Assessment of Missirian’s
Oriental farmers
Komotini and Katerini, Greece

Agricultural Labor Practices Program

August, 2016

Assessment

Table of Content
Executive summary .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 3Market and company background .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 61. Implementation of the ALP Program .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 81.1.

Commitment to the ALP Program. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 9

1.2.

Strategy and objectives .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 9

1.3.

Internal capacity.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 10

1.4. Communication of the ALP Code requirements to farmers.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 15
1.5.

Internal monitoring: data collection, accuracy, and addressing issues .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 19

1.6.

Address systemic and/or widespread issues. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 22

2. Farm-level assessment of working conditions regarding the ALP Code Standards .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 25
2.1.

ALP Code Principle 1: Child labor. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 26

2.2.

ALP Code Principle 2: Income and work hours .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 28

2.3. ALP Code Principle 3: Fair treatment. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 31
2.4. ALP Code Principle 4: Forced labor. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 32
2.5.

ALP Code Principle 5: Safe work environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

2.6. ALP Code Principle 6: Freedom of association.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 37
2.7. ALP Code Principle 7: Compliance with the law .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 38
3. ALP Program: feedback from farmers, workers and other stakeholders . .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 39
Appendices.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 41
Appendix I – Missirian Action Plan. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 42
Appendix II – Scope and methodology .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 54
Appendix III – Legal information.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 60
Appendix IV – Findings Farm-by-farm monitoring system .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 71
Appendix V – Communication materials .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 73
Appendix VI – Glossary. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 84

EXECUTIVE SUMMARYASSESSMENT
Missirian’s Oriental farmers

Assessment

As part of PMI’s Agricultural Labor Practices (ALP)
external monitoring system, Control Union (CU)
conducted an assessment of the ALP Program
implementation in Missirian’s oriental tobacco
growing operations in the Komotini and Katerini
areas of northern Greece. The assessment evaluatedthe labor practices at contracted farms and whether
these were meeting the standards of the Agricultural
Labor Practices (ALP) Code. 1 CU also evaluatedMissirian’s internal capacity to implement the ALP
Program and its understanding of farm practices,and how issues were being identified, recorded andaddressed.

ALP implementation. Furthermore, several risks
were not included in Missirian’s risk assessment andit was not linked directly with their action plan.

Over a two-week period CU visited 66 farms, 24
in Katerini and 42 in Komotini, and interviewed
80 family members, 68 workers, and six village
facilitators – the field technicians’ main contact inthe villages. The village facilitators supported CU inlocating farmers and fields, and encouraged not yet
contracted farmers to engage with Missirian.

At the time of the assessment, communicationof the ALP Code to farmers was mainly done
individually during field technician visits and witha set of written communication materials. Several
inaccuracies were identified in these documentsthat could lead to misunderstanding among farmers.
In addition, CU identified several major knowledge
gaps on ALP among field technicians and a numberof minor gaps at management level.

Aninformation
triangulation
methodology
was used to evaluate farm practices. The threesources included interviews, documentation andobservation, together with a “Five Whys Analysis”
of problems. The “Plan, Do, Check, Act” cycle wasadopted for analyzing Missirian’s management
approach. CU interviewed eight managers, 15
field personnel, and one representative from the
PMI Regional office. Additionally, CU interviewed
four stakeholders: three representatives of
farmer associations (two in Katerini and one in
Komotini) and one representative of Food Standard,
responsible for the support mechanism.
Missirian specializes in the production of Oriental
tobacco. The company first implemented ALP in
Greece in 2012, and has made progress with theimplementation ever since. Although Missirian
performed an annual risk assessment, CU foundthat it did not have a clear long-term strategy for

Organizational capacity was created to implement
the ALP Program. Missirian invested in training its
field technicians and a digital system was developed
in-house to gather farm data. In addition, Missirian
implemented several initiatives to improve farmlabor practices, which were mainly directed towards
child labor and safe work environment, and improve
the farmers’ cash flow during the season to enable
them to buy crop inputs and pay employees.

Although communication on ALP was mainly
directed towards farmers, their wives sometimes
listened in on the meetings with the field technician.
To enhance communication to female family
members Missirian had recently employed two
female field techncians. External (migrant) workers
were not targeted in ALP communications, although
in two pilot areas they received information about asupport mechanism developed by Food Standard incooperation with PMI’s local affiliate, Papastratos.
While most farmers were aware of the ALP
Program, fewer family members and almost none of
the workers were aware of its existence. In a review
of awareness on the specific ALP Code Principles,
CU identified that child labor and safe work
environment were best known, while knowledge ofthe remaining principles was found to be weaker.

1.	 The main goal of the ALP Code is to eliminate child labor and other labor abuses progressively where they arefound,and to achieve safe and fair working conditions on all farms from which PMI sources tobacco (https://www.pmi.com/resources/docs/default-source/pmi-sustainability/alp-code9a7cd8bc6c7468f696e2ff0400458fff.
pdf?sfvrsn=0). For more information on the background of the ALP Program https://www.pmi.com/sustainability/
good-agriculturalpractices.
4

Assessment

Missirian used an in-house system to gather
farm data, including Farm Profiles, farm-by-farmmonitoring, and Prompt Action issues. FarmProfile data was generally accurate and only minor
inaccuracies were identified. However, farm-byfarm monitoring with integrated Prompt Action
reporting contained a large number of inaccuracies.
Field technicians focused mainly on child laborand safe work environment, and did not report
Prompt Actions for the other ALP Code Principles.
Instead, field technicians reported farms as meetingthe standard for these ALP Code Principles bydefault. Furthermore, cases of child labor and safe
work environment were recorded as meeting thestandard, but some of those reports were inaccurate.
CU identified several systemic widespread issues
during the assessment, mainly: family children
involved with hazardous activities; migrant and local
workers with no formalized employment; mainly
migrant workers being underpaid and exceedingworking hours; issues with CPA practices and usageof protective clothing and PPE. In addition, CU
noted indirect, delayed and end of harvest payments
which are considered risks of forced labor.
During the CU assessment field technicians,
farmers, and several family members referred tothe benefits of the ALP Program and understanding
more clearly the issues of farm safety, PPE usage,
and the importance of a reduction of CPA usage inthe field. Also several interviewees mentioned an
reduction in child labor risks. However, there wasno structured way for the field technicians to obtainsuch information and report this to the ALP Steering
Committee.
This assessment can be used in future as amanagement tool to help instill continuous
improvement throughout Missirian’s organization.
Control Union acknowledges the supplier’s efforts
and commitment to addressing the identified
issues, and to seeking out the improvement areas byimplementing a concise and feasible plan of action.

5

MARKET AND COMPANY BACKGROUNDASSESSMENT
Missirian’s Oriental farmers

Assessment

Missirian was founded in 1902 and specializes in the
production of Oriental tobacco. At the time of theassessment, Missirian had a 35% share of the 20,000
tons of tobacco produced in Greece each year, and
95% of the tobacco was exported to 27 countries.2
As Missirian produced tobacco for other customers
in addition to Papastratos and PMI, several otherclient programs were implemented next to the ALP
Program.
Two oriental tobacco varieties are grown in
Greece; approximately 80% Basma and 20%
Katerini. Missirian’s growing areas are located in
the Macedonia, Elasonna and Thrace. The scopeof this assessment was limited to the Katerini and
Komotini regions which are located in the provincesof Macedonia and Thrace (see Appendix II).
Missirian had contracts with farmer associations,which in turn contracted farmers. In total, Missirian

provided field support to 3,751 farmers through its
27 field technicians and six Head field technicians.
Most farmers used one or more machines, such asa tractor, for CPA spraying, or sprinkler irrigation.
Nevertheless, in most cases harvesting and stringing
were done manually.
At the time of the assessment, Greece was in the
midst of the financial crisis and its citizens andcompanies were subject to capital controls. This
meant that monetary access was restricted to €60
per day with the option to withdraw a maximum of€420 in one transaction per week. In addition, EU
farmer subsidies had been reduced3 in comparison
with the previous years, and the taxation system
had changed to tax farmers more heavily.4 Thesedevelopments had a significant impact on the
farmers’ financial situation, limiting their ability
to access capital and reducing their cash flow withwhich to pay for labor and crop inputs.

2.	 Source: Missirian
3.	 Farmers ‘EU Rights’ decreased from 2015 to 2016 by 8%. This decrease rate is annual and started from crop 2015
until 2019 (total decrease 40%) of the amount of the rights that the farmers were receiving until 2014 (Source:
Missirian).
4.	 Farmers taxation increase from 13% in 2015 to 22 & 26% (2 rates depending on the income amount) of their net
income in 2016 (Source: Missirian).Source: Missirian.
7

Chapter 1

IMPLEMENTATION OF THE ALP PROGRAMASSESSMENT
Missirian’s Oriental farmers

Assessment

1.1. Commitment to the ALP Program
Missirian had been implementing the ALP Program
since 2011. Although the ALP Program was seen
initially as just another client requirement, at thetime of the assessment Missirian considered it
useful and important to improve the situation on
the farms. This was demonstrated by the fact that
the ALP Program was not just implemented in thoseregions from which PMI sourced, but in all regions
from which Missirian sourced tobacco.
Commitment to the ALP Program was noted at alllevels of the company. Of the senior management,
the managing director was the most committed. He
mentioned the relevance of improving the situationon the farms and named two important initiatives;
the Contractual Agriculture Card and Health
Insurance (see 1.6). The members of the Steering
Committee also showed individual commitment
and field technicians mentioned that the program
was important to improve farm practices, especiallywhen it came to child labor and safe work
environment.

1.2. Strategy and objectives
Missirian performed a basic risk assessment of
the issues identified. Information regarding therisks was gathered during regional meetings of
the ALP Steering Committee with the Head fieldtechnicians and mainly based on the expertise of theparticipants of these meetings. The information wasused to compile the annual risk assessment.

Missirian’sannualrisk
assessment
consisted of the following list of risks,
which included several potential root
causes of the risks identified.
• The economic difficulties faced by
farmers due to the economic crisis(capital controls, higher taxes, lower
EU subsidies) increased the risk of
involvement of children and a shortageof measures to ensure a safe work
environment• Farmers were disappointed by their lastcrop and were resistant to cooperatewith the ALP Program• Farmers’ children were still keen to help
on the farm
• There was a lack of local places forchildren to spend time during summer• External workers preferred not to havewritten employment contracts• Most workers preferred piece rate, which
can result in overtime• Local temporary workers, who were
mostly from the same village as thefarmers, were reluctant to share
information with field technicians
regarding their employment conditions
and circumstances at the farm.
• Increased fees have to be paid togovernment authorities for non-EU
workers• Difficulties with getting women working
and/or living at the farms acquainted
with the ALP Program, especially in theThrace region.

9

Assessment

Based on the list CU concluded Missirian
had identified the following risks:

The remaining targets were related to
the general implementation of the ALP
Program:• Involvement of farmers’ children• Unsafe work environment• Lack of written employment contracts• Overtime hours• Lack of registration of non-EU workers

Even though clear differences were recognized
between the regions in the annual regional risk
assessments, Missirian did not distinguish between
the regions when describing these risks in theirannual risk assessment. While the above risks wereconfirmed during the external assessment, CU
identified additional risks, including: wages below
the legal minimum, overtime not only related topiece-rate salaries, and a lack of registration ofboth EU and non-EU migrant workers (see chapter2). CU also noted additional underlying factors that
increased the risks for the abovementioned issues(see chapter 2).
In order to improve labor practices, Missirian had
formulated an action plan with targets. This plan
did not directly address all the issues identified in
the risk assessment and it seemed to have been aseparate exercise.

Only the following three targets focused
directly on one or more of the issues
mentioned above:• All farmers to be aware of the “hazardous
tasks”• All farmers to be aware of the Measurable
Standards• 75% of the female population involved
with farm work participate in training• All field technicians to be retrained• All Prompt Action follow-ups to be done
within two weeks• Four visits per farmer are organized toprovide training• All farmers to receive new pamphlets/
stickers• All farmers and workers to be included in
the support mechanism pilot (see 2.3.2)

Targets were mainly based on farmer coverage,
and not on the desired behavioral change (see 1.6).
Also, no evidence was available measuring the
progress against these targets. Action plans had
been created since 2013, but only the first year’s
progress was measured. For all actions the startingand completion date were assigned. The ALP
Coordinator was the main person responsible for all
actions, supported by the Steering Committee.

1.3. Internal capacity
1.3.1. Dedicated organizational
structure
Missirian created a cross-functional ALP Steering
Committee, including the Operations Director, whofunctioned as the ALP Coordinator, the Agronomy
Director and HR Director. The ALP Coordinator
was supported by an assistant. The IT Manager andan external law firm supported the ALP Steeringcommittee when necessary. The (Head) fieldtechnicians formed a link between management andthe farmers, and so were also part of the internal
structure to implement the ALP Program.
Missirian worked in close contact with the PMI
Regional team responsible for the EU and based10Assessment

in Izmir, Turkey. They received regular guidance on the implementation of the ALP Program. In addition,
Missirian worked with Papastratos to develop the support mechanism (see 2.3.2).

Internal structure for ALP implementation

PMI regional
PMI affiliate

Senior management

ALP Steering Committee
Law (external)

ALP Coordinator

IT

HR
Agronomy

Coordinator assistant

Head field technicians (2)Field technicians (14)Farmers(2073)

11

Assessment

1.3.2. Roles and responsibilities
Of the senior management, the Operation Director
was most actively involved with the ALP Programas he functioned as the ALP Coordinator. He was
responsible for managing the field technician
training, data collection, follow-up of Prompt
Actions and communication with the Head Field
Technicians. The other members of the ALP Steering
Committee, the HR Director and the Agronomy
Director also participated in the ALP Steering
Committee although they did not have specific ALPrelated responsibilities. Senior management all
had the responsibility to manage ‘client programs’(of which the ALP Program was one) specified intheir job description. However, no specific ALP
responsibilities were included.
For field technicians the ALP responsibilities were
included in their job description to manage ‘client
programs’. Although ALP responsibilities were notspecifically included, the description included the
responsibility for field technicians to monitor andreport on farm practices and to guide farmers ingeneral. There were two types of field technician:agronomists who had an educational backgroundin Agronomy, and leaf technicians who had
extensive experience in tobacco but no agronomy
background. For agronomy tasks, responsibilities
were clearly divided between these two types offield technician; agronomists provided agronomy
support, leaf technicians purchased tobacco. For
the ALP Program, however, both had the same
responsibilities which consisted of visiting andtraining farmers on ALP, communicating the ALP
Code, and collecting farm data (monitoring, FarmProfiles, and Prompt Action issues). As farmer
support was mainly provided during the crop season,around 33% of the field technicians were employedseasonally. Although most field technicians (10,or 71%) were unaware of the inclusion of these
responsibilities in their job description, all had aclear picture of their ALP-related responsibilities.

1.3.3. Training and knowledge of the
ALP Program
Senior management received guidance on ALP fromPMI Regional including several workshops.

Management employees generally had
an adequate understanding of the ALP
Code, however, the following gaps wereidentified:• ALP Code Principle 1 (Child labor):“children between the ages of 13 to
15 performing light labor” had been
included twice in the regional risk
assessment, while this is allowed in a
family setting by the ALP Code.
• ALP Code Principle 4 (Forced labor):
Three management employees gave
an incomplete explanation, or related
the ALP Code Principle either to fairtreatment or child labor.
• ALP Code Principle 7 (Compliance withthe law): Four management employees
statedincorrectly
thatwrittenemployment contracts were required by
the ALP Code and one mentioned thatterms of the agreement should be fair andas agreed (not mentioned the agreement
should be according to the law). Twomanagement employees thought that
this ALP Code Principle referred tocompliance with all legislation.

Missirian response: “Missirian will test and evaluate
the level of ALP knowledge of all management
employees. Internal rotation of staff to further embed
the program throughout the organization will beconsidered and time allocated to the program will be
increased.”12Assessment

Field technicians were trained on a regular basis andreceived six classroom trainings per year, conductedby the ALP Coordinator and his assistant. Training
materials were provided by PMI and knowledge wasvalidated wit a written multiple choice test. Field
technicians were also accompanied in the field toverify their performance, however, no records ofthis were kept. All field technicians mentioned thatthey found the trainings useful, that refreshing
their knowledge was helpful and they could shareexperiences from the field during the trainings.
An assessment of 14 field technicians’ knowledge
per ALP Code Principle:• Child labor: All field technicians mentioned thecorrect legal minimum working age of 15. All fieldtechnicians also referred to children between
the ages of 13 to 15 as only being allowed tohelp their family. In addition, all field techniciansstated correctly that children below 18 yearsof age should not be involved with hazardous
activities.
All field technicians mentioned the handling andspraying of CPA as a hazardous task. However,four (29%) were not aware that harvesting was ahazardous activity and ten (71%) were not awarethat stringing was a hazardous activity.
• Income and work hours: When asked about thelegal minimum wage all field technicians repliedwith one or more of the following amounts. sevenfield technicians mentioned the monthly wage of€460 (50%); four a daily wage of €26 (29%); foura daily wage of €21 (29%); and three an hourly
wage of €2.60 (21%).

Missirian included the legal minimum wage 5 incommunication materials as being either €460
monthly, €21 daily, and €2.60 hourly (see 1.4.1).
However, in the farm-by-farm monitoring system
the gross daily legal minimum wage was referred
to as €22.83 for employees below the age of 25
and €26.18 for employees above 25 years old.
This might have led to confusion among the fieldtechnicians.
Four field technicians (29%) were aware of the
maximum limit of 40 regular working hours per
week and eight per day, while another two (14%)
only mentioned the maximum daily limit of eight
regular working hours. Six field technicians(43%) referred incorrectly to a 48 hour per
week threshold which was mentioned in earlier
communications of Missirian. The remaining
two field technicians (14%) referred to otherincorrect numbers. Four field technicians (29%)
were aware that the rate for overtime hours was
20% in addition to the regular hourly rate.6
Six field technicians (43%) had someunderstanding of the legal benefits a worker wasentitled to and mentioned social insurance and/or leave. The remaining eight field technicians(57%) did not have any understanding of themeaning of legal benefits, and referred to workers
as being entitled to safe accommodation, food,transportation, drinkable water, etc.
• Fair treatment: The majority of field technicians(13, or 93%) mentioned that no discrimination
should take place on the farm. Ten (71%) referred
to verbal abuse, ten (71%) to physical abuse,eight to sexual abuse (57%), and five (36%) also
referred correctly to the principle of the support
mechanism.

5.	 The gross legal minimum wage in Greece was: €586.08 monthly or €26.18 daily for workers over 25 and, €510.95
monthly or €22.83 daily for workers under 25. Missirian informed farmers of the net wage which was calculated witha deduction of ~21% from the gross legal minimum wage. This 21% was an estimate calculated using the 17.7% social
security contribution plus taxes. From the gross legal minimum, the net minimum wage was calculated to be €460
monthly, €21 daily and €2.60 hourly. (See Appendix III for more detailed legal information).
6.	 The overtime rate was a 20% premium to the paid hourly wage, from the 41st to the 45th hour (five-day working
schedule) and from the 41st to the 48th hour (six-day working schedule). Overtime: no more than 9 hours per day
and 45 or 48 hours per week. Legitimate overtime: up to 120 hours a year, each hour is paid with a 40% augment to
the paid hourly wage; above the 120-hour limit, each hour is paid at a 60% premium to the paid hourly wage (seeAppendix III for more detailed legal information).
13

Assessment• Forced labor: 11 field technicians (78%) knewthat identity documents should not be kept
by the farmer, and nine (64%) mentioned thatworkers should not be forced to work against
their will. Fewer field technicians related forcedlabor to workers having debts with the farmers(6, or 43%) or to prison labor (2, or 14%). Two
field technicians (14%) incorrectly referred to
ALP Code Principles and mentioned topics thatwere related to either income and work hours,
fair treatment, or compliance with the law.
• Safe work environment: Field technicians had
a good understanding of the required safetymeasures for tobacco farms, such as the use of
PPE, CPA storage, having a tidy environment, andthe importance of clean water. However, several
topics were less known by the field technicians;
five (36%) referred to accommodation, five (36%)
to CPA re-entry times, and four (29%) to GTS.
• Freedom of association: All field technicians had
an adequate understanding of this ALP CodePrinciple.
• Compliance with the law: Nine field technicians(64%) explained that workers should be informed
about their legal rights, four (29%) that contracts
should be in compliance with the law, two (14%)
that workers should be registered, and three(21%) that contracts could be either written orverbal. However, two field technicians (14%)
mentioned that the ALP Code Principle was notapplicable as all agreements were verbal, one (7%)
referred to retaining identity documents which
is a risk for forced labor, two (14%) mentioned
incorrectly that a written employment contract
should be in place.

