GRI Standards Content Index

This report has been prepared in accordance with the GRI Standards: Core option.
No portion of this disclosure has been externally reviewed.

GRI STANDARD DISCLOSURE RESPONSES & LINKS
GRI 102: General Disclosures Disclosure 102-1 Name of the organization a. Name of the organization: Pipeline Foods
Disclosure 102-2 Activities, brands, products, and services a. A description of the organization’s activities: SEE: Home Page

b. Primary brands, products, and services, including an explanation of any products or services that are banned in certain markets: Pipeline Foods is currently working with customers marketing products as regenerative, and there is currently food industry debate around the use of that label (SEE: Home Page).
Disclosure 102-3 Location of headquarters a. Location of the organization’s headquarters: Minneapolis, MN
Disclosure 102-4 Location of operations a. Number of countries where the organization operates, and the names of countries where it has significant operations and/or that are relevant to the topics covered in the report: SEE: Asset Map
Disclosure 102-5 Ownership and legal form a. Nature of ownership and legal form: Pipeline Foods, LLC is a Delaware limited liability company. Pipeline Foods, LLC is a wholly owned subsidiary of Pipeline Foods Holdings, LLC which is also a Delaware limited liability company. Both entities are active and in good standing in the state of Delaware and the state of Minnesota, the registered place of business for both entities.

Pipeline Foods Holdings is managed by a three person board of managers. The managers are determined by the members of Pipeline Holdings, LLC. All management decisions for Pipeline Holdings, LLC are made by the board of managers. The day to day management of Pipeline Foods is managed by its executive team.
Disclosure 102-6 Markets served a. Markets served, including:

i. geographic locations where products and services are offered: Pipeline Foods sells products and services domestically in the United States, as well as in Canada, China, Korea, and Australia. Pipeline Foods imports raw and processed organic grain, pulse, and oilseed commodities from India, Romania, Canada, and Argentina into the United States. Pipeline Foods exports raw and processed organic grain, pulse and oilseed commodities to China, Korea, Japan, and the United Kingdom.
ii. sectors served: SEE: Home Page
iii. types of customers and beneficiaries: SEE: Farm Profit Program

Disclosure 102-7 Scale of the organization a. Scale of the organization, including:
i. total number of employees: Pipeline Foods had 61 active employees at the end of calendar year 2018.
ii. total number of operations: Pipeline Foods owned and operated six facilities at the end of calendar year 2018.
iii. net sales (for private sector organizations) or net revenues (for public sector organizations): Pipeline Foods does not disclose net sales in compliance with our financial partner’s requirements.
iv. total capitalization (for private sector organizations) broken down in terms of debt and equity: Pipeline Foods does not disclose total capitalization in compliance with our financial partner’s requirements.
v. quantity of products or services provided: SEE: Volume Originated Chart. In 2018, Farmers who took advantage of FPP services contracted to sell over 1,000,000 bushels of organic grain to Pipeline; this does not include long-term commitments, Long-Term Off-Take contract offerings (executed two, ten-year contracts for a total of about 24,000 acres).
Disclosure 102-8 Information on employees and other workers a. Total number of employees by employment contract (permanent and temporary), by gender:
Permanent: 43 male, 18 female
Temporary: 0 male, 2 female


b. Total number of employees by employment contract (permanent and temporary), by region:
Permanent:
USA - 45
Canada - 13
Argentina - 3

Temporary:
USA - 1
Canada - 1


c. Total number of employees by employment type (full-time and part-time), by gender:
Full-time: 43 male, 19 female
Part-time: 0 male, 1 female


d. Whether a significant portion of the organization’s activities are performed by workers who are not employees. If applicable, a description of the nature and scale of work performed by workers who are not employees: No, a significant portion of Pipeline Foods' activities are not performed by workers who are not employees. The workers who are not employees are responsible for the following activities: Farm Profit Program consultant, Ag Impact Team consultant, controller on the corporate accounting team, IT/technology support.

e. Any significant variations in the numbers reported in Disclosures 102-8-a, 102-8-b, and 102-8-c (such as seasonal variations in the tourism or agricultural industries): Although we have seasonal variations in the quantity of work we are completing at the facilities, it (as of December 31, 2018) had not changed the number of team members we were employing.

