THIRD PARTY ASSESSMENT
DELTAFINA
Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

Control Union Certifications
Meeuwenlaan 4-68011 BZ ZWOLLE
Netherlands

September 2015

PMI Third Party Assessment

Control Union Certifications
TABLE OF CONTENTS

1. ALP PROGRAM BACKGROUND AND ASSESSMENT OVERVIEW ....................... 5
2. DELTAFINA ASSESSMENT: SCOPE AND METHODOLOGY ................................... 8
2.1 SCOPE............................................................................................................................................ 9
2.2 OPENING MEETING ....................................................................................................................... 9
2.3 STAFF INTERVIEWS AND ALP PROGRAM DOCUMENTATION ...................................................... 9
2.4 FARM SAMPLE SELECTION ............................................................................................................ 9
2.5 FARM VISITS ............................................................................................................................... 12
2.6 PERSONS INTERVIEWED ............................................................................................................. 13
2.7 CLOSING MEETING ...................................................................................................................... 15
2.8 PREPARATION OF THE FINAL REPORT ........................................................................................ 15
3. ASSESSMENT: IMPLEMENTATION OF PHASE 1 OF THE ALP PROGRAM .. 16
3.1 CONDUCT OF THE ASSESSMENT................................................................................................. 17
3.2 PEOPLE AND PROCESSES TO MANAGE THE ALP PROGRAM...................................................... 17
3.2.1 Company internal structure ..............................................................................173.2.2 Internal structure for ALP implementation .................................................18
3.2.3 Internal communication and reporting ........................................................19
3.2.4 ALP training, roles and responsibilities ........................................................20
3.2.5 Engagement with the ALP Program ...............................................................21
3.3 COMMUNICATING THE ALP CODE REQUIREMENTS TO ALL FARMERS ..................................... 21
3.3.1 The ALP communication strategy ...................................................................21
3.3.2 ALP communication methods and materials ..............................................22
3.3.3 Understanding and perception of the ALP Program ................................23
3.4 BUILDING FARM PROFILES FOR ALL CONTRACTED FARMS ....................................................... 24
3.4.1 Data gathering system for Farm Profiles.....................................................25
3.4.2 Accuracy of Farm Profiles ..................................................................................25
3.4.3 Analysis on information Farm Profiles ..........................................................26
3.5 PROMPT ACTIONS ....................................................................................................................... 26
3.5.1 Prompt Action reporting mechanism ............................................................26
4. ASSESSMENT OF THE CURRENT STATUS OF PHASE 2 OF THE ALPPROGRAM .................................................................................................................................... 28
4.1 MONITORING OF LABOR PRACTICES FARM BY FARM................................................................. 29
4.1.1 Selection of issues ...............................................................................................29
4.1.2 Mechanism for monitoring ................................................................................29
4.2 ADDRESSING WIDESPREAD AND/OR SYSTEMIC ISSUES .......................................................... 30
4.2.1 Investigation of root causes .............................................................................30
4.2.2 Initiatives to address widespread and/or systemic issues ...................30
4.3 SUPPORT MECHANISM ................................................................................................................ 30
5.1 ALP CODE PRINCIPLE 1: CHILD LABOR ................................................................................... 33
5.1.1 Prevalence of children working .......................................................................33
5.1.2 Awareness of legal minimum working age .................................................34
5.1.3 Awareness of hazardous work .........................................................................34
5.1.4 Age verification .....................................................................................................34
5.1.5 Child supervision ..................................................................................................34

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5.2 ALP CODE PRINCIPLE 2: INCOME AND WORK HOURS ............................................................ 35
5.2.1 Minimum salary and payment schedule ......................................................36
5.2.2 Regular and overtime hours .............................................................................37
5.2.3 Legal benefits .........................................................................................................37
5.2.4 Awareness of legal minimum wage ...............................................................37
5.2.5 Awareness of legal working hours .................................................................37
5.2.6 Record keeping and pay slips ..........................................................................37
5.3 ALP CODE PRINCIPLE 3: FAIR TREATMENT ............................................................................. 38
5.3.1 Fair treatment ........................................................................................................39
5.3.2 Communication with workers ..........................................................................39
5.4 ALP CODE PRINCIPLE 4: FORCED LABOR ................................................................................ 40
5.4.1 No evidence of workers unable to leave their job ...................................40
5.4.2 Financial problems among farmers ...............................................................40
5.5 ALP CODE PRINCIPLE 5: SAFE WORK ENVIRONMENT............................................................. 41
5.5.1 Training and awareness of Green Tobacco Sickness (GTS) .................41
5.5.2 CPA handling and training .................................................................................425.5.3 Clean drinking and washing water .................................................................43
5.5.4 Re-entry period .....................................................................................................43
5.5.5 CPA storage and final disposal ........................................................................43
5.5.6 Safe and sanitary environment .......................................................................43
5.5.7 General safety measures ...................................................................................44
5.6 ALP CODE PRINCIPLE 6: FREEDOM OF ASSOCIATION ............................................................ 45
5.6.1 Workers´ right to freedom of association ...................................................45
5.6.2 Awareness of freedom of association ...........................................................45
5.7 ALP CODE PRINCIPLE 7: COMPLIANCE WITH THE LAW .......................................................... 46
5.7.1 Information on legal rights ...............................................................................46
5.7.2 Employment contracts ........................................................................................46
6. CONCLUDING REMARKS ................................................................................................. 47
APPENDICES .............................................................................................................................. 49
APPENDIX 1. DELTAFINA RESPONSE AND ALP PROGRAM ACTION PLAN ................................... 50
APPENDIX 2. ALP CODE ................................................................................................................... 59

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GLOSSARY OF TERMS and ACRONYMS
ALP
ALP Code
ALP Code Principle

ALP Program
CU
DELTAFINA
CPA
Crew leader
Family farm
Farm Profiles

FCV
GAP
GTS
IBERTABACO
COOLOSARTABACOEXUNAGRIITP
Leaf tobacco supplier
Migrant labor

Measurable Standard

NGO
OC
Phase 1
Phase 2
Piece work
PMI
PMIM SA
PPE
Prompt Action

Support mechanism

Agricultural Labor Practices
PMI’s Agricultural Labor Practices Code
Short statements that set the expectations of how the farmer
should manage labor on his farm with regards to the seven focus
areas
Agricultural Labor Practices Program
Control Union Certifications
PMI tobacco supplier in Spain
Crop Protection Agents
Person responsible for managing a group of workers
A farm that depends mainly on family members for the productionof tobacco
A data collecting tool, developed by PMI with Verité, to track thesocio-economic status of the farms and systematically gather
detailed information about (among other things): the type of labor
employed, the farming activities that minors may be involved in,and the hiring process
Flue-cured Virginia tobacco
Good Agricultural Practices
Green Tobacco Sickness
Second tier cooperative
First tier cooperative: Sociedad Cooperativa Agraria de Losar de la
Vera
First tier cooperative: Tabacos de Extremadura Sociedad
Cooperativa Limitada
First tier Cooperative: Union de Agricultores de Riolobos Sociedad
Cooperativa Limitada
International Tobacco Procurement program of PMI
Company that has a contract with PMI to supply tobacco but is nota farmer
Migrant labor refers to labor that comes from outside the farm’s
immediate area. Migrant labor can come from a neighboring
region in the same country, or from a different country
A Measurable Standard defines a good labor practice on a tobacco
farm and helps determine to what extent the labor conditions andpractices on a tobacco farm are in line with each of the ALP Codeprinciples
Non-Governmental Organization
PMI Operations Centre (Lausanne, Switzerland)Start-up of ALP Program (training, communication and outreach)
ALP Program full implementation (monitoring and addressing
problems)
Payment at a fixed rate per unit of production or work
Philip Morris International, Inc. or any of its direct or indirect
subsidiaries
Philip Morris International Management SA
Personal Protection Equipment
A situation in which workers’ physical or mental well-being might
be at risk, children or a vulnerable group (e.g. pregnant women,
the elderly) are in danger, or workers might not be free to leave
their job
A way for workers to access information and get support in difficult
situations and for workers and farmers to get support in mediating
disputes. Farmers have access to additional services to improvelabor and business practices.

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1. ALP Program background and assessment
overview

THIRD PARTY ASSESSMENT
DELTAFINA
Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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In 2011, Philip Morris International Inc. (PMI)1 launched a worldwide Agricultural
Labor Practices (ALP) program to progressively eliminate child labor and otherlabor abuses, where they are found and to achieve safe and fair working
conditions on tobacco farms. This program applies to all tobacco farms with which
PMI, or PMI´s leaf tobacco suppliers, have contracts to grow tobacco for PMI andconsist of four main components:(1) the Agricultural Labor Practices Code: setting clear standards for all
tobacco farms growing tobacco from which PMI ultimately buys;(2) an extensive training program for all PMI and leaf tobacco supplier’s
staff that are directly involved with tobacco growing, in particular the fieldtechnicians that provide regular visits to the farms;(3) a multi-layered internal and external monitoring system; and(4) involvement of governmental and non-governmental (NGO)stakeholders in improving labor practices and enhancing the livelihoods oftobacco growing communities.
The ALP Program was developed, and is being implemented, in partnership with
Verité: a global social compliance and labor rights NGO. Control Union
Certifications (CU) was commissioned by PMI to develop the external monitoring
component of the ALP Program working in tandem with Verité to assess PMI leaf
tobacco suppliers and tobacco farms worldwide. All PMI leaf tobacco suppliers
submit internal, annual reports and are assessed regularly on their performance.
For the ALP Program implementation, internal reviews are also being performed toassess the progress and challenges in the program’s implementation. Third party
assessments (periodic reviews) of PMI leaf tobacco suppliers and tobacco farms
worldwide are undertaken by CU. In this initial stage of implementing the ALP
Program, these third party assessments focus solely on the ALP Program
implementation. They specifically focus on the progress of each leaf tobacco
supplier‘s implementation of the ALP Code, framed against the strategic objectives
set by PMI. The ALP Code contains seven (7) principles:2
1.
2.

3.

4.
5.

6.
7.

Child Labor
There shall be no child labor.
Income and Work Hours
Income earned during a pay period or growing season shall always be enough to meet workers’ basic needs
and shall be of a sufficient level to enable the generation of discretionary income. Workers shall not work
excessive or illegal work hours.
Fair Treatment
Farmers shall ensure fair treatment of workers. There shall be no harassment, discrimination, physical ormental punishment, or any other forms of abuse.
Forced Labor
Farm labor must be voluntary. There shall be no forced labor.
Safe Work Environment
Farmers shall provide a safe work environment to prevent accidents and injury and to minimize health risks.
Accommodation, where provided, shall be clean, safe and meet the basic needs of the workers.
Freedom of Association
Farmers shall recognize and respect workers’ rights to freedom of association and to bargain collectively.
Compliance with the Law
Farmers shall comply with all laws of their country relating to employment.

1

For the purposes of this report, “PMI” means Philip Morris International, Inc. or any of its direct orindirect subsidiaries.
2
The full ALP Code is contained in appendix 2.

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The implementation of PMI’s ALP Program by leaf tobacco suppliers that purchase
tobacco for PMI has been divided into two phases:3
Phase 1Management personnel and field technicians understand the ALP Code andthe implementation approach, including ensuring capacity of people andprocesses in place to roll-out and manage the ALP Program;
Communicate the ALP Code, requirements and expectations to all farmers;
Document Farm Profiles for every contracted farm including identifying risk
areas and tracking communication efforts to farmers;
Being aware and engaged to identify situations and incidents at farms thatshould be both reported and addressed immediately.

Phase 2 (full implementation of the program)








Collect detailed information about labor practices on every contracted
farm;
Systemically assess each farm for status of the Measurable Standards
outlined in the ALP Code;Create and implement an improvement plan for each farm to improve theimplementation of all required standards;
Identify and implement corrective and/or preventive measures to identify
and address the root causes of potential situations not meeting thestandards and risks found on the farms;
Systemic reporting on the progress being made;Support mechanism in place.

(Source: Verité & PMI, 2011)
3

Often, there is not a strict distinction between the two phases during ALP implementation. In
practice suppliers in many markets start to consider how to address and respond to situations that do
not meet the Code and to monitor changes before formally finishing Phase 1.

