To our stakeholders:
As you will see in the attached report, Louis Dreyfus Commodities has made significant progress in 2012. On behalf of LDC, I am very pleased to reaffirm the Company’s support of the Ten Principles of the United Nations Global Compact in the areas of Human rights, Labour, Environment and Anti-Corruption.
In this Annual Communication on Progress, we describe a number of actions and initiatives taken by the Company during the course of the last year (our second as a member of the UN Global Compact); actions which demonstrate our commitment to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.
I am particularly committed to the principle of setting the tone from the top. As an example, I was personally delighted during the course of the year to formally launch the first of a series of e-learning modules being developed internally to train LDC staff with regard to our Code of Conduct, which specifically covers many of the UN Global Compact Principles. This first module is training our entire staff.

Sincerely Yours
Serge Schoen
Chief Executive Officer
Louis Dreyfus Commodities

As per our previous submission, Louis Dreyfus Commodities’ start point on human rights is to ensure as a minimum that we operate within the law in all of the territories where we have a business presence. Our Sustainability Policy specifically targets certain human rights elements such as child and forced labour, as well as any form of discrimination as alien to our global culture, and therefore completely unacceptable. Where new ventures have been entered into where perceived risk on this topic may exist, we have been quick to apply and educate on our existing policies to new colleagues, or write new policies to address specific challenges, as was the case for example with our new palm oil joint venture in Indonesia.
The Louis Dreyfus Commodities Code of Conduct states that “Discrimination including based on sex, race, origin, religion, age, disability, sexual orientation or beliefs, is in contradiction with our values, history, culture and economical interest, and will not be accepted.”

During the course of the last reporting year, we have developed and launched an e-learning module covering the Louis Dreyfus Commodities Code of Conduct. This module is the first of as series to be launched throughout the Group, and is a mandatory training for the 5,000 staff within the Company.
In addition, during the course of the year, a new committee was created specifically to consider Sustainability and Trade Practice issues in all fields but in particular in relation to any new projects that the Company is planning to invest in. Part of the brief of this committee is to study and assess any actual or potential human rights issues that may arise as a result of LDC investment.

The evolution of the markets in which we operate, and the escalating requirements of key clients in many domains, result in our industrial facilities being subject to rigorous annual external audits, many of which have a human rights assessment as a constituent element.
In addition, increasing volumes of the products that we produce and trade require annual certification in order for Louis Dreyfus Commodities to maintain a “licence to operate” in certain sectors – the issuance of these certificates invariably depend on external verification that LDC processes and practices do not violate human rights in any way.

The Louis Dreyfus Commodities Sustainability Policy targets to ensure that LDC and our business partners are not involved in any activity involving forced, compulsory or child labour. Specific reference is made in the Policy to ILO Convention 138 on child labour and young workers. The safety and health of our workforce is also an element that features prominently in the Policy, a message that is reinforced at an annual global Safety Day sponsored by the Executive Management and held each March at every Company-owned facility around the world.
In addition, the Louis Dreyfus Commodities Code of Conduct states that “We strongly condemn child or forced labour and pro-actively apply the UN recommendations in this respect. We promote relations with providers, business partners and sub-contractors operating under the same values.”

The e-learning module mentioned in the previous section also trains our 5,000 staff in the unacceptability of child labour, either directly or indirectly.
The process we described in our last Communication on Progress to encourage the various commodity trade Associations to adopt a Human Rights clause covering child and forced labour in their standard contract terms continued during the last reporting period. Unfortunately, all the Associations we contacted as part of this endeavor responded negatively to our request, principally for technical reasons related to the difficulty in defining arbitration criteria for such a clause. This has prompted us to adopt a different approach in seeking to have the same Associations adopt a supportive stance on Human Rights through their articles of incorporation or equivalent. This process is ongoing.
During the course of the last reporting year, we participated in a meeting chaired by the International Labour Organisation International Programme on the Elimination of Child Labour (ILO IPEC) that formally launched the ILO Child Labour Platform, a forum previously set up and chaired by the Dutch Sustainable Trade Initiative (IDH). We anticipate through continued participation in this forum to be able to learn about and implement new developments and best practices on the subject of child labour into our standard business practice.

The e-learning module mentioned previously provides the responsible corporate functions with the results achieved by the targeted recipients of this training, thereby ensuring that all those who may require supplemental training on labour issues receive it.
Again, the external audits that we participate in at our industrial facilities either at the request of specific clients or as part of a certification process for a particular product or commodity invariably include a study of our labour practices and Human Resources records to attest to our legal compliance in that particular territory, as well as our observance of internationally accepted practices.
The internal controls in use by our global Human Resources network reported no breaches of policy in relation to forced or child labour during the course of the last reporting period.

