THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES CODE

Control Union Certifications
Meeuwenlaan 4-68011 BZ ZWOLLE
Netherlands

February 2014

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TABLE OF CONTENTS

1.

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

ULT ASSESSMENT: SCOPE AND METHODOLOGY ................................................... 8
2.1 OPENING MEETING .......................................................................................................................... 9
2.2 STAFF INTERVIEWS AND ALP PROGRAM DOCUMENTATION ......................................................... 9
2.3 FARM SAMPLE SELECTION ............................................................................................................. 10
2.4 FARM VISITS .................................................................................................................................. 11
2.5 EXTERNAL WORKERS AND FAMILY MEMBERS OF THE FARMERS INTERVIEWED.......................... 11
2.6 CLOSING MEETING ........................................................................................................................ 12
2.7 PREPARATION OF THE FINAL REPORT ........................................................................................... 12

3. ASSESSMENT IMPLEMENTATION PHASE 1 OF THE ALP PROGRAM .............. 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 ........................................................ 16
3.2.3 ALP training, roles and responsibilities ........................................................ 16
3.3 COMMUNICATING THE ALP CODE REQUIREMENTS TO ALL FARMERS ........................................ 17
3.3.1 The ALP communication strategy ................................................................... 17
3.3.2 Unregistered farmers .......................................................................................... 19
3.3.3 ALP communication methods and materials .............................................. 19
3.3.4 Understanding and perception of the ALP Program ................................ 21
3.4 BUILDING FARM PROFILES FOR ALL CONTRACTED FARMS ......................................................... 22
3.4.1 Data gathering system for Farm Profiles .................................................... 23
3.4.2 Accuracy Farm Profiles ....................................................................................... 23
3.5 PROMPT ACTIONS .......................................................................................................................... 24
3.5.1 Prompt Action reporting mechanism ............................................................ 25
3.6 SUPPORT MECHANISM (PHASE 2 REQUIREMENT) ....................................................................... 25
3.6.1 Pilot in Tabora region.......................................................................................... 25
4.

FARM LEVEL ASSESSMENT OF ALP CODE STANDARDS ................................... 27
4.1 ALP CODE PRINCIPLE 1: CHILD LABOR ...................................................................................... 28
4.1.1 Prevalence of children working ....................................................................... 29
4.1.2 Underlying factors that increase risk ............................................................ 31
4.1.3 Awareness of hazardous work ......................................................................... 31
4.1.4 Awareness of legal minimum working age ................................................. 32
4.1.5 Age verification ..................................................................................................... 32
4.2 ALP CODE PRINCIPLE 2: INCOME AND WORK HOURS ............................................................... 32
4.2.1 Minimum salary ..................................................................................................... 33
4.2.2 End-of-the-harvest payments ......................................................................... 33
4.2.3 Regular and overtime hours ............................................................................ 34
4.2.4 Legal benefits ........................................................................................................ 34
4.2.5 Awareness of legal rights .................................................................................. 34
4.2.6 Record keeping ..................................................................................................... 34
4.3 ALP CODE PRINCIPLE 3: FAIR TREATMENT ................................................................................ 35

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4.3.1 Two cases of verbal harassment .................................................................... 36
4.4 ALP CODE PRINCIPLE 4: FORCED LABOR ................................................................................... 36
4.4.1 Migrant workers unable to leave their job .................................................. 37
4.4.2 Unethical employment practices .................................................................... 38
4.4.3 Cultural practices ................................................................................................. 38
4.5 ALP CODE PRINCIPLE 5: SAFE WORK ENVIRONMENT ............................................................... 38
4.5.1 Training and awareness of Green Tobacco Sickness .............................. 39
4.5.2 CPA handling and training ................................................................................ 40
4.5.3 Clean drinking and washing water ................................................................ 41
4.5.4 Worker accommodation ..................................................................................... 41
4.5.5 General safety measures .................................................................................. 41
4.5.6 CPA record keeping ............................................................................................. 42
4.6 ALP CODE PRINCIPLE 6: FREEDOM OF ASSOCIATION ............................................................... 43
4.6.1 Labor unions........................................................................................................... 43
4.6.2 Worker representatives ..................................................................................... 43
4.6.3 Awareness of freedom of association ........................................................... 44
4.7 ALP CODE PRINCIPLE 7: COMPLIANCE WITH THE LAW ............................................................. 44
4.7.1 Statement of particulars .................................................................................... 45
4.7.2 Awareness of legal rights .................................................................................. 45
5.

CONCLUDING REMARKS ................................................................................................. 47

APPENDICES ................................................................................................................................. 49
APPENDIX 1. ULT RESPONSE AND ALP PROGRAMME ACTION PLAN ................................................ 50
APPENDIX 2. ALP CODE ...................................................................................................................... 66

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GLOSSARY OF TERMS and ACRONYMS
ALP
ALP Code
ALP Code Principle
ALP Country Team (or CT)
ALP Program
ALP Technician
ATTT
CA
CU
Contact farmer
CPA
EHS
ELRA
Family farm
Farm Profiles

FCV
LT
GAP
GTS
Leaf tobacco supplier
Migrant labor

Measurable Standard

NGO
OC
Phase 1
Phase 2
Piece work
PMI
PPE
Primary Society
Prompt Action

Sharecropping

STP
Support mechanism

TTB
ULT

Agricultural Labor Practices
PMI’s labor practices code with seven ALP Code Principles
Short statements that set expectations of how the farmer manages
his farm in seven focus areas
Inter-department group charged with ALP implementation
Agricultural Labor Practices Program
Leaf Technician specialized in the ALP Program
Association of Tanzania Tobacco Traders, extension and logistics
service provider to PMI suppliers
Corporate Affairs
Control Union
Farmer through which ULT/ATTT communicate to other farmers
Crop Protection Agents
Environment, Health, Safety and Security Department of a PMI entity
Employment and Labour Relations Act of Tanzania
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
Flue-cured Virginia tobacco
Leaf Technician
Good Agricultural Practices
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 help 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
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 International
Personal Protection Equipment
Name for farmer associations in Tanzania
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
A system of agriculture in which a landowner allows a tenant touse/rent the land in return for a share of the crops produced on theland.
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.
Tanzania Tobacco Board
Universal Leaf Tobacco Tanzania

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1. ALP Program background and assessment
overview

THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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In 2011, Philip Morris International Inc. 1 (PMI) launched a worldwide Agricultural
Labor Practices (ALP) Program to progressively eliminate child labor and achievesafe and fair working conditions on tobacco farms. This program applies to all
tobacco farms with which PMI or PMI´s suppliers hold contracts to grow tobacco for
PMI. The ALP Program consists of (1) an Agricultural Labor Practices Code, setting
clear standards for all tobacco farms growing tobacco that PMI ultimately buys; (2)an extensive training program for all PMI and supplier’s staff that are directly
involved with tobacco growing, in particular the field technicians that provide
regular visits to the farms; (3) a multi-layered internal and external monitoring
system; and (4) involvement of governmental and non-governmental (NGO)stakeholders in improving labor practices and enhancing the livelihoods 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 PMI’s strategic partner Verité carrying out
assessments at PMI suppliers and contracted tobacco farms worldwide. All PMI
suppliers submit annual reports and are assessed regularly on their performance.
For the ALP Program implementation, internal reviews are also being performed in
all countries where tobacco is sourced to assess both initial progress and challenges
in the program’s implementation. The third party assessments that constitute theexternal monitoring component of the ALP Program are periodic reviews of PMI leaf
tobacco suppliers and contracted tobacco farms worldwide undertaken by CU. In
this initial stage of implementation, these third party assessments focus solely on
the implementation of the ALP Program. They specifically focus on the progress in
implementing the ALP Code framed against the strategic objectives set by PMI.
The ALP Code contains seven (7) principles2:
1.
2.

3.

4.
5.

6.
7.

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

1

For the purposes of this Code, “PMI” refers to Philip Morris International, Inc. or any of its direct orindirect subsidiaries. Where used, “supplier” refers to a company with a contract to supply tobacco to
PMI but is not a farmer.
2
The full ALP Code is contained in appendix 2.

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The implementation of PMI’s ALP Program has been divided into two phases 3:
Phase 1Management personnel and field technicians understand the ALP Code andthe implementation approach, ensuring capacity of people and the 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;
Systematically 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 during ALP implementation. In practice,many countries start to consider how to address and respond to situations not meeting the ALP Codeand to monitor progress before formally finishing Phase 1.

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2. ULT assessment: Scope and methodology

THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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The ALP Program was launched in 2011 and this report is Control Union’s fourth
external assessment. Tanzania was the first African market to be assessed and theTabora region was selected to be assessed by CU for both ULT and PMI´s othersupplier operated there. The two companies cooperated to implement the ALP
through a partnership with the Association of Tanzania Tobacco Traders (ATTT), of
which ULT was a 65% shareholder, with the remaining 35% owned by PMI´s othersupplier. Due to the fact that ULT and PMI´s other supplier operating in the region
cooperated through their partnership with ATTT, the reports for these twocompanies are almost identical. At the time of the assessment in February 2014,
ULT was implementing Phase 1 of the ALP Program and completed the second crop
season under the ALP Program.
2.1 Opening meeting
On 6 February 2014, CU started the assessment with an opening meeting with ULTsenior management, ALP Country Team representatives, ATTT management andfield personnel, PMI Regional ALP Coordinators and a representative of the OC.
During this meeting, CU presented the assessment’s objectives and plan. Together
with ATTT, ULT provided an overview of the implementation of ALP.
2.2 Staff interviews and ALP Program documentation
The assessment of ULT’s and ATTT´s work during Phase 1 of ALP included individualinterviews with ULT’s senior management, staff and the ALP Country Team involvedin the implementation of the ALP Program, including the ATTT management andfield personnel. All interviews were conducted individually to ensure thatinterviewees could talk freely. In total, 13 leaf technicians, 4 ALP technicians and
14 staff members of ATTT were interviewed. Additionally, CU interviewed four ULT
staff and two members of a Primary Society 4 . Interviews covered the following
topics:














General awareness of the ALP Program and knowledge of the ALP Code;
Implementation of the ALP Program at supplier 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;
System for reporting of Prompt Actions;
Efforts undertaken to mitigate risks;Internal procedure to report Prompt Actions;
Records showing the number of leaf technicians trained;
Records showing the number of farmers included in ALP communication;
Relationship between the three companies ULT, PMI´s other supplier
operating in the region, and ATTT;
Relationship with external stakeholders.

ULT and ATTT provided all the relevant documentation related to the ALP Program
implementation requested by CU, namely: Farm Profiles, farmer communication

4

Name for farmer associations in Tanzania.

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materials, purchase contracts, Prompt Action reports, training records and company
personnel records.
2.3 Farm sample selection
In total, CU visited 58 farms in the Tabora region supplying tobacco to ULT.
According to CU’s standard procedure to establish a representative sample, theminimum number of farms to be visited was 58, calculated from the square root of
the combined number of farms contracted by ULT and PMI´s other supplier
operating in the region5 multiplied by a risk factor of 0.8. The resulting 110 farms
was divided proportionally between the two suppliers (ULT: 58 farms and PMI´sother supplier operating in the region: 52 farms).
Unannounced visits were conducted on the full sample of 58 farms. During the first
three days of the assessment, CU visited six farms per day (18 in total). Whenselecting the farms, CU ensured that a maximum number of Primary Societies andleaf technicians were included in the sample. Each leaf technician was appointed to
one Primary Society and responsible for the farms contracted through thatparticular farmer association. In addition to the Primary Societies and leaf
technicians, the sample included all seven growing areas. On day four logisticalchallenges required CU to increase the number of randomly selected farms visitedfrom six to ten per day. These challenges included long travel times andinaccessible farms. Increasing the number of farms per day also reduced thenumber of field days and total travel time.
The farms supplying ULT were divided over seven growing regions: Tabora Central(11%), Mambali (12%), Ulyankulu West (17%), Ulyankulu East (17%), Nzega(19%), Mabama North (17%) and Mabama South (7%). In the Tabora region,
100% of the tobacco produced was Virginia Flue-Cured.
Among the farmers supplying tobacco to ULT, 81% of the farmers grew between
0.1 and 1.0 hectares of tobacco, 18.7% between 1.1 and 4.0 hectares, 0.1%
between 4.1 and 15 hectares and 0.2% more than 15 hectares. While, this sample
represents the total universe of farms in the different tobacco growing areas, theselection was purposely skewed towards larger farms employing more workers.
The largest proportion of farmers supplying ULT with tobacco was contracted via a
Primary Society, acting as an intermediary party. The supplier then held contracts
with the Primary Society. Farmers did not legally need to be contracted through a
Primary Society and could also hold a contract directly with a tobacco company.
From the farms visited, 93% of the farmers sold their tobacco via a PrimarySociety. The remaining 7% consisted of four farmers that were members of groups
of independent farmers called “associations”.

5

There were 18,709 farms in the Tabora region at the time of the assessment: 9,840 farms weresourcing to ULT and 8,869 to PMI´s other supplier operating in the region.

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The tables below summarize information on the sample of 58 farms.

*Migrant workers: Including both workers from neighboring countries and workers from other regions
within Tanzania. Due to similarities in language and appearance, a worker’s origins were difficult todistinguish by CU´s local auditors.

2.4 Farm visits
On each farm, CU conducted individual interviews with the farmer to assess theeffectiveness of ATTT’s communication efforts during Phase 1 to verify:whether farmers had received information about the ALP Code;their level of understanding and attitude towards ALP Code Principles;the extent to which farmers met the standards of the ALP Code.

When reviewing farm practices, CU used a variety of methods to collect the
information in relation to all the ALP Code’s Measurable Standards including:interviews with farmers and workers, verification of documentation and visualobservation of fields, storage rooms, curing barns, working areas and housing.
Before every interview, CU briefly explained the intention of the assessment andassured the interviewees that all information would be treated confidentially.
2.5 External workers and family members of the farmers interviewed
In total, 72 workers and family members of farmers were interviewed during thefarm visits. The graphs below summarize the data collected on their status. To
avoid bias, interviews with workers were conducted alone. On each farm, CU aimed

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to interview different “types” of family workers and workers i.e. permanent andtemporary workers, men and women, migrant and local. In addition to interviews,
visual observation was an important assessment technique.