f. An explanation of how the data have been compiled, including any assumptions made: All data was provided by the Pipeline Foods Human Capital Department.
Disclosure 102-9 Supply chain a. A description of the organization’s supply chain, including its main elements as they relate to the organization’s activities, primary brands, products, and services: The vast majority of products and services sourced by Pipeline Foods are crops purchased directly from farmers in the United States and Canada. In addition, Pipeline Foods sources raw and processed organic grain, pulse, and oilseed commodities from India, Ukraine, Romania, and Argentina into the United States. (SEE: Home Page, Economic Performance & Profitability)
Disclosure 102-10 Significant changes to the organization and its supply chain a. Significant changes to the organization’s size, structure, ownership, or supply chain, including:
i. Changes in the location of, or changes in, operations, including facility openings, closings, and expansions: Pipeline Foods was established in February of 2017. During calendar year 2017, Pipeline Foods acquired two assets in Saskatchewan, Canada, one asset in North Dakota and one asset in Missouri in the United States. During calendar year 2018, the Pipeline Foods operational footprint expanded to include a new, owned grain terminal in North Dakota and a leased elevator in Argentina. There were no facility closures in calendar year 2018.
ii. Changes in the share capital structure and other capital formation, maintenance, and alteration operations (for private sector organizations): There were no changes in the share capital structure or other capital formation, maintenance and alteration operations in 2018.
iii. Changes in the location of suppliers, the structure of the supply chain, or relationships with suppliers, including selection and termination: In 2018, Pipeline Foods established and deployed its organic integrity program, which includes a supplier verification process (SEE: Organic Integrity). The deployment of this program did not result in any immediate supplier terminations. Pipeline Foods substantially increased its farmer supplier network in Canada and the United States in 2018, relative to 2017.
Disclosure 102-11 Precautionary Principle or approach a. Whether and how the organization applies the Precautionary Principle or approach: While Pipeline Foods employs aspects of the Precautionary Principle in practice, we have not established a formal Precautionary Principle policy.
Disclosure 102-12 External initiatives a. A list of externally-developed economic, environmental and social charters, principles, or other initiatives to which the organization subscribes, or which it endorses: Pipeline Foods’ vision is to accelerate the availability and reliability of organic, non-GMO and regeneratively-grown food (SEE: Our Company). In all cases, the organic products that we sell come with environmental and social mandates that are overseen by regulatory bodies. As well, Pipeline Foods has voluntarily pursued Project Verified Certification at our Malden, MO facility. In 2019, we have developed our own voluntary non-GMO assurance program, adhered to at all other relevant facilities. In addition, Pipeline Foods has voluntarily secured SQF Food Safety Certification at our facilities in Hope, MN and Cresco, IA. We have also voluntarily secured Kosher Certifications at our facilities in Hope, MN, Cresco, IA and Malden, MO. Finally, Pipeline Foods is a Regenerative Organic Certification Ally.
Disclosure 102-13 Membership of associations a. A list of the main memberships of industry or other associations, and national or international advocacy organizations: Pipeline Foods is an active member in the US Organic Trade Association, and has played leadership roles in various organic integrity and policy development initiatives. Pipeline Foods is also a member of the Canadian Organic Trade Association (COTA), Sask Organic, National Grain & Feed Association, Saskatchewan Trade & Export Partnership, Oregon Tilth, Organic Alberta, American Fats & Oils, Soybean Export Association, Montana Organic Association, and Practical Farmers of Iowa.
Disclosure 102-14 Statement from senior decision-maker a. A statement from the most senior decision-maker of the organization (such as CEO, chair, or equivalent senior position) about the relevance of sustainability to the organization and its strategy for addressing sustainability: We started Pipeline Foods as a mission-driven organization to support the growth and success of regenerative agriculture.

Our work is important. Without it, farmers who are pursuing more sustainable farming practices would have fewer value-added market for their crops. Without it, our corporate customers would struggle to incorporate sustainability through their supply chain. And without Pipeline Foods, our debt and equity providers would not have a boots-on-the-ground partner to help them identify sustainable lending and investing practices to accelerate the availability of organic grains.

We are building supply chains that are more efficient, thereby reducing road-miles traveled. We work with farmers to help them improve their yields without using synthetic chemical inputs. And our customers celebrate success in our sustainability efforts by talking about them with the consumers who ultimately care about what they feed their families and how those crops were grown and brought to market.

