350 Fifth Avenue, 34th Floor
New York, NY 10118-3299
Tel: +1-212-290-4700
Fax: +1-212-736-1300; 917-591-3452
Kenneth Roth, Executive Director

March 31, 2014

Deputy Executive Directors
Michele Alexander, Development and Global Initiatives
Carroll Bogert, External Relations
Iain Levine, Program
Chuck Lustig, Operations
Dinah PoKempner, General Counsel
James Ross, Legal and Policy Director
Division and Program Directors
Brad Adams, Asia
Daniel Bekele, Africa
Alison Parker, United States
José Miguel Vivanco, Americas
Sarah Leah Whitson, Middle East and North Africa
Hugh Williamson, Europe and Central Asia
Joseph Amon, Health and Human Rights
Shantha Rau Barriga, Disability Rights
Peter Bouckaert, Emergencies
Zama Coursen-Neff, Children’s Rights
Richard Dicker, International JusticeBill Frelick, Refugees’ Rights
Arvind Ganesan, Business and Human Rights
Liesl Gerntholtz, Women’s Rights
Steve Goose, Arms
Graeme Reid, Lesbian, Gay, Bisexual, and Transgender Rights
Advocacy Directors
Philippe Bolopion, United Nations, New YorkMaria Laura Canineu, Brazil
Kanae Doi, Japan
Jean-Marie Fardeau, France
Meenakshi Ganguly, South Asia
Tiseke Kasambala, Southern Africa
Lotte Leicht, European Union
Sarah Margon, Washington DC, ActingDavid Mepham, United Kingdom
Wenzel Michalski, Germany
Elaine Pearson, Australia
Juliette de Rivero, United Nations, Geneva
Board of Directors
Hassan Elmasry, Co-Chair
Joel Motley, Co-Chair
Wendy Keys, Vice-Chair
Susan Manilow, Vice-Chair
Jean-Louis Servan-Schreiber, Vice-Chair
Sid Sheinberg, Vice-ChairJohn J. Studzinski, Vice-Chair
Michael G. Fisch, Treasurer
Bruce Rabb, Secretary
Karen Ackman
Jorge Castañeda
Tony ElliottMichael E. Gellert
Hina Jilani
Betsy Karel
Robert Kissane
Kimberly Marteau Emerson
Oki Matsumoto
Barry Meyer
Aoife O’Brien
Joan R. PlattAmy Rao
Neil RimerVictoria Riskin
Graham Robeson
Shelley Rubin
Kevin P. Ryan
Ambassador Robin Sanders
Javier Solana
Siri Stolt-Nielsen
Darian W. SwigJohn R. Taylor
Amy Towers
Marie Warburg
Catherine Zennström

André Calantzopoulos
Chief Executive Officer
Philip Morris International, Inc.
120 Park Avenue
New York, New York 10017
Cc: Jennifer P. Goodale
Vice President, Contributions
Philip Morris International
Avenue de Rhodanie 50
1007 Lausanne, Switzerland
Dear Mr. Calantzopoulos,
Thank you for your letter of February 4, 2014 and for the meeting ofFebruary 6, 2014. We appreciate the constructive dialogue with PhilipMorris International. We have appreciated the opportunities to learn
more about Philip Morris International’s policies and practices
concerning child labor. We look forward to seeing you on April 10 inRaleigh when we will present our findings and recommendations at
the Farm Labor Practices Group meeting.
We are writing today to share with you some additional information
regarding the counties in North Carolina, Kentucky, and Tennessee inwhich children reported working. We are also taking this opportunity
to share our key recommendations to businesses purchasing tobaccoin the United States.
Counties where Children Reported Working
As we explained previously, consistent with our methodology forinvestigating human rights worldwide, we go to great lengths toprotect the confidentiality of interviewees. Out of concern forinterviewees’ security, we are unable to report specific farms wherechildren worked, but we can share a list of counties where children
reported working in North Carolina, Kentucky, and Tennessee(attached). We do not preclude the possibility that children work in
tobacco farming in other counties in these states. Due to the verysmall number of children we interviewed in Virginia, we are unable toprovide county-level information for that state.

