THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions

AGRICULTURAL LABOR PRACTICES PROGRAM

Control Union Certifications
Meeuwenlaan 4-68011 BZ ZWOLLE
Netherlands

September 2014

PMI Third Party Assessment

Control Union Certifications
TABLE OF CONTENTS

1.

ALP PROGRAM BACKGROUND AND ASSESSMENT OVERVIEW ....................... 52.

AOT ASSESSMENT: SCOPE AND METHODOLOGY .................................................. 8
2.1 OPENING MEETING .......................................................................................................................... 9
2.2 STAFF INTERVIEWS AND ALP PROGRAM DOCUMENTATION ......................................................... 9
2.3 OVERVIEW OF AOT TOBACCO GROWING AREAS........................................................................... 9
2.4 FARM SAMPLE SELECTION ............................................................................................................. 10
2.5 DEMOGRAPHICS OF FARMS SAMPLED BY CU ............................................................................... 10
2.6 FARM VISITS .................................................................................................................................. 11
2.7 EXTERNAL WORKERS AND FAMILY MEMBERS OF THE FARMERS INTERVIEWED.......................... 11
2.8 CLOSING MEETING ........................................................................................................................ 12
2.9 PREPARATION OF THE FINAL REPORT ........................................................................................... 12

3. ASSESSMENT OF THE IMPLEMENTATION OF PHASE 1 OF THE ALPPROGRAM ....................................................................................................................................... 13
3.1 CONDUCT OF THE ASSESSMENT ................................................................................................... 14
3.2 PEOPLE AND PROCESSES TO MANAGE THE ALP PROGRAM ........................................................ 14
3.2.1 Internal structure for ALP implementation ................................................. 14
3.2.2 Internal communication and reporting ........................................................ 15
3.2.3 ALP training, roles and responsibilities ........................................................ 16
3.2.4 Understanding of the ALP Code Principles .................................................. 16
3.3 COMMUNICATING THE ALP CODE REQUIREMENTS TO ALL FARMERS ........................................ 17
3.3.1 The ALP communication strategy ................................................................... 17
3.3.2 ALP communication methods and materials .............................................. 18
3.4 BUILDING FARM PROFILES FOR ALL CONTRACTED FARMS ......................................................... 19
3.4.1 Data gathering system for Farm Profiles .................................................... 19
3.5 PROMPT ACTIONS .......................................................................................................................... 20
3.5.1 Prompt Action reporting mechanism ............................................................ 20
3.5.2 Understanding and reporting Prompt Actions ........................................... 21
4. ASSESSMENT OF THE CURRENT STATUS OF PHASE 2 OF THE ALPPROGRAM ....................................................................................................................................... 22
4.1 MONITORING OF LABOR PRACTICES FARM BY FARM ................................................................... 23
4.1.1 Building capacity for Phase 2........................................................................... 23
4.1.2 Selection of issues ............................................................................................... 23
4.1.3 Mechanism for monitoring labor practices ................................................. 23
4.2 ADDRESS WIDESPREAD ISSUES ................................................................................................... 25
4.2.1 Investigation of root causes ............................................................................. 25
4.2.2 Initiatives to address widespread issues ..................................................... 25
4.3 SUPPORT MECHANISM ................................................................................................................... 25
4.3.1 Support mechanism ............................................................................................ 25
5.

FARM LEVEL ASSESSMENT OF ALP CODE STANDARDS ................................... 27
5.1 ALP CODE PRINCIPLE 1: CHILD LABOR ...................................................................................... 28
5.1.1 Prevalence of children working ....................................................................... 29

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5.1.2 Awareness of legal minimum working age ................................................. 29
5.1.3 Awareness of hazardous work ......................................................................... 31
5.1.4 Underlying factors that increase risk ............................................................ 31
5.2 ALP CODE PRINCIPLE 2: INCOME AND WORK HOURS ............................................................... 32
5.2.1 Minimum salary ..................................................................................................... 32
5.2.2 Payment schedule ................................................................................................ 32
5.2.3 Regular and overtime hours ............................................................................ 33
5.2.4 Legal benefits ........................................................................................................ 33
5.2.5 Awareness of legal minimum wage ............................................................... 33
5.2.6 Crew leaders .......................................................................................................... 34
5.2.7 Record keeping ..................................................................................................... 34
5.2.8 Pay slips ................................................................................................................... 34
5.3 ALP CODE PRINCIPLE 3: FAIR TREATMENT ................................................................................ 35
5.3.1 No evidence of practices suggestive of unfair treatment ..................... 35
5.4 ALP CODE PRINCIPLE 4: FORCED LABOR ................................................................................... 35
5.4.1 No evidence of workers unable to leave their job ................................... 36
5.4.2 Crew leaders .......................................................................................................... 36
5.4.3 Advance payments during winter .................................................................. 36
5.5 ALP CODE PRINCIPLE 5: SAFE WORK ENVIRONMENT ............................................................... 37
5.5.1 Training and awareness of Green Tobacco Sickness (GTS) ................. 38
5.5.2 CPA handling and training ................................................................................ 38
5.5.3 CPA storage and disposal .................................................................................. 38
5.5.4 Housing .................................................................................................................... 40
5.5.5 Clean drinking and washing water ................................................................ 40
5.5.6 General safety measures .................................................................................. 40
5.6 ALP CODE PRINCIPLE 6: FREEDOM OF ASSOCIATION ............................................................... 41
5.6.1 Workers´ right to freedom of association................................................... 41
5.6.2 Awareness of freedom of association ........................................................... 41
5.7 ALP CODE PRINCIPLE 7: COMPLIANCE WITH THE LAW ............................................................. 42
5.7.1 Information on legal rights ............................................................................... 42
6.

CONCLUDING REMARKS ................................................................................................. 43

APPENDICES ................................................................................................................................. 45
APPENDIX 1. AOT’S RESPONSE AND ALP PROGRAM ACTION PLAN ................................................. 46
APPENDIX 2. ALP CODE ...................................................................................................................... 55

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GLOSSARY OF TERMS and ACRONYMS

ALP
ALP Code
ALP Code Principle
ALP steering committee
ALP Program
CA
CU
CPA
Crew leader
EU
Family farm
Farm Profiles

GAP
GMS
GTS
Leaf tobacco supplier
Migrant labor

Measurable StandardNGO
Oriental tobacco
OCPhase 1
Phase 2
Piece work
PHILSAPMIPMIM SA
PPE
Prompt Action

STP
Support mechanism

Agricultural Labor Practices
PMI’s Agricultural Labor Practices Code
Short statements that set expectations of how the farmer should
manage labor on his farm in seven focus areas
Inter-department group charged with ALP implementation
Agricultural Labor Practices Program
Corporate Affairs
Control Union
Crop Protection Agents
Person responsible for recruitment, supply and/or managing a groupof workers.
European Union
A farm that depends mainly on family members for the production of
tobaccoA data collecting tool developed by PMI with Verité to track thesocio-economic status of the farms, systematically gather detailed
information about, among other things, the type of labor employed,
farming activities that minors may be involved in, and hiring
Good Agricultural Practices
Grower Management System
Green Tobacco Sickness
A 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 us determine to what extent the labor conditions andpractices on a tobacco farm are in line with each of the ALP Codeprinciples
Non-Governmental Organization
A sun-cured, highly aromatic, small-leafed variety of tobacco
PMI Operations Center (Lausanne, Switzerland)Startup of ALP Program (training, communications, outreach)
ALP Program full implementation (monitoring, addressing problems)Payment at a fixed rate per unit of production/work
Philip Morris joint venture in Turkey
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 – pregnant women, the elderly- are in danger, or workers might not be free to leave their job
Sustainable Tobacco Production
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 improve laborand business practices.

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1. ALP Program background and assessment
overview

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
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 other laborabuses 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´sleaf tobacco suppliers have contracts to grow tobacco for PMI and consists of fourmain 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 providing 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 of tobacco
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 suppliers submit internal, annual reports andare assessed regularly on their performance. For the ALP Program implementation,internal reviews are also being performed to assess the progress and challenges in
the program’s implementation. Third party assessments are periodic reviews
undertaken by CU of PMI leaf tobacco suppliers and tobacco farms worldwide.
In this initial stage of implementing the ALP Program, these third party
assessments focus solely on the ALP Program implementation. They specificallyfocus on each leaf tobacco supplier´s progress in implementing the ALP Codeframed 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 ofa 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 or mental
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 Code, “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 at supplier level understand the
ALP Code and the implementation approach, ensuring capacity of people andthe processes 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, identifying risk areas andtracking communication efforts to farmers;
Being aware and engaged to identify situations and incidents at farms thatshould be both reported and addressed immediately.

Phase 2








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;
Report systematically on the progress that is being made;Support mechanism in place.

(Source: Verité & PMI, 2011)
3

Often, there is not a strict distinction between the two phases of the ALP implementation. In practicesuppliers in many countries start considering 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. AOT assessment: Scope and methodology

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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In 2011 PMI launched its global ALP Program. This report of AOT’s tobacco growing
operations in the Tavas and Muğla regions of Turkey, is the sixth external ALP
assessment by Control Union. The review was conducted in August 2014 when AOT
was completing its third crop season under the ALP Program and its first year of
implementing Phase 2.
2.1 Opening meeting
On 5 August 2014, CU started the assessment at the Philip Morris factory in Torbali,
near Izmir, with a meeting with AOT’s senior management (some of whom aremembers the ALP steering committee), the ALP coordinator and regional
supervisors. Representatives of PHILSA, Philip Morris EU & OR regional leaf office,
PMI OC and Verité also attended. In this meeting AOT provided an overview of thecontinuing implementation of ALP and CU presented the objectives of theassessment.
2.2 Staff interviews and ALP Program documentation
CU conducted interviews with AOT’s senior management and the staff involved in
the implementation of the ALP Program. In addition, all four field technicians fromthe selected regions were interviewed. All interviews were conducted individually sothat interviewees felt comfortable to speak freely and raise any issues. Interviews
covered the following topics:












General awareness of the ALP Program and knowledge of the ALP Code;
Implementation of the ALP Program at AOT 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 through Farm Profiles;
Mechanism for reporting Prompt Actions;
Steps taken to prepare for Phase 2;
Methods and tools used for monitoring labor practices;
Initiatives implemented to address widespread issues; andSupport mechanism.

CU then reviewed all relevant documentation related to the ALP Program
implementation, including: Farm Profiles, farmer communication materials,
purchase contracts, Prompt Action reports, training records, personnel records,
monitoring forms, and annual job objectives of the ALP Coordinator.
2.3 Overview of AOT tobacco growing areas
The farms contracted by AOT within the scope of the assessment were divided into
two regions: Tavas region (84%) and the Muğla region (16%). All farms within thescope produce oriental tobacco. Regarding farm size, 28% of the farmers weregrowing between 0,1 and 1 hectares, 40% between 1,1 and 2 hectares, and 32%
more than 2 hectares.