Last but not least, our investments in infrastructure have almost exclusively been made in repurposed brownfield sites. We have brought back to life older facilities in rural North America that otherwise may have been torn down or closed. And we provide good jobs at fair wages in support of these families and communities.

We know that sharing our story - both successes and failures - with the world is imperative to fulfilling our commitments to sustainability, integrity and collaboration. We welcome you to follow our journey.

Sincerely,
Eric Jackson
Founder & Chairman
Disclosure 102-16 Values, principles, standards, and norms of behavior a. A description of the organization’s values, principles, standards, and norms of behavior: SEE: About Us. Pipeline Foods’ organizational values and principles were a critical component of the concept of Pipeline Foods before the company was even founded (SEE: statement from Pipeline Foods Founder & Chairman, Eric Jackson). Standards of operation and norms of behavior have been intentionally developed since the company’s establishment. These standards and norms of behavior are captured in a set of company policies and standard operating procedures, the employee on boarding process, through training programs, and through intentional cultural development and internal communications channels. All policies and procedures have been developed and are overseen by the company’s Vice President of Operations Risk Management or the Senior Vice President of Finance & Administration and their teams, and they have been reviewed and approved by senior leadership. Training modules have been adopted from an online training service supplier, and/or internally developed to meet our high standards for food safety, organic integrity, human health and safety, and environmental management. In 2019, the company undertook a significant project to integrate two teams and create a brilliant culture where all employees and the company will thrive. More details will be disclosed on this initiative in 2020. Policies and procedures are not made available in other languages to foreign employees or contractors.
Disclosure 102-18 Governance structure a. Governance structure of the organization, including committees of the highest governance body: Pipeline Foods, LLC is a Delaware limited liability company. Pipeline Foods, LLC is a wholly owned subsidiary of Pipeline Foods Holdings, LLC which is also a Delaware limited liability company. Both entities are active and in good standing in the state of Delaware and the state of Minnesota, the registered place of business for both entities.

Pipeline Foods Holdings is managed by a three person board of managers. The managers are determined by the members of Pipeline Holdings, LLC. All management decisions for Pipeline Holdings, LLC are made by the board of managers. The day to day management of Pipeline Foods is managed by its executive team.


b. Committees responsible for decision-making on economic, environmental, and social topics: There exist no committees or subsidiary governing structures within/under the Board of Managers.
Disclosure 102-40 List of stakeholder groups a. A list of stakeholder groups engaged by the organization: Pipeline Foods proactively engages all four of our key stakeholder groups, which include: customers, farmer and ingredient suppliers, employees, and financial partners. Included in our employee engagement activities are certain contract employees.
Disclosure 102-41 Collective bargaining agreements a. Percentage of total employees covered by collective bargaining agreements: 0%
Disclosure 102-42 Identifying and selecting stakeholders a. The basis for identifying and selecting stakeholders with whom to engage: Pipeline Foods underwent a comprehensive stakeholder evaluation and marketing, communications and brand strategic development process in 2017. During this exercise, the Pipeline Foods leadership was guided by a third party expert through multiple exercises to identify our stakeholder and to define our key stakeholders. These exercises included desktop research, extensive interviews, and internal group brainstorming and decision-making sessions.
Disclosure 102-43 Approach to stakeholder engagement a. The organization’s approach to stakeholder engagement, including frequency of engagement by type and by stakeholder group, and an indication of whether any of the engagement was undertaken specifically as part of the report preparation process: Pipeline Foods’ key stakeholder engagement varies in frequency and approach for each stakeholder group. However, the company anticipated eventually adhering to GRI guidelines for stakeholder engagement from the very beginning of the company’s establishment, so all stakeholder engagement activities have been conducted with intent to utilize stakeholder feedback to define sustainability strategy and reporting. In 2018, a materiality assessment survey was distributed to our four key stakeholder groups, and each stakeholder was asked to force rank a set of industry-relevant issues (SEE: Our Approach). Additionally, Pipeline Foods engages its employee base on a daily, weekly and monthly basis through direct communications, an employee newsletter and other internal written communications, and starting in 2019, a dedicated employee “what matters” survey. Our farmer suppliers receive weekly communications in the form of bid sheets, market updates, and a Farm Profit Program newsletter, if they subscribe. Those communications consistently include opportunities for farmer supplier collaboration and feedback. In terms of food company and other customer engagement, our Sales and Ag Impact Teams are in regular contact with our customer base. Our Ag Impact team, in particular, works with food companies to understand the needs and challenges associated with consumer and corporate demand for traceability, transparency and sustainability. Pipeline Foods has five sets of financial partners. Three of the company’s senior leaders and co-founders are also investors in Pipeline Foods. Pipeline Foods also has three lending institution partners and our primary financial partner is a private equity firm out of New York City, AMERRA. AMERRA is an active part of Pipeline Foods’ day-to-day decision-making and two of the three Board of Managers seats are held by AMERRA. In summary, all of Pipeline Foods’ financial partners are continuously engaged. Additionally, see comments regarding stakeholder engagement in Disclosure 102-42.
Disclosure 102-44 Key topics and concerns raised a. Key topics and concerns that have been raised through stakeholder engagement, including:
i. how the organization has responded to those key topics and concerns, including through its reporting: Key topics and concerns raised by stakeholders are as follows:
Organic Integrity
Economic Performance & Profitability
Soil Health
Financial Implications of Risk Management
Traceability & Transparency
Food Safety
Occupational Health & Safety
Local, Regional or National Product Sourcing/Origination
Regulatory Compliance
Farmer Livelihood
Clean Label Market Growth

