Thank you for your impact assessment efforts! I have some doubts about the implications of the points you raise.
On “JBS Ear Notching—Non-Existent Commitment” you say:
The impact calculations were not corrected (ACE has stated this), and still incorrectly credit Sinergia for helping millions of JBS’s pigs who were not impacted.
Emphasizing that the figure is in the millions suggests (at least to me!) that this difference is significant and that it implies a difference in impact that could alter funders’ appreciation of Sinergia’s work. However, ACE added the following clarification in the spreadsheet you refer to:
The second comment previously read “Committed to banning ear notching by 2023” but was updated in March 2025. Because of this miscommunication, although it would have been ideal to apply discounts at both the “number of animals affected” and the “SADs averted per dollar” levels, our SADs estimates were already conservative, and the magnitude of the change would not affect our decision to recommend Sinergia. Therefore, we have not refreshed the calculations for the number of animals impacted by the commitment.
What do you think of this response? (Beyond the fact that you think “the numbers should be corrected—and doing so would not be particularly difficult,” as you say at the end of the article)
It seems to me that the whole point of an evaluation process such as the one you are conducting is to verify whether the promised impact is being achieved. If we realize that there is an error, even if it is “in millions,” in one of the figures without this altering the order of magnitude of the expected impact, why dwell on this error in the figures (instead of, for example, simply acknowledging that there is no real cause for concern on this point)?
On “JBS Gestation Crates—Pre-existing Policy Presented As a New Commitment” you say:
The policy referenced in the alleged 2023 Pre-Implantation Commitment existed prior to 2023. JBS’s 2021 sustainability report already stated JBS’s “new systems use a pre-implantation transfer system.” [11]
The footnote cites page 113 of the 2021 report, which states (emphasis added):
In pig breeding operations, we have policies to encourage farms to adapt their facilities and gradually replace individual gestation crates with collective gestation stalls. These adaptations are designed to ensure that sows spend a maximum of 28 days in individual gestation crates. The new systems use a pre-implantation transfer system that allows sows to be housed in collective systems after artificial insemination. Nurseries are 100% temperature-controlled to offer piglets optimal comfort. Environmental enrichment projects are also currently being implemented. Procedures that cause pain or discomfort are discouraged and surgical castration has been discontinued—at Seara, 100% of male pigs are immunocastrated.
And on the following page, in the section “Initiatives and projects in Brazil,” subsection “Pork”:
Construction of 16,000 pre-implantation transfer system positions.
These very concise excerpts raise many questions:
Where is the commitment to the 2023 transition deadline? The only mention of time here refers to a gradual change with no deadline for existing installations.
What does the figure 16,000 represent? Is it 100% of their new units? Or is it, for example, only a fraction to make the report look good, on a voluntary basis, while they continue to build new units with individual gestation crates?
It is unclear in this paragraph whether the sentence beginning with “The new systems use...” should be understood as synonymous with “From now on, all new units use...” or more modestly as “When farms are willing to listen to our non-binding encouragement to upgrade their individual gestation crates to new systems, then the new systems use...”.
Charities’ impact claims need to be examined with hindsight, but so do the agribusiness companies’ statements about their ethics, and I wonder if you are jumping to conclusions a little too quickly in assuming that this document demonstrates that JBS was already “Committed to adopt crate-free system for the new units by 2023.”
(I’ll stop there for today, I may comment on the rest of your article later!)
Hello!
Thank you for your impact assessment efforts! I have some doubts about the implications of the points you raise.
On “JBS Ear Notching—Non-Existent Commitment” you say:
Emphasizing that the figure is in the millions suggests (at least to me!) that this difference is significant and that it implies a difference in impact that could alter funders’ appreciation of Sinergia’s work. However, ACE added the following clarification in the spreadsheet you refer to:
What do you think of this response? (Beyond the fact that you think “the numbers should be corrected—and doing so would not be particularly difficult,” as you say at the end of the article)
It seems to me that the whole point of an evaluation process such as the one you are conducting is to verify whether the promised impact is being achieved. If we realize that there is an error, even if it is “in millions,” in one of the figures without this altering the order of magnitude of the expected impact, why dwell on this error in the figures (instead of, for example, simply acknowledging that there is no real cause for concern on this point)?
On “JBS Gestation Crates—Pre-existing Policy Presented As a New Commitment” you say:
The footnote cites page 113 of the 2021 report, which states (emphasis added):
And on the following page, in the section “Initiatives and projects in Brazil,” subsection “Pork”:
These very concise excerpts raise many questions:
Where is the commitment to the 2023 transition deadline? The only mention of time here refers to a gradual change with no deadline for existing installations.
What does the figure 16,000 represent? Is it 100% of their new units? Or is it, for example, only a fraction to make the report look good, on a voluntary basis, while they continue to build new units with individual gestation crates?
It is unclear in this paragraph whether the sentence beginning with “The new systems use...” should be understood as synonymous with “From now on, all new units use...” or more modestly as “When farms are willing to listen to our non-binding encouragement to upgrade their individual gestation crates to new systems, then the new systems use...”.
Charities’ impact claims need to be examined with hindsight, but so do the agribusiness companies’ statements about their ethics, and I wonder if you are jumping to conclusions a little too quickly in assuming that this document demonstrates that JBS was already “Committed to adopt crate-free system for the new units by 2023.”
(I’ll stop there for today, I may comment on the rest of your article later!)