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2.4 Farm sample selection
At the time of the assessment AOT purchased tobacco from 924 farms in the Tavas
and Muğla regions. CU randomly selected 30 farms to visit, constituting ameaningful sample based on the square root of the total number of farms
contracted. The CU sample was purposely skewed towards larger farms, as a larger
number of workers were expected to be present on such farms. Consequently, thenumber presented in this report do not necessarily represent a statistical reflectionof pervasive behavior.
2.5 Demographics of farms sampled by CU
The graphs below reflect specific, demographic information on the sample of 30
farms visited.
Farm size (Ha)CU sample 30 farms**

RegionCU sample 30 farms**

17%

33%

0-1
50%

Mugla

1< - 2
33%

>2

67%

Tavas

Contract status
CU sample 30 farms**

13%

Newly contracted farmer

Existing contracted farmer
87%

Farm typeCU sample 30 farms**
Family farm with only family members working

7% 3%

Farm with family members and local workers
30%
Farm with family members and migrant workers
60%
Farm with family members and local and migrant
workers** While the selected farm sample represented the total universe of farms in the different tobacco growing
regions, the assessment selection was purposely skewed towards larger farms, as a larger number of workers
were expected to be present on such farms. Consequently, the numbers presented in this report are not a blind
indicator of pervasive behavior.

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2.6 Farm visits
Farm visits were only announced to the field technicians on the day of the visit. CU
used a variety of methods to collect information on the practices at each farm.
These included: interviews with farmers and workers, verification of documentationand visual observation in the field, storage rooms, curing barns, working areas andhousing. Before each interview, CU explained the purpose of the assessment andassured interviewees that all information would be completely confidential.
In addition, CU also interviewed individual farmers to assess the effectiveness of
AOT’s communication efforts and initiatives to verify:






If the farmers had been made aware of the ALP Code;The farmers´ level of understanding and attitude towards ALP CodePrinciples;
The key messages received;
Perception of and participation in initiatives implemented;
Their willingness and ability to meet the standards of the ALP Code.

2.7 External workers and family members of the farmers interviewed
In total, 101 external workers and family members of the farms visited wereinterviewed. To avoid bias, interviews with workers were conducted without thefarmer and field technician present. On each farm, CU attempted to interview
different “types” of workers i.e. workers with different types of employment, men
and women, family members and external workers. Additionally, visualobservations of the working conditions were an important technique during thefarm visits. The graphs below illustrate the demographics of the sample.
100%

100%

80%

80%

60%

60%

Occasional
External
workers

40%

Familymembers

20%

Seasonal

40%

Permanent

20%
0%

0%

Type ofemployment*

Type ofinterviewee* Permanent (year round),Seasonal (1-11 months),
Occasional (<1 month)(Only external workers = 40)

100%

100%

80%

80%
<13

60%
Women
40%

Men

60%

13-15

40%

16-17
Adults**

20%

20%

0%
Gender

110%
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100%
80%

Migrant from another region**Adults (≥18)
within the country

60%
40%

Local
20%
0%
Migrant Status(Only external workers = 40)

2.8 Closing meeting
The closing meeting was held on 14 October 2014 at Philip Morris Turkey factory in
Torbali, near Izmir. CU presented the initial findings of its assessment. AOT senior
management (some of whom were members of the ALP steering committee), the
ALP coordinator and the regional supervisors, as well as representatives fromPHILSA, Philip Morris EU&OR regional leaf office, PMI OC and Verité.
2.9 Preparation of the final report
The final public report is an important external measurement of the progress ofglobal ALP implementation in all countries where PMI sources tobacco, including
Turkey. Public release demonstrates PMI’s commitment to transparency as animportant component of the ALP Program. CU authors the final assessment reportwith quality control provided by Verité.
While drafting the report, PMI and the leaf tobacco supplier may request
clarifications on specific findings. After both PMI and the leaf tobacco supplier feelfindings have been clarified and understood, a market action plan is prepared or themarket revises the existing GAP/ALP Program plans to respond to the findings.

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3.

Control Union Certifications

Assessment of the implementation of Phase 1 of
the ALP Program

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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This chapter documents the findings of the assessment of AOT’s implementation forPhase 1 of the ALP Program. Phase 1 began with the training for management
personnel and field technicians globally including:
1) AOT’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 communication and how to build a Farm Profile;5) Identifying problems when AOI visits the farmers they support.
3.1 Conduct of the assessment
CU was satisfied with the cooperation and access to company information provided
by AOT. All interviewees 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. In addition, AOT provided all the relevant documentation related to the ALP
Program implementation.
3.2 People and processes to manage the ALP Program
3.2.1 Internal structure for ALP implementation
At the time of assessment, AOT had established both an ALP coordinator and ALP
steering committee, in which the leaf department was represented. The regional
ALP coordinator, responsible for ALP implementation and maintenance in all EU
countries for AOT, was also a member of the ALP steering committee. For the Tavas
office, one field technician served as the primary contact for the ALP coordinator. Asa group, field technicians were wholly responsible for the farms in their regions andvisited farmers alternately. Consequently, individual farmers could be visited andprovided with support by different field technicians throughout the year. On
average, field technicians each provided support to 231 farmers.

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Organizational chart for ALP implementation* The group of field technicians was wholly responsible for the farms in their regions and visited farmers alternately.

3.2.2 Internal communication and reporting
AOT reported to PMI through a quarterly report which concluded ALP related
progress and identified issues with the ALP implementation. These reports included
the status of initiatives to address widespread issues, farm monitoring, Prompt
Actions, Farm Profiles and the progress of ALP implementation. The ALP Steering
Committee - responsible for the implementation of the ALP Program – held
quarterly meetings to review new developments, progress and challenges. If notable to join to meeting physically, the regional (EU) ALP coordinator4 joined thesteering committee meetings via teleconference.
The ALP coordinator conducted monthly meetings with the field technicians
discussing ALP, among other topics. One of the field technicians, the primarycontact to the ALP coordinator, reported weekly on the status of the region’s
tobacco crop and any urgent issues on ALP. When necessary, field technicians
discussed ALP related issues in the office. Every two weeks, the chief expert(regional supervisor) visited the local office to provide hands-on technical guidance.
As field technicians were visiting farms alternately, qualitative information transfer
between this group of field technicians responsible for collection of both FarmProfiles, Prompt Action reporting and monitoring of farm practices was very
important.

4

The regional (EU) ALP coordinator was responsible for ALP implementation for all EU countries AOT
was operational.

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3.2.3 ALP training, roles and responsibilities
All personnel involved in the ALP implementation had been trained and the ALP
related responsibilities of the ALP coordinator, regional supervisors, fieldtechnicians, and ALP Steering committee as a whole were defined. In November
2011 and December 2013, management personnel received Phase 1 and 2
workshops by PMI in association with Verité. As field technicians developed andmaintained close communications and relationships with farmers, they received
special training. Initially the trainings were conducted by the PMI regional team for
all field technicians of four regional suppliers5 whom PMI sources tobacco from. In
December 2011, the first ALP training was delivered. Again in March 2012, the fieldtechnicians were trained to deliver ALP farmer communication. In March 2013, fieldtechnicians participated in a refresher training on the ALP Code given by the ALP
coordinator. The use of Farm Profiles, escalation of child labor and farm safety was
specifically discussed. In March 2014, the ALP coordinator trained them on Phase 2
and how to conduct farm monitoring and use the monitoring forms (see chapter
4.1.3). During this training, the new digital system (GMS)6 was also discussed,
which is meant to collect ALP information. However, delays in its development
prevented the use of the system to collect information at the farm level in the 2014
crop season. The knowledge of field technicians on the ALP Code was tested duringpersonal interviews with the ALP coordinator resulting in an overview
demonstrating the understanding of each field technician on the ALP Code.
AOT’s response: “Alliance One Turkey Management reviewed the operational model of the Leafand Agronomy Team to better incorporate the work load and assignments necessary to achieve ALP
and GAP Program objectives.”
3.2.4 Understanding of the ALP Code Principles
Field technicians had a good understanding of and experience in the field with the
ALP Code Principles addressing child labor and safe work environment. These werealso the principles chosen by AOT as focus areas. Their knowledge on the principleof fair treatment was adequate. With regards to the remaining ALP Code Principles(income and work hours, forced labor, freedom of association and compliance withthe law), the understanding was more limited;
1. Principle 2 (income and work hours): field technicians were aware of thelegal minimum wage according to labor law, however this is not applicable.
The applicable legal minimum wage is stated in the Decision of Minimum
Wage Determination Commission issued by the Ministry of Labor and Social
Security, being 37,80 TL daily. None of the field technicians were aware ofthis legal minimum wage.
2. Principle 4 (forced labor): field technicians were unaware of the risks that
could be associated with forced labor regarding financial agreements
between farmers and workers including end of harvest payments or advancepayments during winter. The risks for forced labor associated with hiring
labor via crew leaders were also unclear for the field technicians.

56Socotab (Universal Leaf), Alliance One, Türk Tütün Limited and Öz-Ege.
GMS : Grower Management System

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3. Principle 6 (freedom of association): as there were no worker associations
active in the visited regions, freedom of association was a more theoreticalconcept for the field technicians.
4. Principle 7 (compliance with the law): Generally, field technicians could
easily reflect on a farm’s working dynamic (no contracts, basic agreement
on work hours, etc.), but did not have sufficient knowledge to inform
farmers on their legal rights.
A thorough understanding of the ALP Code is important to prevent field techniciansfrom developing a blind spot to non-prioritized issues and not being capable toeither detect or react appropriately. Additional training is required for theknowledge gaps identified to better guide farmers.
AOT’s response: “…the ALP Country team reiterated the importance of each ALP principle during
AOT’s April 2015 refresher training. In May 2015, the Company also provided additional training on
the prompt action escalation process that should be followed as serious issues arise.”

3.3 Communicating the ALP Code requirements to all farmers
3.3.1 The ALP communication strategy
At time of the assessment, all farmers visited had been included in thecommunications on the ALP Code, leveraging both group and individual meetings.
In 2012, a series of group meetings was conducted for farmers at village houses, acommon meeting point. Every group meeting was led by four field technicians, each
representing one of the participating tobacco suppliers.7 In addition to the groupmeetings, field technicians informed and trained individual farmers on ALP CodePrinciples during their regular farm visits.
From interviews with 30 farmers, appeared they were generally familiar with the
ALP Code. As with field technicians, when farmers were asked about the ALP Codethey could easily remember child Labor (90%)and safe work environment (77%).8
The principles farmers less easily remembered were forced labor (33%), fairtreatment (30%), income and work hours (20%), compliance with the law (7%),
freedom of association (3%).8 These findings are in line with AOT’s chosen focal
areas (child labor and safe work environment) and the knowledge of fieldtechnicians described in chapter 3.2.4. Assessment of farmer and worker
awareness of ALP Code Principles is reported more specifically in chapter 4.
The inclusion of a clause in AOT’s farmer growing contracts also supported
communication efforts with all seven principles referenced in simple, one line
statements. Some ALP related topics were described in greater detail including childlabor, income and work hours and Green Tobacco Sickness (GTS).

7

Participating suppliers in the ALP industry approach were; Socotab (universal Leaf), Alliance One, Türk
Tütün Limited and Öz-Ege.
8
Percentages refer to the farmers interviewed.

