CW 3 Manager of the Accounting North Goonyella, Peabody Class Action
62. CW-3 was employed by Peabody as Manager of the Accounting team throughout the Class Period. In his role as a Manager of Accounting, CW-3 managed the accounting for the “coal trade” and worked closely with the Peabody trade desk.
188. CW-3 stated that Peabody’s initial projections for North Goonyella re-opening after the fire were very ambitious. CW-3 advised that at first, the Peabody forecasting team was using a mathematical approach to calculate which portions of the North Goonyella mine were “not good” but, as time went on, forecasting’s reliability decreased and their risk for inaccuracy increased.
189. CW-3 added that there was an internal model at Peabody that was used to make predictions, but eventually, they had to scrap the predictions because when North Goonyella was included and they kept missing the mark, in essence, it was more of “a burden than a benefit to include the predictions on North Goonyella.” CW-3 recalled that predictions were still being included during the summer of 2019.
190. CW-3 worked on the coal trade team, which contributed trade numbers and forecasts to hedge the trading side of the business. According to CW-3, Justin Burk (Peabody Sales & Trading) and Bryan Galli (Chief Marketing Officer) were the heads of the trade team and primary users of forecasted material. Galli reported either to COO Charles Meintjes or directly to CEO Kellow.
191. CW-3 recalled that CFO Schwetz had oversight on forecasting for production, but not sales. According to CW-3, everything with trade went through Bryan Galli, and that at that time, Galli and Kellow would have both been on Peabody’s Board and should have been very informed as to what was occurring. CW-3 advised that there were sales and trade meetings on a weekly basis that Schwetz periodically attended.
192. CW-3 said that there was a team that managed forecasts and that St. Louis was the main hub to which various mine sites in Australia sent their sales number and other information. CW-3 recalled that there was a lot of internal discontent over how the numbers came together and that there were inaccuracies in the numbers. CW-3 added that there was an effort during his tenure to address the problems related to forecasting specifically.
