DATE CONTACT COMPANY NAME ADDRESS Dear CONTACT, The undersigned investors represent socially responsible and religious investors that believe shareholders can have a positive impact on people and the planet while making a profit. The investors represent more than $31 billion in assets under management and include several shareholders of COMPANY. We are writing to you today to raise questions about our company s efforts to mitigate an important emerging systemic risk Colony Collapse Disorder (CCD), a global syndrome that is killing off honey bees in startling numbers. Because we are diversified investors, we hold shares in companies dependent on pollinators at several points in their supply chains, and because honey bees are the most economically important pollinators globally, our organizations have been closely tracking the double digit decline in honey bee and other pollinator populations over the past several winters. As described below, we believe that CCD presents risks to the long term value of our investment in COMPANY, and are writing to open a dialogue to learn more about your approach to mitigating these risks. Background on Colony Collapse Disorder Bee die offs attributed to colony collapse disorder (CCD) pose serious threats to our food supply. According to the US Department of Agriculture, Bee pollination is responsible for more than $15 billion in increased crop value each year and [a]bout one mouthful in three in our diet directly or indirectly benefits from honey bee pollination. 1 According to the U.S Department of Agriculture, between 2006 and 2011 annual winter bee die off reached an average of about 33 percent of the total bee population each year. According to the agency, 1 U.S. Department of Agriculture, Agricultural Research Service, Honey Bees and Colony Collapse Disorder, available at: http://www.ars.usda.gov/news/docs.htm?docid=15572#public According to the Environmental Protection Agency, in the United States, pollination contributes to crop production worth $20-30 billion in agricultural production annually. http://yosemite.epa.gov/opa/admpress.nsf/0c0affede4f840bc8525781f00436213/e04602a5e7aa060685257b5f00 4a12d3!OpenDocument
If losses continue at the 33 percent level, it could threaten the economic viability of the bee pollination industry. Honey bees would not disappear entirely, but the cost of honey bee pollination services would rise, and those increased costs would ultimately be passed on to consumers through higher food costs. Now is the time for research into the cause and treatment of CCD before CCD becomes an agricultural crisis. 2 Evidence suggests that there are a number of interacting factors contributing to CCD, including pathogens, pesticides, and poor nutrition. Recent science shows that even low doses of exposure to the class of pesticides called neonicotinoids (or neonics ) undermine bee immunity against pathogens and impair critical brain functions. 3 Regulatory Action In April, the European Commission suspended the use of certain neonicotinoids throughout the continent for two years beginning December 2013, after the European Food Safety Authority found that the chemicals pose highly acute risks to bees. 4 In August the EPA announced that it will require a warning label on pesticides containing certain neonics, in recognition of the risks presented to bees and other insect pollinators. The new label warns against using the pesticide where bees are present and on flowering plants in bloom.. 5 In its decision, EPA took an important step in acknowledging the role pesticides play in bee die offs. However, environmentalists have criticized the EPA s action as falling short to meaningfully protect our bee populations. Warning labels without education and enforcement do little to address the properties of systemic, persistent neonicotinoid pesticides. In addition, it is unclear how the EPA s action will impact plants and seeds that are pre coated with neonics, another potent risk to bee populations. In July, legislation was introduced in Congress to suspend the use of neonics on bee attractive plants until the EPA reviews all available data. We suspect that these new labels and the public attention to CCD, including a recent cover story in Time Magazine, will prompt difficult questions from consumers regarding the use of these products. In addition, as you are no doubt aware, Friends of the Earth is leading a campaign targeting COMPANY. 2 U.S. Department of Agriculture, Agricultural Research Service, Honey Bees and Colony Collapse Disorder, available at: http://www.ars.usda.gov/news/docs.htm?docid=15572#public 3 Carl Zimmer, 2 Studies Point to Common Pesticide as a Culprit in Declining Bee Colonies, The New York Times, March 29, 2012. 4 European Commission Health and Consumers website, available at: http://ec.europa.eu/food/animal/liveanimals/bees/neonicotinoids_en.htm 5 http://yosemite.epa.gov/opa/admpress.nsf/0c0affede4f840bc8525781f00436213/e04602a5e7aa060685257b5f0 04a12d3!OpenDocument The announcement affects products containing these neonicotinoids: imidacloprid, dinotefuran, clothianidin and thiamethoxam. The label is available at: http://www.epa.gov/pesticides/ecosystem/pollinator/bee label info graphic.pdf
