Syngenta ProjectReport 2007-2008 - Fair Labor … 1 FLA SYNGENTA PROJECT REPORT 2007 ... III. KEY EVENTS ... Basel. It ranks third in

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FLA SYNGENTA PROJECT REPORT 2007 - 2008

THE FAIR LABOR ASSOCIATION

THE SYNGENTA PROJECT

REPORT 2007-2008

MONITORING THE AGRICULTURE SECTOR

Syngenta sponsored child to school poster on the wall of a local school

REPORT PREPARED BY RICHA MITTAL

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TABLE OF CONTENTS

I. EXECUTIVE SUMMARY……………………………………………………3

II. BACKGROUND…………………………….………………………………..4

III. KEY EVENTS……………………………………………………….………6

IV. FLA INDEPENDENT EXTERNAL MONITORING…………………….7

• FINDINGS…………………………………………………………………..9

V. HIGHLIGHTS FOR REMEDIATION………………………………..……11

VI. KEY LEARNINGS………..………………………………………………...11

VII. SYNGENTA AND FLA OBLIGATION OF COMPANIES…...……….12

VIII. FURTHER RECOMMENDATION……………………..……………...15

IX. REFERENCES……………………………………………………………..15

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EXECUTIVE SUMMARY The FLA began a pilot project in the agriculture sector in 2004 when Syngenta Seeds Inc. a Swiss agro-business company approached the FLA to help them monitor working conditions in their Indian hybrid cotton seed supply chain. Though the project was initiated in the cotton seed sector, Syngenta sold its global cotton seed business in 2005. The FLA and Syngenta continued the project in the hybrid vegetable seed sector, beginning in 2006,1 and have made significant progress in past two years. The FLA built an in-depth understanding of the tasks and risks involved in the hybrid seed production. Through this process, the FLA developed and field tested a set of benchmarks and a monitoring system with relevant tools for the agriculture sector, based on ILO conventions and the FLA’s Principles of Monitoring. In keeping with the FLA 3.0 philosophy, five multi-stakeholder consultations were jointly held by the FLA and Syngenta at different stages of the process to share the project with stakeholders and solicit their advice. Stakeholders prioritized monitoring of child labor, health and safety, and wages and benefits, as well as remedial actions on child labor and health and safety. Many stakeholders, who attended the consultations and provided candid opinions, viewed the meetings as successful and appreciated Syngenta’s willingness to integrate recommendations into their internal compliance program. In 2008, FLA conducted unannounced independent external monitoring (IEM) visits of Syngenta’s farms. Each IEM was conducted on a cluster of approximately 25 farms each selected at random from farm lists provided by Syngenta. This was done as the farms are small and ranged between 0.25 – 1 acre. Health and safety, code awareness and hours of work emerged as top three non-compliance issues in external monitoring. FLA as part of its transparency initiative, designated web space for the project on its website under special projects, where progress reports, research studies, monthly newsletters and monitoring reports with remediation plans are published. Syngenta submitted corrective action plan for the issues uncovered in both internal and external monitoring. Syngenta has made efforts to fulfill FLA’s company obligations as prioritized by stakeholders in the consultations. Although there are areas for improvement, the project has tested Syngenta’s commitment towards improving working conditions in their supply chain. Syngenta has internally monitored 1727 farms for all code of conduct elements in contrast to other seed companies operating in India, which only monitor for child labor,. This pilot project demonstrates that the FLA’s independent external monitoring methodology can be adapted well to the hybrid vegetable seed sector. The experience and learning from the Syngenta project suggest that the FLA system may have the capacity to go deeper into the supply chain of the apparel sector, such as home-based work, cotton seed production, and more. As the methodology emerging from the Syngenta project is further refined, it may prove to be adaptable to other supply chains involving small rural land holdings.

