Update to the Third Party Assessment in Malawi

Oct 2017

Control Union’s (CU) assessment of Alliance One Tobacco (Malawi) Limited’s ( AOTM) implementation of the Agricultural
Labor Practice (ALP) program, in 2016 was Malawi’s first assessment of the program. Progress on the implementationof the action plan on addressing findings of the CU report continued as the report underwent adjustments required on thereporting methodology and format, which subsequently impacted the release of the report.

Program management and internal processes
AOTM appreciated CU’s acknowledgement of the positive changes thathave occurred in its contracted farmer base since the beginning of ALP
program implementation. Findings from the CU assessment allowed
AOTM to prioritize and develop a focused action plan starting with the2016 crop year to address the identified issues. AOTM understands that
this will require allocation of sufficient resources to meet the ALP
commitments and an increased level of engagement with contracted
farmers, their families, and workers.
AOTM is committed to achieving long-term sustainability of tobacco
production in Malawi while ensuring that all contracted farmers makecontinuous improvement towards the implementation of the ALP
program.
In 2016, AOTM monitored all contracted farms for compliance with theChild Labor and Safe Work Environment principles. While these two
principles continued to be a high priority for in-depth monitoring in the2017 crop year, AOTM monitored contracted farmers for compliance withall seven principles through our Growers Management System™ (GMS)tool.
A risk assessment was conducted based on all the information gatheredat the end of 2016 crop year to identify risk areas that do not meet ALP
standards across the seven ALP principles which need attention. Thefindings of the risk assessment enabled AOTM to develop Sustainable
Tobacco Production initiatives with robust, concrete, measurable actionplans addressing the risk areas in crop year 2017. AOTM developed three
STP initiatives addressing identified ALP risk areas and all contracted
farmers were monitored for compliance with the associated measurable
standards.

Addressing complex systemic issues
The main focus areas identified by AOTM during the first phase of the ALP program rollout were related to child labor,safe work environment and potential forced labor (tenants). Child labor focus areas reflect issues faced within the entire
agricultural sector in Malawi, where the rural population accounts for 84% of the total population, with about 11 million people
engaged in smallholder subsistence farming (18,570,321 total population est. 2017). At the beginning of 2017, according tolatest estimates, Malawi’s population by age distribution was as follows:
0-14 years: 46.53% (male 4,299,076/female 4,341,129)
15-24 years: 20.49% (male 1,889,240/female 1,915,843)
25-54 years: 27.26% (male 2,512,247/female 2,549,766)
55-64 years: 3.03% (male 268,691/female 294,713)
65 years and over: 2.69% (male 220,608/female 279,008) (2016 est.)
As noted by CU, the tenancy system in Malawi creates risk of forced labor. Tenancy labor is defined as a social relation inwhich tenants and their family members are employed to produce crops on a plot allocated by the leaseholder or estate
owner. The tenancy labor force largely comprises internal (local) migrants mostly originating from the southern regions of
the country, due to the lack of arable land, to the tobacco-growing districts in the Central and Northern regions.

1|PageChild Labor
AOTM does not allow the use of child labor in its supply chain and continues to make efforts to develop initiatives that
address child labor. Primary focus areas for 2016 included monitoring (1) the employment of children on farms, (2)involvement of family children in tobacco production and (2) exposure of children below the age of 18 to hazardous workon farms.

FARMER SPOUSE TRAINING
In order to mitigate the occurrence of child labor, AOTM trained all of its
contracted farmers and workers about its standards and how to remain incompliance with the seven ALP principles and measurable standards, throughvarious mediums of communication such as regular Leaf Technicians farm visits,
drama groups, group meetings and ALP Committees.
Through farm monitoring, AOTM is able to identify contracted farmers withchildren and/or orphans living on the farm so that tailored action plans can bedeveloped. These action plans include = additional monitoring by field staff andtraining to improve contracted farmers and workers knowledge of types ofhazardous work.
The Malawi Employment Act CAP 55:02 Prohibition of Hazardous work forchildren Section 6/(1)/2 does not restrict children 16-18 from working inhazardous work, however, as per ALP program requirements, AOTM has
opted to restrict this age group from engaging in hazardous tasks. AOTM continues to engage with relevant stakeholders
to help them understand the need for greater protection for individuals under the age of 18 and the protection provided
by the ALP program
While feedback to date indicates a positive impact on the mitigation of child labor risks, AOTM continues to monitor, trainand create awareness of the negative impact of child labor.

