THIRD PARTY ASSESSMENTMASSALIN PARTICULARES S.R.L.
ARGENTINEAN NEA REGION

Agricultural Labor Practices Program

December, 2015

External Assessment

Table of Content
Glossary of terms and acronyms.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 51. ALP Program background and assessment overview.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 72. Massalin assessment: scope and methodology. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 10
2.1 Scope. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.2 Opening meeting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.3 Staff interviews and ALP Program documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.4 Farm sample selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.5 Farm visits. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2.6 Persons interviewed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2.7 Closing meeting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
2.8 Preparation of the final report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3. Assessment of the implementation of Phase 1 of the ALP Program.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 16
3.1 Conduct of the assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.2 People and processes to manage the ALP Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.2.1 Internal structure for ALP implementation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.2.2 Role of NGO CONCIENCIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.2.3 Internal communication and reporting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.2.4 ALP training, roles and responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.2.5 Engagement with the ALP Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.3 Communicating the ALP Code requirements to all farmers. . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.3.1 The ALP communication strategy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.3.2 ALP communication methods and materials. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.3.3 Understanding and perception of the ALP Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
3.4 Building Farm Profiles for all contracted farms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
3.4.1 Data gathering system for Farm Profiles. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
3.4.2 Accuracy of Farm Profiles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
3.4.3 Analysis on information Farm Profiles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

External Assessment

3.5 Prompt Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
3.5.1 Prompt Action reporting mechanism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
3.5.2 Understanding Prompt Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
3.5.3 Addressing Prompt Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
4. Assessment of the current status of Phase 2 of the ALP Program.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 26
4.1 Monitoring of labor practices farm by farm . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
4.1.1 Selection of issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
4.1.2 Mechanism for monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
4.2 Address widespread and/or systemic issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
4.2.1 Investigation of root causes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
4.2.2. Initiatives to address widespread and/or systemic issues. . . . . . . . . . . . . . . . . . . . . . . 28
4.2.3 Stakeholder engagement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
4.3 Support mechanism. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
4.3.1 Hotline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
5. Farm level assessment of ALP Code standards. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 30
5.1 ALP Code Principle 1: Child labor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
5.1.1 Prevalence of children working . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
5.1.2 Awareness of legal minimum working age. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
5.1.3 Awareness of hazardous work. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
5.1.4 Age verification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
5.2 ALP Code Principle 2: Income and work hours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
5.2.1 Minimum salary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
5.2.2 Payment schedule. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.3 Regular and overtime hours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.4 Legal benefits. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.5 Awareness of legal requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.6 Awareness of legal work hours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.7 Record keeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.8. Exchange of labor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
5.2.9 Sharecropping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

3

External Assessment

5.3 ALP Code Principle 3: Fair treatment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
5.3.1 Fair treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
5.3.2 Communication with workers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
5.4 ALP Code Principle 4: Forced labor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
5.4.1 No evidence of workers unable to leave their job. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
5.4.2 Financial problems among farmers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
5.4.3 Payment schedule. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
5.5 ALP Code Principle 5: Safe work environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
5.5.1 Training and awareness of Green Tobacco Sickness (GTS). . . . . . . . . . . . . . . . . . . . . . . 40
5.5.2 CPA handling and training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
5.5.3 Clean drinking and washing water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
5.5.4 Worker accommodation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
5.5.5 Re-entry period. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
5.5.6 CPA storage and final disposal. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
5.5.7 General safety measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
5.6 ALP Code Principle 6: Freedom of association . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
5.6.1 Workers’ right to freedom of association. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
5.6.2 Awareness of freedom of association . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
5.7 ALP Code Principle 7: Compliance with the law. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
5.7.1 Information on legal rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
5.7.2 Employment contracts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
Concluding remarks. .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 46
Appendices.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 48
Appendix 1. Massalin response and ALP Program action plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Appendix 2. ALP Code. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

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External Assessment

Glossary of terms and acronyms
ACTIM

Asociación de Campesinos Tabacaleros Independientes de Misiones(Tobacco Independent Farmers Association from Misiones)

ALP

Agricultural Labor Practices

ALP Code

PMI’s Agricultural Labor Practices Code

ALP Code Principle

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

ALP Program

Agricultural Labor Practices Program

BU

Burley tobacco

CA

Corporate Affairs

CASAFE

Cámara Argentina de Sanidad y Fertilizantes (Chamber of Agricultural
Health and Fertilizers)

CU

Control Union

COTTAPROM

Comisión Técnica de Tabaco de la Provincia de Misiones (Tobacco
Technical Commission of the Province of Misiones)

CPA

Crop Protection Agents

CTM

Cooperativa Tabacalera de Misiones Ltda. (Tobacco Cooperative of
Misiones)

Family farm

A farm that depends mainly on family members for the production of
tobaccoFarm Profiles

A data collecting tool developed by PMI with Verité to track the socioeconomic 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

GAP

Good Agricultural Practices

GTS

Green Tobacco Sickness

Leaf tobacco supplierCompany that has a contract with PMI to supply tobacco but is not a
farmerMassalin Particulares S.R.L.

PMI affiliate in Argentina (Massalin)

Migrant labor

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

Measurable Standard

A Measurable Standard defines a good labor practice on a tobacco farmand helps determine to what extent the labor conditions and practices
on a tobacco farm are in line with each of the ALP Code principles
5External Assessment

NGO

Non-Governmental OrganizationOC

PMI Operations Center (Lausanne, Switzerland)

Phase 1

Startup of ALP Program (training, communications, outreach)Phase 2

ALP Program full implementation (monitoring, addressing problems)

Piece work

Payment at a fixed rate per unit of production/work completed

PMI

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

PPE

Personal Protection Equipment

Prompt Action

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

STP

Sustainable Tobacco Production

Support mechanism

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 improvetheir labor and business practices.

UIF

Unemployment Insurance Fund, which provides compensation to
insured workers that became unemployed.

ULT

Universal Leaf Tobacco

ULSA

Universal Leaf South Africa, a local subsidiary of Universal

Support mechanism

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

6

Chapter 1

ALP Program background andassessment overview

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

In 2011, Philip Morris International Inc. (PMI)1
launched a worldwide Agricultural Labor Practices(ALP) program to progressively eliminate child laborand other labor abuses where they are found and toachieve safe and fair working conditions on tobacco
farms. This program applies to all tobacco farms
with which PMI or PMI´s leaf tobacco suppliers havecontracts to grow tobacco for PMI and consist offour main components:
1. the Agricultural Labor Practices Code, setting
clear standards for all tobacco farms growing
tobacco from which PMI ultimately buys;
2. an extensive training program for all PMI andleaf tobacco 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 internalmonitoring system; andandexternal

4. involvement of governmental and nongovernmental(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 componentof the ALP Program working in tandem with Verité
to assess PMI leaf tobacco suppliers and tobacco
farms worldwide. All PMI leaf tobacco suppliers
submit internal, annual reports and are assessed
regularly on their performance. For the ALP Program
implementation, internal reviews are also being
performed to assess the progress and challenges
in the program’s implementation. Third party
assessments are periodic reviews undertaken by
CU of PMI leaf tobacco suppliers and tobacco farms
worldwide. In this initial stage of implementing
the ALP Program, these third party assessments
focus on the ALP Program implementation by PMI
1.
2.

affiliates and suppliers and evaluate the current
status of farm labor practices and risk areas. They
specifically assess each leaf tobacco supplier´sprogress in implementing the ALP Code framed
against the strategic objectives set by PMI. . The
ALP Code contains seven principles 2:

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

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

The implementation of PMI’s ALP Program by leaf
tobacco suppliers that purchase tobacco for PMI
has been divided into two phases3:
Phase 1
• Management personnel and field technicians
understand the ALP Code and the implementation
approach, ensuring capacity of people and theprocesses in place to roll-out and manage the
ALP Program;• Communicate the ALP Code, requirements andexpectations to all farmers;• Document Farm Profiles for every contracted
farm, identifying risk areas and tracking
communication efforts to farmers;• Being aware and engaged to identify situations
and incidents at farms that should be bothreported and addressed immediately.

Phase 2 (full implementation of the program)• Collect detailed information about
practices on every contracted farm;• Systemically assess each farm for status of the
Measurable Standards outlined in the ALP Code;• Create and implement an improvement plan foreach farm to improve the implementation of all
required standards;• Identify and implement corrective and/or
preventive measures to identify and address theroot causes of potential situations not meetingthe standards and risks found on the farms;• Systemic reporting on the progress being made;• Support mechanism in place.

PHASE I

PHASE II

• Build organisation capability• Train supplier’s teamlabor

• Monitoring of labor practices farmby farm• Communicate to all farmers• Improvement plans for every farm

• Build farm profiles• Address widespread issues (e.g.

• Address prompt actions

STP Initiatives)• Regular assessments• Support mechanism in every market(Source: Verité & PMI, 2011)

3.

Often, there is not a strict distinction between the two phases during ALP implementation. In practice suppliers inmany markets start to consider how to address and respond to situations that do not meet the Code and to monitorchanges before formally finishing Phase 1.
9Chapter 2

Massalin Assessment: Scope andMethodology

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

2.1 ScopeThis report of Massalin’s tobacco growing
operations in the North East region of Argentina is
the fifteenth external ALP assessment by Control
Union. The assessment was conducted in December
2015 during the completion of Massalin’s fourthcrop season under the ALP Program.

2.2 Opening meeting
On 3rd December 2015, CU started the assessmentwith a meeting at Massalin’s offices in Buenos Aires,
attended by the ALP steering committee (Managing
Director, Leaf Manager, Corporate Affairs Manager,
Senior Counsel, and Operations Director), the
ALP Country Team (Law, Corporate Affairs, NorthWest Operations and North East Operations) andrepresentatives from PMI’s Regional Team 4. During• Responsibilities
personnel;ofmanagement

and

field

• Internal training and communication on the ALP
Program;• Communication of the ALP Code to farmers;• Internal system to collect information for FarmProfiles;• Mechanism for reporting Prompt Actions;• Records showing the training of field technicians;• Relationship with external stakeholders;• Steps taken to implement Phase 2;• Pilot conducted for monitoring labor practices;

the meeting, CU presented the objectives of theassessment and Massalin provided an overview of
the ALP implementation in their supply chain.

• Initiatives implemented to address widespread
and/or systemic issues; and2.3 Staff interviews and ALP Program
documentation

Massalin provided all the relevant documentation
related to the ALP Program implementation
requested by CU, including Farm Profiles, farmer
communication materials, purchase contracts,
Prompt Action reports, training records, personnel
records, and internal ALP related job objectives.

The assessment of Massalin included individualinterviews with the ALP steering committee andthe ALP Country Team at the head office. CU
also conducted interviews with three agronomy
supervisors, one sustainable projects coordinatorand nine field technicians at the local offices in thevisited region. In addition to Massalin personnel,
interviews in the field included two external
stakeholders supporting Massalin’s contribution
programs to address the identified widespread
issues. All interviews were conducted individually,
so interviewees felt comfortable to speak freely
and raise any issues. The conversations covered thefollowing topics:• General awareness of the ALP Program andknowledge of the ALP Code;• Implementation of the ALP Program at theMassalin level;4.
5.

• Support mechanism.

2.4 Farm sample selection
To constitute a meaningful sample, CU needed tovisit at least 51 farms; the square root of the total
number of farmers directly contracted by Massalinin the Argentinean North East region. 5 In total, CU
visited 51 farms. Farm selection was determinedbased on the following categories:• Geographical spread• Farm size
• Farms with reported Prompt Actions in 2014
and/or 2015

Regional Agricultural Programs
2,600 farms at the time of the assessment.
11External Assessment

100% of the farm visits were unannounced. The day
before a specific farm visit and assessment of a fieldtechnician, CU informed the ALP Country Team
leader and agronomy supervisors. The farmers to
be visited were informed at the moment of the visit.
Over two weeks, CU visited an average of 12 farms
per field day with a full day of reporting reserved
after two or three days of field visits.
The total number of contracted farms within thescope was divided among six growing districts, insidewhat is called the “central region of the Argentinean
North East Region” 6, with Burley being the type of
tobacco that was assessed. In this region, the farms
generally grow small areas of tobacco (averaging
1.4 hectares). In the assessed regions, many farmers
grow additional cash crops such as citronella, maize,
bananas, tomatoes and soybean among others.
The graphs and tables below provide informationon the 51 sampled farms. Percentages refer to thedemographic breakdown of this specific sample offarms.

Stage of tobacco during assessment

Growing

Topping

Harvesting

Curing

0

10

20

30

40

50

60

Number of farms

Types of farms 7

6%

Farms assessed by region

18%
41%

2% 2%
2%
8%
29%
33%
31%
Family farm

Family farm exchanging labor withother farmers

28%
El Soberbio
San Vicente
San Pedro
9 de julio
Caraguatay

Family farm with local workers
Family farm with local workers andexchanging labor
Family farm exchanging labor,hiring workers and sharecroppingDos de Mayo

6. El Soberbio, San Pedro, San Vicente, Dos de Mayo, 9 de Julio and Caraguatay
7.	 Exchange of labor: Arrangement between neighboring farmers work on each other´s farms (often with theirfamily members) without receiving cash but in-kind payment.						Sharecropper: Commercial relation between a worker who is responsible for managing a plot of land and the farmowner who provides the inputs. At the end of the harvest the worker and the farm owner share the profit.
12External Assessment

2.5 Farm visits

2.6 Persons interviewed

CU used a variety of methods to collect information
on each farm’s practices. These included interviews
with farmers and workers, verification of farm
related documentation (Farm Profiles, monitoring
forms, Massalin growing contract, Prompt Action
forms, records for payments or hours registration,
employment contracts) and visual observation offields, storage rooms, curing barns, working areasand housing. Before every interview, CU explained
the objective of the assessment and assured
interviewees that anonymity would be preserved at
all times.

In total, 111 people were interviewed. To avoid
undue interference or influence, CU attempted to
conduct all interviews with workers without thepresence of the farmer.

On each farm, CU conducted an individual interview
with the farmer to assess the effectiveness of
Massalin communication efforts, verifying:

The graphs below provide a demographic profile ofthis sample of interviews.
Persons interviewed: 111

44%

46%

• The farmer’s awareness of the ALP Code;• The farmer’s level of understanding and attitude
towards the ALP Code;10%
Family members (49)• The key messages received from Massalin;

External workers (11)Farmers (51)• The farmer’s willingness and ability to meet thestandards of the ALP Code.
In addition, CU conducted individual and groupinterviews with farm workers and family members
working at the farms, verifying:

Gender of interviewees (External
workers and family members)• The worker’s awareness of the ALP Code;• The worker’s level of understanding and attitude
towards the ALP Code;• The labor practices at the farm.

45%
55%

Female (27)Male (33)13External Assessment

The following graphs provide demographic
information on the 72 family members assessed in
all the regions.

Age distribution (family members)

The following graphs provide demographic
information on the 11 external workers interviewedof whom one (4%) was a migrant worker from Brazil,
the rest being local workers8.
Age distribution (External workers)
4%

7%
6%

11%
19%

68%
85%
<=15

0-13

16-17

13-14

Adults (>=18)

15-17
Adults (>=18)

Work duration (Family members)

Work frequency (External workers)

10%
19%
16%

39%

23%

81%

12%
Less than 1 month
1-3 months

Full shifts several days a week

3-6 months

Full shifts full workweek

9-12 months
Permanent

8.

Workers who travel home daily.
14External Assessment

Work duration (External workers)
5%

14%
33%

48%
Less than 1 month
1-3 months
3-6 months
6-9 months

2.7 Closing meeting
On the 8th of January 2016, the closing meeting
was held in Buenos Aires during which CU
presented their initial findings. The closing meeting
was attended by the Steering Committee, the ALP
Country Team leader, the Sustainable Project
Leader, one representative of PMI OC and one
representative from Verité.

2.8 Preparation of the final report
The final public report is an important externalmeasurement of the progress of the global ALP
implementation, in all countries where PMI sources
tobacco. Public release of this report demonstrates
PMI’s commitment to transparency; a cornerstonecomponent of the ALP Program. CU prepares the
final assessment report with Verité providing
quality control. While drafting the report, PMI andthe local PMI affiliate or leaf tobacco supplier may
request clarifications on specific findings. After
both PMI and the local PMI entity (or leaf tobacco
supplier), feel that the findings have been clarified
and understood, a country action plan is prepared or
the country revises the existing GAP/ALP Programplans to respond to the findings.
All findings included in this report refer to the sampleof employees from the leaf tobacco supplier, farmers,family members and/or workers as applicable andassessed; unless described otherwise. Hence, thenumbers and percentages presented do not referto the entire farm base or staff contracted by the
tobacco leaf supplier.