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3.3.2 ALP communication methods and materials
AOT developed several materials to communicate the ALP Code to farmers. AOT
distributed a leaflet specific on GTS, an ALP leaflet and provided the farmers with acap with the ALP logo. Via the ALP leaflet, all ALP Code Principles werecommunicated. Information on the ALP Code was edited for the local market andtranslated into direct messaging more easily understood by farmers. Picturesvisually supported the messaging. Again child labor and safe work environment
were specifically addressed in detail with others only mentioned briefly.

ALP Leaflet
Regarding child labor, information was provided on the legal minimum working age
and acceptable work activities. There was limited reference to local, Turkish law.
For example, while the leaflet referenced “fair” wages andworkers shouldn’t work long hours, no other specifics were
included. Additionally, no information was provided on theminimum frequency of payments. More specific information on
the legal minimum wage, minimum working age and other local
regulations applicable to Turkish tobacco farms would guidefarmers in comparison to their current practices and better meet
the ALP Code standards.

ALP cap

Most farmers declared they had learned about ALP during
individual meetings (87%) and group meetings (80%). 70% of farmers reported
they had received the leaflet. Generally farmers said they learned more from verbal
communication methods compared to written communication materials, as theyoften just didn’t read them.
The legal wording of all communication materials had been checked by the legal
department of PHILSA.

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AOT’s response:
1. ”In partnership with PMI, Alliance One Turkey developed a clearer explanation of thecountry’s laws regarding minimum wages, holidays and working hours based on the Law(code of obligation, number 6089).”
2. “Given the dynamic nature of tobacco farms, together with socio-economic changes intobacco-farming communities, AOT makes continual adjustments to the materials in its ALP
toolbox to better meet the needs of the growers and their communities as well as to address
the findings of the CU report and new Company initiatives.”
3. “The 2015 toolbox was furnished with the below items:•
Brochures that include information about all ALP principles•
Mobile devices equipped with AOI’s Growers Management System (GMS) to help FTs
monitor farms and capture farm profile data.
•
Directives on Prompt Action escalation process•
2015 Prompt action lists•
Separate brochure on Green Tobacco Sickness (GTS)•
Awareness booklet on health and safety issues (providing real life examples)•
Detailed information related to the Income and Work Hours principle (includingreference to laws)”

3.4 Building Farm Profiles for all contracted farms
As a requirement of Phase 1, AOT is expected to build Farm Profiles for every farm.
PMI has developed a global template for leaf tobacco suppliers to collect socioeconomic indicators such as farm size, number of workers, age and number ofchildren in the farmer’s family, working status (for example part time, full time,
migrants), the pay period for workers and living conditions.
3.4.1 Data gathering system for Farm Profiles
Field technicians recorded Farm Profiles on paper forms and data was transferredmonthly to an excel spreadsheet. To better understand the farmer base, AOT
analyzed the Farm Profiles for the 2013 crop season, using a template provided by
PMI.
At the time of the assessment, 93% of the farms visited had an updated FarmProfile for the 2014 crop season. For the remaining farms (7%), Farm Profiles ofthe 2013 season were available. Of the completed profiles, 18% of the FarmProfiles were missing information in the section of ALP communication to the farmer
and 11% of the Farm Profiles were missing information on more topics (living
conditions, employment conditions, commercial crops on the farm, food grown forhousehold consumption, farm tasks).
For the 2014 crop season, CU verified the accuracy of the Farm Profiles and foundthat 64% matched the situation on these farms. For the remaining 36%,
inaccuracies were identified; the size of the contracted tobacco field (7%), thenumber of reported people (18%) and living conditions (11%) were inaccurate.9
Due to fluctuating demand for labor during high seasons, which is inherent to the9

Percentages of the completed Farm Profiles for the 2014 crop season.

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agricultural sector, collection of accurate information on the number of workers
proved to be challenging.
3.5 Prompt Actions
PMI defines a Prompt Action as:“a situation in which workers’ physical or mental well-being might be at risk,children or a vulnerable group – pregnant women, the elderly - are indanger, or workers might not be free to leave their job.” (source: PMI, 2011)
Phase 1 requires the addressing of Prompt Actions found on farms AOT sources
tobacco from. Any Prompt Action should be reported immediately to the ALP
coordinator, who should then provide guidance on how to either address or escalate
the issue within the organization.
3.5.1 Prompt Action reporting mechanism
Farm incident sheets were used to record identified Prompt Actions in the field. This
sheet was suitable to record both Prompt Actions and other situations not meetingthe standard. Field technicians could easily identify a situation as Prompt Action
with a tick box. The issues identified were classified under the applicable ALP CodePrinciple and Measurable Standard with space to describe the issue identified with acorresponding action plan and follow up. The dates of visit and re-visit were also
noted on the form.
AOT distinguished between widespread and unique Prompt Actions. For widespread
Prompt Actions - regularly encountered on their farms - field technicians were
expected to know how to react while in the field. In case of a unique Prompt Action
identified for the first time, field technicians needed to inform and discuss the issue
with the ALP Coordinator to agree upon an adequate approach. In case both fieldtechnicians and chief expert (regional supervisor) would not be able to solve acertain Prompt Action they could involve the ALP Steering committee. Prompt
Actions were directly reported to the ALP Coordinator after re-occurrence of theissue during a second visit. Field technicians reported widespread Prompt Actions
on a monthly basis to the ALP Coordinator using an excel template. Reporting ofidentified Prompt Actions to PMI was included in the quarterly reports.
AOT created a list of the following 10 situations to be considered as widespread
Prompt Actions: children under 15 hired, family children under 13 working, under
18 driving a tractor, under 18 handling CPA, Pregnant/nursing women applying
CPA, forced labor, physical or mental abuse, empty CPA bottles creating unsafe
situations for human health, elderly involved in hazardous work as defined by PMI,CPA usage without using PPE. Not all situations that regularly occurred were
included in the list of widespread Prompt Actions. For example, children under 18
performing hazardous activities as defined by PMI, such as harvesting and stringing
was assigned as a widespread Prompt Action.
In addition, as farms were not always visited by the same field technician, goodquality reporting of issues was crucial to keep all involved field technicians informedon the farm’s situation and enabling them to provide them with good support on

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ALP. This was not the case at the time of the assessment. Also, in order to better
analyze the aggregated data and identify root causes, additional information wasneeded about individual Prompt Actions. For example, without information from thefarmers as to why children were working on a farm it is difficult to develop an
effective mitigation strategy. Currently, this level of interactive detail was notavailable.
During the 2013 crop season, 32 Prompt Actions had been recorded in both theTavas and Muğla regions; predominately regarding child labor (59%) and safe work
environment (41%). The re-visits were supposed to be planned within two weeks
after initial identification of the Prompt Action according to AOT’s Prompt Action
procedure. However, field technicians mentioned a range in between 15 to 20 daysin which they would conduct the re-visit. Examining re-occurrences was identified
as a challenge by CU. Prompt Actions were only reported when physically observed
during a visit by a field technician. As farms are not always operational during afarm visit, it can be challenging to determine whether the Prompt Action is still ongoing or fully resolved.
3.5.2 Understanding and reporting Prompt Actions
Field technicians were aware and focusing on the widespread (pre-listed) types ofPrompt Actions. As the reporting forms did not describe every category in explicit
detail, it was not immediately clear what should be reported. For example thecategory ‘children under 15 hired’ was more clearly defined than ‘forced labor.’ For
the latter, field technicians were uncertain when to identify a situation as a Prompt
Action. The limited exposure of these risks also in the Turkish market also
contributes to their confusion. Consequently, no Prompt Actions were recorded on‘forced labor’ during the 2013 crop season. By creating such a list there is a riskthat field technicians do not pay specific attention to identify unique or new issues
not meeting the standard.
During the assessment, Prompt Actions were reported for 17% of the farms visited.
All farmers were aware of the fact that a Prompt Action had been reported by thefield technician, but none of them had changed their practices. CU identified reoccurrence on all of the farms visited. These Prompt Actions related to child labor ina family setting and farmers reporting the need for their children to contribute to
the work on the farm.

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

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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This chapter describes the findings on the current status of AOT’s implementation ofphase 2 of the ALP Program. As AOT had recently initiated Phase 2, certain
requirements such as improvement plans were not yet implemented.
When the supplier decides they are ready to implement, PMI introduces leaf
tobacco suppliers to Phase 2. This does not necessarily mean that all Phase 1
requirements have been achieved. PMI and Verité then provide training to the ALP
Country Team which includes:
1) Preparation of the ALP Country Team to train staff to systematically monitor
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, leaf tobacco suppliers are expected to start monitoring labor practices
on individual farms. They select a minimum of 2 ALP Code Principles to focus theirefforts in the first year of implementation, progressively monitoring all ALP CodePrinciples and Measurable Standards.
4.1.1 Building capacity for Phase 2
In December 2013, management personnel received a special training from Verité
and the OC to ensure that all relevant staff was prepared for Phase 2 of the ALP
Program. In April 2014, field technicians and chief experts (regional supervisors),
responsible for visiting the farms, were given a special training on Phase 2 by the
ALP coordinator.
4.1.2 Selection of issues
AOT started the implementation with a focus on the two principles they identified as
the area’s main issues: child labor and safe work environment. This focus waschosen together with the PMI regional team, based on AOT’s Farm Profile analysis.
4.1.3 Mechanism for monitoring labor practices
Since the start of the 2014 crop season, monitoring was conducted and fieldtechnicians recorded their findings on a monitoring form. In contrast with thechosen focus on child labor and safe work environment, AOT chose to include 33
questions on the form covering all Measurable Standards of the ALP Code. This
increased work load for field technicians, however did not contribute to the qualityof reporting as knowledge of field technicians was not adequate to conduct
monitoring for part of the non-prioritized principles (income and work hours, forcedlabor, freedom of association, compliance with the law)
Each year, field technicians used one form per farm recording several monitoring
visits. Every time the field technicians completed monitoring, a different color pen
was used to update the form to be able to distinguish information from visits. Field
technicians monitored their farms several times a year but there was only limited

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space on the form to describe the context of the identified situation not meeting thestandard. The quantitative information collected via the forms was gathered in an
excel spreadsheet by the ALP coordinator.
The form contained several references to Turkish Labor Law, not applicable toworkers on small farms (with less than 50 workers). For example, working hours
were referenced as a maximum of 45 hours weekly. According to AOT, the Code ofobligations (number 6098) applied and these regulations should form the basis formonitoring. In addition, there was no legal reference included for several questions
on the monitoring form, such as questions on the minimum wage or frequency of
payments to workers. In addition, regarding principle 7 of the ALP Code(compliance with local law) it was only mentioned that contracts should be inaccordance with related laws, without any specific reference to the applicable laws.
The lack of appropriate use of applicable laws and clearly phrased questions affects
the monitoring of field technicians and decreases the accuracy of their reporting.
At the time of the assessment, monitoring forms were available for 96% of thefarms visited. For one farm, CU received a completed monitoring form while thefarmer declared that the field technician had not visited the farm yet. CU checked
the quality of the available monitoring forms and found deviations between thereporting information and actual farm practices on 45% of the forms.


Number of children: for 28% of the checked forms these differences could
be explained with updates being made since the previous farm visit.
Inaccuracies included the number of children found working in the field
during the assessment compared with the information recorded on the form.
This could be due to changes in work load or season since the previous visit.
Frequency of payments and direct payment: for 17% of the checked forms
these differences concerned the following inaccuracies; recorded wages
being paid on time or wages being paid directly, while workers declared theyreceipt of end of harvest or indirect payment.
Another case included a form referencing a child below 18 working on thefarm but not including their specific involvement in hazardous work as
defined by PMI.