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2. DELTAFINA Assessment: Scope and Methodology

THIRD PARTY ASSESSMENT
DELTAFINA
Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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2.1 Scope
In 2011 PMI launched the ALP Program globally. This report of DELTAFINA’s
tobacco growing operations in the Spanish region of Extremadura is the eleventh
external ALP assessment by Control Union. The assessment was conducted in
September 2015 during the completion of DELTAFINA’s third crop season underthe ALP Program and its second year of implementing Phase 2.
2.2 Opening meeting
On 21st September 2015, CU started the assessment with a meeting at the
IBERTABACO offices in Rosalejo, attended by the DELTAFINA ALP steeringcommittee (regional Managing Director, ALP regional agronomy chief and ALP
regional coordinator), the DELTAFINA ALP Country Team (IBERTABACO Managing
Director, Coolosar Managing Director and Tabacoex Managing Director) and the
PMI regional ALP coordinator. During the meeting CU presented the objectives of
the assessment and DELTAFINA provided an overview of ALP implementation in
their supply chain.
2.3 Staff interviews and ALP Program documentation
The assessment of DELTAFINA’s work included individual interviews with the ALP
steering committee and the ALP Country Team at the IBERTABACO and Coloosar
offices. All interviews were conducted individually so interviewees felt comfortableto speak freely and raise any issues. The conversations covered the following
topics in relation to the ALP Program:













General awareness of the ALP Program and knowledge of the ALP Code;
Implementation of the ALP Program at the DELTAFINA level;
Responsibilities of management personnel;
Internal training and communication on the ALP Program;
Communication of the ALP Code to farmers;
Internal system to collect information for Farm Profiles;
Mechanism for reporting Prompt Actions;
Records showing the training of field technicians;
Relationship with external stakeholders;
Pilot conducted for monitoring labor practices;
Initiatives implemented to address widespread and/or systemic issues; andSupport mechanism.

DELTAFINA provided all the relevant documentation related to the ALP Program
implementation requested by CU, including: Farm Profiles, farmer communicationmaterials, purchase contracts, Prompt Action reports, training records, personnel
records, and internal ALP related job objectives.
2.4 Farm sample selection
To constitute a meaningful sample, CU needed to visit at least 13 farms, thesquare root of the total of 169 farmers directly contracted by DELTAFINA in theregion of Extremadura. In total, CU visited 13 farms. Farm selection wasprioritized based on the following categories:

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Geographical spread
Farm size
Farms with reported Prompt Actions in 2014 and/or 2015

100% of the farm visits were unannounced. The day before a specific farm visit
and assessment of a field technician, CU informed the ALP Country Team leader.
The farmers to be visited were notified on the day of the visit. Over one week, CU
visited an average of four farms per field day with a full day of reporting reserved
after two day of field visits.
The total number of contracted farms within the scope was divided over sevengrowing regions inside Extremadura: Pueblonuevo de Miramontes, Riolobos,
Rosalejo, Tietar, Losar de la Vera, Jarandilla de la Vera and Villanueva de la Vera(including only Flue Cured Virginia farmers).
The graphs and tables below provide information on the 13 sampled farms.
Percentages refer to the demographic breakdown of this specific sample of farms.

Farms per region

Jarandilla de la Vera8%8%Villanueva de la Vera

23%

8%

Losar de la Vera
Riolobos
Tietar

15%
23%
15%

Rosalejo
Pueblonuevo deMiramontes

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At the time of the assessment all farms visited were in the harvesting stage oftobacco production and some of them were already curing and/or classifying (seegraph below).

Stage of tobacco production
14
12

13

10
8
6

7

4
2
2
0

Harvesting

CuringClassifying

Farm size(hectares of tobacco)

38%

0-10
10< 100
62%

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Type of farm
(T=13)5
Family farm with only family members working
8%15%

Farm with family members and local workers

15%
Farm with family members and migrant workers

Farm with family members and local and migrant workers
8%
Farm with only local workers (no family members)
38%

8%

Farm with local and migrant workers (no family members)
8%
Farm with sharecroppers who hire local workers
4

2.5 Farm visits
CU used a variety of methods to collect information on each farm’s
implementation practices for the ALP Code’s Measurable Standards. These
included: interviews with farmers and workers, verification of farm related
documentation and visual observation of fields, storage rooms, curing barns,
working areas and housing. Before each interview, CU explained the objective of
the assessment and assured interviewees that anonymity would be preserved at
all times.
On each farm, CU conducted an individual interview with the farmer to assess theeffectiveness of DELTAFINA’s communication efforts, verifying:The farmer’s awareness of the ALP Code;The farmer’s level of understanding and attitude towards the ALP Code;The key messages received from DELTAFINA;
The farmer’s willingness and ability to meet the standards of the ALP Code.

In addition, CU conducted individual and group interviews with farm workers andfamily members working at the farms, verifying:

The worker’s awareness of the ALP Code;
The worker´s level of understanding and attitude towards the ALP Code;4

Sharecropper: Person responsible for managing a plot of land for which the farmer provides the
inputs and at the end of the harvest the worker shares the profit with the farmer.

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The labor practices at the farm.

2.6 Persons interviewed
In total, 27 people were interviewed. To avoid undue interference or influence,
CU attempted to conduct all interviews with workers without the presence of the
farmer. The graphs below provide a demographic profile of this sample ofinterviews.

Persons Interviewed
100%
80%

48%
Farmers (13)60%
4%External workers (13)

40%
20%

Family members (1)48%0%Total (27)
The following two graphs provide demographic information on the 13 external
workers and the family member of the farmers interviewed in the assessedregions. All workers interviewed were local5 and above 18 years old, as was thefamily member who was interviewed.

5

Workers who travelled home daily.

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Gender of external workers and family
members interviewed
100%

80%
64%
60%

Male
Female

40%

20%

36%

0%
Total (14)The following graphs provide additional information about the workers’ type of
employment for the farms visited.6

Duration of employment external workers
100%
15%

3-6 months
80%

1-3 months
60%

56%

40%

Less than 1
month

20%
29%
0%

Total (41)6Based on worker interviews and farmer declarations.

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Origin assessed external workers
12%
10%
78%

PolandMoroccoLocal

2.7 Closing meeting
CU presented its initial findings in Madrid on 23rd October 2015. The meeting, wasattended by representatives of the DELTAFINA ALP steering committee, part of
the DELTAFINA ALP Country Team (represented by the IBERTABACO Managing
Director), two representatives from the OC, two representatives of PMI regional
agricultural programs for Europe and four management representatives from PMI
Spain.
2.8 Preparation of the final report
This final public report is an important external measurement of the progress ofglobal ALP implementation, in all countries where PMI sources tobacco, including
Spain. Public release of this report demonstrates DELTAFINA’s and PMI’scommitment to transparency; this is an important component of the ALP Program.
CU prepares the final assessment report with Verité providing quality control.
While drafting the report, PMI and the local PMI entity or leaf tobacco supplier
may request clarifications on specific findings. After both PMI and the local PMI
entity (or leaf tobacco supplier), feel that the findings have been clarified andunderstood, a country action plan is prepared or the country revises the existing
GAP/ALP Program plans to respond to the findings.
All findings included in this report refer to the sample of employees of the leaf
tobacco supplier, farmers, family members and/or workers applicable andassessed, unless described otherwise. Hence, the numbers and percentages
presented do not refer to the entire farm base or staff contracted by the tobacco
leaf supplier.

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3. Assessment: implementation of Phase 1 of the
ALP Program

THIRD PARTY ASSESSMENT
DELTAFINA

Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

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This chapter documents the findings of the assessment of DELTAFINA’s
implementation for Phase 1 of the ALP Program. Phase 1 began with training for
management personnel and field technicians, including:
1) DELTAFINA’s objectives and expectations;2) The meaning of the ALP Code Principles and Measurable Standards;
3) Techniques to communicate the ALP Code to farmers;
4) Tracking progress of communications and how to build a Farm Profile;5) Identifying issues when visiting farmers.
3.1 Conduct of the assessment
CU was satisfied with the cooperation and access to information provided by
DELTAFINA. Everyone interviewed demonstrated a willingness to explain internal
processes and provide their professional feedback. Both management and field
personnel were fully transparent during the assessment and provided all support
requested by CU. All farmers visited were willing to participate in the assessment
while sharing the required documentation and/or allow interviews with farmworkers. It was not possible to interview the ALP Country Coordinator as she left
the company just a few weeks before the assessment was conducted.
3.2 People and processes to manage the ALP Program
3.2.1 Company internal structure
To understand the company’s strategy for implementing the ALP Program it isimportant to describe DELTAFINA’s organizational structure. DELTAFINA S.C. isthe Spanish subsidiary of the Italian company DELTAFINA S.P.A. In Spain, thecompany contracts the second tier cooperative, IBERTABACO, for tobacco services
which in turn gathers three first tier cooperatives: Coolosar, Unagri and Tabaco
which contract with the farmers, as shown in the chart below:

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Organizational chart

3.2.2 Internal structure for ALP implementation
At the time of the assessment, DELTAFINA had previously established an
ALP Steering Committee which included: the regional Managing Director,
Agronomy Chief, ALP Coordinator and the Country Managing Director. An ALP
Country Team was also created which included: an ALP country leader, one firsttier cooperative’s Managing Director, three second tier cooperative’s Managing
Directors and five field technicians. Both the Steering Committee and ALP Country
Team were supported by the PMI Regional ALP Coordinator and all these
employees were also involved in the broader Good Agriculture Practices (GAP)
Program.

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Organizational chart for ALP implementation

DELTAFINA response: “The Contracting structure for tobacco farmers in Spain is multi-layered
and therefore the effective implementation of the ALP Program requires commitment at all levels of
the supply chain. DELTAFINA at the top of this structure, together with the second tier cooperative“IBERTABACO” and first tier cooperatives “Tabacoex”, “Unagri MD” and “Coolosar”, shall lead thisprocess, with the involvement of technicians from the first tier cooperatives and coordinators fromIBERTABACO. The strong relationship and commitment of DELTAFINA and IBERTABACO will ensure thesuccessful implementation of the STP.
DELTAFINA and IBERTABACO are planning to organize different group meetings with the farmers at thedifferent crop stages of the season. The first meeting will be held just before signing the contracts forthe new crop (2016) to be sure that all farmers are committed to STP requirements. The first scheduled
meeting will be in February 2016, and DELTAFINA will explain to all of its contracted farmers thecommitments for the coming crop (2016) in terms of the mandatory agronomic programs under ALP
and STP. At this point the farmers can decide whether to sign with DELTAFINA or another supplier.”
3.2.3 Internal communication and reporting
The ALP Country Team and the Steering Committee held quarterly meetings
during which ALP was discussed. The ALP Country Team coordinator and theCountry Managing Director reported on program developments and related issues
including: the ALP plan, farm monitoring, addressing issues with farmers, Prompt
Actions, budgets and impact on the initiatives. Subsequently, the ALP country
coordinator sent a quarterly report to the ALP Steering Committee and the PMI
Regional ALP Coordinator.
The Country Managing Director, ALP Country Coordinator and Agronomy Chief
held monthly meetings in which updates about the ALP implementation status was
discussed.
In the local offices, the ALP country coordinator, the cooperative’s Managing
Directors and field technicians met weekly to discuss ALP related issues, including:status of Prompt Actions, difficulties in how to communicate the ALP to thefarmers and strategies on how to better reach farmers. These meetings were also

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attended by the Country Managing Director who actively joined in both thediscussions and in gathering valuable field information. To continually improve
both the knowledge and understanding of the ALP Code, different teachingstrategies were used to facilitate the learning process and help field technicians
share their experiences from field visits.
As well as these weekly meetings, personnel involved in the ALP implementation
were constantly updated by emails, phone calls or informal meetings.
3.2.4 ALP training, roles and responsibilities
All required personnel involved in implementing ALP were trained. The regional
Managing Director, Agronomy Chief and Country Managing Director were firsttrained in 2011 and 2012 by the PMI Regional team. In 2013, updated training
sessions with the cooperative’s Managing Directors, the ALP country coordinatorand field technicians were held by the PMI Regional ALP Coordinator. In 2014 and2015, the PMI Regional team organized a workshop with the ALP Steering
Committee and the ALP Country Team. The workshop included visits to the farms
to analyse improvement areas for the implementation of the ALP Code in the field.
During weekly meetings, the field technicians were continually trained and theirknowledge was assessed through both and written tests.
Despite there being no written roles and responsibilities regarding ALP these wereclear for all personnel involved in the ALP Program.
Only the ALP Country Coordinator had a full time responsibility for the ALP
Program; the rest of the ALP Country Team members had other responsibilities
and tasks (administrative, buying, curing barn management, agronomy
support, etc.) in addition to the ALP Program.
DELTAFINA response:”…DELTAFINA will hold several meetings at different levels. The first will be
in February then one more after the transplanting in June - July with the participation of:
1.
2.

3.
4.

DELTAFINA HQ and IBERTABACO: in order to manage and analyze the current situation andestablish an intensive training program for all STP participants.
STP Country Team: in order to analyze each cooperative’s specific structural and operational
circumstances and how they impact the implementation of ALP. In particular, allmanagement and participants to understand the ALP program and the relationship anddistinction where applicable, from relevant laws.
STP Country Team: in order to refresh FT’s knowledge based on CU’s findings.
Farmers: with the target to meet 100 % of them, provide training to refresh their knowledge
and understanding through meetings held twice a year and face to face discussions with FTs
during the season. All the meetings will be held in the headquarters of each cooperative.”

