Archer-Daniels-Midland Co

The proposal requests that ADM prepare a report, at reasonable expense and excluding proprietary information, explaining if and how the company can incorporate pesticide use data reporting into its regenerative agriculture program disclosures. Proponents argue that tracking pesticide use is necessary because pesticide dependence undermines soil health, biodiversity, and the carbon sequestration potential of regenerative practices, and that reporting would improve credibility and reduce the risk of greenwashing. The proposal notes that other large food companies already disclose pesticide reductions within their regenerative programs and suggests ADM’s disclosure gaps could affect supply-chain partners and downstream corporate sustainability claims. The requested report should describe feasibility, data approaches, and potential disclosure frameworks for incorporating pesticide use data into ADM’s regenerative agriculture reporting.