JBS ESG Position Statements
I. Responsible Supply Chain, Land Use and Environmental Stewardship
JBS is committed to ensuring that its global supply chain operates in full compliance with environmental laws, land-use regulations, and internationally recognized sustainability standards. The company applies a precautionary and enforcement-driven approach to sourcing, combined with long-term investments in monitoring systems, traceability infrastructure, supplier engagement, and sector-wide collaboration.
Cattle sourcing, deforestation and land-use compliance
JBS maintains a strict policy prohibiting the purchase of cattle from farms associated with illegal deforestation, forced labor, invasion or occupation of Indigenous lands, or areas embargoed by environmental authorities. These requirements are applied across all Brazilian operations, under the Unified Protocol for Monitoring Cattle Suppliers (Beef on Track Protocol). These policies and controls are publicly disclosed in the company’s Sustainability Report.
To enforce these standards, JBS operates an advanced supplier-monitoring system that integrates satellite imagery, georeferenced farm boundaries, and official government databases. Suppliers found to be non-compliant are immediately blocked, and have been excluded from the supply chain due to environmental or legal non-compliance.
Traceability, indirect suppliers and systemic solutions
JBS recognizes that traceability of indirect suppliers represents a structural, sector-wide challenge. To address this risk, the company has invested in scalable and transparent solutions, including the Transparent Livestock Platform, a blockchain-based system designed to share supply-chain information and strengthen indirect supplier oversight.
Environmental remediation, restoration and low-carbon initiatives
Beyond enforcement, JBS invests in initiatives designed to support environmental regularization and sustainable land use. Through its Green Offices Program, JBS provides free technical and environmental assistance to cattle producers, supporting compliance with the Brazilian Forest Code. As of 2024, more than 6,000 hectares had been allocated for recovery through these efforts.
JBS also addresses broader environmental impacts, including methane emissions, through science-based and operational initiatives. These include investments in feed-additive research, large-scale biodigesters that convert methane into renewable energy, and circular-economy solutions that reduce waste and emissions across JBS’s own operations in Brazil, the United States, Canada, Mexico, and Australia. These initiatives are detailed in the environmental performance sections of the Sustainability Report and reflect a focus on measurable emissions reductions and resource efficiency.
Sustainable aquaculture and environmental safeguards
Huon Aquaculture is one of three salmon farming companies in Tasmania and is part of the JBS Australia Group of Companies. In November 2025, the Australian Pesticides and Veterinary Medicines Authority (APVMA), Australia’s federal regulator responsible for assessing, approving and overseeing the safe use of agricultural and veterinary chemicals, granted an emergency permit for the use of florfenicol (FFC) to treat Piscirickettsiosis, caused by the endemic P. salmonis bacteria. FFC has been proven globally to be a very effective treatment for P.salmonis.
Antibiotics are used only when necessary to safeguard animal health and welfare, and under veterinary direction and strictly within regulatory allowances. The salmon industry in Tasmania has used FFC in line with APVMA approvals, supported by robust environmental monitoring requirements.
Huon Aquaculture’s use of FFC remains fully compliant with all current APVMA permit conditions, including stringent environmental sampling and reporting obligations. Huon remains committed to responsible antibiotic use, transparent reporting, and ongoing collaboration with regulators to support sustainable aquaculture and protect surrounding marine ecosystems.
II. People, Human Rights, Labor Practices and Community Impact
Respect for human rights, worker safety, and community well-being is central to JBS’s operating model. The company applies a zero-tolerance approach to forced labor, child labor, discrimination, unsafe working conditions, and violations of Indigenous Peoples’ rights across its own operations and throughout its value chain.
Human rights, Indigenous Peoples and supplier standards
JBS’s Global Human Rights Policy and Code of Conduct and Ethics explicitly prohibit land grabbing, violations of Indigenous land rights, forced labor, and any form of discrimination. Supplier compliance with these standards is mandatory and subject to monitoring, audits, and contractual enforcement. In Brazil, daily geospatial screening cross-checks supplier coordinates against official registries of Indigenous lands and protected areas, and any non-compliant suppliers are immediately blocked.
In parallel, JBS supports social inclusion and sustainable livelihoods in sensitive regions through initiatives such as JUNTOS: People + Forests + Livestock and RestaurAmazônia, which combine traceability, income generation, and sustainable production practices for smallholder farmers in the Amazon region.
Labor practices, worker safety and Covid-19 response
JBS maintains comprehensive labor and safety standards across its global operations. During the Covid-19 pandemic, the company prioritized worker health and safety by investing more than R$3 billion globally in protective measures, paid leave, testing, healthcare coverage, and community support. In the United States and Brazil, these measures included facility adaptations, enhanced ventilation systems, medical partnerships, and extensive workforce monitoring.