In 2018, Pipeline Foods’ Sustainability team, with support of our investor partner, AMERRA, conducted its first materiality assessment SEE: Materiality Matrix). The objective was to engage both internal and external key stakeholders to identify their highest priority environmental, social, and economic priorities, and determine our company's ability to influence stakeholder outcomes on each issue and how we can contribute most significantly to positive impacts in these areas.


ii. the stakeholder groups that raised each of the key topics and concerns, and the top three issues for each:
Farmers
Food Company/CPGs
Investors
Lenders
Venture Capital Firms
Retailers
Non-Profit Farmer Education
Organic Industry Associations
Ingredient Processors
Disclosure 102-45 Entities included in the consolidated financial statements a. A list of all entities included in the organization’s consolidated financial statements or equivalent documents:
- Pipeline Holdings, LLC
- Pipeline Foods, LLC
- Pipeline Real Estate Holding Company, LLC
- Pipeline Foods Southern Cone S.R.L.
- Pipeline Foods ULC


b. Whether any entity included in the organization’s consolidated financial statements or equivalent documents is not covered by the report: No
Disclosure 102-46 Defining report content and topic Boundaries a. An explanation of the process for defining the report content and the topic Boundaries: All reporting covers the entirety of Pipeline Foods’ footprint as described in Disclosures 102-4 and 102-6.

b. An explanation of how the organization has implemented the Reporting Principles for defining report content: Regarding adherence to the four GRI Reporting Principles, see Our Approach for a complete description of how the materiality principle has been applied to identify material topics. Our process for determining key stakeholders and engaging stakeholders is described in Disclosure 102-43. Our approach for ensuring Sustainability Context is described in Our Approach. In adherence to the GRI Completeness Principle, our reporting is based in materiality (SEE: Our Approach), and all Boundaries are disclosed in this Disclosure. As this is Pipeline Foods’ first public reporting effort, there is very little performance to report, however all information provided reflects calendar year 2018 unless otherwise noted.
Disclosure 102-47 List of material topics a. A list of the material topics identified in the process for defining report content: SEE: Our Approach
Disclosure 102-48 Restatements of information a. The effect of any restatements of information given in previous reports, and the reasons for such restatements: This Disclosure is not applicable as this is Pipeline Foods’ first public reporting effort.
Disclosure 102-49 Changes in reporting a. Significant changes from previous reporting periods in the list of material topics and topic Boundaries: This Disclosure is not applicable as this is Pipeline Foods’ first public reporting effort.
Disclosure 102-50 Reporting period a. Reporting period for the information provided: The reporting period for the disclosed information is calendar year 2018 unless otherwise noted.
Disclosure 102-51 Date of most recent report a. If applicable, the date of the most recent previous report: N/A
Disclosure 102-52 Reporting cycle a. Reporting cycle: This report will cover Pipeline Foods’ activity for calendar year 2018 and the first half of our 2020 fiscal year ending June 30, 2020. Thereafter, the reporting cycle will align with our fiscal year, which runs from July 1 to June 30.
Disclosure 102-53 Contact point for questions regarding the report a. The contact point for questions regarding the report or its contents: All questions regarding Disclosures should be direct to Rachel Jackson: rjackson@pipelinefoods.com.
Disclosure 102-54 Claims of reporting in accordance with the GRI Standards a. The claim made by the organization, if it has prepared a report in accordance with the GRI Standards: This report has been prepared in accordance with the GRI Standards: Core Option.
Disclosure 102-55 GRI content index a. The GRI content index, which specifies each of the GRI Standards used and lists all disclosures included in the report: This page is inclusive of Pipeline Foods’ entire GRI Context Standards Index.

