smithfield Foods holds global relationships, although SFR undertakes its purchasing directly. A Supplier Code of Conduct is part of corporate and management policies and to ensure that SFR supplier purchasing fully meets the expectations of PS6, SFR will develop and implement a procedure to ensure its primary suppliers are (1) fully aware of and commit to the Supplier Code of Conduct and (2), provide satisfactory assurances soy is not sourced from regions where there is a risk of significant conversion of natural and/or critical habitats. This is captured in the E&S Action Plan.



SFR will increasingly take ‘outside’ (contract grower) pigs for slaughter and processing. As with its own farms, contract growers within the EU will be subject to independent inspection by veterinarians and any pigs sourced from outside the EU (e.g. Serbia) will also be subject to similar inspection through importation regulations.

SFR’s website provides details of the wide range of community related initiatives that it undertakes, including programs that focus on environment, education and social and cultural aspects.

Cristina Bodea
Sustainability Director, Smithfield Romania
e-mail cristina.bodea@smithfield .ro
Phone +40-256-404-900
Fax +40-256-400-401
Mobile +40-728-10-574

S C Smithfield Romania SRL
Str Polona Nr 4
300523 Timisoara
ROMANIA

Broad Community Support is not applicable for this project

Smithfield Roman(34984) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
SFR will develop and implement a procedure to ensure its primary soybean meal suppliers are (1) fully aware of and commit to the Smithfield Foods Supplier Code of Conduct and (2), provide satisfactory assurances soy is not sourced from regions where there is a risk of significant conversion of natural and/or critical habitats.	30-Sep-2014	Completed	Completed	12/26/2014