JBS continues to maintain occupational health and safety systems, regular audits, training programs, and grievance mechanisms to identify and address labor-related risks. Where concerns have arisen — including allegations related to working conditions, discrimination, or contractor practices — the company has implemented corrective actions, strengthened oversight, and reinforced compliance with labor laws and internal policies.
Child labor, contractors and remediation
JBS enforces a zero-tolerance policy toward child labor. In cases involving third-party service providers, including sanitation contractors in the United States, JBS acted decisively by terminating contracts, strengthening vendor screening, and transitioning sanitation services in-house through JBS Sanitation, established in partnership with the United Food and Commercial Workers International Union (UFCW). This model ensures rigorous employment verification, training, and compliance protocols across all U.S. facilities.
III. Governance, Ethics, Compliance and Transparency
JBS’s ESG commitments are supported by a governance framework designed to ensure effective oversight of environmental, social, and ethical risks. The company’s governance structure integrates sustainability, compliance, and risk management at both executive and board levels.
Ethics, compliance and anti-corruption
JBS maintains a robust global compliance framework aligned with leading international standards, including anti-bribery, anti-corruption, and antitrust laws. Mandatory training, third-party due diligence, internal audits, and confidential whistleblower channels are in place across all operations. The company’s policies prohibit unethical conduct and provide clear mechanisms for investigation and remediation.
Competition, antitrust and legal matters
JBS has faced investigations and legal proceedings related to competition and market conduct in certain jurisdictions. The company consistently maintains that it operates in compliance with applicable antitrust laws and has resolved certain matters through settlements to avoid prolonged litigation, without admission of wrongdoing. These cases have led to strengthened compliance controls, enhanced training, and reinforced governance oversight to mitigate future risks.
Food safety, product integrity and regulatory compliance
Food safety and quality are core priorities for JBS. The company operates under globally recognized food safety systems, including HACCP, GMPs, SOPs, and GFSI certifications. Where regulatory issues have arisen — including temporary trade suspensions or facility-specific findings — JBS has worked closely with authorities to implement corrective actions and restore compliance.
Tax, transparency and public reporting
JBS complies with applicable tax laws in all jurisdictions where it operates and maintains transparency through public reporting and regulatory disclosures. The company’s Sustainability Report, ESG website, and financial filings provide detailed information on policies, performance metrics, and governance structures, enabling stakeholders to assess risk management and progress over time.
Corruption Risk Exposure & Controversies
JBS operates across a large and diversified global platform, encompassing multiple geographies, regulatory regimes, and operational realities. This operating context underscores the importance of maintaining strong, consistent, and continuously evolving ethics, integrity, and compliance practices across the organization, supported by clear governance structures and effective oversight mechanisms.
Over the past several years, JBS has significantly strengthened its global compliance framework, building a program designed to prevent, detect, and respond to ethical and integrity risks across all operations. The framework is anchored in a global Code of Conduct and Ethics, supported by, among other things, anti-bribery and anti-corruption policies, conflict-of-interest and related-party policies, antitrust guidelines, mandatory training programs, and third-party due diligence. These policies are implemented consistently across business units and geographies and are reinforced through regular communication, monitoring, and training cycles.
Risk assessment is a continuous process at JBS. The company regularly evaluates evolving internal and external risks, considering regulatory developments, operational changes, geographic exposure, and sector-specific dynamics. This risk-based approach informs the periodic review and updating of internal controls, policies, procedures, and training content, ensuring that the compliance program remains aligned with the company’s operational footprint and risk profile.
Risk identification and escalation are embedded throughout the organization. Potential concerns are identified through multiple channels, including a global Ethics Line available 24/7, compliance and legal teams, ethics committees, third-party due diligence processes, and ongoing internal reviews. Allegations are investigated in accordance with established procedures and addressed through corrective actions and remediation measures, with oversight from senior management and the Board of Directors.
Governance oversight of ethics and compliance is reinforced by the company’s current board structure. The Global Chief Ethics and Compliance Officer has direct access to the Board of Directors, ensuring independence and direct access to oversight bodies. Ethics and compliance matters are regularly reviewed at board and committee levels, reinforcing accountability and alignment with the company’s governance expectations.
The Company’s dual listing in the United States represents an important milestone in the evolution of this framework. Listing in New York accelerates JBS’s efforts to enhance corporate governance and transparency through adherence to Securities and Exchange Commission requirements, NYSE listing standards, and U.S. securities laws. These requirements further strengthen internal controls, disclosure practices, and board-level oversight, reinforcing the robustness of the compliance environment.
