Organization Information:

Monsanto Company
800 N. Lindbergh Blvd.
St. Louis, Missouri 63167
Phone: 314-694-7762
Fax: 314-694-1622
http://monsanto.com
Contact Information:

Contact Office: Alice Conway, Assistant General Counsel, Commercial and Employment Law
Phone: 314-694-7762 Fax: 314-694-1622 Email: alice.e.conway@monsanto.com

Corporate Officer Information:

Corporate Officer: Scott B. Baucum, Director of Business Conduct
Phone: 314-694-7653 Fax: 314-694-1622 Email: scott.b.baucum@monsanto.com

Safe Harbor Information:

Signed up to safe harbor 07/27/2004 10:46:44 AM
Next certification 07/27/2009
EU/EEA Countries From Which Personal Information Is Received: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, United Kingdom
Industry Sector: Agricultural Chemicals - (AGC) Biotechnology - (BTC) Agricultural Services - (AGS)
Personal Information Received From the EU: The US Monsanto Human Resources Function collects, processes and stores contact information and job related information from EU applicants for employment, and contact information, salary and other job-related information of EU employees for the purpose of working together with EU Monsanto to design, evaluate and administer various human resources programs.

Emergency contact information is also collected for our employees, including EU employees, who travel on Monsanto business or are present in hotels where Monsanto is hosting a conference. Monsanto has this information so that, in the event of an emergency, the employee can be contacted, and in the event of a disaster, Monsanto will know how to begin ascertaining the whereabouts and safety of the employees.

Monsanto has a contract including data controller and other required provisions, with a travel agency that receives personal information about EU Monsanto employees who travel on business.

US Monsanto occasionally receives information about occupational health of its EU employees, but the information is anonymized and therefore not covered by the Safe Harbor Privacy Principles.

Farmers in the EU, some of whom may be our direct customers, may visit our Dekalb and Yieldgard websites seeking information about our products, and they may voluntarily provide their names, addresses, and a list of the Monsanto products they buy and the number of acres on which they use those products. They may give Monsanto permission to e-mail or postal-mail them information and advertising. This information can be viewed by employees who need it to do their jobs within and outside the EU. It is kept in a secure fashion. These websites have privacy policies and they have terms and conditions which explain that growers' information may be viewed and used for business and order-processing purposes by Monsanto employees within and outside the EU. Before registering on these websites and providing any information to Monsanto, the growers must sign that they have read these terms and conditions and consent to Monsanto's use of their information.

Employees and customers may make use of a Monsanto blog that can be viewed by all Monsanto employees.

Monsanto's Business Conduct Office and EU Business Conduct Working Group may occasionally receive information about possible employee wrongdoing, and such matters are investigated in compliance with all applicable laws and regulations, including those of CNIL.

As a "best practice" to ensure compliance with anti-bribery laws throughout the world, Monsanto requests limited information, using a consent form, from officers of entities that may represent us to a government, or do business with a government on our behalf, and from non- US government officials with whom we do business or on whose behalf we may incur expenses. The information includes name, job title, family ties to governments, political party affiliations of government officials, and some information about criminal convictions.

To eliminate paper and e mail storage, Monsanto is now placing all of its "best practices" documents on a secured, password-protected website that can only be viewed by the above-described Monsanto's Europe Africa Business Conduct Working Group a cross-functional team of Monsanto employees who perform the anti-corruption best practices described above. These documents can also be viewed by the Business Conduct Office in St. Louis, Missouri at Monsanto headquarters, and also by other Monsanto Business Conduct Working Groups in other regions. These Working Groups constitute a tiny fraction of Monsanto's employees.

The Business Conduct Office will take reasonable steps to safeguard PI from loss, misuse, alteration, destruction, or unauthorized access or disclosure. These measures include employee access on a need-to-know basis only, file cabinets that lock, computer user ID'S and log-on passwords.
Privacy Policy Effective: 09/01/2004
Location: Intranet Site: http://w3.foundation.monsanto.com/BUSINESSCONDUCT/ASP/Policy_EU_Privacy.asp
Regulated by: Federal Trade Commission
Privacy Programs: None.
Verification: Third Party
Dispute Resolution: Questions or complaints about the way US Monsanto has treated PI will be handled by the employee's local HR Representative in the EU. If the issue is not resolved there, the HR Representative or the employee may take it up with the Business Conduct Program at Headquarters in St. Louis, Missouri. If the matter is not resolved with the Business Conduct Program, either the Business Conduct Program or the employee may take it up with the local Data Protection Authority (DPA) in the EU or the Swiss Federal Data Protection and Information Commissioner (FDPIC).

If the in-house dispute resolution process results in the conclusion that PI was incorrectly handled, Monsanto will do whatever is feasible to undo any damage caused by the incorrect handling. If the process goes to the DPA or the FDPIC and the DPA or the FDPIC concludes that information was incorrectly handled, Monsanto will cooperate with DPA's or the FDPIC's processes and advice. Monsanto will not retaliate against any employee who takes advantage of these processes in good faith. Verification of Compliance with Safe Harbor Principles Monsanto will rely on and cooperate with DPAs and FDPIC to verify its compliance with Safe Harbor Principles.

If in connection with Monsanto's anti-corruption best practices, a government official or vendor were to object to Monsanto's collection of any "personal information" then the objection would go to the Europe- Africa Business Conduct Working Group, which is a cross-functional team of Monsanto employees who perform the above-described best practices relating to FCPA and other anti-corruption laws. If this group decided that it needed the personal information, it would refer the matter to the Business Conduct Office in St. Louis, Missouri at Monsanto's Headquarters. If this Office could not resolve the matter, it would send the matter to a Data Protection Agency in the EU just as Hustan Resources would send an unresolved matter involving information collected by HR.
Personal Data Covered: Human Resources Data
Human Resource Data Covered: Yes

Do you agree to cooperate and comply with the European Data Protection Authorities? Yes

Certification Status: Not Current
Compliance Status:

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