In light of these developments, companies are beginning to respond and are working to reduce or eliminate these pesticides of concern from their supply chain. For example, in the United Kingdom home improvement chains B&Q, Home Base and Wilkes have agreed to remove harmful neonicotinoid containing pesticides from their store shelves. Risks to Long Term Value We are concerned that COMPANY faces potential impacts to its bottom line due to the reputational risks of being associated with a contributing cause to CCD. Given the serious impacts declining bee populations could have on the environment and global food systems, we believe that potentially affected companies should take a precautionary approach on this issue. As shareholders, we recommend that COMPANY work to better understand its risk exposure to CCD and identify opportunities to benefit from acting as a proactive leader on this issue. Furthermore, we believe that this issue presents COMPANY with an opportunity for a perfectly mission aligned corporate social responsibility initiative. Promoting healthy bee populations through consumer education and the encouragement of pro bee gardening campaigns could strengthen customer loyalty, boost the company s reputation and improve sales. Instead of being targeted as a contributor to CCD and its threat to the environment and global food supply, COMPANY has the chance to be seen as a leader, receptive to consumer issues and successful at promoting environmental health as well as sales. Given the risks and opportunities we have presented, we would like to open a dialogue with COMPANY to understand how the company is responding to this issue. We respectfully request responses to the following questions: How is the company monitoring the science related to pollinator decline? What steps would be necessary in order for the company to assess the financial implications of phasing out the sale of neonicotinoid containing products? What, if any, options are being explored to reduce bee toxic pesticide classes including neonicotinoids in the seeds and seedlings sold by the company? What might be the potential financial risks to COMPANY from restrictions, regulations or shifting consumer demand resulting from growing public concern around bee population declines? Given the introduction of warning labels on bee toxic pesticides how could the company benefit from a marketing campaign promoting healthy bee gardens? We are concerned that CCD, left unabated, could have devastating implications for the environment, global food systems, and the long term value of many of our holdings. As investors, we encourage the company to review its existing policies as well as the risks of inaction. We understand that this is a complex problem and would welcome the opportunity to discuss this pressing issue with your team. Please contact Larisa Ruoff at lruoff@lwcotrust.com or Susan Baker at sbaker@trilliuminvest.com with your reply to this letter.
Thank you for your attention to this matter. Larisa Ruoff Shareholder Advocacy and SRI Research The Sustainability Group Loring, Wolcott & Coolidge Trust, LLC Susan Baker VP, Shareholder Advocacy & Corporate Engagement Trillium Asset Management, LLC Ellen Kennedy Manager, Environment and Climate Change Calvert s Steven Viederman Chair, Finance Committee Christopher Reynolds Foundation Shelley Alpern Director of Research & Social Advocacy Clean Yield Asset Management Margaret Weber Corporate Responsibility Director Congregation of St. Basil Susan Vickers, RSM VP, Community Health Dignity Health Adam M. Kanzer, Esq. Managing Director & General Counsel Domini Social s, LLC Steven J. Schueth, President First Affirmative Financial Network Jeffrey W. Perkins Executive Director Friends Fiduciary Corporation Leslie Samuelrich Senior Vice President Green Century Capital Management Richard A. Liroff, Ph.D. Executive Director Investor Environmental Health Network Cathy Rowan Corporate Responsibility Coordinator Maryknoll Sisters Valerie Heinonen, o.s.u Director, Shareholder Advocacy Mercy Services Barbara Jennings, CSJ Midwest Coalition for Responsible Luan Steinhilber Director of Operations and Shareholder Advocacy Miller/Howard s, Inc. Christina Herman Justice, Peace/Integrity of Creation Office Missionary Oblates of Mary Immaculate Judy Byron, OP Northwest Coalition for Responsible Sr. Josie Chrosniak, HM Coordinator Region 6 Coalition for Responsible
Tom McCaney Associate Director, Corporate Social Responsibility Sisters of St. Francis of Philadelphia Stephen L. Zielinski, CIMA ViaGem, LLC Registered Advisor for: Sisters of the Presentation Aberdeen, SD Dominican Sisters of Springfield, IL Diocese of Springfield, IL Servants of the Paraclete Dittmer, MO Denise Granger, S.S. J Justice and Peace Coordinator Sisters of St Joseph of Springfield Claire Deroche Social Justice Committee UU Congregation at Shelter Rock Long Island, NY