Disclosure 102-56 External assurance a. A description of the organization’s policy and current practice with regard to seeking external assurance for the report: Pipeline Foods does not seek external assurance for our sustainability/impact reporting, however our reporting has been reviewed by an expert third party.
GRI 103: Management Approach 2016 The Management Approach for each of the identified material issues is described on the respective material issue pages.
GRI 203: Indirect Economic Impacts 2016 GRI 203-1 Infrastructure investments and services supported a. Extent of development of significant infrastructure investments and services supported: SEE: Home Page

b. Current or expected impacts on communities and local economies, including positive and negative impacts where relevant: SEE: Farmer Livelihood

c. Whether these investments and services are commercial, in-kind, or pro bono engagements: SEE: Farmer Livelihood
GRI 203-2 Significant indirect economic impacts a. Examples of significant identified indirect economic impacts of the organization, including positive and negative impacts. SEE: Farmer Livelihood, Clean Label Market Growth, Organic Integrity

b. Significance of the indirect economic impacts in the context of external benchmarks and stakeholder priorities, such as national and international standards, protocols, and policy agendas: SEE: Clean Label Market Growth, Organic Integrity
GRI 204: Procurement Practices 2016 GRI 204-1 Proportion of spending on local suppliers a. Percentage of the procurement budget used for significant locations of operation that is spent on suppliers local to that operation (such as percentage of products and services purchased locally): SEE: Percent Originated Graph

b. The organization’s geographical definition of ‘local’: “Local” refers to a supplier within 100 miles of our owned and/or operated assets. This refers strictly to the number of farmer suppliers, which constitute more than 95% of our suppliers; we are not currently evaluating others.

c. The definition used for ‘significant locations of operation’: Pipeline Foods owned and/or operated processing and storage assets.
GRI 204: Procurement Practices 2016 - GRI Food Processing Sector Disclosure: Procurement/Sourcing Practices GRI FP1 Percentage of purchased volume from suppliers compliant with company's sourcing policy 100% of purchase volume from suppliers is compliant with Pipeline Foods' sourcing policy.
GRI FP2 Percentage of purchased volume which is verified as being in accordance with credible, internationally-recognized responsible production standards, broken down by standard.
GRI 307: Environmental Compliance 2016 GRI 307-1 Non-compliance with environmental laws and regulations a. Significant fines and non-monetary sanctions for non-compliance with environmental laws and/or regulations in terms of:
i. total monetary value of significant fines: None
ii. total number of non-monetary sanctions: None
iii. cases brought through dispute resolution mechanisms: None

b. If the organization has not identified any non-compliance with environmental laws and/or regulations, a brief statement of this fact is sufficient: Pipeline Foods has not identified any non-compliance with environmental laws and/or regulations, a brief statement of this fact is sufficient.
GRI 308: Supplier Environmental Assessment 2016 GRI 308-2 Negative environmental impacts in the supply chain and actions taken The reporting organization shall report the following information:

a. Number of suppliers assessed for environmental impacts: 95 of 341 U.S. farmer suppliers responded to our first annual grower survey assessing farm practices in 2018.

b. Number of suppliers identified as having significant actual and potential negative environmental impacts: All farms have the potential to have a significant negative impact on the environment, however, 100% of the 95 farmer suppliers responding to the annual grower survey are certified organic farmers, which inherently minimizes the number and magnitude of environmental impacts of farming (SEE: Soil Health).

