Comments
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:
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!)
Sinergia Animal is concerned regarding the engagement practices and level of transparency demonstrated by Vetted Causes. We have not been provided—nor have we seen made available to the public—any ethical guidelines, a professional and respectful code of conduct for engaging with charities, or clear information about the research methodology and qualifications of the specialists involved in their evaluations.
Given these concerns, we have chosen to limit our engagement with Vetted Causes to written communication.
We also disagree with the imposition of arbitrary deadlines in Vetted Causes’ processes. As a charity with limited resources and critical ongoing work, it is not always feasible for us to respond within compressed timeframes without compromising our well-being and effectiveness. Although we requested to be consulted regarding suitable timelines for responding to clarification questions and reviewing the article draft, these requests were not accommodated.
Had the process been more transparent and respectful, we believe readers of this Forum would have benefited from more accurate and balanced information, helping to prevent the spread of mistaken information.
A summary of our responses:
Vetted Causes’ analysis was incorrect—the commitment does, in fact, exist. The only issue was an unintentional error by Sinergia regarding the stated deadline.
Vetted Causes’ analysis is incorrect, and Sinergia Animal provides further clarification below.
Vetted Causes’ analysis is incorrect, and Sinergia Animal provides further clarification below.
Vetted Causes’ analysis is incorrect, and Sinergia Animal provides further clarification below.
Vetted Causes’ analysis is incorrect, and Sinergia Animal provides further clarification below.
There is no contradiction, and Sinergia Animal provides further clarification below.
1. JBS Ear Notching - Non-existent commitment, according to Vetted Causes
SINERGIA’S RESPONSE:
Sinergia already explained this is a valid commitment and Vetted Causes was mistaken to classify it as a non-existing commitment. We acknowledge and regret the deadline error in our spreadsheet shared with ACE. As we have stated, this was not an attempt to misrepresent data or inflate our impact, as implied by Vetted Causes. All metrics were calculated in good faith.
2. JBS Gestation Crates - Pre-existing Policy Presented As a New Commitment, according to Vetted Causes
SINERGIA’S RESPONSE:
Vetted Causes' claim that this policy existed prior to 2023 is incorrect. This conclusion overlooks essential context and suggests a limited understanding of how animal protection NGOs secure and validate corporate animal welfare commitments. The work of influencing corporate policy is highly nuanced and requires a deep familiarity with internal processes, negotiations, and criteria for valid policies—knowledge that appears to be missing in Vetted Causes’ analysis.
We are particularly concerned by Vetted Causes’ ongoing refusal to clarify whether their evaluations are informed by professionals with expertise in securing animal welfare commitments from major corporations. When we asked if such specialists were consulted, Vetted Causes stated that this information is confidential.
An organization that positions itself as a charity evaluator has a responsibility to operate with transparency—especially when making public assessments that can affect the credibility of nonprofits. The identities of specialists consulted should not be withheld.
Failing to engage relevant experts not only undermines the accuracy of the reviews but also wastes the time of the broader community who rely on these evaluations for reliable guidance. We strongly urge Vetted Causes to adopt more rigorous standards of transparency and expertise in order to provide fair and constructive assessments.
Vetted Causes is also omitting important information on this topic. This is what Sinergia said about this topic when it previously replied to Vetted Causes:
“It is a misconception to think that securing a policy necessarily requires numerous meetings, or a certain number of meetings. Many other factors are highly significant, such as how important the company considers animal welfare to be, long-term engagement with NGOs, and the NGO being well known as an organization that works with mobilization tactics. Additionally, when NGO communications explain the potential for either negative or positive brand exposure (such as the case of the Pigs in Focus program) they can be particularly effective.”
We regret that Vetted Causes appears to place disproportionate weight on the number of meetings as the primary indicator of a charity's ability to influence policy. This view is mistaken and overlooks the complexity of policy advocacy.
History behind the validation of JBS’s official policy
Sinergia started engaging with JBS and asking them to move towards the cobre e solta system in June 2020. JBS began discussing the implementation of the "cobre e solta" (pre-implantation) system in new facilities publicly in March 2021—first in a media article and later in a report published in 2021 and again in 2022. However, in none of these mentions did the company make it clear that this was a permanent commitment and 100% of the new facilities would adopt the "cobre e solta" system.
