Across our value chain, we implement Human Rights Due Diligence (HRDD) to identify, prevent, and address adverse impacts. This is in line with the UN Guiding Principles on Business and Human Rights, with Human Rights Impact Assessments (HRIAs) playing a central role in this approach.1 Through HRIAs, we deepen our understanding of various impacts in high-risk contexts, engage directly with rightsholders, and assess effectiveness of our actions in practice.
By the end of 2025, we had fulfilled our commitment by conducting 11 HRIAs in some of the highest-risk countries since 2018, and we used the findings to strengthen our policies, processes, and partnerships over time. In line with this commitment, we conducted an HRIA in Türkiye in 2021—focused on the tobacco supply chain—and a follow-up in-depth assessment in 2024.
Understanding the operating context in Türkiye
Türkiye is a key sourcing country for Oriental tobacco and an important part of our global supply chain. Tobacco growing in Türkiye is characterized by seasonal work and complex labor arrangements. Combined, these factors can increase the risk of impacts on working conditions, Occupational Health and Safety (OHS), and child labor, highlighting the need for a structured approach to HRDD. Within this operating context, the HRIA provided an important foundation for this work by helping us ground our actions with evidence and a rightsholder perspective.
In 2021, PMI partnered with peer companies and six Turkish tobacco leaf suppliers to commission an industry-wide HRIA of the Turkish tobacco supply chain. Conducted by the business and human rights consultancy, twentyfifty, the assessment highlighted key areas of concern, including child labor, farmer livelihoods, working conditions, gender equality, and environmental impacts. While many good practices were already in place, the finding showed that some challenges were systematic and required active collaboration between industry and suppliers to be addressed. The 2021 HRIA laid the groundwork for more coordinated action. Read more about this 2021 assessment in this case study.
Assessing progress: The 2024 in-depth follow up assessment
Following the 2021 assessment, we worked with suppliers and peers to translate the findings into targeted action plans. In parallel, industry-wide working groups were established under the Aegean Tobacco Exporters’ Association (ATEA) to address shared priorities, particularly child labor, OHS, and working conditions.
In 2024, joined by the same stakeholders and a new alliance manufacturer member, KT&G, we engaged again with twentyfifty to conduct a follow-up in-depth assessment to evaluate progress since 2021 and identify where further efforts were needed. The scope of the assessment focused specifically on human rights impacts. Our main objectives were to reassess suppliers’ HRDD capacity and maturity, evaluate the effectiveness of measures implemented since 2021, and review progress achieved through industry collaboration.
Across 10 tobacco-growing regions, we carried out 439 consultations with farmers, workers, and other stakeholders providing us with valuable insights into the first-hand perspectives, changes happening on the ground, and persisting challenges.
Since 2021, the industry collaboration has clearly strengthened awareness of the key risks, and we began to see positive changes in the targeted areas. This includes the completion of a comprehensive study on children’s involvement in family farming to clarify hazardous and non-hazardous tasks, which was commissioned to a third-party consultant, EYKA. This was done alongside the publication, by the industry collaboration members, of an industry-wide Child Labor Policy Statement,3 reaffirming a shared commitment to responsible agricultural practices. Within the OHS area, our focus has been on building awareness and strengthening safe working practices, informed by targeted research and collaboration with academic partners. A major pillar of the research is the Green Tobacco Sickness (GTS) study, completed in the beginning of 2025 by Ege University, which is considered the most credible and scientifically grounded research on oriental tobacco growing. It enables us and our stakeholders to better understand the associated risks and barriers to effective protective equipment use.
Practical improvements on the ground have included a large-scale crop protection agent collection initiative, covering approximately 12,000 farmers across the Aegean region. We have also implemented several health awareness initiatives aimed at supporting women’s wellbeing in agriculture.
At the same time, this follow-up assessment confirmed that some risks persist and require continued, targeted attention.
Working conditions
The 2024 assessment identified ongoing challenges related to recruitment practices, including reliance on middlemen, daily wage labor, and seasonal migrant workers. In some cases, gaps in communication and limited awareness of labor rights continue to affect worker wellbeing. To support improvements, together with our suppliers, we continue to focus on strengthening engagement with farmers, workers, and communities. We are improving communication channels to ensure information reaches workers more directly, including through SMS and visual tools; delivering training on labor rights and fair treatment; and assessing migrant labor risks with legal consultants following the 2025 harvest.
Occupational health & safety
OHS remains a key area of focus. While progress has been made since the initial assessment, the 2024 HRIA confirmed the need for further attention to safe working practices. In response, we continue to work with suppliers to reinforce the use of personal protective equipment, safer handling and storage of crop protection agents, improved waste collection, and expectations on basic water, sanitation, and hygiene conditions.
Child Labor
Child labor risks continue to be identified, despite increased awareness efforts. These risks are influenced by broader socio-economic and cultural factors common in family-based agriculture. While awareness initiatives have supported greater understanding of child labor impacts, the assessment indicates that additional, targeted measures are needed to address these underlying dynamics. In response, we are planning to launch renewed communication tools and a second phase of remediation activities within the areas of alternative income generation, community awareness and youth empowerment during 2026.
Embedding learning into future action
Beyond specific focus areas, the 2024 in-depth assessment reinforced several cross-cutting priorities for our work in Türkiye going forward. These include strengthening grievance mechanisms through continued awareness-building, improving how we measure long-term impact, and using industry platforms to share tools, training, and best practices more systematically.
Our monitoring and verification data show that most concerns are not present in PMI’s tobacco sources specifically; however, this assessment reveals the importance of ongoing careful oversight due to persistent structural and systemic challenges. Accordingly, proactive collaboration with rightsholders, suppliers and industry peers will be central to translating these priorities into lasting impact, a more responsible tobacco supply chain.
Stories of Impact
Assessing human rights impacts in the tobacco supply chain in Turkey
We took a collaborative approach in 2021 by engaging in a multistakeholder tobacco leaf supply chain assessment in Turkey.
Human rights impact assessment: Indonesia
Our commitment to human rights is important for addressing potential issues within our supply chain.
Human Rights Impact Assessment: Kazakhstan
PMI is committed to respecting human rights within our organization and across our value chain.