Human Rights Impact Assessment: Senegal

Across our value chain, we take a systematic approach following the United Nations Guiding Principles on Business and Human Rights to implement Human Rights Due Diligence (HRDD) that identifies, prevents, and addresses potential adverse impacts. Human Rights Impact Assessments (HRIAs) play an important role in this approach. Through HRIAs, we deepen our understanding of risks in high-risk contexts, engage directly with rights-holders, and assess how effectively our actions work in practice. Since 2018, we have conducted HRIAs in the highest-risk countries, using the findings to strengthen our policies, processes, and partnerships over time.

In 2025, we partnered with our external human rights advisor, Article One, to conduct an HRIA in Senegal and assess actual and potential human rights impacts across our own operations and downstream value chain, including logistics and sales activities. The assessment aimed to surface salient human rights risks, evaluate the effectiveness of existing management measures, and inform a practical corrective action plan to strengthen protections for workers and other rightsholders.

The operating context in Senegal

PMI Operations in Senegal commenced in 2003, followed by the establishment of our manufacturing facility in Pikine, Dakar in 2005. Today, the market employs more than 400 people and is supported by a broad supplier network of over 450 partners. From Senegal, Operations provide services to more than 20 countries across West and Central Africa where PMI products are distributed.

Senegal’s strategic regional footprint, combined with a “medium” PMI Operations human rights risk classification, were key factors in selecting the country for an in-depth, country-level HRIA. The market also presented an opportunity to expand the geographic scope of our HRIAs into Sub-Saharan Africa and to apply an end-to-end perspective across operations and downstream activities, including logistics and sales. This approach was particularly relevant considering elevated regional risks associated with downstream practices and the prevention of underage people having access to tobacco and nicotine-containing products, underscoring the importance of the HRIA in understanding how these risks materialize in practice.

Assessment methodology

The HRIA was carried out between July and November 2025 and followed PMI’s established country-level assessment approach, strengthened through insights gained from assessments conducted across over 10 markets since 2018. Article One combined desk research with virtual engagement with our internal leadership and external human rights experts to establish a robust understanding of the local context in Senegal. They then carried out an in-country visit involving facility walkthroughs and focus group discussions with 118 rightsholders across the factory, headquarters, logistics, and sales functions.

Engagements were designed to support safe, meaningful participation, using confidentiality safeguards, informed consent, multilingual facilitation, and dedicated sessions for women and trade union members. Workers across functions demonstrated a strong willingness to engage openly, reflecting trust in the process.

Outcome

Through this assessment, Article One identified several areas where existing practices are already contributing positively to workers’ wellbeing and overall workplace culture. A strong safety and compliance environment was evident, with stakeholders demonstrating high awareness of health and safety procedures and consistent use of personal protective equipment, supported by clear signage and well-understood incident response processes. Employees also reported that PMI’s benefits package—including paid maternity leave, and medical coverage that exceeds legal requirements—plays an important role in their wellbeing. The assessment further found strong gender representation in management, with female employees noting equal pay for equal work, meaningful involvement in decision making, and supportive parental and flexible working policies. Across functions, workers described PMI as a fair and professional employer, and many third-party workers expressed aspirations for direct employment, reflecting PMI Senegal’s positive reputation in the local labor market.

The assessment also identified several potential risks, particularly in outsourced and downstream activities. In response, local management in Senegal reviewed the findings and developed a comprehensive, cross‑functional action plan to address key focus areas over the next two years.

Working hours

The assessment highlighted where improvements could be made in terms of working hours and workloads across the factory, headquarters, logistics, and sales teams to improve quality of work and workers’ work/life balance. In response, PMI Senegal is transitioning to an eight‑hour work pattern through the introduction of a fourth crew, alongside a review of shift structures and workload planning.

The market will also enhance communication on available wellbeing facilities, including a new gym, prayer room, improved mothers’ space, and mental health services. In addition, employee focus groups will be held to better understand the drivers of work–life imbalance and to identify further opportunities for improvement.

Wages and cost-of-living pressures

Rising living costs in Dakar emerged as a key concern, with workers reporting that inflation outpaces their day-to-day expenses despite wages meeting basic needs. In response, PMI Senegal reviewed its compensation framework and is reinforcing expectations with vendors under PMI’s living wage commitments, helping ensure that remuneration continues to support an adequate and dignified standard of living.

Equal opportunities for third-party workers

The assessment found that third-party workers often experience differentiated working conditions—particularly in relation to pay, benefits, and access to development opportunities—when compared to PMI employees. While this is not unusual, PMI Senegal is strengthening expectations for vendors and improving communication to teams on career development pathways and the performance calibration process, with the aim of reducing perception of insecurity and promoting greater fairness across employment arrangements.

Looking ahead, PMI Senegal will continue striving to enhance working conditions for third-party workers through clear contractual expectations and proactive engagement with service providers, while upholding legal requirements that prevent direct supervision or the creation of a subordination relationship. This approach enables us to foster responsible practices and fairness across our value chain while navigating applicable legal and operational frameworks.¹

Downstream employment insecurity and precarious work

Sales and distribution workers, many of whom operate as outsourced or independent microentrepreneurs, face income volatility, occasional payment delays, limited contractual protections, and elevated personal safety risks. PMI Senegal resolved the identified payment delays immediately and is working with partners to improve payment transparency, clarify roles and expectations, strengthen safety measures, and expand training aligned with the market’s training matrix. Opportunities to make personal protective equipment more accessible, including through preferential supplier pricing, are also being explored to reduce vulnerabilities for workers operating in less formal arrangements.

Access to grievance mechanisms

Awareness and accessibility of grievance channels varied across the value chain, particularly for third-party workers. To address this, PMI Senegal is enhancing communication on available mechanisms—using local languages where appropriate—and expanding outreach across outsourced and downstream functions to ensure all workers can raise concerns safely and confidently.

Looking ahead

The 2025 HRIA marks an important step in our efforts to identify, prevent, and mitigate human rights risks in Senegal. By pairing a candid assessment of challenges with a targeted corrective action plan, we aim to strengthen protections for workers, enhance accountability across the value chain, and contribute to improved labor standards in Senegal. Implementation of the corrective action plan will be overseen at the market level, with progress tracked and reported through PMI’s established HRDD governance structures.

We will continue to monitor developments, engage with stakeholders, and integrate lessons learned into our broader HRDD program, reinforcing our commitment to responsible business conduct in complex operating environments.

¹ While we remain committed to working to improve working conditions for third party workers through our partners, we cannot ensure that third-party workers receive the same employment conditions as PMI employees, as PMI is not their employer.