One meeting will be held before the crop season (February 2016) and at least one other meeting will
be held during the growing phase (June 2016). These meetings will be attended by DELTAFINA HQ
personnel, the STP country team and all the farmers. The refresher meetings within the Country STP
team will take place on a monthly basis, with particular emphasis on the gaps related to the Prompt
Action issues, improving their knowledge about the topic and identifying the main areas of concern
through the risk assessment.”

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3.2.5 Engagement with the ALP Program
The ALP Steering Committee was very engaged with the ALP Program. From theirperspective the main goal of the ALP Program was to demonstrate social
responsibility, add value to the final product and improve rural living.
The ALP Steering Committee was fully aware of the widespread issues and theprogress of the initiatives at the farm level. To reinforce ownership and to provide
a participatory role, tools and special documents were developed for gathering
information at the farms. Additionally, members of the ALP Steering Committee
occasionally joined field personnel on farm visits giving them insight into specificchallenges and the perspective of farmers.
The ALP Country Team members were engaged with the program as they all
responded that they found the ALP code was a way to improve safety at thefarmers’ workplace and demonstrated a social commitment in the tobacco
production sector. However, the Managing Director of one of the cooperatives
claimed that the ALP code was neither a useful program nor a priority, as in hisview all the principles were already covered by the local law for the Spanish
tobacco market.
Moving down the organization, the engagement of field technicians was importantas they managed the primary contact with the farmers. Most of them declared
they saw the ALP Code as an opportunity for the farmers to comply with the local
laws and improve the safety at the farm. However, there was one field technician
who was not very engaged with the program. He did not consider it useful as in
his opinion the laws in Spain were stricter than the ALP Code. This field technician
and the Managing Director referred to above, both belonged to the same
cooperative.
3.3 Communicating the ALP Code requirements to all farmers
3.3.1 The ALP communication strategy
The communication strategy and the materials and methodologies used were
defined based on the information gathered in Phase 1 (Farm Profiles and Prompt
Actions), Phase 2 (monitoring forms), during regular farm visits and theworkshops conducted by the ALP PMI Regional team.
All farmers contracted by DELTAFINA were included in the ALP communication andtraining programs. It should be noted that although the communication materials
described in the following chapter included all seven ALP Code Principles, fieldtechnicians focused primarily on safety (GTS & CPA) during the farm visits asthese were considered the most critical topics. However, in July 2015 DELTAFINA
decided to also emphasize the Income and Work Hours principle as PMI Regional
had identified a lack of knowledge among farmers and workers in this area.
As a result of DELTAFINA’s communication efforts, 11 farmers (85%) were awareof the ALP Code. The table below shows farmers’ awareness of the different ALP
Code principles. The percentages do not refer to the farmers’ total awareness of
the ALP Code Principles, only of the 7 major topics selected for the interviews.

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Farmers that named andexplained the principle

Child Labor

10 (77%)

Income and Work hours

9 (69%)

Safe Work environment

8 (62%)

Fair Treatment

8 (62%)

Forced Labor

5 (38%)

Freedom of Association

1 (8%)

Compliance with the law

1 (8%)Of the 11 farmers that were aware of the ALP Code, nine (82%) considered it
important. They understood its significance for improving safety at the farm andfor using it as a guide to comply with local laws and company rules.
12 farmers (98%) considered their relationship with the field technicians good.
They were satisfied with the agronomy support that was in place to help them
improve both their tobacco productivity and income. Only one farmer declared hewas dissatisfied with the support of the field technician. This farmer explained thatthe field technician was only giving support via cell phone instead of visiting
the farm.
3.3.2 ALP communication methods and materials
Three main methods of communication were used to communicate the ALP Codeto farmers: Group meetings in the cooperatives during the contracting period to
introduce the ALP Code to farmers
 Regular field technicians visits
 Individual meetings in the cooperatives when farmers visit thecooperatives
The communication materials included:






ALP printed presentation
ALP posters: these included all 7 ALP Code Principles
Income and work hours poster
GTS posters
GAP yearly bulletin

The support of field technicians is very important. All field technicians interviewed
declared they visited the farms at least three times per season. One fieldtechnician (20%) said he needed more time to communicate the ALP Code with
farmers as he had other tasks to perform during the farm visits. The number of22

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farmers each field technician had to visit varied among the three cooperatives,
and ranged from 12 to 81 farmers.
The table below shows the communication methods that farmers remembered
when asked how they heard about the ALP Code.7
Communication method

Farmers

Regular Visits

10 (77%)

Group meetings

4 (20%)

Poster3 (15%)Other

3 (15%)

DELTAFINA response: “DELTAFINA, in cooperation with IBERTABACO, will update and compile
new communication materials aimed at improving farmers’ understanding of the ALP Code Principles
and their responsibilities. The following communication materials will be prepared by April 2016 in
Spanish (all migrant workers employed by farmers speak fluent Spanish) and distributed to all farms
during the first field visits:










New brochure for Good Agricultural Practices in the field.”“New ALP poster with the 7 Principles that will include updated photos (based on Spanish
conditions) and a more precise translation.
Based on CU recommendations a new poster will be published in 2016 focusing on income andworking hours which will highlight minimum wages, working hours and overtime work.”“An updated leaflet will be provided during 2016 crop for distribution by the farmers to theirworkers, focusing on workers’ rights, which will include the emergency telephone number(112) which workers can call for support.”“A new brochure will be prepared for the 2016 crop containing a new list of hazardous tasks
which must never be performed by minors (no person below 18 is allowed to perform any typeof hazardous work).”“A GTS poster with information on how to prevent exposure to green tobacco sickness, how torecognize the symptoms and what workers should do if they experience GTS.
Update all the principal information and documentation edited by the ALP country team andsupervised by the Steering Committee relating to the ALP program on the website:
www.IBERTABACO.com.”

3.3.3 Understanding and perception of the ALP Program
The DELTAFINA management team generally had a good understanding of the ALP
Program and ALP Code Principles. Field technicians’ understanding of the ALP
Code is critical as they are the main point of contact with the farmers. They saw
the ALP Code as a tool to progressively eradicate child labor and to improve thequality of life of the farmers. Overall their knowledge of the seven ALP Code7

A farmer could report more than one communication method.

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Principles was good but some areas for improvement were identified. CU’s findings
are summarized below:
Child labor: All 5 field technicians interviewed knew that the minimum
working age for the tobacco sector was 16 years. Three (60%) fieldtechnicians were able to explain that children between 16 and 18 can work
but with certain restrictions. With regards to hazardous activities, all thefield technicians had a good understanding of this concept and gave
accurate examples of hazardous and non-hazardous activities.



Income and work hours: Three (60%) of the field technicians were awareof the legal monthly and daily minimum wage in accordance to theExtremadura collective bargaining agreement. The other two only knew thenational legal minimum wage. Regarding the legal maximum weekly anddaily working hours, the concept of voluntary overtime and legal rest days
were clear to all of the technicians.

Fair treatment: All field technicians understood the basic concept of thisprinciple. They knew that workers should be treated equally (nodiscrimination) and fairly (provide good working conditions / “treat them as
friends”).

Forced labor: All field technicians demonstrated they understood theconcept of this principle by stating that workers must be free to work andcannot be forced under any circumstance. They also mentioned risks
associated to maintaining original identity documents, working under debt
and end of the harvest payment.



Safe work environment: All field technicians had a good understanding of
this principle; workers should have a safe working place and take theadequate safety measures to avoid accidents. The need to use PPE for CPA
application, protective clothing for harvesting, sanitary facilities, access towater and adequate housing was clear to them.



Freedom of association: All field technicians understood the basic conceptof this principle; workers should be free to join unions or build their own
labor unions and no worker shall be excluded due to union membership.

Compliance with the law: All field technicians understood this principle as arequirement for the farmer to comply with all the country’s laws regarding
workers employment but none explicitly mentioned that employment
conditions and legal rights should be communicated to the worker at the
moment of the contract.

3.4 Building Farm Profiles for all contracted farms
As a requirement of Phase 1, DELTAFINA employees were expected to build FarmProfiles for every farm. PMI developed a global template to support the collectionof information on socio-economic indicators including: farm size, number ofworkers, age and number of children in the farmer’s family, employment status

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Control Union Certifications(for example part time, full time, migrants), the pay period for workers and living
conditions.
3.4.1 Data gathering system for Farm Profiles
At the beginning of Phase 1, DELTAFINA developed a written procedure on
gathering the information for the Farm Profiles. Part of the information was
gathered at the beginning of the season when the cooperative received from thefarmer the data included in the Integrated Production8 notebook.9 The rest of thedata was gathered at the farm using a shortened version of the PMI Farm Profile
global template, with both the ALP country coordinator and the field technicians
being responsible for the gathering and recording of this information.10 All thisinformation was digitally centralized, on a yearly basis, using internal software.
This data was subsequently analyzed and updated if needed. Although
improvements were required to obtain all relevant information, the fact that
DELTAFINA had developed their own procedure and systems to obtain the datafrom the farm, showed ownership of the ALP Program. Nevertheless, PMI Regionalrequested DELTAFINA to only use the PMI Farm Profile global template resulting inless ownership and a less efficient procedure.
At the time of the assessment, DELTAFINA was looking forward to theimplementation of Mobileaf, a handheld data collection tool that will be used byfield technicians to gather Farm Profile information. This was expected to reduce
the time used to gather the relevant information at each farm.
3.4.2 Accuracy of Farm Profiles
By comparing the information on the Farm Profiles with the situations observed at
the farms, CU concluded that eight (62%) of the Farm Profiles assessed were
accurate. For the remaining five Farm Profiles, one or more of the following
inaccuracies were identified:

Farm tasks: in four Farm Profiles the tasks performed by were missing.
People on the farm: one Farm Profile did not include the seasonal workers
hired by the farmer.
Tobacco area: one Farm Profile did not match the actual planted tobacco
area.

According to both the supervisors and field technicians interviewed, Farm Profiles
were completed yearly and revised at the farm during the first visit. An update
was done when relevant changes were identified on the farm when the fieldtechnicians mainly focused their attention on changes in the planted area.

8

The Integrated Production program is regulated by the Royal Decree 1201/2002 for the entire crop
production in Spain. Among other requirements, the farmer must complete an Integrated Production
notebook, in which all the crop activities are recorded.
9
Farm size and address, name and farmer ID, and type of farm.
10
Number of family members and their ages, number of workers and their ages, tasks performed byworkers and family members at the farm, and other commercial crops on the farm, origin and native
language of migrant workers.

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3.4.3 Analysis on information Farm Profiles
Based on the information obtained through the Farm Profiles, DELTAFINA
conducted quarterly and annual analyses with which to design initiatives toaddress widespread and/or systemic issues.
DELTAFINA response: “Despite the complexity of the Spanish organization (DELTAFINA,
3 Cooperatives, 1 STP Coordinator, 7 FT’s, 120 farms, 170 farmers) and the fact that all the data had to
be entered manually into the ALP database, Control Union found that all farms have their Farm Profile
sheet duly updated, although some contained incorrect information at the time of the assessment. The
form is currently paper-based and we are assessing the possibility to use a more effective electronic
tool. DELTAFINA expects to roll out the MobiLeaf handheld device to the three cooperatives during
autumn 2016. This will help improve the accuracy of the data collection and farm-by-farm monitoringprocess conducted by Field Technicians. In order to assess the accuracy of Farm Profile monitoring
data, DELTAFINA will conduct unannounced visits during the crop season.
In order to improve the farm-by-farm monitoring process, DELTAFINA will increase the number of fieldvisits by Field Technicians from three to at least six visits per farm during the crop season, with 100% of
contracted farms to be monitored on all ALP principles. During the first visit (April-May), FTs will collectcomprehensive information for the Farm Profile, as a baseline with which to measure subsequent visits.
Field technicians will update the Farm Profile data after each visit to ensure that it is precise andaccurate, and verify whether there are any issues on the farm. One specific focus of farm visits will beto draw attention to CU’s recommendations on the principles relating to income, working hours andsafe working environment.”
3.5 Prompt Actions
PMI defines a Prompt Action as:“a situation in which workers’ physical or mental well-being might be atrisk, children or a vulnerable group – pregnant women, the elderly - are indanger, or workers might not be free to leave their job.” (Source: PMI, 2011)
Another Phase 1 requirement is to identify and address Prompt Actions found at
the farms contracted to supply tobacco to DELTAFINA. Any Prompt Action should
be reported immediately to the ALP Country Team leader, who should thenprovide guidance on how to address the issue or escalate it within theorganization.
3.5.1 Prompt Action reporting mechanism
In the 2014/2015 crop season, 44 Prompt Actions were identified, all of which
related to safe work environment. All those involved in the reporting of Prompt
Actions were aware of the reporting procedure. Field technicians had written
documentation on identifying Prompt Actions and the procedures to be followed.
This documentation also included specific examples of situations at the farm thatwere considered to be Prompt Actions. The template for reporting Prompt Actions
was clear and easy to understand.

