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3.4.1(a) The Managing Entity has a system in place to accurately collect and maintain the following information on CmiA-contracted farmers and farmer groups: • Name • Location • Gender • Age • Area under cotton cultivation • Inputs provided (type and amount) [this includes records of chemicals used] • (Input) pre-finance amount and repayment • Seed cotton at market • Training participation The data are updated annually. PRINCIPLE 9: CmiA Managing Entities minimise the adverse effects of crop-protection practices. Adoption of integrated production and pest management (IPPM), including and emphasising pest control techniques other than pesticide application, thereby leading to a reduction in the quantity of pesticide used. CRITERION 9.2 The Managing Entity only uses pesticides that are: (1) nationally registered and approved for use in cotton cultivation; and (2) labelled according to national standards in at least one of the national languages or an applicable official regional language.

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CRITERION 3.4 The Managing Entity operates a datamanagement system. PRINCIPLE 9: CmiA Managing Entities minimise the adverse effects of crop-protection practices.

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9.3.1 The Managing Entity only purchases, distributes, and uses pesticides that are not banned from use for the cultivation of CmiA cotton. Substances falling under the following categories are banned under CmiA: • Stockholm Convention, Annexes A and B • Rotterdam Convention, Annex III • Montreal Protocol, Annexes • Active ingredients categorised as WHO Class Ia (extremely hazardous) or Class Ib (highly hazardous), respectively listed in categories 1 and 2 of GHS For organic production, the regulations relevant for the obtained organic certificate apply.

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CRITERION 9.3

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CRITERION 8.3 Given the very low fertiliser application rates across sub-Saharan Africa, CmiA does not generally limit the amount of fertiliser used. Instead, the focus is on reconciling the Managing Entity’s policies on fertiliser utilisation with regional soil conditions, national scientific recommendations, and economic thresholds. This also includes training in the use of locally available, natural fertilisers such as compost or manure. Since shallow or highly weathered soils and ineffective or absent soil conservation techniques are major risk factors for net losses of nitrogen, techniques to maintain and improve soil structures contribute greatly to improved nitrogen fixation.

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CRITERION 8.3

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9.9.1 Dedicated (organic) pesticide storage areas of the Managing Entity must fully comply with relevant legislation. 9.9.2 Central (organic) pesticides storage facilities have: a sound roof and impermeable floors; shelves with non-absorbent and fire-resistant material; a system to retain spillage; clear, permanent warning signs close to access doors; visible safety warnings, explanations of pictograms, symptoms of intoxication, and first-aid information for each product stored; a visible emergency procedure; and an eye-washing area.

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CRITERION 9.9

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CRITERION 9.1 The Managing Entity adopts an integrated production and pest management (IPPM) plan. Based on the results of the monitoring, it is decided whether and when to use which pest management inputs. Sustainable biological, physical, and other non-chemical methods must be given priority over chemical methods if they provide satisfactory pest control. Pesticides should only be applied as a last resort when there are no adequate non-chemical alternatives and the use of pesticides is economically justified. The pesticides applied shall be as specific as possible to the target and shall have the least side effects on human health, non-target organisms, and the environment, and their use should be kept at minimum levels, e.g. through partial applications

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9.7.1 The Managing Entity regularly trains CmiA-contracted farmers in: (a) the proper preparation of spray formulations for effective use; (b) safe spraying techniques; (c) maintaining appropriate equipment for (organic) pesticide application; and (d) considering weather conditions when scheduling spraying.

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CRITERION 9.7

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9.1.3 The Managing Entity trains CmiA-contracted farmers in threshold spraying and in scouting for key pest and beneficiary insects.

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CRITERION 9.1

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9.1.1 The Managing Entity has established a locally adapted and time-bound integrated production and pest management (IPPM) plan that identifies the appropriate specific practices for implementing the five IPPM components: (1) Growing healthy crops (2) Preventing the build-up of pest populations and the spread of disease (3) Preserving and enhancing populations of beneficial insects (4) Conducting regular field observations of crop health and of key pest and beneficial insects (5) Managing resistance 9.1.3 The Managing Entity trains CmiA-contracted farmers in threshold spraying and in scouting for key pest and beneficiary insects.

