Today, the Humane Society of the United States (HSUS) and the Center for Biological Diversity (Center), with the assistance of the Farmed Animal Advocacy Clinic at Vermont Law and Graduate School, filed a crucial complaint to the U.S. Securities and Exchange Commission (SEC) against JBS SA and Pilgrim’s Pride. These corporations are among the largest meat and poultry producers in the world, and their sustainability claims, particularly regarding animal welfare practices, deforestation conduct, and net zero emissions commitments, appear to be false and misleading.

Key Allegations in the Complaint

HSUS and the Center allege that JBS and Pilgrim’s Pride have violated federal securities laws by making apparent false and misleading statements in their Offering Documents, which are intended to facilitate an initial public offering (IPO) in the U.S. The primary allegations include:

1. Animal Welfare Misrepresentations:

JBS and Pilgrim’s Pride claim to ensure the humane treatment and housing of animals in their supply chains. However, compelling evidence, including USDA violations, shows inhumane handling and inadequate care, contradicting their claims. This potentially misleads both consumers and investors who prioritize animal welfare in their purchasing and investment decisions.

2. Environmental Impact Omissions:

The Group's Offering Documents fail to disclose significant risks related to their environmental practices, particularly deforestation and climate change commitments. Despite a public commitment to achieve net zero GHG emissions by 2040, the companies have not demonstrated plausible plans to meet this goal, especially given their projected growth in meat production.

3. Regulatory Compliance Risks:

The complaint also highlights the Group’s failure to disclose risks associated with upcoming regulations, such as the European Union Deforestation Regulation and California’s Voluntary Carbon Market Disclosures Act. These laws require stringent compliance that the Group is unlikely to meet, posing significant financial and operational risks.

Educational Impact on Student Clinicians

For our student clinicians, working on this complaint has been an invaluable educational experience, providing real-world insights into the intersection of animal advocacy, environmental justice, investor protection, and corporate accountability. Kristi Fox, JD '24, reflects on her experience:

“Working on the SEC complaint against JBS and Pilgrim's Pride in the Farmed Animal Advocacy Clinic was deeply eye-opening. These companies' apparent misrepresentations on Environmental, Social, and Governance (ESG) issues like animal welfare and environmental justice reveal a troubling level of potential deception. It's crucial that their statements reflect the reality of their practices, and that’s why the complaint urges the SEC to thoroughly investigate the companies’ claims. The skills I've honed here in persuasive writing and legal strategy are tools I will carry forward in my career, dedicated to making a meaningful difference in the world."

This complaint is a testament to our ongoing commitment to transparency and accountability in the animal agriculture industry. Our collaboration with HSUS and the Center demonstrates our dedication to educating and empowering the next generation of legal advocates. At the Farmed Animal Advocacy Clinic, we remain steadfast in our mission to effect positive change through legal avenues and equip our students with the skills to champion animal and environmental protection.