15

Chapter 3

Assessment of the implementationof Phase 1 of the ALP Program

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

This chapter documents the findings of theassessment of Massalin implementation of Phase
1 of the ALP Program. Phase 1 began with training
for management personnel and field technicians
including:
1. Massalin objectives and expectations;2. The meaning of the ALP Code Principles andMeasurable Standards;
3. Techniques to communicate the ALP Code tofarmers;
4. Tracking progress of communications andhow to build a Farm Profile;
5. Identifying issues when visiting farmers.

3.1 Conduct of the assessment
CU was satisfied with the cooperation and accessto information provided by Massalin. All persons
interviewed demonstrated a willingness to explaininternal processes, provide their professional
feedback and share experiences to provide a better
understanding of this phase. Both management andfield personnel were fully transparent during theassessment and provided all support requested by
CU. All farmers visited were willing to participate
in the assessment while sharing the required
documentation and/or allowing interviews withfarm workers.

3.2 People and processes to manage the
ALP Program
3.2.1 Internal structure for ALP
implementation
At the time of the assessment, Massalin had aninternal structure in place consisting of a Steering
Committee, an ALP Country Team and the Agronomy
Team. The steering committee was represented by
the Local MD, Leaf Manager, Director Operations,
Senior Counsel and an external Sponsor (Regional
MD). The ALP Country Team was represented by:
Production Manager from NW and NE Tobacco,
CA manager and Legal manager. The regional
Leaf Production Managers coordinated the ALP
implementation in the two tobacco production
regions (NW and NE). Both the Steering Committee
and ALP Country Team were supported by
the Regional PMI MD. Finally, the Agronomy
department was represented by supervisors andfield technicians. See organization chart below.
In June 2015 changes in the ALP implementation
structure were made; the national ALP Coordinator
was replaced by two GAP-ALP coordinators (NW
and NE). This is reflected in the organization chart
below.

Organizational chart for ALP Implementation

SponsorOPS Director

Steering Committee

ALP Country Team

MD

Leaf

NE Leaf

NW Leaf

Legal

CA

CA

Legal

Agronomy Supervisor

NGO
CONCIENCIA
Field Technicians

Farms
17

External Assessment

3.2.2 Role of NGO CONCIENCIA
In 2003, Massalin contacted the NGO CONCIENCIA
to develop a program with the aim to open childcare centers for the tobacco producers in theArgentinean North West tobacco production area
(Jujuy and Salta provinces) during the tobaccoseason.
In 2012 and with the launch of the ALP code,
CONCIENCIA was asked to develop a program toaddress Child Labor in the Argentinean North East
region. The program was named “Porvenir” andhad as main goal to increase school attendance (byimproving school infrastructure, educating teachers
about child labor, providing school materials tochildren and addressing other issues related topoor school attendance) in the growing areas and toraise awareness among teachers, children, farmers,
workers and Massalin’s employees about child labor.
The program gained with the time an importantrole in Massalin’s ALP implementation strategy
as it is now expected to include the ALP principles
and concepts in their communication materials
for children and teachers, train field technicians
and regional staff in child labor and safe work
environment, train farmers about child labor,develop a support mechanism pilot, assess the ALP
situation at farm level and in the future to also
give support to the field technicians when issuing
Prompt Actions. CONCIENCIA receives most of
their economic support from Massalin and to a lesser
extent from the Misiones Tobacco Cooperative9 andthe Technical Committee of Tobacco of the Misiones
Province10.

3.2.3 Internal communication andreporting
The ALP Steering Committee held internal monthly
meetings and quarterly meetings with the ALP
Country Team during which ALP was discussed. The
ALP Country Team leader reported on developments
and related issues including the ALP plan, farm

monitoring, addressing issues with farmers, Prompt
Actions, support mechanism, initiatives, budget,and stakeholder engagement. Subsequently, the
ALP Country team Leader sent a quarterly report to
the ALP Steering Committee and the PMI Regional
ALP Coordinator.
The ALP Country Team held monthly meetings
to discuss the status of initiatives, Farm Profiles,
Prompt Actions, addressing widespread issues andany other relevant issues in the ALP implementation.
Subsequently, minutes were sent by email to the
ALP Country Team and ALP Steering Committee.
In the local offices, agronomy supervisors andfield technicians met on a monthly basis to discuss
ALP related issues including the status of Prompt
Actions, difficulties gathering the informationand how to communicate ALP to the farmers andstrategies on how to better reach farmers.
Personnel involved in the ALP implementation wereconstantly updated with emails, phone calls or atinformal meetings.

3.2.4 ALP training, roles andresponsibilities
All required personnel involved in implementing
ALP were trained or had some previous experiencein the development and implementation of the ALP
code in other countries. Regarding the local MD, he
was first trained in 2013 by the CA Manager when
he was the regional MD. The rest of the Management
Staff, ALP Country Team and Agronomy Supervisors
were first trained in 2011 by Verité. The coordinatorof the “Porvenir NEA” program had also participatedin that training as she was at that time part of thelocal Massalin staff in Misiones.
Field technicians were first trained by the Agronomy
Supervisors in 2011 and have received two updates
per year since then. Exams and tests were part ofthese trainings; the aim was to test the knowledgeof the field technicians and to discover areas for
improvement to be included in future trainings.

9. Cooperativa Tabacalera de Misiones
10. Comisión Técnica del Tabaco en la Provincia de Misiones
18External Assessment

Additionally, between 2012 and 2015, fieldtechnicians and Agronomy Supervisors participatedin trainings organized by the NGO CONCIENCIA(with the participation of COTTAPROM, CASAFE,
CTM, the Misiones Ecology Ministry, etc.) in Childlabor and safe working environment aspects. It is
important to mention that even if the ALP Codeprinciples were named, most those trainings weremainly focused on child labor, Argentinean law
and good agricultural practices when managing
pesticides (toxicology, proper CPA application tools,
methods to keep application tools in shape, etc.).
It is interesting to note that the company statedthey had an “industry approach” meaning that
other companies or cooperatives were invited toparticipate in the CONCIENCIA trainings. The aim
was for the whole market in the region to be awareof the child labor and safe working environment
challenges and so they could unify their efforts toreach all the farms and workers in the area with thesame message.

3.2.5 Engagement with the ALP Program
From the perspective of the ALP Steering
Committee, ALP Country Team and field technicians,
they saw the ALP code as a social complement to the
GAP program, understanding that it includes social
aspects of the farmers, workers and rural living in
tobacco production.
Rather than being committed to the ALP program,the members of the ALP team had a big commitment
to addressing the social problems at a farm level.
Steering committee members often went to thefield to monitor the initiatives, attending identified
widespread issues. To reinforce a participatory role
they occasionally joined field personnel on farm
visits giving them insight into a specific challenge
and the perspective of the farmer.
The members of the ALP Country team wereconstantly in touch with field technicians, farmers

and workers and they often went to the field toactively participate in initiatives, trainings or teammeetings.
Moving down the organization, the engagementof agronomy supervisors and field technicians wasimportant as they managed the primary contact
with the farmers. All of them declared that they see
the ALP Code as an opportunity for the region toeradicate Child Labor and improve the Safe Working
Environment at the farms.
Additionally, Regional Agronomy Supervisors, fieldtechnicians, the ALP Country Team Leader and somemembers of the Steering Committee had good andinnovative ideas to improve the rural living in themarket (new initiatives, communication materials,
growing techniques that could reduce child labor,etc.).

3.3 Communicating the ALP Coderequirements to all farmers
3.3.1 The ALP communication strategy
All farmers contracted by Massalin were included
in ALP communication and training programs.
Although the communication materials describedin the following chapter included all seven ALP
Code Principles, during farm visits, field technicians
focused primarily on two topics; child labor andsafety (CPA management) as these were considered
to be the most critical topics in the assessed region.
As a result of Massalin’s communications efforts, 47
farmers11 (92% of those visited) were aware of the
ALP Code.
The table below summarizes the farmers’
awareness of the different ALP Code Principles.
These percentages do not refer to the farmers’ total
awareness of the ALP Code Principles, only the 7
major topics selected for the interviews12.

11. Two farmers were not aware, one was a new farmer and the other had two children under 18 helping at the farm
performing hazardous activities.
12. Numbers between brackets refer to the total number of farmers.
19External Assessment

ALP Code Principle

Percentage of farmers that named
and explained the principle

Child labor47 (100%)

Safe work environment

27 (57%)Forced labor

5 (11%)

Compliance with the law

3 (6%)

Income and work hours

1 (2%)Of the farmers that were aware of the code, 45 (96%of the farmers visited) considered the ALP Code an

during regular visits but they made special focus inchild labor and safe work environment principles

important issue. They understood the importanceof sending children to school and of ensuring thechildren’s (and the family’s) health and wellbeing on
the farm by taking the proper safety measures whenhandling CPAs. In addition, they understood the ALP
Code as a requirement to comply with the company
rules and thus they had to meet the standard.

as they understood that those were the main
issues at the farms. During the assessment, thefield technician to farmer ratio was 1:173. All fieldtechnicians declared that they visit farms four to
six times per season. Six (66%) said that they haveenough time to communicate the ALP Code tofarmers during regular visits. The rest stated that thefarmers sometimes had difficulties to understandthe need to change to these new practices and thatthey had not enough time to convince them.

All the farmers interviewed considered theirrelationship with the field technicians good. They
were satisfied with the agronomy advice and insome cases also with the support on safe work
environment issues that assisted them to improve
not only their tobacco productivity and income, butalso the safety of rural conditions on the farm.

3.3.2 ALP communication methods andmaterials
Five specific groups of activities and materials wereused to communicate the ALP Code to farmers.
First, group meetings of 15 to 20 farmers were held
during the contracting period and used to introduce
GAP practices and the ALP Code to farmers (mainly
safe work environment at the farm).
Second, and one of the most important, was the
support of field technicians. All field technicians
declared that they communicated the ALP CodeThird, a variety of communication materials weredeveloped by the Porvenir NEA program for farmers
and their children, teachers and field technicians.
While communication materials were produced
and designed by CONCIENCIA the content wasprovided by Massalin. All communication materials
were revised and approved by the ALP Steering
Committee and the ALP Country Team before they
were distributed. These included:• Calendars for the farmers: the seven ALP CodePrinciples were illustrated in the calendars.
• Brochures for farmers: these referenced childlabor and safe work environment on the farm.
• Brochures for children: brochures withinformation and games highlighting issues aboutchild labor and the safe work environment.

20External Assessment• Posters: for schools and farmers, referring tochild labor and safe work environment on thefarm.
• Notebooks for teachers and field technicians:
focusing on child labor prevention andresponsible management of CPAs.
• Radio broadcasts: about Child Labor, based on
the UN Declaration of the Rights of the Child andthe minimum working age law.
Fourth, in 2012 Massalin amended the growing
contract to include annexes (points 9 and 10.c) inwhich the farmer undertakes not to use children
under 16 years of age in the production process was
required to do his best to comply with the seven
ALP Code Principles.
The company also adapted communicationmaterials to ensure that all children, farmers andworkers could understand them. A clear example
was the replacement of written communicationmaterials with images, targeting illiterate farmers
and workers.
It was noted, however, that while all thecommunication materials and the growing contracts
are in Spanish 13 for a significant part of the region
Portuguese is the farmers and workers’ mothertongue. At one visited farm (2%), the farmer claimed
he could not understand the contract because hismother language was Portuguese and he did notknow how to speak or read Spanish. The company
should take this into account when developing
communication materials and when signing thegrowing contracts.
The table below summarizes the responses of the 47
farmers who were aware of the ALP Code14, based on
the different communication methods. CU primarily
focused on identifying which communication
method was used to teach farmers about ALP15.

Communication Method

Farmers

Group meetings

47 (100%)

Regular field technician visit

18 (38%)Poster/calendar

7 (15%)

Radio

6 (13%)

Cellphone

1 (2%)

Massalin Particulares S.R.L. response:“MP will continue working on a communication planwith a variety of materials developed together with
CONCIENCIA, for farmers and their children, teachersand field technicians.”“Communication material will be consolidated ina tool-kit, containing the main concepts related toevery ALP principle to equip field technicians with atailored material to support situations not meeting
ALP standards.”“Friendly

communicationmaterialsuchasscreensavers in handheld devices and screen
backgrounds containing ALP messages will allow
easy access to the latest information. Visualcommunication will help field technicians to transfer
and reinforce key ALP messages. When: Q4 2016
onwards. Scope: MP´s field staff. Expected result: field
staff with tools to effectively communicate ALP key
indicators to farmers.”“As part of Porvenir’s new approach, as of the second
quarter of 2017, CONCIENCIA will provide training
workshops on the organization of the farm as a
productive family unit. With this innovative proposal,
tobacco families will gain knowledge and skills to redesign tasks and reallocate resources, avoiding theneed to involve minors under 18 in tobacco activities.”

13. The official language in Argentina is Spanish.
14. Four farmers were not aware of the ALP Code. One of them was a new farmer and did not use PPE when applying
CPA. The other three were farmers hiring workers and not using or using incomplete PPE for CPA application and/or
harvesting. One of them had a 16 year old daughter who was found harvesting.
15. Numbers between brackets refer to the total number of farmers; one farmer may have given more than one answer.
21External Assessment

3.3.3 Understanding and perception of
the ALP Program
Massalin management generally had a goodunderstanding of the ALP Program and ALP CodePrinciples. The field technicians served as theprimary contact for farmers, therefore, theirunderstanding of the ALP was critical. They saw
the ALP Code as a tool to progressively eradicate
child labor and improve the quality of life forfarmers. Overall, field technicians’ knowledge ofthe seven ALP Code Principles was good but some
improvements were identified:• Child labor: Eight (89%) field technicians were
aware of the legal minimum working age (16years old) and the requirements for children
between 16 and 18 years to be allowed to work.
With regards to hazardous activities, four fieldtechnicians (44%) had a good understandingof this concept giving accurate examples ofhazardous and non-hazardous activities. Of theother field technicians, four (44%) recognized
harvesting and CPA application as hazardous
tasks but did not recognize them as such whenusing PPE and protective clothing. One fieldtechnician (11%) declared that hazardous
activities are any activities that can put family
safety at risk.
• Income and work hours: None of the fieldtechnicians were aware of the legal monthly anddaily minimum wage, which was 7,680 AR$ permonth or 337 AR$ per day 16. This was attributed
to the fact that the new legal minimum wage hadentered into effect on the same day CU started its
assessment. However, 7 of the 9 field technicians(77%) were aware of the previous minimum wageof 7,200 AR$ per month and 316 AR$ per day.

The following was clear for all field technicians:
the legal maximum work hours per day, theconcept of overtime (and that it should bevoluntary), that one paid rest day should be
provided per week, and the maximum work
hours per week. The maximum hours for children
between 16 and 18 years was also clear for all
field technicians. However, payment-in-kindand the amount of holiday days corresponding
to the workers, was not clear for any of the fieldtechnicians interviewed.
• Fair treatment: All field technicians understoodthe basic concept of this principle. They knewthat workers should be treated equally (nodiscrimination) and fairly.
• Forced labor: All field technicians understoodthe concept of this principle as they said workers
must be free to work and cannot be forced
under any circumstance. They also mentioned
risks associated to maintaining original identity
documents. None of them saw workers being paid
at the end of the harvest as a risk situation. Noneof the field technicians named indirect payment
as a practice going against this principle.
• Safe work environment: All field technicians had
a good understanding about the risks of handling
CPAs without the proper PPE. They also thoughtthat it was important that workers should havea safe working place and took adequate safetymeasures to avoid accidents. The need to use
protective clothing for harvesting, to havesanitary facilities and to have access to waterand adequate housing was clear for all of them.
• Freedom of association: All field technicians
understood the basic concept of this principle;
workers should be free to join unions or build
their own labor unions and no worker should be
excluded because of being part of a union.

16. The same day CU started the assessment in the region, the national minimum wage entered into effect as per the law
published on the “Boletín Oficial” of 9th November 2015. (https://www.boletinoficial.gob.ar/#!DetalleNormaBusqueda
Avanzada/11496449/null).
22

External Assessment• Compliance with the law: All field technicians
understood this principle as a requirement
for the farmer to comply with all the country’slaws, but none of them explicitly mentioned
employment contracts and legal rights. Noneof the field technicians specifically mentioned
terms and conditions of employment contract
between farmer and worker.