c. Significant actual and potential negative environmental impacts identified in the supply chain: It is well established that where farmers are not employing minimal tillage, extended crop rotations and other soil conservation practices, the risk of soil erosion, nutrient run-off, and greenhouse gas emissions increases. Two of the 95 farmers responding to the annual grower survey did not employ any of seven-plus soil erosion prevention practices. 100% of farmers employ extended rotations as mandated by the National Organic Program (SEE: Impact Report).

d. Percentage of suppliers identified as having significant actual and potential negative environmental impacts with which improvements were agreed upon as a result of assessment: Pipeline Foods has not yet taken the opportunity to directly engage growers responding to the annual grower survey in 2018 to facilitate improvements to their practices. It is anticipated that some direct engagement will evolve in the coming year(s) in collaboration with food company customers. Pipeline Foods’ Farm Profit Program seeks to provide a variety of resources to support farmers in more aggressively adopting regenerative farm practices.

e. Percentage of suppliers identified as having significant actual and potential negative environmental impacts with which relationships were terminated as a result of assessment, and why: Pipeline Foods has terminated 0% of farmer suppliers completing the annual grower survey as a result of our assessment of their responses, as there were no indications of grower practices failing to meet our supplier qualification criteria (SEE: Organic Integrity).
GRI 403: Occupational Health & Safety 2018 GRI 403-10 Work-related ill health a. For all employees:
i. The number of fatalities as a result of work-related ill health: 0
ii. The number of cases of recordable work-related ill health: 1 lost/restricted workday injuries, and 2 recordable injuries during the 2018 calendar year.
iii. The main types of work-related ill health: We experienced a chipped tooth when an employee was struck by an air hose fitting and an ankle strain when an employee tripped when descending stairs.

b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number of fatalities as a result of work-related ill health: N/A
ii. The number of cases of recordable work-related ill health: N/A
iii. The main types of work-related ill health: N/A

c. The work-related hazards that pose a risk of ill health, including:
i. how these hazards have been determined: Pipeline Foods' Human Health and Safety Team referenced OSHA’s 2018 Top 10 Most-Cited Violations, NGFA’s safety guidance documents, and the OSHA’s Grain Handling Standard (29 CFR 1910.272) to determine the work-related hazards that were most likely to pose a risk of ill health. These hazards were evaluated, safety policies and procedures were developed and implemented, and daily and annual training content was shared with employees for exposed hazards.
ii. which of these hazards have caused or contributed to cases of ill health during the reporting period: OSHA’s Top 10 includes slips, trips, and falls which relates to the Pipeline Foods employee injured while descending the stairs.
iii. actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls: Following the injury, we assessed facility stair design against OSHA requirements and made multiple corrections. We also provided education and training on managing state of mind to reduce risk of rushing and raise awareness to focus eyes on path when moving. We communicated the risk of injury for falls and identified behaviors to reduce or minimize risks when performing work or at home. Pipeline Foods complies with all state and federal regulatory requirements, however, we proactively put in place a robust compliance management system to minimize health and human safety risks.

d. Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded: No workers were excluded from this disclosure.

e. Any contextual information necessary to understand how the data have been compiled, such asany standards, methodologies, and assumptions used: See part c.
GRI 416: Customer Health & Safety 2016 GRI 416-1 Assessment of the health and safety impacts of product and service categories a. Percentage of significant product and service categories for which health and safety impacts are assessed for improvement: 100%; SEE: Soil Health, Organic Intregrity
GRI Food Processing Sector Disclosure: Customer Health & Safety GRI FP5 Percentage of production volume manufactured in sites certified by an independent third party according to internationall-recognized food safety management system standards In 2019, Pipeline Foods acquired facilities in Cresco, IA and Hope, MN that are certified to the SQF Food Safety standard. However, 0% of the volume manufactured in calendar year 2018 was processed by these facilities.
GRI 419: Socioeconomic Compliance 2016 GRI 419-1 Non-compliance with laws and regulations in the social and economic area a. Significant fines and non-monetary sanctions for non-compliance with laws and/or regulations in the social and economic area in terms of:
i. total monetary value of significant fines: None
ii. total number of non-monetary sanctions: None
iii. cases brought through dispute resolution mechanisms: None

b. If the organization has not identified any non-compliance with laws and/or regulations, a brief statement of this fact is sufficient. c. The context against which significant fines and non-monetary sanctions were incurred: None