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3.5.2 Understanding Prompt Actions
All field technicians understood a Prompt Action as an activity or situation that had
to be immediately addressed, but only one of them could mention the definition
mentioned above. The other four field technicians considered a Prompt Action as
any situation not meeting the ALP Code.
3.5.3 Addressing Prompt Actions
When observing a Prompt Action situation, Field Technicians were expected to
explain the danger involved to the farmer, family members and/or workers; thencomplete the Prompt Action form and submit it to the ALP country coordinator.
The ALP country coordinator would then visit the involved farm to talk with thefarmer about the Prompt Action and find a solution to solve the situation. The fieldtechnicians followed up with the farmer, but with no specific deadline. The Prompt
Action was meant to be resolved before the next field visit. From the four Prompt
Actions verified by CU, all farmers were aware of the Prompt Action being
reported and resolved.
DELTAFINA response: “DELTAFINA will work with field technicians to improve theirunderstanding and capability to distinguish Prompt Actions from other situations not meeting the ALP
Code, through the following actions:a) Discuss the definition of Prompt Action and the reporting procedure in detail during therefresher meetings with field technicians.
b) Compile a new Prompt Action List to be distributed to field technicians during the 2016 crop
season. All relevant documents, including the brochure, and the PPE kit will be distributed assoon as DELTAFINA signs the contract with IBERTABACO in April 2016.
c) Before the 2016 season starts in April, additional refresher training will be given to the FTs
about Prompt Actions, which will include several examples of different situations on the farmthat should be considered Prompt Action or situations not meeting the ALP Code Standards.
The refresher training will also include the analysis of Prompt Actions reported in 2015 to help
FTs differentiate issues on the farm and how to record them properly.
In case a FT from any of the cooperatives observes any Prompt Action situation on a farm, he isrequired to agree with the farmer on an improvement plan to resolve the situation, as well as to recordand report the situation immediately. After each Prompt Action issue, the field technician will conduct
an unannounced visit to verify whether the issue is still happening and to follow-up on the
improvement plan agreed with the farmer.
In the event that a farmer does not satisfactorily resolve a Prompt Action issue, consideration will begiven as to what further action should be taken in response thereto. Any such, consideration will needto take account of all the surrounding circumstances.”

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4. Assessment of the current status of Phase 2 of
the ALP Program

THIRD PARTY ASSESSMENT
DELTAFINA

Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

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This chapter describes DELTAFINA’s implementation of Phase 2 of the ALP
Program. As DELTAFINA had only recently initiated Phase 2, certain requirements
were not completed. These included improvement plans for every farm, regularassessments and plans for addressing widespread issues as these were still in thepilot phase.
When PMI makes the decision that a country is ready, the relevant organizations
are introduced to Phase 2. This does not necessarily mean that all Phase 1
requirements have been achieved.
As part of this PMI provides training to the ALP Country Team, which includes:
1) Preparation of the ALP Country Team to train staff to systematicallymonitor labor practices on farms;2) ALP status update;3) Introduction to Phase 2;
4) General approach for monitoring before, during and after a farm visit; and
5) Next steps and planning for the upcoming season.
4.1 Monitoring of labor practices farm by farm
In Phase 2, PMI expects that monitoring of labor practices on individual farms has
started and that at least two ALP Code Principles have been selected to focus
efforts in year one. Afterwards, a review will take place and PMI and the leaf
tobacco supplier will analyse if the implementation system is ready for monitoringall ALP Code Principles and Measurable Standards.
4.1.1 Selection of issues
DELTAFINA selected several issues that were considered widespread and/or
systemic based on: Farm Profile analysis, Prompt Actions and personnel
experience in the field. In the tobacco sector of this region, the most widespread
issues were usage of PPE/protective clothing and untidy conditions at the farm.
4.1.2 Mechanism for monitoring
Despite the abovementioned selection, DELTAFINA started in 2014 with
monitoring all ALP Code Principles in all the contracted farms. As with theprocedure for Farm Profiles, DELTAFINA had developed a monitoring form tosimplify the monitoring at the farm, but was requested by PMI Regional to use the
PMI global template for monitoring, resulting in additional administration for fieldtechnicians.
At the time of the assessment the 2015 monitoring was still ongoing. Every time
the ALP country coordinator and the field technicians visited a farm all sevenprinciples were monitored and a paper monitoring sheet was filled in. At the timeof the assessment, the company was developing a digital monitoring system
which will also be part of the Mobileaf project.
Of the total 13 farms assessed by CU, seven (54% of the assessed farms) werealready monitored in 2015.

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DELTAFINA response: “DELTAFINA moved to Phase 2 of the implementation of the ALP Programin 2014, following a joint evaluation of its efforts with Philip Morris International. The second phase of
the ALP Program required DELTAFINA to put in place farm-by-farm monitoring conducted throughseveral visits (i) by field technicians to all contracted farms; and (ii) visits supervised by the program
coordinator. FT’s refresher sessions will be organized each year on a monthly base, focusing onprioritized principles. At the end of refresher sessions, the effectiveness of the training will be
evaluated by conducting tests for the FT’s.
Once the contracts have been signed with farmers, ALP Program team meetings will be held with fieldtechnicians on a monthly basis during the crop year to enhance and improve the knowledge of the ALP
Code and to refresh the weakest aspects such as: Prompt Action understandings/knowledge and theescalation process; hazardous tasks, and local legislation regarding labor rights and employment
conditions.”
4.2 Addressing widespread and/or systemic issues
Phase 2 requires the investigation of the root causes of various issues identified
during the implementation of the ALP Program. The diverse issues were both
identified and addressed under the ALP Program with two distinct but
complementary approaches. First, initiatives were implemented to mitigate
specific risks and improve the overall rural living conditions of contracted farms.
Second, other initiatives involving the relevant stakeholders, including projects
sponsored by the PMI Contributions department, addressed those problems
identified at the community level.
4.2.1 Investigation of root causes
Based on analyses conducted on Farm Profiles, meetings with the farmers,
irregularities reported during farm visits, Prompt Action analysis, a risk
assessment performed in 2014, DELTAFINA identified different root causes for the
aforementioned widespread and/or systemic issue related to safe work
environment. Many farmers and workers were unaware of the measures thatshould be taken when applying CPA, or harvesting, or managing tobacco. In manycases the farmers knew that they had to wear PPE, but not what the complete
equipment consisted of.
4.2.2 Initiatives to address widespread and/or systemic issues
At the time of the assessment, DELTAFINA was distributing a complete set of PPE
which included: CPA application mask, breathing mask with filters, hooded overall,
goggles and latex-neoprene gloves.
Participation rates and additional insights regarding this initiative can be found inchapter 5.5.2.
4.3 Support mechanism
Support mechanisms are programs that seek to facilitate workers in accessing
information and getting support in difficult situations, and also support workers
and farmers in mediating disputes.

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Although DELTAFINA did not promote a support mechanism among farmers andworkers, CU assessed if the workers and farmers had knowledge of where they
could get legal information when mediating disputes.
When farmers were asked about the sources from which they could obtain such
legal information, eight of them (62%) gave at least one example. The farmers’
responses are summarised below:
Information source

Farmers

Administration office

4 (50%)Union

3 (38%)

Government

1 (13%)

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5. Farm level assessment of ALP Code standards

THIRD PARTY ASSESSMENT
DELTAFINA
Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

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Chapter 5 summarizes the field assessment of the current status of the ALP
implementation. At the time of the assessment, DELTAFINA was in the third yearof implementing Phase 1 and the first year of implementing Phase 2 of the ALP
Program. It was expected to engage directly with farmers to address situations
not meeting the ALP Code standards. As DELTAFINA had just initiated Phase 2,
this farm assessment should be viewed as a baseline to support the further
implementation of Phase 2.
Before presenting the findings, it is important to clarify the structure of the ALP
Code as this determines CU’s analysis of farmers´ practices. The ALP Code has
seven ALP Code Principles, each with several Measurable Standards. ALP CodePrinciples are short statements designed to guide farmers on specific practices
resulting in safe and fair working conditions.
A Measurable Standard defines good practice and over time can be objectively
monitored to determine whether, and to what extent, the labor conditions andpractices on a tobacco farm are in line with each ALP Code Principle. Each chapter
covers one of the seven ALP Code Principles and CU’s findings. Risks, situations
that may lead to problems in the future or about which a conclusion cannot bereached due to lack of evidence, are also discussed.
5.1 ALP Code Principle 1: Child labor
Background
Minimum age regulations: According to the
Spanish Statute of Workers (Estatuto de lostrabajadores) the legal minimum working age in
Spain is 16 years old.

ALP Code Principle 1
Child labor´There shall be no child
It is compulsory to attend school from 6 to 16,
labor.´
although children have the right to attend until
they are 18 years old. According to the Statute ofWorkers (Estatuto de los trabajadores), children
between 16 and 18 years of age will not perform"those activities or jobs which the Government, atthe proposal of the Ministry of Labour and Social Security, in consultation with themost representative trade unions are consider to be unhealthy, arduous, harmful
or dangerous both for their health and for their professional and personal
development. In addition, the Decree from 26th of July 1957 establishes theactivities that are banned for children between 16 and 18 years old.
ALP Code versus Spanish law: Regarding the minimum working age, the Spanish
law prevails as it sets a higher minimum age than the ALP Code (15 years old).
Child labor: Overall findings and challenges
5.1.1 Prevalence of children working
CU found no evidence of farmers employing children below 16 years old, norchildren under 13 working on the farm, nor children from the ages of 13 to
16 years old doing work that is not considered light.

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5.1.2 Awareness of legal minimum working age
The level of awareness of the legal minimum working age among farmers andworkers was high in the assessed farms: all farmers were aware and in five farms(71%) the workers were also aware of the minimum working age.
Child labor: Risks
5.1.3 Awareness of hazardous work
The majority of the farmers (9 farms or 69%) and the workers at four farms(50%) were aware of the meaning of “hazardous activities”.
5.1.4 Age verification
All farmers verified the age of the workers at the time of contracting. In order tofully understand the contracting process, it is important to explain the importanceof the administration offices11, as they play a key role in the process of hiring
and/or registering workers. These offices provide many different services to thefarmers, including advice on legal and social laws, registering the payroll, workand residence permits, while working under a strict control of the National Labor
Ministry. By using these administration offices for hiring and managing payment
to employees, the farmers ensure compliance with the legal requirements for
employment.
5.1.5 Child supervision
In two farms (15%) the farmers declared that their children could walk around the
production areas without supervision.
Child labor: Analysis and Priorities
CU found no evidence of child labor, or children between 13 and 16 years old
carrying out hazardous activities in the assessed farms. This finding is alignedwith the fact that all the farmers demonstrated awareness of the minimum
working age and verified the age of workers at the time of contracting.
Regarding the workers’ knowledge of the minimum employment age, activities
that children between 13 and 16 years old could perform and the understanding of
farmers and workers in regards to hazardous activities, there is still room for
improvement. DELTAFINA’s challenge will be to find the best way to increase theawareness of farmers and workers.

11“Gestorias” in Spanish.

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DELTAFINA response: “DELTAFINA believes that there is still room for improvement in farmers’
and workers’ understanding in order to prevent the risk of having children below 18 years old involved
in hazardous activities. DELTAFINA will highlight this information by including an updated list ofhazardous tasks in the new 2016 brochure. This brochure will be distributed to all contract farmers
each year, with the contents being discussed and the farmer asked to sign a list confirming his receipt
of same.”

5.2 ALP Code Principle 2: Income and work hours
Background
Minimum salary regulations: According to the2013
ExtremaduraCollective
Bargaining
Agreement, the legal minimum wage forpermanent agricultural worker is € 699.08 permonth and € 37.77 per day for temporary
workers.12 Independent of the type of
employment, salaries or wages must be paid atleast on a monthly basis. Piece work is allowed,
so is payment in kind, as long as it does notexceed 30% of the total salary. End of season
payments are not allowed.
Working hours regulations: According to Article
12
from
the
ExtremaduraCollective
Bargaining:

ALP Code Principle 2
Income and Work Hours‘Income earned during apay period or growing
season shall always beenough to meet workers’
basic needs and shall be ofa sufficient level to enable
the generation of
discretionary income.
Workers shall not work
excessive or illegal work

Maximum working hours: 1,768 working
hours per year composed of 39 hours aweek, with a maximum of 9 working
hours per day. Workers must have 12hours of rest between each working day.

Regulations for children between 16 and 18 years old: It is not allowed forchildren aged between 16 and 18 to work at night,13 or to work overtime.
Furthermore, they must receive the same salary as other workers when
performing the same tasks.
Night shifts: Article 33 from the Extremadura Collective Bargaining Agreement
declares that wages for work performed between 10pm and 6am shall pay theemployee an extra 25%. No employee can do night shifts for more than 2 weeks
in a row (except in cases where the employer offers this to employees on a
voluntary basis). Personnel contracted for night shifts will receive 15% bonus asrecompense.
12

Temporary workers are those that provide their services for a certain number of days per year, permonth or per week, or for a specified number of hours, respectively, below two-thirds of thoseconsidered normal in the activity in question in the same period of time and work up to 6.5 hours perday
13Overnight work is considered to be that carried out between 10 pm and 6 am.