AMSTERDAM · BEIRUT · BERLIN · BRUSSELS · CHICAGO · GENEVA · JOHANNESBURG · LONDON · LOS ANGELES · MOSCOW · NAIROBI · NEW YORK · PARIS ·SAN FRANCISCO · SÃO PAULO · SYDNEY · TOKYO · TORONTO · WASHINGTON · ZÜRICH

While we hope our list of counties might help to guide Philip Morris International’s
efforts to address hazardous child labor on farms in its supply chain, we wouldencourage the company to do a comprehensive investigation of child labor in every
county from which Philip Morris International purchases tobacco. Due to the small
size of our team and the nature of our methodology, we are not in a position toconduct a broad survey to examine conditions in every tobacco-growing county in
the US. However, our research indicated patterns of hazardous child labor on
tobacco farms in many different locations, and we urge Philip Morris International tolook beyond the counties we identified in order to investigate thoroughly child laboron all US tobacco farms in its supply chain.
Recommendations
We would like to take this opportunity to share our initial recommendations for
tobacco manufacturing companies and tobacco leaf companies which we believe are
essential to protect children from hazards particular to tobacco farming. We lookforward to discussing these recommendations with you. Human Rights Watch has
also developed detailed recommendations for other relevant actors, including the USCongress, the US Senate, the President of the United States, the US Department ofLabor, the Environmental Protection Agency, tobacco-producing states, tobacco
growers’ associations and Farm Bureaus, agricultural employers, and theInternational Labour Organization.
Human Rights Watch bases these recommendations on our research findings which
we detailed to you in our December 11, 2013 letter, extensive reviews of available
public health literature, interviews with public health researchers, analysis ofnational laws and practice, analysis of ILO laws and reports, interviews with ILO
experts on child labor, interviews with representatives of the Eliminating Child
Labour in Tobacco Growing Foundation (ECLT), and ECLT materials.
Based on our findings, Human Rights Watch believes that no child under age 18
should be permitted to work with tobacco in any form, including plants of any size ordried tobacco leaves, due to the inherent health risks posed by nicotine and thepesticides applied to the crop.
Because exposure to tobacco in any form is unsafe, Human Rights Watch has
determined, based on our field investigations and other research, that as a practicalmatter there is no way for children under 18 to work safely on US tobacco farms when
they have direct contact with tobacco plants of any size or dried tobacco leaves,
even if wearing protective equipment. Though protective equipment may help
mitigate exposure to nicotine and pesticide residues, rain suits and watertight
gloves would not completely eliminate absorption of toxins through the skin andwould greatly increase children’s risk of suffering heat-related illnesses. The
inadequacy of protective equipment to protect children, as documented by Human

Rights Watch in the US, seems likely to extend to tobacco farms outside the UnitedStates.
A number of countries have laws or regulations prohibiting all children from working
in tobacco farming, or from performing the majority of tasks in which they come into
direct contact with tobacco in any form, including Brazil, India, Malawi, Kazakhstan,Russia, and Uganda.
Recognizing the risks to children of work in tobacco farming, the US Department ofLabor proposed regulations in 2011 that would have prohibited all children under 16(the minimum age for hazardous work in agriculture in the US) from “all work in thetobacco production and curing, including, but not limited to such activities asplanting, cultivating, topping, harvesting, baling, barning, and curing.” Theregulations were withdrawn in 2012. The ILO Committee of Experts has strongly
urged the US government to reconsider withdrawal of the proposed regulations.
This evidence and our analysis are further detailed in our forthcoming report, as areadditional recommendations. Our key recommendations to businesses purchasing
tobacco in the United States include:
Regarding Child Labor

Adopt and implement policies globally prohibiting the use of child labor
anywhere in the supply chain. The policy should specify that hazardous workfor children under 18 is prohibited, including any work in which children comeinto direct contact with tobacco plants of any size and dried tobacco leaves.
Consistent with ILO conventions, the policy should also prohibit work bychildren under the age of 15, except for light work by children ages 13 to 15, or
the minimum age provided by the country’s laws, whichever affords greater
protection. The policy should specify that it is in effect throughout the supply

chain in all countries irrespective of local laws that afford lesser protections.
Strive to phase out the use of child labor in the supply chain by establishingclear timeframes.