While CU identified several risks of forced labor during the farm visits (chapter 5.4),
no issues were documented in the monitoring forms of these specific farms.
During the CU farm visits, 76% of the forms had been updated by the fieldtechnician after each visit conducted in the 2014 crop season. In their quarterly
reports, information was included on the progress regarding the information
gathered with the monitoring of farm practices. Only the results regarding theprioritized principles child labor and safe work environment were shown in theirquarterly report as these were the principles of focus.
In addition, it is not clear during which stage of tobacco production the monitoring
was being conducted. Without this information the supplier is not able to identify
how both good practices and risks change during the crop cycle and how to betterinteract with farmers to influence their behavior. For example, on one farm during
harvest, the risks of finding children involved in hazardous activities as defined by
PMI is higher compared to another farm in the growing phase.

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AOT’s response: “AOT utilizes Alliance One Internationals’ award-winning, global data collection
tool, Growers Management System (GMS), to collect, analyse and report ALP data incidents
efficiently and effectively.
In Turkey, GMS is incorporated into a handheld mobile device (smart phone) for each of AOT’s fieldtechnicians, and these technicians input data into the system as they visit each grower. The GMS
application guides the FTs through farm assessments by asking specific questions related to ALP, andthe software does not allow them to close Prompt Action issues if conditions do not meet expected
standards. For every prompt action recorded in GMS during Farm Monitoring, the AOT ALP
coordinator and GMS supervisor receive an automatically-generated email that includes incident
details. The software also offers FTs the opportunity to document positive improvements thatgrowers achieve.
GMS allows AOT FTs and management to build risk profiles for growers and provide real-time
support to help them meet GAP and ALP requirements. To date, 100% of Alliance One Turkey’s
contracted growers have profiles in GMS.”

4.2 Address widespread issues
Phase 2 requires leaf tobacco suppliers to investigate the root causes of various
challenges in the implementation of ALP often influenced by external, socioeconomic constraints. Because of their diversity, the ALP Program addresses themthrough two mechanisms. First, initiatives are implemented to mitigate specificrisks and improve the overall socio-economic conditions of contracted farms.
Second, more inclusive initiatives involving all relevant stakeholders include
projects sponsored by PMI and/or suppliers addressing problems identified at thecommunity level.
4.2.1 Investigation of root causes
As discussed in chapter 4.1.2, the analysis of Farm Profiles influenced AOT focusing
on two principles; child labor and safe work environment. In regards to children
involved with harvesting on the family farm, AOT identified two root causes. First,
farmers do not have enough money to hire external labor. Second, working at thefarm is important to learn the family business and is socially acceptable in acommunity of farmers. AOT continues to investigate the root causes of other issues
identified.
4.2.2 Initiatives to address widespread issues
AOT had developed initiatives to address both child labor and unsafe CPA andharvest practices. In chapter 5, these initiatives are described in more detail
together with the findings of the farm assessments.

4.3 Support mechanism
4.3.1 Support mechanism
At the time of the assessment, the support mechanism was not yet in place.
PHILSA was exploring different options that would address the local dynamics. The

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main focus was to establish a support line in cooperation with a specialized callcenter supported by a law firm and an independent consultant. This support line
should provide farmers and workers with advice and consultation on ALP related
matters tailored to the Turkish market. The initial scope was planned to be on childlabor, safe work environment and income and working hours.
AOT’s response: “In partnership with PMI and other stakeholders, AOT introduced a support
mechanism (CALLPEX) in pilot locations, which workers can use to voice concerns regarding ALP
principles. The Support Mechanism (SM) has a dual function: (1) to provide a more qualified opinion
on the employment conditions (by receiving the complaints from workers, replying to farmers
regarding all ALP subjects, informing people on farm on legal issues or working conditions), and (2) toprovide guidance on child labor issues. Skilled personnel, including individuals with legal background,have been hired and trained to manage potential issues that arise through the support mechanism.
When necessary, the Support Mechanism forwards more complicated legal issues to legal
consultants and any other issues to those with the qualified expertise to research further and findsolutions. In this capacity, SM personnel visit the farms (without any effort to replace Suppliers’ Farm
Monitoring program) to make their operation more open and visible in the rural areas.”

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5. Farm level assessment of ALP Code standards

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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Chapter 5 describes the findings of the field assessment and the current status of
the ALP implementation at the farm level. At the time of assessment, AOT was inPhase 2 of the ALP Program engaging directly with farmers to address any
dynamics not meeting the ALP Code standards. As AOT had just initiated Phase 2,
the farm assessment should be viewed as a baseline for supporting further
implementation.
Before presenting the findings, it is important to clarify the structure of the ALP
Code as this determines CU´s analysis of farm practices. The ALP Code (Appendix
2) has seven ALP Code Principles enshrined in short statements designed to guidefarmers on specific practices resulting in safe and fair working conditions. Each ALP
Code Principles has several Measurable Standards.
A Measurable Standard defines a good practice that 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 of thefollowing chapters includes one of the seven ALP Code Principles and CU’s findings.
It also covers the risks (situations that may lead to problems in the future or about
which a conclusion cannot be reached due to lack of evidence). As discussed in 4.2,
AOT’s initiatives to address widespread issues are also included in this chapter.
5.1 ALP Code Principle 1: Child labor
Background
Minimum age regulations: There is no age limit
for child workers subject to Code ofChild labor
Obligations, as it is not explicitly set forth
under the legislation. However, there is a
´There shall be no childlimitation for children subject to mandatorylabor.´
education. The Preliminary Education and
Education Law (Number 222) states thatchildren aged 6 to 13 are subject to mandatory
education. If a child is not pursuing mandatory
education, they cannot be employed whether
they are paid or unpaid. If a child is pursing
mandatory education, then they can be employed outside of school hours. In
addition, the ALP Code stipulates that the minimum age for child workers is 15. In
the case of family farms a child may help on their family farm provided that thework is light and the child is between 13 and 15 years old.
ALP Code Principle 1

Regulations working hours: There is no regulation of working hours for children
working subject to the Code of Obligations, as it is not explicitly covered bylegislation. Although not directly applicable, the Labor Law and the Children andYoung Employees Regulation include certain limitations in this regard; namely thatwork for children who have completed their basic education and are no longer
attending school shall not exceed 7 hours a day or 35 hours a week. For children 15
and older, this work may be increased up to 8 hours a day and 40 hours a week.
The working hours of children attending school during the school year must falloutside their training hours and shall not exceed 2 hours a day and 10 hours a
week.

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Child labor: Overall findings and challenges
5.1.1 Prevalence of children working
On 53% of the farms visited, a total of 25 children below 18 were found working. Of
these children, 7 were aged either 13 or 14 years old and 9 children were below 13
years. 92% (23) were children of the farmer. The remaining two children, aged 9
and 17, were children of a worker and therefore considered to be employed. One of
the employed children, aged 17 was working full shifts in a full time work week. The
other 24 children only worked during school holidays. All children under 15 wereattending school.

Number of children

All 25 children were involved in hazardous activities as defined by PMI. The graphbelow summarizes the activities these children performed. Note that one child canbe involved in more than one activity.
24
22
20
18
16
14
12
10
8
6
4
2
0

*Tobacco related activities defined as hazardous by PMI

5.1.2 Awareness of legal minimum working age
The majority of the farmers visited (73%) and approximately half of the workers
interviewed (47%) were aware of the communicated minimum working age of 18.
As described in chapter 3.3 on ALP communication to farmers, AOT chose tocommunicate a minimum working age of 18 for tobacco related activities, which
was more easily understood by farmers. As children were mainly involved withhazardous activities as defined by PMI, such as harvesting and stringing and bycommunicating the age of 18, farmers no longer had to navigate which lightactivities were acceptable. Setting the age at 18 is clear and definitive, however
according to the ALP Code it is allowed to involve children below 18 with certain
activities on the farm (dependent on age and type of activity). It is important forfarmers to be aware of this, so they can involve their children in cases where this isallowed according to the ALP Code.

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Initiatives to address child Labor
Loose leaf curing
During the assessment, AOT was piloting with a newtechnique for drying oriental tobacco known as ‘loose leaf
curing’. Instead of sticking tobacco leaves and threadingthem with needle and string to hang them for curing. The
loose leaves are placed in the hopper of a vento machine
and blown into a long woven net. This net can then be hungdirectly in the curing barn (see picture). By removing thetask of stringing the tobacco, loose leaf curing has thepotential to reduce the involvement of children. At the timeof the assessment Öz-Ege had distributed 75 of the loose
leaf curing machines to selected farmers.
While loose leaf curing eliminates the use of sharp needles, children could still be
involved in harvesting of tobacco leaves and feeding the curing machine. Although
this technique does not fully prevent children from coming into contact with green
tobacco leaves, this is a proactive step to mitigate the risk of child labor.
Already 10% of the farmers visited were using loose leaf
curing for part of their harvest and all of them declared theyfound the initiative useful. Farmers did not mention the
reduction of children involved in stringing as the main
reason to use the technique, however, they did say that it
enabled them to work more efficiently which reduced labor
requirements and associated costs. As farmers will need toinvest in the machine, the technique might not be
accessible for the smallest family farms.
Frame curing
AOT was piloting ‘frame curing’ as an alternate means of eliminating stringing.
Tobacco leaves were arranged on a frame and placed in the curing barn. 11% of
the farmers visited were using frame curing for part of their harvest. All of themfound the initiative useful reporting that they could work more efficiently, reducing
time and expenses.
This technique also eliminates the need for sharp needles but does not eliminate
the risk of children being involved in harvesting. It is unlikely young children will
carry the frames due to their weight, however, older children could help to load the
barn.

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Child labor: Risks
5.1.3 Awareness of hazardous work
30% of the farmers and 63% of the workers interviewed lacked awareness ofhazardous activities as defined by PMI. Those interviewees were not aware of thehealth hazards related to working with green tobacco leaves. As children are notallowed to be involved in hazardous activities it is important that farmers are able
to distinguish between hazardous and non-hazardous activities as clearly defined in
the ALP Code.
5.1.4 Underlying factors that increase risk
Additional to the two underlying factors for child labor identified by AOT (chapter
4.2.1), CU identified a third reason for involvement of children in tobacco related
activities. In order to prevent especially the younger children from being
unsupervised, their parents had them join in the tobacco field so they could bewatched.
Child labor: Analysis and Priorities
As the majority of farmers were aware of the minimum working age of 18 and thedefinition of hazardous activities as defined by PMI, AOT’s communication efforts
seem to have been effective. Conversely, the knowledge level of the workers
regarding child labor still needs improvement. To start, the knowledge transfer
between farmers and workers could be improved so that farmers create andreinforce awareness with the support of field technicians. Also, despite theawareness among farmers, many children were still found to be involved inhazardous activities as defined by PMI. Increasing communication and promoting
the spread of new curing methods could positively influence this situation.
AOT’s response:
1. “Recognizing that child labor will not be eliminated without an understanding of its root
cause, AOT is continuing to collect data in order to better understand the overall situation.
The FTs’ focus is on helping growers continuously improve their labor practices byreinforcing training related to child labor and hazardous work. Throughout the 2015 season,
FTs provided refresher training to the growers and focused on helping growers learn how to
distinguish between hazardous and non-hazardous activities (such as: extreme heat/cold,
long hours, night work, handling with dangerous equipment & toxic substances), understandthe nature or the circumstances under which hazardous tasks are carried out, andunderstand the likelihood of certain activities harming the health, safety or morals ofchildren. Examples of hazardous activities for children are visually demonstrated in the ALP
brochures that FTs provided to growers.
2. “In light of these findings, AOT has continued to introduce mechanical stringing machinesthat help AOT contracted growers minimize the risk of child labor. In total, AOT has
distributed 283 Vento machines (148 in 2014 and 135 in 2015). While AOT believes that
vento machines help reduce the risk of child labor, future rates of expansion will depend on
product quality acceptance by our customers. When compared to stringing, harvesting
requires a higher level of skill and training. To minimize the involvement of children in thistask, AOT acquired a prototype harvester (HM), specially designed for Izmir Oriental
tobacco, which is being used for mechanized harvesting trials. Although HM is still in thetrial stages, the results are very promising.”