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Overtime hour’s regulations:
Article 38 from the Extremadura Collective
Bargaining Agreement recommends that given the current unemployment
situation, and in order to foster a supportive social policy promoting job creation,
overtime hours be suspended. In any case, overtime hours will be paid with asurcharge of 75% on the first two hours, and 100% extra for the following hours.
Hours worked on Sundays and public holidays will be paid at 100% on top of theregular salary. Also, the realization of these hours will be communicated to thelabor authority and entered into the payroll. Furthermore, according to theWorkers Statute, a limit of 80 overtime hours will be set per year.
Benefits regulations: In accordance with the Extremadura Collective Bargaining
Agreement worker benefits include a holiday period of at least 30 calendar days,
assistance for loss of family members, help in case of disease or accident, periodic
salary revisions, specific break periods per week, maternity and paternity leave,transport allowance when applicable, housing where applicable, reduction ofworking hours for parents, special holidays after marriage, social security, publichealth care and pensions.
Income and work hours: Overall findings and challenges
5.2.1 Minimum salary and payment schedule
All farmers were paid at least the minimum wage as per the collective bargaining
agreement and in accordance with the local legal pay schedule. In one farm(14%) the worker was not aware of the payment schedules. The table below sets
out the payment schedule for workers on the assessed farms.
Payment ScheduleDaily
6 farmers

Weekly1 farmerMonthly
4 farmers

Regarding the type of employment: six farmers hiring workers (54%) declaredthat they pay on a daily basis, one (9%) declare he pay on a weekly basis andfour (36%) declared they pay on a monthly basis. Additionally, six farmers (54%)
explained they pay per hour, three (27%) per day and six (54%) pay for piece
work (loading curing barns and driving harvesting machines). The table below sets
out the respective rates of pay.
Payment Rates

Per Hour€ 6.60€ 6.50€ 6.10€ 6.00€ 6.00€ 5.87Daily€ 40€ 37.77€ 37.77

Piece Work€ 70 (per harvested plot)14€ 70 (per harvested plot)€ 65 (per harvested plot)€ 37 (per loaded barn) 15€ 37 (per loaded barn)€ 36 (per loaded barn)

14

Wages were paid on a daily basis. All drivers of harvesting machines declared that it took between 7
and 8 hours to harvest a tobacco field.
15
Four to five hours are needed to load a curing barn.

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At one farm (8%) the farmer had a sharecropping arrangement in which thesharecropper provided manpower, while the farmer provided the fertilizer, theCPAs and the curing barns. At the end of the season both parties would share theproduction income based on a percentage arranged beforehand.
5.2.2 Regular and overtime hours
In one farm (9%) the worker declared that he worked more than 39 hours per
week. In the rest of the farms, the working hours were in compliance withthe law.
Regarding overtime hours, CU found no evidence of involuntary working hours.
However, in eight farms (73%) the farmers were not aware of the legal
requirements regarding overtime pay. Also, none of the workers were aware of
the legal overtime pay rate.
5.2.3 Legal benefits
In all the farms, workers were provided with the benefits, leave and holidays towhich they were entitled by law. However, five interviewed farmers (45%) andworkers at three farms (30%), were not aware of the benefits, leave and holidays
to which workers were entitled by law. Farmers used administration offices toensure that all workers received the benefits, leave and holidays to which they
were entitled by law.
5.2.4 Awareness of legal minimum wage
All assessed farmers were aware of the legal minimum wage, but in five farms(50%) the workers were not aware of the legal minimum salary wage.
5.2.5 Awareness of legal working hours
While all farmers were aware of the maximum legal working hours, on five farms(50%) the workers were not.
Income and work hours: Risks
5.2.6 Record keeping and pay slips
All farmers in the assessed region kept records of working hours, and days/tasks
completed, and provided pay slips to the workers.
5.2.7 Exchange of labor
The practice of exchanging labor normally involved two or more parties thatexchanged the same type of work and/or for the same amount of time. Twointerviewed farmers (15%) declared that they exchanged labor during theharvesting season. In both cases it was a group of farmers buying a harvester andsharing the maintenance costs. Another farmer (8%) stated that he exchangedlabor for almost every stage of production with his brother.

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Income and work hours: Analysis and Priorities
The recommendation of the Extremadura Collective Bargaining Agreement to hire
more workers instead of working more hours seems to have had an effect on thefarms as no evidence was found of excessive working hours. While all farmers
were aware of the legal working hours, DELTAFINA should increase the level ofawareness on this topic among workers. Additionally, workers need more
information on the legal overtime rate and the legal minimum wage.
DELTAFINA response: “In Spain, and in particular in the region of Extremadura, the minimum
wage is set in a collective bargaining process that has a three-year validity. The previous agreement
was in force between 2013 and 2015. In 2016, a new agreement will be negotiated for the following
three years. DELTAFINA will follow this process closely in order to communicate the new minimum
wage to both field technicians and farmers in a timely manner. Once the new agreement is in place wewill modify our leaflets and communicate the details to the farmers and workers.”“…DELTAFINA will inform all farmers and distribute brochures and posters (listing the applicablerequirements) to clarify and reinforce these key points about the obligations of farmers towards theirworkers (e.g. basic conditions of employment, minimum wage, working hours, legal requirements for
extra hours, remuneration for paid holiday and overtime). In an effort to provide training to allcontracted farmers during crop 2016, two training meetings with farmers are planned for February andJune/July, to be conducted by the Country ALP committee. In order to refresh their knowledge,
DELTAFINA/IBERTABACO will organize meetings and face to face discussions with FTs during theseason. Four specific leaflets will be available before transplanting and delivered by the Cooperatives’
FTs to farmers. The Cooperatives will ask farmers to distribute the leaflets to their workers. DELTAFINA
will conduct unannounced visits throughout the crop season to check whether the information isreaching the workers.”

5.3 ALP Code Principle 3: Fair treatment
Background
Regulations: The 2007 Spanish Act on Equal
Opportunities between Men and WomenALP Code Principle 3
establishes a full legal framework to prevent
any type of discrimination and/or harassment
Fair treatment
at work. Companies are required to approveand implement equal opportunities programs,‘Farmers shall ensure fairin order to ensure an appropriate working
treatment of workers. Thereenvironment free from discrimination and/or
shall be no harassment,harassment. Employees may claim damages indiscrimination, physical or
court for cases of discrimination and/or
mental punishment, or any
harassment.
Additionally,anyphysicalother forms of abuse.’aggression is considered a criminal offence, as
per the Spanish Criminal Code, with severe
penalties. The law prohibits recruitment fees
being paid by candidates or employees. Third
party recruiters for temporary employees have specific regulations for their role.

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Fair treatment: Overall findings and challenges
5.3.1 Fair treatment
No evidence was found of sexual, verbal or physical abuse or harassment.
5.3.2 Communication with workers
No evidence was found of workers not being able to communicate with farmers, orsharecroppers, to file potential grievances. Nevertheless, some farmers declaredthat they hired foreign workers (who barely speak the farmer’s language) to growand harvest other crops like pepper, implying there is a potential risk of workers
not being able to file potential grievances in the tobacco production.
Fair treatment: Analysis and Priorities
Despite the fact that no evidence was found of unfair treatment, it is crucial that
farmers can communicate with their workers. This proved to be a challenge as asignificant percentage of the assessed workers were not native Spanish speakers(see 2.6). Therefore, it is important to ensure assistance is provided to farmers
who contract foreign workers to ensure they can communicate with each other.
DELTAFINA response: “DELTAFINA recognizes the importance of conveying to farmers the needto communicate to their workers about legal labour rights and employment conditions. If there are any
language or rights problems, several professionals are available in the tobacco growing area from thenational and regional unions (UGT) and other governmental offices (CEPAMIN and ADHEX) who canadvise workers in their native language on the relevant legislation and information regarding theirrights. In Spain, before they find a legal job, immigrants receive a salary (an allowance?) to participate
in a language course paid for by the governmental authority. DELTAFINA and IBERTABACO eachmonitor compliance with the local and national laws and have not observed any violations in recent
years.
DELTAFINA will continue engaging with the Workers’ Union to communicate ALP. As of 2016,
DELTAFINA will encourage the Workers Union to be more involved in sharing the new information on
ALP and issuing bulletins regarding workers’ rights to be distributed with communication materials anddiscussed during visits and meetings at the farmer and worker level.
Leaflets in Spanish will be used to inform workers about their rights as well the resources available incase they require further information about their labor rights, need additional support, or wish to raisea concern, by either (i) submitting a claim/suggestion via the IBERTABACO web page, or (ii) contacting
the legal services of the Worker Unions. These options are available to anyone who needs to file acomplaint or needs legal clarification. This support is also provided by the local “Gestoria” office for
employment.”

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5.4 ALP Code Principle 4: Forced labor
ALP Code Principle 4

Background
Regulations: According to Articles 311, 312
and 313 from the Spanish Penal Code forced,
compulsory or prison labor are prohibited.
Forced labor: Overall findings andchallenges

Forced labor‘All farm labor must be
voluntary. There shall be noforced labor.’

5.4.1 No evidence of workers unable to leave their job
All of the workers interviewed stated they were free to leave their employment
with reasonable notice. In addition, all workers declared that they had not beenrequired to make any financial deposits or relinquish their original identity card or
travel documents. Also, no evidence was found of payments withheld beyond legal
or agreed payment conditions.
Forced labor: Risks
5.4.2 Financial problems among farmers
Two farmers (25%) declared that they have had occasional financial problems at
the end of the harvest, leading to an inability to pay their workers at the timeagreed at the beginning of the contract. However, in both cases the payment
schedule was still within the legal maximum period according to the local
legislation.
5.4.3 Resignation procedure
In five farms (71%), the workers were unaware of the resignation procedure andnotice period they needed to give the farmer before leaving.
Forced labor: Analysis and Priorities
The findings indicate that the risk of forced labor is very low in this market.
However, further investigation of the root causes of financial instability among
farmers and potential need for assistance is required as this has resulted inseveral cases of workers not being paid within the agreed timeframe.
DELTAFINA response: “In order to mitigate the risks of forced labor DELTAFINA will: Continue monitoring farmers’ financial conditions to further assess their ability to pay
workers. It should be noted that all the farmers who are members of the Cooperative use its
financial services and so the payment of the workers is automatic with the service of theemployment office “Gestoria” used by all the farmers.
 Provide leaflets in Spanish to all the farmers (referred to in section 3 above) with therequirement that these be distributed to their workers, who must sign an acknowledgement ofreceipt to ensure that workers are made aware of their rights.
 ALP country team to conduct 20 to 25 unannounced visits to verify that leaflets have been
distributed to the workers.”

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5.5 ALP Code Principle 5: Safe work environment
Background
Regulations: As per Article 41 from theExtremaduraCollective
Bargaining
Agreement, if provided, housing should
comply with decent living conditions, both for
the worker and for his family, if applicable.
Article 45 from Extremadura Collective
Bargaining
Agreement
statesthat theemployer, on a yearly basis, must provide
their employees with: a raincoat, one pair ofwaterproof boots, one pair of working boots
and an overall. Article 47 from Extremadura

ALP Code Principle 5
Safe work environment‘Farmers shall provide a safe
work environment to prevent
accidents and injury and tominimize health risks.
Accommodation, where
provided, shall be clean, safe
and meet the basic needs ofthe workers.’

Collective Bargaining Agreement also includes
the farmers’ obligation to provide the workers
a safe working environment, including:machinery in good shape, safe working areas
and washing facilities. Regarding empty CPA
containers, the Royal Decree 41 establishes
the obligation for the farmer to: triple rinse containers, pouring the resulting
water into a specific tank prepared for that and to store the containers in a closed
bag for subsequent transport to a collection point. Regarding CPA application, allpersonnel in charge of this must have the corresponding application permit, issued
by the Ministry of Agriculture, Food and Environment.
Safe work environment: Overall findings and challenges
5.5.1 Training and awareness of Green Tobacco Sickness (GTS)
At seven farms (64%), persons who handled green tobacco declared that they hadreceived training on the avoidance of GTS. However, when asked to describe thesymptoms of GTS, the workers at four farms (57%) were unaware and associatedthose symptoms with other causes. In the case of the interviewed farmers, all
could relate the symptoms to GTS. While on eight of the farms visited (62%) the
harvest was mechanized, for the rest those charged with handling green tobaccoused one or more types of protective clothing (see table below).

16

Equipment used by people harvesting
tobacco at the farm

Farms

Full equipment16

3 (60%)Long pants + boots

2 (40%)

Full equipment: gloves, long pants and long sleeves, boots and raingear.