2021 Media article:
At the time, it was stated: “Currently, all our new projects follow the “cobre e solta” system. However, it was not made clear that this was a permanent company policy or a permanent commitment.
2021 Report:
“New projects adopt the ‘cobre e solta’ system, allowing the sows, after being artificially inseminated, to be housed in group housing.”
2022 Report:
“New projects adopt the ‘cobre e solta’ system, allowing the sows, after being artificially inseminated, to be housed in group housing.”
Just as Sinergia consistently demands clarity and precision in cage-free egg commitments—ensuring that corporate language confirms policies are permanent, comprehensive, not partial, and apply to all facilities or the full supply chain—we applied the same rigorous standards in our engagement with pig producing companies in Brazil. Specifically, Sinergia requested that JBS explicitly include terms such as “100%” and/or “all farms” in its statements, and that this language be published as a formal, ongoing commitment on its public animal welfare policy page.
This request was first fulfilled in August 2023, when the Seara webpage was updated to state:
“The ‘cobre e solta’ system is implemented in all new projects.”
Subsequently, in October 2023, JBS published a report stating:
“For new piglet production unit projects, the following are planned: 100% of gestation facilities will be climate-controlled, with “cobre e solta” (pre-implantation) management.”
It is critical to note that JBS had the opportunity to review its evaluation in the Pigs in Focus report.
This process and its benchmarks were thoroughly deliberated by our team, including what should or should not be classified as a valid commitment. We made a conscious decision to uphold high standards—especially for large corporations ranked at Pigs In Focus, which have the resources to establish clear, permanent, and transparent animal welfare policies. These policies must also be published with proper visibility on official web pages and reports.
It would have been easier and more expedient for Sinergia to accept vague statements from media articles or loosely worded references in corporate reports. Doing so could have even provided strategic advantages: for example, by including a weak policy claim in Pigs in Focus 2022, we might have encouraged other companies to follow suit. But we made a deliberate choice to prioritize accountability and real impact over publicity or credit.
Our commitment is to drive authentic progress for animals, not to artificially inflate achievements. That’s why we only recognize fully established and well-documented policies—because those have the greatest potential to create lasting, systemic change.
It’s also important to address a factual error made by Vetted Causes in its first article. That article stated:
“However, the gestation crate policy that the alleged commitment references was already listed on JBS's website in 2020, and has been in effect since that point.”
This shows that Vetted Causes originally misattributed the policy in question, suggesting that Sinergia took credit for JBS’s existing 2015 group housing policy, rather than for the pre-implantation ‘cobre e solta’ policy, which is the correct focus. It appears Vetted Causes later conducted additional research and shifted its argument—rather than acknowledging this initial mistake.
3. Teeth Clipping - Practice Was Already Illegal Prior to Alleged Commitments, according to Vetted Causes
SINERGIA’S RESPONSE:
Vetted Causes’ analysis is inaccurate and reflects a clear lack of local expertise and contextual understanding. Sinergia directly asked Vetted Causes: “Have you consulted any Brazilian specialists regarding inspections, enforcement, or sanctions related to violations of animal welfare legislation or the pig welfare normative?” Their response was that they could not confirm or deny this, as this information is confidential. In this case, a failure to engage local knowledge has likely led to flawed conclusions and misinformed readers. Please also note that Vetted Causes did not provide any real example of an administrative sanction being applied under the norms of the N113 normative.
However, based on the information available to Sinergia—provided by local country specialists—we maintain our original assessment: that Normative Instruction 113 is not being effectively inspected or enforced in practice. Given the contextual challenges we have already outlined, including systemic issues in regulatory oversight, we believe it is unlikely that violations of this normative currently result in meaningful sanctions.
We must be realistic: enforcement does not happen automatically just because a normative/policy exists. Even in the European Union, civil society organizations have had to campaign relentlessly over the years to pressure governments to uphold and enforce animal welfare legislation. Brazil is unlikely to be an exception. It is a serious mistake of Vetted Causes to assume that the mere existence of a normative in Brazil ensures its effectiveness or immediate impact.