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BACKGROUND The concern about unfair labor practices prevailing in the agriculture sector has been well documented in a range of studies by the International Labor Organization (ILO)2, independent researchers3, international4 and national non government organizations (NGO) and media campaigns. There are several reports on poor working conditions in cotton production in Uzbekistan, Pakistan and India, cocoa farms in Africa and coffee estates in Central America. Some studies have also reported on child labor issues in the hybrid seed production sector in India5. One such media campaign in 2003 regarding the presence of child labor in the Indian cotton seed farms of Syngenta Seeds Inc. brought that company to the Fair Labor Association (FLA). Syngenta Seeds Inc. is a Swiss multinational headquartered in Basel. It ranks third in high-value commercial seeds market in the world with sales of approximately $9.2 billion in 2007. Syngenta employs over 21,000 people in more than 90 countries. Until 2004, Syngenta was the largest producer of hybrid cotton seeds in the world with business accounting for USD 3 million. The FLA at that time had monitoring and remediation experience in the apparel, footwear and sporting goods sector. The FLA advised Syngenta to develop a project wherein both organizations would work in collaboration to map, assess, analyse, monitor and remediate the issues in Syngenta’s hybrid seed supply chain. FLA organized the first activity under the project in 2004. It developed a task and risk mapping methodology and mapped Syngenta’s hybrid cotton seed supply chain. Two Task and Risk Mapping Studies were commissioned by the FLA in April 20046 and October 20047 to identify the tasks undertaken in production of the hybrid cotton seeds and the risks associated to each task. The outcome of the first study was shared with stakeholders at a consultation held in Brussels in July 2004. The objective of the consultation was to put the corporate social responsibility commitments made by Syngenta into practice, to engage with stakeholders, to take the lead in several social and environmental issues, and to give stakeholder an opportunity to engage with the company. As requested by key stakeholders, such as the Indian Committee of Netherlands, a follow-up consultation was organized by Syngenta along with the FLA and Phillias in Hyderabad in July 2005.8 The objective of this consultation was to identify potential problems, reduce inherent risks of long production chains, and helping to assure sustainable social and environmental practices. Based on recommendation provided by the participants of both consultations, Syngenta and FLA’s staff in India started developing a monitoring program for the cotton seed sector. The company staff undertook certain preliminary steps such as drawing up written contracts with growers with clauses against employment of child labor, sponsoring education items in the village schools, and conducting awareness programs in the villages. As the project progressed, Syngenta took the business decision to sell their global cotton seed business. Nevertheless, they decided to continue their engagement with the FLA and start monitoring their hybrid vegetable seed farms, the second most important business for them. Most learning from the cotton seed sector could be well applied to the vegetable seeds. Therefore a program was initiated in the vegetable seed sector in June 2006. Similar methodology of task and risk mapping was used to

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identify high risk areas in the vegetable seed sector.9 The FLA and Syngenta then jointly developed the seed production practices document 10 (benchmarks) to be adopted by the Syngenta growers and an internal monitoring program based on the FLA’s obligations of companies.11 Syngenta conducted internal monitoring of their farms in 2007. By the end of 2008, they had monitored a total of 1727 farms. Child labor was a problem during peak season, when 8-10 workers were needed for cross-pollination activities. Health, safety and environment (HSE) also emerged as a priority issue as workers were not aware of personal protection during chemical use. Syngenta developed comprehensive health and safety remediation plans. To tackle the child labor issue, the FLA and Syngenta invited a selected group of experts to the Hyderabad consultation in November 2007, to discuss the child labor issue in Syngenta’s okra and pepper farms.12 Based on expert recommendations, Syngenta developed an additional child labor monitoring tool for the farms. They also introduced an incentive scheme13 and piloted it with their okra growers in April 2008. Syngenta monitored their farms three times in one production season as prescribed by the task and risk mapping. Growers who were in compliance at all three monitoring events were given a bonus of up to 5 percent of the total procurement price. The maximum leverage, in the incentive scheme, was given if there was an absence of child labor. Additionally, a progressive disciplinary policy was introduced, wherein after repeated reminders and remediation, a grower would be blacklisted if found delinquent on child labor for two consecutive production seasons. Several awareness building programs were mounted in the field. Pre-season meetings with the growers were organized to make them aware of the COC and Syngenta’s relationship with the FLA. Written contracts with fair working conditions clauses were drawn with growers. A labor monitoring tool was integrated with the existing field crop card (for quality check of the seeds during the production season) and supervisors were trained to look for labor compliance issues while conducting field visits. Syngenta submitted their farm lists for ten vegetable seeds to the FLA starting in 2007. Other documents necessary for the FLA to conduct IEMs, such as the farm access letter, location of regional offices, and monitoring services agreement, were provided by Syngenta. Syngenta also remitted IEM dues and submitted an annual report.