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CRITERION 9.1

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CRITERION 9.1 Pesticides should only be applied as a last resort when there are no adequate non-chemical alternatives and the use of pesticides is economically justified. 9.1.3 The Managing Entity trains CmiA-contracted farmers in threshold spraying and in scouting for key pest and beneficiary insects. 9.1.4 The Managing Entity actively discourages CmiA-contracted farmers from calendar or random spraying.

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CRITERION 9.1

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7.2.1 An up-to-date overview map of the production areas and the location of the ginneries is available. The Managing Entity collaborates with national environmental authorities to identify and map out protected areas and areas with a high conservation value (HCV) within cotton-growing areas cultivated by contracted farmers. Such areas include: • Primary forest and other intact forest landscapes • Important bird areas (IBA) • UNESCO world heritage sites • Strict nature reserves (IUC Ia) • Wilderness areas (IUC Ib) • National parks (IUC II) • Natural monuments or features (IUC III) • Habitat/Species management areas (IUC IV) • Wetlands (Ramsar Convention) • Rivers and riparian buffer areas 7.2.3 In the event of any conversion from non-agricultural land to agricultural land, the Managing Entity ensures that CmiA-contracted farmers: • have the right to use the land (ideally holding land tenure); • maintain a ten-metre buffer zone of perennial vegetation with open water (river, stream, ditch, canal, pond, or lake); • ensure that no cotton is cultivated in the locally mandated buffer zone for officially designated protected areas; and • ensure that no cotton is cultivated in the locally mandated buffer zone for intact forest landscapes.

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CRITERION 7.2

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"Cutting of primary forest or destruction of other forms of national resources which are designated andprotected by national law or international legislation (currently valid) in order to cultivate cotton"

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Criteria Matrix, Version 3, 1.1.2014, Exclusion Criteria No 7

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7.2.1 An up-to-date overview map of the production areas and the location of the ginneries is available. The Managing Entity collaborates with national environmental authorities to identify and map out protected areas and areas with a high conservation value (HCV) within cotton-growing areas cultivated by contracted farmers. Such areas include: • Primary forest and other intact forest landscapes • Important bird areas (IBA) • UNESCO world heritage sites • Strict nature reserves (IUC Ia) • Wilderness areas (IUC Ib) • National parks (IUC II) • Natural monuments or features (IUC III) • Habitat/Species management areas (IUC IV) • Wetlands (Ramsar Convention) • Rivers and riparian buffer areas

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CRITERION 7.2

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There is no specific requirement in the Verification of CmiA Criteria Matrix 2012 that addresses this issue.

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7.2.1 An up-to-date overview map of the production areas and the location of the ginneries is available. The Managing Entity collaborates with national environmental authorities to identify and map out protected areas and areas with a high conservation value (HCV) within cotton-growing areas cultivated by contracted farmers. Such areas include: • Primary forest and other intact forest landscapes • Important bird areas (IBA) • UNESCO world heritage sites • Strict nature reserves (IUC Ia) • Wilderness areas (IUC Ib) • National parks (IUC II) • Natural monuments or features (IUC III) • Habitat/Species management areas (IUC IV) • Wetlands (Ramsar Convention) • Rivers and riparian buffer areas

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CRITERION 7.2

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8.1.1 The Managing Entity must provide GMO-free cotton seeds. In countries where national legislation allows the cultivation of genetically modified cotton, the Managing Entity can guarantee that CmiA-contracted farmers do not receive any GMO seeds and that clear segregation between GMO and non-GMO cotton is maintained, e.g. in the case of toll ginning.

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CRITERION 8.1

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7.5.3 The use of fire for preparing land, replanting, or destroying crop residues is avoided, except in situations where national law requires otherwise.

