According to the Complaint, Braskem S.A. is purportedly the largest producer of thermoplastic resins in the Americas, based on the annual production capacity of the Company's twenty-nine plants in Brazil, six plants in the U.S., two plants in Germany, and four plants in Mexico, as of December 31, 2019. The Company's segments include, among others, its Vinyls Unit, which involved salt mining operations in Alagoas, Brazil.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements regarding the Company's business, operational and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and/or failed to disclose that: (i) Braskem's salt mining operations were unsafe and presented a significant danger to surrounding areas, including nearly two thousand properties; (ii) the foregoing foreseeably increased the risk that Braskem would be subjected to remedial liabilities, including, but not limited to, increased governmental and/or regulatory oversight or enforcement, significant monetary and reputational damage, and/or the permanent closure of one or more of its salt mining operations; (iii) accordingly, earnings generated from Braskem's salt mining operations were unsustainable; (iv) Braskem downplayed the true scope and severity of the Company's liability with respect to its salt mining operations; and (v) as a result, the Company's public statements were materially false and misleading at all relevant times.