COMPETITION LAW STATEMENT

The TRACT Group of companies is a joint venture, owned by four Shareholders – ADM, Cargill, LDC and Olam. These organisations are also Users of the TRACT Platform. However, the TRACT Group of companies is run and operated as a set of wholly independent and separate organisations to the Shareholders. Other than for the purposes of managing their ownership, the Shareholders have no day-to-day involvement in TRACT and there are legal limitations as to their involvement to observe competition law and to ensure against anti-trust behaviour.

The need for this independence is critical because in providing the TRACT Platform, the TRACT Group of companies will be made party to information confidential to their Users and contracted 3rd party suppliers and which if shared, even inadvertently, could be used in an anti-competitive manner.

Anti-trust and competition laws form the foundation of free markets by regulating business practices to ensure competition is fair & undistorted, and consumers aren’t harmed. These regulations apply to all contact between all parties when engaging with TRACT during any physical or virtual meeting, or any form of written communication (including email, chat tools, etc).

The TRACT Group treats the safety and security of all confidential information with the utmost importance and for all contact (verbal or written) either within the TRACT Group or with any external party, the observance of competition law and the need to maintain confidentiality of information is paramount.

In all communications, please think about:

1. what you are sharing

2. how you are sharing it

3. why you are sharing it

4. how what you are sharing may be interpreted

5. how that information might be used by a recipient

To assist We have outlined a set of parameters below to guide which topics parties may and may not engage in. This is however not exhaustive and care should be taken when engaging in discussions.

If any party involved in a joint venture meeting has concerns that discussions are veering onto improper subjects such as those identified on the next page, you must:

• expressly state that such conversations are prohibited, and you cannot be party to the discussions,

• leave the meeting and ensure your departure is recorded in meeting minutes,

• eport the incident to your legal and/or compliance representative for guidance on next steps