*Permanent = working for more than 1 consecutive month at a particular farm
*Migrant workers: Including both workers from neighboring countries and workers from other regions within
Tanzania. These two types of migrant workers were difficult to distinguish due to the great similarities inappearance and language.

2.6 Closing meeting
The closing meeting was held in Dar es Salaam on 27 February 2014 when CU
presented the initial findings of the assessment. The meeting was attended by
ULT’s senior management and ALP Country Team representatives, the ATTT
management and PMI Regional ALP Coordinators.
2.7 Preparation of the final report
The final, public report of the assessment is an important, external measurement of
the progress of global ALP implementation in all countries where PMI sources
tobacco. Public release ensures the intended transparency of the ALP Program. Key
components of the reporting process include quality control by Verité, review andfeedback by PMI and ULT and ATTT and market action planning. CU’s main
responsibility is to author the final assessment report. While drafting the report,
PMI and the local supplier may request clarifications on specific findings. After both
PMI and the local supplier feel any findings have been clarified and understood,
they prepare a market action plan or revise existing GAP/ALP Program plans to
respond to the findings. This plan is included in Appendix 1.

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3. Assessment implementation Phase 1 of the
ALP Program

THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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This chapter documents the findings of the assessment of ULT’s implementation forPhase 1 of the ALP Program. Phase 1 began with the implementation of training for
management personnel and field technicians including:1) Program 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 visiting the farmers they support.
3.1 Conduct of the assessment
CU was satisfied with the cooperation and access to information provided by both
ULT and ATTT. All persons interviewed willingly explained internal processes andprovided information. However, during the farm assessments CU identified several
cases of the leaf technician steering the farm selection process. For example, in atleast three cases, leaf technicians claimed that the farm was inaccessible when it
was actually reached easily. In at least five cases, leaf technicians tried to take CU
to farmers they knew best. Furthermore, at least two cases of coaching of farmers
and workers were identified where leaf technicians tried to influence what farmers
and workers would say to CU. This was observed by the assessment team andbecame clear from the triangulation of answers of different interviewees. This iscommon in many markets in which third party assessments are conducted andunderstandable as leaf technicians want to show the best practices in the market.
CU decided to adjust its selection methodology from pre-selected farms to arandom selection (see also chapter 3.4). As a result, CU prevented these few cases
from significantly influencing the final results of this report.
3.2 People and processes to manage the ALP Program
3.2.1 Internal structure for ALP implementation
At the time of the assessment an internal structure supported implementation of
the ALP in the Tabora region. To start, ATTT was primarily responsible for the
implementation of the program. In order to be better prepared for ALP
implementation, ATTT had formed an ALP committee at national (1), regional (1)and area 6 (7) levels 7 and assigned a national ALP coordinator and a regional
supervisor to control and monitor the progress of the implementation. In addition,
seven ALP technicians had been appointed to support leaf technicians with the ALP
Code implementation. ATTT’s internal ALP team was also repositioned from field
production to the Corporate Affairs department. Because it was more focused on
people issues, it was considered better suited for leading the ALP Program. Equallyimportant, ULT took responsibility for planning and resource management.
ULT response (see Appendix 1): “The ULT Tanzania ALP Country Team has takenover the direct management of the ALP programme following the restructuring of
ATTT, which including the disbanding of the ATTT ALP Country Team.”
6

ULT divided the Tabora region into geographical “areas” of farms to improve oversight and allocationof resources.
7
Numbers refer to the number of committees active in the Tabora region.

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Control Union Certifications“In addition, Field Technicians are continuously supported in their ALP roles by anenhanced team of 2 National ALP Coordinators and 26 ALP Sector Coordinators
based across all growing areas. The restructuring of ULT Tanzania Field teams fromseparate ALP and Leaf technicians to each Field Technician providing a holistic
approach to training in GAP, ALP and Forestry will also help to improve quality of
training given to farmers.”
In addition, ULT formed an ALP Country Team to roll out the ALP Program from the
supplier´s side: making decisions on ALP related issues with a business impact andto allocate resources for the program. ULT’s senior management was also involved
with the ALP Program participating in the national ALP committee and enforcing
policies within the company. Finally, ULT management participated in a recently
formed task force appointed by Tanzania’s Ministry of Agriculture to address themost urgent problems related to the ALP in Tabora and other regions.
Organizational Chart: ULT’s structure for ALP implementation*All numbers mentioned refer specifically to the Tabora region** The colors represent: PMI (dark blue), ULT (light blue), ALP committees (yellow), ATTT (orange), Cooperative
Union and Primary Societies (grey) and the farms (green).

This complex operating environment with a large number of external stakeholders(PMI´s other supplier operating in the region, ATTT, WETCU, TTB, the Ministry ofAgriculture, and 50 Primary Societies) posed challenges for the implementation of
the ALP Program. According to ULT, PMI´s other supplier operating in the region
and ATTT, this complex environment was due to the following factors:
 The majority of farmers supplied through a Primary Society, Imprudent lending from the Primary Societies and non-payment by farmers
had resulted in farmers focusing on survival rather than ALP
implementation,

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Slow registration process of farmers by the TTB 8 retarded thecommunication of the ALP to (new) farmers,
Lack of enforcement of laws relevant to the ALP Code by the government,
Initial reluctance of WETCU9 to support the ALP and share information with
ATTT. Since the start of the Taskforce obligating WETCU to cooperate, thisdynamic has improved.

ULT response: “Communications between Banks, Primary Societies, Unions and
ULT Tanzania is being further strengthened, the main objective being to work
collaboratively to reduce potential farmer debt. In Tanzania, merchants such as
ULT Tanzania no longer provide crop finance to farmers. The Tanzania Government
introduced crop reforms mandating that inputs be purchased through the unions
and distributed to their farmers through Primary Societies. Under this restructuring
the Primary Societies negotiate loans with the banks on behalf of their members inorder to finance the inputs.”“After each sale of tobacco, ULT Tanzania will communicate with the respective
Primary Society and banks to indicate anticipated Loan Recoveries based on thosesales. Through these procedures, the management of debts is transparent and it ishoped this process will lead to reduced debt issues faced by farmers.”
3.2.2 Internal communication and reporting
The abovementioned structure was implemented to support the flow of informationon the ALP between the different stakeholders. The national ALP committee held
three, annual meetings while the regional and area ALP committees organizedmonthly meetings. During these meetings, issues concerning the ALP werediscussed and action plans formulated. From these meetings, ATTT collated amonthly report to internally inform the ULT management on the progress of the ALP
Program.
At the field level, leaf and ALP technicians in each area met weekly to discuss the
ALP. These meetings focused on ALP related issues, experiences and the status in
the field. These meetings were also used to report on Farm Profiles and Prompt
Actions between leaf and ALP technicians (see chapter 3.5 for more information).
ULT response: “The GAP Country Team now meets as a steering committee eachquarter, to review the progress of the ALP Programme and implement
improvements, as required. Specific issues are being dealt with throughextraordinary meetings if or when required. In addition, the ALP Country
coordinator teams will meet on a more regular basis, monthly or even weekly if or
when required. Meetings will be recorded and feedback provided to the GAPCountry Team.”
3.2.3 ALP training, roles and responsibilities
Several programs have supported implementation and training. To start in 2011,
PMI conducted the initial training on the ALP Program. Between August 2011 and
8

9

The TTB registered farmers and provided them with a license to sell tobacco.
Western Tobacco Growers Co-operative Union; Cooperative Union for farmers and workers.

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February 2012, all relevant staff from both ATTT and ULT were trained. Second,training of new staff and refresher training sessions were regularly performed by
the national ALP coordinator, the ATTT Corporate Affairs manager or one of PMI’s
regional ALP coordinators. Cross trainings with ALP colleagues from Malawi andMozambique were also organized to share practical experience.
As previously mentioned, leaf technicians also discussed the ALP on a weekly basis
during meetings with ALP technicians ensuring a regular repetition of the ALP
theory. Leaf technicians were also given an exam.
Although ATTT’s and ULT’s management both expressed their commitment to the
ALP Program and were actively involved (see also chapter 3.2.1), specific ALP
responsibilities were not yet included in the job descriptions of either the technicalor management staff.
ULT response: “Training and understanding is formally tested and assessed after
each training session and entered in the FT’s personal training log to enable
management to continually improve training programs and Field Technician
personal development objectives each year. Specific ALP-related responsibilities
and Key Performance Indicators (KPIs) have been formally included in the job
descriptions and objectives of all relevant personnel from Field Technicians tosenior Agronomy Management since August 2015.”
Finally, ULT, PMI´s other supplier operating in the region, and ATTT engaged with85 external stakeholders including schools, teachers and village leaders to mitigate
child labor through open dialogue, also involving them in ALP training sessions.
3.3 Communicating the ALP Code requirements to all farmers
3.3.1 The ALP communication strategy
All farms registered by ULT for the 2012/2013 crop season had been included in the
ALP communication strategy and were subsequently trained on the ALP Code. CU
was unable to verify if all farms registered by ULT for the 2013/2014 crop season
were included as the farm list for that season was not available at the time of theassessment.
In Tabora, the communication strategy primarily focused on principles 1 (childlabor) and 5 (safe work environment), perceived as the main problems in theregion. Of the farms visited, the majority were aware of the ALP Code while 10%
were still unaware. The farmers were least familiar with principles 6 (freedom of
association) and 7 (compliance with the law) in parallel with the findings on theknowledge of leaf technicians (chapter 3.3.3). In line with the strategy, farmers
were most familiar with principles 1 (child labor) and 5 (safe work environment) but
the depth of their understanding could be improved. An example relating to childlabor; farmers had a limited awareness of the legal minimum working age andhazardous work (see chapter 4.1). In addition, farmers lacked basic knowledge ofsafe work environment and the safety measures needed to create a safe work place(see chapter 4.5). However, a number of reasons prevented the communication
strategy from being more effective.

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Control Union CertificationsFirst, the low leaf technician to farmer ratio (on average 1:242) meant that 60%10of the farmers had no direct contact with a leaf technician. Some leaf technicians
were responsible for more than 500 farmers. These farmers were targeted via
group meetings, a “contact farmer,” where the leaf technician consulted
approximately 20 farmers per session. Other initiatives to reach farmers in theTabora region included ALP farmer clubs11, group meetings at market centers androadshows. Regarding the ALP farmer clubs, 35% of the farmers were unaware of
their existing membership in the club. They were automatically registered when
they joined a Primary Society and had not been properly informed about either the
existence of the club or their membership. ATTT acknowledged this challenge andhad a three year plan to reduce the ratio to no more than 1:150 farmers.
ULT response: “Since January 2015, company policy recommends a technician tofarmer ratio that will allow for a minimum of six visits during the growing season
for each farmer by field technicians. From an original ratio of 242 farmers pertechnician, this currently equates to a ratio of no more than 150 farmers per
individual technician. This is being implemented in order to achieve alignment tothe company’s long term GAP & ALP objectives. With the improved one on one
contact with farmers, Field Technicians are able to spend more time with individual
growers for training and monitoring.”“The FT visits and activities are recorded both on the farmer index card andMobiLeaf.”
Second, the Phase 1 requirement “communication of the ALP to all farmers” wasnarrowly interpreted because leaf technicians literally only spoke with farmers
about the ALP. A broader interpretation of this requirement included family
members on family farms. For example, as spouses were often active participantsin tobacco production, their involvement would likely accelerate both understanding
and acceptance of topics including child labor and safe work.
Third, CU identified resistance among farmers to participate in the ALP Program.
These farmers did not attend meetings and were reluctant to discuss andimplement the ALP. As previously mentioned, unpaid debts with the Primary Society
might be a factor and farmers focused more on financial survival rather than
implementation of the ALP Code.
Fourth, while the majority of the farmers had a positive relationship with the leaf
technician 17% of the farmers considered the relationship "average” or “bad.”
These farmers explained that the leaf technician did not visit them enough whilesome also associated the non-payment of the Primary Societies with the leaf
technician, even when they were unrelated. The negative perception could be
driven by the deficiency in the leaf technician to farmer ratio, or by a simple
misunderstanding among farmers of the relationship between the leaf technician
and the Primary Society.
Finally, CU identified a unique cultural challenge in the relationship between
farmers and leaf technicians. In general, young leaf technicians were reluctant to10

Based on Farm Profile analysis done by ATTT.
375 ALP clubs were formed in the Tabora region at the time of the assessment. The clubs were activeon Primary Society level.
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inform the farmer about ALP when the farmer was much older as they did not feelthey were in a position to instruct or correct the farmer’s practices. This is not
unusual in hierarchical tribal, cultures.
In summary, increasing the number of leaf technicians should help increase theawareness and adoption of the ALP while building stronger relationships regardlessof cultural norms.
3.3.2 Unregistered farmers
After changing the strategy for farm selection (chapter 2.3), CU met with farmers
not registered with either a Primary Society or ULT. 8.6% of the farmers visited by
CU (five in total) were unregistered with either organization with their tobacco soldto ULT via a contracted Primary Society. These unregistered farmers explained thatthey sell tobacco via another registered farmer. This approach could be influenced
by debts with the Primary Society or from a lack of TTB number. Leaf technicians
confirmed that they did not know these farmers so they were not included in thecommunication programs. ULT was aware of these unregistered farmers andexplained that this issue started in the 2013/2014 crop season. According to ULT,
an action plan was in place to register these farmers and include them in the ALP
communication.
ULT response: “From 2015, all Primary Society contracted farmers are identified on
the ULT Tanzania and Primary Society purchase contract. In addition, ULT
Tanzania requires each of the identified farmers to have a formal contract with thePrimary Society with a copy provided to ULT Tanzania.”“The contracted farmers are strictly prohibited from sub-contracting tounregistered farmers. This is enforced through Field Technician visits and the GPS
identification of all fields and curing barns.”
3.3.3 ALP communication methods and materials
In Tabora an extensive set of communication methods and materials was used to
inform famers about the ALP Code. Written materials included a barn poster,leaflets, t-shirts and water containers printed with the seven principles. As 40% of
the farmers were illiterate this undermined the potential impact of any writtenmaterials, 12 so ULT ensured that other media were used such as a weekly radio
show, bulk SMS broadcasts and drama presentations.
CU identified two challenges with the value of the written materials being
distributed to farmers. First, materials were not produced in sufficient quantities so
did not reach all farmers. Second, ATTT reported that some farmers only spoke atribal language and would not benefit from communication materials in Kiswahili.
A clause on the ALP Code is a required inclusion in the farmer’s growing contract.
As the farmers were contracted through the Primary Societies, this should havebeen included in these documents. However, only child labor and social

12

Percentage of illiteracy among farmers in the Tabora region provided by ATTT.