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DELTAFINA response: “DELTAFINA with IBERTABACO will distribute the following materials after
contracting in April 2016:


PPE kit to 100% of the farmers and in some cases more than one per farm
GTS poster in Spanish to 100% of the farmers

During the field visits conducted by the FTs and the ALP country team we will monitor the level ofunderstanding of the farmers and workers about the GTS. During the face to face meeting with thefarmer, the ALP Country team will also train the farmer on GTS.”

5.5.2 CPA handling and training
In all the farms visited the persons responsible for applying CPA were trained.
On 11 farms (85%) there were persons handling CPAs that declared that they had
never received the training in CPA handling.
Equipment
usedbypeopleapplying CPA at the farm

Farms17

Full equipment18

10 (77%)Overall + boots+ gloves

1 (7%)

Mask + boots + gloves

1 (7%)

Mask + gloves

1 (7%)

Initiative to address safe work environment for application of CPADistribution of CPA application kit: Since the beginning of the ALP
implementation, DELTAFINA’s target was to distribute a CPA application kit
to 100% of the contracted farmers. All visited farmers declared that they
had received the CPA application kit from DELTAFINA and 10 of them(83%) considered this initiative useful for improving the safe work
environment at the farm.
Re-entry period: At the beginning of 2015, the company distributed tofarmers a list with the names, active ingredients and re-entry periods forthe most common CPAs used for tobacco farming in Spain.

DELTAFINA response:



17
18

“To organize training courses for those workers who do not already have the basic license to
apply CPAs.
IBERTABACO will request their members to only hire people who have a license.

Percentages indicate the type of protective equipment used in the assessed farms.
Full equipment includes: overall or long sleeves and long pants, boots, gloves and mask.

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To put in place a prompt action procedure for those farms where workers were foundapplying CPAs without a license.

In addition, DELTAFINA and IBERTABACO will check the correct chemical and protective equipment
usage at farm level through unannounced visits.”“At the beginning of 2015, DELTAFINA distributed to farmers a list with the names of active
ingredients and re-entry periods for the most common CPAs used for tobacco farming in Spain. In April
2016, after signing the contracts, DELTAFINA will distribute to all farmers a brochure with the new
approved CPA list and corresponding re-entry periods as well as the correct CPA storage procedure. All
farmers will be informed about the importance of respecting the re-entry period through refresher
training sessions.
A new poster will be designed with danger signs as a warning after phytosanitary treatments, toensure that the re-entry period is respected on the farm. These materials will be distributed at the endof the transplanting period to all farmers, between May and June 2016.
During the farmers’ training, DELTAFINA and IBERTABACO will focus on this finding and distribute the
new warning poster to be placed in the field after treatment.”“FTs will continue to verify records and support farmers to keep appropriate records for each CPA
application. Such records must, in any event, be kept in order for farmers to qualify for an agriculturalenvironment subsidy.”

5.5.3 Clean drinking and washing water
Washing and drinking water was available in working areas at 10 farms (77%).
For the other farms there was a lack of places or access to drinking and/or
washing water.
5.5.4 Re-entry period
Nine interviewed farmers (75%) did not take any precautions to ensure that there-entry period after CPA application was respected.
5.5.5 CPA storage and final disposal
Three farmers (23%) did not have a locked and closed CPA storage, but all of the
farmers discarded their empty CPA containers correctly.
5.5.6 Safe and sanitary environment
In four farms (31%), the farmers did not provide a safe and sanitary environment
due to:ooooLack of washing facilities in the working areas
CPA being stored in incorrect conditions
PPE & raincoat stored next to the CPAs
CPA and mineral oil spills were observed in several places around thework environment

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Safe work environment: Risks
5.5.7 General safety measures
To ensure a safe and sanitary work environment for both family members andworkers, it is important that farmers are aware of the general safety hazards at
the farm and should take measures to prevent accidents, injury and exposure to
health risks.
First aid kits available to workers were found in 11 farms (85%); all those working
at the assessed farms received first aid training.
In four farms (57%) the workers were unaware of the safety hazards on the farm.
When asked about recording the application of CPAs, three farmers (25%) said
that they did not keep such records.
On all the farms transportation was available in case of an emergency, but on one
farm (14%) a worker claimed that he did not know what to do if such an
emergency occurred.
Safe work environment: Analysis and Priorities
DELTAFINA prioritized this ALP Code Principle in its ALP communications,
initiatives and training with the farmers and field technicians. These efforts werereflected in the field as the majority of farmers and workers used full protective
equipment, both for harvesting and applying CPA. However, lack of awareness on
GTS among workers, not respecting re-entry times and insufficient training for
persons handling CPA still pose safety risks on the farms. The fact thatmechanization reduces the risks of GTS is positive, but workers should still be
informed about its existence and the means to avoid GTS. Therefore, additional
efforts are required from DELTAFINA to further improve farm safety.
DELTAFINA response: “DELTAFINA will increase the number of farm visits conducted by the FTfrom three to six. Safety on farms will be a priority area of attention for FTs.
After the remarks on general safety reported by Control Union, we will raise awareness so it translates
into daily practice. To do this DELTAFINA will train its field technicians so they build their own skills andcapabilities to promote the required change of behavior.
In addition, user friendly brochures will be distributed to farmers and workers which integrate theessential safety requirements established by law and PMI’s ALP Code Standards.”

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5.6 ALP Code Principle 6: Freedom of association
Background
Regulations: The Spanish Constitution recognizes
the right of workers to associate, to join unions
and to go on strike.
Freedomofassociation:
findings and challenges

Overall

5.6.1 Workers´ right to freedom of association

ALP Code Principle 6
Freedom of association‘Farmers shall recognize
and respect workers’ rights
to freedom of associationand to bargain collectively.’

No evidence was found of farmers disrespecting
workers´ right to freedom of association, or tojoin/form labor unions, or of worker representatives being discriminated against in
any of the assessed farms.
Freedom of association: Risks
5.6.2 Awareness of freedom of association
One farmer (10%) and two workers (33%) were not aware of the workers’ right tofreedom of association. The workers, who were not aware of this right, were
migrant laborers who worked on the farm for up to three months during the
tobacco harvest. Depending on their needs they declared that they stay in Spainfor a few more months to work on other farms growing peppers before returning
home.
Three farmers (33%) and two workers (33%) were not aware of the labor unions
present in the area. One of those farmers hired migrant workers and one of thetwo workers was a migrant worker.
In one assessed farm (7%), the workers were actively participating in labor
unions.
Freedom of association: Analysis and Priorities
Although no evidence was found of farmers disrespecting the workers’ right tofreedom of association, a risk exists where workers and farmers were unaware ofthis right and/or the active labor unions operating in the area. The risk is greaterfor migrant workers as they could be more vulnerable to exploitation if not
informed of their worker rights.
DELTAFINA has not prioritized this principle although it clearly requires additional
attention to ensure that all workers are informed and aware of their right tofreedom of association and the labor unions active in the region.
DELTAFINA response: “DELTAFINA will continue to communicate with farmers on this topic toinform them of their obligations and responsibilities as employers, as well as the need to inform theworkers of their rights, including those related to the freedom of association.”

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5.7 ALP Code Principle 7: Compliance with the law
Background
Regulations: In accordance with the Article 21
from the Extremadura Collective Bargaining
Agreement employment agreements exceeding
one month duration must be in writing.
Compliance with the law: Overallfindings and challenges

ALP Code Principle 7
Compliance with the law‘Farmers shall comply withall laws of their country
relating to employment.’

5.7.1 Information on legal rights
In six farms (55%), the workers were not fully informed about their legal rights
and employment conditions. These farmers only generally informed them about
their salary and tasks to be performed.
5.7.2 Employment contracts
In all the assessed farms the terms and conditions of the employment agreement
were aligned with the country’s law. All farmers had entered into a written
employment contract with their workers.
Compliance with the law: Analysis and Priorities
Using the local administration offices to manage all employment aspects at thefarm is an effective way to ensure that employment agreements and conditions
comply with the law. However, the fact that none of the farmers properly
informed their workers of their legal rights and employment conditions indicatedthat there is a need for additional support from DELTAFINA in this respect.
DELTAFINA response: “In the farmer refresher meetings between DELTAFINA, IBERTABACO andthe farmers, which will be held twice a year (at the beginning and during the season) we will stress theimportance of compliance with the law. Together with Gestoria, DELTAFINA and IBERTABACO areaware of the importance to combine these ALP messages.
DELTAFINA with IBERTABACO plan to produce a new poster/leaflet to be displayed on all farms. This
will set out workers’ rights, translated in their native language if deemed necessary. If there arelanguage problems, the workers’ union will provide an office to help workers improve theirunderstanding. The 20 to 25 unannounced visit conducted by the ALP country team will be used tocheck if farmers have distributed the leaflets to their workers.”

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6. Concluding remarks

THIRD PARTY ASSESSMENT
DELTAFINA

Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

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Since the initial implementation of the ALP Program in 2011 up to the time of thisassessment in September 2015, DELTAFINA has made positive progress in theimplementation of the ALP Code. A permanent position was created within thecompany in order to follow up on the implementation of the ALP Program. As to
the rest of the team, all relevant personnel were trained and it is safe to say that
employees from different levels of the organization were engaged with theprogram. Cooperative Managing Directors and field technicians were regularly
updated and trained, and farmers received frequent messages on ALP.
DELTAFINA implemented several strategies to obtain as much information as
possible from its network of farmers. Farm Profiles were completed and analysed
to identify the main issues so they could investigate root causes. The ALP
coordinator accompanied the field technicians when visiting the farmers in orderto get a better insight of the situation at the farms. Additionally this external
assessment was undertaken which can be used as an important tool whenevaluating producers, the total workforce and the overall ALP implementation.
Concerning Phase 2, the company started working on the implementation of
initiatives to tackle the issue regarding safe working conditions (an issue that was
identified during the implementation of Phase 1) and income and work hours (anissue identified after the last PMI Regional visit to the farms), as well as on
constant monitoring of the seven ALP Code Principles.
However, some challenges still remain. Firstly, it is necessary to continue working
and training the team to ensure that all relevant parties are engaged andcommitted to the program. Secondly, it should not be taken for granted that thelaw is controlling all aspects of the ALP Program; additional information forworkers on legal rights is required, especially since a significant percentage of theworkers are not Spanish and are not fully informed about the local law. Thirdly, it
is necessary to continue working on the principles that have been identified as
needing improvement in this external assessment by CU (e.g. overtime hours,
legal aspects when hiring workers, etc.). Fourthly, one or more support
mechanisms should be identified and promoted to ensure that workers can reportpotential problems. Fifthly, the procedures for obtaining information for FarmProfiles and monitoring labor practices could be more efficiently organized toreduce the administrative burden of field technicians. Finally, efforts tocommunicate the ALP Code Principles to workers should be more focused andtranslated in the workers’ native language to ensure a full understanding.

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Appendices

THIRD PARTY ASSESSMENT
DELTAFINA

Extremadura Region, Spain
AGRICULTURAL LABOR PRACTICES PROGRAM

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Appendix 1. DELTAFINA response and ALP Program
action plan
DELTAFINA welcomes Control Union’s (CU) report following the evaluation of theimplementation of the Agricultural Labor Practices (ALP) Program and theassessment of the working conditions in tobacco farms in relation to the ALP CodePrinciples and Measurable Standards.
Although encouraged by CU’s acknowledgement of positive progress in theimplementation of the ALP Program, DELTAFINA is mindful of the fact that morework needs to be done and sees the external assessment conducted by CU as anopportunity to strengthen its efforts to achieve safe and fair working conditions in
all contracted farms. The following action plan seeks to provide detailed insight
into the initiatives which DELTAFINA will put in place to further enhance its
capability to deal with the identified issues and address the areas in need of
improvement.
DELTAFINA has a new Sustainable Tobacco Program (STP) Coordinator for the
execution, implementation and follow-up of the new STP program and who is
responsible for the different aspects of STP, including the People Pillar (ALP). Key
activities include training of trainers, training of farmers, collecting and analyzing
data and overseeing the implementation of the ALP Program.
IMPLEMENTATION OF THE ALP PROGRAM
The Contracting structure for tobacco farmers in Spain is multi-layered andtherefore the effective implementation of the ALP Program requires commitment
at all levels of the supply chain. DELTAFINA at the top of this structure, together
with the second tier cooperative “IBERTABACO” and first tier cooperatives“Tabacoex”, “Unagri MD” and “Coolosar”, shall lead this process, with the
involvement of technicians from the first tier cooperatives and coordinators fromIBERTABACO. The strong relationship and commitment of DELTAFINA andIBERTABACO will ensure the successful implementation of the STP.
DELTAFINA and IBERTABACO are planning to organize different group meetings
with the farmers at the different crop stages of the season. The first meeting will
be held just before signing the contracts for the new crop (2016) to be sure that
all farmers are committed to STP requirements. The first scheduled meeting will
be in February 2016, and DELTAFINA will explain to all of its contracted farmers
the commitments for the coming crop (2016) in terms ofthe mandatory
agronomic programs under ALP and STP. At this point the farmers can decide
whether to sign with DELTAFINA or another supplier.
STAFF AWARENESS AND ENGAGEMENT
CU acknowledged a good level of awareness and engagement from DELTAFINA’s
ALP Steering Committee and Country Team members towards the ALP program.
CU also highlighted the proper functioning of the information flow and goodtraining of all the staff. However, CU identified areas for improvement in Field
Technicians’ knowledge of some of the ALP Code principles, particularly “income
and work hours” and “compliance with the law”.
In order to address these issues, DELTAFINA will hold several meetings at
different levels. The first will be in February then one more after the transplanting
in June - July with the participation of:
1. DELTAFINA HQ and IBERTABACO: in order to manage and analyze thecurrent situation and establish an intensive training program for all STP
participants.