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CRITERION 7.5

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CmiA does not allow for artifical irrigation, therefore this criterion is automatically covered

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8.2.3 The Managing Entity regularly trains CmiA-contracted farmers to consider risks to water quality when managing and applying (organic) pesticides and nutrients (cf. criteria 9.8 and 8.3). 8.2.4 The percentage of CmiA-contracted farmers taking risks to water quality into account when managing and applying (organic) pesticides and nutrients. CRITERION 9.8 The Managing Entity ensures that CmiAcontracted farmers apply pesticides without contaminating bodies of water. 9.8.1 The Managing Entity regularly trains CmiA-contracted farmers in: (a) preventing water contamination when using (organic) pesticides; and (b) maintaining buffer zones around seasonal and permanent bodies of water. 9.8.2 The percentage of CmiA-contracted farmers who apply (organic) pesticides in a way that minimises the risk of negatively influencing water quality (cf. criterion 8.2).

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CRITERION 8.2 CRITERION 9.8

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CmiA smallholder cotton is exclusively cultivated as rain-fed cultivation and is not cultivated using irrigation. In case potential participants with smallholder cotton cultivation under irrigation apply to become member of CmiA, the Aid by Trade Foundation, together with its stakeholders, will develop appropriate technical and social exclusion and sustainability criteria prior to accepting these potential participants.

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There is no specific requirement in the Verification of CmiA Criteria Matrix 2012 that addresses this issue.

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There is no specific requirement in the Verification of CmiA Criteria Matrix 2012 that addresses this issue.

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9.8.1 The Managing Entity regularly trains CmiA-contracted farmers in: (a) preventing water contamination when using (organic) pesticides; and (b) maintaining buffer zones around seasonal and permanent bodies of water. 9.8.2 The percentage of CmiA-contracted farmers who apply (organic) pesticides in a way that minimises the risk of negatively influencing water quality (cf. criterion

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CRITERION 9.8 The Managing Entity ensures that CmiAcontracted farmers apply pesticides without contaminating bodies of water.

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The Managing Entity collects and separates waste from the ginnery according to local requirements. Waste must be properly disposed of in municipal garbage collection systems where available. 7.1.5The Managing Entity has a waste management plan that includes strategies in waste reduction, recycling, reuse, and disposal alternatives. The Managing Entity identifies the main types of waste, ways to reduce and reuse waste materials if applicable, and how to dispose of them in the best available way. The Managing Entity develops measures for waste reduction and documents their implementation and impact.

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CRITERION 7.1

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CRITERION 7.1 The Managing Entity responsibly manages and reduces its environmental impact. Intent The Managing Entity has identified the main negative environmental impacts at both the field and ginnery levels and implements measures to mitigate them. This includes but is not limited to noise, dust, water use, wastewater, waste, and energy consumption, as applicable. 7.1.5 The Managing Entity has a waste management plan that includes strategies in waste reduction, recycling, reuse, and disposal alternatives. The Managing Entity identifies the main types of waste, ways to reduce and reuse waste materials if applicable, and how to dispose of them in the best available way. The Managing Entity develops measures for waste reduction and documents their implementation and impact.

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CRITERION 7.1

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7.1.4(a) The environmental management plan incorporates a monitoring protocol to track the effectiveness of the mitigation measures through a set of indicators (e.g. waste or fuel consumption). 7.1.4(b) The environmental management plan for the ginnery incorporates a monitoring protocol to track the effectiveness of the mitigation measures through a set of indicators (e.g. waste or energy consumption). 7.1.5 The Managing Entity has a waste management plan that includes strategies in waste reduction, recycling, reuse, and disposal alternatives. The Managing Entity identifies the main types of waste, ways to reduce and reuse waste materials if applicable, and how to dispose of them in the best available way. The Managing Entity develops measures for waste reduction and documents their implementation and impact. CRITERION 9.11 The Managing Entity ensures that CmiAcontracted farmers dispose of empty pesticide containers safely.

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CRITERION 7.1 CRITERION 9.11

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7.5.3 The use of fire for preparing land, replanting, or destroying crop residues is avoided, except in situations where national law requires otherwise.