As part of this evolution, JBS operates under a governance structure with a majority-independent Board of Directors, supported by fully independent Audit, Compensation, Nomination, and ESG Committees. These committees play an active role in overseeing financial reporting, risk management, executive compensation, sustainability, and ethics and compliance matters, contributing to effective checks and balances and informed decision-making.
In parallel, JBS has implemented specific governance mechanisms to address areas of heightened risk, including transactions with related parties. All related-party transactions, regardless of value, are subject to prior review by a dedicated Related Party Committee, which operates under its own internal regulations and reports to the Board of Directors. The committee oversees applicable policies, approval processes, and disclosures to ensure that transactions are conducted transparently, on market terms, and in the best interest of the company.
Taken together, the strengthened compliance controls, continuous risk assessment processes, and enhanced governance framework associated with the U.S. listing further support JBS’s efforts to maintain high standards of integrity, transparency, and accountability across its global operations.
Company Response to Governance and Compliance Controversy
Brazil and United States: Historical investigations and plea agreements
The matters referenced in this controversy stem from investigations launched in Brazil and the United States in 2017 involving J&F Investimentos S.A., the controlling shareholder of JBS, and certain group executives. These events date to that period and should be evaluated based on their current legal, regulatory, and governance status.
In Brazil, J&F entered into a leniency agreement with the Federal Public Prosecutor’s Office in 2017 and remains in full compliance with its terms. The reviews and investigations provided under the agreement, conducted by Brazilian authorities and independent third parties, were completed without identifying any ongoing irregularities or unresolved liabilities.
In 2018, investigations conducted by Cleary Gottlieb Steen & Hamilton LLP and audited by KPMG, at the request of Brazil’s National Bank for Economic and Social Development (BNDES), confirmed that no irregularities occurred in transactions between J&F and BNDES. The Federal Court of Accounts also completed its review and found no wrongdoing or losses attributable to JBS or J&F in connection with those transactions.
Separately, allegations of insider trading related to the same period were examined by Brazilian courts and by the Brazilian Securities Commission. These cases were decided on their merits and resulted in the acquittal of all executives involved. There are currently no convictions, sanctions, or restrictions in force against Wesley Mendonça Batista or Joesley Mendonça Batista.
In the United States, J&F entered into an agreement with the U.S. Department of Justice in October 2020 covering the same facts addressed in the Brazilian leniency agreement. The resolution included financial penalties, enhancements to compliance and governance programs, and other obligations, all of which were fully and timely satisfied. Separately, JBS, Wesley Mendonça Batista, Joesley Mendonça Batista, and J&F reached a settlement with the U.S. Securities and Exchange Commission, also in October 2020, which was successfully and timely concluded.
There are currently no pending criminal proceedings in Brazil or the United States involving Wesley Mendonça Batista or Joesley Mendonça Batista related to the events of 2017. No judicial restrictions, sanctions, or disqualifications apply to either individual.
From a governance perspective, Wesley and Joesley Batista serve as non-executive members of the Board of Directors representing the controlling shareholder. They do not hold management roles. Their participation takes place within a governance structure that includes a majority of independent directors, independent board committees, and a professional executive leadership team, in line with international best practices for companies with controlling shareholders.
Accordingly, ESG assessments that reference these matters or flag individual board members are reflecting historical events rather than current legal exposure or unresolved governance risks. The company considers these issues fully addressed, with governance and compliance frameworks significantly strengthened over time.
Business Ethics Controversies
Pilgrim’s Pride Corporation, United States: Poultry Antitrust Matters
JBS acknowledges the resolution of legal matters involving Pilgrim’s Pride Corporation related to allegations of price-fixing in the U.S. poultry industry that relate to past conduct. These matters were addressed through the applicable legal process, including a criminal resolution with U.S. authorities.
Pilgrim’s Pride and JBS maintain a commitment to ethical business practices and compliance standards. JBS operates a global compliance framework that includes a dedicated Antitrust Policy, a global Code of Conduct and Ethics, mandatory training programs for team members, and monitoring activities conducted by the Ethics & Compliance Department. These policies and controls are designed to align with applicable legal and regulatory requirements.
In addition, JBS has established procedures for training, oversight, and due diligence intended to prevent and detect misconduct across its business units. Team members are expected to comply with the Code of Conduct, and violations are addressed through established disciplinary processes.