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KEY PROJECT EVENTS

July 2003 Syngenta approaches the Fair Labor Association

October 2003 FLA President visits India to conduct preliminary investigation

April 2004 FLA commissions a Task and Risk Mapping Study (I) of the hybrid cotton seed sector

October 2004 FLA commissions a Task and Risk Mapping Study (II) of the hybrid cotton seed sector

July 2004 Stakeholder consultation (I) on hybrid cotton seed sector held in Brussels

June 2005 Stakeholder consultation(II) on hybrid cotton seed sector held in Hyderabad

December 2005 Syngenta sells their worldwide cotton seed business to Delta and Pine who in turn sell it to Monsanto

May 2006

Syngenta decides to continue the relationship with the FLA and nominates hybrid vegetable seed for the project

June 2006

FLA commissions a Task and Risk Mapping Study (III) of the hybrid vegetable seed sector

July 2006

Syngenta in collaboration with the FLA develops its internal monitoring system and tools

September 2006

FLA staff conducts a series of field trainings for Syngenta staff on monitoring and code of conduct

October 2006

FLA conducts pilot testing of the its agriculture audit instruments

December 2006 Stakeholder consultation (III) on hybrid vegetable seed sector held in Hyderabad

March 2007

Syngenta submits their first series of farm lists and monitoring documents to the FLA

April – Sept 2007

Syngenta continues to internally monitor their farms

October 2007

Syngenta and FLA work on the remediation strategy for health and safety and child labor issues

November 2007

Stakeholder consultation (IV) on child labor issues in the hybrid vegetable seed sector held in Hyderabad

December 2007

Syngenta submits their Annual Public Report to the FLA

January 2008

FLA finalizes the Monitoring and Compliance Benchmarks and auditing tools for the Agriculture Sector

February 2008

FLA and Syngenta held a series of meetings with grass root level organizations to explore collaboration avenues

April 2008

Syngenta commissions a study on Health and Safety priorities in the vegetable seed sector

May 2008

Syngenta introduces an incentive scheme for okra growers based on their compliance status

July 2008

FLA organizes a workshop for monitors in Bangalore. FLA starts a monthly newsletter to report on project progress

August 2008

FLA films the first unannounced independent external monitoring visit in Maharashtra

September 2008

FLA conducts two more unannounced independent external monitoring visits of Syngenta farms in Gujarat and Karnataka

December 2008 Stakeholder consultation (V) on discussing remedial strategies in the hybrid vegetable seed sector held in Hyderabad

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FLA INDEPENDENT EXTERNAL MONITORING

The FLA, along with International Resources for Fairer Trade (IRFT), adapted the standard FLA monitoring and compliance benchmarks and IEM tools for the agriculture sector. A pilot test of the farm audit tool was conducted in October 2006 in Aurangabad. A multi stakeholder consultation14 was organized in December 2006 in Hyderabad to present the external monitoring methodology and benchmarks to the stakeholders. While they found the benchmarks and IEMs to be comprehensive, stakeholders suggested some modifications to the FLA process for the agricultural sector. Child labor, health and safety, and payment of minimum wages and benefits were prioritized as the most important issues for strengthened monitoring. A common standard (COC) was recommended for all seed producing companies with collaboration on remedial interventions. In 2007, the FLA circulated the draft benchmarks to other international civil society organizations and refined the benchmarks and tools based on recommendations and pilot audits. The FLA also developed the accreditation criteria for the monitors and selected independent external monitors with experience in agriculture monitoring to attend a monitoring workshop in July 2008 prior to the farm audits. Three monitoring teams were selected to conduct three unannounced pilot audits held in August and September 2008. These pilot audits were the final and most critical step in testing whether the adaptation of the FLA methodology to the agriculture sector would be successful. The FLA carried out independent external monitoring visits (IEM) for a cluster sample of 2963 okra farms on a list provided by Syngenta. Okra farms were selected as okra was considered a high risk crop based on the task and risk mapping study and it also has the largest seed production in terms of volume. Some farms were also producing hot peppers for Syngenta. Clustering was used because of the very large number of very small farms (0.25 – 1 acres in size) and the fact that they are located next to each other. Three IEMs were conducted in three different states. The farm lists for each state (Karnataka, Gujarat and Maharashtra) were kept separate to take advantage of regional proximity. In each state there are numerous districts that comprise of a number of talukas, which are made up of several villages. In each village many farms are located that produce seeds for different companies. The taluka for each state selected for the IEM was randomly picked at the FLA headquarters. One IEM was done for a cluster sampling of approximately 25 farms located in one taluka. Twenty five farms were selected in order to test the maximum number of farms that could be visited in two audit days (the average time taken by the FLA auditors in factory audits). One audit day was assigned for field based external information gathering and a regional office visit. Based on task and risk mapping, all three audits were scheduled at the time of cross-pollination, as this was considered a high risk season for the crops with the maximum likelihood of finding hired child labor in the farms. The auditors had to monitor at least 50 percent farms from the random sample, with a flexibility to choose the other 50 percent farms from the locality. This was done so that the monitor can include information if they come across mal-practices in a neighbouring Syngenta farm or identified high-risk farms based on other information

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gathering. A breakdown of the selected villages under each randomly chosen taluka is presented in the table below (number of total okra farms in parenthesis). State Maharashtra (1039) Gujarat (1666) Karnataka (258)

District Buldana (881) Sabarkantha (348) Haveri (46)

Taluka Deulgoan Raja (268) Bayad (291) Haveri (46)

Villages Pangri (12) Lok (69) Gudur (23)

Golegaon (45) Nagana Math (53) Gudusalakoppa (6)

Gillori (18) Punsri (14) Mevundi (15)

Deulgaon Raja (163) Vajawat (33) Niralagi (2)

Balleshwara (16)

As per the FLA’s monitoring guidelines, the monitors conducted pre-audit investigation * , unannounced farm visits, and visit to the regional office of the company. They conducted visual inspection, documentation review, and worker, grower and company staff interviews. Monitors were to inform the FLA of any critical “red flag issue” as defined in the Farm Audit Instrument within 24 hours of uncovering such an issue. Three audit tools – Farm Audit Instrument15 , Internal Monitoring System Audit Instrument 16 and Agriculture Audit and Tracking Instrument17 (AATI) – were developed and provided to the monitors. The FLA staff accompanied the monitors in the audits conducted in Maharashtra and Gujarat. A total of 60 farms were visited in 13 villages in three states producing vegetable seeds as described in the table below. State Region Number of

Villages

Number of

Farms

Total Area

Covered

(Acres)

Number of

Interview

Conducted*

Maharashtra

Deulgaon Raja 4 17 5 23

Gujarat

Sabarkantha 4 19** 5 23

Karnataka

Haveri 5 24 20 26

Total 13 60 72 *The interviews include one-on-one conversation with the growers, workers, management and experts

who were contacted during and before the audit to collect information on agriculture practices. This

does not include the interviews, group discussions and conversation with village residents during

audits.

**A total of 24 farms were visited, however 5 farms were no longer producing for Syngenta when the

monitors visited and therefore are not counted in the final tally of visited farms.

An additional feature included in the agriculture IEMs is a quantitative review of Syngenta’s internal compliance program. This tool was designed to allot scores for each fulfilled company obligation with a maximum score of 100. This information provided a basis to assess Syngenta’s compliance towards obligations of companies set forth in the FLA monitoring guidelines document. A qualitative report was prepared that consolidated all observations made by the auditors with data integrated

* Pre-audit information gathering involves conducting due diligence, research and information gathering before the auditor reaches the audit site. This can involve desk research, discussion with field experts, local NGOs, trade unions, village people and drive through the village. This is done in order to identify prevailing local practices and risks in the region.