Missirian response:• “Missirian plans to deliver 10 refresher trainings
throughout 2017, focused on all ALP principles,
Measurable Standards, local laws and regulations.
These refresher sessions will include examples
of different situations FT might face on farms. In
addition, individual tests and quizzes will be given
after each training session, to assess the levelof understanding and determine further steps.
This training of all staff included in the program
implementation will take place during the season(from January to July), but mainly before theseason startup (six out of the 10 sessions will takeplace from January to March).”• “In the FT training sessions that will be heldin 2017, a separate session held in Q1 will be
dedicated to refresh their knowledge of the legal
minimum wage, working hours, overtime rates andlegal benefits.”

1.3.4. Internal communication
The ALP Steering Committee held three to four
meetings per year. According to the minutes of thesemeetings, each committee member was focused on
one specific initiative. Additional communication
throughout the year was informal and not recorded.
Field technicians met with the Head field technicianseach morning at their local offices. During thesemeetings they discussed work-related issues suchas the ALP Program and any problems with farmdata collection (for monitoring, Prompt Actions,and Farm Profiles) or initiative implementation. No
records of these meetings were created.
Quarterly ALP reports, which included the progressof the ALP implementation, were produced by the
ALP Coordinator and the assistant and sent to PMI
Regional.

14

Assessment

1.4. Communication of the ALP Coderequirements to farmers
1.4.1. Communication strategy and tactics
Missirian started communicating the ALP Codeto farmers in 2011. At the time of the assessment
farmers received ALP information during the regular
visits by field technicians and they were provided
with several written communication materials,
as shown below. Initially, farmer group meetings
were also conducted, however, this changed toindividual communications as it was found to be
more effective.7 The ALP focus during individual
field technician visits was mainly on child labor andsafe work environment.
Each field technician supported an average 148
farmers, visiting four times a year. Resources werepooled so farms were assigned to two or three fieldtechnicians who provided support and conductedvisits alternately. This meant that different fieldtechnicians would visit the same farm during theseason.

especially in Komotini, Missirian employed two
female field technicians. Although the female fieldtechnicians only spoke basic Turkish, and most
wives of the Komotini farmers spoke limited Greek,
communication was found to be adequate. Workers
were not included in the ALP communication.
Missirianhad
producedthefollowingcommunication materials (see Appendix V):• ALP brochure: including all ALP Code Principles
and Measurable Standards. This was a directtranslation of the ALP Code but there was noreference to the local law.
• GTS leaflet and GTS sheet: containing a clear
description of the causes, symptoms, andtreatment of GTS.
• ALP stickers: informing farmers about several
topics these stickers were easy to use and were
found on many farms in places such as the CPA
storage locker or in the barn:– – 166 sticker: referred to the national
emergency hotline 166, with “ALP” included
as text. There was no additional informationon the purpose of the emergency hotline andit was not stated clearly on the sticker that
this was a national emergency hotline, notrelated to the ALP program. This might havebeen confusing to farmers as there was also asupport line available for farmers in two pilot
areas (see 2.3.2).

Field technicians typically worked with “village
facilitators” who were mostly local farmers whoamongst others helped the field technicians tolocate the farmers they wanted to visit. The reason
for this was that most farmers had several fields andcould be working in any one of them at a given time,making them difficult to find. The village facilitators
also encouraged the local farmers to sign contracts
with Missirian. As the facilitators were mainly
farmers, they were included in ALP communications
although they did not have a specific role for the
implementation of ALP.

– – Re-entry period sticker: contained a clear
description of the re-entry periods for all
CPAs used in the field.

Written communication materials were mostly
focused on child labor and safe work environment
although several elements of other ALP CodePrinciples were included such as income and work
hours, fair treatment, forced labor and compliancewith the law. In their regular visits, male fieldtechnicians communicated mainly with the farmers
and occasionally their wives. As communication withwomen was challenging for male field technicians,– – CPA disposal sticker: clearly explained how
to properly dispose of empty CPA containers
advising farmers to triple rinse them, punchholes in them and dispose them in the waste
collection system. The latter referred toMissirian’s waste collection system andcommunal initiatives to collect empty CPA
containers, which were widely available in thefarming communities (see 1.6).

7.	 In group meetings farmers discussed other topics and it was considered challenging to keep the focus on ALP.
15

Assessment• ALP standards poster: contained a list of 15 basic
tips for farmers about how to run their farm labor
practices. Information included child labor, CPA
application, and statements on requirementsthat needed to be met by farmers who employedworkers. The poster included information on
the by Misirian calculated net salary,8 however
no further information was provided that thisconsidered the net salary and how payments
should be conducted.

Although several communication materials weretranslated into Turkish and Greek, not all weretranslated to Turkish.9 Furthermore, only the
support mechanism leaflets were translated into
Bulgarian and Albanian for workers.
Missirian response:“Communication materials will be revised according
to CU suggestions and the improvements will include:
Additions to ALP Standard posters:

The poster referred to specific age classes andtypes of activities allowed. Stringing and tractor
driving, however, were not included in the list ofhazardous activities, and gloves and long sleeves
were only recommended for harvesting and not
for stringing. Also, goggles were not includedin the list of PPE for CPA application. Although
the poster contained valuable requirements forfarmers with hired workers, it contained only
seven statements which did not include important
information like the obligation to register
workers, payment frequency requirements, or
accommodation requirements.
• ALP Principles poster: contained the names ofall seven ALP Code Principles. The text regarding
income and work hours referred to “equal andfair wages” instead of “legal wages”.

• Recommendation of wearing gloves and long
sleeves during the stringing process;• the obligation to register workers, information on
payment frequency, accommodation requirements,and legal overtime;• Recommendation of wearing goggles for CPA
application;
Changes to ALP Principles poster:• the text for Income and work hours referred to ‘fair
wages’ which will be changed to ‘legal wages’
Change in National Emergency Helpline (166) sticker:
the ALP logo will not be used to avoid confusionand clear reference to the emergency service will be
included;
CU noted that not all communication materials
were translated into Turkish. The GTS leaflet will

• Support mechanism leaflets and hat: Leaflets
containing an explanation of the support
mechanism run by Food Standard (see 2.3.2),
its purpose and method of operation. Hats were
distributed to farmers and workers that could
be used for sun protection in the field during
harvesting. These hats showed the phone numberof the support line and referenced “ALP”. Several
farmers/workers were seen in the field wearing
the hats during the farm visits by CU.

be translated to Turkish, Bulgarian and Albanian,and the National Emergency Helpline (166) sticker
to Albanian (as it is currently only in Greek andBulgarian), in order to ensure migrant workers caneasily understand the information.
In order to achieve better results on the workers’
level of awareness, new informative materials will be
developed in Bulgarian and Albanian and distributed
to all of them, during the next crop season.”

8.	 The gross legal minimum wage in Greece was: €586.08 monthly, or €26.18 daily for workers over 25, or €510.95
monthly, or €22.83 daily for workers under 25. Missirian informed farmers of the net wage which was calculatedwith a deduction of ~21% from the gross legal minimum wage. This 21% was an estimate calculated using the 17.7%
social security contribution plus taxes. From the gross legal minimum, the net minimum wage was calculated to be€460 monthly, €21 daily and €2.60 hourly. (See Appendix III for more detailed legal information).
9.	 Communication materials not available in Turkish: the ALP brochure, the GTS leaflet and GTS sheet, and none of the
stickers.
16Assessment

As result of Missirian’s communication efforts, most
farmers (57, or 86%) were aware of the ALP Code.
Awareness was much lower among family members
and workers as shown in the tables below. In linewith the focus of field technicians on child laborand safe work environment, awareness about these
ALP Code Principles was highest. Awareness of theremaining principles was slightly lower in Katerini
and much lower in Komotini.

Level of awareness of ALP Code Principles
Katerini

Komotini

Katerini

Komotini

Katerini

Komotini

Farmers

Farmers

FamilyFamilyExternal

External(T=24)(T=42)

members

members

workers

workers(T=21)(T=59)(T=43)(T=25)

Child labor

15 (63%)31 (74%)13 (62%)18 (31%)--

Income and work hours

13 (54%)7 (17%)

7 (33%)

1 (2%)--

Fair treatment

12 (50%)5 (12%)

6 (29%)---

Forced labor

10 (42%)2 (5%)

6 (29%)---

Safe work environment

20 (83%)34 (81%)13 (62%)19 (32%)-4 (16%)

Freedom of association

6 (25%)

1 (2%)

5 (24%)---

Compliance with the law

9 (38%)

3 (7%)

6 (29%)---

Means of communication through which the ALP Code was received by farmers
Katerini External workers (T=43)

Komotini External workers (T=25)

Group meeting*13 (54%)19 (79%)During regular visit

19 (79%)34 (81%)

Flyer/poster/stickers

2 (8%)

30 (71%)-

3 (7%)

1 (4%)--

1 (2%)

ALP cap
Farmers association
Visit of PMI representative*One female farmer in Komotini mentioned that she had participated in a female group meeting.

17

Assessment

Level of awareness of ALP Code Principles
Katerini family

Komotini family

Katerini external

Komotini external

members (T=21)

members (T=59)

workers (T=43)

workers (T=25)

Verbally from the farmer

11 (52%)13 (22%)-4 (16%)

Verbally from the field technician*9 (43%)

15 (25%)--Flyer/poster/stickers

6 (29%)

7 (12%)-

1 (4%)*One family member mentioned that they had participated in a group meeting.

Katerini migrant workers able
to speak local language** (T=40)

Komotini migrant workers able
to speak local language* (T=17)
4%

40%
60%

96%
Yes

Yes

No

No

**Katerini farmers mainly communicated with
their workers in Greek.

* Komotini farmers talked to either their workers
in Greek or Turkish.

Missirian response:• “The fact that awareness is lower among family members and workers is a concern, and Missirian will strengthen its
actions to increase their level of awareness. Regarding family members this will be done during the regular visits tothe farms, by paying more attention to principles like Income and Work Hours, Fair Treatment, Forced Labor, Freedomof Association and Compliance with Law. All family members will be retrained in family group meetings, during thenext crop year. According to CU’s observations, more efforts will be given to Komotini area family members, where thelevel is lower level than those of Katerini.”• “During training sessions, we record in our system whether the farmer’s wife was present. To gain a better visibilityon the participation of other family members in the trainings, we will extend our record keeping to include them too.
To address the awareness gap of workers, and due to their limited availability during the season, we will mainly focus
on the distribution of informative material (pamphlets, stickers, posters on their accommodation), and on the spot
training. Furthermore, we will record separately the participation of workers, in order to better evaluate the training.
It is Missirian’s objective to deliver these training to all farm workers over the next two crop seasons (2017 & 2018).”

18

Assessment

1.4.2. Farmers’ responsibilities
Contracts between Missirian and the farmers weremade through farmer associations. A clause had
been included in these contracts and the ALP Codewas added in full as an annex. Field technicians
explained that, as the contract was signed with thefarmer association, the latter was responsible for
explaining the terms and conditions of the contract.
Missirian did not incentivize farmers to encourage
the adoption of the ALP Code. Although farmers
were monitored and Prompt Actions were reported,no concrete consequences were formulated whencertain issues recurred. Although the management
mentioned that five farmers had been excluded
during the previous crop season due to bad
performance, it was unclear to what extent ALP
performance had played a role in the decision.
At the time of the assessment, the farmers’ focus was
not on ALP as Greece was in the midst of the financial
crisis (see market and company background).
Missirian noted that taxes for farmers had been
recently increased and this had a significant impact
on their finances.

1.5. Internal monitoring: data collection,accuracy, and addressing issues
At the time of the assessment, Missirian collected
three types of ALP-related data from the farms:
socio-economic Farm Profiles; situations notmeeting the standard (farm-by-farm monitoring);
and Prompt Action issues. Field technicians were
tasked with obtaining all farm data. The information
was in line with PMI’s approach and was included inquarterly reports shared with the PMI’s RegionalTeam.
All farm data was recorded with the software systemdeveloped in-house that was available in Greek andEnglish. The system allowed field technicians toenter data using a mobile device during the farm
visits, and provided a computer interface to generate
aggregated reports of the data. Field technicians
could directly transfer information during the farm
visits, although the system required an internet
connection which was sometimes reported to bepoor in the field. Most field technicians claimed thatthey had no difficulties using the system; only one(7%) field technician reported that he was not goodat handling mobile devices. In order to facilitate
the reporting for field technicians, pre-selectableoptions were built in to minimize the qualitative
information the field technician had to fill in.
While this made the data more consistent and thereporting less time consuming, a lot of information
was lost by preventing the field technicians fromproviding the context to the reported categories(see 1.5.2 and 1.5.3).
Overall the accuracy of the Farm Profiles was
solid (see 1.5.1), although many inaccuracies
were identified in the farm-by-farm monitoring
information (see 1.5.2). As described in chapters
1.5.2 and 1.5.3, the challenges of farm-by-farmmonitoring and Prompt Action reporting resulted in
Missirian not having a reliable data source to fully
understand all risks and issues. More reliable data
was required to implement effective initiatives toaddress the identified challenges.

1.5.1.  Socio-economic data: Farm Profiles
All farms had an updated Farm Profile for thecurrent season, which were created at the start ofthe season. Field technicians declared that they
updated the Farm Profiles during the season incase any changes in the field were identified. This
resulted in a minor number of Farm Profiles (12%)
for which CU identified inaccuracies. In four cases
the hectares of tobacco grown for Missirian differedslightly than recorded, and in four other cases thepeople working and/or living on the farm were notlogged accurately. These were cases in which either
child family members, adult family members, and/or
external workers were not mentioned, even though
they were present at the farm.

1.5.2. Systematic monitoring: situations
not meeting the ALP Code standards
Missirian started farm-by-farm monitoring in the2015-2016 crop season and was running the system
for the second season at the time of the assessment.
Field technicians were expected to report eachfarm visit, and whether the farm was meeting the19Assessment

standard for each ALP Code Measurable standard.
When the field technician identified an issue notmeeting the standard, depending on the issue, thesystem logged it as a situation not meeting thestandard or as a Prompt Action. In case of the latter,field technicians were presented with six options in
the “toolbox” to improve the situation at the farm(see 1.5.3).
For 61 of the farms (94%) field technicians decided
whether the farm met the standard for each ALP
Code Principle. However, 42 of the farms (69%) fieldtechnicians drew conclusions that did not matchwith the situation on the farm. This was partly due
to the strategy of Missirian to focus on child laborand safe work environment, which meant thatfield technicians did not verify the other ALP CodePrinciples in the field. Although not verified, fieldtechnicians reported those remaining principles
as meeting the standard by default. This resulted
in inaccurate data and CU identified situations notmeeting the standard for those ALP Code Principles(see chapter 2). Additionally, also for the ALP CodePrinciples that were verified by the field technicians,
CU identified inaccuracies:• Child labor (7 cases) family children involved in
tobacco-related activities which they were notallowed to undertake while field technicians
reported that these farms met the standard.
• Safe work environment (23 cases) fieldtechnicians had reported that the farms met
with this principle while CU identified issues likeincorrect CPA storage and issues with PPE usage.
Missirian response: “…we will strengthen the FTs
awareness during the coming crop season training
sessions to improve their reporting and to fully justify
the reasons when a farm meets the standard.”

CU identified the following areas to improve thereporting software :• Several selectable options in the monitoring form
were formulated in a way that was confusing tofield technicians (see appendix IV).
• Several selectable options were not fully
displayed on the mobile device, which meant thatfield technicians could not read them properly.

Missirian response: “Following the CU remark on
confusing terminology in the software, the wording
has been improved as of September 2016 (e.g.
reference to gross legal minimum wage changed to
net legal minimum wage, and all selectable options
become fully displayed on the device for better
reading).”

1.5.3. Prompt Actions
Missirian has conducted Prompt Action10 reporting
since 2015 and integrated it into its farm-by-farmmonitoring. In total, field technicians reported
30 Prompt Actions in 2015 and 77 in 2016. After
identification of a Prompt Action, field technicians
were expected to report it on their mobile device.
A predefined list of Prompt Actions per ALP CodePrinciple was available from which an option could
be selected. For the current crop season, predefinedreasons were listed as to why the farmer was notmeeting or, in case of a resolved Prompt Action, wasmeeting the standard, although no qualitative data
could be added. For example, if a child was involved
with harvesting, field technicians would record“hazardous work” and “harvesting”, but no details
on the child (e.g. the relation to the farmer, family or
external, age etc). Such information is important togain more insight of the issue and to determine anapproach for remedial action.
As field technicians shared their responsibilities,
a given farmer could be visited by a different fieldtechnician each time. As a result, a field technician

10.	 A situation in which workers’ physical or mental well being might be at risk, children or a vulnerable group – pregnant
women, the elderly – are in danger, or workers might not be free to leave their job
20

Assessmentthat visited a farmer after a Prompt Action wasreported by a colleague might not be able to obtaina thorough understanding of the situation based on
the information recorded in the system. In addition,
the mobile device did not indicate which fieldtechnician had reported the Prompt Action, making
it complicated to request additional information
via phone when necessary; this information was
only visible in the desktop version of the system.
Even though field technicians explained that they
discussed Prompt Actions in the morning at theoffice, no records were made of these meetings.
In general, field technicians checked the Prompt
Actions they had reported and not the ones reportedby their colleagues.
After selection of the Prompt Action category, fieldtechnicians needed to choose from the following six
measures from a “toolbox” to improve the situation
at the farm:• “Farmer’s counseling and overall guidance”• “Farmer’s family counseling in case the family is
involved in the farm activities”• “Distribution of informative/promotional
material”• “Farmer’s refresh training programs”• “Worker’s refresh training programs”• “Notification of ALP Coordinator to intervene
and take action”
All field technicians were aware that Prompt Actions
had to be reported on their mobile device. Field
technicians declared that they conducted follow up
visits within 15 days, which was the deadline set by
Missirian’s management. However, the system did
not send an automatic notification of when a followup visit was required, and the reporting dates were
not easily accessible on the mobile device. Instead,field technicians had the possibility to print out an
overview at the office in the morning and checkthe dates on which they had reported a Prompt
Action. However, there was no evidence that fieldtechnicians actually made use of this option andindeed several mentioned that they kept their own
notes on paper to keep track of Prompt Action
follow ups.
Three field technicians (21%) mentioned that they
considered all situations not meeting the standard
to be Prompt Actions, and one field technician(7%) only regarded children working under 18 asa Prompt Action. The remaining field technicians
had a better understanding; five (36%) referred
to children working, pregnant women working,hazardous work, no payment, and no PPE used orsafety precautions taken when applying CPAs. The
other four (29%) referred mainly to the urgency of a
Prompt Action and mentioned it was a situation thatneeded to be addressed immediately. However, they
provided no specific examples.
On 25 farms (38%) Prompt Actions were checked by
CU, of which 19 related to safe working environmentand six to child labor. In 16 cases (64%) the farmer
was aware of the reported Prompt Action, and foreight of these the farmer stated that he had agreed
with the field technician on how to solve the issue,
such as the provision of a CPA locker by Missirian
or the improved usage of PPE. In eight cases (33%)
the Prompt Actions were not resolved, even thoughfour of these had been incorrectly marked as solvedin the system.
Missirian response:• “To cover the qualitative data gap, as per CU’sremarks, a new data field will be added to thesystem, and will be used during the next crop
season. Missirian keeps records of the age ofchildren in the system which are retrievable by FTs
at any given time. They will be used to gain moreinsight on detected issues.”• “…we will modify the system to send notifications
when follow-up visits are due. This will be in place
for the next crop season (Q1 2017).”• “The name of the FT, who reported the PA, isalso now visible to the mobile device, therefore
everyone who visits the farm has full picture of thedetails concerned.”21

Assessment

1.5.4. Data management and analysis
An overview of ALP-related farm data was available
using the desktop version of the system. This data
was an input for the annual Farm Profile analysis,
conducted by the ALP Coordinator and his assistant.
Missirian used the PMI template for the FarmProfile analysis. Although information as to thereasons why a farmer was meeting a standard or not
was already included in the system for a reported
Prompt Action (see 1.5.2), the overview to extract
this information from the system was not yet built.
Missirian response: “A summary report to display
the reasons why a farm does not meet the standards
will be programmed in the system, as per CU’s
recommendation. This will be in place at the end of
the current crop season (2016). The evaluation ofreasons at the end of this year will be the source of
information to get useful assumptions on the current
situation and build specific strategies for the next
crop season (2017).”