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responsibility programs were mentioned in the contracts issued by the PrimarySociety.

ALP barn poster

ALP T-shirt with the seven ALP Code Principles written on the back20

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GTS leaflet (left) and a water container with the seven ALP Code Principles (right)

3.3.4 Understanding and perception of the ALP Program
As the primary source of information, farmers are dependent on the knowledge andaccess to leaf technicians. This makes their understanding critical for bothknowledge transfer and adoption. During interviews with leaf technicians 13 , CU
found that while all leaf technicians were familiar with the ALP Program, some had
limited understanding of specific ALP Code Principles:








Principles 1 (child labor) and 3 (fair treatment) were best understood withrespectively 88% and 96% of the leaf technicians interviewed having a goodunderstanding of these principles. Regarding Principle 1, the remaining 12%
lacked knowledge of the activities that were allowed for specific age
categories and/or mistakenly perceived that children in general were notallowed to work on tobacco farms at all.
For Principle 2 (income and work hours), 62% of the leaf technicians
interviewed had a good understanding while 38% were unclear of local laws
on minimum wage, work hours, overtime payment and/or benefits.
Regarding Principle 4 (forced labor): 58% of leaf technicians had a goodunderstanding of forced labor. The remainder only considered physicallycoercing workers as applicable in this principle while practices like end of
harvest payment without provision of advanced payments is also a risk offorced labor.
Principle 5 (safe work environment): 52% of the leaf technicians interviewed
had a good understanding of this Principle. While these leaf technicians were

13

All Leaf technicians contracted by ATTT were trained together, regardless of the Primary Society that
was appointed to them and thus regardless to which supplier the farmers under their responsibility
source tobacco. Furthermore, a number of Leaf technicians worked for several Primary Societies someof which were contracted by ULT and some by PMI´s other supplier operating in the region. Therefore
CU´s analysis of the understanding and perception of the ALP Program, included all 26 interviewed Leaf
technicians.

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aware that PPE was required for protection for working with tobacco, theyalso considered the use of only gloves14 as sufficient protection.
Principle 6 (freedom of association): 50% of the leaf technicians interviewed
had a good understanding while the remainder felt it was irrelevant todiscuss this topic with farmers due to a lack of labor unions in the region.
For Principle 7 (compliance with the law): 38% of the interviewed leaf
technicians had a good understanding of this principle making it the least
understood. These leaf technicians primarily lacked knowledge about thelegal requirements for contracts between farmers and workers.

ULT response: “Field Technician and ALP coordinator training will be improved bytranslation of the ALP principles into Kiswahili for the 2016 crop with greater
emphasis on the training of the weaker areas of a Technician’s understanding.”“Since August 2014, the ULT Tanzania GAP Country Team has implemented a
programme of quarterly performance and understanding evaluations of allagronomy extension personnel (from divisional management through to Field
Technicians). The objective is to identify each individual’s strengths andweaknesses in relation to their GAP & ALP understanding and progressively
improve their skills and knowledge, in order to transfer these effectively to all
farmers. A competency profile of every Field Technician’s knowledge andunderstanding of GAP & ALP is updated on an annual basis in order to highlightindividual training requirements.”
At the management level, both ULT and ATTT personnel had a good understandingof the ALP Program. One member of the ALP Country Team had received training
just prior to the assessment and understandably, was not fully aware of the ALP
Program and activities being implemented.
A specific gap was the staff’s misunderstanding of migrant workers, perceived only
as workers from other countries. According to PMI’s definition15, this classification
also includes workers from other regions within Tanzania. Similar to migrant
workers from abroad, they are typically living far from home and are fully reliant on
the farmers they work for so are similarly vulnerable to foreign migrant workers.
3.4 Building Farm Profiles for all contracted farms
In Phase 1 of the ALP Program, ULT is expected to build Farm Profiles for every
contracted farm. PMI has developed a global template for suppliers and affiliates tocollect information on socio-economic indicators including farm size, number ofworkers, age and number of children in the farmer’s family, working status (forexample part time, full time or migrant), the pay period for workers and living
conditions. ATTT managed data collection of information and completed the PMI
Farm Profile analysis. Thorough analysis was conducted on the information obtained
through the Farm Profiles to better understand the primary risks and track progressin communicating the ALP Code.

14

The gloves present at the farms were too thin to provide proper protection and were not of a highenough quality to last the entire harvest season.
15
Migrant labor refers to labor that comes from outside the farm’s immediate area. Migrant labor cancome from a neighboring region in the same country, or from a different country.

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3.4.1 Data gathering system for Farm Profiles
Farm Profiles were collected by the leaf technicians during either farms visits orgroup meetings. First, the information was enumerated into a physical form andthen compiled into an Excel spreadsheet. The paper versions were grouped perPrimary Society 16 and stored in binders at the ATTT office. At the time of theassessment a digital system was still under development. Eventually tablet
computers will facilitate the collection of Farm Profiles. During the assessment, CU
had only access to the paper versions.
At the time of the assessment, CU could not confirm that 100% of the Farm Profiles
had been completed. For 33% of the farms visited, no Farm Profile was present in
the referenced binder. This could have been due to one of the following reasons:






Farmers used several different names: ATTT clarified that farmers often
used several names interchangeably, so the name reported by the farmer
during the field visit could be different from the name in the Farm Profile.
Unregistered farmers: As previously documented, five farmers wereunregistered so no Farm Profile was available.
For new farmers in the 2013/14 crop season, Farm Profiles had yet to becompleted.
Duplications: farmers sometimes registered at several different PrimarySocieties to ensure they received sufficient crop inputs. This created
duplications in the farm list with Farm Profiles being filed in another PrimarySociety than that listed in the farm list.

3.4.2 Accuracy Farm Profiles
As no new Farm Profiles had been completed for the 2013/2014 crop season, theiraccuracy could not be verified by CU. The deadline for this task was planned forAugust 2014, the end of the tobacco season. However, several leaf technicians
reported that this process had not started and no new Farm Profiles were provided
to CU. According to ATTT, updating Farm Profiles at the beginning of the season
was unlikely because of the large number of farmers in each region and themultiple levels of information that needed to be recorded at different stages of the
production cycle.
Assurance of the accuracy of the Farm Profiles by leaf technicians was found to belimited. As 60% of the farmers did not have direct contact with a leaf technician,information was primarily collected during group meetings and based on farmer
declarations rather than verification at individual farms.
The accuracy was also influenced by the attitude and needs of the farmers. First
many were suspicious of why the data was being collected. Second, farmers
reported that they did not understand the information written on the Farm Profileby the leaf technician; either because it was in English or because they were semiliterate. Finally, farmers interviewed requested more feedback and guidance fromthe leaf technician which decreased the time to collect data.

16

During the 2012/13 crop season there were on average 312 farms per Primary Society.

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The existence of the five unregistered farmers meant that they had not been
trained and there was no Farm Profile, so ULT was unaware of their farm practices
and if they met the standards of the ALP Code.
ULT response:“In October 2014, ULT Tanzania reviewed the procedure in which Farm Profiles
were recorded and collected by Field Technicians. New measures included FarmProfiles being completed in Kiswahili to improve accuracy. All Farm Profiles werecompleted on-farm, to ensure confirmation of the data collected. ALP Area
Coordinators conducted a 10% verification check per Field Technician to ensure
understanding and data accuracy. In addition, a carbon copy of the Farm Profile inKiswahili language was given to the Farmer as a reference for his/her own records.
This was implemented with the intention to demonstrate to farmers the importanceof keeping records and to increase transparency about the data being collected.
Pre-season confirmation and a master list of Farmers for whom every Field
Technician is responsible, will also ensure annual Farm Profile targets are met
without duplications or inaccurate farmer names. In addition, ULT Tanzania has
complemented manual data collection with electronic data collection as of August
2015, through the MobiLeaf digital data collection system which streamlines theefficiency of Farm Profile collation.”“During the 2014/15 season, 20% of farmer data was collected with MobiLeaf.
Over the 2015/16 season, 100% of farmer profile data will be collected
electronically.”“A particularly important feature is that the application will highlight new issues or
potential issues from previously entered data, thus providing an important
feedback to the farmer by the Technician.”“The MobiLeaf system will replace all data gathering done with excel spreadsheetsin the growing area and regional offices. This means that senior management will
have access to live data enabling them to react to issues on the ground in a much
shorter time scale.”
3.5 Prompt Actions
PMI defines a Prompt Action situation as:“a situation in which (1) workers’ physical or mental well-being might be atrisk, (2) children or a vulnerable group – pregnant women, the elderly - arein danger, or (3) workers might not be free to leave their job.” (source: PMI, 2011)
Phase 1 of the ALP Program implementation primarily focuses on training andcommunication. However, even at this stage, PMI’s expectation is that its suppliers
will address Prompt Actions found on any farms in their supply chain. In May 2012,
Phase 1 training included the response to Prompt Actions. To start, leaf technicians
are expected to immediately report any Prompt Actions to the ALP coordinator, whoprovides them with guidance on how to address the issue or escalate it within theorganization.

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3.5.1 Prompt Action reporting mechanism
In the 2012/2013 crop season, the implementation of the Prompt Actions reporting
mechanism was highly successful and resulted in 802 Prompt Actions being
reported. According to ATTT, the number of Prompt Actions continued to increase,most likely due to the success of the reporting mechanism. At area level, thePrompt Actions were compiled and reported on a weekly basis to the management
team. The findings were thoroughly examined in order to identify trends and root
causes.
In regards to the training on reporting of Prompt Actions and the “Prompt Action
book,” CU identified three areas for improvement. First, the book could be
developed in both English and Kiswahili. Some of the leaf technicians were notfluent in English and found it difficult to properly describe Prompt Actions. Second,
the three categories of Prompt Actions defined by PMI were not clearly
distinguished in the form. The third category of Prompt Actions, ‘workers not
permitted to leave their jobs,’ was not clearly understood by all personnel involved
in reporting and/or analyzing Prompt Actions. Finally, migrant workers and orphans
were not identified as vulnerable groups in the Prompt Action book.
Generally, the leaf technicians interviewed had a good understanding of the conceptof Prompt Actions but there was still some confusion, highlighting the need for
additional training. For example, one leaf technician mentioned a lack of toilets at
the farm as a situation that should be reported as a Prompt Action while anotherdescribed Prompt Actions as “any violation with the ALP Code”.
ULT response: “Prompt Action recording books have been improved and translated
to Kiswahili language. Prompt Actions and follow-ups are also recorded on the
MobiLeaf tablets. In addition, all Prompt Action follow-up is monitored by ALP
Sector Coordinators on a case-by-case basis. Reporting and analysis iscommunicated to all senior managers on a monthly basis. Continuous training of
Field Technicians and close monitoring by ALP Coordinators will further improve
Prompt Action understanding.”“As a result of improved data collection systems and improved FTs knowledge,
prompt action reporting increased from 802 cases in August 2013 to 2,811 in July
2015.”
3.6 Support mechanism (Phase 2 requirement)
As explained in chapter 2, the creation of a support mechanism is a requirement
under Phase 2 of the ALP implementation. At the time of assessment, ATTT was
already implementing a pilot mobile support line in the Tabora region.
3.6.1 Pilot in Tabora region
One month prior to the assessment, ATTT launched a support line designed for both
farmers and workers in cooperation with the local NGO Tabora Development
Foundation Trust (TDFT).17 According to ATTT, TDFT received mobile calls and sent
17

For more information on TDFT: http://tdft.or.tz

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a monthly report of cases reported. At the time of the assessment, the support line
was only collecting data with no mechanism to address reported issues.
11 community activists were contracted to promote the support line among farmers
and workers. In the future, the support line will receive and process grievances
reported by farmers and workers.

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4. Farm level assessment of ALP Code standards

THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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This chapter describes the findings of the field assessment and the current situation
at farm level relating to the implementation of the ALP Code. At the time of thisassessment, ULT was implementing Phase 1 of the ALP Program. With theimportant exception of Prompt Actions, ULT was not yet expected to engage with
farmers or address all situations on farms that do not meet the ALP Code standards
in a systematic way. This is the expectation of the Phase 2 implementation.
Before presenting CU´s findings, it is important to understand the structure of the
ALP Code as this guides CU´s analysis of farmer practices. The ALP Code has seven
ALP Code Principles, each with several Measurable Standards. ALP Code Principles
are short statements that set expectations of how the farmers manage their farm inseven focus areas. These principles are designed to guide farmers on specificpractices resulting in safe and fair working conditions.
A Measurable Standard defines a good practice and over time can be objectively
monitored to determine whether and to what extent the labor conditions andpractices on a tobacco farm are in line with each ALP Code Principle. Each chapter
covers one of the seven ALP Code Principles and CU’s findings regarding the extent
to which the practices on farms contracted to supply tobacco currently meet therequirements of the Measurable Standards. Risks are also documented and include
situations that may lead to problems in the future or about which a conclusion
cannot be reached due to a lack of evidence.
4.1 ALP Code Principle 1: Child labor
Background
Minimum age regulations: The Employment
and Labor Relations Act (ELRA) determines
ALP Code Principle 1that the minimum age for working in Tanzania
Child laboris 14 years, provided that the child hascompleted at least Standard 7 of the primary´There shall be no childeducation. The ILO accepts a minimumlabor.´
working age of 14 years for developing
countries such as Tanzania, and states thatchildren between the age of 12 and 14 areallowed to help on their family’s farm. The Lawof the Child Act 2009 (82)3 constitutes a list of hazardous activities that cannot be
performed by persons under 18 years which includes, inter alia, porterage of heavyloads. In addition, this law defines hazardous work to mean any work which placesa child at risk to suffer physical or mental injury. Furthermore, persons below theage of 18 are restricted from working at night between 8pm and 6am. Also,
children shall not be employed or engaged in any kind of exploitative labor,
meaning work that (a) deprives the child of his health or development; (b) exceeds
6 hours a day (c) is inappropriate to his age; or (d) the child receives inadequate
remuneration (78).