It is also important to clarify that Sinergia Animal did not, at any point, discourage ACE from considering IN 113 as a basis for assessing legal deadlines, for the following reason:
Lack of enforcement mechanisms: At present, neither Sinergia nor the broader movement has a successful program specifically aimed at ensuring the enforcement of IN 113. This does not mean we underestimate its importance or potential—but rather, we acknowledge its current limitations. We are beginning public policy work in Brazil in 2025, with the aim of driving long-term impact. One of our central goals is to help transform IN 113 into binding legislation and to further strengthen it by 2045. So, we think it makes sense for ACE to work with the 2030 and 2045 normative deadlines. While the outcomes of this advocacy remain to be seen, we hope our efforts will make the normative recommendations better and more meaningful and enforceable over time.
4. Aurora - Pre-Existing Policy Presented as a New Commitment, According to Vetted Causes
SINERGIA’S RESPONSE:
Vetted Causes’ assessment is mistaken.
The claim that Aurora had a formal and exclusive immunocastration policy prior to 2023 does not align with the timeline of documented changes to the company’s website. On October 24, 2022, Aurora’s webpage underwent two rapid edits, according to Web Archive.
The first edit, at 16:44, introduced the phrase cited by Vetted Causes: “The Cooperative only chooses to adopt immunocastration, as it is a less invasive practice.” However, this version was online for just one minute (if Web Archive is right). At 16:45, the page was edited again, and that second version—which does not contain the language cited by Vetted Causes—is the one that remained publicly available and is the one we referenced in Sinergia’s 2022 Pigs in Focus report.
This shows that the wording presented by Vetted Causes did not reflect the final or stable version of the company's communications at the time. Therefore, our reporting was not based on incomplete or misleading information.
Moreover, the Pigs in Focus report was shared with Aurora Coop ahead of publication in 2022, as was done with all companies featured in the evaluation.
If Aurora had already made this transition earlier, it would have been in our interest to highlight such a progressive policy in the 2022 edition of Pigs in Focus. We are committed to promoting genuine advances in animal welfare. Recognizing an early, strong commitment would have not only benefited Aurora’s ranking, but also encouraged peer companies to follow suit.
Please note that Sinergia believes the appearance of the phrase “The Cooperative only chooses to adopt immunocastration, as it is a less invasive practice” on Aurora’s website in a Web Archive snapshot from October 2022 at 16:44 could due to a technical error of the website. Our communications indicate that this wording was only adopted by Aurora in 2023.
5. BRF - Pre-Existing Policy Presented as a New Commitment, According to Vetted Causes
SINERGIA’S RESPONSE:
Sinergia Animal appreciates that Vetted Causes has acknowledged its earlier error and recognized that this policy was, in fact, successfully secured in 2023.
About the number of sows, the total number of sows reflected in the spreadsheet corresponds to the full scope of BRF’s public commitment to eliminate gestation crates—encompassing our work to enforce the group housing (2014 commitment) and pre-implantation systems (2023 commitment). Our impact estimation reflected this broader policy shift, which BRF has made public and which Sinergia continues to monitor and help enforce. Additionally, the current 5% is likely to increase in future years.
Having said that, we do welcome the concern of separating our impact numbers into: 1) new commitments and 2) commitments being enforced. We will work on this later this year and will be happy to share it with the community when we find a good solution for it.
6. Female Piglets Surgical Castration
SINERGIA’S RESPONSE:
There is no contradiction and Vetted Causes seems to be omitting information. Sinergia said estimations are still correct because AIM's SADs calculations already took into "prevalence" of castration (taking out female piglets) but the latter [number of piglets affected] was stated incorrectly because they didn't include the same discount. In other words: Sinergia never said the number of piglets was correct. It was an unintentional mistake of Sinergia’s team to leave all piglets, and not only male piglets on the spreadsheet that estimates the number of animals. We failed to notice that when we provided and reviewed materials provided to ACE. We are committed to being more attentive and correcting this mistake in future estimations.
Hello Carolina.
