Holding the World’s Largest Meat Company to Account – On Behalf of Greenpeace Netherlands
The Background
Our work with Greenpeace on the JBS matter did not begin yesterday. In 2025, when JBS restructured its global corporate group and integrated a Dutch top-holding company in its corporate structure — a move timed to facilitate an IPO on the New York Stock Exchange — we acted swiftly on Greenpeace’s behalf in the context of their campaign against the negative impacts of ‘big agriculture’ on planetary boundaries.
At that stage, we addressed a letter to JBS’s presumed Dutch notary, placing him on notice of the serious anti-money laundering and compliance risks he assumed by facilitating the redomiciliation of a company with JBS’s documented history: a holding company that had pleaded guilty to violations of US foreign bribery law, paid over $256 million in criminal fines, and acknowledged corruption at the highest executive levels as the engine of its global expansion.
The notary’s role under Dutch law is not merely administrative. Where there are material red flags – and there were many – professional duties of care and anti-money laundering obligations require scrutiny, not rubber-stamping. That letter was part of Greenpeace’s broader effort to challenge the legitimacy of the restructuring and the NYSE listing.
The 30 April demand letter is the natural continuation of that work, now directed at JBS’s board itself.
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$86bn
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241 Mt
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$2.5bn
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470k ha
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| JBS REVENUE 2025 | ESTIMATED CO₂EQ EMISSIONS 2023 | NIGERIA EXPANSION PLAN | DEFORESTATION LINKED TO JBS (2009 – 2023) |
The Legal Case
Why We Advised JBS Is in Breach of Dutch Law
JBS moved its parent company to the Netherlands and listed on the NYSE. By making that choice, the company and its board submitted themselves to Dutch law — including the Dutch duty of care under Article 6:162 of the Dutch Civil Code and the corporate governance obligations that apply to listed companies under the Dutch Corporate Governance Code.
That duty of care, as developed through landmark Dutch climate litigation, requires major companies to take concrete measures to reduce their contribution to dangerous climate change, protect biodiversity, and respect the rights of vulnerable groups. It extends across a company’s entire value chain, not merely its own operations.
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THE CORE ALLEGATION JBS has published extensive sustainability commitments. It has also systematically failed to honour them — while planning $5–6 billion in new infrastructure expansion that would lock in decades of additional harm. |
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The evidence assembled in our letter — drawn from JBS’s own filings, independent research, government records, and investigative journalism — supports three distinct allegations of breach.
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I. Dangerous Climate Change JBS’s ‘Net Zero by 2040’ pledge was stripped of its SBTi validation, found misleading by US advertising regulators, and settled with the New York Attorney General. The company now has no absolute emissions reduction plan — only intensity targets that allow total emissions to grow as output expands. |
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II. Biodiversity & Ecosystems Despite commitments dating to 2008, JBS’s supply chain continues to be linked to large-scale Amazon deforestation. Its own advisors and ranchers describe the deforestation-free pledge as unenforceable, and its monitoring system — focused only on direct suppliers — is not fit for purpose. |
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III. Rights of Vulnerable Groups JBS operations and supply chains have been repeatedly linked to forced labour, child labour, and the illegal use of Indigenous lands in Brazil and elsewhere — resulting in regulatory settlements, court orders, and a $4 million US Department of Labor agreement in 2025. |
A KEY LEGAL ARGUMENT
Expansion as a Legal Risk: The Climate Lock-In Principle
One of the most significant legal arguments in our letter draws directly on the Shell ruling. The Dutch Court of Appeal recognised that major capital investments in fossil infrastructure create a ‘lock-in effect’: to generate a return on investment, the infrastructure must be used to maximum capacity for years or decades — making systemic transformation harder and more expensive with each passing year.
We argue that the same logic applies to JBS’s planned expansion of industrial meat processing capacity. Building new slaughterhouses and processing plants in Nigeria, Vietnam, Saudi Arabia, and Oman is not a neutral business decision. It creates structural lock-ins – economic, social, and environmental – that will shape agricultural systems, land use, and GHG emissions in those regions for decades.
JBS proposes to spend $5–6 billion doing precisely this, without any publicly available environmental or social impact assessments, and without consultation with affected communities. Until JBS demonstrates that its expansion is compatible with the Paris Agreement, the Kunming-Montreal Global Biodiversity Framework, and Dutch law, they are called to halt all new capital investments.
TIMELINE
2025 — NOTARY LETTER
Acting for Greenpeace Netherlands and Greenpeace International, we addressed the Dutch notary of JBS, alerting him to anti-money laundering and professional compliance risks arising from his role in facilitating JBS’s redomiciliation and NYSE listing. The letter drew on JBS’s admitted history of systemic bribery and called for independent scrutiny before any further notarial acts.
2025–2026 — FURTHER CASE DEVELOPMENT
Greenpeace Netherlands and our team (notably Nikki Wilwik) assembled a comprehensive factual and legal case, drawing on JBS’s own sustainability reports and SEC filings, independent emissions research, satellite deforestation data, court records, and investigative journalism across four continents.
30 APRIL 2026 — FORMAL DEMAND
We sent an, admittedly: pretty long, legal demand letter to JBS N.V.’s management board in Amstelveen, asserting breach of the Dutch duty of care across three domains, requesting extensive documentary disclosure under the new Dutch evidence law, and calling on JBS to halt all expansion pending compliance assessment. Greenpeace activists simultaneously campaigned at JBS’s AGM in Amsterdam.
NEXT STEPS
JBS has three weeks to respond and provide the requested information. If it fails to do so – or if the information confirms the concerns – Greenpeace Netherlands reserves the right to seek judicial intervention, including court-ordered disclosure, witness hearings, and independent expert examination of JBS records.
INFORMATION REQUEST
Transparency as a Legal Obligation
Under the new Dutch law of evidence that came into force on 1 January 2025, parties with a legitimate interest may demand access to specific information held by another party – without needing to initiate full proceedings first. Our letter invokes this provision to require JBS to produce a detailed set of documents and data, including:
- Comprehensive GHG emissions data broken down by gas, region, and supply chain stage – including deforestation that JBS currently excludes from its reporting.
- Digital mapping files showing the geolocation of its livestock and feed supply base.
- Data on supplier non-compliance with its own environmental and human rights policies.
- The full Memorandum of Understanding with the Nigerian government and any related agreements.
- Board-level documentation on expansion decisions since May 2025.
- Environmental and social impact assessments for all announced expansion projects.
JBS has long claimed, through its own sustainability policies, that it monitors and manages these impacts. If that is true, the information exists. Our letter requires them to produce it.