Data quality was monitored by the ALP
Coordinator’s assistant. However, there was noprocedure for checking the reported data andthe assistant had limited time due to Production
department activities. It was not possible tovalidate what data had been checked, although theassistant knew the approximate amount of datathat was expected in each stage of the season. Due
to limited time, only Prompt Actions and situations
not meeting the standard were checked. In addition,
the assistant extracted data to generate quarterly
reports in cooperation with the ALP Coordinator.

1.5.5. Improvement plans for individual
farms
As describe in chapter 1.5.3, for eight of the verified
Prompt Actions (36%) corrections were agreed upon
between field technicians and farmers, howeverthese verbal agreements were not recorded. In
these cases farmers reported that the agreements
entailed the provision of CPA cupboards (fourcases), agreements with the farmer to use a mask

during CPA application (two cases) or agreements to
not involve children in hazardous tasks (two cases).

Missirian response: “During the next crop, Missirian
will introduce the recording of the agreed improvement
plan in the software system, as suggested by CU. This
will help FTs to keep track of the agreed plans.”

1.6. Address systemic and/or widespread
issuesBased on the risks and issues identified (see 1.2), leaf
tobacco suppliers are expected to address systemic
and/or widespread issues through operational(STP) initiatives, community programs (possibly
supported by PMI’s contributions), and engagementwith key stakeholders.
At the time of the assessment, Missirian was
implementing the following operational initiatives:• Vento curing: Missirian promoted Vento curing
and reported that 19 machines were being used;
14 for Basma farms and five for Katerini. The
Vento curing method uses a machine to blow
tobacco leaves into a long net (see picture),
which is then hung in the curing barn. This is atime saving alternative to stringing which is very
labor intensive. Although Missirian did not relate
this initiative directly to child labor, it could
reduce the involvement of children in stringing.
The initial Vento trials by Missirian had notshown an significant reduction in labor.
In total, seven farmers (11%) had used the
Vento machine and only three of them claimed
that they would use it again. Although farmers
confirmed that Vento reduced the stringing
time, they thought that the quality of the cured
tobacco was lower, and that workers found it
uncomfortable as the machine was operated in astanding position.
On none of the farms with the Vento machine CU
observed children involved in stringing, whileat one of these farms a child was involved withcarrying boxes of harvested tobacco.
22Assessment

while working. Farmers also mentioned that thewhite shirt got dirty quickly. In some cases, theshirt provided was too small.
• Distribution of CPA storage cupboard: Ten
farmers (15%) received a CPA storage cupboard
from Missirian. The locker was provided to those
who did not have one as identified in a Prompt
Action and most farmers were positive about it.
However, two farmers reported that no lock wasprovided with the cupboard.

Vento machine used to fill string nets with tobacco for sun
curing.

• Distribution of PPE: 56 famers (85%) received
a PPE set from Missirian. Most of the farmers
were positive about the initiative and reported
that it was a nice gesture of the supplier, good for
health and safety, and it saved money. However,some farmers erroneously claimed that they did
not need the PPE set because they applied CPA
with a tractor. Although PPE is not required
when CPA is sprayed with a tractor with a closed
cabin, PPE are still required during preparationof the CPA. Several farmers mentioned that the
goggles and mask were uncomfortable.
• Distribution of long sleeve shirts for harvesting:48 farmers (74%) received long-sleeve shirts.
Farmers said that while it was nice to receive afree shirt that gave protection from the sun, mostmentioned that it was uncomfortable as it wasmade of polyester and was too hot to wear in thefield. Furthermore, farmers thought the shirt was
unsuitable for harvesting as the sleeves were tooloose and bunched up around the wearer’s arms

The CPA storage cupboard distributed by Missirian• Distribution of first aid kits: 20 Katerini farmers(83%) received a first aid kit from Missirian
which were distributed in 2015. All farmers
were positive and understood the necessity of
the kit. At the time of the assessment the kits
had only been donated in the Katerini region, forbudgetary reasons.
• Waste collection system: For most farmers(57, or 85%) either Missirian’s waste collection
system or a communal collection system wasavailable to discard empty CPA bottles. Whilethe collection points organized by Missirian had
suitable containers to collect the empty CPA
bottles, the communal collection points were
inadequate for safe storage as there was a riskthat residues could leak out and pollute the areas
surrounding the bins.

23

Assessment

Farmers found the waste collection useful,understood why it was needed, and declared thatthe initiative improved the organization in thefields greatly as containers used to be burned.

Missirian CPA container collection bin

for workers (60% of the value). Besides
increasing farmer registration, Missirian
considered this an important measure toensure that farmers had sufficient cash at thepeak of the harvest, which was a challenge
due to the capital controls. According toMissirian the card was used by 2680 famersin 309 villages. CU did not verify the numberof farmers participating in this initiative– – Health insurance: Missirian provided thisbenefit at no cost to over 50% of its contracted
farmers in 100 villages in Thrace since May
2015. The insurance provided farmers withaccess to private hospitals, labs, diagnostics,
and a doctor in case of accident or illness.
CU did not verify the number of farmers
participating in this initiative.
While Missirian had put the above intitiatives
in place to address farm-level and systemic and/or widespread issues. No concrete actions had
been taken on the following practices whichwere identified by CU: payments below the legal
minimum wage, working hours and days off,
indirect payments, formalization of employment,
provision of the legal benefits.

Missirian response:
Communal waste collection bin• Initiatives to address lack of worker registration:
Missirian was aware of the challenges toregister workers (see 2.2.4 and 2.7.2). They
realized that the approach to address this issue
needed to be gradual, as most farmers were noteven registered as employers at the required
government institutions. To encourage farmers
to register, Missirian had pioneered the following
two initiatives:– – Contractual Agriculture Card: This card
provided the farmer with access to a loan
against the contract with Missirian that could
be used for purchasing crop inputs (40% of
the value) and withdraw cash to cover wages• “The number of the materials to be distributed tofarmers, such as PPEs, CPA lockers, or First Aid kits
will be determined at the Annual Risk Assessmentof the current crop and included in the ALP Action
Plan for the following crop.”• “An updated ‘STP Farmer book’ is planned to be
distributed to all farmers before the start of thenext season (Q1 2017), that will help guide themto improve their farm practices and activities. It
will include all ALP related issues, risks, potential
solutions, improvements, legal information etc.”• “Missirian will expand the provision of theContractual Agriculture Card to its farmers in
2017. We hope this initiative to help farmers
convincing their workers to register.”

24

Chapter 2

Farm-level assessment of working conditions
regarding the ALP Code Standards

ASSESSMENT
Missirian’s Oriental farmers

Assessment

This chapter describes CU’s assessment of theworking conditions on farms in regards to the ALP
Code Principles and Measurable Standards.

Frequency of work (t=20)5%2.1. ALP Code Principle 1: Child labor
There shall be no child labor.

20%

5%
5%

Main findings and challenges
65%

2.1.1. Children working and activities
performed
At one farm (4%) visited by CU a child below 15 in
Katerini was considered to be employed as it wasa child of an Albanian worker that was not paid forthe work. This nine-year-old11 child occasionally

Only afternoons

helped carrying relatively light boxes with strung
tobacco. In addition, CU identified four children
below the age of 13 who were helping on theirfamily farm; three at Komotini farms (7%) and one
at a Katerini farm (4%). Of these children, two wereaged 12 and two were nine, and they were involved
with stringing and moving boxes. At three Katerini
farms (13%) and ten Komotini farms (24%) a totalof 20 children below 18 years old were involved inhazardous activities.

Occasional

Only during school holidays
Full shirts full workweek
Full shifts several days a week

Activities children

Frequency of work (t=20)

25%

40%

35%
<13
13-14

Number of children* hazardous activities

15-17

11.	 The legal minimum age for working in Greece is 15 years old. (See Appendix III for more detailed legal information).
26

Assessment

Underlying factors that increase risk
CU identified several underlying factors that
increased the risk of child labor:• Farmers did not understand the risks involved
with certain tasks, such as driving a tractor.
Several farmers were even proud that theirchildren could drive a tractor. Awarenessabout hazardous activities was low with 48
farmers (73%) and workers at 40 farms (89%)
not having a thorough understanding of themeaning of “hazardous work”. Farmers often
did not consider harvesting and stringing to be
hazardous activities.
• 26 farmers (39%) and workers at 27 farms (96%)
were unaware of the legal minimum age forworking with tobacco.
• Three farmers that involved their children in
tobacco-related activities said that they could
not afford to hire workers.

Missirian will promote the use of mechanicalstringing machines for all farms that do not alreadyhave one, and we plan to provide some machines in2017 (based on the current crop risk assessment).
Children generally cannot handle this machine, solabor involvement with this task will be reduced.”

Analysis and priorities
This ALP Code Principle was one of the main focus
areas of Missirian, and child labor was the mostimportant topic in the communication efforts andreporting by field technicians. As mentioned, theVento machine was being trialed with the aim ofeliminating the stringing process, which would
indirectly address child labor. Despite these efforts,
farmers continued to involve their children in(hazardous) tobacco-related activities, indicatingthat additional efforts were required.

• In two instances Katerini farmers and/or workers
reported that there was no supervision available
for children when they were working in the fieldso they had to bring their children with them towork.

Missirian response:• “In 2017 Missirian will reinforce the training to
all farmers and family members, to make themunderstand that these activities [hazardous tasks]
can impact the health and safety of their children
and therefore should be considered hazardous andnot allowed for any person below 18 years old to
be involved with.”• “During Q2 & Q3 2017, FTs will pay more
attention to harvesting and stringing activities,
and the agreed farmer improvement plan will havepredetermined follow up actions.”• “Informative pamphlets targeting the avoidanceof stringing and tractor driving will be developed
and distributed during the next year. As part ofour efforts to avoid stringing by family children,27

Assessment

2.2. ALP Code Principle 2: Income andwork hours

rate communicated and applied by Missirian (€2.60 per hour) Control Union assessed the payment
conditions. Based on the above calculation method,
Control Union reached the conclusion that (i) 15
Katerini farmers (94%) and (ii) seven Komotini
farmers (58%) paid their workers below the legal
minimum wage. The workers on these farms were
hired for harvesting and stringing activities andagreed their payment terms either “by piece rate” or“monthly”. Although in some of these cases, workers
effectively received an amount that was equal to or
higher than the legal monthly minimum wage (€460
per month), however and because this payment was
based on a number of hours that was higher than
the statutory working hours (8 hours per day or 40
hours per week) the workers ended up receiving
lower payments than what they were entitled to.

Income earned during a pay period or
growing season shall always be enoughto meet workers’ basic needs and shall beof a sufficient level to enable the generation of discretionary income.Workers
shall not work excessive or illegal work
hours.
Main findings and challenges

2.2.1. Payment of workers
Based on the Greece legal information (attached
as Appendix III Legal Information) and the hourly

The breakdown of the salaries are shown in thetables below.

Breakdown of calculated daily salaries in Komotini
Type of workers

Hourly wages

Monthly wages

Piece rate*

Salary range

Salaries 0-1.50

Salaries

Salaries

Salaries

LowestHighest(Euro/hour)

1.50<2.00

2.00<2.60

2.60 (Euro/hour)

salarysalary(Euro/hour)(Euro/hour)

and above(Euro)(Euro)--

5 (100%)2.60 Euro/

4 Euro/

hour

hour

450 Euro/

500 Euro/

month

month

2.18 Euro/

2.18 Euro/

hour

hour

-

-

-

-

-

6 (100%)1 (100%)--*Calculated by the number of pieces per day times the price per piece divided by the hours worked.

12.	 The gross legal minimum wage in Greece was: €586.08 monthly, or €26.18 daily for workers over 25, or €510.95
monthly, or €22.83 daily for workers under 25. Missirian informed farmers of the net wage which was calculatedwith a deduction of ~21% from the gross legal minimum wage. This 21% was an estimate calculated using the 17.7%
social security contribution plus taxes. From the gross legal minimum, the net minimum salary was €460 monthly,€21 daily and €2.60 hourly as per Missirian calculation. (See Appendix III for more detailed legal information)
28

Assessment

Type of workers

Salaries 0-1.50(Euro/hour)

Daily wages*

Piece rate**-

1 (7%)

Salaries

Salaries

Salaries

LowestHighest1.50<2.00

2.00<2.60

2.60 (Euro/hour)

salarysalary(Euro/hour)(Euro/hour)

and above(Euro)(Euro)--

9 (100%)28 Euro/35 Euro/dayday

0.9 Euro/

2.70 Euro/

hour

hour

2 (13%)

10 (67%)

2 (13%)****Only for cultivation activities**Calculated by the number of pieces per day times the price per piece divided by the hours worked.
***Although these piece rate payments average to 2.70 euro/hour which is above 2.60 euro/hour, the minimum wage
for these two farms is not met as workers are not able to meet overtime payment requirement.

In addition to the cash payments, workers in
Komotini were provided with food and, whenneeded, with accommodation at no cost. Workers
in Katerini also received free accommodation,
however, they had to arrange food for themselves.
Payments “in- kind” are legally permitted, however
the Greek laws do not specify the value of these typeof payments. Control Union did not find evidence
that these payments “in-kind”13 were deducted fromthe cash payments made to the workers. On theother hand and the same time, there was no specificdata available in the law, in the labor agreements, orin any other relevant documentation on the specificvalue of the “in kind” payments. Therefore thesevalues could not be quantified.
Payments below the minimum wage mainly related
to migrant workers. In Komotini this concerned
Bulgarian migrant workers with a fixed monthly
salary. In Katerini these were mainly Albanianmigrant workers receiving piece rate payments. The
main reason for paying below the legal minimum wasthat farmers paid workers considering local market
dynamics and market rates. In addition, the level ofawareness of farmers and workers about the legal
minimum wage in Greece was low; five Komotini
farmers (38%) and at four Komotini farms (40%)
workers were unaware of the legal minimum wage;
and nine Katerini farmers (53%) and at 14 Katerini
farms (88%) workers were unaware.
Missirian response:• “The findings of CU regarding the workers’
payment, will enhance our attempts to investigate
if and where there are workers that are paid below
the legal minimum wage and whether the overtime
hours are paid. We will focus on these items on
both the FTs and farmers’ training as from thecurrent season.”• “Missirian’s FTs will conduct additional training
to farmers regarding the minimum wage, work
hours, overtime rates and legal benefits. Workers
will also be included in the training courses during
the next crop season, where we will raise theirawareness regarding their legal rights. The trainingof all workers will be completed in the next 2 crop
seasons.”

13.	 Salary payments may be agreed “in kind”, however, there are restrictions. Remuneration in kind cannot cover theworker’s whole salary (however, the percentage of the salary that can be paid in kind is not determined by law) andbenefits in kind should be useful for the worker and his family (see Appendix III for more detailed legal information)

29

Assessment

2.2.2. Payment schedule
15 Katerini farmers (94%) and two Komotini
famers (17%) did not pay their workers regularly inaccordance with the law.14 At these farms salaries
were paid to migrant workers at the end of theharvest for a working period of between one to six
months. When necessary workers could receive
advances on their salary to buy food. The main reason
given by farmers was they did not have the money
before selling the tobacco. As described in 2.2.1
these workers were provided with accommodation
during this period.
Missirian response:• “Missirian will target in the farmers’ training
in 2017 to raise awareness on the regularity of
payments schedule.”• “Missirian will review the schedule of cash
advances given to farmers for the next crop season,
to help them improve their cash flow, especiallywhen worker payments are due.”

2.2.3. Work hours
At all Katerini farms and five Komotini farms (50%)
workers worked more than the maximum legal
working hours. 15 They worked in between 10 and 14
hours per day for five to seven days a week. At 13
Katerini farms (81%) and five Komotini farms (50%)
workers did not receive the minimum one resting
day per week. One of the reasons for the excessive
hours was piece-rate payment, which incentivises

workers to earn as much money as they can during
the harvesting season.
No evidence was found of workers working
involuntary overtime hours. When salaries were
calculated daily or monthly workers did not receive
additional payment for overtime, and piece-rate
payments were not adjusted for overtime either.
This was common practice as farmers and workers
were unaware of the legal requirements regarding
overtime rates. 16

2.2.4. Legal benefits
None of the farmers provided their workers
with the basic entitlements required by law (e.g.
social security, health care, holidays, other leave
entitlements etc.).17 Only at two Katerini farms(12%) and one Komotini farm (7%) part of theworkers were registered and their social security
contributions were covered 18. This was mainly
because workers had no formalized employment andwere not registered with the required government
institutions. Indeed, migrant workers did not wantto have their employment formalized: Albanians(non-EU residents) would have to arrange a work
visa which was expensive; and Bulgarians (EUresidents) did not want to lose their unemployment
benefits back home in Bulgaria, which might happen
if they were registered for work in Greece.

Analysis and priorities
Missirian did not focus on this ALP Code Principle
even though the findings indicate that many

14.	 Payments should be made at least monthly (see Appendix III for more detailed legal information).
15.	 Maximum work hours in Greece were 40 hours per week. Employers are entitled to employ their employees for five
additional hours per week concerning the five-day work system or for eight additional hours per week concerning
the six-day work system. (see Appendix III for more detailed legal information).
16.	 The overtime rate should be at a 20% premium to the paid hourly wage, from the 41st to the 45th hour (five-day
working schedule) and from the 41st to the 48th hour (six-day working schedule). Overtime should be limited to no
more than 9 hours per day and 45 or 48 hours per week. Legitimate overtime should be limited to 120 hours a year,with each hour paid at a 40% premium to the paid hourly wage; above the 120 hour limit, each hour should be paidwith a 60% premium (see Appendix III for more detailed legal information).
17.	 Basic entitlements required by law: payment of social security contributions, paid annual leave, paid leave for otherreasons such as marriage or illness and a Christmas and Easter allowance (see Appendix III for more detailed legal
information).
18.	 Farm workers, who are insured by the Agricultural Insurance Organisation (OGA), should be paid (by the employer)
via “ergosimo”. “Ergosimo” is a method of payment of salary and social security contributions (applicable to specificcategories of employees). The social security contributions to OGA (10% of the nominal value of “ergosimo”), arewithheld from the workers’ salary. (see Appendix III for more detailed legal information).
30

Assessment

farm practices were not meeting the standards.
CU identified gaps in field technician knowledge
regarding the legal minimum wage, working
hours, overtime rates, and legal benefits (see1.3). Furthermore, farmers and workers lacked
knowledge on relevant legal aspects such as theminimum wage, overtime rate, and formalizationof employment. Although Missirian identified piece
rate payments as a risk for overtime hours in theirrisk assessment (see 1.2), no actions were taken to
inform farmers or address this.