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Child labor: Overall findings and challenges
4.1.1 Prevalence of children working
The number of farms on which CU found children below 14 (the legal minimum age
for working) employed, was relatively low with only two farms; one farmer
employed two children below 14 and one farmer five. CU also found child family
members of the farmers helping out at the farm, a part of the local economy andculture; at 14% of the farms visited, children between 12 and 14 were found doing
heavy work and/or children below 12 were helping on the farm. Also, at 34% of thefarms visited, persons below 18 were found involved in hazardous work. In total,
CU identified 50 children involved in tobacco related activities (20 children were
employed at one farm). For the three different age categories, the table below sets
out the number of children per activity and that children are engaging in hazardous
activities including stringing tobacco, harvesting, and carrying tobacco leaves.18
ChildrenChildrenChildrenbelow 12
between 12
between 14 and(total=7)
and 1418 (total=30)(total=13)
Sowing7
25
Applying fertilizer*
5
20Transplanting
1
7
22
Irrigation
18
CPA application/handling*
1
1
22
Harvesting*1
7
26
Stringing tobacco leaves*7
11
29
Carrying tobacco leaves*
627(un) loading curing barns*
20
Monitoring curing barns*
18
Classifying
1
19*This activity is considered to be hazardous for this age class.

The reported school attendance for school age children 14 years and under was
67% (24 in total). In the same age category; five worked full shifts the whole
week, six children worked full shifts several days a week, six children only workedon the weekends, four children only worked in the afternoon and three children
were working only on school holidays. Of the children between 15-17 (26 children
in total), seven children worked full shifts the whole week, two children worked fullshifts several days a week and two children only worked on weekend.

Frequency of work children 14 andbelow (Total = 24)

School attendance children 14 andbelow (Total = 24)

Full shifts full workweek
21%

25%

13%

25%
17%

18

Full shifts several days aweek
Only afternoons
Only school holidays

33%
Yes
No
67%

Only weekends

One child can do multiple activities.

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Initiatives to address child labor
The ATTT entered into a partnership with the ECLT Foundation 19 (Elimination ofChild Labor in Tobacco growing) on a project called PROSPER 20. The project’s goal
was to reduce child labor in Tanzania’s tobacco industry through targetedinterventions in the Tabora region. This project started in July 2011, and planned
to be active until December 2015 with a budget of 4.750.000 USD (combined for
the Urambo, Sikonge and Tabora regions). The objectives were to protect: children(5-17 years old) from exploitative, hazardous, and worst forms of child labor in
tobacco growing and legally working children (15-17 years old) in non-hazardous
work in tobacco growing.
In addition, the ATTT involved school teachers to reduce absenteeism. Teachers in
the Tabora region followed up on absent children and reported school attendance tothe area ALP committee. The school teachers were also involved in the training on
the ALP (see chapter 3.2.4).

ULT has taken the following efforts to address child labor:
1. “ULT Tanzania will continue to engage farmers on the legal minimum
working age with a new focus through training of farmers and theirspouses/partners during each Technician visit and via multiple channels
such as drama groups and radio programmes to achieve improved
understanding of the target audience.”“The spouse’s attendance is recorded on the MobiLeaf system. In 2014/15,
over 29,000 spouses were recorded as having attended training sessions
which was over the 20,000 target set for the season. In future seasons, thetarget number of spouses will be collected at the time of farmer
registration. The target is 100% of contracted farmers’ spouses.”
2. “Another primary channel of communication identified, is through a Village
Child Labour Committee (VCLC) which are already set up in some villages.
Above these is the District Child Labour Committee (DCLC).”“The objective of developing these communication channels is to encourage
deeper cultural awareness and behavioural change, particularly in relation
to child labour.”
3. “During the 2015/2016 season, ULT Tanzania will collect and monitor dataon all orphans at contracted farms, through the MobiLeaf system. The
information includes: name, gender, age, school enrolment, school
attendance, resident on or off farm and if any hazardous tasks are
performed.”
4. “Education is a key theme and objective in ULT Tanzania’s approach to
tackle child labour, and the company responds to many requests for help
from various education authorities or from its own area managers withsupport for the refurbishment of schools. In the last few years, for example,
ULT Tanzania has invested over 100,000,000 TZS (US$ 46,055 at thecurrent exchange rate) to refurbish or enlarge 7 schools, more than
31,000,000 TZS (US$ 14,277) to supply desks to 6 schools and over
20,000,000 TZS (US$ 9,211) to provide textbooks to 2 schools. These
contributions have helped improve education conditions for approximately
2,500 children.”
19

More information can be found on http://www.eclt.org/site/about-child-labour/agriculture-andtobacco/
20
PROSPER: Promoting Sustainable Practices to Eradicate child labor in tobacco growing.

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5. “National conference “Pathways to Sustainability: Together We Can
Eradicate Child Labour in Agriculture” (2015). ULT Tanzania actively
engaged with the Government of Tanzania and supported a two and a half
day conference organized through the Prime Minister’s Office – Regional
Administration and Local Government (PMO-RALG) and the Ministry ofLabour and Employment (MoLE) in collaboration with the Elimination ofChild Labour in Tobacco-growing Foundation (ECLT) and its implementing
partner Winrock International.”
6. “The board of ECLT on which ULT is represented agreed to fund a new
Country Plan for 2016-2017 focused on advocacy and increased technicalassistance to the government, district level coordination, youth
employment, and targeted interventions to prevent child labour andpromote school retention (e.g. Village Saving and Loans Associations,referral services, awareness raising).”
7. “In May 2015, the ILO and the ECLT entered into an agreement to develop
global guidance on hazardous child labour and occupational safety intobacco production and to support associated social dialogue in three pilot
countries, including Tanzania. The deliverables, the process and thetimelines still have to be finalized. ULT Tanzania will support the efforts
made through this public private partnership.”Child labor: Risks
4.1.2 Underlying factors that increase risk
In Tabora, the majority of the farms that sourced for ULT (48%) consisted ofrelatively small size farms fully reliant on family labor. Subsequently, CU identified
four factors posing a risk of child labor. First, children traditionally helped on thefarm, perceived and valued as a part of their education. Second, many farmers
reported they could not hire worker because of limited cash flow. Third, adolescentmarriage posed another risk for child labor. Finally, the availability of both primaryand secondary schools in the Tabora region was insufficient, increasing the risk ofchildren working on farms instead of attending school. On 55% of the farms visited,children were on hand because they either lived there or were accompanying theirparents.
4.1.3 Awareness of hazardous work
78% of famers and 55% of the workers21 interviewed were aware of the meaning of“hazardous work.” The remaining did not know that harvesting, CPA application,
and working at heights are hazardous activities and should not be performed bypersons under 18. In line with this finding, all 50 children found working on thefarms were involved in one or more activities that are not allowed in their age
category (see 4.1.1).

21

As explained in chapter 2, raising awareness among farmers is a requirement under Phase 1 of the
ALP roll out, while raising awareness among workers is part of Phase 2. As ULT was in Phase 1 at thetime of the assessment, raising worker awareness was not a requirement.

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4.1.4 Awareness of legal minimum working age
79% of the farmers and 54% of the workers22 were aware of the legal minimum
working age. The remaining either reported they did not know the legal age
children could be employed or named an age higher or lower than the legal
minimum working age of 14. This lack of awareness could lead to farmers hiring
children below the required age limit.
4.1.5 Age verification
91% of the farmers that hired labor did not verify the age of the workers they
employed. Even if the farmer was willing to verify the age workers, this wasimpeded by the lack of local identify documents.
Child labor: Analysis and Priorities
Given these findings, ATTT´s choice to focus its communication efforts on childlabor is logical. While the awareness levels of the legal minimum working age andhazardous work among both farmers and workers was relatively high, this had not
yet translated into all-encompassing behavior change. Seven children below thelegal minimum working age were employed and all 50 children identified by CU
were involved in one or more activities that were not appropriate for their age.
Additional root cause analysis on the reported Prompt Actions and the underlying
factors that increase risk could provide valuable input for implementing targeted
initiatives to educate on this issue while considering how best to support the local
culture of family tobacco farming.
4.2 ALP Code Principle 2: Income and work hours
Background
Minimum salary regulations: The minimum
wage is regulated by the law. The employee
representative union for the agricultural
workers, Tanzania Plantation and Agricultural
Workers Union (TPAWU) can only negotiate forbetter terms that are more than the minimum
wage set by the law. At the time of theassessment,
according
to
the
Labor
Institutions Wage Order, 2013 (GN 196 of
2013), the gross minimum wage for
employees
inagricultural
servicesinTanzanian Shillings was as follows:

512.85 TZS per hour
846.50 TZS per day
23,078.70 TZS 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.’

22

As explained in chapter 2, raising awareness among farmers is a requirement under Phase 1 of the
ALP roll out, while raising awareness among workers is part of Phase 2. As ULT was in Phase 1 at thetime of the assessment, raising worker awareness was not a requirement.

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46,157.40 TZS per fortnight
100,000.00 TZS per month

Salary payments must be made during work hours at the place of work on theagreed pay day and made in cash (unless the employee agrees otherwise). End of
season payments are allowed. Remuneration shall be due and payable at the end of
the contract period provided the employer may pay an advance before the due day
on a mutually agreed day and, if such day is not agreed, at least once oncompletion of half the contract period. Such advance shall not be considered a loanand shall not attract interest.
Work hours regulations: The ELRA states that workers on tobacco farms can work amaximum of 9 regular hours per day, not more than 45 regular hours and six daysa week. It is prohibited to require or permit a worker to work more than 12 hours
on any day and for more than 50 overtime hours in any four week cycle.
Overtime hours must be paid one and a half times the regular wage. Night work
should be paid at 1.05 times the regular wage. Overtime hours during the nightshould be paid 1.575 times (1.5 * 1.05) the regular wage. Work done on national
holidays should be paid at two times the regular wage.
Benefits regulations: Benefits that apply to all workers: sick leave and overtime
payment. Benefits only apply to workers who work for more than six consecutive
months and include: paid annual leave (28 days), maternity and paternity leave(84 and 3 days).
Income and work hours: Overall findings and challenges
4.2.1 Minimum salary
61% of the farmers visited who contracted workers paid their workers less than thelegal minimum wage in cash. The monthly salaries reported were between 37,500
and 150,000 TZS, while the minimum wage is 100,000 TZS per month. Of theseworkers, the ones who were paid on a daily basis, or doing piecework generated anincome between approximately 3,000 up to 7,000 TZS a day, which in some cases
is less than the daily minimum wage of 3,846.50 TZS. In one case, children
stringing tobacco leaves were paid per string which resulted in a daily wage
between 625 TZS and 875 TZS as they could not finish more strings in one day.
Some of the farmers reported that they were unable to pay their workers becauseof non-payment by their Primary Society or stated that the profit margins would be
too low if they paid the legal minimum wage. Other farmers considered an in-kindpayment of accommodation and food as part of their worker´s salary but it was notformally documented.
4.2.2 End-of-the-harvest payments
Practically all migrant workers interviewed were being paid at the end of theharvest. Even though this payment schedule is legally permitted, the ALP Codediscourages end of the harvest payment as it increases dependence of workers on
farmers and therefore causes risks of forced labor. Furthermore, only a few farmers

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provided advancements during the season as required by the law at least once on
the half of the contract period.
4.2.3 Regular and overtime hours
48% of the farmers visited who contracted workers did not respect the maximum
work hours. In general, work hours varied according to the production stage. For
agricultural work, it is acceptable that schedules fluctuate especially during busy
and harvest seasons. However, in the cases reported, workers were regularly
engaged a full seven days and more than 48 hours a week especially true forworkers in the curing barns. Although the monitoring of a curing barn is not hardlabor as it involves waiting time during which the workers can rest, CU must
consider the total hours accrued in a shift. The absence of documented work hours
made it difficult to do any formal calculation of overtime hours and associatedpayments required. Consequently, none of the farmers visited paid overtime at thelegal premium.
4.2.4 Legal benefits
None of the farmers visited who contracted workers for more than six consecutive
months provided the legally entitled benefits to workers. This practice is in line withthe low awareness on legal rights and benefits among both farmers and workers to
be explained below.
Income and work hours: Risks
4.2.5 Awareness of legal rights
Both farmers and workers generally had limited awareness of the legal rights
workers are entitled to. These figures are documented in the following tables:

Minimum salaryWork hours
Overtime
Legal benefits% of farmers unaware(Phase 1 requirement)
45%
17%
67%
95%

% of workers unaware(Phase 2 requirement)
82%
50%
84%
79%

4.2.6 Record keeping
None of the farmers visited who contracted workers recorded payments and 52% of
the farmers who contracted workers did not record work hours or tasks completed.
In addition, none of the farmers who contracted workers provided pay slips.
Income and work hours: Analysis and Priorities
CU´s findings demonstrate that more efforts are required to inform farmers about
the labor laws applicable to the ALP Code and consequently change their practices
accordingly. The low level of awareness among both farmers and workers resulted
in salary payments below the legal minimum wage, excessive work hours and lackof benefits. Migrant workers were especially vulnerable as they fully depend on the
farmer for their income, food and accommodation. Farmers, however, could only
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provide monthly payments. Including this group of workers in the Prompt Action
book could help obtaining a better picture of their situation. Also, together withraising awareness on legal requirements, assistance in record keeping could
improve workers´ position with regards to work hours and overtime. However,potential solutions for record keeping should consider the fact that approximately
40% of the contracted farmers were illiterate.
ULT response: “…a Support mechanism for workers and farmers was rolled out inJanuary 2014 as a pilot project in Tabora Region.”“The Support mechanism is run by a third-party NGO, the Tabora Development
Foundation Trust (TDFT), which is supported by the international NGO Winrock
International.The support mechanism provides a means for farmworkers toanonymously or confidentially report and discuss any grievances including thoserelated to income and work hours through either a call centre or local “community
activists”…”
4.3 ALP Code Principle 3: Fair treatment
Background
Regulations: The ELRA, No. 6 of 2004 protects
employees
fromdiscrimination
and/orharassment:










ALP Code Principle 3
Fair treatment‘Farmers shall ensure fair
Section 7 (1) of the ELRA imposes atreatment of workers. There
duty upon the employer to ensure thatshall be no harassment,
he promotes an equal opportunity indiscrimination, physical or
employment, and to strive to eliminate
mentalpunishment, or any
discrimination in any employment policy
other forms of abuse.’or practice.
Section 7(2) of the ELRA requires an
employer to register, with the Labour
Commissioner, a plan to promote equal
opportunity and to eliminate discrimination in the work place.
Section 7 (4) of the ELRA prohibits an employer from discriminating, directly
or indirectly, an employee, in any employment policy or practice, on any of
the following grounds, namely: colour, nationality, tribe or place of origin,race, national extraction, social origin, political opinion or religion, sex,
gender, pregnancy, marital status or family responsibility, disability, age or
status of life.
Section 7 (5) of the ELRA states that harassment of the employee shall be aform of discrimination and shall be prohibited if done on any or a
combination of the above grounds.
Section 7 (7) of the ELRA gives a right to an employee who has been
discriminated to complain to the Labour Court.”