The version from 24 October 2022 at 16:45:06 does have the sentence "The Cooperative only chooses to adopt Immunocastration, as it is a less invasive practice.", as mentioned by VettedCauses. The original Portuguese version says "A Cooperativa [Aurora] opta somente pela adoção a Imunocastração, por ser uma prática menos invasiva.". As a native Portuguese speaker, I would translate this to "The Cooperative only chooses Immunocastration, as it is a less invasive practice.". @VettedCauses, despite this, I agree with @Carolina Galvani - Sinergia Animal that Aurora was still performing surgical castration in 2022, although "with the use of anesthetic". Otherwise, I would not have expected the version from 24 October 2022 at 16:45:06 to have elaborated on what to do when immunological castration is not possible.
I cannot access the version from 24 October 2022 at 16:44:58. I am redirected to the version from 8 s later which has the sentence mentioned by VettedCauses.
Nevertheless, Aurora said in 2021 that they were using immunocastration on a large scale, and the information on Aurora's website on 24 October 2022 at 14:45:06 is compatible with surgical castration rarely being performed then, and ending in 2023 regardless of Sinergia's work. I guess ACE overestimated Sinergia's impact on Aurora's commitment by assuming this was as beneficial as preventing 7 years of all piglets being surgically castrated.
Moreover, I think ACE overestimated the benefits of the commitment, @Vince Mak 🔸. They used a decrease of 0.628 suffering-adjusted days (SADs) per piglet helped referring an improvement from "Piglets (HIC) - full suite of mutilations" to "Piglets (HIC) - no castration", whereas the real improvement was from surgical castration with the use of anesthetic to immunological castration, which seems to respect a much smaller decrease in the amount of suffering.
I do not understand what was Sinergia's contribution to JBS' commitment to only rely on the pre-implantation system in all new projects, @Vince Mak 🔸. JBS' wording from 2021 already included "all our new projects", just as the wording from 2023 did (see what I bolded below). What am I missing? In addition, I do not think you should have assumed all their 290 k sows (which you took from p. 20 here) transitioned to the pre-implantation system in 2023. The transition should take roughly as long as the lifetime of farms? For example, if farms have an expected lifetime of 10 years, and all new farms use a new system, I would expect it would take 10 years for all farms to be using the new system.
There are two JBS ear notching commitments Sinergia has claimed existed:
It appears Sinergia and Vetted Causes agree that Commitment 1 never existed.
Note: Sinergia is currently being credited for Commitment 1 even though it never existed.
It appears Sinergia and Vetted Causes agree that this is a pre-existing policy being presented as a new commitment. The policy was already in place in 2021, yet Sinergia claimed it as a new 2023 win.
It’s also worth noting that many of the commitments Sinergia takes credit for don’t use definitive language like “100%” or “all farms.” For example, Alibem's surgical castration commitment from Row 4 states Alibem will: “Maintain immunocastration instead of surgical castration – a procedure that was voluntarily eliminated from the Company’s protocols in 2010.” (translated from Portuguese to English).
Sinergia took 70% credit for this 2010 policy even though Sinergia didn't exist until 2017. Further, there is no mention of "100%" or "all farms."
Additionally, Sinergia’s own “Upper bound” for how many companies will actually follow through on their commitments is just 65% (see Cell B14), which shows many of these commitments are not reliable or permanent. JBS themselves has already walked back their ear notching commitment (see Page 42) .
It appears Sinergia and Vetted Causes agree teeth clipping was already illegal prior to the alleged commitments. Here is a quote from Sinergia's Pigs in Focus report: "According to Normative Instruction 113/2020 (IN 113/2020), teeth clipping is prohibited".
This is factually incorrect, the edits Sinergia describes did not occur. Every archive of the webpage from October 24, 2022 states: “The Cooperative only chooses to adopt immunocastration, as it is a less invasive practice.” (translated from Portuguese to English)
Here is a screen recording proving this to be the case.
It appears Sinergia and Vetted Causes agree that Sinergia should not have taken credit for helping 100% of BRF’s sows in 2023 through this commitment when only ~5% were impacted.
It appears Sinergia and Vetted Causes agree that: