T OBACCO ’ S H IDDEN C HILDREN 126 T OBACCO ’ S H IDDEN C HILDREN 126

T OBACCO ’ S H IDDEN C HILDREN 126 T OBACCO ’ S H IDDEN C HILDREN 126

The US Tobacco GAP approach to labor emphasizes growers’ obligations under US law, and requires growers to provide “a safe work environment,” recognize workers’ rights to freedom of association, meet minimum standards for housing, and train workers on health and safety hazards, including nicotine poisoning. 475 Regarding child labor, the GAP Program handbook requires growers to: “Follow all relevant contractual and legal requirements concerning the regulations on child labor,” and advises growers to review federal and state laws governing the employment of children under 18 in agriculture. 476 A number of companies noted to Human Rights Watch that starting in 2013, third party auditors will be used to evaluate grower compliance with US GAP on an annual basis. 477

Multi-Stakeholder Initiative Since April 2012, three large tobacco product manufacturers began participating in a North Carolina-based multi-stakeholder initiative, called the Farm Labor Practices Group (FLPG). 478 The group now includes several leading tobacco manufacturers and leaf merchants—Altria Group, Philip Morris International, Reynolds American, Japan Tobacco International, Alliance One, and Universal—along with tobacco grower representatives, FLOC, the Interfaith Center on Corporate Responsibility (ICCR), and US Department of Labor representatives.

473 US Tobacco GAP Program Handbook, https://gapconnections-public.sharepoint.com/GAPC%20Book/Guidelines.pdf (accessed February 13, 2014), , p. 1.

474 The US Tobacco GAP Program was endorsed by: Alliance One International, American Snuff Co., Burley Stabilization Corporation, Hail and Cotton, John Middleton Company, Japan Tobacco International Leaf Services (US), Lorillard Tobacco

Company, Philip Morris International, Philip Morris USA, R.J. Reynolds Tobacco Company, Santa Fe Natural Tobacco Co., United Tobacco Company, Universal Corporation, US Smokeless Tobacco Company, and US Tobacco Cooperative.

475 US Tobacco GAP Program Handbook, pp. 15-21. 476 Ibid, pp. 16-17. 477 For example, letter from Ligon, p. 5. 478 The original companies involved were Altria Group, Philip Morris International, and Reynolds American.

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Many of the companies specifically mentioned their participation in the FLPG in their written responses to and in meetings with Human Rights Watch. The aim of the group, which has met several times since its inception, is, according to Altria Group, “to help both farmers and farmworkers better understand and comply with applicable labor laws and regulations, and to foster improved farm labor practices, where needed.” 479 According to Universal, “Significant issues identified by the FLPG to date include the use of disreputable labor contractors, the protection of undocumented migrant labor, and housing conditions for farm laborers” and that the FLPG “had not identified child labor as

a significant problem in U.S. tobacco farming relative to other issues being discussed.” 480 There are sub-groups assigned to specific topics such as public policy, training and education, and grievance procedures. 481 At the invitation of some members of the group, Human Rights Watch staff gave a presentation to the group on April 10, 2014 concerning the findings and recommendations of this report. Following the presentation, FLPG members agreed to form a working group on child labor.

Eliminating Child Labour in Tobacco Growing Foundation Seven of the ten companies contacted for our report are members of the Eliminating Child Labour in Tobacco Growing Foundation (ECLT Foundation), a Geneva-based organization devoted to preventing child labor in tobacco agriculture. The organization’s US$6.4 million budget is funded through contributions primarily from tobacco and tobacco leaf companies that sit on the foundation’s board. 482 The foundation carries out projects in tobacco-growing countries, including Kyrgyzstan, Tanzania, Malawi, Mozambique, and Uganda, (and had projects in Zambia and the Philippines in the recent past), to withdraw children from tobacco farmwork, improve access to education, and strengthen economic livelihoods in tobacco- producing communities. ECLT Foundation initiatives to provide children with alternatives to tobacco work include model farm schools in Tanzania, after-school education programs income-generation projects, and occupational safety and health advocacy in Malawi, holiday camps for children of tobacco workers in Kyrgyzstan, and scholarship programs in Uganda. 483 The Foundation does not carry out any projects in the United States.

479 Letter from Hubbard. 480 Letter from Ligon, p. 6. 481 R.J. Reynolds, “Farm Labor Issues,” http://www.rjrt.com/laborissues.aspx (accessed February 11, 2014). 482 The board includes 17 organizations, including tobacco and tobacco leaf companies, tobacco growers’ associations, and unions. The International Labour Organization and Save the Children are advisors to the board.

483 Human Rights Watch meeting with Sonia Velázquez, executive director; Nicholas McCoy, senior policy and advocacy officer; and Innocent Mugwagwa, senior programme manager, ECLT Foundation, Geneva, Switzerland, March 14, 2014.