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The success of this measure largely depends on the farmers willingness to use PPE.[394] Regarding expectations for and monitoring of its suppliers, BAT relies on a program called the Social Responsibility in Tobacco Production (SRTP) program, adopted by a number of tobacco manufacturers (see Imperial Tobacco Group, below), which sets minimum performance levels for contracted leaf growers on agricultural practices as well as labor, child labor, occupational health, and other issues.[395] Concerning child labor, since 2012 the SRTP program has included the statement: formal reference is given to the treatment of child labour in the context of ILO conventions 138 and 182.[396] BAT requires all of its suppliers, including in the US, to act in accordance with the SRTP program and educate farmers and workers on the program and monitor progress.[397] Under the program, suppliers carry out self-assessments and a monitoring group conducts assessments of suppliers reports.[398] BAT states that the 2013 SRTP child labor score for the companys US suppliers was 98 percent.[399] Imperial Tobacco Group According to its website, the UK-based Imperial Tobacco Group operates in more than 160 countries worldwide and manufactures cigarette brands that are among the most popular in the world, including Davidoff and Gauloises .[400] The company also states it is the global leader in fine cut tobacco and papers and has exclusive rights to sell all luxury Cuban cigars.[401] Imperial Tobacco Groups 2013 annual report recorded a 5.8 percent global market share.[402] Imperial Tobacco Group does not have a separate child labor policy but stated in a January 2014 letter to Human Rights Watch that the company and its subsidiaries do not employ children and that it works with suppliers to encourage their compliance with international standards on child labor. This includes: freedom for children from any work that subjects a child to economic exploitation, is hazardous, interferes with the childs education, or is harmful to a childs health or physical, mental or social development.[403] It is not clear from the information available to Human Rights Watch how Imperial Tobacco Group applies these definitions to actual working conditions in its supply chain, including which types of work Imperial Tobacco Group considers harmful or hazardous

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