2.3. ALP Code Principle 3: Fair treatment

Farmers shall ensure fair treatment ofworkers. There shall be no harassment,
discrimination, physical or mental punishment, or any other forms of abuse.

Main findings and challenges

2.3.1. Treatment of workers
No evidence was found of verbal, sexual, or physicalabuse on the farms visited.19 As farmers and workers
generally had long-term relationships over many
years, farmers treated their workers well to ensure
they would return to work the following season.
Komotini migrant workers were mainly womenand typically lived in the homes of the farmers andtreated as family.

2.3.2. Discriminatory cultural practice
CU identified a cultural practice in Komotini that
could be considered as a discriminatory practice.
Most external workers (22, or 88%) hired in
Komotini were female as farmers in this region, in
general, declared they did not want to have anotherman in their house. This could be seen as a formof discrimination as men would not have equal job

opportunities compared to women. Although CU did
not find any evidence of men who wanted to work at
the farm being rejected by farmers, no interviews
were conducted with men in that region as CU onlyinterviewed people working and living at the farms.

2.3.3. Support mechanism
Support mechanisms help to facilitate workers bygiving access to information and remedy, support
to workers in difficult situations, and mediation of
disputes between farmers and workers. Leaf tobacco
suppliers are expected to ensure that farmers andworkers have access to such a mechanism.
Missirian worked with Papastratos, PMI’s local
affiliate, which had developed a support mechanism
in cooperation with a third-party organization, Foodstandard.20 The first pilot started in 2015 and waspromoted among farmers contracted to the threeleaf tobacco suppliers that supplied to Papastratos,
including Missirian. A total of 800 farmers (Greek
and Turkish speaking) and 900 workers (Greek,
Turkish, Albanian, Bulgarian speaking) were
informed about the existence of the line in two pilot
areas (Vrodou and Arriana).
Although efforts were made to promote the support
mechanism, in the first year only five calls weremade (four farmers and one worker). Therefore,
Food standard started contacting farmers andworkers actively, and went into the field to reachout to 150 farmers and 100 workers. Resulting in
all farmers visited by CU included within the pilot
areas of the support mechanism were aware of theline’s existence. In addition, several farmers outside
the direct pilot area were aware as they had either
heard about the initiative from field technicians
or from other farmers. In total, 14 farmers (21%)
and workers at four farms (14%) were aware. Two
farmers had used the support mechanism and theyfound it useful. In one of those cases the farmer
asked for legal advice about how to formalize
the employment of Bulgarian workers. Workers

19.	 One of the employer’s obligations in Greek labour law is the duty of care / welfare, which involves, among others, theprotection of health and life of workers, and the protection of their personal rights. In addition, workers shall not be
discriminated. (See Appendix III for more detailed legal information)
20.	 https://www.foodstandard.gr/
31

Assessment

reported either that they had no reason to use themechanism, that they were not fully aware of the
purpose of the mechanism, and one of the workers
mentioned to not use the support mechanism as hethought it was only meant for registered workers,
which he was not.

–– Distribute multi-lingual information leaflets forfarmers and workers, and–– Continue to organize field visits in order to meetand discuss with farmers and their workers the
support mechanism, its scope and the operationof the help line.”

CU made two phone calls to test the support line;
one in Greek and one in Albanian. Although the calls
were not directly answered, a return call was madewithin a couple of minutes. It appeared that no one
was able to speak Albanian. A conversation in greek
did take place. The general experience was positive,
and the operator asked for time to check relevant
legislation and then call back. Additionally, CU wasattended in a friendly and polite way. However, theanswers given we not completely in line with the
ALP Code.21
Missirian response:• “Missirian expects to provide access to the support
mechanism to all workers and farms within the

Analysis and priorities
A major effort was made by Papastratos with theintroduction of the support mechanism for the
farmers in the pilot areas. Although farmers were
aware of the existence of the support mechanism,
only a few workers had heard of it. Also, theunderstanding among the farmers and workers as tothe purpose of the mechanism could be improved.
Furthermore, additional insight into the root causesof the culturale practice of hiring mainly female
workers in Komotini should be gained to evaluate
potential solutions.

2.4. ALP Code Principle 4: Forced labornext four years.”• “In order to secure the smooth management ofincoming calls, the detailed Q&A of potential

All farm labor must be voluntary. Thereissues, questions and concerns will be reviewed

shall be no forced labor.

and re-edited in February 2017. Following CU
finding regarding the inexistence of an Albanian
speaking operator, it will be fixed in 2017 contract
with the external third party.”• “To achieve a better understanding of the helpline and message penetration on the support
mechanism to farmers and workers, we willconcentrate on the following actions for the 2017
crop:

Main findings and challenges

2.4.1. No evidence of involuntary labor
No evidence was found of workers who wereunable to leave their employment, workers working
against their will, or contracted prison labor.22 Alsono evidence was found of workers being obliged tohand over their original identity documents or pay afinancial deposit.

21.	 On the question about whether a son of Albanian workers aged 16 could harvest, the answer given was correct
in terms of information on working hours, age proof prior to hiring and no hazardous work. However, when asked
the meaning of hazardous work and whether harvesting should be considered hazardous, the operator replied thatharvesting was allowed as long as the child would use gloves.
22.	 Laws on forced labor: Workers shall be free to leave their work at any time within a reasonable notice period. Forcedlabor may involve situations where the employer: withholds the worker’s identity documents; puts workers in a
debt situation by taking cash deposits or by deducting money from wages or by overcharging for services or goods
provided; withholds wages that the employee is entitled to without a schedule or an agreement or threatens not to
pay salaries in situations where the employee owes money to the farmer and is forced to work until the debt is paidin full; or threatens to report a foreign worker without a residence permit to the authorities. In addition, prison labor
is prohibited in Greece (see Appendix III for more detailed legal information).
32

Assessment

2.4.2. Indirect payment
Four Katerini farmers (18%) paid part of theirmigrant workers indirectly; in three cases payments
were made via the workers’ family members who
were also working at the farm. In one case workers
worked on the farm of another farmer, and payments
were arranged via the farmers. The latter case wasa form of labor exchange in which external workers
were exchanged by farmers. These practices posedrisks of forced labor as farmers could not guaranteethat workers were being paid (properly).

2.4.3. Delayed payments
At four Katerini farms (25%) payments to workers
were delayed. All cases concerned Albanian migrant
workers who received the wages approximately
one month after they had left. The farmers in thesecases went to the border to hand over the money as
the Albanian workers could not enter the country
again due to expired tourist visas which were only
valid for three months.

Analysis and priorities
Although no evidence of forced labor was found,risks were identified that could lead to situationsof forced labor. Missirian implemented the‘Contractual Agriculture Card’ (see 1.6) to improvethe cash flow of the farmers during the crop season.
This initiative might enable farmers to meet theminimum legal monthly payment frequency, thereby
solving the risk of end-of-harvest payments anddelayed payments. However as shown in 2.4.4 thisinitiative had not yet resulted in all farmers paying
workers regularly. For the remaining risks identified
Missirian did not have an initiative in place at thetime of the assessment.

Missirian response:• “…in order to gain a better visibility into therecruiting and payment practices on farms, weenhanced our data collection with information
about migrant workers, including:–– number of years the workers have been brought

2.4.4. End of harvest payment
15 Katerini farmers (94%) and two Komotini
farmers (17%) paid their workers at the end of theharvest. This represented a potential risk of forcedlabor, as these workers had to wait until the endof the harvest to receive their payment. In twocases workers reported that they did not receive
any advance payments to cover basic needs. In
the remaining cases workers declared that theyreceived small amounts of their salary in advance.

to the farm (1-2 years; above 3 years);–– In case of new workers, how did he/she find thejob (e.g. advertisement, recommended by otherfarmer, recommended by other worker, on his
own, via crew leader);–– Whether they work only daily or for a longer
period..”• “In order to further secure the regularity of
payments to workers, Missirian will increase
the cash flow of farmers by expanding the‘Contractual Agricultural Card’ (covering 100%

Underlying factors that increase riskof all contracted farmers in Basma, Katerini, East

Control Union identified four underlying factorsthat increased the risk of the abovementioned
practices. 1) Farmers did not have the required
cash flow to pay workers on a regular basis due tocapital controls in Greece. 2) Farmers did not havemoney to pay workers before selling the tobacco.
3) Workers wanted to receive payments at theend of the harvest, so that they could not spend it
beforehand. 4) Indirect payments were made mainly
to a family relations and were common practice.

has most hired workers population) from 45%

and West Macedonia districts where Missirian
of its contracted farmers in 2016 to 55% of its
contracted farmers in the 2017 crop year.”33

Assessment

2.5. ALP Code Principle 5: Safe work
environment
Farmers shall provide a safe work
environment to prevent accidents andinjury and to minimize health risks.
Accommodation, where provided, shallbe clean, safe and meet the basic needsof the workers.
Main findings and challenges

2.5.1. Training and awareness of GTS
At 19 Katerini farms (79%) and 24 Komotini farms(62%) people handling green tobacco were nottrained on the avoidance of GTS. 23 11 Katerini

Use of protective clothing for harvesting

farmers (46%) and 14 Komotini farmers (35%) were
unaware of the existence of GTS. Furthermore, eight
Katerini farmers (33%) and ten Komotini farmers(26%) did not see the necessity to train workers
and/or family members.
At 22 Katerini farms (92%) and 17 Komotini farms(43%) people handling green tobacco did not wear
the required harvesting clothes. The main reasonsstated for this were that people were unaware of
the necessity to wear protective clothing and/or
considered the protective clothing uncomfortable.
The usage of protective clothing is shown in
the table below. In all cases the gloves used for
harvesting were thin surgical gloves. These were
easily torn, and workers had to use several pairs ofgloves per harvesting session. In addition, several
workers reported that they had an allergic reaction
to the gloves.

Katerini farms

Komotini farms

Long sleeves, long pants, gloves, shoes

3 (13%)

21 (53%)

Long sleeves, long pants, shoes

10 (42%)6 (15%)Long sleeves, long pants, gloves-

5 (13%)Long sleeves, long pants

2 (8%)

2 (5%)Long sleeves, shoes

2 (8%)-Long pants, shoes-

1 (3%)Long sleeves, gloves-

2 (5%)

7 (29%)

2 (5%)

One of the items above

23.	 The Greek law states that employers shall take the necessary measures for the healthy and safe protection ofworkers; shall report accidents to competent Inspection of labor, the nearest police station and social insurance
institute; personal protective equipment (PPE) is needed for using, handling, storing or disposal of CPA’s; CPA use,
handling, storing or disposing should be done without endangering human and animal health, using processes or
methods which prevent damage to the environment. (see Appendix III for more detailed legal information)

34

Assessment

Missirian response: “Missirian will target people

Missirian response: “Further training, promotional

who handle green tobacco, aiming to distribute amaterial (stickers) for 100 % of the contracted farms

full set of PPEs to all contracted farms over the next

and locker distribution will be regularly included in

2 crop years. Further to that, during the next crop

the FTs toolbox for the 2017 crop season, in orderseason, the electronic data collection system will be

to maximize awareness. The number of lockers to

upgraded to include a field to allow FTs to record the

be distributed next year will be determined in theexact missing PPEs on each farm.”

current crop Risk Assessment.”

2.5.2. Training and handling of CPA
Handling CPA proved to be a challenge at the farms.
11 Katerini farmers (58%) and 15 Komotini farmers(43%) did not store their CPA safely. The main
reasons were that farmers did not lock their storage
facility. The CPA containers were lying outside thestorage or stored together with the tobacco. In
some cases the CPA containers were stored in an
unlocked refrigerator, which posed extra risk ofchildren accessing the storage thinking the bottles
contained drinkable liquid.

At six Katerini farms (29%) and five Komotini
farms (15%) people handling CPA were not trained.
Farmers were typically responsible for CPA spraying
and it was obligatory by law to have a license. 28
farmers (42%) declared that they completed agovernment training to obtain the license, however
in ten of these cases the farmers could not show thelicense and declared they had not received it yet.
At seven Katerini farms (41%) and 11 Komotini
farms (30%) people responsible for CPA application
did not use the complete set of PPE. The main reason
was that those handling CPA were unaware of thenecessity to wear (the complete set of) PPE. Other
reasons included the discomfort of wearing PPE orthat they did not think it was necessary.

Use of PPE for CPA application

Katerini farms

Komotini farms

Overall, mask, boots, goggles, gloves

7 (41%)

17 (46%)

Mask, boots, gloves, goggles

1 (6%)

2 (5%)Overall, mask, goggles, gloves

2 (12%)

6 (17%)Overall, mask, goggles

1 (6%)-

Mask, gloves, goggles-

1 (3%)

Boots, gloves-

2 (6%)

Mask, boots

1 (6%)-

Mask, gloves-

2 (6%)

Only one of the items above

2 (12%)

5 (14%)

None of the items above

3 (18%)

2 (6%)

35

Assessment

Missirian response:• “Missirian,through

Missirian response: “Missirian will retrain all of its
the

IPM@PMI

programimplementation, will train all those involved aboutproper CPA spraying techniques and the proper

contracted farmers during 2017 crop year on theproper disposal of CPA containers (piercing, triple
washing & discarding at designated points).”

usage of PPEs. Missirian will record during 2017
crop season the acquisition of spraying licenses by
farmers.”• “Another step taken is the distribution of overalls
to 100% of the farmers, which will be completed
by 2017.”• “Further to that, the electronic data collection
system will be upgraded to include a field where
FTs will record any missing PPEs during the 2017
crop season.”

22 Katerini farmers (96%) and 29 Komotini farmers(71%) ensured that family members did not enter
the field after recent CPA application. There wasa high level of awareness on the re-entry periodamong farmers (59 or 92%), however, only ten
farmers (15%) declared that they used warning
signs after CPA application.

2.5.3. Worker accommodation
Duringtheassessment CU
verifiedsix
accommodations in Komotini and 15 in Katerini. At
five Katerini farms (33%) worker accommodation
was inadequate; there was a lack of personal space,basement area without any windows or it wasconsidered unsafe because workers were sleeping
in the tobacco storage area. Farmers declared thatthey could not afford better housing.
Missirian

response:“Worker

accommodations

have been assessed and they are all equipped withclean drinking water, hot water and kitchens. As
CU reported, there are farms that need to improve
sanitary conditions and we will establish an
improvement plan with the farmer, to be fixed forthe coming 2017 crop. All farms will be up to an
acceptable level by 2019.”

Missirian response: “Another target that has been
set in the IPM program that Missirian is running is
to raise awareness of the field re-entry period after

2.5.4. Clean drinking and washing water

the CPA application to all parties involved. To achieve
this objective, specific leaflets and stickers have been
distributed to 100% of the farms and seminars havebeen delivered to all farmers. All family members
and workers will be included in the 2017 program. A
second initiative is the distribution of 250 field safety
re-entry signs to 125 farmers this year. These actions
will be continued during next year, to cover all farms.”

14 Katerini farmers (61%) and 29 Komotini
farmers (74%) did not wash and discard empty CPA
containers correctly; they typically did not pierce
and/or triple wash the containers before discarding.
Although the majority of the farmers used either acommunal waste collection system or the collection
system from Missirian (see 1.6), nine farmers(15%) discarded containers with the normal waste.
Furthermore, two farmers burned their containers.

No evidence was found of farmers not providing
clean drinking water to family members andexternal workers. At 19 Katerini farms (79%) and 18
Komotini farms (46%) washing water and/or soap
was not available close to where people worked(the fields were in a remote location). These farmers
did not consider it necessary to wash their hands
directly after working in the field and mentionedthat they washed their hands when they reachedhome. In addition, farmers mentioned washing was
not necessary as they were using gloves. In sevencases washing water was available but soap wasnot. One farmer reported to use water from theirrigation pipe for washing.

36

Assessment

2.5.5. Sanitary facilities
Sanitary facilities were not close to the fields inboth Katerini and Komotini. Although in somecases it was reported to be a five minute drive tothe farmers’ premise, workers could not go on theirown. In general, workers went into the bushes whenneeded or waited until after work.

2.6. ALP Code Principle 6: Freedom of
association

Farmers shall recognize and respect
workers’ rights to freedom of association
bargain collectively.

2.5.6. General safety measures
Most farmers did take basic safety measures into
consideration. For example: having a means oftransport available in case of an accident (55, or83%); having a first aid kit on the farm (36, or 55%);
ensuring that their equipment and tools were storedsafely (44, or 67%); and contact details of healthinstitutions were available (41, or 62%). However,none of the farmers had received first aid training.

Main findings and challenges

2.6.1. Workers’ right to freedom of
association
No evidence was found of farmers disrespecting theworkers’ right to freedom of association. Still noneof the workers were connected to an association,and there were no worker associations active in theregion.

Analysis and priorities
Missirian had prioritized this ALP Code Principle
in their communication to farmers, and efforts
were visible with farmers being aware of safe work
environment in general. However, many farmers
were still unaware of topics such as the existence
and avoidance of GTS. Also, awareness on safetymeasures was low among workers.
The initiatives developed by Missirian were in linewith the challenges identified in the field by CU. The
waste collection systems were used by the farmers– although the communal collection was found to beinadequate in many cases – and had improved thesituation in the fields. In addition, many farmers
in the Katerini region had a Missirian first aid kit
available. Having said that, the abovementioned
findings demonstrate that these initiatives had not
yet resulted in the desired behavioral change at all
farms.

Analysis and priorities
This ALP Code Principle was not prioritizedby Missirian which was understandable. Field
technicians had sufficient knowledge on this topic,
however, they did not communicate it to farmers
and workers. Their perception was that freedom of
association was not applicable with the reason thatno worker unions or associations were active in theregions visited (Katerini and Komotini).

37

Assessment

2.7. ALP Code Principle 7: Compliancewith the law

Farmers shall comply with all laws of
their country relating to employment.

Main findings and challenges

2.7.1. Information on legal rights
Typically, workers were only informed about theirbasic employment conditions at that farm; the wage
they would receive, the period of employment, theirtasks, and the moment of payment. However, 13
Komotini farmers (93%) and all Katerini farmers did
not fully inform their workers about their legal rights,
such as the right to legal benefits and legal minimum
wage et cetera. Two reasons were identified for
this: farmers lacked the required knowledge about
legal aspects to inform their workers properly, andfarmers were unaware of their responsibility toprovide this information to their workers.

taxes over the current season and labor costs weretax deductible.
Employment contracts could be concluded verballyaccording to law, however workers should be
informed on the employment conditions in writing. 25
As mentioned in 2.7.1, none of the farmers provided
this information to their workers.

Analysis and priorities
Missirian started an initiative to address the lackof formalization of employment (see 1.6) with thefocus to work gradually toward more formalizationof the farmers’ business. Thereafter formalizationof worker employment would be the next step.
However, CU identified lack of knowledge in theareas of: legal rights among farmers; farmers not
informing workers about their legal rights; andfield technicians having knowledge gaps regarding
this ALP Code Principle (see 1.3). Therefore,
improvement was needed on several levels toensure that the correct information would reachfarmers and their workers.

Missirian response:

2.7.2. Formalization of employment
According to Greek law, employment should
be formalized via the Agricultural Insurance
Organisation (OGA).24 At none of the farms workers
were registered via OGA. Furthermore, payments toworkers should be made via the bank and workers
should be insured. At two Katerini farms (12%) andone Komotini farm (7%) only part of the workers
were paid via the bank.
The main reason CU identified the lack of formalized
employment was that workers did not want to havetheir employment formalized (see 2.2.4). Farmers
on the other hand were interested in employing
workers with formalized employment, as they paid

• “Missirian will provide refresher training to its FTs
in Q1 2017 to cover all gaps identified in theirknowledge of this principle, in order for them to beable to clarify the farmer’s legal obligations to his
workers. The Civil code and local labor laws will be
included in the training material.”• “To improve farmers’ awareness, Missirian will
enhance the training during 2017 crop season
to all its contracted farmers with regards to theentrepreneurial behavior they should adopt. The
training will include information on all the key legal
aspects they should comply with, like employment
conditions, work hours, minimum salary, benefits.”