Legal department will support trainings related tominimum wage, regular payment and end of season
payments. When: these trainings will be held at aminimum, according to regulation updates. Additionalsessions may be requested by FT if the farmers are
to reorganize their activities and their need to hirepeople, where there is a key need to ensure hiring isdone in a fair way, documented and compliant with

Massalin Particulares S.R.L. response:“To reinforce the field staff understanding of ALP, thefollowing action plan was developed:• MP´s agriculture team to hold workshops withrole-play activities where different scenarios
are performed by field technicians, while thecolleagues can observe, share their opinions,and align their view and understanding about
different issues. These workshops will also allow
field technicians to share experiences on how they
are solving problems found on farms during crop
season activities. Scope: MP´s field staff. Expected
result: align Field Technician´s understanding of
key ALP measurable standards.
• E-learning modules for Field technicians developedwith interactive activities on ALP concepts.

the law. Scope: ALP country team and field staff.”

3.4 Building Farm profiles for all
contracted farms
As a requirement of Phase 1, Massalin employees
were expected to build Farm Profiles for every
farm. PMI developed a global template to support
the collection of information on socio-economic
indicators including farm size, number of workers,
age and number of children in the farmer’s family,
working status (for example part time, full time,
migrants), the pay period for workers and living
conditions.

3.4.1 Data gathering system for FarmProfilesModules will be available in handheld devices,with videos and quizzes, and will include a test to
quickly assess field technician’s understanding.
When: Q1 2017. Scope: MP´s field staff.
Expected result: Uniformity in Field technicians
understanding of ALP related processes and mostcommon situations.
CONCIENCIA will continue to work with fieldtechnicians of all tobacco companies, throughworkshops and “one to one” visits to reinforce the
ALP understanding, with special attention to the newChild labor legislation, assessing field technicians´knowledge at the end of each training session.

In 2012, Massalin started to compile information
for the Farm Profiles in a paper format. One year
later, looking to improve the data gathering, adigital system to complete the Farm Profiles wasdeveloped17 using a hand held device. In 2015, thecompany changed the hardware to an iPad andintroduced an application developed by PMI 18 tocollect the information at the farm level. Some
problems arose from the data migration and someof the farm profiles collected on the old software
could not be imported to the Leaf2Go program; thismeant that information was not easily available to
the ALP Country Team for further analysis.

17. Called “Chango Mobile”
18. Called “Leaf2Go”
23External Assessment

Field technicians were in charge of gathering andupdating the information for the Farm Profiles.
After completing the Farm Profile template,they uploaded it and updated the information in
Massalin’s internal system.
Of the farms visited during the assessment, noneof the Farm Profiles could be opened on the tablets
and thus all of them were provided to CU after thevisits.

3.4.2 Accuracy of Farm Profiles
By comparing the information on the Farm Profiles
with the situations found at the farms, CU concluded
that 46 (90%) of the Farm Profiles were accurate.
Of the remaining five (10%) farms had at least one
inaccuracy in the data collected (a farm may have
had more than one inaccuracy):• Number of hectares: In five Farm Profiles (10%)
the number of hectares did not match with thearea declared by the farmer.
• People on the farm: Five Farm Profiles (10%) did
not include the workers hired by the farmer.

3.4.3 Analysis on information FarmProfilesBased on the information obtained through theFarm Profiles, Massalin conducted annual analyses
to design initiatives to address widespread and/or
systemic issues.
Massalin Particulares S.R.L. response:“By comparing the information on the FarmProfiles with situations found during farms visits,

check data during the season to ensure quality of
information; captured target is 5% of farms for thiscontrol”

3.5 Prompt Actions
PMI defines a Prompt Action as:“a situation in which workers’ physical or mental
well-being might be at risk, children or a vulnerable
group – pregnant women, the elderly - are in danger,
or workers might not be free to leave their job.”(source: PMI, 2011)
Another Phase 1 requirement was to identify andaddress Prompt Actions found on farms contracted
to supply tobacco to Massalin. Any Prompt Action
should be reported immediately to the ALP Country
Team leader, who should then provide guidance on
how to address the issue or escalate it within theorganization.

3.5.1 Prompt Action reporting
mechanism
In the 2015 crop season, 184 Prompt Actions wereidentified. 107 (58%) of these related to Child
Labor, 75 (41%) to Safe Work Environment and two(1%) to Income and Work Hours. Prompt Actions
were reported using Leaf2Go software which wasobserved to be easy to understand; the software
provides a handbook with examples and also guides
the user through all the steps when issuing a Prompt
Action.
All persons involved in reporting Prompt Actions
were aware of the reporting procedure.

CU concluded that 90% of the Farm Profiles were
accurate. As at the time of data input the system
was on a transition phase from the old platform to
the new one, the remaining farm profiles had at least
one information inaccuracy, created by problems
with input of data collected and storage process.
ALP program team and field supervisors will cross

3.5.2 Understanding Prompt Actions
Six field technicians (67%) understood that a Prompt
Action was a situation that goes against the ALP
code19. Three (33%) explained that a prompt action
was a situation that should be stopped immediately

19. Only examples relating to Safe Work Environment and Child Labor were given.
24External Assessment

and when asked for examples one (11%) technician
gave wrong examples20 although the other two(22%) gave accurate examples.
It is important to mention that the Leaf2Go software
was also used at the farm to record general data andnon-conformities related to the GAP program whichwere also identified with the wording “Prompt
Action” 21. This could lead to field technicians
confusing the definitions of situations that theymust consider as Prompt Actions for the ALP Code.

3.5.3 Addressing Prompt Actions
When observing a Prompt Action situation, fieldtechnicians were expected to explain the danger
involved to the farmer, family members and/or
workers and then complete the Prompt Action
form in Leaf2Go. The data was then uploaded to the
Massalin database when the tablet was connectedto the internet.

From the four Prompt Actions verified by CU, twofarmers (50%) were not aware of the Prompt Action
being reported. This lack of awareness could be
because the farmers did not receive a copy of thePrompt Action form. Two of the Prompt Actions(50%) verified by CU were not well described, as
only the Principle related to the Prompt Action wasnamed.

Massalin Particulares S.R.L. response:“In order to ensure these findings are properly
addressed,thefollowing

initiatives

will

be

implemented:• Training sessions to enforce clear knowledge on
prompt actions and process flow will be carried out
with field staff.
• Prompt actions concepts and process will be
addressed in workshops with field staff.”

When A Prompt Action was not yet solved, it
appeared in the database as “pending Prompt
Action”. As soon as the follow up was done, thedatabase was updated and the Prompt Action
appeared as “closed Prompt Action”22. This
information was later analyzed by the regional ALP
Country Team leader who, in turn, forwarded themto the other members of the ALP Country Team andthe ALP Steering Committee. The field technicians
followed up with the farmer but no specific deadline
was given. Prompt Actions need to be monitored
closely to ensure the situation is addressed quickly.
This will help avoid confusion for both the farmer
and field technician. The Prompt Action should be
solved before the next field visit.

20. Not having a CPA storage or using an incorrect dose when applying CPAs.
21. An example of this wording was “PROMPT ACTION: A farmer is not using the recommended CPA for tobacco
production”.
22. At the time of the assessment, there were some problems with the software and it was not possible to update thePrompt Actions in the MP database. This is why screenshots were sent to the Leaf department who gathered theinformation and classified it according to the type of Prompt Action reported.
25

Chapter 4

Assessment of the Current Status
of Phase 2 of the ALP Program

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

This chapter describes Massalin implementation
Phase 2 of the ALP Program. When PMI makes
the decision that a country is ready, the relevantorganizations are introduced to Phase 2. This does
not necessarily mean that all Phase 1 requirements
have been achieved. PMI and Verité then provide
training to the ALP Country Team including:
1. Preparation of the ALP Country Team to train
staff to systematically monitor labor practices
on farms;

4.1.2 Mechanism for monitoring
Since 2013, Massalin has monitored all the ALP
Code Principles. The field technicians monitored theseven ALP principles at every visit and registered
the results in their iPads using Leaf2Go. For this,and in order to use the time in a more efficient way,
they only recorded situations that went against (orcould be at risk of going against) any of the ALP
measurable standards. Of the farms visited by CU,
41 (80%) had been included in the 2015 monitoring.

2. ALP status update;
3. Introduction to Phase 2;
4. General approach for monitoring before,
during and after a farm visit; and5. Next steps and planning for the upcoming
season.

4.1 Monitoring of labor practices farm byfarm
In Phase 2, PMI expects that monitoring of labor
practices on individual farms has started and that atleast two ALP Code Principles have been selected
to focus efforts on. Eventually, the intention is thatall ALP Code Principles and Measurable Standards
should be implemented and monitored.

Massalin Particulares S.R.L. response:“As of 2018 crop season, MP farm monitoring strategy
will be divided in two:
• Monitoring of ALP Priority Focus Areas: They will
be monitored during farm visits along the season in
100% of farms.
• Additional

Monitoring(“blindspots”):

All

indicators of ALP principles will be monitored in
10% of farms, randomly selected.
ALP coordinators present the farm monitoring results
to ALP country team for monthly reviews during theseason. Whenever there is a spike in any ALP indicator,
the ALP country team will evaluate the situation to
include it into monitoring of Priority Focus Areas “

4.1.1 Selection of issues
Based on Farm Profile analysis, NGO’s assessments,
Monitoring data, Prompt Actions, and personnel
experience on the field, Massalin selected several
issues that were considered widespread and/or
systemic. In the region the most widespread issues
were:• children involved in hazardous activities• children helping or being employed at the farms• usage of PPE and protective clothing• lack of CPA storage sites• poor rural living conditions• gaps in the educational system in the croppingarea

4.2 Address widespread and/or systemic
issuesPhase 2 requires investigation of the root causes of
the widespread and/or systemic issues identified.
These issues are both identified and addressed
under the ALP Program with two distinct but
complementary approaches. Firstly, initiatives are
implemented to mitigate specific risks and improve
the overall rural living conditions of the contracted
farms. Secondly, other initiatives involving therelevant stakeholders (including projects sponsoredby the PMI Contributions department) address
problems identified at the community level.

• lack of access to drinkable water.
27

External Assessment

4.2.1 Investigation of root causes
Based on analyses conducted on Farm Profiles,
irregularities reported during farm visits, Prompt
Action analysis, a workshop performed by
Verité, assessments and feedback from the NGO
CONCIENCIA and consultations with different
national stakeholders, Massalin identified threedifferent root causes for the abovementioned
widespread and/or systemic issues;
1. Weak education system: Low educational
coverage, lack of (or poor) school
infrastructure and a lack of roads andtransport that made it difficult for farmers tosend their children to school.
2. Regional working culture: Farmers werereluctant to adopt certain labor practices
such as the usage of PPE for CPA application.
Additionally, as soon as their children finish
primary school farmers prefer them to learn
how to grow tobacco at the farm rather than
go to secondary school.
3. Poor living conditions: Poverty and poor rural
living conditions in the region led to untidy
farms and an unsafe working environment.

4.2.2. Initiatives to address widespread
and/or systemic issues
At the time of the assessment, Massalin was
implementing several initiatives to mitigate
specific risks and improve the overall rural living
conditions of contracted farmers. These included:
scholarships23 for children of technical secondary
school age (12-17 years), distribution of PPE,
promoting the building of CPA lockers among
farmers, and safety training to address unsafe work
environments.

In addition, the NGO CONCIENCIA through the
Porvenir NEA program was implementing initiatives
to address issues related to the weak educational
system in the region and the problems identified
at the community level to address poor living
conditions:• School Infrastructure: In 2012 the NGO assessed
the access to drinkable water in the entire
growing region. Areas with a lack of potablewater were identified as suitable places to drillbore holes. At the time of the CU assessment thecompany was waiting to get the final approval
from the national institutions to build these bore
holes.
• Porvenir NEA: Development of material forteachers and students in primary schools.
Improvement of school infrastructure anddistribution of schooling materials amongchildren attending schools involved in the
program 24. Distribution of communicationmaterial among teachers, children and farmers
about child labor and safe working environment
at the farms. Since the beginning of the programin the assessed region, the Porvenir NEA Program
has involved 11,000 children (3,000 of them arechildren of tobacco growers), 145 schools havereceived schooling materials, 5 schools latrines
were replaced with bathrooms, and 300 teachers
and 90 field technicians were trained on childlabor.

4.2.3 Stakeholder engagement
In addition to the NGO CONCIENCIA, otherstakeholders took part in the training anddevelopment of the communication for the Porvenir
NEA program (see 3.2.2)25.

23. Farmers with children attending technical secondary schools were asked if they were interested in receiving ascholarship. The list of farmers and their children was sent to the CA Manager who would check with the Agronomy
department if children were the son of active growers.
24. Field technicians were asked to prepare a list of schools attended by farmers’ children. This list was delivered to
CONCIENCIA and Massalin for inclusion in the approved list for the program.
25. Ministry of Culture, Education, Science and Technology; regional Ministry of Labor; regional Ministry of Employment
and Social Security; regional Ministry of Agriculture and Production of Misiones, ILO and National Commission for
the Eradication of Child Labor.
28

External Assessment

4.3 Support mechanism
Unlike programs that target the root cause ofpoverty, support mechanisms aim to help workers
in their role by facilitating access to information,
providing support in difficult situations, andassisting workers and farmers in mediating disputes.

4.3.1 Hotline
In December 2014, Massalin launched a pilot
support mechanism aimed at covering the tworegions26, and 1,200 tobacco farmers, with theaim of giving legal support and more informationon the seven ALP principles. The mechanism wasmanaged by CONCIENCIA and promoted by thefield technicians during their regular farm visits
and by radio advertisements. During the farm visits,
field technicians distributed a calendar, a brochure,a poster and a thermos with the name of the support
mechanism and the 0-800 hotline number. The
company decided to stop the pilot in June 2015
when it realized it was not obtaining the desired
results. After six months the hotline had received
just seven calls: four requesting more information
relating to requirements such as the minimum
working age and regarding the Child Labor principle
which were resolved during the same calls.
The field technicians, Agronomy Supervisor and
the Porvenir NEA coordinator gave the following
reasons for the lack of success of the pilot:

Of the assessed farmers in the regions where thepilot was launched, eight (25%) were aware of the
support mechanism, but when asked none of themclaimed to have used it.
When asked how they knew about the support
mechanism, farmers gave different responses
including the field technician’s visit, magnets,
posters, caps and group meetings.
Among the workers interviewed in the area where
the pilot was launched, none of them were awareof the support mechanism. This could be due tothe communication strategy (aimed at reaching
the farmers but not the workers) which could
also explain why the mechanism did not work as
expected.

Massalin Particulares S.R.L. response:“Massalin Particulares will explore local organizations
capable of providing services on worker´s rights. As
in Misiones labor contracting is mostly informal, MP
will design and distribute a employment record form
designed to farmers, to help them formalize theirrelation with employees, recording name, ages, work
dates and time, wages and trainings received. FT
will check these records during farm visits, enablingthem to assess the transparency of workers´ hiring. In
addition, the +Chacra program will provide training
on farm safety aspects, not only to farmers, but toworkers as well “• farmers did not trust a hot line when discussingthese kind of issues• there was no cell phone signal at the farms• some farmers used a Brazilian cell phone line andtherefore the hotline was not toll free for them

26. San Vicente and El Soberbio.
29

Chapter 5

Farm level assessment of
ALP Code standards

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

Chapter 5 summarizes the field assessment of thecurrent status of the farm practices in relation
to the ALP Code. At the time of the assessment,
Massalin was in the fifth year of implementing the
ALP Program, and is expected to engage directlywith farmers to address dynamics not meeting the
ALP Code standards.
Before presenting the findings, it is important
to clarify the structure of the ALP Code as thisdetermines CU’s analysis of farmers’ practices.
The ALP Code has seven Principles, each withseveral Measurable Standards. ALP Code Principles
are short statements designed to guide farmers
on specific practices to resulting in safe and fairworking conditions.
A Measurable Standard defines a good practice andover time can be objectively monitored to determine
whether, and to what extent, the labor conditions
and practices on a tobacco farm are in line with each
ALP Code Principle. Each chapter covers one of theseven ALP Code Principles and CU’s findings. Risks,
situations that may lead to problems in the future or
about which a conclusion cannot be reached due tolack of evidence are also discussed.

5.1 ALP Code Principle 1: Child labor

There shall be no child labor.

owned by their parents in activities that are notarduous, dangerous and/or unhealthy, where thework does not interfere in the school attendance
and performance, and the family business obtains
the approval of the local Labor Administrative
Authority.
The Argentinean Constitution, National Education
Law 27.045 and the Federal Education Law 26.206
encompass the right and obligation to education,
which includes two years of preschool and elevenyears of basic education (elementary school andmiddle school).