Additionally, the Employment and Labor Relations (Code of Good Practices) Rules(GN No. 42 of 16/02/2007) under its regulation 28(3) went further to state thatharassment of an employee, whether of sexual nature or otherwise constitutes aform of discrimination.

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Fair treatment: Overall findings and challenges
4.3.1 Two cases of verbal harassment
At the majority of the farms visited, CU did not identify any practices suggestive ofunfair treatment. Most farmers and workers interviewed confirmed that physical,
sexual and verbal abuse was not a problem. Nevertheless, during two farm visits,
workers reported that the farmers had shouted and insulted them.
Fair treatment: Analysis and Priorities
As only two cases of verbal harassment were identified by CU, unfair treatment
does not seem to be widespread among the contracted farms. However, theimplementation of a support mechanism will be important to obtain more
information on this type of situation as it will provide an opportunity for workers toreport incidents anonymously.
ULT response:“Since 2014, a support mechanism was made available to farmers and workers inpartnership with a local NGO, the Tabora Development Foundation Trust (TDFT).
The support mechanism leverages on dedicated staffed, so called “community
activists” (CA) due to their role of engaging with all relevant members of thecommunities from seven key areas of the Tabora Region. In addition, the support
mechanism offers a toll-free line to allow an alternative avenue for workers andfarmers to raise their concerns. Community Activists receive training from ULTTanzania and support from TDFT management. All calls are confidential and issues
identified are followed up and dealt with by the TDFT Community Activists.”“In the first year of operation, 67 cases were reported, most of which related toworkers’ payments, breach of contract, and unfair treatment.”“In 2015/16, all farmers and their workers in the target area will receive abusiness card containing details of the support mechanism. In addition, all Farmer
Index Cards and Worker Contracts will have the support mechanism number
printed on them. The Support mechanism will also be communicated to all farmers
and workers in the target area through local radio broadcasts, leaflets, andposters.”
4.4 ALP Code Principle 4: Forced labor
Background
Regulations: The Tanzanian Anti-Trafficking in
Persons Act (2008) strictly forbids any type of
humantrafficking.
Furthermore,
official
recruitment agencies are permitted, but
informallabor
brokersareprohibited.
Additionally, The ELRA prohibits forced labor:

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

Section 6 (1) of the ELRA states that,“Any person who procures, demands or
imposes forced labour, commits an

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offence”.
Section 6 (2) of the ELRA defines forced labour as including bonded labouror any work exacted from a person under the threat of a penalty and towhich that person has not consented but does not includea. any work exacted under the National Defence Act, 1966 for work of apurely military character;b. any work that forms part of the normal civic obligations of a citizen of
the United Republic of Tanzania;
c. any work exacted from any person as a consequence of a conviction
in a court of law, provided that the work is carried out under thesupervision and control of a public authority and that the person is not
hired to, or placed at, the disposal of private persons;d. any work exacted in cases of an emergency or a circumstance thatwould endanger the existence or the well-being of the whole or part ofthe population;
e. minor communal services performed by the members of acommunity in the direct interest of that community after consultation
with them or their direct representatives on the need for the services.”
Forced labor: Overall findings and challenges

4.4.1 Migrant workers unable to leave their job
At 20% of the farms visited with contracted workers, migrant workers wererequired to stay until the end of the harvest in order to receive their salary. These
workers did not receive any advance payments during the season. Because they
had limited access to funds, this inhibited their freedom to leave their employment.
These workers explained that if they left before the end of the harvest, the farmer
could not afford to pay them their salary. Once the farmer received payment fromthe sale of tobacco, workers would be paid. According to the majority of theseworkers, in the previous crop season, it had taken several weeks or months before
salaries were finally paid. In addition, if the farmers’ payment was delayed by thePrimary Society, workers could not be paid on time and could not leave until they
were paid. Some farmers did provide workers with food and other jobs in the samecommunity while waiting to pay their final salaries.
ULT response: “ULT Tanzania will further investigate and monitor migrant workers
on farms. In addition to capturing the number of migrant workers from countries
other than Tanzania, ULT Tanzania undertook to capture the number of migrant
workers from other regions of Tanzania working on farms during the 2014/2015
season.
This programme will be enhanced in the 2015/16 season with clearer identification
through MobilLeaf data capture of types of migrants, whether from within or
outside of Tanzania, languages spoken, payments types and frequency, and allrisks associated with migrant labour that FTs need to be aware of.
This will help ULT Tanzania, and the FTs, identify workers who may be more at risk

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due to their dependency on their employer. This information will be used toencourage the FTs to be more attentive to potential issues, in particular any end of
season payments for workers. Migrant workers are being registered and monitored
by FTs and the ALP country team through the farm profiles, MobiLeaf and the ALP
monitoring reports.”
4.4.2 Unethical employment practices
CU identified two cases in which migrant workers were employed under false
pretenses. In one case, nine migrant workers were told beforehand that they would
be contracted for irrigation on a tree nursery, but when arriving at the farm they
had to work on tobacco. At another farm two workers had agreed to work on
tobacco, but they had to work on other crops too. If they refused, money was
deducted from their salaries.
Forced labor: Risks
4.4.3 Cultural practices
CU found one cultural practice that posed a risk of forced labor. In this case farmers
had several wives who all managed their own plot of land with workers. The wives
were not paid and had to manage some crops to feed the workers and cook forthem. If the farmers would earn more, they would engage another wife to do thesame. These farmers were from a certain tribe that is known for this practice.
Although this could be considered family labor, there is a posed risk of forced laboras these women were not free to choose whether they wanted to work or not.
Forced labor: Analysis and Priorities
The abovementioned findings demonstrate that increased efforts are required toreduce the risks of forced labor at the contracted farms. As explained in chapter
3.3.4, there was a misunderstanding among ULT´s staff regarding the term
“migrant workers” as only workers from another country were included in thisgroup. By identifying workers from other regions within Tanzania as migrant
workers and training leaf technicians to monitor this group closely, ULT could obtaina better understanding of the risks associated with this type of employment. As isshown from the demographic information on workers presented in chapter 2.5, themajority of the workers come from other regions and thus should be considered
migrant workers, who are typically more vulnerable than local workers.
4.5 ALP Code Principle 5: Safe work environment
Background
Regulations: Requirements by law on the safe work environment are embedded in
the Occupational Health and Safety Act (OHS), No. 5 of 2003 and the Tobacco
Industry Act, 2001 and the National Environmental Management Act (EMA) (2004).
The latter covers management of chemicals and toxic substances and is aframework law which sets the institutional responsibilities of various actors anddirects the management of the environment.

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Regulations
important
for
safe
work
environment during the assessment were:
















Control Union Certifications

ALP Code Principle 5

The farmer has the obligation to ensure
Safe work environmentthat no employee is exposed to:‘Farmers shall provide a(a)Hazardous
machineryandsafe work environment toequipment, (b) harmful animals andprevent accidents andinsects, (c) infectious insects or
injury and to minimize
allergens, (d) hazardous chemicals, (e)health risks.
hazardous environment while doing
Accommodation, where
work as agricultural worker.
provided, shall be clean,
The farmer has the duty to properly
safe and meet the basic
dispose all chemical containers andneeds of the workers.’
chemical residues so they do not cause
harm to human health and theenvironment.
The farmer shall ensure that an
adequate supply of safe drinking water is provided and maintained and isaccessible to all workers.
The farmer has to provide additional protective clothing to handlers of toxic
materials or substances.
PPP (CPA) has to be registered in the national list of approved pesticides.
Workers have to be fully instructed to the danger they are likely to be
exposed to and should have received sufficient training for the machine orprocess they are involved with.
There should be a first aid box available on the farm. This box has to be
distinctively marked as ‘first aid’ and should only contain appliances orstocks for first aid
When an accident or injury occurs this should be reported to the chief
inspector within 24 hours and thereafter a duly prescribed form should besend within 7 days.
Tanzanian laws do not compel the employer to give accommodation to theemployee. However, the practice has been that the employer provides
accommodation or gives a housing allowance. Common knowledge dictatesthat where the employer decides to give accommodation, it shall be fit to behabitable. If not habitable and the employer allows the employee to continue
to stay in the premises in case of any accident/loss the employer will be
liable under occupiers liability. The obligation is also under Occupational
Health and Safety Act, No 5 of 2003.
Safe work environment: Overall findings and challenges

4.5.1 Training and awareness of Green Tobacco Sickness
At 70% of the farms visited, workers and/or family members were involved inharvesting without being trained on GTS.23 At these farms, workers were harvesting

23

Generally the recommended action is to stop exposure - by resting, showering or washing, changing
clothing, ceasing to work and drinking water. A doctor should be consulted if the symptoms persist. For
further information see: http://tobaccocontrol.bmj.com/content/7/3/294.full

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without protective clothing and were unaware of safety practices24. 34 children andfour pregnant/nursing women were involved in harvesting. These children are also
included in chapter 4.1.1. Many workers and family members reported to have felt
symptoms of GTS, but they were not aware this was caused by green tobacco. On
most of the farms there was no appropriate PPE available.

Initiative to address Green Tobacco Sickness
ATTT implemented an initiative to address GTS, namely the provision of gloves tofarmers. Also, farmers provided plastic bags that could be worn to protect against
GTS. However, these items were considered inadequate as they did not provide
proper protection to the workers: the gloves provided were too thin and could
easily be torn during harvesting and the bags did not cover the arms and so did
not fully protect the skin from contact with green tobacco leaves.

4.5.2 CPA handling and training
At 76% of the farms visited, workers and/or family members were involved in CPA
application without being trained, including 24 children and two pregnant/nursing
women. At 86% of the farms visited, the re-entry period of CPA was also notrespected. Workers on these farms reported entering the field shortly after CPA
application. Some farmers warned their workers or family members verbally, but nosigns were placed in the field to warn external persons. These farmers said that noexternal persons ever walk in their fields or that they could smell when CPA wasapplied, which repelled them. As children had free access to the fields, they could
easily walk into a recently sprayed field.
On the majority of farms surveyed, CPA storage was either non-existent, waswithout an appropriate lock or was kept inside the farmer’s house. There was nocollection service in place for the discarding of used CPA containers. While farmers
could triple wash the empty containers before discarding them, CU found noevidence of this practice. CU also found two farmers burning their empty
containers.
For topping, workers used 500 ml drinking bottles with a small hole in the cap to
apply suckercide on the tobacco. The chemical was applied without any protective
equipment and the bottles were filled from an open bucket. There were also nomasks or other PPE available for protection during the spraying of CPA. In regard to
CPA application, farmers stated that either they did not know where to buy
appropriate PPE or could not afford it.
ULT response: “ULT Tanzania engaged with the Tanzania Tobacco Council (TTC) forthe provision of a Personal Protective Equipment (PPE) Pack to every farmer on anannual basis. The relevant Unions supplying farmer inputs will be required to issue
every farmer with a comprehensive PPE pack per hectare of tobacco cultivated,
24

As explained in chapter 2, raising awareness among farmers is a requirement under Phase 1 of the
ALP roll out, while raising awareness among workers is part of Phase 2. As ULT was in Phase 1 at thetime of the assessment, raising worker awareness was not a requirement.

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consisting of four pairs of work gloves, eye goggles, mouth masks and two lightweight protective ponchos covering 75% of the body. These will be included in the
farmer inputs package in 2015/16 season. The type and quality of the PPE has
been approved by the TTC. The pack will be delivered in a lockable box to be used
for CPA storage.”“ULT Tanzania will be developing a programme in the 2016/2017 season for thecollection and destruction of used CPA containers.”
4.5.3 Clean drinking and washing water
The majority, 84% of farms visited provided clean drinking and washing water. A
minority of 16% provided drinking water in dirty containers or provided no water atall. In general, there was a lack of potable water in some areas of the Tabora
region.
4.5.4 Worker accommodation
Provision of worker accommodation appeared to be a challenge with 55% of thefarms visited found to be inadequate. At these farms the following cases wereidentified;










Workers sleeping in fertilizer bags
Workers sleeping in curing barns
Workers sleeping in the open air
Housing without ventilation
Lack of mattresses and mosquito nets
Workers sleeping in the same room as the CPA storage
Insufficient space for the number of workers
Workers sleeping too close to operating curing barns
Farmer housing without a buffer zone for the CPA

ULT response: “Action plans being put in place include: Informing the farmer about the housing improvements he/she needs tomake.
 Helping the farmer identify the priority areas and prepare an improvementplan.
 Inform farmer that a coordinator will contact him/her to follow-up on
improvement plan previously agreed.”
Safe work environment: Risks
4.5.5 General safety measures
In order to ensure a safe and sanitary work environment for both family members
and workers, 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.
However, safety is still a concern and CU could not identify a farm without
challenges to provide a completely safe and sanitary working environment. All
farms had at least one of the following challenges:

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






Control Union Certifications

During topping usage of leaking CPA sprayers or improvised equipment,such as drinking bottles used to apply suckercide25.
No safety measures in curing barns: Some curing barns had strong ladders,but others had nothing to prevent falls. Also, in some curing barns the metal
pipes were fully exposed (not covered with clay) causing a risk of falling
leaves catching fire.
Exposure to extreme heat and smoke: sometimes curing barns had to be
repaired during curing, so workers worked in extreme heat and smoke.
Inadequate resources to act in case of emergency: no fire extinguisher or
first aid kit was available at any of the farms visited.
Limited access to sanitation: many farms did not have sanitary facilities
available for their workers. Because of cultural reasons, some tribes in theTabora region did not use toilets.