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5.2 ALP Code Principle 2: Income and work hours
Background
Minimum salary regulations: According to theDecision of Minimum Wage Determination
Commission issued by the Ministry of Labor andSocial Security, the daily gross minimum wage
is TL 37.80. These wages are determined on a“daily” basis not on an hourly basis.
Work hour regulations: The Code of Obligations
does not set out the maximum daily or weekly
working hours for workers who are subject to
the Code of Obligations. In this case, the ALP
Code prevails and states that the maximum
regular weekly working hours should not be
more than 48 (excluding overtime). In addition,
the ALP Code determines that workers should
receive at least one resting day per week.

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
hours.’

Overtime payment regulations: The Code ofObligations (article 402) states that for overtime
work, the employer must pay the employee hisnormal salary with at least an additional fifty percent of the salary. With theconsent of the employee, the employer may give vacation days during a suitable
time in proportion to the overtime work instead of overtime payment
Benefit regulations: The Law on Social Security and General Health Insurance(number 5510) states that all workers working for a period longer than 30 days ona farm should be registered at a social security institution. The Code of Obligations
does not require the employer to provide additional benefits to the employee. The
employer is only obliged to provide employees with the benefits set out under thecontract or that are customary.
Income and work hours: Overall findings and challenges
5.2.1 Minimum salary
All farmers visited with hired labor paid their workers at least the legal minimum
wage as defined in the Decision of Minimum Wage Determination Commission(37.80 TL gross daily). Payments were in the range of 50 to 75 TL daily. At one
farm workers were paid at piece rate. These workers received 5 TL per string andwere able to complete approximately 12 strings in 7 to 8 hours of work (55-60 TL
daily).
5.2.2 Payment scheduleOn the farms visited that hired labor, the following payment schedules were found;at 25% of the farms all workers were paid weekly, at 15% of the farms all workers
were paid daily, at 15% of the farms all workers were paid end of harvest, at 25%of the farms workers were either paid weekly or daily and at 20% of the farms

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workers were paid end of harvest or weekly. In reference to end of harvest
payments, workers received advances on their salaries upon request.
5.2.3 Regular and overtime hours
At 43% of the farms visited with hired labor, workers labored for more than 48
hours a week. Moreover, on 35% of the farms that hire labor, workers did notreceive at least one resting day a week. For 40% of the farms that hired labor,
workers switched between farms during the week, making the weekly working
hours the worker’s responsibility. On the farms where hired labor reported no
resting day, workers reported to work the full season on one farm without a resting
day or they reported to only take a day off when they were sick. In several cases
workers reported they worked between 40 and 60 consecutive days. Workers
wanted to earn as much as possible during the harvest season lasting three to fourmonths (June to September). CU also identified long work hours on family farms
which did not have the financial means to hire labor.
At 31% of the farms visited that hired labor, CU noted that workers received
additional overtime payments. These are extra working hours additional to theagreed hours at the start of work. The overtime rate was equal to the regular rate
and on one farm overtime payment was paid per piece. In this case workers
received 5 TL per string. Overtime payments were not conducted according to theregulations as set forth in the Code of Obligations being the normal salary with atleast with at least an additional fifty percent of the salary. On the 22% of the farms
workers reported to not receive additional payment for extra hours and on 47% of
the farms workers reported to not work overtime hours.
5.2.4 Legal benefits
According to the Law on Social Security and General Health Insurance (number
5510) workers need to be registered in case they are employed for a period
exceeding 30 days. None of the workers interviewed during the assessment wereregistered, however 85% of the workers interviewed were employed for a period of
1 to 11 months (see chapter 2.5; figure ‘Type of Employment’). These workers
needed to be registered at a social security institution. The workers were working
without registration and did not receive any form of insurance or social security, so
were not insured for potential work related accidents and injuries. In addition to the
cash payment of their salary, workers were mainly provided with meals during the
day and in some cases with transport to the field.
Income and work hours: Risks
5.2.5 Awareness of legal minimum wage
76% of the farmers and 53% of the workers interviewed were aware of the monthly
legal minimum wage determined by the Labor Law of approximately 800 TL (netamount according to Labor Law was 891.03 TL per month). However, they were notaware on the minimum daily wage of 37.80 TL as defined in the Decision of
Minimum Wage Determination Commission issued by the Ministry of Labor andSocial Security. In any case, farmers did not use the minimum wage defined by

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Labor Law or Code of Obligations as the basis for their payments to workers. Farms
paid workers according to the market price, on average 40% higher than theapplicable legal minimum wage defined above. In one case migrant workers were
not aware of the wage they would receive at the end of the season. They received
end of season payment and worked for the full season at the same farm. In theprevious season these workers worked on the same farm and received 55 TL per
day, however the wage for the current season was not agreed upon.
5.2.6 Crew leaders
At 29% of the farms that hire labor, workers were hired via crew leaders. In thesecases, the farmer paid both a commission and wages to the crew leader. In thismodel, the farmer was not in control of the payment creating a risk for improper ordelayed payments.
AOT’s response: ”AOT encourages its contracted growers to pay workers directly or to requestthat the crew leader provide documentation to demonstrate that proper payments have been made.
Throughout the 2015 farm visits, AOT FTs worked with farmers to improve their understanding of theimportance of transparency of payments and work assignments.”

5.2.7 Record keeping
52% of the farmers visited with hired labor did not record payments made toworkers. Also, 52% of the farmers that hired labor did not record hours/days
worked or tasks completed. The farmers that paid their workers on a daily basis
found it unnecessary to record the payments. Of the farmers without proper
records of payments and hours/days worked, 38% paid their workers weekly, 12%daily, 25% either daily or weekly, 25% at end of harvest.
5.2.8 Pay slips
None of the farmers with hired labor provided their workers with pay slips. Workers
only received payments in cash.
Income and work hours: Analysis and Priorities
AOT did not identify income and work hours as a priority principle. Nevertheless, CU
identified several serious issues regarding indirect payments, working hours,
resting days and benefits for workers. In order to better understand the root causesof these situations, and thus to be able to determine whether this principle should
receive more attention, further research is required.

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5.3 ALP Code Principle 3: Fair treatment
Background
Regulations: The Code of Obligations (Article417) states that (a) the employer is obliged to
ALP Code Principle 3
take all necessary precautions in order toprotect the personal rights of the worker,
Fair treatment
respect the worker, ensure an environment in‘Farmers shall ensure fair
the workplace in line with the principles of goodtreatment of workers. Therefaith and especially to prevent the workers toshall be no harassment,
be subject to psychological abuse or sexual
discrimination, physical or
harassment and to prevent those who havementalpunishment, or any
been subject to these types of acts to suffer
other forms of abuse.’further harm from these acts. (b) The
compensation for damages arising from thebreach of provisions above and other acts ofthe employer against the law and theagreement which causes the death of the worker, damage to the physical integrityor personal rights of the worker, is subject to the provisions regarding the liability
for breach of contract.
Fair treatment: Overall findings and challenges
5.3.1 No evidence of practices suggestive of unfair treatment
CU did not identify any practices of unfair treatment such as physical, sexual andverbal abuse or any form of discrimination. As agricultural workers were relatively
scarce in the regions visited, farmers needed to provide fair working environment
so workers remain during the season and return to their farms the following
season.
Fair treatment: Analysis and Priorities
Although no issues were identified regarding fair treatment, the planned
implementation of an independent support mechanism for farmers and workers isstill an important milestone. Both support and subsequent analysis will give AOT
insight into the main challenges they face and help streamline adoption of the ALP
within their supply chain.
5.4 ALP Code Principle 4: Forced labor
Background
Regulations: Forced labor is prohibited by theTurkish Constitution (Article 18). Moreover, theTurkish Criminal Code (Article 117) states that
persons shall be subject to imprisonment oradministrative fine in case they; (1) violate thefreedom of work and employment by force or bythreat or by any act against law, or in case they;

ALP Code Principle 4
Forced labor‘All farm labor must be
voluntary. There shall be noforced labor.’

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Control Union Certifications(2) employ a person or persons by exploiting their desperateness, desolation or
dependence with a fee clearly disproportional to the work, or make the workers
subject to working and accommodation conditions incompatible with human dignity.
Forced labor: Overall findings and challenges
5.4.1 No evidence of workers unable to leave their job
All workers interviewed declared that they were free to leave their employment
with reasonable notice. None of the workers interviewed also said that they wererequired to make any financial deposits or hand in their original identity documents.
Forced labor: Risks
5.4.2 Crew leaders
As mentioned in chapter 5.2.6, at 29% of the farms visited with hired labor,
workers were hired via a crew leader. In these cases payments to the workers wereconducted via the crew leader, without the farmer having direct control. As a result,the farmer could not ensure that workers were receiving the wage they wereentitled to, with the risk of workers receiving no payment at all or a wage that was
lower than the legal minimum according to the Code of Obligations.
AOT’s response: ” As crew leaders respond to market dynamics and fluctuations in the supply
and demand of the labor force, there is a concern about individuals being forced to work against
their will. One way to minimize this risk is for growers to pay workers directly, rather than through acrew leader. AOT encourages direct payment to ensure that improper amounts are not withheld fromwages. If growers do not currently pay their workers directly, AOT field technicians encourage
growers to strive for transparency and maintain documentation of crew leaders’ proper payments toworkers.”

5.4.3 Advance payments during winterAt 21% of the farms visited that hired labor, workers received advance payments
during the winter to ensure that they would work for the farmer the following
tobacco growing season. These workers received between 30% and 80% of thewage they would make during the season. To settle their debt, they were obliged towork on the farm. Advance payments during winter were made to workers that
already worked for the farmer during the previous season(s). Migrant labor was
hired at 50% of the farms with advance payments during winter which received theadvances by mail. As well as a risk for the workers, the farmer also runs the riskthat workers do not return to work despite receiving their financial advance.
5.4.4 End of harvest payments
At 35% of the farms visited that hired labor, workers were receiving end of harvest
payments. In these cases workers also reported they could take financial advances
upon request which would be deducted from their salaries at the end of harvest. In
the case workers received end of harvest payments, they reported the option toreceive advances upon request. Migrants were working at one of the farms with endof harvest payments.