24.	 Farm workers, who are insured by the Agricultural Insurance Organisation (OGA), should be paid (by the employer)
via “ergosimo”. “Ergosimo” is a method of payment of salary and social security contributions (applicable to specificcategories of employees). The social security contributions to OGA (10% of the nominal value of “ergosimo”), arewithheld from the workers’ salary. (see Appendix III for more detailed legal information).
25.	 Pursuant to Presidential Decree 156/1994, any employee should be informed in writing of the a) place of work, b)
position of work-duties, c) duration of employment, d) annual leave, e) severance payment and notice period in caseof termination, f) remuneration and other benefits, g) working hours and h) applicable collective labor agreement or
arbitration agreement. (see Appendix III for more detailed legal information)
38

Chapter 3

ALP Program: feedback from farmers, workers
and other stakeholders

ASSESSMENT
Missirian’s Oriental farmers

Assessment

CU asked farmers, family members and external
workers who were aware of the ALP Program what
had changed on the farm since it was implemented.
33 farmers (58%), 16 family members (57%), andone external worker (25%) declared that safety on
the farms had improved due to the use of PPE, that
CPA application practices were better, and thatthe amount of CPA used in the field had decreased,
which was actually more related to GAP, and a few
people mentioned an increased knowledge about
GTS. Two farmers (4%) and 2 family members (7%)
stated that the involvement of children had been
reduced. Seven farmers (12%) reported that ingeneral they had gained more understanding fromthe ALP on how farm practices should be organized.
13 farmers (23%) and ten family members (36%)
mentioned that nothing had changed since the startof ALP.

Field technicians communicated ALP topics
mainly to farmers and sometimes with theirfamily members. However, field technicians did
not converse with external workers (see 1.4.1).
Field technicians discussed their findings and field
experiences during their daily morning meetings
with the Head field technician. But there was no
structured process when it came to reporting the
feedback from farmers and workers to the ALP
Steering Committee.
Seven farmers (11%) declared that they had provided
feedback to a field technician. The majority of thisfeedback concerned technical or commercial topics
and was then dealt with by the field technicians.

40

Chapter 4

Appendices

ASSESSMENT
Missirian’s Oriental farmers

Assessment

Appendix I – Missirian Action Plan
Introduction

2012

Missirian welcomes CU for its assessment of our
ALP program implementation and commits to use it
as a tool for further improvements in our tobacco
supply chain.

In Q1 of 2012, Missirian provided three initialtraining sessions to the FTs, using the training
materials provided by PMI.

CU findings were in line with Missirian’s
understandings in most aspects, and helped withthe clarification of various objectives.
Missirian would also like to extend its appreciation
to PMI and Verité for their on-going contribution
and support during the implementation of the ALP
program.

Background
Missirian buys and processes Basma and Katerini
oriental tobacco. In Greece, tobacco farmers areorganized in regional groups of farmers (GF). Earlyin the season, farmers declare the company theywant to contract with. The company negotiates
the reference contract prices with the GF and thenannual contracts are signed between the company
and the GF. The need to implement the ALP Programis an integral part of the contract.
Missirian implements various agronomy programswith its contracted farmers that are overseen by
its agronomy team. Field technician (FT) provide
support and assistance to farmers throughout
the year. This way, a strong relationship is forged
between Missirian’s FTs and the farmers’ community.

Missirian & ALP Program in Greece
The ALP program was introduced to Missirian by
PMI in December 2011, when PMI delivered a
training seminar helping clarifying expectactions
and building internal capacity. The implementationof the program started immediately after with theorganization of Missiarian’s internal ALP team, andthe allocation of roles and responsibilities to thestaff.

In Q2 2012, Missirian started delivering training
sessions to farmers. The training was organized ingroup meetings held in strategic locations, mainly invillage coffee shops, which enabled gathering 30 to
50 farmers in each session. At the same time, socioeconomic data (farm profiles) was collected for
100% of our contracted farmers. This provided us
with valuable knowledge about the socio-economic
conditions of farms, which has been used as animportant reference tool since. We collect data
every year, which is updated during the course ofeach season to ensure all information is up to dateand relevant to the FTs and ALP Country Team.
In 2012, each FT was responsible for providing
support to 229 farmers.

2013
In 2013, Missirian continued working on therequirements of Phase 1 of the ALP Program, aimed
at improving program knowledge for staff andfarmers, as well as to act promptly to address hazards
and situations in need of immediate intervention.
The main goals were to deepen the training, assess
the weak points of the initial implementation, andimprove internal reporting.
In order to build on the initial trainings held in
the first year of the implementation of the ALP
Program, Missirian organized four training sessions
for its FTs.
To improve the farmer’s training, Missirian started
to provide individual training sessions, as some ofthem were reluctant to express themselves when in
the presence of their peers. The individual training
sessions covered 87% of contracted farmers.

42

Assessment

The close relationship between FTs and farmers
and their families allowed Missirian to understandthe importance of women in the context of the
farm and their families. In order to improve thecommunication of ALP messages to household andto leverage on farmers’ wives, Missirian hired fivefemale FTs.
Missirian continued building internal capacity tofurther advance the implementation of the ALP
Program, improving the Farmer-FT ratio from
229:1 to 188:1.

2014
At the end of the 2013 season, PMI conducteda Phase 1 review to assess the implementationof the ALP Program and its effectiveness, whichgave Missirian the green light to proceed with
the introduction of the systematic farm-by-farmmonitoring in the 2014 crop season, a criticalcomponent of the Phase 2 of the ALP Program.
In December 2013, after a workshop held in
Antalya, Turkey, Missirian introduced farm-by-farmmonitoring of the seven ALP Code Principles and its
32 measurable standard (MS).
During the first year of systematic monitoring, all
FTs attended seven training sessions focused on
the new objectives and requirements of the ALP
program and their practical implementation on
farms. The initial version of an electronic database
was created, where all 32 MS were monitored.
Missirian monitored 100% of its contracted farmers
with four visits per crop season to each one of them,during the different stages of production.
Missirian continued training farmers on the ALP
Program on a regular basis, conducting individualrefresher training with 98% of the contracted
farms, while the remaining 2% were trained in groupmeetings.
In order to meet the additional requirements of thesecond phase of the ALP Program, and additional 27
FTs were hired, resulting in a positive decrease of
the farmer-FT ratio to 168:1.

2015
In 2015, improving FT’s knowledge of the ALP
Program and their skills to identify and address
issues continued to be a priority. Missirian delivered
eight training sessions to FT. Communication tofarmers about the ALP Program and their role asemployers also remained a top priority throughindividual training of 100 % of the farmers andapproximately 35% of their wives. Missirian also
started reaching out to and training workers. FarmProfiles were collected for all farms and 100% of
our contracted farms were monitored throughout
the crop season.
After the annual performance review, Missirian
identified areas for improvement in the reporting
procedures and addressed them. As an example,
Missirian reviewed and updated its monitoring
system to allow FT to report qualitative information
about the reason why a farm meets, or not, themeasurable standards of the ALP Code. This allows
the FT and the ALP Country Team to keep record
and to have a better understanding of the situationon the farm and to determine the most appropriate
course of action.
In terms of internal capacity and as a result ofMissirian’s continued commitment to the ALP
Program, the farmer-FT ratio decreased from 229:1
in 2012 to 153:1 in 2015.

Implementation of the ALP Program
Commitment to the ALP Program
Missirian has embraced the ALP program since
its introduction and devoted key people in its
organization to lead it, as well as a dedicatedteam of field technicians focused on its day to day
implementation. We believe that the ALP programsupports the tobacco farmers’ community (byhelping them in improving the quality of their cropand the predictability of their business), the people
involved in tobacco production (by eliminating childlabor and other labor abuses), and the company
implementing it (by strenghting the relationshipwith tobacco farmers towards a more sustainableproduction).
43

Assessment

Accordingly, Missirian wants to design future
tobacco crops to be in line with ALP principles,
expecting that these efforts will be appreciated by
the farming community.
Missirian acknowledges that efforts which require
behavioral change, need time to be accepted andadopted and will continue focused on improving
labor practices in the long-term.

Strategy and objectives
At the end of each crop season, all staff involvedin the program participate in the assessment ofeach tobacco area, where issues are thoroughly
discussed and risks identified. These assessments
are the basis of the annual risk assessment, which
also include factors such as the difficulties that
farmers face due to country’s economic crisis.
As a next step, the steering committee develops an
Action Plan for the following crop season. This plan
includes:• long term actions, that will be implemented
gradually over the next years (i.e. to raiseawareness of the program to farming
communities), which are usually more difficult tomeasure and evaluate.

This action plan includes concrete actions andfurther detail on the abovementioned priority areas.
As CU clearly points out, measuring progressagainst all targets was not yet in place. Where
possible, this will be immediately adopted to be fully
functional in the next crop season. Missirian will use
this information as a basis to build the action planfor the coming year.
As part of its action plan, Missirian will also focus its
attention on the following:• improve current procedures, namely the Risk
Assessment, ALP Action Plan,data collection
accuracy, and Prompt Actions reporting andfollow-up;• raise internal awareness about ALP principles,systematic monitoring and development andrecording of improvement plans for every farm
• ensure that sufficient human resources are inplace for the program implementation;• extend its cooperation with external stakeholders,like FOODSTANDARD who currently provides
on the ground service for support mechanism
pilot and outreach to Groups of farmers;• short term actions focused on resolving gaps
identified either in the internal organization(i.e. FTs retraining, PA escalation process) or
at farm level (i.e. distribution of informative
materials, widespread issues), which can usually
be measured and evaluated.

Roles and Responsibilities

Following CU’s assessment, Missirian reviewed its
strategy and plans with the objective of defining
priorities for the 2017 crop season and addressing
the areas in need of improvement. As a result,
Missirian identified the following three priority
areas which were not included in the initial internalrisk assessment:

Missirian has integrated Leaf and Agronomy
departments into an operational team responsible
for the implementation of both the ALP and STP
programs.

1.  Payment of workers below the minimum wage;
2.  Overtime, including but not limited to piece rate

Since the introduction of Systematic Monitoring
2014, Missirian focused on the internal team of FTs,
to ensure they understood the principles involved,
and have strong skills in training and cooperation
with farmers.

Field Technicians are assigned specific farmers prior
to each season, to achieve better understandingof the situation on the farm. This helps to createa relationship of trust between the farmer, family
members, farm workers and the FT.

3.  Lack of registration of workers for both EU and
Non-EU migrants
44

Assessment

Training and knowledge of the ALP program
Field technicians are trained to identify and report
both situations requiring immediate intervention(prompt actions) and situations not meeting the
ALP Code Standards. The aim is to keep them alertin case a situation not meeting the standard evolves
into a prompt action issue. This is the reason why
such incidents are included in the regional risk
assessments.
Unannounced visits by the ALP Coordinator, his
assistant and the Agronomy Director are made tofarms to assess the level of knowledge of farmers,family members, workers, and consequently FT’s
performance. These assessments will cover 5% of
the farmers assigned to every FT. This procedure
will be included in our handheld electronic system
as of the coming crop season in order to keep recordof this evaluation and allow the analysis of the dataat the end of the crop season.
Although the ALP program is heavily based on
the skills of the internal organization, CU notedsome gaps in FTs knowledge, so it is imperative tostrengthen the FT training. Missirian plans to deliver
10 refresher trainings throughout 2017, focusedon all ALP principles, Measurable Standards, local
laws and regulations. These refresher sessions will
include examples of different situations FT mightface on farms. In addition, individual tests andquizzes will be given after each training session, toassess the level of understanding and determine
further steps. This training of all staff included in
the program implementation will take place during
the season (from January to July), but mainly before
the season startup (six out of the 10 sessions willtake place from January to March).
Prior to the crop season, and considering CU’sfinding on Income & Work Hours, we will amend
the monitoring system to reflect net wages to avoid
misinterpretations of the FT on the legal minimum
wage.
The training of current and new staff on ALP is an
ongoing process. Missirian will test and evaluate
the level of ALP knowledge of all management
employees. Internal rotation of staff to further

embed the program throughout the organization
will be considered and time allocated to the program
will be increased.

Communication strategy and tactics
Communication includes training of the ALP
principles to the farming community mainly
performed in individual meetings, and distributionof communication materials like pamphlets, stickers,
supporting documents and promotional materials
such as clothing with the ALP logo.
We have concluded that individual meetings
at farms are the most effective communication
method, and as such will remain our main method totrain, address issues and agree on solutions with all
people involved.
Based on the previous years’ findings, most of
the issues concern Child Labor and Safe Work
Environment. Therefore, FTs have put a lot ofeffort in raising farmers’ awareness of these ALP
principles, which is also by CU’s assessment.
The fact that awareness is lower among family
members and workers is a concern, and Missirian
will strengthen its actions to increase their levelof awareness. Regarding family members this will
be done during the regular visits to the farms, by
paying more attention to principles like Income
and Work Hours, Fair Treatment, Forced Labor,
Freedom of Association and Compliance with Law.
All family members will be retrained in family groupmeetings, during the next crop year. According toCU’s observations, more efforts will be given to
Komotini area family members, where the level islower level than those of Katerini.
During training sessions, we record in our system
whether the farmer’s wife was present. To gaina better visibility on the participation of otherfamily members in the trainings, we will extend ourrecord keeping to include them too. To address theawareness gap of workers, and due to their limited
availability during the season, we will mainly focus on
the distribution of informative material (pamphlets,
stickers, posters on their accommodation), andon the spot training. Furthermore, we will record
separately the participation of workers, in order to45Assessment

better evaluate the training. It is Missirian’s objective
to deliver these training to all farm workers over the
next two crop seasons (2017 & 2018).
Communication materials will be revised according
to CU suggestions and the improvements will
include::• Additions to ALP Standard posters:a) Recommendation of wearing gloves and long
sleeves during the stringing process;b) the obligation to register workers, information
on payment frequency, accommodation
requirements, and legal overtime;c) Recommendation of wearing goggles for CPA
application;• Changes to ALP Principles poster:a) the text for Income and work hours referredto ‘fair wages’ which will be changed to ‘legal
wages’• Change in National Emergency Helpline (166)sticker: the ALP logo will not be used to avoid
confusion and clear reference to the emergency
service will be included;
CU noted that not all communication materials
were translated into Turkish. The GTS leaflet willbe translated to Turkish, Bulgarian and Albanian,and the National Emergency Helpline (166) sticker
to Albanian (as it is currently only in Greek andBulgarian), in order to ensure migrant workers caneasily understand the information.
In order to achieve better results on the workers’
level of awareness, new informative materials
will be developed in Bulgarian and Albanian anddistributed to all of them, during the next crop
season.

Farmers’ responsibilities
Missirian will continue supporting farmers in
improving labor practices on their farms, as it is
the company’s preferred approach. Missirian’s
assessment of contracted farmers’ performanceand level of engagement with the ALP Program andwillingness to improve (or lack of) will continue tobe a criteria for contracting farmers. As stated to
CU and included in their report, Missirian decided
to not renew contracts in five instances in the past
due to poor performace on ALP.

Internal monitoring: Data collection,accuracy and addressing issues
Missirian has developed internally a softwaresystem which is used to record all Farm Profiles andmonitoring data. This system is upgraded constantly
to assist FTs with data collection, and implements
various validation rules to ensure data consistency
and reporting accuracy.
Up to date information is accessible to every user(area supervisor, ALP Country team member) at any
time. Data collection is done using handheld mobile
devices, and each FT is equipped with one. The data
is input during the farm visit. The processing of data
is done on desktop computers at Missirian’s local
and central offices.

Farm Profiles
The collection of the FPs starts early in the season
and is built up gradually during the crop andupdated at any point when changes are noted (likethe number of workers, which can vary). Some
inaccuracies, which were also noted by CU, areexpected, as farmers do not always provide accurate
information. This information will be verified by theFTs during monitoring visits. Data about the foodsupply from farmers to workers is also collected.
Following PMI’s suggestion, and in order to gain abetter visibility into the recruiting and payment
practices on farms, we enhanced our data collection
with information about migrant workers, including:• number of years the workers have been brought
to the farm (1-2 years; above 3 years);• In case of new workers, how did he/she find thejob (e.g. advertisement, recommended by otherfarmer, recommended by other worker, on his
own, via crew leader);• Whether they work only daily or for a longer
period.
46

Assessment

Systematic Monitoring
The farm-by-farm monitoring has been integrated
in the general system that Missirian applies to
its contracted farmers, with at least four visits toeach farm during the each of the cultivation stages:
seedbed, field, harvesting and curing/boxing. During
these visits, FTs cover all related activities regarding
the STP pillars (crop, environment, people or ALP).
The strategy of Missirian is to focus on all ALP
principles, therefore the FTs are instructed toverify whether a farm meets each standard. Whena farm does not employ workers, the software
prompts surveys only for Child Labor and Safe Work
Environment issues, marking the other principles as
not checked for that specific visit.
The findings of CU regarding Child Labor and Safe
Work environment confirm that these are the most‘risky’ areas and the reason why the majority of
the findings reported by the FTs fall under these 2
principles. FTs will keep their ‘eyes and ears’ open
for other principles, particularly Income and work
hours and Forced Labor.
Regarding the inaccuracies found and reported by
CU, we will strengthen the FTs awareness during
the coming crop season training sessions to improvetheir reporting and to fully justify the reasons whena farm meets the standard.
Following the CU remark on confusing terminology
in the software, the wording has been improved asof September 2016 (e.g. reference to gross legal
minimum wage changed to net legal minimum wage,
and all selectable options become fully displayed on
the device for better reading).

Prompt actions
The identification and reporting of prompt action
issues started from the first year of the ALP program
implementation (2012). This helped the FTs in the
coming years to clearly identify prompt actions,distinguish them from situations not meeting the
ALP Code standards, and agree on improvement
plans with the farmer.

The software system has a list of predefined reasons
as to why the farm meets / does not meet / is not
sure of the standards.
Follow-up visits have been performed for the
open PAs at the time of the assessment, and wereresolved. For every PA, the FT will conduct a followup visit within the following 15 days. This process
will be repeated until the situations have beenaddressed. As suggested by CU, we will modify thesystem to send notifications when follow-up visits
are due. This will be in place for the next crop season(Q1 2017).
In addition, farms PA will undergo a final evaluation(meets/does not meet/not sure) at the end of theseason.In case of severe circumstances, and if the
farmer is not willing to follow any improvement plan,
Missirian will consider not to renew his contract.
To cover the qualitative data gap, as per CU’s remarks,
a new data field will be added to the system, andwill be used during the next crop season. Missirian
keeps records of the age of children in the system
which are retrievable by FTs at any given time. They
will be used to gain more insight on detected issues.
The current procedure, where all FTs meet in theirlocal office each morning and discuss the open issuesof the area has been proven to be quite effective forthe program implementation.
The name of the FT, who reported the PA, is also
now visible to the mobile device, therefore everyone
who visits the farm has full picture of the details
concerned.
Missirian will continue training FTs on PAs regularly,
and will include more guidance on the reporting andbetter understanding of resolving methods. At theend of the 2017 season the new notification system
will be evaluated and further actions will be taken,
if necessary.

Data management and analysis
A summary report to display the reasons why a farm
does not meet the standards will be programmed in
the system, as per CU’s recommendation. This will
be in place at the end of the current crop season(2016).
47

Assessment

The evaluation of reasons at the end of this year
will be the source of information to get useful
assumptions on the current situation and build
specific strategies for the next crop season (2017).

Missirian will expand the provision of theContractual Agriculture Card to its farmers in 2017.
We hope this initiative to help farmers convincing
their workers to register.

As previously mentioned, the software is a datacollection system accessible to all users (areasupervisor, ALP Country team member) at any
time. The data checking and the overall program
implementation is reviewed and amended regularly(almost daily) as needed. Data validation andintegrity checks are an integral part of the system,
and 90% of the data is pre-checked and verified,thus reducing the quantity and extent of further
checks required.