Child labor: Overall findings and challenges

5.1.1 Prevalence of children working
In one farm (2%) a child below 16 (15 years old) was
employed to do stringing and sticking.
At 16 farms (31%), 25 children below 18 wereinvolved in hazardous activities. Four of them (16%)
were employed at one farm (three of them were
16 years old and one was 15 years old, referred toabove) and the rest were child family members of the
farmers, helping on the farm. More details regarding
the employment frequency, and tasks performed bythose children can be seen in the graphs below.
Employment frequency(External workers)

Background
Minimum age regulations: According to the Child
Labor Law 26.390 and Agricultural Labor Law
26.727, 16 years is the legal minimum working age
in Argentina. However, minors between 16 and 18
years old are allowed to work if they have beenauthorized by their parents/person in charge, andthey do not perform any type of hazardous work
which is forbidden by law for minors below 18. It
should be noted that Argentinean law only provides
a general definition of hazardous work (e.g. if the useof pesticides may jeopardize health, such an activity
is deemed hazardous). In exceptional cases minors
between 14 and 16 years old can work in companies

25%

75%

Full shifts several days a week
Full shifts full workweek

31

External Assessment

Helping frequency (Family members)

17%

Full shifts several days a week
13%

52%

Full shifts full workweek
Only during school holidays
Only afternoons

13%

Only weekends
4%

Tasks performed by family members

16

15

14

12

12

11
9

10

9

8

10
7

5

5

6
4

3

2

3

4

4

2

2

0

g
n
n*
nt tionng ping ing* ing* arn* ing* ing* ing* sks*
als
in
io
t
tio eedi
me
at
k
nt
il
im
p
d
a
b
p
s
i
a
ra
t
c
a
v
a
a
n
r
o
i
l
i
e
z
g
a
r
i
e
B
T
n
lt
St
fa
W
G
rv g/St
sp
ep
in
til
di
an
Cu
eo
pr Tran
er
Ha
ch
n
oa
r
i
m
F
a
l
d
a
g
n
d
n
M
/u
gc
rin
be
La
in
St
ng
ed
i
k
e
Ta
S
ad
Lo
e
ag

*These tasks are considered as hazardous

Tasks performed by workers

5
4

4
3

3

Stringing/Sticking*Loading/unloading barn*

3
2
10Harvesting**These tasks are considered as hazardous
32

External Assessment

Regarding school attendance, 14 children (52%) above 14 years old (one of 14 years old, three 15 years old,seven 16 years old and three 17 years old and all of compulsory secondary school age) were absent fromschool.

Initiatives to address child labor• Porvenir NEA program 27:
Seven farmers declared that they sent their children to primary schools that benefited from the
Porvenir program. On two of the farms the children were interviewed and described how they
were taught in school about child labor and the hazardous tasks on the farm. All of these farmers
thought this was a good way to teach children about the safe work environment and child labor.
• Scholarships for technical schools:
Implemented since 2008, for the scholarships program Massalin involved all the children of
secondary school age from the farmers that grow tobacco for Massalin: 46 schools were includedin the program and the scholarships were intended to cover all or part of the student quota forthe year. The aim of the program was to improve secondary school attendance but also to reduce
the time that the children spend on the farm where they may be exposed to hazardous activities.
Of the farmers visited, five of them stated that their children had received scholarships and werevery pleased with the program.

5.1.2 Awareness of legal minimum
working age
43 (84%) farmers were aware of the legal minimum
working age and on four farms (36%) the workers
were aware of the minimum working age.
Three (6%) farmers stated that they disagreed
with the ALP code as they thought 12 year oldchildren should be able to help with all the tobacco
production tasks with the exception of handling
CPA’s and fertilizers.

Child labor: Risks

5.1.3 Awareness of hazardous work
25 farmers (50%) and the workers at 10 farms(91%) were unaware of the meaning of “hazardous
activities”. Practices such as harvesting and thehandling of green tobacco, were not considered tobe hazardous tasks by farmers.

5.1.4 Age verification
11 farmers (92%) said that they did not verify theage of the workers when hiring.

Child labor: Analysis and Priorities
Massalin’s communication efforts and focus on thisprinciple is not bearing fruit as expected. While
Porvenir NEA is a positive program that increases
school attendance among farmers’ children ofprimary school age, it is not enough to preventchildren below 18 years old from being hired or
involved in hazardous farm activities. Additional
efforts are still required to raise awareness among
farmers and especially workers on: the prohibitionof family members below 18 from performing
hazardous activities, and the understanding andidentification of hazardous activities.

27. Porvenir NEA” means “Future NEA”.
33

External Assessment

Massalin Particulares S.R.L. response:“In order to mitigate the risks, as of 2016 Massalin
Particulares will start to implement an integrated
approach, with a combination of actions to reduce thelabor requirements on tobacco production. Within thiscontext, there will be two approaches to implement
technical innovations: the first through individual
farmers; the second through service providers.“

5.2 ALP Code Principle 2: Income andwork hours
Income earned during a pay period or
growing season shall always be enoughto meet workers’ basic needs and shallbe of a sufficient level to enable thegeneration of discretionary income.
Workers shall not work excessive orillegal work hours.

Background
Minimum salary regulations: According to the
Resolution 84/2015 issued in December 2015 by
the National Commission for Agricultural Work,the legal minimum wage is 7,680 AR$ per month or
338 AR$ per day. The Argentinean labor law statesthat for monthly workers, wages must be paid atleast on a monthly basis. For weekly or day laborers,salaries or wages must be paid at least weekly or
every 15 days. For piece workers, payment must
be made every week or every 15 days in relation
to the work finished during the mentioned periods,
and an amount proportional to the value of the restof the job performed. The employer may hold as aguarantee a sum not exceeding a third of the total

amount. Payment-in-kind is allowed but cannot
exceed 20% of the total salary. If an employee has
been working for the same employer for more than
one year, an additional amount of 1% per year shallbe added.
Work hour’s regulations: According to Agricultural
Labor Law 26.727;• Maximum work hours for children of 14-16 years
old: three hours a day and 15 hours per week.
Night shifts are forbidden.
• Maximum work hours for children of 17 years
old: six hours per day or 32 hours per week witha maximum of 7 hours per day 28. No night shifts(8pm to 5am of the following day) are allowed.
• Maximum work hours for adults: eight hours
per day or 44 hours per week (with a maximumof 9 hours per day), from Monday to 1pm on
Saturday. This schedule excludes tasks that,
because of their nature, are usually performedon Sundays. In such cases, employers shall allow
workers to take a compensatory rest day during
the following week. Night work (from 8:00 pm
to 5:00 am) cannot exceed 7 hours per day or 42
per week. In combined working schedules (dayand night hours), every night hour implies: (a) aproportional reduction of the total work shift by
8 minutes; or (b) these 8 minutes to be paid as
overtime.
Overtime regulations: There are no specificrequirements to be met by employers to request
overtime from workers, except for the employer’s
obligation to comply with the employee’s restingtime between each working day. The maximum
overtime allowed is 30 hours per month or 200
hours per year. Every overtime hour shall be paidwith a 50% increase, if it takes place from Monday
to 1pm on Saturday or with a 100% increase, if istakes place on Saturday after 1pm or on Sundays.

28. However, in exceptional cases, and upon approval of the Administrative Labor Authority, this schedule may be
increased to 8 hours per day and 44 hours per week, provided that it does not affect the minors’ education. Porvenir
NEA” means “Future NEA”.
34

External Assessment

Benefits regulations: Workers are included in theregular social security provisions, and they havetheir own health care system. Employees must
deduct from their salary 3% for Elders’ Social
Services Association (PAMI), 3% for the worker’s
Health Association and 11% for Pension Plan
contributions. The employer must pay 17% of thegross salary as social security contributions and1.5% as unemployment insurance. Benefits also
include vacations, leave for exams or parental
deaths, maternity leave for 90 consecutive days andpaternity leave of 30 days.

rights and obligations as local workers; any
difference in treatment would be considered illegal.

Income and work hours: Overall findings andchallenges

5.2.1 Minimum salary
In all farms workers were being paid below the legal
minimum wage.
On four farms (44%) the workers were receiving
more than 20% of their salary in-kind. Two of them(22%) received 100% of their wage-in-kind29.

Migrant workers: Migrant workers shall obtaina working visa from the National Direction ofMigration (Dirección Nacional de Migraciones).
Upon issuance, migrant workers have the same

Details of the different ways in which farmers were
paying wages can be found in the table below.

Percentage (InKind Salary/
Total Salary)

Total

-

100%

AR$ 250,0031

AR$ 200,00

AR$50,00

20%

AR$ 250,00-

AR$ 180,00

AR$50,00

22%

AR$ 230,00-

AR$ 250,00

-

100%

AR$ 250,0032-

AR$ 150,00

AR$ 50,00

25%

AR$ 200,00-

AR$ 150,00

AR$ 50,00

25%

AR$ 200,00-

AR$ 200,00

AR$ 50,00

20%

AR$ 250,00

AR$ 1.000,00

-

-

-

AR$ 1.000,00 32

AR$ 25.000,00

-

-

-

AR$ 25.000,00

End of theharvest Salary

Daily Salary

In Kind Salary-

AR$ 250,00-

30

29. The in-kind payment exceeded the legal minimum. Payment-in-kind is allowed but cannot exceed the 20% of thetotal salary.
30. Breakfast and lunch, valued at 50 AR$.
31. The farmer gave the employee the option to receive the salary in kind by purchasing goods (for the amount of theagreed salary) in grocery on which the producer received a special discount or to receive salary in cash.
32. Included food and accommodation for the entire harvest season.
35

External Assessment

5.2.2 Payment schedule
At 10 farms (67%), the payment schedules were inaccordance with the local law. Workers were paid
either on a daily or a weekly basis. On two otherfarms (13%) the workers were paid at the end of theharvest which is against the law33. In both cases thefarmers explained that the workers were contracted
to work during the whole tobacco season and thatthey would receive full payment at the end of theseason. In three farms (20%), sharecroppers werebeing in an employment rather than in a commercial
relation with the farmers (see 5.2.9) and paid at theend of the harvest.

5.2.3 Regular and overtime hours
At five farms (42%) the work hours were incompliance with the local law. On the other farms
workers worked up to 10 hours a day. At those
farms with overtime hours, none of the farmers
paid overtime but also no evidence was found of
involuntary overtime hours in the region. Workers
received a fixed amount per day.

5.2.4 Legal benefits
None of the workers interviewed received thebenefits to which they are entitled by law. In addition,none of the farmers or workers in either region were
aware of the legal requirements regarding benefits,holidays and leave (i.e. leave for maternity) to which
the workers were entitled by law.

Income and work hours: Risks

5.2.5 Awareness of legal requirements
None of the farmers and workers were aware of
the legal minimum wage, overtime rates, workers
benefits, leave and holidays to which they wereentitled by law.

5.2.6 Awareness of legal work hours
None of the farmers were aware of the legal work
hours and at 10 farms (91%) the workers were notaware of the legal work hours.

5.2.7 Record keeping
11 farmers (92%) visited do not keep records ofhours/days worked, tasks performed or payments
made to workers. In addition, none of the farmers
provided pay slips to the workers.

5.2.8. Exchange of labor
22 farmers (43%) participated in some type of
exchange of labor arrangement (see 2.4). This
usually only involved the farmer and his/her spouse
without involving their children. Commonly theexchange of labor is done between family related
farmers and/or neighbors for tasks such as weeding,
CPA application and harvesting. Some farmers
explained that they exchanged labor with farmers
who had a tractor; the normal deal being 2 man daysfor 1 tractor day.
Massalin was aware of these types of arrangement
and the possibility of having contracted farmers
exchanging labor with non-contracted farmers. To
ensure all farmers were informed about the ALP
code, Massalin organized trainings and meetings
with all the field technicians in the region to talkabout safe working environment and child labor on
the farm. Field technicians from other companies
in the area were expected to communicate these
topics to their farmers.

5.2.9 Sharecropping
Three farms (6%) were working with sharecroppers
and in two cases family members were involved.
One farmer who had a contract with Massalin lentpart of his land to his son who worked it and earned
a profit. In the second case, the sharecropper was
the one providing the labor and the farmer who had

33. Between 6 and 9 months.
36

External Assessment

the contract provided the inputs and land. At theend of the harvest the sharecropper would receive
half of the payment as arranged at the beginningof the season with the farmer. In the third case,the sharecropper was providing the labor and thefarmer the inputs, work tools and land. At the endof the harvest they would share the income34 withthe sharecropper according to the surface lent 35.
As all these sharecroppers agreed on the revenue
for their work with the farmers, as well as thetasks to be performed, and worked on the land of
the contracted farmers, their profit would depend
mainly on the inputs provided by the contracted
farmer. In addition, they did not manage their own
plots. Therefore, it could be concluded that rather
than a commercial, an employment relation existed.
The main difference between a commercial andsharecropping situation is that sharecroppers in acommercial relation are business partners whereas
sharecroppers in an employment relation were
employees. As they received a percentage of therevenue without having insight in the total amount,received this payment at the end of the harvest, andalso paid for crop inputs, this is considered an unfair
arrangement since employees should be paid a fixedsalary, receive this at least monthly, should not haveto pay for any inputs, and have their employment
formalized.
In addition, most sharecroppers do not own the land
they managed which poses risks to their investment(i.e. loss of production because of bad weather).
Second, all sharecroppers paid for the crop inputs
without having a formal contract with the farmer,
so if the farmer would decide not to pay they did
not have any proof of their right the deduction of
the revenue. Third, sharecroppers generally did
not have insight in the total revenue of the tobacco
sales causing a lack of transparency in the relation.

Income and work hours: Analysis and Priorities
These findings demonstrate that Massalin needs
to give more attention to this ALP Code Principle.
There was no awareness among farmers andworkers on topics such as the legal minimum
wage, overtime hours, and benefits. Farmers andworkers need time to learn about these laws andconcepts. The poor results can be attributed toa lack of knowledge among field technicians andinadequate communication material. Even though
the number of farmers hiring workers was low(only 25% according to the CU assessment) thisissue needs to be addressed as all workers werebeing paid below the legal minimum wage, overtime
was not being paid at all, and none of the workers
received benefits. Workers interviewed claimed
that they were being paid in kind, and CU found inall such cases this payment exceeded the maximum
legal percentage. In addition, close monitoring of
the relations between farmers and sharecroppers
is required to verify whether these are employment
or commercial relations and if commercial, if theconditions are fair.

Massalin Particulares S.R.L. response:“MP´s plan to integrate labor reduction initiatives
on tobacco production will not only mitigate risks
associated to Income and Work Hours principle, butalso increase farmers’ income. Working Hours, Wages
and Regularity of Payment are the ALP indicatorsthat will be part of a systematic monitoring, enabling
identification and follow up of Measurable Standards“

34. Inputs used by the sharecropper were deducted from the final income.
35. Total farm surface was 2.5 hectares and 0.5 were worked by the sharecropper. This means the sharecropper would
receive 20% of the tobacco income at the end of the harvest.
37

External Assessment

5.3 ALP Code Principle 3: Fair treatment

Farmers shall ensure fair treatment of

was not a main focus of Massalin and Consciencia.
Despite this attention should still be paid to therelations between the farmers and their workers toensure that all workers are treated fairly.

workers. There shall be no harassment,
discrimination, physical or mental
punishment, or any other forms of abuse.

Massalin Particulares S.R.L. response:“Although CU did not find any evidence of unfair
treatment, MP will continue to monitor farmers toensure fair treatment to all workers, and if such a

Backgroundsituation is identified, will respond to any breach ofthis important Principle by setting case by case action

Regulations: Any kind of abuse (physical, verbal,etc.) or mistreatment is prohibited. The employer
must comply with the constitutional duty ofensuring decent working conditions and is required
to observe the regulations on health and safety atwork. With regards to discrimination, the National
Constitution specifically states that all inhabitants
are equal before the law, and equal employment
access without any other requirement thantheir abilities. Besides, the Anti-Discrimination
Law 23.592 protects employees from arbitrary
discrimination and the Law for the Comprehensive
Protection of Women 26.485 specifically punishes
discrimination and violence against this gender.

Fair treatment: Overall findings and challenges

5.3.1 Fair treatment
No evidence was found at the farms visited ineither region, of sexual, verbal or physical abuse or
harassment, or of discriminatory practices.