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Forced labor: Analysis and Priorities
Just as the income and work hours principle, forced labor was not considered apriority by AOT. CU did not find any evidence of workers being unable to leave theiremployment, however several important risks of forced labor that require AOT’s
attention and further investigation were identified: indirect payment through crewleaders, advances during winter, and end of the harvest payments. Root cause
analysis is required to better understand these situations and the risks involved.
5.5 ALP Code Principle 5: Safe work environment
Background
Regulations: In the Occupational Health and
Safety Code (number 6331; article 4) it statesthat employers should take all the necessary
measures for the safety and health protectionofemployees,
includingpreventionofoccupational risks and provision of informationand training and the necessary organizationand maintenance of all the needed means andtools. In turn, employees are obligated tofollow and observe all the measures taken in
the field of occupational health and safety. In
addition, employers shall notify, in written
form, any work accident and occupational
disease which occurs to the relevant regional
directorate of labor within two working days.

ALP Code Principle 5
Safe work environment‘Farmers shall provide asafe work environment toprevent accidents andinjury and to minimize
health risks.
Accommodation, where
provided, shall be clean,safe and meet the basic
needs of the workers.’

The Occupational Health and Safety Code(number 6331; article 15/2) also states that an employee shall not be engaged foror employed on any arduous or dangerous work without a certificate based on the
results of a medical examination. The medical certificate shall be obtained from an
occupational physician working in a health and safety unit or joint health and safetyunit. Any objection to the medical certificates shall be filed to an adjudicatorhospital assigned by the Ministry of Health. The decision made by at a hospital shallconstitute the definitive judgment.
In addition (Occupational Health and Safety Code; number 6331; article 13), any
employee faced with an imminent, urgent and life-threatening danger which may
do harm to his health or endanger his body integrity may make an application tothe occupational health and safety board / or in the absence of such board to theemployer with a request for the determination of the case and a decision for the
adoption of necessary measures. In the event the board takes a decision consistent
with an employee’s request, the employee may refrain from working until thenecessary occupational health and safety measure is taken. The employee’s wages
and other rights shall be reserved during the period he refrains from working.

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Safe work environment: Overall findings and challenges
5.5.1 Training and awareness of Green Tobacco Sickness (GTS)
67% of the farmers and 10% of the workers interviewed were aware of theexistence and symptoms of GTS. The remaining farmers and workers did not knowwhat GTS was and how they could protect themselves against harm. In the field,
workers declared they used long sleeves (70%), long pants (57%) and gloves(13%). However, they only partially mentioned GTS as the reason to use theprotective clothing. In most cases, persons involved in harvesting reported theywear the clothing to prevent their skin from getting sticky from handling the
tobacco leaves. Additionally, at 14% of the farms visited, in total four
pregnant/nursing women were involved in harvesting and three of them were also
involved in stringing of tobacco leaves. In two of these cases, they were notwearing proper protective clothing for harvesting wet tobacco.
5.5.2 CPA handling and training
During the assessment, no CPA spraying was observed in the field at the farms
visited. Therefore CU did not find any evidence that persons who apply chemicals
do not wear the proper PPE. At 52% of the farms visited, persons involved inhandling or applying chemicals were specifically trained on how to perform theirduties. In all of the cases where training was given, the farmer was trained. On
three farms, family members were also trained (21%).
As protection, persons involved in CPA application declared to use gloves (70%),
mask (70%), overall/apron (33%), boots (37%) and goggles (33%). The main
reported reason for not wearing goggles was that they were uncomfortable to wearand got foggy. Only one farmer reported using a thick rubber overall to protect
himself during CPA application.
68% of the farmers reported to respect the re-entry period after CPA application.
They verbally informed their family members and workers not to enter into thefield. 10% of these farmers reported to use warning signs after CPA application.
5.5.3 CPA storage and disposal
33% of the farmers visited did not store their CPA’s safely. The remaining farmers
did not have a closed and locked CPA storage. CPA bottles were found stored on
open shelves or inside plastic bags. This posed a significant safety risk especially ifchildren had access, which was the case at 25% of the farms with improper CPA
storage. CU also identified a case in which CPA’s were stored in an old refrigerator.
35% of the farmers visited did not discard empty CPA containers correctly. These
farmers discarded them with regular garbage or dumped them in a river or forest.
Without a collection system in place, farmers were burning or piercing and burying
their bottles. The latter was at the time of the assessment considered to be thebest option. 8% of the farmers visited declared to triple wash the CPA containers
before disposal.

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Initiatives to address unsafe farm practices
PPE setWith the aim of improving safety practices at thefarms, AOT distributed a PPE set to their farmers.
Of the farmers visited, 87% reported they hadreceived the set. This set was meant to improvethe usage of PPE and contained goggles, overall
for single use (while CPA was generally applied
more often), a mask for CPA application andreusable rubber gloves.
96% of the farmers that received the PPE set
declared they found this initiative useful to createawareness and reported the need for protection
against chemicals. It seems that the distribution
had a positive effect on the usage of PPE. Of the
farmers that found the initiative useful, 91%
reported using gloves, 91% reported using amask, 41% reported using goggles and 41%
reported to use the overall during CPA
applications.

PPE set
CPA lockup
By providing a CPA lockup box to the farmers,
AOT aimed to improve CPA storage practices.
66% of the farmers visited had received the CPA
lockup. Farmers acknowledged that proper
storage of CPA’s was important for their safety
and they wanted to prevent their children fromreaching the chemicals. Accordingly, 95% of the
farmers that received the CPA lockup declared
they found the initiative useful and 83% stored
chemicals in a closed and locked storage facility.
As this is an increased percentage and is higher
over the farmers referenced in chapter 5.5.3.,
this reflects a positive impact of the proper
storage of CPA.
CPA recording books

CPA lockup
AOT distributed CPA recording books to their
farmers to improve recording of CPA applications.
Of the farmers visited, 53% reported receipt of the CPA recording book. 56% of
the farmers who received the recording book declared they found this initiative
useful and mentioned that it helped them to trace CPA applications between fields
as well as to remember application dates. Of the farmers that found the initiative
useful, 80% recorded CPA applications to their tobacco field. The remaining 44%of the farmers did not see the benefit of recording CPA applications or forgot torecord these applications.

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5.5.4 Housing
For two of the three farms visited with migrant workers, CU verified housing
conditions. In these cases farmers provided decent housing to workers, being clean
with access to a washing machine, TV and bathroom with toilet. As previously
mentioned, the scarcity of agricultural labor requires farmers to provide goodworking and living conditions.
5.5.5 Clean drinking and washing water
All farmers visited provided clean drinking water near the field. At only 7% of thefarms visited, no washing water and/or soap was found close to the working area.
Soap and water are needed to wash the skin after contact with green tobacco
leaves and lower the risk of GTS.
Safe work environment: Risks
5.5.6 General safety measures
To ensure a safe and sanitary work environment for both family members andworkers, it is important that farmers are aware of general safety hazards at thefarm and take measures to prevent accidents, injury, and exposure to health risks.
CU identified the following issues:

77% of the farmers visited did not store all their equipment and tools safely.
At 35% of these farms, this may pose a risk to children with free access tothe farm.
93% of the farmers visited did not provide a first aid kit at the farm.
Safe work environment: Analysis and Priorities

AOT’s focus on CPA and PPE practices seems to have had a positive effect on theawareness of farmers. The majority of farmers were aware of how to store CPA andhow to protect themselves against the hazard of working with chemicals and green
tobacco. Conversely, worker’s awareness was found to be much lower indicatingpoor knowledge transfer between farmers and workers regarding safe working
practices at the farm.
Most important, AOT’s initiatives have improved three practices of its farms. First
distribution of CPA lockups has influenced the storage of chemicals in a safer way.
Second, the provision of PPE sets has also improved the protection against
chemicals. However, the farmer’s usage of goggles continues to lag. Finally, theinitiative to provide a CPA record book has initiated positive record keeping. While
the adoption rate needs to increase, more guidance to farmers can influence
farmers to adopt better record keeping practices. Additional focus could be made on
general safety on the farm. Generally, there is room for improvement to eliminate
tools lying around and the purchase and training on how to use first aid kits.

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AOT’s response:
1. ” AOT plans to expand STP projects in this area. These initiatives include the distribution of
CPA lockers, PPE sets and first-aid kits to growers.”
2. “..the toolbox has been updated to include new communication material (brochures andleaflets) on GTS and Farm Safety and Health to educate and protect workers on the farm. A
key holder with emergency contact phone numbers was distributed to farmers and workers
to further raise awareness.”

5.6 ALP Code Principle 6: Freedom of association
Background
Regulations: The Turkish Constitution (article 33) states that everyone has the rightto form associations, to become a member of an association and to withdraw frommembership without prior permission. The
Turkish Constitution (article 55) also states that
ALP Code Principle 6
employees have the right to form trade unions
without obtaining permission and they have theFreedom of associationright to become a member of a union and thatthey can freely withdraw from membership. No‘Farmers shall recognize
one shall be forced to become a member of aand respect workers’ rights
union or to withdraw from membership. A person
to freedom of association
who
prevents
workersfromjoiningor
and to bargain collectively.’
participating in a trade union conducts a crime
according to the Turkish Criminal Code (article
118).
Freedom of association: Overall findings and challenges
5.6.1 Workers´ right to freedom of association
CU found no evidence of farmers disrespecting workers´ right the freedom of
association. There were also no associations or unions active for workers on
tobacco farms.
Freedom of association: Risks
5.6.2 Awareness of freedom of association
Most of the farmers (90%) and workers (94%) were unaware of the workers’ rightto freedom of association and the purpose it served. They did not understand what
benefits an association could provide to them.
Freedom of association: Analysis and Priorities
As no labor unions or worker associations are present in the visited regions, thisprinciple is rather abstract for both farmers and workers. As mentioned before, also
field technicians had difficulties understanding the concept of freedom of
association.

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5.7 ALP Code Principle 7: Compliance with the law
Background
Regulations: As the farmers included in thescope of this assessment employed less than 50
ALP Code Principle 7
workers, local Labor Law does not apply. In
these cases, the Code of Obligations (number
Compliance with the law6098) applies to workers on tobacco farms. This
‘Farmers shall comply withcode states that if an undetermined term
all laws of their country
contract has been in force up to than 1 year, therelating to employment.’
contract can be unilaterally terminated following
two weeks terminations notice. If the contract
has been in force from 1 to 5 years, thecontracts can be unilaterally terminated four
weeks
followingthetermination
notice.
Furthermore, it is not required by the Code ofObligations to conclude an employment agreement in writing.
Compliance with the law: Overall findings and challenges
5.7.1 Information on legal rights
Farmers and workers generally agreed verbally upon the type of work, the work
hours and the wage. No further legal rights such as legal minimum wage andregistration with the social security institution were discussed.
Compliance with the law: Analysis and Priorities
As the Labor Law is not applicable to the workers at the farms, farmers must beaware of the regulations included in the Code of Obligations. Any support from AOT
could be focused on assisting farmers to understand their obligations and theircommunication of these legal rights to their workers. At the time of theassessment, workers were verbally informed about the type of work, the work
hours and the wage they would earn.
AOT’s response: ” To encourage compliance with employment laws, it is critical that growers
understand that they are employers and, therefore, have legal obligations to their employees. All
AOT contracted growers are required to comply with all applicable laws, including labor laws.”