Mother Groups
Recognizing that women are the catalyst of change due to their child-rearing and care taking role in the communities,
AOTM involve women, and mothers in its child labor elimination programs.
AOTM started providing ALP training to contracted farmer’s spouses in the 2017 crop year and is continuing with theprogram. Encouraging farmer’s spouses to take up community ALP training will help to ensure sustainability of the ALP
program, not only on AOTM-contracted farms but also within communities.
AOTM have initiated the establishment of pilot Mother Groups where the mothers in farming families are encouraged towork together with other women in the community to address child labor issues and gain a deeper understanding ofchild labor laws. The participation of women is essential as they take a major role in defining the greatest needs offamilies, including education and wellbeing, and therefore are an influential demographic group that could greatlyinfluence ALP awareness and adherence in the communities.
Specific objectives of these groups include: (1) training mothers in peer training skills; (2) training mothers in child labor
regulations; (3) training mothers in child labor monitoring; and (4) enforcing and monitoring compliance with child laborlaw.

2|PageCommunity ALP Committees
AOTM began involving community members in the ALP program in 2015, through the introduction of ALP Committees
which aim to strengthen ALP implementation at the farm and community level. The development of this community
committee framework presented the community with an opportunity to contribute to the evolution and implementationof good Agricultural Labor Practices.
ALP Community Committees facilitate the dialogue about ALP by providing direct training and technical assistance to theidentified growing area sites, serving as a repository for community information, and acting as a resource for tobacco
farmers, workers and the community at large interested in learning more about ALP and its implementation. The sharingof successes, failures, and frustrations now forms an integral part of this process.
Without strong ties to the community, AOTM did not have access topertinent information from community members that could help early
identification and remedial actions and/or deter incidents. Community
members have been more forthcoming with helpful information whereAOTM has established a relationship of trust within the community.
Establishing trust with communities has taken time, but has beenachieved once community members understood that AOTM is genuinely
interested in community perspectives and problems. They have started
to view the ALP program as a part of community enhancement.

Safe Working Conditions
In the 2017 crop year, AOTM improved its visualizations to show what
constitutes adequate Personal Protective Equipment (PPE), according tothe Malawi Occupational Safety, Health and Welfare Act CH 55:07 section
58. The visual display demonstrates how farmers are intended to correctly
use PPE.
It is the farmers’ responsibility to enforce the proper use of PPE on thefarm and maintain PPE in a clean, sanitary and reliable condition. Worn ordefective PPE should be replaced. This responsibility is included in the
farmer contract and explained by the leaf technicians during contract
signing. Contracted farmers are required to train his/her workers on proper
PPE usage and storage.
Leaf Technicians use the farm visits to monitor effective enforcement ofsafe work environment which includes worker accommodation, PPE, Green
Tobacco Sickness (GTS) prevention and Crop Protection Agent (CPA)
handling. Contracted farmers are expected to train their workers at eachrelevant crop stage (seedbed, land, crop stages). Training records aremonitored through inspection of the farmer book, a record-keeping andeducational tool provided by AOTM. Training records should have worker
signature/thumbprint. In 2017 and going forward, AOTM intensified
monitoring of worker training by farmers to ensure greater awareness andencourage adherence to the standards set forth in purchase agreements.

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Safe CPA storage was also addressed and AOTM will continue to provide contracted farmers with tins/buckets to safely
store CPA containers on the farms.

ALP posters all updated
to communicate a clearer
and consistent message.

ectFarmer/Tenant Minimum Standards
In August 2015, AOTM actively participated in industry stakeholder
meetings with the Malawi Ministry of Labor that led to government
approval of Industry Minimum Standards relating to Farmer/Tenant
agreements. The minimum standards are intended to protect not only
the worker/tenant only but also the farmer through written contractual
agreements.
In the 2016 season both the seven ALP Principles as well as the minimum
standards were incorporated in the AOTM/Farmer written contract
agreement.

Final remarks
AOTM’s ongoing efforts to strengthen and sustain ALP program
implementation encompass significant engagement with various
stakeholders, including relevant government ministries, farmers,workers and the surrounding communities.
All AOTM’s contracted growers are sensitized on ALP issues and arerequired to attend training by the Leaf Technicians (LT) and the Area
Field Administrators (AFA). All are contractually obligated to comply withall the seven ALP principles. Through the IPS system and its ALP
programs, AOTM is better able to reach and educate its contracted
growers on the importance of ALP compliance.

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