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from the farm audit instrument and internal monitoring system instrument. The company was to provide a remediation plan. FINDINGS

In spite of scheduling the audits at peak season, monitors observed small saplings at the farms instead of the waist-high plants required for cross-pollination. The delay of monsoon rains in all three regions damaged the crop and new seeds had to be sown. This has a bearing on the audit findings. During the audits, no hired workers were at the farms. Only family workers were present in the farms. Therefore the following findings are based on interview with growers, family labor and management, visual inspection and documentation review. A total of 54 noncompliances were identified in the three audits. The number of noncompliances is based on the number of benchmarks not fulfilled under each IEM. If more than one farm or all farms in the IEM unit or cluster were found to be noncompliant on the same benchmark, only one noncompliance was recorded. The breakdown of noncompliances is provided below:

FLA Code Noncompliances Percent (%)

Code Awareness 8 14.81

Forced / Bonded Labor 2 3.70 Child Labor 2 3.70 Harassment & Abuse 3 5.56

Health & Safety 27 50.00 Freedom of Association 1 1.85

Hours of Work 6 11.11 Wages, Benefits & Overtime 5 9.26 Total 54 100.00

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Code Awareness: Many growers were not aware of Syngenta’s code of conduct, and none of the family workers had any code awareness. The regional offices did not have sufficient documentation of training programs provided to growers and workers. Although 80 percent of the work was conducted by women, none of the Syngenta trainings involved women as target audience. Very few growers were aware of the relationship between the FLA and Syngenta. No grievance mechanism existed at the farms and the noncompliance reporting mechanism was only available for growers as opposed to workers. Forced / Bonded Labor: No employment records were maintained for workers or family labor. Child Labor: Syngenta’s existing child labor policy did not require farms to have an age verification process or to maintain documents that verify the age of the workers. No children were observed working at the farms at the time of monitoring. Nevertheless, their presence cannot be ruled out during peak season. Harassment and Abuse: There is no policy or procedure on handling grievances at the farms. The workers and growers were not trained in disciplinary measures and grievance handling mechanisms, therefore were unaware of such procedures. Non-discrimination: The audits highlighted gender-based wage discrimination existing in all farms. The women workers were paid less wages per day as compared to their male counterparts. Health and Safety: Many monitored farms reported issues related to chemical management, including lack of training, proper management and health risks associated to unprotected use of chemicals such as pesticides and insecticides. In general there was lack of presence and use of personal protective equipment (PPE) such as masks, gloves and closed shoes. Syngenta kept first aid kits in some village schools, as this was a common place where growers and workers can visit to access first aid in case of emergency, but no one was trained in first aid handling. Health and safety policies or procedures were not made available to the growers. Some monitors reported a lack of proper rest areas, toilets and clean drinking water at the farms. Freedom of Association: No worker organizations are operating in the audited regions, and thus there were no noncompliances with respect to freedom of association. The monitors listed lack of grievance mechanism under the freedom of association section. Hours of Work: There was no system for recording the number of hours worked at the farms. Growers were provided an attendance register by the company but they only recorded daily attendance, not total hours worked. According to some growers, during peak season workers might be in the fields up to 10-12 hours per day for 30 consecutive days, without any breaks in between. Wages and Benefits: None of the audited farms paid minimum wages as prescribed by the government to the workers and as stated above, gender-based wage discrimination was commonly found. Deductions from daily wages were made for food and transportation provided. Workers were not provided wage awareness training by the company. There were no wages and benefits documentation maintained at the farms. Overtime Compensation: The overtime hours and related wages were not tracked and paid to the workers.