4.5.6 CPA record keeping
95% of the farmers visited did not record the CPA applications they conducted.
With a largely illiterate network of farmers, this may continue to be a challenge.
Simultaneously, 59% of the farmers visited were unaware of the correct re-entry
period after CPA application.
ULT response: “For the new season which (as of August 2015), farmers will be
required to record dates of CPA application and acknowledge whether PPEs wereused. A section is provided on the Farmer Index Card for this information and it isalso being recorded on the MobiLeaf system. The prevention of GTS is also coveredon the ALP Index card and MobiLeaf. FTs are required to check this information oneach visit and countersign the farmers’ declarations. The information is being
collected and analysed by the ALP country team through MobiLeaf.”
Safe work environment: Analysis and Priorities
ATTT´s focus on safe work environment is logical. The situation at the farms
demonstrated that both farmers and workers have insufficient knowledge about
safety measures and therefore additional training is required. Cultural and longstanding practices make change more difficult. In addition, farmers lacked financial
means to ensure a safe and sanitary work environment as they were unable topurchase PPE, provide adequate accommodation or invest in their curing barns tomake them safer. Additional root cause analysis is required to determine the bestsolutions for these issues. As these safety measures must be implemented at thefarm, close monitoring and on-farm assistance by leaf technicians – which requires
a higher leaf technician to farmer ratio – will be necessary to achieve any
meaningful results. Therefore, ATTT´s plan to increase the number of leaf
technicians is very important.

25

Suckeride is applied during the topping to inhibit vertical growth of the tobacco plant and ensure theplant invests its energy in the already grown leaves.

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4.6 ALP Code Principle 6: Freedom of association
Background
Regulations: The ELRA provides for the right of
freedom of association to employees. Section 9(1) of the ELRA states that “Every employee
shall have the right (a) to form and join a tradeunion; (b) to participate in the lawful activitiesof the trade union”. Part IV of ELRA deals withcollective bargaining: “Must be a registeredtrade union that represents majority of theemployees; Recognized as exclusive bargaining
unit agent for the employees; Parties have got
the duty to bargain in good faith”.

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

Section 38 of the ELRA provides that: “trade union officials and representatives play
an important role on behalf of their members in preventing discrimination and inpromoting equal opportunity and good employments relations; trade unions shallnot discriminate by unfairly refusing membership or offering membership oroffering less favorable membership based on discrimination grounds such as
discrimination against color, nationality, tribe or place of origin, race, national
extraction, social origin, political opinion or religion, sex, gender, pregnancy,
marital status or family responsibility, disability, HIV/AIDS, age or station of life.”
The ELRA provides for the establishment of branch of a trade union at workplaceand having workers’ representatives.
Freedom of association: Overall findings and challenges
4.6.1 Labor unions
At the time of the assessment, TPAWU was the only union available to agricultural
workers. This union was operational on a national scale, but could only be joined bypermanent workers as the monthly fees requested by the union made association
impossible for tobacco workers who were not paid until the end of harvest.
4.6.2 Worker representatives
Instead of joining a formal labor union, some workers appointed a single worker as
their representative to negotiate with the farmer whenever necessary. Farmers
welcomed this interaction and no evidence was found of farmers disrespecting thefreedom of association.

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Freedom of association: Risks
4.6.3 Awareness of freedom of association
76% of the farmers and 50% of the workers26 interviewed were aware of the rightof freedom of association and the purpose it served. The lack of awareness could
create situations where workers cannot access the rights they are entitled to.
ULT response: “ULT Tanzania continues to work with Tanzania Plantation andAgricultural Workers Union (TPAWU) in an effort to increase the levels ofawareness amongst workers in rural areas. The one-to one-system of Field
Technician visits is allowing ULT Tanzania to provide further awareness to farmers
on their responsibilities as employers with regards the recognition and respect ofworkers’ rights to freedom of association, as well as to workers on their right to
Freedom of Association.”
Freedom of association: Analysis and Priorities
The general perception among 50% of the leaf technicians that freedom of
association was irrelevant due to the lack of active labor unions in the Tabora
region has most likely contributed to the limited awareness among both farmers
and workers. Therefore, additional training of leaf technicians and farmers is
required.
4.7 ALP Code Principle 7: Compliance with the law
Background
Regulations: Tanzanian law does not require theemployer to issue a written employment
contract to its employee. If a worker is
employed for more than six consecutive months
at one farm, the employer must supply an
employee with a written “statement ofparticulars” (S. 15 of the ELRA), including:










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

name, age, permanent address andsex of the employee;place of recruitment;
job description;
date of commencement;
form and duration of the contract;
place of work;
hours of work;
remuneration, the method of its calculation, and details of any benefits
or payments in kind; andany other prescribed matter.

26

As explained in chapter 2, raising awareness among farmers is a requirement under Phase 1 of the
ALP roll out, while raising awareness among workers is part of Phase 2. As ULT was in Phase 1 at thetime of the assessment, raising worker awareness was not a requirement.

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A contract with an employee shall be of the following types (S. 14 (1) of the ELRA).
i.
ii.
iii.

A contract for an unspecified period of time;
A contract for specified period of time;
A contract for a specific task

Compliance with the law: Overall findings and challenges
4.7.1 Statement of particulars
None of the farmers visited who contracted workers for more than six consecutive
months had issued a “statement of particulars”. In general, workers and farmers
did not see the necessity of documenting the relationship which they considered to
be grounded in mutual trust, driven by a local, tribal culture. Again illiteracy
contributed to the absence of written contracts. Although there were seven farms
with informal contracts, they were not compliant with the abovementioned legal
requirements. The majority of these contracts were issued through the village
leaders in the place of origin of the migrant workers. These village leaders also
witnessed the contract, a practice beneficial to farmers and workers. In summary,farmers were ensured they were engaged with trustworthy workers and workers
avoided exploitation. However, migrant workers from abroad without a work permit
were unable to enjoy this protection.
ULT response: “ULT Tanzania has developed a one-page Worker Contract template
to be provided to every contract farmer and his/her workers. The contract is in
Kiswahili and has been developed in consultation with, and approved by, theMinistry of Labour and the Tanzania Tobacco Board.
The Worker Contract initiative was implemented in August 2015 and is designed
as a training tool for farmers and workers to understand the minimum labour
standards in Tanzania, as well as to provide workers with knowledge of their legal
rights under the Tanzania Employment and Labour Relations Act of 2004 (asamended).”Compliance with the law: Risks
4.7.2 Awareness of legal rights
None of the farmers visited who contracted workers properly informed the workers
about their legal rights and employment conditions. The workers usually only knew
their salary. Other rights, such as, minimum wage, work hours, overtime payment,
benefits, employment contracts or statements of particulars, were unknown tothem. Some farmers stated that they did not feel comfortable talking to theworkers about their legal rights because they were not able to provide their workers
with the benefits and working conditions they were entitled to by law. In addition,
38% of the farmers and 55% of the workers 27 were unaware of the legal
requirements to issue a statement of particulars for workers who work for morethan six consecutive months.
27

As explained in chapter 2, raising awareness among farmers is a requirement under Phase 1 of the
ALP roll out, while raising awareness among workers is part of Phase 2. As ULT was in Phase 1 at thetime of the assessment, raising worker awareness was not a requirement.

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Compliance with the law: Analysis and Priorities
The most important issue for this ALP Code Principle is the information on legal
rights. As they are likely to be more vulnerable than local workers, this is especially
important for migrant workers. Increased efforts are required to assist farmers in
informing their workers of their legal rights, especially when illiteracy creates abarrier.

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5. Concluding remarks

THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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Despite this complex environment with multiple, external stakeholders that posechallenges to the implementation of the ALP, extensive progress had been made inrolling out Phase 1 of the ALP Program. The combined size of the Tabora region andthe influence of numerous external stakeholders had forced ULT to look for creative
ways to reach the farmers to engage them with the ALP.
ULT is clearly committed to and engaged with implementing the ALP Program andfully cooperated with CU to ensure a successful assessment. With the initialprogress, the dynamic character of the region requires additional efforts to move
forward to Phase 2 with four key points of focus. First, the system for building FarmProfiles must be improved and the accuracy of the information collected will
increase the understanding of the situation at the farms. Second, increasing thenumber of leaf technicians and the one-on-one communication with farmers is
required to establish stronger relationships supporting better understanding andadoption of ALP communication to farmers. Third, all external stakeholders need tobe better engaged to solve issues negatively affecting the acceptance of the ALP
among farmers. This includes the role and credit provided by Primary Societies.
Finally, unregistered farmers must be included in the communication and FarmProfiles are required to monitor these farmers and help improve the sustainable
impact of the ALP Program.
In summary, the partnership strategy implementing the ALP Program in Tanzania isan effective model. At the time of the assessment, ULT faced challenges meeting
the requirements in all seven ALP Code Principles with prioritization needed on childlabor, income and work hours and safe work environment. These areas will only be
improved with the use of additional staff and interactive training of farmers. With
time and the continued commitment and collaboration between the two tobaccocompanies a better understanding will be facilitated for the wider adoption of the
ALP Code to all farmers in the Tabora region.
Based on the ULT response and the ALP Programme action plan (Appendix 1), it
can be concluded that ULT has taken CU’s report seriously and it appears that muchprogress has been made since the assessment, including moving to Phase 2 of the
ALP Program implementation. Promising improvements are described in theorganizational structure, the training of field technicians, and data collection. Futureassessments will determine whether these actions have achieved the desired
results.

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Appendices

THIRD PARTY ASSESSMENT
Universal Leaf Tanzania
Tabora Region
AGRICULTURAL LABOR PRACTICES PROGRAM

DRAFT

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Appendix 1. ULT response and ALP Programme action plan

Universal Leaf Tobacco (ULT) Tanzania welcomes Control Union’s comprehensive assessment
and recommendations to further strengthen and improve the Agricultural Labour Practices
Programme being implemented in Tanzania.
ULT Tanzania is pleased that Control Union has recognised the extensive commitment andefforts of the ALP Programme in Tanzania after only three years of implementation. ULTTanzania also acknowledges that additional work is still required and welcomes CU’s
recommendations for enhanced improvements to the Company’s ALP systems and processes.
ULT Tanzania’s objective is the continuous improvement of all its contracted farmers toachieve long term sustainability and adherence to the principles of Good Agricultural Practices(GAP) and Agricultural Labour Practices Code (ALP).
The ULT Tanzania ALP Country Team has taken over the direct management of the ALP
programme following the restructuring of ATTT, which including the disbanding of the ATTTALP Country Team. With the assistance of PMI Africa Team, we have developed andimplemented an extensive action plan in response to the recommendations given in Control
Union’s independent assessment.
People and Processes to manage the ALP Programme
Despite Control Union’s positive appreciation of ULT Tanzania’s commitment and extensive
progress made to date in the implementation of the ALP Programme, CU identified andrecommended four key areas for focus (Ref: 5. Concluding remarks – Page 46/47):
1. Increasing the one-on-one communication with farmers and establish stronger
relationships to facilitate the adoption of the ALP Code.
1.1 As part of Universal Leaf Tanzania’s long-term sustainable tobacco production
strategy, the company has completed a major restructuring of its agronomy extension
model between November 2014 and January 2015. This focused on improving the ratio ofField Technicians to Farmers to encompass a complete ‘one-to-one’ extension training andmonitoring programme.
Since January 2015, company policy recommends a technician to farmer ratio that willallow for a minimum of six visits during the growing season for each farmer by fieldtechnicians. From an original ratio of 242 farmers per technician, this currently equates toa ratio of no more than 150 farmers per individual technician. This is being implemented inorder to achieve alignment to the company’s long term GAP & ALP objectives. With the
improved one on one contact with farmers, Field Technicians are able to spend more timewith individual growers for training and monitoring.

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In addition, Field Technicians are continuously supported in their ALP roles by an enhanced
team of 2 National ALP Coordinators and 26 ALP Sector Coordinators based across all
growing areas.
The restructuring of ULT Tanzania Field teams from separate ALP and Leaf technicians toeach Field Technician providing a holistic approach to training in GAP, ALP and Forestry will
also help to improve quality of training given to farmers.
Having direct contact with the farmer and collecting information through farmer index
cards and the MobiLeaf electronic data collection system will result in far more detailed
information being recorded on farms. This data will be used to analyse and identify issues
that require further attention to support the continued improvement in GAP and ALP
compliance.
Direct contact with individual farmers provides far more detailed information relating to
ALP issues and a far greater opportunity for the Field Technicians and ALP coordinators tomonitor and address problematic practices.
Field Technicians are expected to visit each individual farmer at least six times over thegrowing season in addition to attending group meetings and training. The FT visits andactivities are recorded both on the farmer index card and MobiLeaf.
Field Technician and ALP coordinator training will be improved by translation of the ALP
principles into Kiswahili for the 2016 crop with greater emphasis on the training of theweaker areas of a Technician’s understanding.
Training and understanding is formally tested and assessed after each training session andentered in the FT’s personal training log to enable management to continually improvetraining programs and Field Technician personal development objectives each year.
1.1.2 Specific ALP-related responsibilities and Key Performance Indicators (KPIs) have beenformally included in the job descriptions and objectives of all relevant personnel from Field
Technicians to senior Agronomy Management since August 2015.
1.1.3 Since August 2014, the ULT Tanzania GAP Country Team has implemented a
programme of quarterly performance and understanding evaluations of all agronomy
extension personnel (from divisional management through to Field Technicians). The
objective is to identify each individual’s strengths and weaknesses in relation to their GAP& ALP understanding and progressively improve their skills and knowledge, in order totransfer these effectively to all farmers. A competency profile of every Field Technician’s
knowledge and understanding of GAP & ALP is updated on an annual basis in order tohighlight individual training requirements.