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2. STP Country Team: in order to analyze each cooperative’s specificstructural and operational circumstances and how they impact theimplementation of ALP. In particular, all management and participants
to understand the ALP program and the relationship and distinction
where applicable, from relevant laws.
3. STP Country Team: in order to refresh FT’s knowledge based on CU’sfindings.
4. Farmers: with the target to meet 100 % of them, provide training torefresh their knowledge and understanding through meetings held twicea year and face to face discussions with FTs during the season. All the
meetings will be held in the headquarters of each cooperative.
One meeting will be held before the crop season (February 2016) and at least one
other meeting will be held during the growing phase (June 2016). These meetings
will be attended by DELTAFINA HQ personnel, the STP country team and all the
farmers. The refresher meetings within the Country STP team will take place on amonthly basis, with particular emphasis on the gaps related to the Prompt Action
issues, improving their knowledge about the topic and identifying the main areasof concern through the risk assessment.
On a quarterly basis, the Steering committee and the Country STP Team will holdmeetings to strengthen the commitment towards the ALP program, clarifying thedifferent tasks (providing guidance on each of the ALP Code principles andmeasurable standards) and describing the different responsibilities within the local
team.
a) COMMITMENT OF COOPERATIVES’S FIELD TECHNICIANS TO ALPPROGRAMDELTAFINA moved to Phase 2 of the implementation of the ALP Program in 2014,
following a joint evaluation of its efforts with Philip Morris International. The
second phase of the ALP Program required DELTAFINA to put in place farm-byfarm monitoring conducted through several visits (i) by field technicians to allcontracted farms; and (ii) visits supervised by the program coordinator. FT’s
refresher sessions will be organized each year on a monthly base, focusing onprioritized principles. At the end of refresher sessions, the effectiveness of the
training will be evaluated by conducting tests for the FT’s.
Once the contracts have been signed with farmers, ALP Program team meetings
will be held with field technicians on a monthly basis during the crop year toenhance and improve the knowledge of the ALP Code and to refresh the weakest
aspects such as: Prompt Action understandings/knowledge and the escalation
process; hazardous tasks, and local legislation regarding labor rights andemployment conditions.
b) COMMUNICATION WITH FARMERSDELTAFINA is pleased with the positive results reflected in CU’s assessment report
regarding both farmers’ awareness of the ALP Code (85%) and theirunderstanding of its importance (82%) to improve working conditions on theirfarms. Together with the farmers that emphasize their good relationship with fieldtechnicians (98%), we believe that these results are encouraging and a good
indicator of the open communication on ALP.
However, CU notes that there is still room for improvement in terms of theeffectiveness of the communication materials. DELTAFINA, in cooperation withIBERTABACO, will update and compile new communication materials aimed at
improving farmers’ understanding of the ALP Code Principles and their
responsibilities. The following communication materials will be prepared by

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April 2016 in Spanish (all migrant workers employed by farmers speak fluent
Spanish) and distributed to all farms during the first field visits.













New brochure for Good Agricultural Practices in the field. The 2015
edition of the GAP brochure will be restructured and updated in 2016
taking into account all of the suggestions of CU in respect of the mainprincipals of the ALP Code. The structure of the new edition will be
adapted to the STP and the pillars, to facilitate familiarity with theprogram.
New ALP poster with the 7 Principles that will include updated photos(based on Spanish conditions) and a more precise translation.
Based on CU recommendations a new poster will be published in 2016
focusing on income and working hours which will highlight minimum
wages, working hours and overtime work. All the relevant informationmaterials will be available only in Spanish due the small number of
migrant workers and because all of them speak fluent Spanish.
An updated leaflet will be provided during 2016 crop for distribution by
the farmers to their workers, focusing on workers’ rights, which will
include the emergency telephone number (112) which workers can callfor support. This will address one of the weaknesses detected by CU,
concerning the lack of information given to workers.
A new brochure will be prepared for the 2016 crop containing a new listof hazardous tasks which must never be performed by minors (noperson below 18 is allowed to perform any type of hazardous work).
This will include graphics from PMI adapted to the Spanish tobacco crop
season. Brochures will be printed for all farmers who will receive thedocument along with the other informative material. After receiving a
copy the farmer will be asked to sign a receipt.
A GTS poster with information on how to prevent exposure to green
tobacco sickness, how to recognize the symptoms and what workers
should do if they experience GTS.
Update all the principal information and documentation edited by the
ALP country team and supervised by the Steering Committee relating to
the ALP program on the website: www.IBERTABACO.com. The web
page will be updated during the season whenever the ALP local teamand the steering committee deem it appropriate and necessary.
DELTAFINA will conduct unannounced visits which will also check
whether the farmers are providing information to workers, including the
ALP leaflet. Because at least 10% of the visits will be unannounced thiswill be equivalent to around 20 to 25 visits for a normal crop season.

c) MONITORING AND COLLECTION OF FARM PROFILES
Despite the complexity of the Spanish organization (DELTAFINA, 3 Cooperatives,
1 STP Coordinator, 7 FT’s, 120 farms, 170 farmers) and the fact that all the data
had to be entered manually into the ALP database, Control Union found that all
farms have their Farm Profile sheet duly updated, although some contained
incorrect information at the time of the assessment. The form is currently paperbased and we are assessing the possibility to use a more effective electronic tool.
DELTAFINA expects to roll out the MobiLeaf handheld device to the three
cooperatives during autumn 2016. This will help improve the accuracy of the data

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collection and farm-by-farm monitoring process conducted by Field Technicians. In
order to assess the accuracy of Farm Profile monitoring data, DELTAFINA willconduct unannounced visits during the crop season.
In order to improve the farm-by-farm monitoring process, DELTAFINA will
increase the number of field visits by Field Technicians from three to at least six
visits per farm during the crop season, with 100% of contracted farms to bemonitored on all ALP principles.. During the first visit (April-May), FTs will collectcomprehensive information for the Farm Profile, as a baseline with which tomeasure subsequent visits. Field technicians will update the Farm Profile data
after each visit to ensure that it is precise and accurate, and verify whether there
are any issues on the farm. One specific focus of farm visits will be to draw
attention to CU’s recommendations on the principles relating to income, working
hours and safe working environment.
d) PROMPT ACTION
The Prompt Action Protocol was reviewed by Control Union and although all fieldtechnicians understood a Prompt Action as an activity or situation that needs to be
immediately addressed, their understanding about the detailed definition was
rather limited.
DELTAFINA will work with field technicians to improve their understanding andcapability to distinguish Prompt Actions from other situations not meeting the ALP
Code, through the following actions:a) Discuss the definition of Prompt Action and the reporting procedure in detailduring the refresher meetings with field technicians.
b) Compile a new Prompt Action List to be distributed to field technicians
during the 2016 crop season. All relevant documents, including the brochure,and the PPE kit will be distributed as soon as DELTAFINA signs the contract
with IBERTABACO in April 2016.
c) Before the 2016 season starts in April, additional refresher training will begiven to the FTs about Prompt Actions, which will include several examples ofdifferent situations on the farm that should be considered Prompt Action orsituations not meeting the ALP Code Standards. The refresher training will also
include the analysis of Prompt Actions reported in 2015 to help FTs
differentiate issues on the farm and how to record them properly.
In case a FT from any of the cooperatives observes any Prompt Action situation ona farm, he is required to agree with the farmer on an improvement plan to resolve
the situation, as well as to record and report the situation immediately. After each
Prompt Action issue, the field technician will conduct an unannounced visit toverify whether the issue is still happening and to follow-up on the improvement
plan agreed with the farmer.
In the event that a farmer does not satisfactorily resolve a Prompt Action issue,
consideration will be given as to what further action should be taken in response
thereto. Any such, consideration will need to take account of all the surrounding
circumstances.

ACTIONS TO
PRINCIPLESADDRESS

FINDINGSRELATED

TO

THE

ALP

CODE

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DELTAFINA will also take steps to address the risks and issues identified by CU
during their farm level assessment in relation to the principles of the ALP Code.
1. CHILD LABOUR
In line with DELTAFINA’s previous internal assessments of the conditions on
farms, Control Union did not find any evidence of child labor and highlighted thehigh level of awareness of farmers and workers, particularly regarding the legal
minimum working age. However, while the majority of farmers were aware of andunderstood what constitutes hazardous work, only half of the workers had a goodknowledge of the topic. DELTAFINA believes that there is still room for
improvement in farmers’ and workers’ understanding in order to prevent the riskof having children below 18 years old involved in hazardous activities. DELTAFINA
will highlight this information by including an updated list of hazardous tasks inthe new 2016 brochure. This brochure will be distributed to all contract farmers
each year, with the contents being discussed and the farmer asked to sign a list
confirming his receipt of same.
2. INCOME AND WORKING HOURS
In line with DELTAFINA’s internal information, CU’s assessment confirmed that all
workers are being paid at least the minimum wage in accordance with the local
legal pay schedule. In Spain, and in particular in the region of Extremadura, theminimum wage is set in a collective bargaining process that has a three-year
validity. The previous agreement was in force between 2013 and 2015. In 2016, a
new agreement will be negotiated for the following three years. DELTAFINA will
follow this process closely in order to communicate the new minimum wage toboth field technicians and farmers in a timely manner. Once the new agreement isin place we will modify our leaflets and communicate the details to the farmers
and workers.
Although all farmers were familiar with the legal working hours and the minimum
wage, some workers did not have the same level of awareness for these two
topics. In addition, most farmers and workers did not know which benefits theworkers were entitled to by law (e.g. vacation), nor the requirements for thepayment of overtime.
For this reason, DELTAFINA will inform all farmers and distribute brochures andposters (listing the applicable requirements) to clarify and reinforce these key
points about the obligations of farmers towards their workers (e.g. basic
conditions of employment, minimum wage, working hours, legal requirements for
extra hours, remuneration for paid holiday and overtime). In an effort to provide
training to all contracted farmers during crop 2016, two training meetings with
farmers are planned for February and June/July, to be conducted by the Country
ALP committee. In order to refresh their knowledge, DELTAFINA /IBERTABACO willorganize meetings and face to face discussions with FTs during the season. Four
specific leaflets will be available before transplanting and delivered by the
Cooperatives’ FTs to farmers. The Cooperatives will ask farmers to distribute theleaflets to their workers. DELTAFINA will conduct unannounced visits throughout
the crop season to check whether the information is reaching the workers.

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3. FAIR TREATMENT
Although Control Union did not find any evidence of physical, verbal or sexual
abuse at any of the farms, it highlighted the need to allow workers tocommunicate with farmers and, if needed, raise concerns. DELTAFINA agrees with
CU that as a significant proportion of migrant workers speak no Spanish, they area particularly vulnerable group. However, it is important to note that Control
Union did not identify any abuse, suggesting that the situation of tobacco workers
in Spain is not as precarious as in other sectors.
DELTAFINA recognizes the importance of conveying to farmers the need tocommunicate to their workers about legal labour rights and employment
conditions. If there are any language or rights problems, several professionals areavailable in the tobacco growing area from the national and regional unions (UGT)
and other governmental offices (CEPAMIN and ADHEX) who can advise workers intheir native language on the relevant legislation and information regarding theirrights. In Spain, before they find a legal job, immigrants receive a salary (anallowance?) to participate in a language course paid for by the governmental
authority. DELTAFINA and IBERTABACO each monitor compliance with the local
and national laws and have not observed any violations in recent years.
DELTAFINA will continue engaging with the Workers’ Union to communicate ALP.
As of 2016, DELTAFINA will encourage the Workers Union to be more involved insharing the new information on ALP and issuing bulletins regarding workers’ rights
to be distributed with communication materials and discussed during visits andmeetings at the farmer and worker level.
Leaflets in Spanish will be used to inform workers about their rights as well the
resources available in case they require further information about their laborrights, need additional support, or wish to raise a concern, by either (i) submitting
a claim/suggestion via the IBERTABACO web page, or (ii) contacting the legal
services of the Worker Unions. These options are available to anyone who needs
to file a complaint or needs legal clarification. This support is also provided by the
local “Gestoria” office for employment.
4. FORCED LABOUR
Control Union found no evidence of forced labor (e.g. financial deposits, retentionof original identity documents, or delayed payment beyond the legal andconventional terms). However, CU found that workers are unaware of their rights
and of the proper procedure and notice they need to give before leaving the job.
In order to mitigate the risks of forced labor DELTAFINA will:Continue monitoring farmers’ financial conditions to further assess theirability to pay workers. It should be noted that all the farmers who aremembers of the Cooperative use its financial services and so thepayment of the workers is automatic with the service of theemployment office “Gestoria” used by all the farmers.

