In April 2019 Ethical Consumer viewed Bayer's website which stated in a FAQ section

"Animal studies are essential for a research-based life science company like us. About 90% of the animal studies we conduct are legally required. Animal research plays an important role in ensuring that the benefits of our products outweigh the risks. Nevertheless, we engage actively in 3R research (reduce, refine and replace animal studies) and use alternative methods to animal studies wherever reasonable.

The company further stated that animal studies were conducted at Bayer "In the areas of health (Pharmaceuticals division, Animal Health business unit), crop protection (Crop Science division) and in the departments responsible for environmental matters (Currenta)."

As a result Bayer was marked down in the Animal Testing category.

Reference:

Bayer website (29 May 2019)