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6. Concluding remarks

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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Significant progress had been made towards the full implementation of Phase 2 of
the ALP Program. At the time of the assessment AOT had all the required ALP
procedures in place with the plan to implement a digital system (GMS) to collect alldata relevant to the ALP. CU identified room for improvement in the following key
areas.
First, while AOT’s focus has been understandably on the chosen principles of childlabor and safe work environment as CU identified issues and risks in these areas,
additional issues and risks were identified regarding income and work hours andforced labor in the visited regions.
Second, investigation is required to better understand the risks involved with thepayments to workers. This includes crew leaders in control of payment to workers,
workers receiving end of harvest payments and advance payments during thewinter.
Third, field technicians need to improve their knowledge on the non-prioritized ALP
Code Principles to assure reliable monitoring on the full ALP Program.
Fourth, the use of the monitoring forms to collect quality data from farmers tobetter analyze causal behavior must be improved because qualitative reporting ispoor, without description of the context of a situation identified not meeting thestandard.
Finally, record keeping must be improved at the farm level referencing both
payments and work assignments. While CU found workers to be paid above thelegal minimum wage, records would ensure complete transparency.
Most important, AOT initiated several initiatives to improve the working
circumstances on their network of farms. By investing in both new relationships andpromising initiatives, AOT can expect continuous improvement in production that
benefits from a complete implementation of the ALP Code Principles.

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Appendices

THIRD PARTY ASSESSMENT
ALLIANCE ONE TURKEY
Tavas and Muğla regions
AGRICULTURAL LABOR PRACTICES (ALP) PROGRAM

DRAFT

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Appendix 1. AOT’s response and ALP Program action plan

Alliance One Turkey (AOT) welcomes Control Union’s (CU) comprehensive report from theAgricultural Labor Practices (ALP) assessment conducted in the Tavas and Mugla regions.
Findings and insights from the assessment will help AOT further improve and strengthen theimplementation of its ALP program.
AOT appreciates CU’s recognition of the Company’s extensive efforts in planning andimplementing the ALP program, but also acknowledges that there remains room for
improvement.
Many of the issues identified by CU during the assessment must be addressed within thecontext of the socio-economic and cultural conditions present in the Turkish tobacco-growing
communities. While it takes time and resources to resolve these issues, AOT is fully committed
to tackling these challenges by identifying the root causes at farm-gate level and by proposing
sets of tangible solutions with measurable results over time. AOT recognizes that developing
solutions to these challenges often involves engaging with a wide range of stakeholders,
including governments, local communities, NGOs, and we look forward to continuing to workwith these organizations in the future.
AOT’s objective is to achieve long-term sustainability of tobacco production in Turkey, while
ensuring that all of its contracted growers meet the standards set forth in Good Agricultural
Practices (GAP), which includes the ALP Code, and they make continuous improvement toward
the implementation of its principles.
1. Comments and acknowledgements

a. People & Commitment

Alliance One Turkey Management and the ALP team remain committed to the ALP code andare focused on progressively eliminating child labor and all labor abuses from the farms where
AOT sources tobacco. In 2014, AOT aligned its ALP Country Team structure with its GAPCountry Team structure, enabling AOT to fully integrate ALP into its existing GAP program.
Additional operational initiatives included:••

Alliance One Turkey Management reviewed the operational model of the Leaf andAgronomy Team to better incorporate the work load and assignments necessary toachieve ALP and GAP Program objectives; andAlliance One Turkey Management provided refresher trainings to field technicians(FTs) on all ALP principles, as a response to the new operational needs.

In its report, CU expressed its positive appreciation of the current processes in place and thelevel of commitment of AOT’s team. What became apparent from the assessment was thenecessity to improve our FTs understanding of:46

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The ALP principles, particularly Income and Work Hours and Forced Labor as thosewere not chosen areas of focus during the initial phases of ALP implementation;
andIssues that require FTs to follow the Prompt Action escalation process.

To address these concerns, the ALP Country team reiterated the importance of each ALP
principle during AOT’s April 2015 refresher training. In May 2015, the Company also provided
additional training on the prompt action escalation process that should be followed as serious
issues arise.
In order to encourage FTs to continue to improve their understanding of ALP and enhance
farmers’ compliance with the ALP program, AOT is considering implementation of a reward
system associated with FT performance.
b. Communication Procedures

As noted in CU’s report, AOT has developed solutions that support field technicians’ (FT)
efforts in addressing labor abuses where they are found. Initiatives aimed at improving safety
on the farms and providing ways for tobacco farmers and farmworkers to voice their concerns
include:•Providing Personal Protective Equipment (PPE) sets for 2,700 farms in 2015 (7,052 intotal over the last two years)•

Providing CPA lockers for 2,065 farms in 2015 (5,565 in total over the last two years)•

Providing 135 vento machines in 2015 (283 machines in total over the last two years)•

Introducing a support line mechanism in key growing areasProviding a key holder that includes emergency telephone numbers and text aboutfirst-aid kit importance (At least one key holder was distributed to all contracted
farms, for a total of 8,100 key holders)Given the dynamic nature of tobacco farms, together with socio-economic changes in tobaccofarming communities, AOT makes continual adjustments to the materials in its ALP toolbox tobetter meet the needs of the growers and their communities as well as to address the findingsof the CU report and new Company initiatives.
The 2015 toolbox was furnished with the below items:•

Brochures that include information about all ALP principles•

Mobile devices equipped with AOI’s Growers Management System (GMS) to help FTs
monitor farms and capture farm profile data.

•

Directives on Prompt Action escalation process•

2015 Prompt action lists•

Separate brochure on Green Tobacco Sickness (GTS)47

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Awareness booklet on health and safety issues (providing real life examples)•

Detailed information related to the Income and Work Hours principle (includingreference to laws)c.

Farm Monitoring Tools

In 2015, AOT monitored 100% of its contracted farmers 4 times in different stages of theseason: seedbed, field, harvesting and curing, and storing and boxing. During each farm visit,
AOT FTs collected farm profile information and monitored growers for compliance with the
ALP program. The Child Labor and Safe Work Environment principles were monitored on 100%of the farmer base, and the Income and Working Hours Principle was monitored on 100% of
the farms that hired labor.
As stated in the CU report, there is a low risk that there will be labor issues related to theprinciples of Fair Treatment, Forced Labor, Freedom of Association and Compliance with Law.
Therefore, a random sample of 15% of the farms that used hired labor in 2015 were monitored
for compliance with these principles. On the remaining farms, Field Technicians followed theprinciple "eyes and ears open" in order to mitigate blind spots. In the future, the sampling of
farmers monitored for these principles will be different than current years, as this process willallow us to monitor all farms for compliance within a set period of time. AOT plans to continue
the same farm monitoring strategy in the future. FTs will continue to collect and update farm
profile data on an annual basis.
CU assessment also identified that the quality and accuracy of grower data was an area for
improvement, particularly as growers do not always provide accurate information. AOT utilizes
Alliance One Internationals’ award-winning, global data collection tool, Growers Management
System (GMS), to collect, analyse and report ALP data incidents efficiently and effectively.
In Turkey, GMS is incorporated into a handheld mobile device (smart phone) for each of AOT’s
field technicians, and these technicians input data into the system as they visit each grower.
The GMS application guides the FTs through farm assessments by asking specific questions
related to ALP, and the software does not allow them to close
Prompt Action issues if conditions do not meet expected
standards. For every prompt action recorded in GMS during
Farm Monitoring, the AOT ALP coordinator and GMS
supervisor receive an automatically-generated email that
includes incident details. The software also offers FTs theopportunity to document positive improvements that growers
achieve.
GMS allows AOT FTs and management to build risk profiles forgrowers and provide real-time support to help them meet GAP
and ALP requirements. To date, 100% of Alliance One Turkey’s
contracted growers have profiles in GMS.

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2. Action Plan

The AOT ALP Country Team has developed an action plan in response to CU’s assessment
findings. As previously stated, for the 2015 crop, AOT monitored all of its contracted farmers
four times during different tobacco growing stages, and AOT plans to continue the same
strategy on farm monitoring in 2016 and in the future.
AOT’s action plan for each principle is listed below:•

Child Labor

Alliance One does not tolerate child labor at any of its contracted farms. Prior to the start of
the growing season, AOT provides training on this topic and the potential risks, as well as thePrompt Action escalation process. For the 2015 crop, refresher trainings took place in April andMay.
Recognizing that child labor will not be eliminated without an understanding of its root cause,
AOT is continuing to collect data in order to better understand the overall situation. The FTs’
focus is on helping growers continuously improve their labor practices by reinforcing training
related to child labor and hazardous work. Throughout the 2015 season, FTs provided
refresher training to the growers and focused on helping growers learn how to distinguishbetween hazardous and non-hazardous activities (such as: extreme heat/cold, long hours,
night work, handling with dangerous equipment & toxic substances), understand the nature or
the circumstances under which hazardous tasks are carried out, and understand the likelihoodof certain activities harming the health, safety or morals of children. Examples of hazardous
activities for children are visually demonstrated in the ALP brochures that FTs provided to
growers.
The CU assessment found that stringing and harvesting are the most common hazardous
activities that children are involved with, and this mirrors the findings of AOT’s own farm
monitoring. Of the two tasks, AOT’s data shows that stringing is the hazardous task children
are mostly likely to be involved with because this task does not require any additional training
or experience.
In light of these findings, AOT has continued to introduce mechanical stringing machines that
help AOT contracted growers minimize the risk of child labor. In total, AOT has distributed 283
Vento machines (148 in 2014 and 135 in 2015). While AOT believes that vento machines help
reduce the risk of child labor, future rates of expansion will depend on product quality
acceptance by our customers.
When compared to stringing, harvesting requires a higher level of skill and training. To
minimize the involvement of children in this task, AOT acquired a prototype harvester (HM),specially designed for Izmir Oriental tobacco, which is being used for mechanized harvestingtrials. Although HM is still in the trial stages, the results are very promising.
AOT has also worked with stakeholders to develop community programs that provide
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village authorities, a pilot society contribution program, “Eğlenceli Bilim Köyümüzde,” has been
established in the Tavas region (Yahşiler, Çalıköy, Sofular, Ebecik villages). This program offers
children with the opportunity to participate in activities such as playing, drawing, dancing, etc.
rather than work in tobacco fields.
AOT monitored 100% of its contracted farms in 2015 for compliance with this principle, andwill continue that approach in the future.
•

