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Letter to Neogen

• << Back to 2002 Meeting Archives

Dear Sir,

RainFrog Ethical Investment Partnership would like to take this opportunity to explain why we have voted to sell our shares in Neogen Corporation.

Initially, our partnership was pleased to purchase stock in Neogen and to support your work in the food safety and animal health industries. However, in July of 2004 it came to our attention that Neogen had acquired Hacco Inc., a company that manufactures diphacinone rodenticides. As a socially responsible investment partnership, we simply don't feel it is appropriate for us to invest in the production of a known carcinogen and environmental toxin.

The danger diphacinone poses to mammals is summarized in the EPA report Reregistration Eligibility Decision: Rodenticide Cluster (EPA-738-F-007, July 1998. HYPERLINK "http://www.epa.gov/REDs/" http://www.epa.gov/REDs/.) Potential environmental threats have led to legal challenges against diphacinone use. For example, in 2001 the Animal Protection Institute (API) filed a petition against the California Department of Fish and Game to stop the prevent the use of diphacinone to control rabbit populations. According to the API, every county in California has now labeled diphacinone as "too dangerous to use."

While RainFrog recognizes the need to control rodent populations, we simply don't feel that toxic chemicals are in the long-term best interest of our environment or of the human populations that depend on that environment. We believe that rodents populations can be more appropriately checked with sanitation, the maintenance of natural control systems, and where necessary, with mechanical trapping. As ethical investors, we cannot invest in a product that we would not like to see used in our own communities.

For the reasons above, we have decided to discontinue our investment in Neogen. If Neogen should exit the toxic chemical industry in the future, we would be happy to reconsider our investment decision.

Yours sincerely,

R. Tucker Gilman
President