Our policies

Child Labour Policy

1. Introduction

Child labour remains a persistent global issue, particularly in the agricultural sector. According to the International Labour Organization (ILO), approximately 98 million children are engaged in agricultural work worldwide. Mkwawa Leaf Tobacco Limited (“MLTL”) acknowledges that this challenge may affect regions where we operate. As a responsible entity, MLTL is committed to eliminating child labour from its supply chain and promoting ethical, safe, and lawful labour practices across all levels of operation.

This policy outlines MLTL’s commitment to preventing child labour, the standards we uphold, and the actions we take to ensure compliance. It serves as a guiding document for all employees, contractors, growers, and business partners associated with MLTL.

2. Scope

This policy applies to:

  • All MLTL employees and directors

  • Contracted growers and suppliers

  • Joint ventures and partnerships

  • Any business entity in which MLTL has a controlling or participating interest

3. Child Labour Prevention Policy

Mkwawa Leaf Tobacco Ltd is committed to preventing and eliminating child labour across our operations and tobacco supply chain. We uphold applicable national laws and internationally recognized labour standards.

We align our practices with:

  • ILO Convention No. 138 - Concerning the Minimum Age for Admission to Employment

  • ILO Convention No. 182 - Concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour

We believe that child labour is neither acceptable nor necessary. Our goal is to ensure that all children are protected from exploitation and have access to education and a safe, healthy upbringing. We recognize that addressing child labour requires a comprehensive and collaborative approach involving education, awareness, enforcement, and community engagement.

Our Approach

Our approach focuses on prevention, awareness, monitoring and corrective action. Farmers and relevant stakeholders receive guidance on child labour requirements, while regular farm visits and compliance monitoring help identify and address potential risks. We maintain reporting and follow-up mechanisms for suspected cases and work with relevant stakeholders to ensure appropriate and timely resolution.

We strictly prohibit the involvement of children in hazardous work, including handling tobacco or crop protection chemicals, operating machinery, using sharp tools, working at heights, carrying unsafe loads, and work that interferes with education, health or wellbeing. Through education, stakeholder engagement and continuous improvement.

Mkwawa Leaf Tobacco is committed to protecting children’s rights and supporting responsible and sustainable communities.

4. Implementation Strategy

To achieve our objectives, MLTL has developed a multi-faceted strategy that includes the following key components:

  • Training and Capacity Building: We provide regular training to MLTL staff, business stakeholders and contracted growers on child labour laws, ethical labour practices, and the identification of child labour risks.

  • Awareness Campaigns: We conduct awareness campaigns using various media, including posters, brochures, radio programs, and digital platforms, to educate communities and stakeholders about the dangers and illegality of child labour.

  • Stakeholder Engagement: We collaborate with non-governmental organizations (NGOs), community leaders, worker associations, customers, and government agencies to address the root causes of child labour and promote sustainable solutions.

  • Monitoring and Compliance: Our trained field staff conduct regular farm visits to monitor compliance with child labour standards. Any suspected or confirmed cases are documented, investigated, and addressed promptly.

  • Incident Reporting and Resolution: We maintain a transparent and confidential reporting system for child labour incidents. All reports are investigated thoroughly, and appropriate corrective actions are taken.

  • Third-Party Audits: We engage and support independent third-party organizations to conduct periodic audits and assessments of our operations to ensure compliance and identify areas for improvement.

  • Continuous Improvement: We use data from internal monitoring and external assessments to refine our policies, training programs, and operational procedures.

5. Definitions

To ensure clarity and consistency, MLTL defines the following terms as follows:

  • Child Labour: Any work performed by individuals under the age of 14 as defined by the country’s laws, and who have not completed compulsory schooling. For light work on family farms, this includes children under the age of 12. For hazardous work, it includes any individual under the age of 18.

  • Hazardous Work: Work that is likely to harm the health, safety, or morals of children, or interfere with their education. This includes tasks that are physically, mentally, or emotionally demanding or dangerous.

6. Prohibited Hazardous Tasks

MLTL prohibits individuals under the age of 18 from engaging in the following hazardous tasks:

  • Handling Green Tobacco: Activities such as harvesting, topping, or suckering that may expose individuals to green tobacco leaves and cause Green Tobacco Sickness.

  • Operating Machinery or Vehicles: Use of equipment with moving parts or vehicles, unless explicitly permitted by law under safe conditions.

  • Using Sharp Tools: Tasks involving machetes (pangas), knives, or other sharp implements used for planting, weeding, or cutting.

  • Handling Chemicals: Exposure to fertilizers, pesticides, or other crop protection agents.

  • Working at Heights: Tasks performed at elevations where a fall could result in injury.

  • Carrying Heavy Loads: Lifting or transporting loads that exceed safe weight limits based on the individual’s age and physical condition.

  • Working in Poor Lighting or After Dark: Tasks performed in environments with inadequate lighting that may pose safety risks.

  • Exposure to Extreme Temperatures: Working in very hot or cold conditions that may affect health.

  • Excessive Working Hours: Work schedules that interfere with rest, health, or education.

MLTL supports growers in identifying and avoiding these and other hazardous tasks for minors and provides guidance on safe alternatives.

7. Roles and Responsibilities

All MLTL leaders and employees are responsible for implementing and upholding this policy. They are expected to demonstrate visible leadership, ensure compliance, and foster a culture of accountability and ethical conduct.

The policy will be publicly disseminated and translated into local languages where necessary. It will also be integrated into operational procedures, supplier contracts, and training materials.

8. Implementation and Governance

This policy is administered by the ESG Committee, ensuring alignment with our core values and international standards. The committee will:

  • Monitor and report on performance indicators related to Child Labour.

  • Review and update the policy regularly to ensure it remains relevant and effective in addressing Child Labour challenges associated with our operations.

9. Conclusion

Mkwawa Leaf Tobacco Ltd is committed to creating a supply chain that is free from child labour. We recognize that this is a complex issue that requires long-term commitment, collaboration, and continuous improvement. Through education, monitoring, and partnership, we aim to protect children’s rights, support families, and contribute to the development of safe and sustainable communities.

We call upon all stakeholders, employees, growers, partners, and community members to join us in this important mission. Together, we can ensure that every child has the opportunity to grow, learn, and thrive in a safe and supportive environment.