5.3.2 Communication with workers
Farmers were expected to communicate directlywith all workers so small problems could be solved
without further escalation. In none of the farms
visited was there evidence of workers not being able
to communicate with the farmers to raise potential
grievances.

Fair treatment: Analysis and Priorities
As CU did not find any evidence of unfair treatment,
it is understandable that this ALP Code Principle

plans“

5.4 ALP Code Principle 4: Forced labor

All farm labor must be voluntary. There
shall be no forced labor.

Background
Regulations: As Argentina ratified the ILO
Convention on Forced Labor in 1950, its provisions
apply; namely that forced labor is forbidden and it
shall be permitted only as an exceptional measure.
Notwithstanding this, the Argentine Constitution
considers prison and “forced labor” - more
specifically “slavery” - as a crime and thus protects
all workers against this practice. This protection
covers any task performed by a person against
their will, under the menace of penalty. As regards
third party recruiters, the Agricultural Labor Law
prohibits any personnel agency from recruiting
workers for activities that fall under the scope of
this Law.

Forced labor: Overall findings and challenges

5.4.1 No evidence of workers unable toleave their job
All workers interviewed said they were free toleave their employment with reasonable notice. In
addition, none of the workers declared that they38External Assessment

had been required to make any financial deposits
or relinquish their original, identity or travel
documents.

Massalin Particulares S.R.L. response:“CU did not find evidence of workers unable to leave
their jobs. There were, however, risks associatedForced labor: Risks

with end of season payments and the need to further
investigate farmers and sharecroppers relation. As

5.4.2 Financial problems among farmers
Eight farmers that hired workers (89%) declaredthat they had suffered financial problems andthus had a lack of cash to pay workers at the timearranged in the contract. These farmers reported
that they had run out of cash at the end of season
and had to wait until they sold their tobacco tofinish paying the workers.

5.4.3 Payment scheduleOn three farms (27%) the workers were unawareof the payment schedule. They explained that theycame to the farm looking for work and when the
farmer said he would pay them he did not mention
when and the workers did not ask either.
In the three farms with sharecropping arrangements(6%), the sharecroppers would not receive their
payment until the end of the season.

Forced labor: Analysis and Priorities
As field technicians did not understand the risk
involved with end of harvest payments, it is unlikelythat they would detect the risks associated withsharecropping in employment relations or ofworkers being paid at the end of the harvest. In
general, Massalin did not pay much attention
to labor relations in this region as the common
understanding was that farmers did not hire any
workers. Based on CU’s findings, this conclusion
is incorrect and investigation of labor relations isrequired to identify potential risks.

in the Fair Treatment principle, initiatives aiming
to reduce labor hours will affect this principle andimprove farmers’ income, mitigating the risks of force
labor.
Training program through role-play activities ande-learnings for FT will allow that risks associated withend of harvest payments are understood.
Employment forms will be delivered to farmers tomonitor payment schedule and will help to establish
action plans for those farmers not being able to pay
daily workers at least weekly, or monthly for monthly
workers.”

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

Background
Regulations: Under the Agricultural Law 26.727
agricultural work shall be performed in adequate
hygienic and secure conditions in order to avoid
diseases and accidents. In addition the employer
must: adopt every necessary measure to protect
the workers’ dignity and personal safety; avoiding
detrimental effects of risky or unhealthy tasks;
comply with every regulation regarding hygiene
and safety at the workplace; and when necessary(e.g.: handling of CPAs) provide workers withclothes and/or protection elements, instructing
39External Assessment

them on specific usage. Specific hygiene andsecurity conditions for each workplace, machinery
and working tools are determined by the National
Commission for Agricultural Work in addition toother specific regulations. If worker accommodation
is provided, the Law states that employer shallprovide “adequate and sufficient conditions” inregards to hygiene, security, light, adequate spaces
for each family member and separate bathrooms.
According to the provincial Law 2.980 if the tobacco
production farmers are considered CPAs users theyshall, amongst other requirements: comply with theusage, appropriate PPEs (clothes, masks, globes,etc.); avoid handling CPA near houses or animals;
avoid storing empty CPA containers inside houses,
avoid eating/drinking/smoking while applying CPA;
pay special attention to weather conditions; after
finishing their shifts, take a shower and change
clothes. The Law specifically forbids minors under
the age of 18 and pregnant women to handle, orintervene in any task related to, CPA. Moreover,
Misiones Decree No. 1701/04 states that after
appropriate draining, washing and rendering empty
CPA containers useless, containers shall be disposedas the Authorities state. Regarding the empty CPA
containers, the national Law 24.051 states theyshall be considered as hazardous waste and, as such,
subject to special treatment.

Protective clothing36

Safe work environment: Overall findings andchallenges

5.5.1 Training and awareness of Green
Tobacco Sickness (GTS)At 37 farms (77%) those responsible for handlinggreen tobacco were unaware of the existence
and symptoms of GTS. Additionally, at six farms(75%) workers were unaware of the existence andsymptoms of GTS. None of the people interviewed
remembered being trained on this topic.
On one farm (2%), a 16 year old girl who wasbreastfeeding was found stringing and harvesting
green tobacco, a high health risk.
In 15 farms (29%) those in charge of handling green
tobacco were not using any type of protective
clothing. They explained that they had never beensick after handling green tobacco and the use of theprotective clothing was not comfortable becauseof the hot weather. Of the rest, on two farms (4%)
the complete protective equipment was used andin the other farms one or more types of protective
clothing for handling green tobacco was used. See
the table below for additional details about thefarmers’ answers about types, or combinations of,protective clothing.

Number of farms

Percentage

Full equipment37

2

4%Long Sleeve Shirt, Shoes and Long Pants

13

25%

Long Pants and Shoes

7

14%

Long Sleeve Shirt and Shoes

4

8%

Long Sleeve Shirt

3

6%

Long Pants

2

4%

36. Percentages indicate the type of equipment used by the total number of people using any type of protective
equipment in the assessed region.
37. Full equipment comprises gloves, long pants and long sleeves, shoes and rain gear.
40External Assessment

Protective clothing

Number of farms

Percentage

Gloves and Shoes

1

2%

Long Sleeve Shirts, Gloves and Long Pants

1

2%

Long Sleeve Shirts and Long Pants

1

2%

Shoes

1

2%

No protective clothing

15

29%

5.5.2 CPA handling and training
At 32 farms (63%), persons responsible for applying CPA were trained. They stated that the field technician
explained to them how to apply and manage CPA. At the remaining 19 farms (37%) those applying CPA
claimed to have learned this by themselves. The table below shows the type of PPE used for CPA application.

Number of Farms in which thetype of equipment is used

Percentage of farms 38

Full equipment39

13

27%

No equipment

9

18%

Only overall and boots

8

16%

Only mask

3

6%

Only overall, masks and boots

3

6%

Only gloves

2

4%

Only masks and boots

2

4%

Only overall

2

4%Only overall, boots and gloves

2

4%

Only overall and gloves

2

4%

Only boots

1

2%

Only masks and goggles

1

2%

Only overall and mask

1

2%

Not possible to verify

2-Type of PPE used

38. *Percentages indicate the type of equipment used over the total number of people using any type of protective
equipment in the assessed region
39. Full equipment includes an overall with long sleeves and long pants, boots, gloves and mask.
41

External Assessment

Initiative to address safe work environment for application of CPA• Distribution of CPA application kit:
Every two years since 2008 Massalin has distributed a complete PPE kit to all of its contracted
farmers for the application of CPA. One of the field technicians explained that this initiative
had been improved over time: in the first years the company bought PPE made of material thatwas unsuitable for hot conditions while this year PPE adapted for the Misiones region was
being distributed. From the visited farmers, 47 (92%) declared that they had received PPE from
Massalin and 32 (68%) were happy with this initiative. The rest claimed that they did not use the
PPE as they found it uncomfortable to work in.

5.5.3 Clean drinking and washing water
Washing and drinking water was available at 41 farms (85%). The rest of the farms had no access to potablewater. Farmers explain that mainly due the contamination of lakes, rivers and groundwater from the misuseof fertilizers and pesticides the water was not potable.

5.5.4 Worker accommodation
At six farms (86%), worker accommodation verified by CU was considered adequate according to local
standards40.

5.5.5 Re-entry period
47 farmers (92%) could not guarantee that the re-entry period after CPA application was respected.

5.5.6 CPA storage and final disposal
All farmers had a wooden locker for storing CPA. Of these, 21 (50%) did not have a lock and two (5%) were
missing a door.

Initiative to address safe work environment in CPA storage• Distribution of CPA lockers
After conducting an assessment of CPA storage in the region, Massalin started a communication
and awareness campaign to convince all farmers to build CPA lockers.

Disposal of empty CPA containers 41: all of the visited farmers collected the empty containers in specialbags distributed by the field technicians who then called the recycling company to pick up the containers
on a fixed date. The bags were stored in the CPA lockers.
40. Workers sleeping in the same room as the rest of the family, lack of bathrooms in the sleeping area and clean eatingarea.
41. At the time of the assessment, farmers were waiting for the trucker to set a date to pick up their empty CPA containers.
In the San Pedro region, the collecting truck could not reach the farms because the roads were impassable due tothe recent rains.
42External Assessment

Initiative to address proper disposal of empty CPA containers• Recycling Program:
In 2013 Massalin contacted the local authorities and stakeholders to develop a program forthe proper recycling of empty CPA containers. At the time of the assessment the first empty
containers started to be collected.

Initiative to address lack of records in CPA application• CPA Register Poster:
Aimed to encourage the farmer to register the application of CPA in the field. Distributed at the
beginning of the season in 2015, the poster was designed as a form with stubs to record the CPAs
applied on the farm. It included pictures of the products, usage, thresholds and recommended
dosage.

Safe work environment: Risks

5.5.7 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 generalsafety hazards at the farm and take measures toprevent accidents, injury, and exposure to healthrisks.
• 20 farmers (39%) had a first aid kit at the farm.
• 33 farmers (65%) had a means of transport tonearest medical care (car, motorcycle or horse).
• 15 farmers (29%) had contact details of healthinstitutions available at the farm.
• Six farmers (13%) had their own records of CPA
application.

Safe work environment: Analysis and Priorities
Massalin prioritized this ALP Code Principle in ALP
communications, initiatives and trainings with thefarmers and field technicians but this effort was

not reflected in the farms assessed. Awareness of
GTS and CPA application and the use of PPE andprotective clothing were still insufficient.
Massalin’s campaign to encourage farmers to build
a storage locker to store empty CPA containers
was successful as all the farmers had such a facility.
However, there is still room for improvement as half
had no locker and all were made of wood, material
not recommended for the storage of CPA. The CPA
container recycling program was another successfulcompany initiative.
As a last consideration, some of the farmers had
already started to record the application of CPA
in the field on a register poster distributed by
Massalin, which shows that a change in behavior istaking place.
As sharecroppers and farmers with whom laboris exchanged are currently not included in thecommunication efforts by field technicians, it isimportant that these situations will be instigated sothat potential risks can be addressed.

43External Assessment

5.6 ALP Code Principle 6: Freedom of
association

Massalin Particulares S.R.L. response:“MP plans to tackle these observations with thefollowing actions:

Farmers shall recognize and respect+Chacra projectworkers’ rights to freedom of association

This initiative will support the ALP Principle 5, of

bargain collectively.

Safe Work Environment. Through its innovative
approach, MP expects to increase safety awarenessamongst farmers. The training module is focus on CPA

Backgroundhandling, spraying and GTS.
• 2016 onwards. Scope: All tobacco farmers in
Misiones with contracts with MP.
Curing barns roof replacement projectThis project will have a strong farm safety component
as well as labor hours’ reduction. There will be afinancial incentive for replacement of barn roofs toGalvanized Iron sheets and safety harnesses will bepart of the barn improvement package.
Harvesting method and curing barns model pilots
Besides a reduction of the labor hours for harvesting

Regulations: Freedom of association is guaranteedby the National Constitution and reinforced by theUnions Law 23.551. This Law also prevents unionsfrom discriminating any (potential) affiliation
based on sex, religion, political ideology or race;and employers from performing any discriminatory
practice based on prerogatives set forth in theLaw. Furthermore, Law 26,727 regulates how
trade unions may provide employers with workers
to perform temporary tasks, based on the special
regulation that the National Commission for
Agricultural Work (CNTA) may determine.

and the changes expected in practices that will
mitigate child labor risks, the curing barn projectwill mitigate GTS exposure and the risks of work atheights, by developing a rig system for lifting tobacco
sticks to the upper section of the curing barn.

Freedom of association: Overall findings andchallenges

5.6.1 Workers’ right to freedom of
association

Porvenir Program
CONCIENCIA will continue promoting compliancewith Safe Work Conditions on tobacco fields,
contributing to the sustainability of Burley tobacco
production in Misiones. The Porvenir’s action plan isfully described under the Child Labor’s chapter andNo evidence was found of farmers disrespecting
workers´ right to freedom of association or to join/
form labor unions at the farms visited. There were
no tobacco workers’ associations in the assessed
areas.

involves both ALP’s Principles 1 and 5; please refer tothis section for further detail.

Freedom of association: Risks

Additional initiatives
The field technician´s tool-kit and audiovisual
campaign

forhandhelddeviceswill

includeinstructions for GTS, CPA application, CPA empty
container collection and proper use of PPE. The fieldtechnician’s tool-kit will include new awarenessmaterials, and re-entry signs will be delivered tofarmers.”

5.6.2 Awareness of freedom of
association
Eight farmers (50%) were aware of the workers’
right to freedom of association and at one farm (9%)
workers were unaware of their right to freedomof association. Additionally, all the farmers andworkers interviewed declared that they were
unaware of the labor unions active in the area.
44

External Assessment

Freedom of association: Analysis and Priorities
Awareness of workers’ right to freedom of
association among farmers and workers was low.
Even if there were no active labor unions in either
region, workers should be aware of their right toorganize themselves in such a way, to discuss andreview working conditions. This demonstrates that
additional communication on this topic is required.
Having said that, as no risks were identified, it isunderstandable that this ALP Code Principle is not
an area of focus for Massalin.

Massalin Particulares S.R.L. response:

the salary and tasks to be performed. At one farm(10%) the workers were not informed about how
much they were going to receive as payment.

5.7.2 Employment contracts
As a written employment contract is not mandatory
by law, the farmers and workers assessed said theyarranged their contracts verbally. Contracts did notexist between farmers and sharecroppers, which
posed a risk to their arrangement because if the
farmer would decide not to pay they did not haveany proof of their right of the revenue.

Compliance with the law: Analysis and Priorities“CU’s assessment shows that there is no specificrisk in this principle. Nevertheless, communicationmaterials in field technicians’ toolkit will be upgradedto incorporate current applicable laws and names oforganizations available to support workers’ inquiries.
This principle will be included in the additional

The fact that none of the farmers visited properly
informed their workers of their legal rights andemployment conditions, demonstrates the need for
additional support from Massalin to the farmers on
this topic.

monitoring strategy.”
Massalin Particulares S.R.L. response:

5.7 ALP Code Principle 7: Compliancewith the law“MP acknowledges the importance of farmers’
compliancewith

Argentinian

regulationsforemployment relations and is committed to develop

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

communication materials and trainings. A pay slip
form will be developed to improve compliance withthe law and raise farmers’ awareness regarding
contracting requirements for workers. This principle
will also be included in the additional monitoring

Backgroundstrategy mentioned previously”

Regulations: In Argentina, there is no legal
obligation to execute written contracts between
employers and employees, and there are no specificrequirements for regular indefinite term workers.

Compliance with the law: Overall findings andchallenges

5.7.1 Information on legal rights
In none of the farms were the workers informed
about their legal rights and employment conditions.
The farmers generally only informed workers about

45

Chapter 6

Concluding remarks

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

Since the initial implementation of the ALP Programin 2012, less progress than expected has been madein Argentina. Even though all required personnel
were trained and employees from different levels of
the organization were engaged with improving thesocial issues at the farms, the implementation of the
ALP Program has not resulted in much impact in thefield.
Much of the implementation is outsourced to theNGO, CONCIENCIA, which receives guidelines
from Massalin for the development of most of thecommunication materials and for a big part of the
training of the field technicians while Massalin
remained working on GAP related issues, which
it has been doing since 2003|. This demonstrated
that Massalin’s efforts to implement the program
are limited, which directly translates to the slow
progress made.
The ALP Code Principles of child labor andsafe working environment are the only ones
communicated extensively to the farmers. Even
when communicating this last principle, only
issues related to CPA management seemed to beaddressed. Additional attention is required to theother ALP Code Principles as many workers arepresent in the field, which are currently not included
in any communication efforts.