Provide leaflets in Spanish to all the farmers (referred to in section 3 above) withthe requirement that these be distributed to their workers, who must sign an
acknowledgement of receipt to ensure that workers are made aware of theirrights.


ALP country team to conduct 20 to 25 unannounced visits to verify thatleaflets have been distributed to the workers.

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5. SAFE WORK ENVIRONMENTDELTAFINA remains committed to work with contracted farmers in its supply
chain, to support them to ensure that everyone working on the farm enjoys a safe
work environment. This also means a strong focus on preventive measures andrisk mitigation actions.
DELTAFINA will continue to distribute one or more PPE (personal protective
equipment) kits to each farm. These kits include glasses, gloves, a face mask withfilter and overalls. The PPEs will be available in March/April, 2016 in order thatthey can be distributed during the first farms visits.
During the refresher sessions with farmers, DELTAFINA and IBERTABACO willemphasize the importance of the safe working environment principle.
Crop Protection Agents (CPA): handling, re-entry period andstorage:
According to CU’s findings and based on Spanish legislation, every person who
handles CPAs must be trained and obtain a license to ensure correct application.
In Spanish tobacco farms, only licensed individuals are allowed to apply CPAs. To
obtain or renew such a license, individuals must attend a special course and passa test which is prescribed by law. Such a course is held each year at the premisesof IBERTABACO. Based on the legal provisions, and from the course content, allfarmers are aware that unlicensed individuals are not allowed to apply CPAs on
their farms. By helping to co-ordinate the yearly course, DELTAFINA andIBERTABACO ensure that proper focus is given to this important legal
requirement.
To organize training courses for those workers who do not alreadyhave the basic license to apply CPAs.
IBERTABACO will request their members to only hire people whohave a license.
To put in place a prompt action procedure for those farms where
workers were found applying CPAs without a license.

In addition, DELTAFINA and IBERTABACO will check the correct chemical andprotective equipment usage at farm level through unannounced visits.
Most of the farmers have a proper storage place for CPAs and are equipped withat least one set of PPE for each farm. It was found that 75% of the assessed
farms do not use a specific mechanism to warn of the re-entry period after theapplication of pesticides in the field.
At the beginning of 2015, DELTAFINA distributed to farmers a list with the namesof active ingredients and re-entry periods for the most common CPAs used for
tobacco farming in Spain. In April 2016, after signing the contracts, DELTAFINA
will distribute to all farmers a brochure with the new approved CPA list andcorresponding re-entry periods as well as the correct CPA storage procedure. All
farmers will be informed about the importance of respecting the re-entry period
through refresher training sessions.
A new poster will be designed with danger signs as a warning after phytosanitary
treatments, to ensure that the re-entry period is respected on the farm. Thesematerials will be distributed at the end of the transplanting period to all farmers,
between May and June 2016.

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During the farmers’ training, DELTAFINA and IBERTABACO will focus on thisfinding and distribute the new warning poster to be placed in the field after
treatment.
Although the majority of farmers keep records of CPA application on their farms,
there are still 25% who do not. FTs will continue to verify records and support
farmers to keep appropriate records for each CPA application. Such records must,in any event, be kept in order for farmers to qualify for an agriculturalenvironment subsidy This specific agro-environmental support is regulated by the
Regional Decree number 9/2016 February 26. The main topics are:-

6 year agreement by a Farm Plan that includes the surface area andlocation for each year.
Minimum rotation: 16.7 % (average of the 6 years’ agreement)
Integrated Production Management.
Keeping of a field book.
Agronomic commitments on the usage of limited amounts of N/P/K
units.
Verification of the system by an external company.

All farmers who meet these standards receive a subsidy on a per hectare base.
The availability of such a subsidy serves as an additional incentive for farmers tomaintain appropriate CPA records.
Green Tobacco Sickness prevention:
Concerning green tobacco sickness (GTS), 64% of farms are trained about therisks and security measures to take. Although 100% of the farmers are aware of
the risks of GTS when handling green tobacco, not all workers are. DELTAFINA
and IBERTABACO will monitor the increase in knowledge of GTS among workers,
though farm visits and personal interviews with workers and farmers. Also for thisreason, DELTAFINA with IBERTABACO will distribute the following materials after
contracting in April 2016:


PPE kit to 100% of the farmers and in some cases more than one
per farm
GTS poster in Spanish to 100% of the farmers

During the field visits conducted by the FTs and the ALP country team we will
monitor the level of understanding of the farmers and workers about the GTS.
During the face to face meeting with the farmer, the ALP Country team will also
train the farmer on GTS.
General Safety on farms:
DELTAFINA will increase the number of farm visits conducted by the FT from three
to six. Safety on farms will be a priority area of attention for FTs.
After the remarks on general safety reported by Control Union, we will raiseawareness so it translates into daily practice. To do this DELTAFINA will train its
field technicians so they build their own skills and capabilities to promote therequired change of behavior.
In addition, user friendly brochures will be distributed to farmers and workers
which integrate the essential safety requirements established by law and PMI’s
ALP Code Standards.

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6. FREEDOM OF ASSOCIATION
No evidence was found of a violation of the right to freedom of association.
Furthermore, the workers CU interviewed actively participated in labor unions,which suggests no interference in the workers’ rights to join a union, nor theunion from organizing workers. However, given that there are workers who are
unfamiliar with their rights, DELTAFINA will continue to communicate with farmers
on this topic to inform them of their obligations and responsibilities as employers,
as well as the need to inform the workers of their rights, including those related to
the freedom of association.
7. COMPLIANCE WITH THE LAW
In all the farms that CU visited, the terms and conditions of contracts were incompliance with the law, although there were workers who had not been informed
about all of their labor rights and employment conditions. In the farmer refresher
meetings between DELTAFINA, IBERTABACO and the farmers, which will be held
twice a year (at the beginning and during the season) we will stress theimportance of compliance with the law. Together with Gestoria, DELTAFINA andIBERTABACO are aware of the importance to combine these ALP messages.
DELTAFINA with IBERTABACO plan to produce a new poster/leaflet to be displayedon all farms. This will set out workers’ rights, translated in their native language if
deemed necessary. If there are language problems, the workers’ union will
provide an office to help workers improve their understanding. The 20 to 25
unannounced visit conducted by the ALP country team will be used to check if
farmers have distributed the leaflets to their workers.
CONCLUDING REMARKSWith this Action Plan, DELTAFINA undertakes to implement broad, far reaching
integrated actions to address, reduce or eliminate the problematic practices andrisk factors identified by Control Union on contracted farms.
We will continue to tightly monitor the activity of contracted farmers who
participate in Sustainable Tobacco Production. If we notice that they do not fullycomply with any area of the program, we will increase the training andengagement, and schedule unannounced farm visits more frequently.
Because ULT and DELTAFINA are fully committed with the respect of the ALP and
STP if we do not observe the same commitment from farmers to corrective actions
and continuous improvement we will reserve the right to not contract their
tobacco in the following crop or terminate the contract.
DELTAFINA and IBERTABACO believe they are ready to move into Phase 2 of the
ALP Program.
DELTAFINA’s response reflects its commitment to achieve fair and safe working
conditions on farms through the implementation of the ALP Program. DELTAFINA
will take concrete steps to tackle the issues and areas that need improvement.
DELTAFINA also expresses its firm commitment to continue its engagement withall relevant stakeholders.

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DELTAFINA´s action plan aims to address the risks and issues identified in CU´sreport. CU is convinced that DELTAFINA has the organizational capacity to
implement these efforts, which should be assessed in the future to determine theaction plan’s overall impact.

Appendix 2. ALP Code
ALP Code Principle 1: Child labor
There shall be no child labor.
Measurable Standards:
1) There is no employment or recruitment of child labor. The minimum age
for admission to work is not less than the age for the completion ofcompulsory schooling and, in any case, is not less than 15 years or theminimum age provided by the country’s laws, whichever affords greater
protection.19
2) No person below 18 is involved in any type of hazardous work.
3) In the case of family farms, a child may only help on his or her family’s
farm provided that the work is light work and the child is between 13 and
1520 years or above the minimum age for light work as defined by thecountry’s laws, whichever affords greater protection.
ALP Code Principle 2: Income and work hours
Income earned during a pay period or growing season shall always be enough tomeet workers’ basic needs and shall be of a sufficient level to enable thegeneration of discretionary income. Workers shall not work excessive or illegal
work hours.
Measurable Standards:

1) Wages of all workers (including for temporary, piece rate, seasonal, andmigrant workers) meet, at a minimum, national legal standards oragricultural benchmark standards.

19

As an exception, pursuant to ILO Convention 138, developing countries may under certain circumstances specify a minimum
age of 14 years.
20
The same ILO convention 138 allows developing countries to substitute “between the ages 12 and 14 in place of “between theages 13 and 15”.

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2) Wages of all workers are paid regularly, at a minimum, in accordance withthe country’s laws.

3) Work hours are in compliance with the country’s laws. Excluding overtime,
work hours do not exceed, on a regular basis, 48 hours per week.

4) Overtime work hours are voluntary.
5) Overtime wages are paid at a premium as required by the country’s laws orby any applicable collective Agreement.

6) All workers are provided with the benefits, holidays, and leave to which
they are entitled by the country’s laws.
ALP Code Principle 3: Fair treatment
Farmers shall ensure fair treatment of workers. There shall be no harassment,
discrimination, physical or mental punishment, or any other forms of abuse.
Measurable Standards:
1) There is no physical abuse, threat of physical abuse, or physical contact
with the intent to injure or intimidate.
2) There is no sexual abuse or harassment.
3) There is no verbal abuse or harassment.
4) There is no discrimination on the basis of race, color, caste, gender,
religion, political affiliation, union membership, status as a worker
representative,

ethnicity,pregnancy,socialorigin,disability,

sexualorientation, citizenship, or nationality.
5) Workers have access to a fair, transparent and anonymous grievancemechanism.

ALP Code Principle 4: Forced labor
All farm labor must be voluntary. There shall be no forced labor.

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Measurable Standards:
1) Workers do not work under bond, debt or threat and must receive wages
directly from the employer.
2) Workers are free to leave their employment at any time with reasonable
notice.
3) Workers are not required to make financial deposits with employers.
4) Wages or income from crops and work done are not withheld beyond thelegal and agreed payment conditions.
5) Farmers do not retain the original identity documents of any worker.
6) The farmer does not employ prison or compulsory labor.

ALP Code Principle 5: Safe work environment
Farmers shall provide a safe work environment to prevent accidents and injury
and to minimize health risks. Accommodation, where provided, shall be clean,safe and meet the basic needs of the workers.
Measurable Standards:
1) The farmer provides a safe and sanitary working environment, and takes
all reasonable measures to prevent accidents, injury and exposure to
health risks.
2) No worker is permitted to top or harvest tobacco, or to load barns unlessthey have been trained on avoidance of green tobacco sickness.
3) No worker is permitted to use, handle or apply crop protection agents(CPA) or other hazardous substances such as fertilizers, without having
first received adequate training and without using the required personal
protection equipment. Persons under the age of 18, pregnant women, andnursing mothers must not handle or apply CPA.

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4) Workers do not enter a field where CPA have been applied unless and until
it is safe to do so.
5) Workers have access to clean drinking and washing water close to where
they work and live.
6) Accommodation, where provided, is clean, safe, meets the basic needs ofworkers, and conforms to the country’s laws.

ALP Code Principle 6: Freedom of association
Farmers shall recognize and respect workers’ rights to freedom of association andto bargain collectively.
Measurable Standards:
1) The farmer does not interfere with workers’ right to freedom of association.
2) Workers are free to join or form organizations and unions of their own
choosing and to bargain collectively.
3) Worker representatives are not discriminated against and have access tocarry out their representative functions in the workplace.

ALP Code Principle 7: Compliance with the law
Farmers shall comply with all laws of their country relating to employment.
Measurable Standards:
1) All workers are informed of their legal rights and the conditions of theiremployment when they start to work.
2) Farmers and workers have entered into written employment contracts
when required by a country’s laws and workers receive a copy of thecontract.
3) Terms and conditions of employment contracts do not contravene thecountry’s laws.

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