The Lacuna Project

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Exhibit 105

Report on behalf of Bayer AG on Monsanto stakeholder lists

Exhibit 105 ยท Commissioned legal review

Report on behalf of Bayer AG on Monsanto stakeholder lists

Sidley Austin's report for Bayer on FleishmanHillard's stakeholder lists for Monsanto reports that 1,475 individuals were notified, and that 14 list documents held 1,208 names covering France, Germany, Italy, the Netherlands, Poland, Spain, the United Kingdom and EU-institution lists. Sidley found no support for the allegation of illegality.

Source
Sidley Austin LLP for Bayer AG
Date
5 September 2019
Grade
Primary record
Document
https://www.bayer.com/sites/default/files/SA_Report%20on%20Behalf%20of%20Bayer%20AG%20%285%20September%202019%29.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit
Note
Context for the French list, the Le Monde complaint and the agency's suspension: https://corporateeurope.org/en/2019/09/fleishmanhillards-secret-lobby-campaign-monsanto; https://www.ecowatch.com/bayer-pr-firm-investigation-monsanto-file-2637187810.html. Those details are not in the report and are not exhibits yet.

Cited by

Finding MED-4.7
Reported Before IARC classified glyphosate in 2015, a Monsanto plan set the goal "Orchestrate Outcry with IARC Decision." In 2016 its public relations agency compiled stakeholder lists that Bayer's outside counsel counted at 1,208 names in 14 documents, covering seven countries and EU institutions.