The other ALP Code Principles (Income and Work
Hours, Forced Labor, Compliance with the Law,
Freedom of Association and Fair Treatment) are
known by most of the ALP team members but lessmentioned in the communication materials or during
the farm visits. Another important issue is thatworkers are not considered when communicating
the ALP Code. Communication efforts are mademainly towards children and farmers, but not
to workers who in most of the cases showedunawareness on most of the principles.
The Porvenir NEA program proved to be effectivein addressing primary school attendance but needs
to be complemented with other initiatives if thecompany wants to minimize the possibility of childlabor among farmers and workers, and to reduce
the risk of children performing hazardous activities
and/or being hired.
Other initiatives like the distribution of a notebook
to register the application of CPA, the empty
container disposal system and the campaign toencourage farmers to build CPA storage are good
but will only work if awareness is created among
both farmers and workers.

47

Chapter 7

Appendices

EXTERNAL ASSESSMENT
Massalin Particulares S.R.L.

External Assessment

Appendix 1. Massalin response and ALP Program action plan
Introduction
In Argentina, tobacco represents a key activity in the
productive and social framework of seven states,
being the most relevant source of regional economy
for some of them. Concentrated in the Northwest(NWA) and North East (NEA) regions of Argentina,
tobacco production represents a high share of
the Geographic Gross Product in the provincesof Misiones, Salta, Jujuy and Tucuman, with manymunicipalities and small villages depending almost
entirely on tobacco production. This makes tobacco
farming in Argentina not only relevant as sourceof income for small farmers, but a commodity withsocial importance.
The main tobacco-growing province in NEA is
Misiones, where almost 50% of the production takes
place in farms of up to two hectares, demonstrating
the crop’s importance as an income source for small
landholders. Moreover, the economy of many cities
in this province depends almost entirely on tobacco
production. A total of 24,000 hectares are grownannually and production in Misiones represents
20% of the total production volumes in Argentina42.
In 2010, the need to strengthen the actions related
to Agricultural Labor Practices led Massalin
Particulares to set up a series of activities. At thattime, Verité performed the first assessment in the
NWA region. Although there were efforts overthe last years on different social initiatives in the
tobacco growing areas of Argentina, PMI’s launchof the ALP Program in the year 2011 was key tofacing the challenges that mean the eradication ofchild labor and other forms of labor abuse. Parallelto that, Massalin Particulares (MP) appointed a task
force with participation of senior management, so tocome up with a situation analysis and the design ofan action plan adapted to the complex rural context.

The conversion point between Verité’s diagnosis, thelaunching of ALP and the work performed by MP’s
task force paved the way for the implementationof the Argentine chapter of the ALP program. One
high impact initiative developed from these efforts
was the elimination of leaf bundling, which turned
out to be an essential innovation to reduce the needfor labor in tobacco farming. The Integrated CropManagement43 program and the Porvenir NEA 44
are other examples of initiatives that have had asignificant impact on supporting the ALP Program
implementation.
Massalin Particulares welcomes Control Union’s
Assessment, which provides an important insight
into the implementation of the ALP Program.
Furthermore, MP appreciates Control Union’s
positive feedback on the internal work done so far
to implement the ALP Program and is aware of themany challenges still to overcome.

ALP Program Implementation
Assessment of the implementation - Phase 1
Massalin Particulares’ journey towards the ALP
implementation was initiated before its official
worldwide launch, as in 2011 the company was
selected to implement an ALP pilot in Misiones. The
ALP implementation in the province of Misiones
meant not only a transfer of new information fromfield technicians to farmers, but also a change ofparadigm in tobacco production, as an important
hurdle to overcome at the time was the ongoingtraining of personnel focused on technical tasks
rather than social activities. It was necessary totackle some common farming practices that weretraditional in the region but sometimes contrary to
the ALP Code, and strengthen the team to face thefuture for a new set of best practices, as a key change

42. Program for the Reconversion of Tobacco Producing Areas – Ministry of Agriculture, Livestock and Fishing (2016).
Tobacco Industry in Argentina. Buenos Aires, Argentina.
43. Integrated Crop Management: Program implemented seeking reducing labor and cost while increasing yield for
tobacco production in Misiones
44. Porvenir: Child labor prevention program49

External Assessmentin the social aspect of the tobacco production. MP
acknowledges that the process took longer than
expected, but the team today is stronger, with adeep commitment to address social problems atfarm level, and is ready to advance, following theassessment recommendations.

Management of the ALP Program
ALP team re-structuring
The ALP Management seeks to create a strong
and sustained structure to address ALP issues.
Based on that approach, after the assessment, MP
decided to change its organizational structure andworking methods by fully integrating ALP into theGood Agricultural Practices (GAP) program andmerging the NWA and NEA teams, thus creating
one ALP National team. This enabled MP to address
limitations detected in terms of process andcommunication flow. The expected outcomes are:
• Improvements in:a. Identification and follow up of practices notmeeting the standardsb. Accuracy of farm profiles
c. Farm monitoring understanding
d. Handling of prompt actions• Faster and more efficient communication flow.
• Promote interaction, integration and alignmentof field staff, sharing best practices among
personnel.
• Handling of similar issues with same approach,enhancing effectiveness to solve them

External stakeholders - Industry approach
Considering that certain behaviors are deeply
engrained in the cultural context of the communities
within the tobacco growing areas, it is essential towork toward an “industry approach”, so that thewhole Misiones region is aware of key issues in the
tobacco sector and promotes the same message andsolutions.
In this context, for more than 5 years, CONCIENCIA 45
has been leading the interaction and collaborationof key stakeholders, thus contributing to
the involvement of the whole industry in theimplementation of the ALP Code. Their activities
involve creating strategies with COTTAPROM46,
with local government (including state Government,
Ministry of Education, Ministry of Agriculture andMinistry of Labor) and institutions specialized
in Child Labor and Safe Working Environment(including National Committee for the Eradicationof Child Labor - CONAETI, Provincial Committee
for the Eradication of Child Labor - COPRETIMISIONES, the Ministry of Ecology of the Provinceof Misiones and Agricultural Health and Fertilizers
Chamber - CASAFE). Through these interactions,
CONCIENCIA has been key to generating asustainable and long-term approach for ALP
implementation.
On the other hand, as of 2016, MP is strengthening
the industry approach, bringing on board key
Tobaccostakeholders,
like
COTTAPROM47,
Cooperative of Misiones and farmers’ unions tohave a common understanding of ALP, focus areasand interventions, like the +Chacra program, Crop
Protection Agents’ containers collection programand media broadcasting of key ALP messages.

45. Asociación Conciencia (“CONCIENCIA”) is a non-profit, non-partisan NGO, founded in 1982. It works for attaining
citizenship development through community engagement and social inclusion. Education is the pillar of its strategy,
working jointly with the public, private and academic sectors. In Misiones, CONCIENCIA has been working hardalong with MP to progressively eliminate child labor through the program “Porvenir NEA”, in place as of 2012.
46. COTTAPROM: Tobacco Technical Commission of the Province of Misiones. All tobacco companies and cooperatives,
farmers unions and Government agricultural bodies in Misiones province.
47. COTTAPROM: Tobacco Technical Commission of the Province of Misiones. All tobacco companies and cooperatives,
farmers unions and Government agricultural bodies in Misiones province.
50External Assessment

This integrated approach also supports aninteraction with the Ministry of Education, Ministryof Labor, and Ministry of Agriculture to further
explore synergies towards a fully sustainabletobacco production in Misiones.
Industry approach - message alignment
Since 2012, the Porvenir program has raised
awareness on Agriculture Labor Practices (ALP)
among tobacco stakeholders, hundreds of ruralschool teachers, parents (small farmers and tobacco
growers) and Field Technicians, the later being fully
trained to communicate Principles 1 (Child Labor)
and 5 (Safe Work Environment) of the ALP Code. In
this regard, in close collaboration with the Agronomy
team, Porvenir has been leading ALP workshops inorder to promote collaborative work among all fieldtechnicians, to align strategies, develop cohesive
messages and share knowledge.
As a result of the priorities setting derived fromthe original ALP risk assessment, carried out by
MP when implementing the ALP Pilot, the main
ALP principles covered by the agronomy team
were Child Labor and Safe Work Environment.
Porvenir’s trainings have proven to be effective
as all key stakeholders are aligned in conceptof these principles for ALP implementation. As
CU acknowledges in its assessment, regarding
communication achievements, Child Labor is on topof the list, followed the Safe Work Environment.
In this context, CONCIENCIA will continue tosupport and strengthen implementation of the ALP
Code at farm level, promoting compliance with
Principles 1 and 5 through activities strategically
aimed at minimizing associated risks. ThroughPorvenir, CONCIENCIA will ensure the following
lines of action:a. education, focusing on keeping students at
school;National Decree Nº 1117/201648, excluding
any tobacco related activity on the farm forminors under the age 18;
c. strengthening the skills of local Agronomy
team, with special attention to the newlegislationd. sustainability actions
Workshops and tailored trainings for parents,
farmers, field technicians, teachers and otherstakeholders as well as communication activities
for the whole industry will continue to be key in
CONCIENCIA’s work. As of first quarter of 2017,
CONCIENCIA will carry out individual one-to-one
explanation sessions with each grower negotiating
tobacco to MP, being this an excellent opportunity
to reinforce Decree Nº 1117/2016 and ALP
principles 1 and 5, and to include the income andworking hours topic. With the same direct approach,
CONCIENCIA will also reach growers while selling
tobacco to the Tobacco Cooperative of Misiones,
helping MP to spread a uniform message within thewhole industry. Through systematic monitoring,
MP will be able to identify any gap between current
payments and the minimum payment; these gaps
will be recorded when irregularities are identified.
Regarding income and working hours, to this datethere are no apparent communication efforts
by the other stakeholders in Misiones regarding
minimum conditions for labor contract. Once the
CU assessment report is made public, MP will
share the findings with all COTTAPROM members
and develop sessions with farmers’ unions, toexplain the risks associated to hazardous tasks,
to workers being paid below minimum wage, andto irregularities of payments to workers. This will
facilitate communication and understanding among
rural communities of the importance of meeting
ALP requirements. In addition, MP will implement
specific initiatives to address these issues, details
below:

b. training and raising awareness on farmers,
with special emphasis on communicating

48. During October 2016, National Decree Nº 1117/2016 came into force, stating the activities considered “dangerous
tasks” for people under 18 years old. Such Decree includes - among other tasks - the production of tobacco, defining
such activity as prohibited for minors under said age.
51External Assessment

Industry approach: +Chacra
In conjunction with COTTAPROM, MP will
implement “+Chacra”, an innovative mobile training
program designed to tackle specific issues foundin farms, focused specifically on tobacco farmers.
The activities are conducted by specialized trainers
introducing modules relevant for tobacco farming.
These trainers will have a fully equipped vehicle
with visual and practical tools to conduct interactive
trainings, and will have an in-depth knowledge on
the training modules, carefully designed to covertechnical and social aspects of tobacco farming.
The +Chacra training program will travel acrossthe Misiones province, taking place near farmers.
This initiative will be appealing and interesting tofarmers, since training sessions will be conductedwith small groups and will be highly interactive.
Attendees’ knowledge will be tested before andafter each session. This fully customizable training
modules will use feedback from participants
to design future modules. This initiative will besponsored by Massalin Particulares and the Tobacco
Cooperative of Misiones.
Expected benefits:
1. By Dec 2017, all MP farmers trained in
Module I 49
2. By Dec 2019, all MP farmers trained in
Module II 50
3. Expected to progressively achieve behavior
changes and increase the use of PersonalProtection Equipment (PPE) for CPA handling.
Appropriate storage conditions for CPA
and full participation in the CPA containercollection program is also expected. Farmers
will be trained on GTS prevention and about
the importance of children under 18 not being
involved in tobacco production 51.

Communicating the ALP Code requirements to all
farmers
When ALP was launched, training was focused on
disseminating knowledge and raising awarenessamong field technicians of the ALP objectives andthe seven principles. The first step was the designof a detailed and practical strategy with “train-thetrainer” approach, where field technicians wereprepared to be the ones to communicate the ALP
code to tobacco farmers.
From the start, field technicians have beencommitted to the ALP implementation, assuming aleading role with the program. The majority of MP’s
field staff was born and raised in the rural areas
where they currently work, knowing in details how
the social networks and cultural mindset in theregion are structured.
CU highlighted Massalin Particulares’ ALP teamcommitment to address social problems at farmlevel and identified field technicians’ knowledge ofthe seven ALP Code Principles as good. However
CU also raised the fact that some Field Technicians
did not identify certain scenarios as risky situations(i.e. workers being paid at the end of the harvest or
indirect payments), and that some of them did not
fully understand employment contracts and legal
rights as a part of the Compliance with the Law andIncome and Work Hours principles.
The training program must focus on achieving a
deeper knowledge on hazardous activities and theminimum requirements for labor contracting. In thissense, communication of regulatory changes andtheir implications is crucial. The Decree 1117/2016
implies that FT’s role will need to be tailored tounderstand and monitor the prohibition for people
under 18 years old to perform any kind of tobacco
activity. Within this context, MP will communicate
this restriction and drive efforts to raise awarenessfor the need to reorganize farm activities. As part of
Porvenir’s new approach, as of the second quarter of

49. Module I: CPA handling, CPA containers storage, empty CPA containers disposal and Green Tobacco Sickness (GTS).
50. Module II: Child labor, Safe Work Environment and Income and Work Hours.
51. As of 21st October 2016 Argentinean Government declared tobacco production as hazardous for people under 18.
https://www.boletinoficial.gob.ar/#!DetalleNorma/152515/20161021
52

External Assessment

2017, CONCIENCIA will provide training workshops
on the organization of the farm as a productive
family unit. With this innovative proposal, tobacco
families will gain knowledge and skills to re-designtasks and reallocate resources, avoiding the need to
involve minors under 18 in tobacco activities.
Field staff understanding of ALP
Since the launch of the ALP Program, field technicians
had to assume a different role from the one theyused to have in the promotion of Good Agricultural
Practices (GAP). In spite of the relationship alreadyset with each farmer, field technicians have to facedifferent challenges, not only limited to growing
the crop, but how to intervene and how to promote
behavioral changes. These were the new and quite
different challenges to be faced and to do so, field
staff needed to be equipped with a new set ofskills, tools and practical examples to communicate
farmers.
To reinforce the field staff understanding of ALP,
the following action plan was developed:• MP’s agriculture team to hold workshops withrole-play activities where different scenarios
are performed by field technicians, while thecolleagues can observe, share their opinions,and align their view and understanding about
different issues. These workshops will also
allow field technicians to share experiences on
how they are solving problems found on farms
during crop season activities. Scope: MP’s field
staff. Expected result: align Field Technician’s
understanding of key ALP measurable standards.
• E-learning modules for Field technicians
developed with interactive activities on ALP
concepts. Modules will be available in handheld
devices, with videos and quizzes, and will
include a test to quickly assess field technician’s
understanding. When: Q1 2017. Scope: MP’s
field staff. Expected result: Uniformity in Field
technicians understanding of ALP related
processes and most common situations.
CONCIENCIA will continue to work with fieldtechnicians of all tobacco companies, throughworkshops and “one to one” visits to reinforce
the ALP understanding, with special attention to
the new Child labor legislation, assessing fieldtechnicians’ knowledge at the end of each training
session.
Legal department will support trainings related
to minimum wage, regular payment and end of
season payments. When: these trainings will beheld at a minimum, according to regulation updates.
Additional sessions may be requested by FT if the
farmers are to reorganize their activities and theirneed to hire people, where there is a key need toensure hiring is done in a fair way, documented andcompliant with the law. Scope: ALP country teamand field staff.
Communication skills training
MP and CONCIENCIA developed a workshop
to teach and strengthen Field Technicians, todifferentiate risky situations, as well as theircommunication skills. An expert technical consultant
with proven experience in these areas designed anddelivered the trainings. The consultant has beenworking with PMI in other Latin American countries,
as well as with the Governments of Ecuador, Bolivia
and Peru to develop national policies to eradicate
child labor, and has a vast experience in conceiving
tools and instruments to overcome local challenges.
The knowledge on how to approach farmers andidentify the distribution of children’s daily tasks
is valuable for Field Technicians, providing themwith new tools and resources to help disseminate
ALP messages. Since Decree 1117/2016 came into
force, an additional training was given to reinforce
communication to farmers, explaining that no one
under the age of 18 should work in any activity
related to tobacco production. This training updated
Field Technicians about Argentinian regulations andempowered them to communicate ALP principles
effectively, promoting changes in the way ALP
issues in Misiones are addressed.
• When: Q4 2016. Scope: MP’s field staff. Expected
result: field staff empowered to effectively
communicate ALP measurable standards tofarmers53