Income and Work Hours

Control Union identified several issues regarding indirect payments, working hours, restingdays and benefits for workers. To address these concerns and better understand the root
causes, AOT monitored 100% of its contracted farms that used hired labor in 2015 forcompliance with this principle. AOT recognizes that not all issues are black and white, and thatsome problems may arise because a grower or crew leader is unaware that their practices are
not in compliance or because there are some unusual circumstances. AOT’s long-term target(which is an ALP objective as well) is to always help farmers improve their labor practices andcollaboratively work with farmers to develop solutions to issues as they arise.
In partnership with PMI, Alliance One Turkey developed a clearer explanation of the country’s
laws regarding minimum wages, holidays and working hours based on the Law (code ofobligation, number 6089). In June 2015, AOT provided refresher training to its FTs which
expanded on the explanation of the country’s laws. The training also provided details
regarding the prompt action process to be followed when issues are identified. After the
Turkish Government increased the minimum wage rates in July 2015, the FT toolbox was
updated to reflect the recent statutory clarification.
During 2015 farm visits, FTs provided Income and Work Hours refresher training to farmers on
an individual basis. FTs provided farmers with the ALP brochure and shared additional
information about the country’s laws regarding wages, holidays and working hours.
CU noted a particular concern regarding the transparency of crew leaders’ payments toworkers. In Turkish agriculture, it is common practice for farmers to use crew leaders to source
their work force, something that suits both the farmers and the workers. Tobacco farmers
utilize crew leaders to ensure they do not need to worry about finding workers or if they willshow up to work. Crew leaders also bring workers to the farmers’ fields, which is convenient
for the farmers. Working with a crew leader allows the workers to know that they have a more
continuous source of income (the crew leader acts as an agent, providing multiple work
opportunities to the worker, and not limited to one farmer or to one crop). To minimize risk inthis area, AOT encourages its contracted growers to pay workers directly. However, if crewleader is paying workers on the farmers’ behalf, AOT requests that the crew leader provides
documentation to demonstrate that proper payments have been made. Throughout the 2015
farm visits, AOT FTs worked with farmers to improve their understanding of the importance oftransparency of payments and work assignments. Specific areas of focus included:

An explanation of the type of records farmers can keep to track and give bettertransparency; andEmphasis on proper record-keeping to help farmers to better manage their expenses.
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Farm monitoring data from the 2015 crop season depicts that there were no incidents related
to payment from crew leaders.
To obtain further information on the use of crew leaders and their workers at the farm level
during 2015 farm visits, specific surveys were conducted:
Crew Leaders:
AOT interviewed five crew leaders in Tavas, Karacasu and Acipayam areas, regarding payments
and transparency. All five crew leaders confirmed that:

they provide transportation/logistic services and this is the service that they are paid
for; andworkers know and understand the nature of the transaction between the farmer andthe crew leader.

AOT’s FTs advised crew leaders that it would be more appropriate to receive only theircommission / logistic fee from the farmers and that workers should receive their wages fromthe farmers directly.
Farmers and workers:
32 farmers and their 112 workers in Manisa, Karacasu, Gordes, Esme, Kula, Bergama, Kale,
Tavas, Mugla, Demirci, Acipayam were interviewed about payments via crew leaders.
Farmers stated:

it is easier to work with crew leaders to solve their labor requirements logistically;
there is no harm in paying crew leaders because they believe the workers receive
their wages without any problem; andthey confirmed with workers the level of final payment received from crew leaders.

Workers stated:that the system is working for them;
they understand how much crew leaders make and how much they are supposed toreceive;
they prefer to work with crew leaders because they do not worry about obtaining
money from farmers and there is always available work for them; andthey do not need to worry about transportation.

AOT will revisit the issue in the 2016 season to obtain additional data. AOT will also work with
farmers to increase direct payments to workers and prepare a basic form for farmers to keep
records.
•

Fair Treatment

In May 2015, AOT provided refresher training to its FTs to help them better understand how to
mitigate the risks associated with this principle. The education also included further training on
the Prompt Action process.
In partnership with PMI and other stakeholders, AOT introduced a support mechanism(CALLPEX) in pilot locations, which workers can use to voice concerns regarding ALP principles.
The Support Mechanism (SM) has a dual function: (1) to provide a more qualified opinion on
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the employment conditions (by receiving the complaints from workers, replying to farmers
regarding all ALP subjects, informing people on farm on legal issues or working conditions),and (2) to provide guidance on child labor issues. Skilled personnel, including individuals withlegal background, have been hired and trained to manage potential issues that arise throughthe support mechanism. When necessary, the Support Mechanism forwards more complicatedlegal issues to legal consultants and any other issues to those with the qualified expertise toresearch further and find solutions. In this capacity, SM personnel visit the farms (without any
effort to replace Suppliers’ Farm Monitoring program) to make their operation more open andvisible in the rural areas.
The mechanism started to operate in Tavas in April 2015 and has since been extended to theareas of Kale, Karacasu, Acipayam, Bozdogan, Denizli, which covers approximately 3,000 farms.
An experienced consultant was hired to stay in the pilot areas for three months to organize
group meetings and individual farm visits to explain ALP principles as well as inform growers
and workers about the objectives of the support line. Posters that provide details about the
support line are publicly displayed in areas visible to growers and workers, and leaflets withsimilar information were also distributed throughout the areas. Text SMS messages were sent
to all farmers in the target area.
The SM consultant reached approximately 1,150 farmers in 67 villages during 2015.
Due to the low risk for this Measurable Standard, farm monitoring for compliance with this ALP
Code principle was monitored in a random sample of 15% of the farms that hired labor in2015. For the remaining farms, Field Technicians followed the principle "eyes and ears open"
in order to mitigate issues. AOT will continue this approach in 2016.
•

Forced Labor

AOT provided refresher training to its FTs in May 2015 to help them better understand how to
mitigate the risks associated with this principle and included further guidance on the Prompt
Action process.
As crew leaders respond to market dynamics and fluctuations in the supply and demand of thelabor force, there is a concern about individuals being forced to work against their will. One
way to minimize this risk is for growers to pay workers directly, rather than through a crewleader. AOT encourages direct payment to ensure that improper amounts are not withheld
from wages. If growers do not currently pay their workers directly, AOT field technicians
encourage growers to strive for transparency and maintain documentation of crew leaders’proper payments to workers. As previously mentioned (under Income and Work Hours), no
issues have been observed so far but AOT is aware that there may be a risk if the market
dynamics change. Therefore FTs will also be trained using possible examples so they pay more
attention to the subject and encourage farmers for direct payment.
Due to the low risk for this Measurable Standard, farm monitoring for compliance with this ALP
Code principle was monitored in a random sample of 15% of the farms that hired labor in2015. For the remaining farms, Field Technicians followed the principle "eyes and ears open"
in order to mitigate issues. AOT will continue this approach in 2016.
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Safe Working Environment

In line with CU’s analysis of the effectiveness of AOT’s initiatives focused on farm safety
improvements, AOT plans to expand STP projects in this area. These initiatives include the
distribution of CPA lockers, PPE sets and first-aid kits to growers. These tools will help minimize
safety risks for all those working in the tobacco farms. The number of CPA lockers and PPEs
distributed to farmers in 2015 was almost double the amount provided in 2014 (3,200 CPA
lockers in 2014 and 2,100 in 2015; 2,700 PPE sets in 2014 and 4,352 in 2015). First-aid kits
were also distributed to the majority of contracted farmers (75%). Field technicians aremonitoring the use of the CPA lockers, PPE sets and first aid kits and the results are very
positive (66% incremental use of PPEs, 40% improvement in CPA storage). The situation willcontinue to be monitored in the coming crop seasons and FTs will revisit farmers who have notyet made use of the tools provided to raise awareness.
As previously stated, the toolbox has been updated to include new communication material(brochures and leaflets) on GTS and Farm Safety and Health to educate and protect workers on
the farm. A key holder with emergency contact phone numbers was distributed to farmers andworkers to further raise awareness.
FTs received refresher training in May 2015 on this principle and the Prompt Action escalation
process. AOT monitored 100% of its contracted farms in 2015 for compliance with thisprinciple, and will continue this approach in the future.
•

Freedom of Association

Alliance One fully supports the right to freedom of association and collective bargaining andrecognizes the importance of these rights for farmworkers. As noted by CU, “as no labor
unions or worker associations are present in the visited regions, this principle is rather abstract
for both farmers and workers.” However, AOT provided refresher training to its FTs in May
2015 to help them better understand the concept of freedom of association and how to
mitigate any risks associated with this principle. The education also included further training
on the Prompt Action process.
Due to the low risk for this Measurable Standard, farm monitoring for compliance with this ALP
Code principle was monitored in a random sample of 15% of the farms that hired labor in2015. For the remaining farms, Field Technicians followed the principle "eyes and ears open"
in order to mitigate issues. AOT will continue this approach in 2016.
•

Compliance with the Law

To encourage compliance with employment laws, it is critical that growers understand thatthey are employers and, therefore, have legal obligations to their employees. All AOT
contracted growers are required to comply with all applicable laws, including labor laws. AOT
provided refresher training to its FTs in June 2015 to help them better understand how to
mitigate the risks associated with this principle. The education also included further training on
the Prompt Action process. To improve farmer communication, the daily contact between FTs
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and farmers and the relaying of the spirit of this principle, AOT strongly supports and promotes
the expansion of the support mechanism. This has been established in the focus growing
areas, and urges farmers to contact the SL personnel who can provide answers to Legal andCompliance issues.
Due to the low risk for this Measurable Standard, farm monitoring for compliance with this ALP
Code principle will be monitored for a random sample of 15% of the farms that hired labor in2015. For the remaining farms, Field Technicians will follow the principle "eyes and ears open"
in order to mitigate blind spots.
3. Conclusion

Alliance One is committed to eliminating child labor and other labor abuses where they arefound by working with its contracted growers to continuously improve labor practices at theirfarms. The Company appreciates CU’s acknowledgment of the impact of several initiatives toimprove the working conditions in our farm base as well as the progress made towards the full
implementation of Phase 2 of the ALP program. AOT will continue to monitor 100% of its
contracted farms for compliance in the priority areas of Child Labor and Safe Work
Environment, 100% of contracted farms that hire labor for compliance with Income and Work
Hours, and a random of sampling of 15% of contracted farms that hire labor for compliancewith the remaining principles. The additional material in the ALP toolbox, more focusedtraining sessions for FTs, enhanced farmer communication, and improved farm monitoring
through GMS will help AOT achieve its objectives.
As Phase 2 of ALP is further implemented, AOT will continue to focus on strengthening its FTs’
understanding of all ALP principles and the importance of understanding the root causes of
any issues. By collaborating with contracted growers to review their practices against ALP Coderequirements and make changes accordingly to ensure compliance, Alliance One will continue
its efforts to continuously improve agricultural labor practices and progressively eliminate anylabor abuses where they are found.

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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 foradmission to work is not less than the age for the completion of compulsory
schooling and, in any case, is not less than 15 years or the minimum age
provided by the country’s laws, whichever affords greater protection. 102) 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 15 11
years or above the minimum age for light work as defined by the country’slaws, 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 the generationof 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.

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.

10

As an exception, pursuant to ILO Convention 138, developing countries may under certain circumstances specify a minimum ageof 14 years.
11
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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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, social origin, disability, sexual orientation, 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.
Measurable Standards:
1) Workers do not work under bond, debt or threat and must receive wages
directly from the employer.

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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 andto minimize health risks. Accommodation, where provided, shall be clean, safe andmeet 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 healthrisks.
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 firstreceived 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.
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.

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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 whenrequired by a country’s laws and workers receive a copy of the contract.
3) Terms and conditions of employment contracts do not contravene thecountry’s laws.

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