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1.1.4 The GAP Country Team now meets as a steering committee each quarter, to review
the progress of the ALP Programme and implement improvements, as required. Specificissues are being dealt with through extraordinary meetings if or when required.
In addition, the ALP Country coordinator teams will meet on a more regular basis, monthly
or even weekly if or when required. Meetings will be recorded and feedback provided to
the GAP Country Team.
The increase in frequency of meetings will result in management having a better
understanding of day to day ALP activities, provide support in developing solutions to
issues and track implementation of individual farm improvement plans.
Examples of the improvements already being implemented by the GAP Country Team
Steering Committee are:a. Development of the ALP monitoring programme to identify farmers with potential
issues so as to provide extra monitoring and support.
b. Development of the concept paper for the collaboration with Village Child Labour
Committee (VCLC), District Child Labour Committee (DCLC), Gender Forum and Tabora
Development Foundation Trust (TDFT), so that the tasks that constitute Hazardous
work for children can be better understood at a community level.
c. Model farmer: introducing a farmer mentoring speaker. Identifying an influential
farmer who is well trained and who stands out as a role model in Primary Societies tofurther communicate about what constitutes hazardous work.
1.2 Improving the accuracy of the information collected and the understanding of the situation
at the farms.
1.2.1 In October 2014, ULT Tanzania reviewed the procedure in which Farm Profiles wererecorded and collected by Field Technicians. New measures included Farm Profiles being
completed in Kiswahili to improve accuracy. All Farm Profiles were completed on-farm, toensure confirmation of the data collected. ALP Area Coordinators conducted a 10%
verification check per Field Technician to ensure understanding and data accuracy. In
addition, a carbon copy of the Farm Profile in Kiswahili language was given to the Farmer
as a reference for his/her own records. This was implemented with the intention todemonstrate to farmers the importance of keeping records and to increase transparency
about the data being collected.
Pre-season confirmation and a master list of Farmers for whom every Field Technician is
responsible, will also ensure annual Farm Profile targets are met without duplications or
inaccurate farmer names. In addition, ULT Tanzania has complemented manual datacollection with electronic data collection as of August 2015, through the MobiLeaf digital
data collection system which streamlines the efficiency of Farm Profile collation.
The MobiLeaf system is based on a proprietary application running on an Android tablet
with data synched to central servers. During the 2014/15 season, 20% of farmer data was
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collected with MobiLeaf. Over the 2015/16 season, 100% of farmer profile data will becollected electronically.
The system will be used to collect information on all aspects of the farmer’s tobacco
growing and forestry programme as well as detailed Agricultural Labour Practices data. A
particularly important feature is that the application will highlight new issues or potential
issues from previously entered data, thus providing an important feedback to the farmer
by the Technician.
All Technicians have been trained on the tablets which were rolled out during the 2014/15
season, with a number of challenges encountered due to the scale of the project. These
included the registering of new farmers in the system, the movement of farmers between
technicians and the misunderstanding of requirements on certain data capture screens.
These challenges will be managed more effectively in the 2015/16 season with a new
training format. The MobiLeaf system will be fully updated and simplified for the crop
season and training will be systematically rolled out, region by region by a strengthened
training team.
The MobiLeaf system will have a dedicated management structure including training, IT
and support functions to make sure the system runs smoothly and efficiently.
The MobiLeaf system will replace all data gathering done with excel spreadsheets in thegrowing area and regional offices. This means that senior management will have access tolive data enabling them to react to issues on the ground in a much shorter time scale.
1.2.2 In October 2014, ULT Tanzania reviewed the procedure with which Prompt Actions
were recorded and collected by Field Technicians, as well as the resulting follow-up
procedures. Prompt Action recording books have been improved and translated to
Kiswahili language. Prompt Actions and follow-ups are also recorded on the MobiLeaf
tablets. In addition, all Prompt Action follow-up is monitored by ALP Sector Coordinators
on a case-by-case basis. Reporting and analysis is communicated to all senior managers on
a monthly basis.
Continuous training of Field Technicians and close monitoring by ALP Coordinators willfurther improve Prompt Action understanding.
All Field technicians and ALP Coordinators will receive training on Prompt Action reporting.
The training will include the following elements:

Identifying and distinguishing between compliant or non-compliant situations on
farms;
Procedures for identifying what Prompt Action should be taken and reported;
Describing issues and ages for the Prompt Action;
Follow-up actions and procedures.
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During training, FTs will be assessed using the quality of their previously reported Prompt
Actions and their understanding will be tested through role play of potential situations
found on farms.
Training in Prompt Action reporting will continue throughout each season to ensure all
field technicians understand and meet operating procedures. Training is conducted instructured sessions every quarter, as well as through unannounced FT visits by the ALP
coordinator team.
The Prompt Actions are followed up and documented during the next visit by the FT, or if
the case is critical, by an ALP coordinator or a Sector Manager in quick response.
Prompt Action reports are compiled in the Sector Office by the ALP Coordinator, these arethen passed through the Regional Coordinators to National Office for analysis andreporting to ULT Tanzania. As a result of improved data collection systems and improved
FTs knowledge, prompt action reporting increased from 802 cases in August 2013 to 2,811
in July 2015.
1.3 All external stakeholders need to be better engaged to solve issues negatively affecting theoverall situation of the farmers.
1.3.1 Communications between Banks, Primary Societies, Unions and ULT Tanzania is being
further strengthened, the main objective being to work collaboratively to reduce potential
farmer debt.
In Tanzania, merchants such as ULT Tanzania no longer provide crop finance to farmers.
The Tanzania Government introduced crop reforms mandating that inputs be purchased
through the unions and distributed to their farmers through Primary Societies. Under thisrestructuring the Primary Societies negotiate loans with the banks on behalf of theirmembers in order to finance the inputs.
Volumes of inputs required are now directly linked to contracted production and purchasevolumes. These are agreed before the Primary Societies approach the banks for funding.
As per the provisions of the Tanzania Tobacco Council and Primary Society contracts(Clause 3.2), all stakeholders will communicate with other relevant parties on PrimarySociety and Farmer loan transactions and the recovery of those debts through tobacco
sales.
After each sale of tobacco, ULT Tanzania will communicate with the respective PrimarySociety and banks to indicate anticipated Loan Recoveries based on those sales.
Through these procedures, the management of debts is transparent and it is hoped thisprocess will lead to reduced debt issues faced by farmers.
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1.4 Addressing the issue of unregistered farmers, given that in these cases there is nocommunication or visibility into the farm practices.
1.4.1 From 2015, all Primary Society contracted farmers are identified on the ULT Tanzania
and Primary Society purchase contract. In addition, ULT Tanzania requires each of theidentified farmers to have a formal contract with the Primary Society with a copy provided
to ULT Tanzania.
These lists and contracts are the base from which farmers are allocated to Field
Technicians for registration and the implementation of the ALP Program, from support, totraining and systematic monitoring.
1.4.2 The contracted farmers are strictly prohibited from sub-contracting to unregisteredfarmers. This is enforced through Field Technician visits and the GPS identification of all
fields and curing barns. The primary objective of clearly identifying every contracted farmer
is to implement GAP through field extension support which helps farmers to improve thequality and productivity of their crops, respect for the environment with a particular focus
on Forestry, and in meeting the ALP Code standards to achieve safe and fair working
conditions on their farms.
Through this enhanced extension support, ULT Tanzania and its partners are working
closely with farmers, to improve communication and training and to prevent, identify andprogressively eliminate risks and issues faced on farms.
Through direct contracting, and the prohibition of sub-contracting, ULT Tanzania is ensuringthat every farmer receives at least 6 visits from a Field Technician per season and therefore
all purchased tobacco will come from farmers implementing the ALP program. Tobacco will
not be purchased from unregistered farmers.

2. Farm level assessment of ALP Code standards(REF: 4. FARM LEVEL ASSESSMENT OF ALP CODE STANDARDS – PAGE 26)

ULT Tanzania recognises many of the issues identified by Control Union during the farm levelassessment are in the context of the existing socio-economic and cultural traditions present in
the rural farming communities of Tanzania. ULT Tanzania is fully committed to working with all
stakeholders on an industry-wide approach to address these issues by first understanding theroot causes at farm level, followed by implementing tangible and measurable solutions toprogressively improve the labour practices of all contracted farmers. Those issues identified byControl Union that are under the direct control of ULT Tanzania will be addressed as quickly as
is practically possible.

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2.1 Child labour prevention and elimination
While CU acknowledges the awareness levels of the legal minimum working age and hazardous
work among both farmers and workers is relatively high, CU found this had not yet translated
into all-encompassing behaviour change. ULT Tanzania will continue an integrated approach
towards the prevention and elimination of child labour in the rural communities in which it has
a presence.
The elimination of child labour and hazardous work for children is covered in one of ULTTanzania’s annual Sustainable Tobacco Production (STP) initiatives which will be a key
measurable in ULT Tanzania’s reporting for the 2015/16 crop season and beyond.
The initiative identifies a number of commitments towards managing this principle:
1. Expanding ALP training to all contracted farmers, their spouses and other members of
the farming family. Training will also include hired workers;
2. Training in collaboration with other stakeholders, including village councils, school
teachers, health officers;
3. Providing specific training and understanding on child labour and hazardous work forchildren at each Field Technician visit;
4. Developing innovative approaches to training, namely drama groups and radio
programmes;
5. Model farmer: introducing a farmer mentoring speaker. Identifying an influential
farmer who is well trained and who stands out as a role model in Primary Societies;
6. 100% completion and monitoring of ALP registrations;
7. Prompt actions management including causal factors and follow-up process anddocumentation;
8. The development of farmer improvement plans where issues are identified.
Through increased training and awareness programmes aimed at farmers and local
communities, ULT Tanzania is continually working towards an improved understanding of the
ALP codes relating to Child Labour, hazardous work for children and their requirements.
The Field Technicians will continue to receive training and communication on what is
acceptable in relation to tasks that children can and cannot do when working with tobacco. In
addition, the issues are clearly indicated both on Farmer Index Cards and on the MobiLeaf
system.
Prompt Action reporting is used to report on and deal with child labour issues identified in thegrowing areas.
Child Labour: Ongoing and developing initiatives
2.1.1 ULT Tanzania will continue to engage farmers on the legal minimum working age with a
new focus through training of farmers and their spouses/partners during each Technician visit
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Control Union Certificationsand via multiple channels such as drama groups and radio programmes to achieve improved
understanding of the target audience.
ULT Tanzania recognises the role of women in the family business and will continue offering
training to the wives of male farmers. Training offered to spouses will include: the differences
between child labour and child work, understanding hazardous work for children, as well as for
pregnant and nursing mothers and encouraging them to make sure children attend school.
Field Technicians are encouraging farmer spouses to attend meetings relating to the ALP
principles. The spouse’s attendance is recorded on the MobiLeaf system. In 2014/15, over
29,000 spouses were recorded as having attended training sessions which was over the 20,000
target set for the season. In future seasons, the target number of spouses will be collected at
the time of farmer registration. The target is 100% of contracted farmers’ spouses.
2.1.2 Another primary channel of communication identified, is through a Village Child Labour
Committee (VCLC)28 which are already set up in some villages. Above these is the District Child
Labour Committee (DCLC).
These “DCLCs’ and VCLCs” have been developed and implemented by current NGO projects
such as the Eliminating Child Labour in Tobacco Growing Foundation’s (ECLT) PROSPER29 in
Urambo, Sikonge and Kaliua. However, at present there are only a small number of thesecommittees set up in the growing areas.
ULT Tanzania, through the previous ATTT structure, identified that these channels could be
useful to enhance awareness and understanding of the ALP programme, communicate to awider audience, effect buy-in from communities close to the farmers and encourage local
government officials to participate in the programme to help address non-compliance issues
identified.
The following actions are in progress:
a.
b.
c.
d.

Gathering information as to where in ULT Tanzania operations DCLCs and VCLCs
have been formed;
Identifying where there are such Committees, if they were created for specificprojects or are if they are an ongoing entity;
Identifying the composition of the Committees at District and Village level;
Identifying if there are any other key stakeholders in the committees to be
included in communications.

28

Formation of the Village Child Labor Committees is supported by the Government and a directive is inplace for their formation under the guidance of the National Inter Sectorial Coordination Committee.
(Ref Letter and Terms of Reference from the office of the Permanent Secretary of the Ministry ofrdLabour, Employment and Youth Development of Tanzania. 3 August 2007)
29
PROSPER (Promoting Sustainable Practices to Eradicate Child Labour in Tobacco) is a program
designed to complement efforts by the government, employers, workers, and civil society organizations
in fighting child labor in the tobacco-growing sector in Tanzania. The program is funded by the
Eliminating Child Labour in Tobacco Growing Foundation (ECLT).