External Assessment

Communication plan
MP will continue working on a communication planwith a variety of materials developed together
with CONCIENCIA, for farmers and their children,
teachers and field technicians. Key messages will
be delivered through radio and TV as part of suchplan, highlighting ALP principles 1 and 5 as wellas any new applicable legislation such as Decree
1117/2016.
Communication material will be consolidated in atool-kit, containing the main concepts related toevery ALP principle to equip field technicians with atailored material to support situations not meeting
ALP standards. In this regard, Massalin Particularesand CONCIENCIA will develop a card set to resemble
activities and people at the farm, catching farmer’s
attention to this new information. These materials
will be a guide for Field Technicians, containing
examples on how to make required changes and why
these changes are crucial to farmers.
Friendly communication material such as
screensavers in handheld devices and screen
backgrounds containing ALP messages will allow
easy access to the latest information. Visualcommunication will help field technicians to transfer
and reinforce key ALP messages. When: Q4 2016
onwards. Scope: MP’s field staff. Expected result:field staff with tools to effectively communicate
ALP key indicators to farmers.
Assessment of communication effectivenessTo verify the communication effectiveness, Massalin
Particulares will implement the following process:1. Unannounced farm visits performed by the
ALP team and tobacco production supervisors,in order to evaluate communication
effectiveness through farmer’s interviews.
Target: 10% of farmers per year

3. Follow up meetings to discuss results on amonthly basis, which will allow to address in atimely way the lack of farmers’ understanding.
4. When lack of farmer’s understanding is
identified, the most repeated issues will beprioritized in role-play training sessions.
• When: Q4 2017. Scope: Farmers’ ALP
understanding is assessed through sampling.
Expected results:• Enhance of ALP training program dynamics andeffectiveness for Field Technicians by Q4 2017.
• All FTs have improved their communication skills
and knowledge of ALP by Q4 2017.
• All FTs are aware of Decree 1117/2016 andable to properly communicate and generateawareness among farmers.
• All FTs’ understanding is regularly assessed for
ALP principles Q4 2017 and onwards.
• Mechanism in place to identify farmers
implementation of the ALP Program by Q4 2017.
Farm Profiles
By comparing the information on the Farm Profiles
with situations found during farms visits, CU
concluded that 90% of the Farm Profiles were
accurate. As at the time of data input the system
was on a transition phase from the old platform to
the new one, the remaining farm profiles had at least
one information inaccuracy, created by problems
with input of data collected and storage process.
ALP program team and field supervisors will crosscheck data during the season to ensure quality of
information; captured target is 5% of farms for thiscontrol.
• Q1 2018. Scope: MP’s field staff.

2. Additionally the farm by farm monitoring
done by FT will check ALP implementationand if the farmer is applying the informationand changing their practices.

54

External Assessment

Expected result:• Control mechanism in place to identify gaps andeliminate inaccuracies.
Prompt Actions (PA)
According to CU findings, not all Field Technicians(FT) had a clear understanding of a Prompt Action(PA). When FT were requested to give an example
of PA, descriptions were usually related to the crop
component of the overall program52. In addition, no
specific deadline was agreed, identified issues were
not closely monitored to ensure that the situation
was solved, and some farmers were not even awareof having prompt actions.
In order to ensure these findings are properly
addressed, the following initiatives will be
implemented:• Training sessions to enforce clear knowledge on
prompt actions and process flow will be carriedout with field staff.
• Prompt actions concepts and process will be
addressed in workshops with field staff.
As of 2017, PA process will follow the sequence
below:• PA found issues are reviewed and updated on a
yearly basis, according to PMI guidelines. The
issues identified must be clearly highlighted tofarmers.
• PA form to be available in Leaf2Go53, making
easier the identification of those situations thatshould be immediately stopped.
• PA situation detected:–– FT must stop the action and agree with thefarmer about the importance of preventing
recurrence of such a situation.

– – A specific training is delivered to the farmer
by his FT, using applicable materials fromtool-kit.
– – In addition PA will be recorded in Leaf2Go.
• Prompt actions will be immediately reported tosupervisors, which will inform the ALP team.
• FTs follow-up visit should happen within 60 daysof PA identification, to assess the situation. For
those PAs which have not been followed up, FTs
and supervisors will receive a reminder from ALP
team.
• Data of prompt action issues will be categorized
and made available for field staff and ALP
country team. Meetings will be carried out foranalysis and follow up.
• ALP country team, Agronomy manager/
supervisors, ALP coordinators will visit farms toverify progress and effectiveness of improvement
plans. Target: at least one farm per FT.
ALP country team will assess open Prompt
Actions on a case-by-case basis, seeking supportand intervention from CONCIENCIA for social
standpoint before defining specific actions. ALP
team will analyze recurrent cases of child labor aged
16-17 to prioritize implementation of initiatives toaddress Child Labor. The Decree 1117/2016 cameinto force just before harvest season, thus giving
farmers very short time to re-organize their farm
activities. In this context, CONCIENCIA is working
aggressively to communicate the new decree
and is additionally implementing some specificactions - like scholarships for children aged 16-17– to benefit identified minors previously working. In
addition, workshops on the organization of the farm
as a productive family unit are being implemented,
to avoid minors under 18 being involved in tobaccorelated activities.

–– A written notification is delivered to farmers
with the information of the issue found to
make clear the problem and severity of it.

52. GAP/STP program has three pillars. Crop, Environment and People pillar. Last one refers to ALP.
53. PMI data collection system.
55

External Assessment

In case of recurrence and lack of willingness toundergo a change in behavior, MP will not renew
contracts for next crop
• Immediately effective. Scope: MP’s farmers.
Expected results• All FTs are clear about PA situations, theirseverity, and process to follow.
• Clear follow up of PAs process established.
• All open and overdue PAs are immediately
discussed at ALP country team level.
• Clear understanding regarding involvement ofpeople under age 18 in tobacco production.
• MP’s personnel with no direct supervision overFTs to verify PAs resolution.
• PAs records available
description and resolution.

withbackground

Monitoring of Labor Practices Farm by Farm
Following the CU assessment, MP monitoringprocess had not yet been entirely implemented asplanned. There had been some lacks of follow ups
and of the timely identification of risk situations on
farms.
ALP measurable standards have to be managed
under a systematic farm monitoring, as an accurate
form monitoring is crucial to identify situations that
do not meet the ALP Code standards.
MP will drive efforts towards key focus areas andtargeted ALP indicators, implementing an approachbased on self-assessment and on CU findings. This
will serve as a baseline for initiatives and actionplans for significant risk mitigation.
As of 2018 crop season, MP farm monitoring
strategy will be divided in two:
1. Monitoring of ALP Priority Focus Areas: They
will be monitored during farm visits along theseason in 100% of farms.
2. Additional Monitoring (“blind spots”): All
indicators of ALP principles will be monitored
in 10% of farms, randomly selected.

ALP coordinators present the farm monitoring
results to ALP country team for monthly reviews
during the season. Whenever there is a spike in any
ALP indicator, the ALP country team will evaluate
the situation to include it into monitoring of Priority
Focus Areas.
Expected results• All FTs are clear about the focus areas for
systematic monitoring at farm.
• Systematic monitoring will enable impact
measurement from initiatives and action plansto reflect progress of ALP implementation• Additional monitoring will ensure potential blind
spots are identified and monitoring strategy isreviewed.
Support Mechanism
In December 2014, Massalin Particulares launcheda pilot for a support mechanism in Misiones,
managed by CONCIENCIA and promoted by thefield technicians. After six months, the telephone
hotline had received just seven calls. CU attributed
these limited results of the Support Line pilot
implemented in Misiones to the following situations:(i) farmers lack of trust in a telephone hotline; (ii) no
cell phone signal in some tobacco areas; (iii) some
farmers using a Brazilian mobile phone line, so the
hotline was not toll-free for them.
This pilot showed the need for alternative tools
to assess how farmers and workers problems aremanaged. Massalin Particulares will explore localorganizations capable of providing services on
worker’s rights. As in Misiones labor contracting
is mostly informal, MP will design and distribute a
employment record form designed to farmers, tohelp them formalize their relation with employees,
recording name, ages, work dates and time, wages
and trainings received. FT will check these records
during farm visits, enabling them to assess thetransparency of workers’ hiring. In addition, the+Chacra program will provide training on farm
safety aspects, not only to farmers, but to workers
as well.

56

External Assessment

Farm level assessment of ALP Codestandards
ALP Code Principle 1: Child Labor
To have minors helping on family farm tasks is
considered a normal situation, a culturally acceptedbehavior in Misiones, as farmers see it as part oftheir children’s education. Although MP has beenworking to progressively address these issues in
Misiones, CU’s report shows that there is still room
for improvement, in the following areas:• No hiring of workers under age 18• No under 18 years old performing hazardouswork• Reducing school drop-outs (teenagers)• Access to information about child labor on farms,
both to farmers and workers
On October 21st, a new decree 1117/2016 waspublished establishing the tobacco production as
hazardous activity for people under 18, making
any task related to tobacco prohibited for minors.
MP actions will address CU findings as well as thischange in the legislation.
In order to mitigate the risks, as of 2016 Massalin
Particulares will start to implement an integrated
approach, with a combination of actions to reduce
the labor requirements on tobacco production.
Within this context, there will be two approaches toimplement technical innovations: the first throughindividual farmers; the second through service
providers.
Through individual farmers
1. Harvesting methods and curing barns pilot
Massalin Particulares will distribute the necessary
material for 58 curing barns in strategicallyselected farms. Farm selection will be made basedon farmers understanding and alignment to ALP key
aspects. Selected farms will be named Model Farms
and used as best practice examples to replicate themodel with other farmers during field visits. MP will
deliver the equipment and materials free of charge
to these selected farmers to build the new curingbarns. These barns will allow changes in current
harvesting method, with a reduction on man hours
needed for harvesting and for barn loading:• Labor reduction for harvesting will come fromreducing manual cuts needed per plant, and byhandling several plants in sticks, rather than
individual plants hanged on wires.
• Labor reduction for barn loading will come fromthe design of a device for loading up to 90 plants
at a time (currently it is a plant-by-plant activity).
Promotion of innovations
Taking the successful example of the process
implemented to the elimination of tobacco leaf
bundling in 2012, MP is developing an Innovation
Catalogue for FT to take into account technologies
that are easily applicable at farming, such as use ofwatering cans for fertilizer band application andpre-wilting. These techniques can mitigate the risksof minors under 18 being involved in tobacco tasks.
In line with this approach, and as part of the end of
season review, there will be an annual workshop
with agronomy staff to identify the highest impact
initiatives on child labor and labor reduction to be
included in the Innovation Catalogue. By systematiccross-checking monitoring reports and farmers’
technology adoption, it is possible to assess how
these initiatives are impacting the presence ofchildren in tobacco production. These initiatives
will be also evaluated during unannounced visits by
ALP team and production supervisors during peaks
season of labor.
• 2018 onwards. Scope: All farmers suitable for
implementation of each innovation
Through service providers
1. The small size of tobacco farms in Misiones makeinvestments on new technology (i.e. machinery)difficult. Some types of new machinery are57

External Assessment

too expensive to be purchased by individual
farmers and there is little chance of fully utilizing
it. MP will work in an Industry approach todevelop service hubs where suitable suppliers
can offer agricultural services and initiate theimplementation of mechanical activities. Thisinitiative will first target a change in transplanting
practices in Misiones, as this is one of the tasks
where family members under 18 are frequently
involved.
Employment form
An employment record form will be created anddelivered to farmers as part of a toolkit to verify
the age of hired people, recording personnel details.
Field technicians will check these records during
farm visits, to verify if they comply with the law(decree 1117/2016).
Q3 2017 Scope: MP’s farmers are likely to hire
workers, where is possible to hire children under 18
years old.
The above initiatives will have synergy with the
Porvenir program.
Since 2012, Porvenir strengthens development in
the tobacco rural areas of the Province of Misiones
through the progressive improvement of the social,economic, educational and cultural conditionsof local farming communities. It also facilitatesaccess and permanence of sons and daughters of
tobacco growers in the rural educational system.
Additionally, the Program raises awareness of therisks to which children and teenagers are exposed
to at farms, supporting small farmers in theimplementation of good agricultural practices.
During November 2016, an external consultant
with expertise in sustainability programs conducted
an evaluation of the Porvenir program by comparing
two groups of growers (beneficiaries and nonbeneficiaries). Consultant’s knowledge on the
agriculture industry and experience in assessing
tailored-made programs were key to perform astraightforward and independent evaluation, anddeliver the realistic and unbiased findings: i) Porvenir

intervention has improved schools’ infrastructure
conditions; ii) raised awareness on child labor andsafe work environment through meetings andworkshops; iii) improved children’s attendance andpermanence at school; iv) strengthen the strategic
bond with field technician to implement ALP.
CU’s report also acknowledges “the Porvenir
NEA program proved to be effective in addressing
primary school attendance”. Still, both Massalin
Particulares and CONCIENCIA agree with CU in thefact that further initiatives need to be put in place
to support the achievements already accomplishedby Porvenir.
Considering the Misiones’ context, the results ofthe external evaluation requested by CONCIENCIA
during 2016, and the constant feedback fromkey stakeholders, as of 2017 Porvenir will renew
its strategy to reach tobacco families directly toaccomplish an even deeper impact. In line with this,taking advantage of the tobacco-buying season
starting in February 2017, when farmers take afree day to visit the company and negotiate theirproduction, Porvenir will be present at the buying
stations to carry out one-to-one explanations witheach farmer, being this an excellent opportunity
to reinforce Decree Nº 1117/2016. With similar
approach, CONCIENCIA will also reach growers
during their tobacco negotiation day at the Tobacco
Cooperative of Misiones, to spread a uniform
message within Misiones. Such communication
activities will be supported by new instruction cards
in the FT tool kits.
Additionally, the new design of the Porvenir will
improve permanence of children and adolescentsat rural schools located in tobacco regions, byimplementing afterschool activities to avoid
children presence in the farms, keeping them atschool for more time, and supporting scholarships
for high school students. The concept is tostrengthen their permanence at school, decreasing
their availability at farm with risk of Child Labor,
and reducing school dropouts. A total of 150 ruralschools, located in tobacco growing areas, will beequipped with better educational materials to be58

External Assessment

more appealing and ready to the more than 15,000
children living in tobacco growing regions. This will
be accompanied by training sessions for teachers to
help them identify and deal with the risk situations
associated with child labor. In some of these schools,
according with the needs and the percentage oftobacco growers’ children, Porvenir will build anddistribute community water purifiers to improve
hygiene habits and access to clear water. As MP
has been doing for last two years, 2,500 school kits
will be delivered to children of growers who supply
tobacco to MP, to facilitate their access to school
and directly support reduction of child labor.
In order to improve tobacco growers’ knowledge andskills related to ALP Principles, Porvenir will reach
tobacco growers for individual messages on ALP
at the buying stations and will hold meetings withthem to discuss ALP Principles 1 and 5, with special
emphasis on communicating the new legislation
applicable to child labor. A tool kit to support fieldtechnicians’ trainings will be created, and key
messages will be delivered on local radio and TV
stations, highlighting the new legislation regardingchild labor. Taking into account the new decree,
Porvenir will provide training workshops focused on
the organization of the farm as a productive family
unit, to help tobacco growers re-design their farmtasks and reallocate resources to non-hazardous
tasks outside tobacco, avoiding minors under 18 intobacco activities.
Along with the Agronomy team, Porvenir willcontinue to develop actions based on the ALP
Principles for the prevention, intervention andfollow-up in contracted tobacco farms, throughworkshops on training tools for field technicians, withspecial attention to the new child labor legislation,
providing assistance to the local Agronomy teamto improve the toolkit, and performing farm visits
in order to identify risk situations and evaluate
specific interventions. These activities will support
field technicians for the compliance of the ALP code.
Finally, Porvenir will promote sustainable ALP
efforts through alliances with local and provincial

agencies, by designing public positioning strategies
and communication materials to generate media
engagement through ALP messages and presence inpublic events, and by formalizing agreements withkey stakeholders to implement the ALP Program,seeking the commitments of all parties. With theseactions, Porvenir seeks to promote the long-termsustainability of the ALP program in the tobacco
area.
Beyond these activities outlined by Porvenir
Program, MP’s will continue to look for key
stakeholders, to reinforce the ALP awareness andseek together with other institutions a solution to
the labor practice issues. Massalin Particulares is amember of the network of companies against childlabor (part of the National Ministry of Labor) anddevelops institutional contact with national andstate Government Officials.
Expected results• Progressive and consistent reduction of labor
requirements and change of those activities withhighest risk of child labor.
• Farmers that hire workers to fill in employment
forms by 2018.
• Farmers verify age of workers by 2018.
• First version of Innovation Catalogue developedby 2018.
• Work with Porvenir NEA to support:– – By Q3 2017, at least 1,000 growers, suppliersof MP, are fully aware and trained on theprinciples of the ALP Code and the new
applicable legislation.
– – By 2018, 100 growers, suppliers of MP,
participate in training activities on theorganization of the farm as a productive
family unit to have better tools to meet the
principles of the ALP Code and reallocate
teenagers to non-hazardous tasks out of
tobacco.