Ensure that all contracts with growers and suppliers include specific language
prohibiting the use of children in hazardous work under 18, including any
work in which children come into contact with tobacco leaves of any size anddried tobacco leaves. Establish and carry out penalties for those in the supply
chain who violate the no-child labor policy. The penalties should be
sufficiently severe and consistently implemented so as to have a dissuasive
effect. Discontinue contracts with farms that repeatedly violate the policy
prohibiting child labor.

Provide training to agronomists, suppliers, growers, workers, and others on
the hazards to children of working in tobacco. Utilize outside experts on childlabor to conduct these trainings where appropriate.

Establish a regular and rigorous internal monitoring process in all countries inthe supply chain.

Engage qualified third-party monitoring for child labor in supply chains in allcountries.



Engage a third-party organization to develop a no-child labor policy as
outlined above, including the structures for its effective implementation.

Develop or enhance collaboration with local stakeholders to eliminate childlabor on tobacco farms, including by:o Working with federal and local government officials, including theOffice of Migrant Education, to ensure access to education forfarmworker children.
o Implementing, with meaningful input and participation fromfarmworker children, their families, and local stakeholders, freesummer programs each year for both migrant and local children, as analternative to working in tobacco farming. Programs should provide
age-appropriate educational, recreational, and leadershipdevelopment opportunities to children under 18.
o Collaborating with local stakeholders to identify other summer
employment opportunities for children as alternatives to working on
tobacco farms.
o Where possible, cooperating with the ILO’s International Programmeon the Elimination of Child Labour (IPEC), UNICEF, nongovernmentalorganizations, and others undertaking efforts to prevent child labor,
including through the provision of alternatives to working in tobaccofarming.
o Establishing a scholarship fund to provide young farmworkers witheconomic support to pursue higher education. The scholarship
application should account for the unique circumstances offarmworker children’s educational paths.
o Investing in rural health infrastructure to ensure tobacco workers andtheir children have access to health services.
o Collaborating with land-grant universities and extension services toenhance agricultural education in tobacco-growing communities, andto provide farmworker families with access to land for small-scale
agricultural enterprise.

Regarding Industry-Wide Multilateral Initiatives
Develop an international industry-wide standard to prohibit hazardous workfor children under 18 on tobacco farms, including any work in which children
come into contact with tobacco plants of any size and dried tobacco leaves;establish minimum age requirements consistent with ILO conventions.

Amend the US Tobacco Good Agricultural Practices (GAP) labor management
guidelines to specify that hazardous work for children under 18 is prohibited,including any work in which children come into contact with tobacco plants ofany size and dried tobacco leaves. Consistent with ILO conventions, thestandard should also prohibit work by children under the age of 15, except forlight work by children ages 13 to 15. This standard should be a contractual
requirement for all US tobacco growers.
Engage meaningfully in multi-stakeholder initiatives, including with a view tosupport tobacco industry efforts to promote the elimination of child labor in
the tobacco supply chain, effective monitoring of these policies, andinitiatives to support alternative employment, education, and recreational
opportunities for children in tobacco-growing communities.

Increase financial support to nongovernmental organizations working toeliminate hazardous child labor in tobacco farming.

Establish a pooled fund to support programs that provide alternatives to childlabor in US tobacco farming and/or consider expanding programs through theEliminating Child Labour in Tobacco Growing Foundation to include theUnited States.

We look forward to discussing these recommendations with you and welcome any
updates to Philip Morris International’s existing policies and practices regardingchild labor, so that we have the most up-to-date information for our research andreporting.
Best regards,

Arvind Ganesan
Director
Business and Human Rights Division

Jane Buchanan
Associate Director
Children’s Rights DivisionCounties where Children Reported Working
StateCounties

KentuckyBarrenBath
BourbonBoyle
Clark
Crittenden
FayetteFranklin
Harrison
HenryLincoln
McCrory
Metcalfe
MonroeMontgomery
PulaskiScott
ShelbyTaylorWarrenWashington
Wayne

North Carolina

DuplinGreeneJohnston
Jones
LenoirMartinNash
Onslow
Pitt
SampsonWayne
WilsonTennessee

Grainger
Hawkins
Jefferson
Macon
Sumner