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The objective of developing these communication channels is to encourage deeper culturalawareness and behavioural change, particularly in relation to child labour.
Initially, these communication links will be initiated through the DCLC’s already set up in
Urambo, Sikonge and Kaliua. The effectiveness will be assessed at the end of the growing
season to identify what could be changed or improved before rolling out to a larger area
where the communities can support effective communication and relevant stakeholders
support the initiative
2.1.3 Survey of orphan children living on tobacco farms
During the 2015/2016 season, ULT Tanzania will collect and monitor data on all orphans at
contracted farms, through the MobiLeaf system. The information includes: name, gender, age,school enrolment, school attendance, resident on or off farm and if any hazardous tasks are
performed.
2.1.4 Promote access to education
ULT Tanzania strives to reduce or eliminate the root causes of child labour. Many schools inrural areas are in bad condition or are overcrowded and fail to provide a good learning
environment. Education is a key theme and objective in ULT Tanzania’s approach to tackle
child labour, and the company responds to many requests for help from various education
authorities or from its own area managers with support for the refurbishment of schools. In
the last few years, for example, ULT Tanzania has invested over 100,000,000 TZS (US$ 46,055
at the current exchange rate) to refurbish or enlarge 7 schools, more than 31,000,000 TZS (US$14,277) to supply desks to 6 schools and over 20,000,000 TZS (US$ 9,211) to provide textbooks
to 2 schools. These contributions have helped improve education conditions for approximately
2,500 children.
2.1.5 National Conference “Pathways to Sustainability: Together We Can Eradicate Child
Labour in Agriculture” (2015)30
ULT Tanzania actively engaged with the Government of Tanzania and supported a two and ahalf day conference organized through the Prime Minister’s Office – Regional Administrationand Local Government (PMO-RALG) and the Ministry of Labour and Employment (MoLE) in
collaboration with the Elimination of Child Labour in Tobacco-growing Foundation (ECLT) and
its implementing partner Winrock International. ULT Tanzania and ATTT also took an active
part in the conference and ATTT made a presentation on the practices adopted by the tobacco
sector to address child labour, with particular emphasis on the implementation of ALP.
The conference, which took place on 12-13 May 2015 in Dar es Salaam, brought together
different sectors in agriculture, trade unions, authorities, NGOs, and community members to30

http://tanzaniachildlabourconference.org/index.html

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discuss avenues for eliminating child labour in agriculture in Tanzania. The conference wasattended by 140 people and covered the tobacco, sisal, tea and fishing sectors. The objectivesof the conference were to:












assess the child labour situation in agriculture in Tanzania based on prepared researchand papers that consolidate efforts being made by stakeholders to address the
problem;share best practices and sustainable solutions/approaches towards addressing childlabour in agriculture, discuss and agree on priority actions towards the elimination ofworst forms of child labour in agriculture, reach consensus on safe work for youth inagriculture or rural value chains and agree on lists of hazardous work;
agree on strategies to accelerate progress towards addressing child labour in the
agriculture sectors (farming, fisheries, livestock rearing) where the majority of childlabour cases are found;strategize on ways to promote public-private partnerships (PPPs) in addressing childlabour in agriculture;accelerate the implementation of the National Action Plan (NAP) to combat childlabour and make recommendations for the new NAP;
agree on strategies to promote district-level coordination and NAP implementation;agree on ways to streamline efforts to address child labour within child protection
systems;
develop an outcome document stipulating specific commitments and concrete action
by sectors and actors/stakeholders, including the private sector, and mobilize
resources.

At the end of the conference the various stakeholders summarized their recommendations to
the government in a formal document31. Recommendations included:
1. mainstream the issue of child labour in national programs, policies and all sectors
including agriculture and education;
2. build the capacity of the Ministry of Labour and Employment and the National
Intersectoral Coordination Committee (NISCC) in coordination, dissemination of
information and raising community awareness at all levels;
3. strengthen monitoring and evaluation mechanisms on child labour and build thecapacity of District and Village Committees and Labour Officers;
4. the Government to review and evaluate the National Action Plan (NAP) with the Social
Partners and under the leadership of the NISCC, ensuring the allocation of required
resources;
5. the Government to establish and manage the shared/integrated Child Labour
Monitoring Systems (CLMS);
6. develop a new NAP in the light of lessons from current NAP and involve all sectors
including agriculture;31

ECLT Foundation, http://www.eclt.org/wp-content/uploads/2015/09/Pathways-to-SustainabilityConference-Report-on-Conference-proceedings-J...-1.pdf

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7. engage full time, a dedicated focal point in the Ministry of Labour and Employment
who will ensure the implementation of the Outcome Document and report to the
NISCC;
8. ensure increased involvement of the media as one of the key stakeholders incampaigning against child labour;
9. the Ministry of Labour and Employment to continue with coordination of child labour
interventions with close support from stakeholders;
10. undertake district capacity building on child labour and sensitize district authorities tomake budgetary allocations for child labour interventions;11. the NISCC should oversee all subsequent activities following the conference and reportto stakeholders.
ULT Tanzania continues to be very involved in supporting the work of the NISCC and working
with the ECLT implementing partners to engage with government in the fight against childlabour. The NISCC has already met to define priorities of work.
2.1.7 ECLT Country Plan
By the end of 2015, the 54-month ECLT Country Plan to eliminate child labour in tobaccogrowing in Tabora region will come to an end. The board of ECLT on which ULT is represented
agreed to fund a new Country Plan for 2016-2017 focused on advocacy and increased technicalassistance to the government, district level coordination, youth employment, and targetedinterventions to prevent child labour and promote school retention (e.g. Village Saving andLoans Associations, referral services, awareness raising). The new project will start in April
2016, and ULT Tanzania has actively engaged with the ECLT and its implementing partners to
support their efforts, including in defining priorities and areas of intervention.
2.1.8 Collaboration with the Eliminating Child Labour in Tobacco Growing Foundation (ECLT):
Public Private Partnership with the International Labour Organization (ILO) to develop global
guidance on hazardous child labour32
In May 2015, the ILO and the ECLT entered into an agreement to develop global guidance on
hazardous child labour and occupational safety in tobacco production and to support
associated social dialogue in three pilot countries, including Tanzania. The deliverables, theprocess and the timelines still have to be finalized. ULT Tanzania will support the efforts madethrough this public private partnership.

32

http://www.ilo.org/pardev/partnerships/public-privatepartnerships/WCMS_371395/lang--en/index.htm

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2.2 Income & Work Hours and Compliance with the Law
2.2.1 ULT Tanzania has developed a one-page Worker Contract template to be provided toevery contract farmer and his/her workers. The contract is in Kiswahili and has been developedin consultation with, and approved by, the Ministry of Labour and the Tanzania Tobacco Board.
The Worker Contract initiative was implemented in August 2015 and is designed as a training
tool for farmers and workers to understand the minimum labour standards in Tanzania, as wellas to provide workers with knowledge of their legal rights under the Tanzania Employment andLabour Relations Act of 2004 (as amended).
The contracts are provided to farmers through Primary Societies and directly by FTs who thenexplain the concept for those farmers who are illiterate.
ULT Tanzania understands this initiative may be slow to gain acceptance with farmers initially,
but ULT Tanzania is positive that behaviour change and acceptance towards complying withthe minimum legal income and work hours will progressively improve year on year.
In addition, farmers now agree under their Farmer Production Contracts to follow at least theminimum employment requirements as stipulated under the Employment and Labour
Relations Act of 2004.
2.2.2 ULT Tanzania has also identified Income and Work Hours as an area that needs to beaddressed and requiring effective initiatives for change. In this regard, a Support mechanism
for workers and farmers was rolled out in January 2014 as a pilot project in Tabora Region. The
Support mechanism is run by a third-party NGO, the Tabora Development Foundation Trust(TDFT), which is supported by the international NGO Winrock International.
The support mechanism provides a means for farmworkers to anonymously or confidentiallyreport and discuss any grievances including those related to income and work hours througheither a call centre or local “community activists” (see section 2.3 – Fair Treatment for moredetail on the ongoing support mechanism).
2.3 Fair Treatment
2.3.1 Since 2014, a support mechanism was made available to farmers and workers inpartnership with a local NGO, the Tabora Development Foundation Trust (TDFT). The support
mechanism leverages on dedicated staffed, so called “community activists” (CA) due to theirrole of engaging with all relevant members of the communities from seven key areas of theTabora Region. In addition, the support mechanism offers a toll-free line to allow analternative avenue for workers and farmers to raise their concerns.
Community Activists receive training from ULT Tanzania and support from TDFT management.
All calls are confidential and issues identified are followed up and dealt with by the TDFT
Community Activists. On receipt of a call, the operator records as many details as possible,
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contacts and mobilises the area CA who will follow-up and deal with the case. Cases are thenreported through CAs back to TDFT headquarters. General information and data on the issues
reported is shared with ULT Tanzania. It is important to note that TDFT does not sharepersonal information with ULT Tanzania. In the first year of operation, 67 cases were reported,
most of which related to workers’ payments, breach of contract, and unfair treatment.
The rollout of the support mechanism was through an awareness campaign including 15,000
flyers, with at least one per farmer, distributed to and discussed with farmers and theirworkers through ULT’s Field Technicians. The initial uptake and use of the support mechanism
appears to be limited, however, further analysis is ongoing to evaluate its potential.
It is difficult to draw conclusions from a relatively small sample, but it does indicate thatperhaps the biggest challenge faced is to make sure that all farmers and their workers fully
understand the availability and reason for the mechanism and that all calls are confidential.
Following the first pilot, which ended in January 2015, the following actions were discussed
and agreed with TDFT:
Continue the pilot in the following crop season after a joint evaluation of the pilot
phase to understand and develop answers to the challenges and weaknesses
identified:
An assessment of the current support mechanism will take place in September
2015. Following this and subject to the findings of such an assessment, ULT
Tanzania will support TDFT in implementing action plans to improve thefunctioning of the support mechanism before expanding the initiative to othergrowing regions because of its important role in providing a free, independent,
confidential, support to tobacco farmers and their employees.

Continue to focus efforts in the same areas during the 2015/16 season which willthen be followed by an internal assessment and potential to expand to additional
growing regions.

Action plans were also put in place to document the distribution of training materials and thetraining provided including the level of awareness of farmers and workers.
In 2015/16, all farmers and their workers in the target area will receive a business card
containing details of the support mechanism. In addition, all Farmer Index Cards and Worker
Contracts will have the support mechanism number printed on them. The Support mechanism
will also be communicated to all farmers and workers in the target area through local radio
broadcasts, leaflets, and posters.
The support mechanism is considered a key component of the effective implementation of ALP
and ULT Tanzania will continue to support its implementation for farmers and their workers.

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2.4 Forced Labour
2.4.1 As per Control Union’s recommendation, ULT Tanzania will further investigate andmonitor migrant workers on farms. In addition to capturing the number of migrant workers
from countries other than Tanzania, ULT Tanzania undertook to capture the number of
migrant workers from other regions of Tanzania working on farms during the 2014/2015
season.
This programme will be enhanced in the 2015/16 season with clearer identification throughMobilLeaf data capture of types of migrants, whether from within or outside of Tanzania,
languages spoken, payments types and frequency, and all risks associated with migrant labourthat FTs need to be aware of.
This will help ULT Tanzania, and the FTs, identify workers who may be more at risk due to theirdependency on their employer. This information will be used to encourage the FTs to be more
attentive to potential issues, in particular any end of season payments for workers.
Migrant workers are being registered and monitored by FTs and the ALP country team throughthe farm profiles, MobiLeaf and the ALP monitoring reports.
Awareness and access to the Support Mechanism for all migrant workers is also a priority. Thisis being achieved through the distribution of business card size leaflets to all workers. It is
hoped these will be easier for them to keep for future reference.
2.5 Safe Work Environment
2.5.1 ULT Tanzania has proposed a Sustainable Tobacco Production (STP) initiative for Safe
Work Environment which will be a key measurable in our reporting for the 2015/16 crop
season and beyond.
The initiative identifies seven key steps towards addressing this ALP principle:
1. Developing and implementing a Safe Working Environment strategy based on local
conditions and implement at farmer level through training, demonstration andleaflets.
2. Ensuring all farmers receive a Personal Protective Equipment (PPE) Pack in theirpre-season inputs (as described below in 2.5.2).
3. Ensuring all farmers receive appropriate documentation and training on and for: safe storage, use and disposal of CPAs and fertiliser;
 recording the application of CPAs;
 identifying re-entry times on crops applied with CPA; preventing and mitigating exposure to Green Tobacco Sickness.
4. Ensuring 100% contracted farms receive communication on ALP from Field
Technicians, including safe work environment and clean, safe and adequate
accommodation to farmers and workers.
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5. Ensuring 100% of ALP Farm Profiles completed accurately for every contracted
farm.
6. Farm-by-Farm monitoring of conditions on farms and adherence to the ALP CodePrinciples by Field Technicians through 6 visits per season to each farmer.
7. Prompt Action reporting by Field Technicians of ‘immediate risk’ conditions andsubsequent follow-up and reporting to National office.
8. Address the area of worker accommodation as identified by Control Union. The
objective of the STP is to increase the number of workers with access to decent
accommodation.
Action plans being put in place include: Informing the farmer about the housing improvements he/she needs to make.
 Helping the farmer identify the priority areas and prepare an improvementplan.
 Inform farmer that a coordinator will contact him/her to follow-up on
improvement plan previously agreed.
2.5.2 ULT Tanzania engaged with the Tanzania Tobacco Council (TTC) for the provision of a
Personal Protective Equipment (PPE) Pack to every farmer on an annual basis.
The relevant Unions supplying farmer inputs will be required to issue every farmer with acomprehensive PPE pack per hectare of tobacco cultivated, consisting of four pairs of work
gloves, eye goggles, mouth masks and two light-weight protective ponchos covering 75% of
the body. These will be included in the farmer inputs package in 2015/16 season. The type andquality of the PPE has been approved by the TTC.
The pack will be delivered in a lockable box to be used for CPA storage.
2.5.3 The one-to-one system of Field Technician visits is allowing ULT Tanzania to provide
direct training and documentation to all contracted farmers and their workers on a range ofissues related to Safe Work Environment. These include safe storage and handling of Crop
Protection Agents (CPA) and the prevention of Green Tobacco Sickness (GTS).
2.5.4 For the new season which (as of August 2015), farmers will be required to record datesof CPA application and acknowledge whether PPEs were used. A section is provided on the
Farmer Index Card for this information and it is also being recorded on the MobiLeaf system.
The prevention of GTS is also covered on the ALP Index card and MobiLeaf.
FTs are required to check this information on each visit and countersign the farmers’
declarations. The information is being collected and analysed by the ALP country team through
MobiLeaf.
2.5.5 ULT Tanzania will be developing a programme in the 2016/2017 season for the collection
and destruction of used CPA containers.

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2.6. Freedom of Association
2.6.1 ULT Tanzania continues to work with Tanzania Plantation and Agricultural Workers Union(TPAWU) in an effort to increase the levels of awareness amongst workers in rural areas. The
one-to one-system of Field Technician visits is allowing ULT Tanzania to provide further
awareness to farmers on their responsibilities as employers with regards the recognition andrespect of workers’ rights to freedom of association, as well as to workers on their right to
Freedom of Association.

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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. 33
2) No person below 18 is involved in any type of hazardous work.
3) In the case of family farms, a child may only help on his or her family’s farm
provided that the work is light work and the child is between 13 and 15 34
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.

33

As an exception, pursuant to ILO Convention 138, developing countries may under certain circumstances specify a minimum ageof 14 years.
34
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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