United States and Canada: Beef Antitrust Investigations and Civil Litigation
With respect to allegations of anti-competitive conduct in the U.S. and Canadian beef markets, JBS denies wrongdoing and maintains that it has operated in compliance with applicable antitrust laws. To avoid the cost, burden, and uncertainty associated with prolonged litigation, JBS USA agreed to a USD 25 million settlement in a multidistrict antitrust litigation involving commercial and institutional indirect purchasers, covering the period from 2015 to 2023.
The settlement was reached without any admission of liability or wrongdoing. As part of the resolution, JBS committed to cooperating in ongoing proceedings against non-settling parties by providing non-privileged documents and data, in accordance with applicable legal requirements.
JBS maintains a global compliance framework intended to promote fair competition and mitigate antitrust risks. This framework includes a dedicated Antitrust Policy, periodic Code of Conduct and Ethics training for salaried employees, targeted guidance on interactions with competitors and the handling of commercially sensitive information, and oversight by the Ethics & Compliance Department. These controls are supported by periodic risk assessments, audits, and third-party due diligence processes.
Brazil and United States: Government Investigations and Plea Agreements
The matters referenced in this controversy relate to investigations initiated in Brazil and the United States between 2016 and 2017 involving J&F Investimentos S.A. These matters date back to that period and should be assessed considering their current legal, regulatory, and governance status.
In Brazil, J&F entered into a leniency agreement with the Federal Public Prosecutor’s Office in 2017 and is compliant with the terms of this agreement. Reviews and investigations provided for under the agreement, conducted by Brazilian authorities and independent third parties, were concluded without identifying ongoing irregularities or unresolved liabilities. Investigations commissioned by Brazil’s National Bank for Economic and Social Development and conducted by independent advisors confirmed that no irregularities occurred in transactions between J&F and BNDES. The Federal Court of Accounts also concluded its review and did not attribute wrongdoing or losses to JBS or J&F in connection with these transactions.
Separately, allegations of insider trading related to the same period were reviewed by Brazilian courts and by the Brazilian Securities Commission. These matters were assessed on their merits and resulted in the acquittal of all executives involved, with no convictions, sanctions, or restrictions currently in force against Wesley Batista or Joesley Batista.
In the United States, J&F entered into a plea agreement with the Department of Justice in October 2020 regarding the same facts covered by the leniency agreement in Brazil. Separately, J&F and JBS reached a settlement with the U.S. Securities and Exchange Commission, also in October 2020. The agreements included financial penalties, enhancements to compliance and governance programs, and periodic reporting on the enhancements to the Department of Justice and the Securities and Exchange Commission). J&F and JBS timely fulfilled all terms of the agreements, and the matters were formally concluded with no ongoing obligations or enforcement actions.
There are currently no pending criminal proceedings involving Wesley Batista or Joesley Batista in Brazil or the United States related to the facts described in 2017. No judicial restrictions, sanctions, or disqualifications apply to either individual.
From a governance and compliance perspective, JBS has strengthened and institutionalized a global ethics and compliance framework intended to prevent, detect, and address misconduct across its operations. The company maintains an anti-bribery and anti-corruption compliance program aligned with applicable international laws and standards, including the U.S. Foreign Corrupt Practices Act, Brazil’s Clean Company Act, and the UK Bribery Act. Company policies prohibit offering, giving, soliciting, or accepting anything of value intended to secure an improper business advantage.
Compliance protocols are embedded throughout JBS’s operations. Ethics, anti-corruption, and compliance training is provided to employees, supported by periodic refreshers and targeted programs for higher-risk functions. The Ethics & Compliance Department oversees risk assessments, monitoring activities, and internal investigations, with established procedures for escalation, remediation, and disciplinary action when violations are substantiated.
Third-party relationships are subject to risk-based due diligence prior to engagement and throughout the relationship lifecycle. Contractual safeguards are applied based on risk profile and engagement scope and may include compliance clauses, audit rights, and termination provisions in the event of non-compliance. Employees and external stakeholders have access to confidential Ethics Line available on a continuous basis, supported by a global non-retaliation policy and independent review processes.
At the governance level, ethics and compliance oversight is reinforced through the company’s board structure, which includes independent directors and dedicated board committees. The Global Chief Ethics and Compliance Officer has direct access to the Board of Directors. The company’s dual listing on the New York Stock Exchange and Brazil’s B3 subjects JBS to enhanced disclosure, internal control, and governance requirements under U.S. and Brazilian securities regulations.
Accordingly, references in ESG assessments that identify these matters or flag individual board members reflect past events rather than current legal exposure or unresolved governance risks. The company considers the underlying issues addressed and closed, with governance and compliance structures strengthened over time.