The management of Louis Dreyfus Commodities environmental impacts is governed by the Company’s Sustainability Policy, and by the Safety, Health and Environment Policy. These policies commit the Company to operate across all business units in an environmentally sustainable manner, and establish objectives to continuously improve our environmental performance at all of our industrial facilities and business units.
As well as our internal measures to control and improve our environmental impact, Louis Dreyfus Commodities is an active member of various commodity “roundtables” that have as a large part of their objectives good environmental practice and improvement. In addition to our existing membership of the Roundtable for Sustainable Palm Oil (RSPO) and The Roundtable for Responsible Soy (RTRS), the Company joined the following roundtables during the course of the reporting year;
The Sustainable Rice Platform – a new roundtable co-founded by UNEP and The International Rice Research Institute where Louis Dreyfus Commodities, as a founder member, sits on the inaugural Advisory Committee. In particular, more efficient water usage and fertilizer application are specific targets this roundtable seeks to address.
Bonsucro – a roundtable for sugar cane that promotes reducing the environmental impact of this increasingly demanded commodity.
The Better Cotton Initiative – this entity seeks to ensure that uniform good agricultural practices are adopted in the global production and transportation of cotton in order to minimize environmental impact as one of many stated objectives.

In our last Communication on Progress, we reported on our plan to measure four environmental elements, namely greenhouse gas emissions, water usage, energy consumption and waste generation. That process of measurement is now largely complete at all of our industrial units, which should allow us to issue our first report on the measurement of these elements for the calendar year 2012. We anticipate that this report, which should be published in time to be posted as our Communication on Progress for June 2013, will also include reduction targets for all four elements.
The LDC global network of production staff are regularly invited to share best operational and environmental practices at a series of workshops and seminars that take place during the year.

Many of Louis Dreyfus Commodities’ industrial and agricultural processes are subject to rigorous external audit during each year, with environmental impacts a key focus. In addition, we are working with key clients to implement a series of sustainable agricultural practices that will further improve our environmental profile

During the course of the last reporting year, Louis Dreyfus Commodities has significantly increased measures to combat corruption and promote good trade practice in all of the markets and businesses in which the Company operates. The creation of a new board level position, that of Chief Compliance & Risk Officer, and a new Trade Practice Compliance department, paved the way for a new policy and education programme designed to take preventative action against corrupt practices.
As well as stipulating that no members of LDC staff should engage in unfair trade practices of an anti-competitive nature, the Louis Dreyfus Commodities Code of Conduct states as follows;
“Employees are prohibited from offering, promising, authorizing, making or receiving from customers, suppliers, public officials or any other business relations or partners, either directly or through a third party, any inappropriate pecuniary or other benefit and in this respect must always comply with applicable laws and regulations.”
In addition, it states that, “Gifts and entertainment may be offered and received to strengthen business relationships only if they are of modest value and aligned with local business practice and laws and the policies applicable in the companies concerned. In case of doubt, employees should obtain the management’s approval.”
In many of the territories in which the Company operates, business is conducted via a network of agents who invariably receive commission as means of payment. In order to align this activity with good and fair business practice, LDC has introduced an Agents Policy that comprehensively lays out the permissible procedures and parameters to be followed when appointing and conducting business through agents. This is designed to ensure LDC’s anti-corruption measures are extended to the agents acting on the Company’s behalf.
During the course of the next reporting year, the Company plans to introduce new policies covering Gifts & Entertainment that will further define what Louis Dreyfus Commodities considers to be appropriate practice in the context of industry norms.

In order to educate and inform Louis Dreyfus Commodities staff of these structural and policy changes, as series of internal seminars have taken place on a global basis, and will continue to do so as new measures are introduced that address similar subjects. These seminars will be supported by the development of new e-learning modules that specifically educate on corrupt practices, and the Company’s measures to address and eradicate them.
The Code of Conduct specifically encourages LDC staff to report concerns over non-compliant conduct, including any alleged corrupt practices, through a specifically allocated e-mail address. Any e-mails received at this address will be confidentially handled and investigated by the Internal Audit Department at Corporate or Regional level.

Louis Dreyfus Commodities employs and Internal Audit department on a global basis, with officers located in all of the regions in which the Company operates. As well as assessing and advising on better commercial and operational practices throughout our business units, this team is specifically charged with an assessment of corruption risk in all of the Company’s value chains.
Any alleged incidents or corruption are reported by the Head of Internal Audit to the monthly Internal Audit & Sustainability Committee, a committee comprised of the most senior officers in the Company.