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CmiA vol.3.1 - Farm Level Criteria No. 4d

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"Green: The Managing Entity demonstrates that the gins which carry out CmiA cottonginning have developed and implemented appropriatemeasures andpractices, which enable the gin to identify the main environmental impacts ofthe operation. The gin operation has activities planned to remediateundesireable environmental impacts incl. potentialinvestment requirements.Legal requirements and requirements embedded in theoperating licence areobserved and adhered to."

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Criteria Matrix, Version 3, 1.1.2014, CmiA Ginnery Criteria 6 Sustainability Criteria

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7.1.2(b) The Managing Entity conducts regular environmental risk assessments at the ginnery level. The assessment forms the basis for an environmental management plan, which defines measures to eliminate or mitigate the risks and impacts. The environmental assessment includes but is not limited to: • Air emissions • Waste • Hazardous substances • Fuel and energy use • Noise • Land use The environmental management plan is maintained and reviewed when necessary, least every two years. 7.1.6 The Managing Entity applies appropriate emissions-control techniques for operations that generate air pollutants. Control techniques include ventilation, absorption, scrubbing, and noise and vibration reduction. The Managing Entity measures the emission reduction achieved through control techniques.

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CRITERION 7.1

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7.1.2(b) The Managing Entity conducts regular environmental risk assessments at the ginnery level. The assessment forms the basis for an environmental management plan, which defines measures to eliminate or mitigate the risks and impacts. The environmental assessment includes but is not limited to: • Air emissions • Waste • Hazardous substances • Fuel and energy use • Noise • Land use The environmental management plan is maintained and reviewed when necessary, least every two years. 7.1.7 The Managing Entity measures and monitors the energy consumption in its ginneries and develops a plan for energy reduction and recovery. Where appropriate, climate-smart energy sources are used. A system to measure achievements is in place (cf. indicator 7.1.4(b)).

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CRITERION 7.1

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Excl.Crit.8: "Non-submission of input and production data in annual self-assessments as prescribed by AbTF."

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"CmiA Exclusion Criterion 8, Self-Assessment Template (sheet on Inputs provided);Document Request List"

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8.3.5 CmiA-contracted farmers receive regular training in techniques for soil conservation, such as: • Soil regeneration through crop diversity or crop rotation with leguminous crops • Prevention of erosion • The effective use of fertilisers • The monitoring of soil structure, soil fertility, and nutrient status • Tillage methods for reducing negative effects on soil structure/compaction • The use of cover crops / intercropping • The use of organic matter / animal manure • The application of residue management / mulching

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CRITERION 8.3

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"3a (green): ""Furthermore, training is conducted regularly and more than 50% of farmers apply one or more methods of soil and water conservation (e.g. conservation farming, production of compost, etc.).Training content needs to address the most promising agricultural practices showing quick wins and are easy to apply. Thus the farmers have a direct positive impact.""3b (green): ""There is sufficient evidence that crop rotation includes stand-alone plantings for legumes or intercropping with legumes.The Managing Entity can provide sufficient evidence that crop rotation is a common practice and sustainably applied."""

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Criteria Matrix, Version 3, 1.1.2014, CmiA Farm Level Criteria: 3a (Soil and water conservation), 3b (Crop rotation)

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8.3.6 The percentage of CmiA-contracted farmers using crop rotation (i.e. the practice of alternating the crops grown in a specific field in a regular sequence). Cotton is not grown in the same field several years in a row. 8.3.7 The percentage of CmiA-contracted farmers who include a leguminous crop in their crop rotation or who let the field in question lie fallow for one year.

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CRITERION 8.3

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5.5.1 Employees and workers can freely establish and join workers’ organisations, both internal (such as workers’ representation) and external (such as trade unions) and take part in collective bargaining on working conditions. The Managing Entity: • respects the right of all employees and workers to form or join workers’ organisations; • respects the rights of workers’ organisations to draw up their own constitutions and rules, elect representatives, organise activities, and formulate programmes in full freedom; • respects the rights of workers’ organisation to bargain collectively in practice; • accepts that it has the duty to bargain in good faith with workers’ organisations; and • provides workers’ organisations with the information needed for meaningful negotiation in a timely manner.

