T OBACCO ’ S H IDDEN C HILDREN 120

T OBACCO ’ S H IDDEN C HILDREN 120

With regard to training and implementation of the ALP worldwide, since 2001, “over 3,700 PMI employees (and our suppliers) and nearly 500,000 tobacco growers in more than 30 countries have been trained on ALP principles and standards” for the farms where PMI sources tobacco. 436 PMI also undertook to identify priority issues on farms and to “systematically address issues and measure [the] progress on a long-term basis.” 437 Children involved in hazardous work falls under the company’s “prompt action” category. 438

In a February 2014 written response to Human Rights Watch, PMI provided extensive detail about implementation of other aspects of the ALP in the US and globally. 439 PMI also shared with Human Rights Watch details about its monitoring of growers’ adherence to the ALP in the US and globally, including plans to systematically monitor 100 percent of its farms in the US by 2015. 440 PMI participates in the multi-stakeholder Farm Labor Practices Group and stated that it has assumed leadership roles in subgroups created to address specific issues. 441

In response to Human Rights Watch’s findings and recommendations, PMI stated that it would broaden its internal monitoring effort to visit all contracted farms in the US, in addition to the third-party assessment during the 2014 peak season. PMI also stated that it did not agree with Human Rights Watch’s recommendation to extend restrictions on children working to all stages of the tobacco crop. PMI stated that it would welcome “a strengthening of the US regulatory framework to align it with [PMI] and ILO’s international standards, and would support a sector-wide approach” to child labor in tobacco farming. PMI also described initiatives underway in the US, including a higher education scholarship program for children of farmworkers in 2015, and a summer school for migrant farm children. 442

Reynolds American Reynolds American (RAI) is the parent company of R.J. Reynolds Tobacco Company (R.J. Reynolds), the second-largest US tobacco company, and Santa Fe Natural Tobacco

436 Letter from Goodale. 437 Ibid. 438 Letter from Goodale, Annex 1, p. 3. 439 Letter from Goodale, Annex 1. 440 Letter from Goodale. 441 Ibid. 442 Letter from Jennifer P. Goodale, Vice President, Contributions and External Labor Policies, Philip Morris International, to Human Rights Watch, April 24, 2014.

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Company, producer of Natural American Spirit cigarettes, among other companies. 443 Reynolds’ products include two of the best-selling cigarettes in the US: Camel and Pall Mall . 444 As noted above, BAT holds a 42 percent stake in Reynolds American.

R.J. Reynolds, which purchases tobacco leaf on behalf of all Reynolds American tobacco product manufacturing subsidiaries, does not have a specific child labor policy that it implements throughout the supply chain, but stated to Human Rights Watch that it addresses child labor through its expectations that the growers with whom it contracts directly comply with national law. It articulates these expectations through the contracts with growers and provides training and educational resources to growers and workers on health, safety, and other issues to help them operate in “a safe and legally compliant manner.” 445 R.J. Reynolds did not articulate to Human Rights Watch any policies concerning child labor or worker protections expectations for non-contract farms supplying tobacco to the company through intermediaries, namely leaf merchant companies.

Both the R.J. Reynolds letter to Human Rights Watch and the Reynolds American website indicate that the businesses distance themselves from the labor practices in their tobacco supply chain, stating: “Because farm workers are not our employees, we have no control over their recruitment, their hiring, or the terms and conditions of their employment,” 446 and “Because farm workers are not our employees, we have no direct control over their sourcing, their training, their pay rates, or their housing and access to human services.” 447 Instead, the company said it focuses on ensuring that its suppliers “have the training and resources they need to do the right thing” for workers in the supply chain. 448 The company’s website also states that it seeks to “Support and respect the protection of internationally proclaimed human rights.” 449

443 Reynolds American, Homepage, http://www.reynoldsamerican.com/index (accessed February 5, 2014). Reynolds American was created in 2003 when R.J. Reynolds Tobacco Holdings and British American Tobacco (BAT) signed an

agreement to combine the assets and operations of their respective US tobacco businesses. Reynolds American, “Frequently Asked Questions.” http://www.reynoldsamerican.com/faq.cfm (accessed February 5, 2014). 444 Reynolds American, Homepage, and “Frequently Asked Questions.”

445 Letter from John S. Wilson, III, Vice President, Corporate Sustainability and Commercial Equity, RAI Services Company, to Human Rights Watch, February 28, 2014.

446 Ibid. 447 Reynolds American, “Supplier Responsibility,” http://www.reynoldsamerican.com/supplier- responsibility.cfm?plank=SupplierResponsibility3 (February 5, 2014).

448 Ibid. 449 Reynolds American, “Statement on our Efforts to Support Human Rights,” http://www.reynoldsamerican.com/vision.cfm (accessed February 5, 2014).