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HIGHLIGHTS FOR REMEDIATION Syngenta submitted three corrective action plans18 (CAP) in January 2009 to address the noncompliances found in all three IEMs. The CAP incorporated suggestions made by participants of a working session during the multi-stakeholder consultation held in Hyderabad in December 2008. Stakeholders were informed of the noncompliances found on Syngenta’s farms and engaged to help develop remedial strategies for Syngenta. 19 Many noncompliances that were identified were not considered suitable for remediation. These included noncompliances related to maintenance of employment records for family members, having a room as a rest area, providing toilet facilities at the farms, providing wages to the family members and tabulating the barter system for services. Rather, the stakeholders advised adapting the monitoring system to the cultural and practical limitations of the region and of small farms. Discussion on remedial efforts focused on child labor and health and safety. Participants developed steps for: increasing awareness among growers and their family members; identifying and verifying ages of child laborers at the farm level; building awareness at the source of labor recruitment; maintaining minimum documentation requirements at the farms; assessing and intervening in cases of harassment, abuse and discrimination at farms; installing low cost, locally-relevant grievance procedures that will involve prominent people of the local village; focusing on areas for health and safety; developing village level committees; creating rural schemes and incentive schemes for growers. Many voiced the critical role that the seed organizers and company supervisors can play in enhancing the program. KEY LEARNINGS ABOUT THE PROCESS

� The farm selection has to be done from the latest farm lists as there were substantial changes to the farm lists due to consolidation occurring in Syngenta's supply base.

� There is a turn around time of 5 months to receive updated farm lists, conduct farm list breakdown, randomly select the farms, schedule the audit, conduct and report on the audit findings and install remedial interventions. Therefore a stricter timeline is needed in order to cover all seasons and all crops under monitoring, as well as some flexibility built into the process should weather impact the season appropriate for monitoring as was this case with this audit.

� Monitoring activity needs to be scheduled during high-risk activities (emasculation and pollination, chemical spray, harvesting). Weather conditions play significant role in the production cycle as delay of rains or excessive rains can destroy the crop and hence weather conditions need to be taken into account.

� The regional office of the company should be visited at the end of the audit. This will aid in corroboration of most information collected from farms and conduct closing meeting with company representatives.

� The IMS Instrument requires further refinement to provide relevant weighting to questions. It can be used effectively to measure progress over a period of time due to its quantitative nature.

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� Some growers were producing Syngenta crops on only one acre of their land, and growing commercial cotton on other acreage (up to 10 in some cases). Cotton is highly labor intensive crop and has chronic child labor issues. Therefore, the monitors should look into child labor and health and safety issues in those farms.

� The audit visit should be made to the sub-regional office or the regional office where ever the documents of the local growers are present. Therefore all relevant office addresses should be provided to the monitors before an audit.

� Agriculture monitoring is demanding due to distances and lack of good roads. It is therefore necessary to plan the number of days to be spent in the filed accordingly.

� Some growers are PLD (Ploughed Down), which means that after initial sowing, due to various reasons the grower is not on the final list and is not producing for Syngenta any more. Some think, however, that they are still producing for Syngenta. Although the sample was taken from the list provided by Syngenta after sowing, however the monitors have to ensure that PLD growers are not audited.

� All growers have three records at the regional office: (1) Contract between Grower, Syngenta and the Organizer; (2) Field Monitoring Crop Card and; (3) Database. All these need to be verified for all audits.

� The findings need a better system of categorization and analysis. � Engagement with local stakeholders is key to building a successful program. � It is imperative to prioritize issues for monitoring and remediation.

SYNGENTA AND FLA OBLIGATIONS OF COMPANIES

I. Adopts and communicates a code

OBLIGATION OF COMPANIES VERIFICATION BY FLA

Formally adopts a code that meets or exceeds FLA standards

Syngenta has formally adopted a code of conduct that adheres to the FLA COC.

Informs all suppliers in writing Syngenta has informed all its growers in writing about their code of conduct.

Posts the code in a prominent place in supplier facilities in the local languages of workers and managers

The code has not been posted in each farm, but code was found posted in relevant places in the village. The stakeholder consultation participants have advised against posting COC in all farms.

Ensures that workers are informed orally and educated at regular intervals (to take account of labor turnover)

Training programs for growers are being conducted in the field. However, no efforts have yet been made to educate the workers.

