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  • B1. Does the company have a system or process to identify, prevent, mitigate and account for how it addresses its impacts on children in its tobacco sourcing supply chains?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

  • B1.1. Is the company’s child labour due diligence process consistent with its size, the risk of severe child rights impacts, and the nature and context of its operations?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

  • B1.2 Is the company’s child labour due diligence process consistent with the UNGPs?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

      UNGPs OPERATIONAL PRINCIPLE 18

      In order to gauge human rights risks, business enterprises should identify and assess any actual or potential adverse human rights impacts with which they may be involved either through their own activities or as a result of their business relationships. This process should:

      a. Draw on internal and/or independent external human rights expertise;

      b. Involve meaningful consultation with potentially affected groups and other relevant stakeholders, as appropriate to the size of the business enterprise and the nature and context of the operation.

      UNGPs OPERATIONAL PRINCIPLE 19

      In order to prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes, and take appropriate action.

      a. Effective integration requires that:

      • i. Responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise;
      • ii. Internal decision-making, budget allocations and oversight processes enable effective responses to such impacts.

      b. Appropriate action will vary according to:

      • i. Whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products or services by a business relationship;
      • ii. The extent of its leverage in addressing the adverse impact.

      UNGPs OPERATIONAL PRINCIPLE 20

      In order to verify whether adverse human rights impacts are being addressed, business enterprises should track the effectiveness of their response. Tracking should:

      a. Be based on appropriate qualitative and quantitative indicators;

      b. Draw on feedback from both internal and external sources, including affected stakeholders.

      UNGPs OPERATIONAL PRINCIPLE 21

      In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:

      a. Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

      b. Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

      c. In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.

  • B1.3 Is the company’s child labour due diligence process, including tracking, involve instances of meaningful consultation with relevant stakeholders, as appropriate to the size of the company and the nature and context of its operation?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

      UNGPs OPERATIONAL PRINCIPLE 18

      In order to gauge human rights risks, business enterprises should identify and assess any actual or potential adverse human rights impacts with which they may be involved either through their own activities or as a result of their business relationships. This process should:

      a. Draw on internal and/or independent external human rights expertise;

      b. Involve meaningful consultation with potentially affected groups and other relevant stakeholders, as appropriate to the size of the business enterprise and the nature and context of the operation.

      UNGPs OPERATIONAL PRINCIPLE 20

      In order to verify whether adverse human rights impacts are being addressed, business enterprises should track the effectiveness of their response. Tracking should:

      a. Be based on appropriate qualitative and quantitative indicators;

      b. Draw on feedback from both internal and external sources, including affected stakeholders.

  • B1.4 Does the company’s child labour due diligence process cover both adverse impacts a) that the company may directly cause; and b) those which may indirectly arise through its business relationships?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

  • B1.5 Does the company have processes and actions in place to prevent child labour from materializing, or at least reduce, as far as possible, the extent to which it may do so?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

  • B1.6 In order to prevent and mitigate adverse impacts on children in its tobacco sourcing supply chains, does the company integrate findings from its impact assessments across relevant internal functions, including assigning the responsibility to the appropriate level and function, decision making, budget allocation and oversight?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 19

      In order to prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes, and take appropriate action.

      a. Effective integration requires that:

      • i. Responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise;
      • i. Internal decision-making, budget allocations and oversight processes enable effective responses to such impacts.

      b. Appropriate action will vary according to:

      • i. Whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products or services by a business relationship;
      • ii. The extent of its leverage in addressing the adverse impact.

  • B1.7 Does the company communicate publicly about how it addresses its impacts, including on children, in its tobacco sourcing supply chains?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 21

      In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:

      a. Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

      b. Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

      c. In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.

  • B1.8 Does the company have a system of tracking the effectiveness of its child labour programmes, including appropriate qualitative and quantitative indicators?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 20

      In order to verify whether adverse human rights impacts are being addressed, business enterprises should track the effectiveness of their response. Tracking should:

      a. Be based on appropriate qualitative and quantitative indicators;

      b. Draw on feedback from both internal and external sources, including affected stakeholders.

  • B1.9 Does the company have varying degrees of leverage in all markets and/or with specific suppliers?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 19

      In order to prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes, and take appropriate action.

      a. Effective integration requires that:

      • i. Responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise;
      • ii. Internal decision-making, budget allocations and oversight processes enable effective responses to such impacts.

      b. Appropriate action will vary according to:

      • i. Whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products or services by a business relationship;
      • ii. The extent of its leverage in addressing the adverse impact.

  • B1.10 Does the company’s business model with respect to tobacco sourcing allow it to use its leverage in addressing child labour at the bottom of its supply chain?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 19

      In order to prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes, and take appropriate action.

      a. Effective integration requires that:

      • i. Responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise;
      • ii. Internal decision-making, budget allocations and oversight processes enable effective responses to such impacts.

      b. Appropriate action will vary according to:

      • i. Whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products or services by a business relationship;
      • ii. The extent of its leverage in addressing the adverse impact.

  • B1.11 How does the company work to increase its leverage in specific markets where direct contracts may not be possible due to legislation or the market structure?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 19

      In order to prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes, and take appropriate action.

      a. Effective integration requires that:

      • i. Responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise;
      • ii. Internal decision-making, budget allocations and oversight processes enable effective responses to such impacts.

      b. Appropriate action will vary according to:

      • i. Whether the business enterprise causes or contributes to an adverse impact, or whether it is involved solely because the impact is directly linked to its operations, products or services by a business relationship;
      • ii. The extent of its leverage in addressing the adverse impact.

  • B1.12 Is the company’s child labour due diligence an ongoing process i.e. does it recognize that risks to children may change over time as the company’s operations and operating context also change?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 17

      In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

      a. Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

      b. Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

      c. Should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.

  • B1.13 Does the company’s child labour due diligence process draw on internal and/or independent external child rights expertise?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 18

      In order to gauge human rights risks, business enterprises should identify and assess any actual or potential adverse human rights impacts with which they may be involved either through their own activities or as a result of their business relationships. This process should:

      a. Draw on internal and/or independent external human rights expertise;

      b. Involve meaningful consultation with potentially affected groups and other relevant stakeholders, as appropriate to the size of the business enterprise and the nature and context of the operation.

  • B1.14 Is the company’s communication about the due diligence process accessible to its intended audiences and provide information that is sufficient to evaluate the adequacy of the company’s response to child labour?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 21

      In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:

      a. Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

      **b. Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

      c. In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.

  • B1.15 Does the company’s public communication on child labour protect the confidentiality of affected stakeholders, including children?

    • ECLT Member’s Pledge of Commitment

      ECLT FOUNDATION BOARD MEMBERS’ MINIMUM REQUIREMENTS (hereinafter the "requirements"):

      For buyers and manufacturers – to apply these requirements within their entire tobacco-sourcing supply chains, and consistent with the principles of “Protect, Respect, and Remedy Framework” pledge to:

      • Make the appropriate policy commitment to eliminate child labour;
      • Implement due diligence, consistent with the size and circumstances of the company, with the aim of identifying, preventing, mitigating and accounting for their adverse impacts on child labour in tobacco-sourcing supply chains;
      • Provide for/or cooperate in legitimate processes of remediation.

    • UN Guiding Principle

      UNGPs OPERATIONAL PRINCIPLE 21

      In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:

      a. Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

      b. Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

      **c. In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.