59External Assessment– – By 2018, 100% Massalin’ FT have awareness/training tools and an improved toolkit topromote the implementation of ALP on thefield, containing the applicable legal updates.
– – By Q4 2017, at least 20 farms supplying
tobacco to MP receive visits from Porvenir.
– – By 2018, 80% of farming population surveyed
identify/acknowledge the intervention of
Porvenir NEA in matters of Child Labor and/or a Safe Work Environment.
– – 2,500 girls and boys from tobacco growers,
suppliers of MP, improve their permanence atschools by Q2 2017.
– – 150 schools from tobacco areas, receive
improved equipment by Q2 2017, making
schools more appealing, promoting children’saccess and permanence at school for 15,000
students.
– – By 2017, at least 300 students from tobacco
areas minimize exposure to Child Labor (CL)during the tobacco transplant and harvest
stages.
– – Pilot for a scholarship program developedby 2017, for teenagers (sons and daughtersof growers, suppliers of MP) to improvetheir access and permanence in high-school
education, reducing school dropouts.
·· Support 20 rural schools to improvetheir infrastructure by 2018, improving
conditions for children to continue
attending school.
·· At least 300 teachers from rural schools withtools to identify risks and consequences of
CL by 2018.

ALP Code Principle 2: Income and Work Hours
Historically, tobacco farming in Misiones has beendeveloped as a communal labor exchange system.
When this system evolved towards a farmer-worker
relation, it became mostly informal, but considered
fair by both farmers and workers. Tobacco
production is a labor-intensive activity. According
to CU assessment, there are risks associatedwith this kind of informal contracts, which can besummarized by the following findings:• Workers being paid below the minimum wage
• End-of-harvest payments• Sharecroppers
MP’s plan to integrate labor reduction initiatives
on tobacco production will not only mitigate risks
associated to Income and Work Hours principle,
but also increase farmers’ income. Working
Hours, Wages and Regularity of Payment are the
ALP indicators that will be part of a systematic
monitoring, enabling identification and follow up of
Measurable Standards.
Roofs change in curing barn
Construction of curing barn roofs are currently
made out of cardboard sheets with very limited
duration, requiring frequent maintenance andemploying a lot of manual labor. An alternative
material is the Galvanized Iron sheet, with better
resistance. Although cost effective, since galvanizediron sheets are more expensive, farmers use
cardboards. MP will finance the cost difference tohelp farmers execute roof changes. This long-lasting
roof will reduce the labor requirements for repair
and barn maintenance, estimated in more than 4hour/hectare. This initiative will be implemented
covering 20% of farmers per year.
Harvesting method and curing barns model change
pilot
It is estimated that a significant reduction in labor(around 40 hours/hectare) is possible by changing
the harvesting method, from plant-by-plant tothe use of sticks. The use of sticks allow to handle

60External Assessment

tobacco plants more efficiently during harvestingand its transport to barns. Additional time (around
6 hours/hectare) can be saved by using a rig system,
avoiding the need of having one person in each barntier when lifting tobacco into the barn top. This pilot
initiative will serve as a demonstration project forother farmers. This initiative will require additional
modifications in current barns, replacing hang wires
by sticks.
An employment form will be developed as part of the
FT toolkit. This will include farmers that currently
hire workers as well as those farmers not hiring but
who cannot rely anymore on family members under
18 years old. FT will check these records during
their farm visits to enable additional monitoring
regarding farmer-worker terms.
• Q4 2017. Scope: MP’s farmers likely to hire
workers.
As mentioned previously, the tool-kit andaudiovisual campaign for handheld devices will
include minimum wage, overtime hours, in kind
payments and legal benefits.
• Q4 2017. Scope: MP’s field staff.
The expected outcome is to generate the conditions
for farmers to understand why some informal
practices need to be changed, while implementing
interventions to facilitate this change.
Once workers became aware of fair conditions of
employment and work, an additional business for
agricultural service providers will be generated,changing working conditions for the better.
Sharecroppers
According to CU assessment, a close monitoring of
the relations between farmers and sharecroppers
is required to verify whether there is a commercial
relations with employment rights, and if theconditions are fair.

and then visited by field supervisors to assess andagree on how to bring transparency to their business
relation. The implementation of action plans will
be assessed during unannounced visits performedby ALP coordinators and Tobacco Production
Supervisors. Those situations considered not fullytransparent will be submitted to the ALP country
team for evaluation and corrective action. To
reinforce this, MP will work closely with otherstakeholders to have a uniform approach tosharecropping situations in Misiones.
• Q4 2017. Scope: All Misiones farmers withsharecroppers
Expected results• Farmers are aware of legal minimum wage,
overtime hours, and workers’ benefits by 2019.
• Mechanism in place to identify farmers notaware of legal minimum wage, overtime hours,
and workers’ benefits by 2018.
• All farms identified with sharecroppers areassessed and action plans implemented by 2018.
• Risks related to workers not being paid enoughto meet their basic needs are identified andaddressed.
ALP Code Principle 3: Fair Treatment
Although CU did not find any evidence of unfair
treatment, MP will continue to monitor farmers toensure fair treatment to all workers, and if such asituation is identified, will respond to any breachof this important Principle by setting case by caseaction plans.
In addition, initiatives such as new practices forthe reduction of labor hours will support mitigate
labor peaks and risks related to this principle. The
additional monitoring strategy will ensure timely
detection of any blind spots between farmer andworker’s relation.

In this line, MP will assess farmers and sharecroppers’
to identify all their agreements. Farms reported withsharecropping will be listed by ALP coordinators

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Expected results+Chacra project• Maintain fair treatment in all tobacco farms.

This initiative will support the ALP Principle 5, ofSafe Work Environment. Through its innovative
approach, MP expects to increase safety awarenessamongst farmers. The training module is focus on
CPA handling, spraying and GTS.

ALP Code Principle 4: Forced Labor
CU did not find evidence of workers unable to leave
their jobs. There were, however, risks associatedwith end of season payments and the need to further
investigate farmers and sharecroppers relation. As
in the Fair Treatment principle, initiatives aiming
to reduce labor hours will affect this principle andimprove farmers’ income, mitigating the risks offorce labor.
Training program through role-play activities ande-learnings for FT will allow that risks associatedwith end of harvest payments are understood.
Employment forms will be delivered to farmers tomonitor payment schedule and will help to establish
action plans for those farmers not being able topay daily workers at least weekly, or monthly formonthly workers.

• 2016 onwards. Scope: All tobacco farmers in
Misiones with contracts with MP.
Curing barns roof replacement projectThis project will have a strong farm safety component
as well as labor hours’ reduction. There will be afinancial incentive for replacement of barn roofs toGalvanized Iron sheets and safety harnesses will bepart of the barn improvement package.
Harvesting method and curing barns model pilots

MP will monitor 3 out of 6 ALP indicators for forcedlabor in 100% of farms and the remaining indicatorsin 10% of farms.

Besides a reduction of the labor hours for harvesting
and the changes expected in practices that will
mitigate child labor risks, the curing barn projectwill mitigate GTS exposure and the risks of workat heights, by developing a rig system for lifting
tobacco sticks to the upper section of the curingbarn.

Expected results

Porvenir Program• All FTs understand the risks associated to end of
season payments

CONCIENCIA will continue promoting compliancewith Safe Work Conditions on tobacco fields,
contributing to the sustainability of Burley tobacco
production in Misiones. The Porvenir’s action plan isfully described under the Child Labor’s chapter andinvolves both ALP’s Principles 1 and 5; please referto this section for further detail.

• All risks associated to sharecropping and end of
season payments are identified and addressed
ALP Code Principle 5: Safe Work Environment
The CU report showed that there has been progressin terms of communication efforts and farmer
awareness, such as 82% of farmers partially using
PPE, 27% using full equipment, all farmers having
a CPA storage cabinet, and the high adherence of
farmers to the CPA containers’ collection program,
implemented with MP’s participation.
On the other hand, CU raised risks such as low
awareness on GTS, not all CPA cabinets had lockers
and there were still farmers not using any protection
equipment during CPA application. MP plans totackle these observations with the following actions:

Additional initiatives
The field technician’s tool-kit and audiovisual
campaign for handheld devices will include
instructions for GTS, CPA application, CPA empty
container collection and proper use of PPE. The fieldtechnician’s tool-kit will include new awarenessmaterials, and re-entry signs will be delivered tofarmers.
• Q4 2016 onwards. Scope: MP tobacco farmers in
Misiones.
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The CPA application record tracking will continue,
an initiative to encourage farmers to capture
relevant information about product, dosage andthresholds for CPA application.
• 2016 onwards. Scope: MP tobacco farmers in
Misiones.

– – By Q4 2017, at least 20 of the farms supplying
tobacco to MP visited by Porvenir.
– – By 2018, 80% of people surveyed
acknowledges Child Labor or Safe Work
Environment by Porvenir-NEA intervention.
ALP Code Principle 6: Freedom of Association

MP will continue distributing PPEs to farmers insuch a way to ensure its renewal once useful life iscompleted.
• 2016 onwards. Scope: MP tobacco farmers in
Misiones.
MP will start introducing PPE for harvesting in athree-year plan.
• 2018 onwards. Scope: MP tobacco farmers in
Misiones
Expected results• Farmers aware of general safety hazards at farms
by 2017.
• Mechanism in place to identify farmers not awareof safety hazards at farm by 2017.

CU’s assessment shows that there is no specificrisk in this principle. Nevertheless, communicationmaterials in field technicians’ toolkit will be
upgraded to incorporate current applicable laws
and names of organizations available to support
workers’ inquiries. This principle will be included in
the additional monitoring strategy.
ALP Code Principle 7: Compliance with the law.
MP acknowledges the importance of farmers’
compliance with Argentinian regulations for
employment relations and is committed to develop
communication materials and trainings. A pay slip
form will be developed to improve compliance withthe law and raise farmers’ awareness regarding
contracting requirements for workers. This principle
will also be included in the additional monitoring
strategy mentioned previously.

• Farmers have a lock-up CPA storage by 2019.
• Farmers trained by +Chacra fill in their CPA
record form.
• Identified and addressed issues in storage ofempty CPA containers at farms.
• Identified and addressed no use of protective
clothes for CPA application.
• Identified
farmers
notfollowingrecommendations for GTS prevention.
• Through Porvenir Program:–– By 2018, 100% Massalin’ FT have awareness/training tools and an improved toolkit topromote the implementation of ALP on thefield, containing all applicable legal updates.

Concluding Remarks
Since the beginning of the ALP Program in Argentina,
Massalin Particulares has been committed to its
implementation in order to progressively improve
working conditions of tobacco farms in Misiones.
A poor socio-economic environment, made worse
by an erratic weather season due to excess of rain,that negatively affected crop yields and farmers’
income during the assessment, were challenges that
also had to be considered to redesign strategies
looking for ALP implementation.
Before the ALP Program implementation, training of
personnel used to focus on the technical rather than
the social aspect of tobacco production, somethingthat had to be overcome to strengthen the agronomy
team to face the future, looking for a new set of bestpractices for tobacco production in Misiones. This

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process took longer than expected, but the team
today in Massalin Particulares is stronger, with adeep commitment to address social issues at farm,and is ready to advance following the assessment
recommendations.
The Control Union report is a valuable tool toidentify the barriers that must be addressed toachieve the ALP Program objectives of eradicating
child labor and any labor abuse in tobacco farms.
Massalin Particulares acknowledges that thisprocess is complex and some ALP standards were
not managed as priorities before Control Union’s
assessment, but following Control Union findings,
the team implementing ALP today is ready to move
forward and to put in place an integrated plan toaddress systemic labor issues in Misiones.

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Appendix 2. ALP Code
ALP Code Principle 1: Child labor

ALP Code Principle 2: Income and work
hours

There shall be no child labor.
Measurable Standards:
1. There is no employment or recruitment ofchild labor. The minimum age for admission
to work is not less than the age for thecompletion of compulsory schooling and,in any case, is not less than 15 years or theminimum age provided by the country’s laws,
whichever affords greater protection. 54
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 thatthe work is light work and the child is between
13 and 15 55 years or above the minimum age
for light work as defined by the country’slaws, whichever affords greater protection.

Income earned during a pay period or
growing season shall always be enoughto meet workers’ basic needs and shallbe of a sufficient level to enable thegeneration of discretionary income.
Workers shall not work excessive orillegal work hours.
Measurable Standards:
1. Wages of all workers (including for temporary,piece rate, seasonal, and migrant workers)
meet, at a minimum, national legal standards
or agricultural benchmark standards.
2. Wages of all workers are paid regularly, at aminimum, in accordance with the country’slaws.
3. Work hours are in compliance with thecountry’s laws. Excluding overtime, work
hours do not exceed, on a regular basis, 48
hours per week.
4. Overtime work hours are voluntary.
5. Overtime wages are paid at a premium asrequired by the country’s laws or by any
applicable collective Agreement.
6. All workers are provided with the benefits,holidays, and leave to which they are entitledby the country’s laws.

54. As an exception, pursuant to ILO Convention 138, developing countries may under certain circumstances specify aminimum age of 14 years.
55. The same ILO convention 138 allows developing countries to substitute “between the ages 12 and 14 in place of“between the ages 13 and 15”.
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ALP Code Principle 3: Fair treatment

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

5. Farmers do not retain the original identity
documents of any worker.
6. The farmer does not employ prison orcompulsory labor.

ALP Code Principle 5: Safe work
environment
Farmers shall provide a safe work

Measurable Standards:
1. There is no physical abuse, threat of physicalabuse, or physical contact with the intent toinjure or intimidate.
2. There is no sexual abuse or harassment.

environment to prevent accidents andinjury and to minimize health risks.
Accommodation, where provided, shallbe clean, safe and meet the basic needsof the workers.

3. There is no verbal abuse or harassment.
4. There is no discrimination on the basis ofrace, color, caste, gender, religion, politicalaffiliation, union membership, status as aworker representative, ethnicity, pregnancy,social origin, disability, sexual orientation,
citizenship, or nationality.
5. Workers have access to a fair, transparent
and anonymous grievance mechanism.

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 fromthe employer.
2. Workers are free to leave their employment
at any time with reasonable notice.

Measurable Standards:
1. The farmer provides a safe and sanitary
working environment, and takes all reasonablemeasures to prevent accidents, injury andexposure to health risks.
2. No worker is permitted to top or harvest
tobacco, or to load barns unless they havebeen trained on avoidance of green tobacco
sickness.
3. No worker is permitted to use, handle orapply crop protection agents (CPA) or otherhazardous substances such as fertilizers,
without having first received adequate
training and without using the required
personal protection equipment. Persons
under the age of 18, pregnant women, andnursing mothers must not handle or apply
CPA.
4. Workers do not enter a field where CPA havebeen applied unless and until it is safe to doso.

3. Workers are not required to make financial
deposits with employers.

5. Workers have access to clean drinking andwashing water close to where they work andlive.

4. Wages or income from crops and work done
are not withheld beyond the legal and agreed
payment conditions.

6. Accommodation, where provided, is clean,safe, meets the basic needs of workers, andconforms to the country’s laws.
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ALP Code Principle 6: Freedom of

ALP Code Principle 7: Compliance with theassociation

law

Farmers shall recognize and respect

Farmers shall comply with all laws ofworkers’ rights to freedom of association

their country relating to employment.

bargain collectively.
Measurable Standards:
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 discriminatedagainst and have access to carry out theirrepresentative functions in the workplace.

1. All workers are informed of their legal rights
and the conditions of their employment when
they start to work.
2. Farmers and workers have entered into
written employment contracts when requiredby a country’s laws and workers receive a
copy of the contract.
3. Terms and conditions of employment
contracts do not contravene the country’s
laws.

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