Obtain written agreement of suppliers to submit to periodic inspections/audits, including by accredited external monitors, to remediate instances of non compliances with FLA Workplace Standards that arise, and to inform employees about those standards

No written information on the FLA has been shared with the growers. However, there has been no challenge in assessing the farms for auditing purposes.

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II. Trains internal compliance staff


Identifies the staff or service provider responsible for implementing their compliance program

Separate staff members have been identified to manage the internal compliance program.

Ensures that they had training in all the areas under their responsibility, including, as appropriate, international and national labor standards, local languages, occupational and production risk factors, and techniques for monitoring, interviewing and remediating

Only a few trainings, such as on monitoring, child labor issues and health and safety have been conducted. More training can strengthen the program.

Updates that training at regular intervals Only health and safety trainings are updated at regular intervals

III. Provides employees with confidential reporting channels


Encourages the establishment of grievance procedures at supplier facilities

No formal grievance procedures have been established at the farm or village level.

Provides channels for Company employees and workers at those facilities to contact the Company directly and confidentially if warranted

A code of conduct with the phone number of the regional staff is provided to the growers. The workers have no means to access this information. This area needs further improvement.

Ensures the channel is secure, so workers are not punished or prejudiced for using it

The channel is secured but the workers currently do not have an access to the information.

IV. Conducts internal monitoring


Internally monitors an appropriate sampling of suppliers to assess compliance, which includes worker interviews, records review, occupational safety and health review, practices of suppliers in relation to the FLA Workplace Standards

Internal monitoring of appropriate number of farms has been taking place since 2006.

Collects, verifies and quantifies compliance with workplace standards

The internal monitoring information is collected in MICD (Monitoring Information Compliance Database).

Analyzes the monitoring results and implements remediation plans to address non-compliance issues

The internal monitoring information is analysed regularly and shared with the FLA and stakeholders at regular consultations.

Tracks the progress of remediation This area needs further improvement.

V. Remediates in a timely manner


Upon receiving the internal and independent external monitoring reports, contacts the supplier concerned (within a reasonable time frame) to agree to a remediation plan that addresses all compliance issues identified by the monitor

Upon receiving the internal and external monitoring report consultations were held with the growers, organizers, NGOs and experts in the field of agriculture to agree on a remediation strategy.

Implements a remediation plan regarding the noncompliances and the actions taken to prevent the recurrence of such noncompliances

The remediation plan involves short and long term strategy to address the issues. These plans however need to be implemented judicially in the field.

Within sixty (60) days, supplies the FLA with the remediation plan citing all progress made and a timeline for outstanding items

The remediation plans have been provided with in 90 days of receiving the reports.

Confirms the completion of remediation This has yet be to verified.

Conditions future business with contractors and suppliers upon compliance standards

The contractual agreements with the organizers and growers conditions future business on compliance standards.

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VI. Takes all steps necessary to prevent persistent forms of noncompliance


Analyzes compliance information to identify persistent and/or serious forms of non-compliance

Internal compliance information is analysed, however the persistent forms of non compliances and their root causes still need to be identified.

Establishes and implements programs designed to prevent the major forms of such non-compliance

A remediation plan is submitted to the FLA has highlights all the steps suggested by the stakeholders to address noncompliances in the supply chain.

Takes steps to prevent recurrence in other Applicable Facilities where such non-compliance may occur

This has yet be to verified.

VII. Submits to Independent External Monitoring


Provides the FLA with an accurate, up-to-date farm list, farm profile, access letters, etc.

Yes

Ensures that the suppliers selected for IEMs cooperate with the FLA monitors

Yes

Cooperates with FLA requests for information, clarification and follow-up in the IEM process

Yes

VIII. Collects and manages compliance information


Maintains a data-base Yes

Generates up-to-date lists of its suppliers when required Yes

Analyzes compliance findings Yes

Reports to the FLA on those activities It is done when FLA requires the information.