Farm level assessment

Improvement plans for individual farms
During the next crop, Missirian will introduce therecording of the agreed improvement plan in thesoftware system, as suggested by CU. This will help
FTs to keep track of the agreed plans.

Address systemic / Widespread issues
To address the widespread issues that have beenreported, Missirian will continue to provide
materials to provide safety to people working on thefarm, and promote techniques that facilitate tasks
and limit risks. The number of the materials to be
distributed to farmers, such as PPEs, CPA lockers,
or First Aid kits will be determined at the Annual
Risk Assessment of the current crop and included in
the ALP Action Plan for the following crop.
The expansion of the current support mechanism
to other tobacco areas will help address
widespread issues and contribute to the program’s
implementation. Missirian expects to provide accessto the support mechanism to all workers and farms
within the next four years.
An updated ‘STP Farmer book’ is planned to be
distributed to all farmers before the start of thenext season (Q1 2017), that will help guide themto improve their farm practices and activities. It
will include all ALP related issues, risks, potential
solutions, improvements, legal information etc.

I. Child Labor
The analysis of reported Prompt Actions showedduring three years of monitoring there were cases
where family children helped with various tasks(like stringing, driving tractor, transplanting) on
the farm, and one case of a farm worker’s childconsidered to be employed as it was working withhis parent on the farm and not paid. Family children
also performed hazardous tasks, mainly driving
tractors, as well as harvesting and stringing. In 2017
Missirian will reinforce the training to all farmers
and family members, to make them understand thatthese activities can impact the health and safety of
their children and therefore should be consideredhazardous and not allowed for any person below 18
years old to be involved with.
In general, all family children attend school (98%,according to our records). This is something thathas been prioritized by farmers’ families and follows
the general trend in Greece that the education ofchildren is of the highest importance.
During the summer holidays, some farms that do
not have an option for childcare are forced to bring
their children to the fields. This increases the riskthat some of these children may get involved in fieldtasks. FTs will continue to raise all family members’
awareness on the risks related to the involvementof children on tobacco growing.
Regarding hazardous tasks, an improvement has
been noted during the last year. As CU reported
in its feedback from the farms, the number of PA
reported decreased from 38 in 2014 to 12 in 2015.
Missirian will take further steps during the regulartraining of the next crop season to refresh farmers’
and family members and educate workers on childlabor standards. This refresher training, which will
start in Q1 2017, will be conducted for all farmers
and family members, but especially the women48

Assessmentof the farm, and will focus on understanding thehazardous activities and the minimum legal workingage.
The training held by the FTs with examples andinformative material has resulted in the avoidanceof child participation in most hazardous activities,
like equipment handling, exposure to CPA, nightwork, etc. The regular distribution of informative
material will be continued, to raise awareness ofthese subjects. During Q2 & Q3 2017, FTs will
pay more attention to harvesting and stringing
activities, and the agreed farmer improvement plan
will have predetermined follow up actions.
Some issues regarding stringing and tractor driving
are still being recorded identified as farmers takethe issue lightly because they consider it either
something a child enjoy doing or an introduction
to their future involvement in agriculture. Theseissues, which were noted by both CU and Missirian,
are considered a priority area for field technicians.
Informative pamphlets targeting the avoidanceof stringing and tractor driving will be developed
and distributed during the next year. As part ofour efforts to avoid stringing by family children,
Missirian will promote the use of mechanicalstringing machines for all farms that do not alreadyhave one, and we plan to provide some machines in2017 (based on the current crop risk assessment).
Children generally cannot handle this machine, solabor involvement with this task will be reduced.

II. Income and Work Hours
Tobacco production in Greece, and especiallyin Katerini, is dependent on external workers
who are both local (mainly for transplanting andfield preparation tasks) and migrant (mainly for
harvesting). This strong dependency sometimes
results in higher payments for workers when thecompetition for labor is high.

Various worker payment methods have beenreported including hourly, daily, monthly and piecework. During transplanting, payments are usually byday. After transplanting and during field preparation(harrowing, furrowing, ridging), payments are by
day or by hour. During harvesting the majority ofworkers are paid by piece (per string).
Most farmers also provide free housing and food totheir workers. The housing provision is quantified
as follows: 12 m2 space per person equals to € 22/
month. For food it is calculated at € 9/day which sum
up to € 270/month. These € 292 should be calculated
on top of what a worker receives.26
The salaries paid to workers, either monthly or daily
are above the legal minimum wage.
The findings of CU regarding the workers’ payment,
will enhance our attempts to investigate if andwhere there are workers that are paid below thelegal minimum wage and whether the overtime
hours are paid. We will focus on these items on both
the FTs and farmers’ training as from the current
season.
Hourly and daily payments are paid at the endof the day. Workers that are paid by piece or bymonth, receive periodic advances (usually at theend of each week) and the balance as a lump sum
at the end of the season. Farmers and workers
keep detailed employment and payment records,
which are regularly cross-checked amongst them.
Additionally, Missirian distributes payment forms to
all farms that hire labor, to formalize these records
and to be more transparent. Missirian will target in
the farmers’ training in 2017 to raise awareness on
the regularity of payments schedule.
It is common practice in the agricultural and thetobacco sector for the farmer and his workers toconclude their agreement well before the season

26.	 The nominal value of a house in these areas, as set by the Ministry of Finance, is 650-700 € /m2. The tax authorities
determine the monthly rent at 3% of the nominal value. That amounts to about 21 € /month, and since the electricity/water consumption is also provided for free, the total provision sums up to 22 € /month. Besides that, the rent
value in these areas ranges from 100-150 euros/month (for a house of 50 m2, where 4-5 people live).The daily foodprovision, as determined by the law, is determined at 1/50 of the monthly salary ( 460 € /50=9,20 €).
49

Assessment

starts. The terms of the agreement acknowledge
that both parties accept that agricultural hours arevariable and need to be adjusted to daily businesscircumstances. During transplanting and harvesting
work varies between 7 and 12 hours per day,
depending on the farm size and conditions.
Workers are usually keen to finish their tobaccotasks as soon as possible, in order to be available
for employment in farms that deal with other crops(watermelons, kiwis, olives, etc.). This usually leads
them to work excessive hours, including weekends,
even though the farmers themselves never work on
Sundays.
Missirian’s FTs will conduct additional training
to farmers regarding the minimum wage, work
hours, overtime rates and legal benefits. Workers
will also be included in the training courses during
the next crop season, where we will raise theirawareness regarding their legal rights. The trainingof all workers will be completed in the next 2 crop
seasons.
Missirian will review the schedule of cash advances
given to farmers for the next crop season, to help
them improve their cash flow, especially when
worker payments are due. In the FT training sessions
that will be held in 2017, a separate session held in
Q1 will be dedicated to refresh their knowledge ofthe legal minimum wage, working hours, overtime
rates and legal benefits.

III. Fair Treatment
The large range of commercial prices thatcharacterizes the buying system in the country,
motivates farmers to produce the best quality
possible. As a result, they seek to employ workers
that are experienced on how and when to harvest.
Consequently, experienced workers are in demand
and there is a low turnover each year. This createsstrong long term relationships between farmers
and their workers, which is further proven by thesocial visits farmer families make to the workers’
hometowns in Albania and Bulgaria during the offseason.

This creates an environment conducive to fairtreatment, and the occasional tensions and conflicts
are quickly resolved.
Violence, harassment or discrimination issues, havenot been reported, but they remain a priority in our
Field Technicians’ agenda.
In cooperation with PMI, Papastratos and otherstakeholders, a support mechanism was introduced
in 2015. The goal from the beginning was toensurethat workers have access to fair, transparent andanonymous grievance mechanism so that they can
get support and raise questions/queries if/whenneeded .
The findings after the second year of the mechanism’s
operation are as follows:• Farmers are more familiar with the ALP Codethan the Principles. Nevertheless, continuous
action needs to be taken in order to ensure that
all farmers meet the ALP requirements and thatworkers are aware of their rights.
• The majority of farmers and workers havedeveloped close relationships after many yearsof working together. In practice, this meansthat most issues are resolved amicably and thatsomeone would turn to the support mechanism
for help and support for serious matters only.
• The support given by the acting companies isvery important and something that most farmers
acknowledge
In order to secure the smooth management ofincoming calls, the detailed Q&A of potential issues,questions and concerns will be reviewed and reedited in February 2017. Following CU finding
regarding the inexistence of an Albanian speaking
operator, it will be fixed in 2017 contract with theexternal third party.
The degree of trust between the support mechanism
and target groups is high, and will help promote theexpansion of the program participants. The target
for next season will be to double the number of farms

50

Assessmentthat participate. To achieve a better understandingof the help line and message penetration on the
support mechanism to farmers and workers, we willconcentrate on the following actions for the 2017crop:
1.  Distribute multi-lingual information leaflets forfarmers and workers, and2.  Continue to organize field visits in order to meetand discuss with farmers and their workers the
support mechanism, its scope and the operationof the help line.

IV. Forced Labor
No issues were observed under this principle during
the monitoring years regarding involuntary laborand the retention of personal documents, and this is
the conclusion of CU also.
Due to the shortage of skilled workers, it is unlikelythat they would be threatened and are free to leave
whenever they want.
Workers do not deposit money with their employers
and amounts are not withheld from the wages.
The three “indirect payment” incidents reported
by CU wereas payments done to the migrant
workers’ family members also working on the farm.
According to farmers, these payments were done at
the requested of the workers themselves in order toreduce complexities. In the fourth case, the farmers
were related to each other, and the exchange wasmutual agreed and temporary, for the benefit ofworkers. We will continue asking farmers to pay
workers directly.
Regular cash advances are paid to workers as mostof them request to receive the biggest portion of
their wages at the end of the season. Since workers
can’t open new bank accounts and transfer money
to their bank accounts in their home countries (dueto Greece’s capital control regime), they requestfrom their employers to be paid a lump sum at theend of the season, mainly for security reaons (theft,loss). Records of payments due are kept separately
by workers and farmers and they always match,which is confirmed as there were no reported
incidents related to non-payment of workers.

FTs will continue checking for regular payments
throughout the season.
CU findings about some delayed payments, refer toincidents from last year, where farmers and workers
had to face the suddenly imposed banking capital
controls that were introduced in the country.
Under these controls, a person could withdraw
only 60 euros per day, and this amount could notcover his needs and his payments due. However, as
acknowledged by CU farmers went to the border topay Albanian workers who had to leave the country
and did not have a visa to come back in. This reflects
the good relationship between farmers and workers,
as they did not take any advantage of this situationand kept their agreement with the workers.
Farmers in order to have their workers’ expenses
tax deducted, have to register them and issue apayment coupon. This coupon is then cashed out by
the worker through a bank account he is obliged tohave. This procedure guarantees a direct payment.
In order to further secure the regularity of payments
to workers, Missirian will increase the cash flow of
farmers by expanding the ‘Contractual Agricultural
Card’ (covering 100% of all contracted farmers inBasma, Katerini, East and West Macedonia districts
where Missiran has most hired workers population)from 45% of total contracted farmers in 2016 to
55% of total contracted farmers in the 2017 cropyear

V. Safe Work Environment
Farm safety is an issue that FTs have reported noncompliances with the ALP Code principles. Missirian
has taken many actions to address the widespread
issues including training and the distribution ofsafety equipment to farmers, family members andworkers.
In view of the efforts towards the desired behavioral
change of all those involved on the farm, Missirian
will focus on the following:• Encourage people to follow safety standards;• Help them understand the hazards;• Support them on the improvement plans agreed.
51

Assessment

Missirian has started running the IPM@PMI(Integrated Pest Management) First Phase for thecurrent crop which is a strong tool, not only for thecrop, but also for this ALP principle. This programaims reduce the risk of harm to people involved andto the environment. It promotes the reduction of
unnecessary CPA use, the application of the least
hazardous CPAs registered for use in tobacco, andproper CPA management.
It has always been a common practice for people
handling green tobacco to use long sleeve shirts
when harvesting, to avoid expsoure to Green
Tobacco Sickness (GTS).
Missirian has providedlong sleeves shirts to 100%of the contracted farmers during 2016 as aneffective way to mitigate exposure to GTS. During
the last years, usage of single-use plastic gloves
has been widely noted. These practices provide astarting point for our FTs to introduce topics suchas GTS avoidance. Following CU’s findings, it is ourintention to intensify training on GTS prevention
to all farmers, family members and workers during
the next crop year. Missirian will target people who
handle green tobacco, aiming to distribute a fullset of PPEs to all contracted farms over the next
2 crop years. Further to that, during the next crop
season, the electronic data collection system will
be upgraded to include a field to allow FTs to record
the exact missing PPEs on each farm.
Incidents are frequently reported regarding thelack of proper storage for CPA containers and theinadequate handling of toxic substances.
The majority of the farms are equipped with CPA
lockers but these are often old drawers and fridges.
Their condition is not always optimal, and Missirian
has set an initiative to distribute new lockers. During
the past 2 years, 270 lockers were distributed, mainly
to farms with young children, where the farmers do
not involve children with hazardous tasks. Further
training, promotional material (stickers) for 100 %of the contracted farms and locker distribution will
be regularly included in the FTs toolbox for the 2017
crop season, in order to maximize awareness. The
number of lockers to be distributed next year will
be determined in the current crop Risk Assessment.

The proper maintenance of equipment (machinery,
spraying equipment, PPEs) has also been set as a goalin the IPM@PMI program that Missirian undertakeswith its contracted farmers in order to reduce therisk of exposure to CPA. Specific leaflets have been
distributed to farmers and special training sessions
have been organized on these issues during 2016
crop season, and will continue next year.
The preparation and application of CPAs is mainly
a farmer’s task. Several cases of improper handlingof CPAs and wrong PPE usage have been reported.
As mentioned by CU in their report, all farmers in
the country are obliged to acquire a spraying license
which includes training. This procedure will beaccomplished by the end of this year, in accordance
to the local law. Despite that, Missirian, throughthe IPM@PMI program implementation, will train
all those involved about proper CPA spraying
techniques and the proper usage of PPEs. Missirian
will record during 2017 crop season the acquisitionof spraying licenses by farmers.
Field technicians perform training sessions todemonstrate proper use of PPEs to all people
involved. As a further move, a full PPE set (goggles,
mask and gloves) was distributed to 100% of farmers
in 2015. Another step taken is the distributionof overalls to 100% of the farmers, which will becompleted by 2017. Further to that, the electronic
data collection system will be upgraded to include afield where FTs will record any missing PPEs during
the 2017 crop season.
Another target that has been set in the IPM programthat Missirian is running is to raise awareness of the
field re-entry period after the CPA application to allparties involved. To achieve this objective, specificleaflets and stickers have been distributed to 100%of the farms and seminars have been delivered to
all farmers. All family members and workers will be
included in the 2017 program. A second initiativeis the distribution of 250 field safety re-entry signs
to 125 farmers this year. These actions will be
continued during next year, to cover all farms.
An empty CPA container recycling program has beenin place with Missirian since 2014, in cooperation
with local municipalities and groups of farmers and52

Assessment

about 900 farmers participate in this. Farmers aretrained on how to handle the empty containers, but
the CU reported incidents have shown that further
training is needed. Missirian will retrain all of its
contracted farmers during 2017 crop year on theproper disposal of CPA containers (piercing, triple
washing & discarding at designated points).

VI. Freedom of Association

Farmers are usually equipped with first aid kits intheir tractors or vans. Nevertheless, Missirian has
provided such kits to 50% of its contracted farmers
in 2015, to ensure that one is always on site.
Farmers know well the National Health emergency
line (166) but this is not always the case with theirworkers. As workers and farmers work together andany potential accident can be treated immediately.
To reinforce workers’ knowledge of the national
emergency line, Missirian has posted stickers
outside workers’ accommodations (75%), and willcontinue to perform these actions to cover themfully as of next year.

There is an acknowledged general lack of awarenessin the workers’ society regarding their legal rights,
which can be attributed to many reasons such as
undeclared labor and workers’ good relationships
with employers.

Worker accommodations have been assessed andthey are all equipped with clean drinking water, hotwater and kitchens. As CU reported, there are farms
that need to improve sanitary conditions and wewill establish an improvement plan with the farmer,
to be fixed for the coming 2017 crop. All farms will
be up to an acceptable level by 2019.

As CU acknowledged, there is no disrespectingof workers’ right to freedom of association,nevertheless FTs will continue to regularly monitor
for any discriminations.

VII. Compliance with the law

All contracts between farmers and their workers
are verbal. Such an agreement is valid according
to the Civil Code.Missirian promotes the use of
written contracts, which will also be an additional
tool for the farmer to justify expenses for his tax
declaration.
Missirian will provide refresher training to its FTs
in Q1 2017 to cover all gaps identified in theirknowledge of this principle, in order for them to beable to clarify the farmer’s legal obligations to his
workers. The Civil code and local labor laws will be
included in the training material.
To improve farmers’ awareness, Missirian will
enhance the training during 2017 crop season
to all its contracted farmers with regards to theentrepreneurial behavior they should adopt. The
training will include information on all the key legal
aspects they should comply with, like employment
conditions, work hours, minimum salary, benefits.

53

Assessment

Appendix II – Scope and methodology
Assessment teamOpening meeting

The team responsible for conducting this CU
assessment consisted of two Greek and two Turkish
auditors and two coordinators from the Netherlands.
The team was supported by six translators to ensurethat Albanian and Bulgarian migrant workers
could be interviewed, and so the Greek auditors
could communicate with the Turkish farmers in
the Komotini region. The auditors conducted farmassessments and interviewed the field technicians.
The two coordinators interviewed Missirian
management and one of the Head field technicians.
The auditors were trained by Verité and CU, three in2014, and one in 2013. 27 This qualification process
consisted of the following stages:

On July 19, 2016, CU started the assessment with ameeting at Missirian’s head office in Kavala, Greece.
The meeting was attended by Missirian’s ALP
Steering Committee (ALP coordinator, Agronomy
director, HR director), ALP coordinator assistant, IT
manager, Agronomy manager, Head field technician(Komotini), legal advisor (external), and PMI
Regional (via teleconference). CU presented theobjectives and approach of the assessment, while
Missirian provided a brief overview of the market
and company background.

• Selection of candidates by CU;• Webinars organized by CU to verify suitability ofcandidates;• Completion of online training provided by Verité;• Full week classroom training conducted by Verité
with CU; and• Shadowing during farm visits by Verité.

Desk review
Prior to this assessment CU asked Missirian tosend certain documents, to give the assessment
team an overview of the market and the company’s
management systems. With the consent of Missirian,
Papastratos provided legal information that was
relevant to the ALP Code (see Appendix III). Thiswas important to ensure a thorough preparation
prior to the assessment.

Methodology for ALP implementation
system review
The methodology used for the evaluation ofMissirian’s implementation of the ALP Programis based on the widely used PDCA 28 cycle. This isa management method used for the continuous
improvement of processes and products. CU spent
three days (July 20 to 22, 2016) at Missirian’shead office. They interviewed management staff,
analyzed documents and evaluated systems, tobetter understand how the implementation of the
ALP Program was organized. In total, CU interviewed
eight managers,29 15 field personnel,30 and one
representative from PMI Regional. Additionally, CUinterviewed four stakeholders: representatives ofthree farmer associations (two in Katerini and one
in Komotini), and a representative of Food Standard
who was responsible for the support mechanism (see2.3.2). All interviews were conducted individually,so that interviewees felt comfortable and able tospeak freely and raise any issues.

27.	 The coordinators had been trained in 2012 and 2013.
28.	 Plan, Do, Check, Act.
29.	 Managing director, ALP Coordinator, Agronomy Director, HR Director, Agronomy Manager, IT Manager, ALP
Coordinator assistant and Legal advisor (external).
30.	 Two Head field technicians and 13 field technicians.
54Assessment

Scope and farm sampling
Missirian sourced tobacco from seven regions in Greece. To ensure a manageable sample size, the scopeof this assessment was limited to the Oriental tobacco farmers (Katerini and Basma varieties) located in
Katerini and Komotini (see purple and green areas in map below).

Tobacco growing regions in Greece (source: Missirian)In Katerini, the majority of Missirian’s contracted
farmers (68%) grew one to two hectares of tobacco,
18% had more than two hectares, and 14% had lessthan one hectare. In Komotini, the tobacco area
contracted by farmers for Missirian was smaller,
with 49% with one to two hectares, 45% with lessthan one hectare, and 6% with more than two
hectares. In most cases the farmers had more landavailable, which they used to produce other cash
crops such as wheat and corn.
Farmers were members of associations, throughwhich they contracted with Missirian. In Katerini
there were ten such associations, in Komotini justone.
At the time of the assessment, Missirian had
contracted 1,491 Oriental farmers in Komotini
and 582 in Katerini. To constitute a meaningful
sample, CU needed to visit at least 24 Katerini and39 Komotini farmers, the square root of the total
population of farmers in each region. In reality, CU

visited 24 farmers in Katerini and 42 farmers in
Komotini, which were either sampled randomly or
selected based on the following criteria:• Geographical spread;• Farm size: a variety of different farm sizes
was selected with a focus on larger farms withworkers to ensure labor practices could beassessed; and• Farms with reported Prompt Actions: Prompt
Actions were reported for 5% of the farmers
contracted by Missirian. In the CU sample
Prompt Actions were reported for 38% of thefarms visited.
Over a period of two weeks, CU visited an averageof 11 farms per day, with each field day followed
by a day in the office to write up the findings. The
pie charts below provide demographic information
about the farm selection.

55

Assessment

Farm size Katerini (T=24*)(ha contracted by Missirian)

Farm size Komotini (T=42*)(ha contracted by Missirian)

12%
29%
40%

88%

31%

0-1

0-1

1<-2

1<-2

>2

>2

*Of which 6 (14%) were newly contracted farmers*Of which 2 (8%) were newly contracted farmers

Stage of tobacco production (T=66)

70
Number of Farms

60
50
40
30
20
10
0

N

s
ur

er

y
an
Tr

sp

l

t
an

in

g
Gr

ow

in

g

pp
To

in

g
H

ar

v

t
es

in

g

r
Cu

in

g
Cl

as

y
sif

in

D

g

iv
el

er

f
yo

to

c
ba

co

Type of farm Katerini (T=24*)

25%

29%

Family farm with only family members working
Farm with only migrant workers (no family members)
Farm with local and migrant workers (no family members)
Farm with family members and migrant workers

13%

33%
*Exchange of labor practiced at 1 farm visited56

Assessment

Type of farm Komotini (T=42)

2%
2%

14%

14%
68%

Family farm with only family members working
Farm with family members and local workers
Farm with only migrant workers (no family members)
Farm with local workers (no family members)
Farm with family members and migrant workers*Exchange of labor practiced at 4 farms visited

With the collaboration of Missirian, CU managed to
conduct all visits unannounced. This meant that thefarmers had not been informed about the visit or its
objective prior to CU’s arrival. Missirian did inform
farmers several weeks before that a visit could takeplace within a certain period, but said nothing in thedays prior to the visits. CU informed Missirian about
the names of the selected field technicians the day
before their visit would take place. The names of the
farmers were only provided on the day of the visit.
The reason for this was that CU wanted to obtaina realistic picture of the farm practices, which wasmost likely to be seen when arriving unannounced.

Methodology for ALP farm practices
review
The methodology used during the farm visits was
based on triangulation of information. Auditors were
instructed to seek at least two, preferably three,sources of information. They used their findings
to draw conclusions about whether farm practices
were meeting the standard of the ALP Code. Thesesources could be interviews with farmers, family
members, external workers, or village facilitators.
Sources could also include documentation andvisual observation of the farm area, field, storage
facility, and curing barns. This methodology was
also used to investigate the underlying factors that
increase the risk of not meeting the standard. In
addition to information triangulation CU also used
the “Five Whys” methodology, a commonly usedtechnique to obtain an understanding of problems,
to investigate the reasons behind certain issues.
Before each interview CU explained the objectiveof the assessment and assured interviewees that all
information would be kept completely anonymous.
As well as assessing labor practices, CU also verified
the impact of Missirian’s management systems at
the farms to see how these were perceived by fieldtechnicians, farmers, family members, and otherpeople at the farms.

People interviewed
In addition to the farmers, CU interviewed family
members, external workers and village facilitators
at the farms. Wherever possible, these interviews
were conducted individually and without thepresence of the farmer, to avoid undue bias. For
the same reason, all interviews with farmers wereconducted without the field technicians. In total,
154 people were interviewed by CU. The charts
below provide the demographical distribution ofthis sample.

57

Assessment

Komotini (T=89)

Katerini (T=65)
5%

2% 2%

6%
19%

32%

9%
66%

54%
5%

Family members

Family members

External workers (local)

External workers (local)

External workers

External workers (Albanian migrant*)(Bulgarian migrant**)

External workers (Bulgarian migrant**)

Village facilitators

External workers (Pakistan migrant*)
Village facilitators*Non-EU residents | **EU residents

The age and gender of the 148 family members and external workers is set out below:
Katerini (T=64)

Katerini (T=64)

17%
34%

66%
FemaleMale

83%

FemaleMale

58

Assessment

Age of interviewees Katerini (T=64)
2% 4%

Age of interviewees Komotini (T=84)
2% 6%

1%

<13

<13
93%

15-17

13-14
92%

15-17

Adults (≥18)

Adults (≥18)

The following graph shows the duration of employment or work of the external workers interviewed.
Duration of employment
Katerini (T=43)
5%

Duration of employment
Komotini (T=25)

2%
8%

8%

36%
48%
93%

1-3 months

Less than 1 month

3-6 months

1-3 months

Permanent

3-6 months
6-9 months

Closing meeting
On August 23, 2016, the closing meeting was heldin Kavala attended by Missirian’s ALP Steering
Committee (ALP coordinator, Agronomy director,
HR director), ALP coordinator assistant, Agronomy
manager, Managing director, Papastratos, PMI
Regional, and PMI OC. The Verité consultant for
Europe also attended the meeting. CU presented
their initial findings and Missirian requested
clarification of certain items which lead to a
constructive discussion.

Reporting procedure
During the assessment, auditors reported after
each field day to the coordinator who monitored

the findings and provided feedback as necessary.
The coordinator compiled these findings with theresults of the management assessment to create amore complete analysis of the management systems.
CU drafted the final public report which is an
important, external measurement of the global ALP
implementation progress in all countries where PMI
sources tobacco. Public release demonstrates PMI’scommitment to transparency, which is an importantcomponent of the ALP Program. CU authored thefinal report, which was evaluated by Verité. PMI
reviewed the report to ensure consistency with thepresentation of CU’s findings worldwide. Finally,
Missirian reviewed the report to verify the accuracyof the information and to finalize their action plan.
59

Assessment

Appendix III – Legal information
Principle 1 – Child Labour
1.1. Minimum age for employment (in tobacco)
Pursuant to article 51 of Law 3850/2010, 15 years
is the legal minimum age for employment in Greece.
Exceptions to the rule are possible; however, they
are not relevant to tobacco farming. Actually, Greek
law is very strict regarding the protection of children
and the prohibition of child labour (art. 50-67 L.
3850/2010), especially in the tobacco agriculture
sector, which may be considered as unhealthy forchildren.
1.2. Requirements applying to farmers’ own
children or other family members such as nieces andnephews helping on the farm.
There are not such requirements under the Greek
legislation. Kindly note that pursuant to article
1508 of the Greek Civil Code as long as a childis a member of his / her parents household or israised or taken care by them, he / she shall provide
services in the management of the household or the
carrying of their professional, depending on his/her
physical strengths and family needs. In any case, theprovisions concerning prohibition of child labour
are applicable.
1.3. Age (or ages) limit for compulsory schooling
Elementary education is compulsory until
graduation from “junior high school” (usually at theage of 15).
1.4. Definitions of hazardous work (incl. agriculturalactivities that constitute hazardous work) as wellas any tasks that workers under 18 are specificallyprohibited from participating in by law
There is no definition for “hazardous work” in
Greece, but a restrictive, though extensive, list of
sectors or positions, which are considered to be“heavy and unhealthy”. Labour in agriculture andleaf farming may pose threats to health for manyreasons, including of a physical nature (backacheetc.), exposure to the weather, exposure tohazardous chemical or other substances.

1.5. Other restrictions or requirements on theemployment of workers under 18 years (e.g. limit on
work hours, work permits, etc.)
Pursuant to article 3 of Presidential Decree 62/1998
which implemented EU Directive 94/83, working
time for teenagers shall not exceed 8 hours per day
and 40 hours per week. Overtime is prohibited in
the case of juvenile work. However, if the juvenile
is less than 16 years old or if the juvenile is a juniorhigh or high school student or a student in a public
or private technical institute he/she shall not work
for more than 6 hours per day and 30 hours per
week. In addition to this, juveniles are entitled to 12
consecutive hours of rest per day, including hours
from 10 pm to 6 am.

Principle 2 – Income and Work Hours
2.1. Laws on regular and overtime hours (e.g.
maximum work hours)
The statutory working time of an employee working
full time in Greece is 40 hours per week allocated on
a 5 or 6-day basis.
In general, employers are entitled to employ
their employees for 5 additional hours per week(concerning the five-day work system) or for 8
additional hours per week (concerning the six-day
work system).
2.2. Requirements that employers must meet torequest overtime from workers
Filing of application and approval from theInspection of Labour for overtime over 120 hours
per year (41st-45th or 41st-48th hour not included).
Overtime up to 120 hours, shall be registered, in aSpecial Book kept by the employer (Law 4144/2013
article 80), before the extra hours are done.
Overtime shall be also notified through “Ergani”,
an electronic notification system (Law 4310/2014
article 55), within the first 15 days of each monthfor the extra hours that the employee worked theprevious month.

60

Assessment

If the employer has not notified the overtime work,
then overtime is considered illegal, waged areincreases further, criminal charges may be pressed
and administrative sentences (usually fines)
imposed.
2.3. Laws on regular and overtime wages (e.g.
minimum wages, minimum wages agreed with
unions)Extra work from the 41st – 45th hour (five-day
working schedule) and from the 41st - 48th hour(six-day working schedule) is paid with a 20%
augment to the paid hourly wage.

salary of the employee the amount of employee’s
contribution and then to pay it with his/her
contribution to the competent Social Fund.
• Paid annual leave• Paid leave for other reasons (i.e marriage, illnessetc)• Christmas and Easter allowance (wage of up to
25 working days and wage of up to 15 working
days respectively )2.5. Wage and hours law specific to piece rate
workers, seasonal workers, and migrant workers

Overtime (more than 9 hours per day and 45 or 48
hours per week):

The provisions regarding the minimum wages andworking hours are mandatory and applicable to all
workers.

• Legitimate overtime: up to 120 hours a year,
each hour is paid with a 40% augment to the paid
hourly wage; above the 120 hour limit, each houris paid with a 60% augment to the paid hourly
wage;

2.6. Laws on payment of wages relevant to thefrequency of payment in agriculture, for example,
laws on whether end-of-season one-time payments
are permissible• Overtime for which the provisions of law has not
be followed is paid with a 80% augment to thepaid hourly wage.

It can be agreed (in the employment contract) thewages to be paid per day, per week or per month.
Wages shall be paid at short periods, as it covers theworker’s needs (International Labour Convention
No 95 art.12).

NOTICE: The maximum of overtime limits is
calculated daily and annually. There is no maximum
overtime limit per month. The maximum overtime
limit (applicable only to employers in industries,
craft business, enterprises and jobs) has been
determined to 30 hours for the first semester of2014.
2.4. Laws on basic entitlements to be paid toworkers (e.g. social security, health care, holidays,
other leave entitlements etc.)
General entitlements provided to every employee
under Greek law:
• Payment of social security contributions. The
calculation of the amount is not possible. It is
calculated according to the level of employee’s
earnings. It is partially contributed by theemployee and partially by the employer. The
employer has the obligation to deduct from the

2.7. Laws on in-kind payment
Salary payment may be agreed “in kind”. However
restrictions do exist. Remuneration in kind cannot
cover the worker’s whole salary (however, a
percentage of the salary that can be paid in kind is
not determined by law) and benefits in kind should
be useful for the worker and his family (according to
Greek case-law, payment in kind includes providing
accommodation, food, clothing, providing the costof water, gas, electricity, etc.). Benefits in kindconstitute together with salary in cash the worker’s
total salary and are therefore taken into account incalculating holiday allowances, allowance leaves,severance pay etc.
2.8. Legal requirements for migrant workers toensure they are legally permitted to work
A third-country national may enter Greece for61

Assessment

employment, under a dependent-employment
relation, with a specific employer and for a specific
type of employment, provided that he has been
issued with a working visa. Third-country nationals
who have obtained a visa for the provision of
dependent employment in Greece shall be issued
with a residence permit for dependent employment,
provided they have concluded an employment
contract showing that their remuneration is at least
equivalent to the monthly salary (the minimumwage) of unskilled workers.
EU nationals don’t need a work permit to work
anywhere in the EU. Although some typicalrequirements do exist:• Issue of a Tax Identification Number,• Issue of a Social Security Number,• Registration to the Social Insurance Institute(IKA)• Registration to the Police Authorities
2.9. Other specific rules applicable to migrant
workers
Under Greek labour law, the migrant workers havethe same rights with Greek workers as to payment
and work conditions. Specific requirements do notexist. Kindly note that, if a migrant worker does
not have a resident permit or is employed illegally,
the contract between him/her and the employer
is invalid. In this case the employer shall pay theworker for the work provided.

Principle 3 – Fair Treatment
3.1. Laws defining and prohibiting verbal,
psychological, physical punishment, and sexual
harassment and abuse
Law 3896/2010 implementing Directive 2006/54/
EK is applicable. One of the employer’s obligations in
Greek labour law is the duty of care / welfare, which
involves, among others, the protection of health andlife of workers, and the protection of their personal
rights. In other respects, the provisions of Greek
Criminal Law are applicable.

3.2. Laws defining and prohibiting discrimination
The prohibition of discrimination is regulated by
Law 3304/2005 and the principle of equal treatment
between men and women by Law 3896/2010. The
principle of non-discrimination shall be implemented
from recruitment, which means that recruitments
should be based only on the criteria of candidate’sknowledge and experience (merit only) and theirability to perform the required tasks. Furthermore
employers shall not discriminate against employees
during job assignment, the enforcement of sanctions,bonuses, or dismissal/termination.
3.3. Protection of workers from discrimination(workers’ rights and employers’ obligations)
In such cases, employees may claim to be treatedequally. Employees further claims in case of
discrimination or harassment:• Redress infringements• Desist from infringements in future• Compensation for non-material damages
3.4. Laws on resource for victimized workers, if
applicableAs far as we know, there is no such law.

Principle 4 – Forced Labour
4.1. Legislation on forced labour
Pursuant to article 22 par.4 of the Greek Constitution«any form of forced labour is prohibited».
Employees shall not be employed under conditions
analogous to those of slavery, debt or threat, andshall receive their wages directly from the employer.
Deductions in wages or income from crops shall not
exceed the statutory and agreed terms. Workers
shall be free to leave their work at any time within areasonable notice period.
Forced labour may involve situations where theemployer:• Withholds the worker’s identity documents;

62

Assessment• Sets workers in debt situation by taking cash
deposits or by deducting money from wages orby overcharging services or goods provided;• Withholds wages that the employee is entitledwithout a schedule or an agreement or threatens
not to pay salaries in situations where theemployee owes money to the farmer and isforced to work until he the debt is paid; or• Threatens to report a foreign worker without aresidence permit to the authorities.
4.2. Laws on prison labour
Prison labour is prohibited.
4.3. Legislation regulating the operation of labour
brokers and other third party recruiters

5.3. Requirements for personal protective
equipment needed for using, handling, storing, ordisposing of crop protection agents (CPA). Thismight vary depending on the CPA in question
Personal protective equipment (PPE) needed
for using, handling, storing or disposal of CPA’s.
According to the law an inspection system controls
the professional use for pesticide applicationequipment. A certificate of use is recommended for
those who use pesticides (for professional use).
5.4. Restrictions on CPA use, handling, storing, ordisposing. Most countries will have restrictions onvulnerable populations interacting with CPA (orprohibit this outright), such as persons under 18,
pregnant women, nursing mothers, etc.

There is no such concept as labour brokery in
Greece. As to third party recruiters: temporary
employment in Greece is governed by law
4052/2012 implementing Directive 2008/104/EC
on temporary agency work. Temporary Employment
Agencies (such as Manpower, Adeco etc), by which
the Company is supplied with temporary employees,
has to be established and operate under the terms
and conditions specified at the relevant provisions.

According to Law 4036/2012 CPA use, handling,storing or disposing should be done without
endangering human and animal health, using
processes or methods which prevent damage tothe environment. According to Presidential decree
62/1998 which implemented EU Directive 94/33,
the use of pesticides are among the tasks which
are prohibited to be practiced by workers under
18, with harmful effects on the child (fertus) during
pregnancy.

4.4. Laws relating to limits or prohibitions on
recruitment fees and deposits workers may berequired to pay

5.5. Restrictions on farm equipment (such as
maintenance and licensing for operators)

As far as we know, there is no such law.

Principle 5 – Safe Work Environment
5.1. Requirements for provision of medical
protection, such as availability of first aid kit, health& safety training, etc.
The employer shall take the necessary measures
for the healthy and safe protection of workers.
This means that the employer shall provide a safe
working environment.
5.2. Requirements to report accidents and injuries
The employer shall inform (within 24 hours) thecompetent Inspection of Labour, the nearest police
station and Social Insurance Institute (IKA) about
any work accident.

As we mentioned above, according to the law aninspection system controls the professional use forpesticide application equipment. A certificate of use
is recommended for those who use pesticides (forprofessional use).
5.6. Other legislation related to CPA, such as how
and where they may be stored or transported;
more explicit restrictions for specific CPA; weather
conditions under which CPA may or may not beapplied; and any other restrictions limiting contact
or exposure with CPA
Law 4036/2012 imposes the implementation of newmarketing authorization procedures for pesticides
controlled by a coordinating national authority by
the Ministry of rural development. This authority
shall take the measures that prove necessary on the63Assessment

basis of appropriate risk assessments to ensure thatstorage areas for pesticides shall be constructed in a
way as to prevent unwanted releases. Measures aretaken regarding the use of pesticides near sensitive
areas. A sensitive is defined as any school or preschool, kindergarten, childcare centre, community
health center or nursing home.
5.7. Requirements related to providing drinking
water and safe housing for workers
The employer shall respect the employee’s
personality. From the general duty of welfare,
further obligations arise for the employer suchas requirements regarding the supply of drinking
water for workers.
5.8. Specific requirements if worker accommodation
is provided
As per our best legal knowledge, there is no provision
for worker accommodation under Greek labour law.

Principle 6 – Freedom of Association
6.1. Laws on organizing unions and their operation(workers’ rights and employers’ obligations)
Law 1264/1982 (Union Law) is applicable andprovides, inter alia, the following:• the right to establish Unions (article 1)• the right to organise themselves (articles 6 – 13),• the right to strike (article 19), and6.2. Requirements for collective bargaining
Workers are free to join or form trade unionsof their choice. Workers and farmers, or theirrepresentative organizations, have, in accordancewith Union law and national laws and practices,
the right to negotiate and conclude collective
agreements at the appropriate levels and, in casesof conflicts of interest, to take collective action to
defend their interests, including strike action.