IX. Consults with civil society


Maintains links to organizations of civil society involved in labor rights and utilizes, where companies deem necessary, such local institutions to facilitate communication with company employees and employees of contractors and suppliers in the reporting of noncompliance with the workplace standards

Yes

Consults knowledgeable local sources as part of its monitoring activities

No

Consults periodically with the legally constituted unions representing employees at the worksite regarding the monitoring process and utilize the input of such unions where appropriate

No

Assures the implementation of monitoring is consistent with applicable collective bargaining agreements

Not Applicable

X. Pays dues and meets its other procedural requirements


Pays annual dues Yes

Pays IEM administrative and monitoring fees Yes

Signs and honors required FLA contracts Yes

Submits farm lists, a standardized annual report and other information in complete form and on time

Yes

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FURTHER RECOMMENDATIONS

The FLA is encouraged by the results of the pilot project in successfully applying its methodology to this segment of the agriculture sector. The FLA adapted benchmarks, tools, databases, sampling and mapping methodologies that may be relevant to other agriculture supply chains where the production and working conditions are similar to the hybrid seed production. FLA has championed the process of engaging with stakeholders as an innovative approach to achieving sustainable compliance, and this was effective in the Syngenta project. The project continues to be a valuable learning experience for the both the FLA and Syngenta.

REFERENCES

1 The Fair Labor Association’s Syngenta Project Report (2006): Monitoring the Agriculture Sector. 2 Girl Child Labour in Hybrid Cottonseed Production and Processing in Andra Pradesh (2004): A

Study commissioned under ILO-IPEC’s Andra Pradesh State based project for the elimination of child labour and conducted by Glocal Research and Consultancy. 3 Seeds of Bondage (2001): Female Child Bonded Labour in Hybrid Cottonseed Production in Andhra Pradesh. Report by Dr. Venkateshwarlu Davuluri for Business and Community Foundation and Plan International (India Chapter). 4 The Price of Childhood (2005): On the link between prices paid to farmers and the use of child labour in cotton seed production in Andra Pradesh, India. A report commissioned by Indian Committee of Netherlands, International Labor Rights Fund and EINE WELT Netz NRW and conducted by Dr. Venkateshwarlu Davuluri and Lucia da Corta. 5 Recent Trends in Employment of Child Labour in Hybrid Cottonseed Production in India (2007): A

study jointly commissioned by Indian Committee of Netherlands (ICN), International Labor Rights Fund (ILRF) and EINE WELT Netz NRW (EWN NRW), OECD Watch, Deutsche WelthHunderHilife (DWHH) and conducted by Dr. Venkateshwarlu Davuluri. 6 Child Labour and the Cotton Seeds Plantations in India (April, 2004): A report prepared for the Fair Labor Association and conducted by Martine Combemale. 7 Child Labour and the Cotton Seeds Plantations in India (October, 2004): A report prepared for the Fair Labor Association and conducted by Martine Combemale. 8 Dialogue Meeting initiated by Syngenta International “Contribution to Child Labour Eradication (2005): A report by B. Ferdman Guerrier, L. Fabry Lorenzini and P. Winiger. 9 Fair Labor Association Task and Risk Mapping Study of the Hybrid Vegetable Seed Sector (2007). 10 Syngenta Seed Production Practices (Code of Conduct). 11 Fair Labor Association Monitoring Guidance and Compliance Benchmarks: Agriculture Sector. 12 Fair Labor Association – Syngenta Consultation on Child Labor Monitoring (2007): Summary Report. 13 Syngenta’s Compliance Incentive Scheme for Growers 14 Fair Labor Association – Syngenta Consultation on Social Monitoring of the Agriculture Sector in India (2006): Summary Report. 15 Fair Labor Association Farm Audit Instrument (2008)

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16 Fair Labor Association Internal Monitoring System Audit Instrument (2008) 17 Fair Labor Association Agriculture Audit and Tracking Instrument (AATI) (2008) 18 Corrective action plans (2008) 19 Fair Labor Association – Syngenta Consultation on Labor Monitoring of the Agriculture Sector in India (2008): Summary Report.

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Syngenta ProjectReport 2007-2008 - Fair Labor … 1 FLA SYNGENTA PROJECT REPORT 2007 ... III. KEY EVENTS ... Basel. It ranks third in