6.3. Prohibitions on union discrimination andemployer interference in their operations
Workers representatives shall not be discriminatedagainst and shall have access to perform theirrepresentative duties in workplace. They benefit
from special protection regarding dismissal andperformance of duties. More precisely, as far
as dismissal of an employee representative isconcerned, Law 1264/1982 provides that any
such dismissal will be considered as null andvoid. Exceptions are provided for by article 14 of
Law 1264/1982, but they depend on very strict
conditions regarding the merits and the procedure
to be followed.
6.4. Requirements that worker representatives bein place
Pursuant to article 16 par. 5 of law 1264/1982, each
employer who employs more than 100 employees
should provide to the union of the company, which
has the most members, adequate space in theworkplace, in order to be used as office for the
purposes of the Union, if requested.

Principle 7 – Compliance with the law
7.1. Legal requirements to constitute a labour
relation
According to the recent case law of the Greek court(see decision no. 720/2013 of the Supreme Court)
a subordinate employment relationship exists whenthe employee is subjected to legal and personal
dependence on his employer, which is shown throughthe employer’s right to give to the employee orders
and instructions as to the way and the time of his
employment as well as to oversee and check if theemployee has complied to the above orders.
In any case, the court has the jurisdiction to decide
about the existence or non-existence of dependence,
having considered all the facts, that are provedin this case, and interpreting the content of thecontract, as it is required by the good faith and fairmerchantable, regardless of how the contracting
parties or the law have named the contract.

64

Assessment

7.2. Laws and regulations on employment contracts(incl. necessity for written employment contracts,
and if is not what are the grounds to consider the
existence of a verbal employment agreement)
It is not mandatory for the employer to provide
for a written employment contract. However, in
accordance with Presidential Decree 156/1994, theemployer shall provide a written document to theemployee concerning every substantial condition
and term of their agreement.
7.3. Required content for written employment
contracts
The terms and conditions that must be provided inwriting to the employee are:7.5. Requirements for various types of contracts(indefinite term, definite term, temporary workers,
probationary workers)• The successive fixed-term contracts are allowed
since they are justified by an objective reason(e.g. temporary replacement of an employee,
temporary work to be done, temporary
accumulation of work etc). If there is no objective
reason and since the successive fixed-term
employment contracts or relationships exceed
in total three years or in a three-year period
there have been more than three renewals,
these successive contracts are deemed to cover
fixed and permanent needs of the business orundertaking and as a result they are converted
to employment contracts of indefinite duration.

• Identification of the employer and the employee• The address of the central offices/headquartersof the company• Date of start of the employment relationship• Location of employment• Position, specialty, rank, category and work
description of the employee• Duration (if not indefinite term contract)• Annual leave conditions• Reference to the rules governing the terminationof the contract• The duration of employment of temporary
employee to the indirect employer must notexceed, totally, 36 months. However, the law does
not exclude the repositioning of the employee inthe same indirect employer, as long as there isa period of time between the previous and thenew position longer than 23 days. Otherwise, if
the employee continues to be employed by theindirect employer after the expiration of theinitial placement or / and of any renewal (evenwith a new placement), without an intervening
period of 23 calendar days, it is considered thatan employment agreement for indefinite period
exists between the employee and the indirect
employer.

• Wage and other benefits• Definition of the interval to be observed for
payment (per day, month, etc.)• Daily and weekly working hours• Reference to the applicable collective agreement
7.4. Deadline for conclusion of the contract (e.g. on
the date of hire or within 30 days of hire)
The employer shall provide a written document to
the employee with the abovementioned terms andconditions within two months after hiring.

7.6. Requirements for termination of employment(termination with or without cause, wrongfuldismissal, notice periods required to end
employment)• Early termination of a fixed term contract
requires the existence of a “cause”.
• Termination of contract of indefinite duration
does not require justification, but must becompliant to art. 281 Greek Civil Code “in goodfaith & without abuse of legal rights” - burden

65Assessmentof proof for employer. The termination must be
written and the statutory severance (terminationindemnity) must be paid.

7.7. Options for farmers to obtain legal assistanceabout their obligations (e.g. government department,
local labour office, farmers association etc.)– – Severance pay: In order to calculate
severance (termination indemnity), one
considers: a) the duration of the employment
relation (seniority); and b) yearly salary
divided by 12. Statutory severance is equalto specific number of months ‘regular salary’in proportion to duration of the employment
relation(seniority).
Themaximum
compensation is 12 months wages.

In general can farmers can obtain legal assistanceabout their obligations as employers at local
Inspections of Employment, social security services,
Unions, employees and employers’ associations in
the farming sector.

– – Notice: Greek employment law set a certain
notice period depending on the durationof the employment relationship. However,observing this notice period is not mandatory,
but it is directly related to the amount ofseverance indemnity due by the employer.
More precisely, if the notice period set by
law is observed, the statutory severance
indemnity is reduced by 50%.

The purchaser is entitled to add certain terms andconditions. Currently there is a basic template
imposed by the government but this is adjusted tomeet buyers’ requirements such as Crop Protection
Agents (CPA) residue tolerances, Good Agricultural
Practices (GAP) procedures etc (see Ministerial
Decision 238/19130 issued on 18.02.2014
regarding leaf growing contacts defines theminimum content that every leaf- growing contract
shall include). After the contract is signed by thebuyer and the farmer COOP (in which the farmer
belongs) the contract is registered with OPEKEPE.
The applicable terms and condition are followed
thereafter.

Years of experience
0-12 months

Notice period0

12 months-2 years

1 month

2 years – 5 years

2 months

5 years – 10 years

3 months

10 years and above

3 months- Neither notice period nor compensatory
severance pay is required in cases of:* Seniority < 12M (legal probationary period)* Criminal procedure against employee, who hascommitted a crime.

7.8. Specific requirements for leaf growing contracts(government imposed templates, government
approval of contract, freedom to choose the termsof the contract)

Additional Questions/Answers
1. QUESTION:
Could you please provide information on the legal
minimum wage applicable in Greece? Is there any
difference between minimum legal wage for adults
and juvelines? Furthermore, is the extent to whichbasic entitlements should be paid to workers
dependent on the duration of the contract?
1. ANSWER:
a) The statutory minimum salary/wage of privatesector employees all over the country is determinedby law 4093/2012 (subparagraph IA.11). According
to law as it stands today, the statutory minimum
salary/wage figures in the following tables.

66

Assessment

Employees over 25 years old
Years of employment until 14.2.2012

Minimum salary

0 to 3 years

586,08 €3 years fully completed to 6 years

644,69 €6 years fully completed to 9 years

703,3 €

9 years fully completed or more

761,9 €

Employees under 25 years old
Years of employment until 14.2.2012

Minimum salary

0 to 3 years

510,95 €3 years fully completed or more

562,05 €Workers over 25 years old
Years of employment until 14.2.2012

Minimum wage

0 to 3 years

26,18 €

3 years fully completed to 6 years

27,49 €

6 years fully completed to 9 years

28,8 €

9 years fully completed to 12 years

30,11 €

12 years fully completed to 15 years

31,42 €

15 years fully completed to 18 years

32,73 €

18 years fully completed or more

34,03 €

Workers under 25 years old
Years of employment until 14.2.2012

Minimum wage

0 to 3 years

22,83 €

3 years fully completed to 6 years

23,97 €

6 years fully completed or more

25,11 €b) There is no difference between the statutory minimum salary/wage for adults and juveniles (under 25
years old).
c) Last but not least, kindly note that pursuant to article 4 of Act no. 6/28.2.2012 of the Council of Ministers,
any allowance for maturity (dependent on the duration of employment) provided by law or collective labor
agreement has been suspended since 14.2.2012. In other words, only the years of employment until
14.2.2012 are taken into account for determining the level of minimum salary/wage.
67

Assessment

2. QUESTION:

basis of a six-day workweek) or 22 days/year (onthe basis of a five-day workweek).

Is it correct the salaries in between € 510.95 and €761 are monthly and the salaries in between € 22.83
and €34.03 are daily? Are these salaries based on a
8 hour working day and in addition how many days
are calculated for a monthly salary?

4. QUESTION:

2. ANSWER:

4. ANSWER:

Correct. The monthly salary is based on 8 working
hours/day x 5 days/week (=40 working hours/week);
it corresponds to (on average) 25 working days.

The law distinguishes between employees (or whitecollar workers) and workers (or blue collar workers).
Specifically, according to the settled case-law,
employees are those who render primarily mental
work, while, workers are those who render primarily
manual work. The importance of the distinction
appears mainly in the notice period to be observed
before terminating the employment agreement andin the severance payment.

3. QUESTION:
Furthermore the second question in the email below
referred to how benefits (maternity leave, holidays,
etcetera) to which workers are entitled should be
calculated. For example: how many holidays (andother benefits) should be provided to a temporary
worker contracted for a period of for example threemonths?
3. ANSWER:
The calculation of the benefits depends on the
duration of employment and varies according to thekind of benefit.31 For example, as regards the annual
leave:• For the 1st (calendar) year of employment– theemployee is entitled to 2 days of paid leave
per month of employment (on the basis of asix-day workweek) or 1,66 days paid leave permonth of employment (on the basis of a five-day
workweek). Thus, an employee who provides
his/her services for example for three months
is entitled to 6 days of paid leave, if he/she isemployed six days per week.
• For the 2nd (calendar) year of employment–
the employee is entitled to 2,08 days/month of
employment (on the basis of a six-day workweek)
or 1,75 days/month (on the basis of a five-day
workweek).
• For the 3rd (calendar) year of employment
or more– (from 1st January of the year) the
employee is entitled to 26 days/year (on the

Is there any difference in definition of ‘employees’and ‘workers’ as used in the tables above?

5. QUESTION:
Which is the regulation for “Ergosimo”? Which legal
benefits are covered by Ergosimo and is this thecomplete list of benefits that should be compliedwith?
5. ANSWER:
Pursuant to article 20 of law 3863/2010, the(national and foreign) farm workers, who are
insured by the Agricultural Insurance Organisation(OGA), can also be paid (by the employer) via“ergosimo”. The statutory minimum salary/wage ofprivate-sector employees all over the country, as
it is determined by law 4093/2012 (subparagraphIA.11) as it stands today, is applicable.
Moreover, the social security contributions to OGA(10% of the nominal value of “ergosimo”, as it stands
today), are withheld from the workers’ salary.
Practically speaking, the farm workers are paid thenominal value of “ergosimo” minus 10%.
Thus, “ergosimo” is nothing more than an optional
method of payment of salary and social security
contributions (applicable to specific categories of
employees).

31.	 Without prejudice to the more favourable (to employees) provisions of (applicable) sectoral or business CLA.
68

Assessment

6. QUESTION:
To what extent legal benefits (social insurance,
holidays, leave etc.) are covered, when a worker ispaid by ergosimo?
6. ANSWER:
Pursuant to law 3863/2010 (particularly article 20),in conjunction with Circular No. 9/2011 issued by
the Agricultural Insurance Organisation (OGA) andthe Ministerial Decision No 14913/2011 issued by
the Ministry of Labour, the farm workers are paid (fortheir provided services) and insured via “ergosimo”,
which is nothing more than a method of payment ofsalary and social security contributions, applicableto specific categories of employees. Given that thelegal benefits, pursuant to the labor legislation, areconsidered as remuneration, one could support thatthe legal benefits can be paid via “ergosimo” as well.
But, typically, legally speaking, neither the law nor
the Circular provides that “ergosimo” covers legal
benefits, other than the workers’ salary and social
security contributions).
7. QUESTION:
Could you please inform whether a farmer should
pay the gross wage or the calculated net wage toworkers? And whether it is correct if the suppliercommunicates only on the net wage to farmers andworkers?
7. ANSWER:
The general rule is that the employer should pay
the employees the net wage (having withheld social
security contributions and taxes).
However, in case a farm worker is paid and insured
via “ergosimo”, the following shall apply:• The social security contribution to OGA (10%of the nominal value of “ergosimo”, as it stands
today), is withheld from the workers’ salary.
Practically speaking, the farm workers are paid
the nominal value of “ergosimo”, minus 10%.
• As regards the farm workers’ income taxation,“ergosimo” is not subject to withholding tax. The
farm workers are subject to taxation for theirprovided services according to articles 12 and

60 of the Greek Income Tax Code. In particular,
the farm workers shall include in their income
tax return (there are two certain fields about“ergosimo”, No 309 and 310) any amount thatthey were paid via “ergosimo” and the (total)
income tax is payable at the stage of the clearanceof their tax return.
There is not any correct wage communication bydefinition. If the net wage is communicated, it has
to be clear that it is indeed the net wage, following a
deduction of the social security contribution and, if
the farmer or the worker asks for more information,
the supplier has to provide the explanation of how
the net wage is calculated.
8. QUESTION:
Is it “ergosimo” also a “short-term employment”
form, a way to record/evidence the existence of an
employment relation? Or, is it simply a “payment
method”?
8. ANSWER:“Ergosimo” is a payment method, it cannot replacea labor agreement, either of a short or long term,of a definite or an indefinite period. In other words,“Ergosimo” is an evidence of the payment of theworker’s salary and of the respective social security
contributions, but it is not an evidence of the overall
contractual relationship between the farmer andthe worker.
9. QUESTION:
Is it the 10% for SS deducted (withheld) from thefinal payment to the worker based on the ergosimo?
Thus, we should understand that workers, paid
under the ergosimo payment method, end receiving
10% less.
9. ANSWER:
The social security contribution for the land
workers, who are engaged in works covered by
OGA (Organization for the Agricultural Security), is
10% on the salary, covering health and pension, no
matter if the payment method is “ergosimo” or other(like bank deposit or transfer).

69

Assessment

10. QUESTION:
Is there any legal limitations (or risks) tocommunicate/converse/talk to external (3rdparties) workers?
10. ANSWER:
This is a very general question to be answered witha “yes” or “no”. A lot depends on the conditions andthe circumstances under which the communication
takes place, the subject matter of the discussion,
the content of the discussion, the perception of theworker of what was discussed, etc. What I can say
is that the direct communication with the workers
on issues related to the implementation and theresults of the ALP program does not present majorrisks, provided that we approach the workers in a
cautious, well structured manner.

70

Assessment

Appendix IV – Findings Farm-by-farm monitoring system
CU identified the following statements andquestions in the farm-by-farm monitoring system
which were either not in line with ALP or were
unclearly stated. The findings are described per ALP
Code Principle.
Child labor:• The following statements included requirements
for children aged below 15, while these are not
relevant as it is not allowed to hire children
below 15 in any case: “Hiring of children <15years, that attend school and are employed formore than 6 hours per day”, “Employment ofchildren<15 years old, during night hours (22.0006.00)”, “Employment of children<15 years old,
for more than 12 consecutive hours”, “Overtime
employment of children<15 years old”.
• Stringing of tobacco leaves was not included in
the list of hazardous work.
• Farmers children doing ‘light tasks’ in the age
category 13-15 were reported as Prompt Action,
while this is allowed in a family setting.
• “The presence of any child<15 in the field is notallowed by its family” while children in between
13-15 can do light tasks.
Income and work hours:• Wages mentioned were different to thecommunicated wages to farmers. Whilecommunication materials referred to thecalculated net minimum wage, the monitoring
system referred to the gross legal minimum
wage 32 as follows: “Unexperienced laborers,>25 years old, are paid < 26, 18 € (with the
exception of those that are paid piece rate” and“Inexperienced laborers, 18-25 years old, arepaid <22, 83 € (with the exception of those thatare paid piece rate”. In addition, the minimum
wages are also applicable to piece rate payments,
while in the statement these are mentioned as
exeption.
• Regular work hours are 40 instead of 48 in
Greece. while the following is stated in themonitoring: “Employment over 48 hours weekly,
in cases of contracts that specify a 5-day labor
week”• The overtime rate for additional work hours is
not included. In the monitoring is only referredto that these hours should be paid.
• Payment frequency is stated without reference
to the frequency of once a month that should be
met: “Wages are paid regularly”• Regarding the benefits that should be provided
to workers, only is mentioned “Holidays, bonuses
not paid, in cases of contracted employment”
without any further reference to the numberof days of holiday that need to be provided or
which bonuses the farmer should provide to theworkers.
Fair treatment:• As solution for ‘physical abuse’, ‘discrimination’and ‘sexual abuse’ was mentioned the “endof cooperation” with the worker, but there
was no further information provided on what
requirements should be met in such cases toensure a proper arrangement for the worker.
Forced labor:• “Not free to leave from their tasks for a break”
mentioned under the ALP Code Principle of32.	 The gross legal minimum wage in Greece is: €586.08 monthly or €26.18 daily for workers over 25 or, €510.95 monthlyor €22.83 daily for workers under 25. Missirian communicated to farmers the net wage which was calculated by adeduction of approximately 21% of the gross legal minimum wage. This 21% is an estimate calculated by a 17.70%
social security contribution and taxes. From the gross legal minimum as mentioned in the legal analysis in appendix
III, the net minimum wage is calculated to be €460 monthly, €21 daily and €2.60 hourly. (See Appendix III for moredetailed legal information).
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Assessment

forced labor, however this should be related
to the ALP Code Principle of income and work
hours.
Compliance with the law• “No written employment contracts” wasmentioned as Prompt Action, while neither
the local law or the ALP required employment
contracts to be written.

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Assessment

Appendix V – Communication materials

ALP Brochure (1/2)

73Assessment

ALP Brochure (2/2)

74Assessment

GTS leaflet

75Assessment

GTS sheet76

Assessment

ALP stickers

166 sticker

77Assessment

CPA disposal sticker

78

Assessment

Re-entry period sticker

Re-entry period sticker

79

Assessment

ALP Stickers

80Assessment

ALP standards poster81

Assessment

ALP Principles poster82

Assessment

Support line leaflets and hat

83

Assessment

Appendix VI – Glossary
ALP

Agricultural Labor Practices

ALP Code

PMI’s Agricultural Labor Practices Code

ALP Code Principle

Short statements that set expectations of how the farmer should manage labor on
his/her farm in seven focus areas

ALP Program

Agricultural Labor Practices Program

Correction

Any action that is taken to eliminate a situation not meeting the standard

Corrective action

Steps taken to remove the causes of a situation not meeting the standard

CPA

Crop Protection AgentsEU

European Union

Family farm

Farm that depends mainly on family members for the production of tobacco

Farm Profiles

A data collecting tool developed by PMI with Verité to track the socio-economic
profile of the farms

Food standard

Third party contracted by Papastratos to implement the support mechanism.

GAP

Good Agricultural Practices

GTS

Green Tobacco Sickness

Leaf tobacco supplierCompany that has a contract with PMI to supply tobacco but is not a farmer

Measurable Standard

A Measurable Standard defines a good labor practice on a tobacco farm and helps
determining to what extent the labor conditions and practices on a tobacco farm arein line with the ALP Code Principles

Migrant labor

Labor coming from outside the farm’s immediate geographic areaNGO

Non-Governmental OrganizationOC

PMI Operations Center (Lausanne, Switzerland)

Papastratos

PMI’s affiliate in Greece

Piece work

Payment at a fixed rate per unit of production/work

PMI

Philip Morris International, Inc. or any of its direct or indirect subsidiaries

PPE

Personal Protection Equipment

Preventive action

Steps taken to remove the causes of potential situations not meeting the standard

Prompt Action

A situation in which workers’ physical or mental well-being might be at risk, children
or a vulnerable group – pregnant women, the elderly - are in danger, or workers
might not be free to leave their job

Root cause

The underlying reason that caused a situation not meeting the standard

Root cause analysis

A set of analyzing and problem solving techniques targeted at identifying theunderlying reason that caused a situation not meeting the standard

Sharecropping

A system of agriculture in which the farmer has a partner (“socio”) who either works
together with the farmer or manages a plot of land. Costs of inputs and/or revenue
are shared.

STP

Sustainable Tobacco Production

SRTP

Social Responsibility in Tobaccos Production; industry-wide program

Support mechanism

A way for workers to access information and get support in difficult situations andfor workers and farmers to get support in mediating disputes. Farmers have accessto additional services to improve labor and business practices.

Village facilitators

Field technicians main contact in villages which supported in finding farmer andfields and promoted farmers to join and contract Missirian.
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