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CRITERION 5.5

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5.5.6 In countries where a collective bargaining agreement (CBA) is in place for the sector, the Managing Entity signs and adheres to this agreement. Collective bargaining at the company level may take place even if a sector-wide collective agreement exists; however, the company-level agreements may not provide lesser terms and conditions than the sector-wide agreements.

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CRITERION 5.5

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5.1.1(a) No forced, bonded, trafficked, or otherwise involuntary labour, including involuntary prison labour, is used or tolerated at the field level. 5.1.1(b) No forced, bonded, trafficked, or otherwise involuntary labour, including involuntary prison labour, is used or tolerated at the ginnery level.

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CRITERION 5.1

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6.1.1 The Managing Entity has a time-bound plan for the prevention of child labour at the field level in accordance with ILO conventions 138 and 182 and applicable national laws. 6.1.2(a) The Managing Entity establishes and implements a child labour policy that includes a clear statement against child labour. The policy also specifies under which circumstances and for which tasks children of CmiA-contracted farmers are allowed to help on the family farm. This policy is communicated to all CmiA-contracted farmers. 6.1.2(b) The Managing Entity establishes and implements a child labour policy that includes a clear statement against child labour. This policy is communicated to all employees and workers. It is also communicated to sub-contractors as a mandatory contractual component. The Managing Entity’s subcontractors must comply with the policy. 6.1.4 CmiA-contracted farmers do not employ children below the age of 15 (14 in certain specified countries) or under the age defined by local law, whichever is higher. 6.1.6 The Managing Entity does not employ workers directly or indirectly (through sub-contracting) below the age of 15 (14 in certain specified countries) or below the minimum age for employment defined by local law, whichever is higher. Robust age-verification mechanisms are part of the recruitment process to ensure compliance with the minimum age.

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CRITERION 6.1

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6.1.1 The Managing Entity has a time-bound plan for the prevention of child labour at the field level in accordance with ILO conventions 138 and 182 and applicable national laws.

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CRITERION 6.1

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5.9.4 The Managing Entity offers equal pay for equal work to all employees and workers— whether permanent, temporary, or migrant—without discrimination based on gender or any other factor. This includes equivalent benefits and employment conditions for equal work.

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CRITERION 5.9

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5.2.1 The Managing Entity does not tolerate any form of discrimination. This includes benefits or discrimination in terms of contracting, promotion, remuneration, training, or other activities on any basis, including gender, age, religion, race, colour, caste, ethnicity, nationality, social background, disability, political opinion, sexual orientation, family responsibilities, pregnancy, childbirth, marital status, disease, and membership in farmers’ unions or farmers’ representative bodies.

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CRITERION 5.2

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CRITERION 5.3 The Managing Entity ensures a respectful working environment without harassment or corporal punishment and with transparent disciplinary measures. 5.3.1(a) The Managing Entity does not directly or indirectly engage in, support, or tolerate the use of corporal punishment, sexual harassment, mental or physical coercion, or any other kind of verbal or physical abuse or harassment at the field level. 5.3.1(b) The Managing Entity does not directly or indirectly engage in, support, or tolerate the use of corporal punishment, sexual harassment, mental or physical coercion, or any other kind of verbal or physical abuse or harassment at the ginnery level.

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CRITERION 5.3

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CRITERION 5.12 The Managing Entity provides a safe and healthy workplace Managing Entities respect the right of workers to healthy working conditions and must comply with national occupational health and safety regulations or, if domestic legislation is weak or poorly enforced, with international standards. Staff need to be provided with the information and training they need to perform their work safely and without risk to their health. This way, staff can gain their own understanding of the extent of the hazards and associated risks and will more easily adopt the measures necessary to manage and reduce these risks. It is the Managing Entity’s responsibility to prevent accidents and injuries by minimising, as far as reasonably practicable, risks inherent in the working environment through appropriate measures and adequate control. The buildings, workplaces, machinery, equipment, and processes under the Managing Entity’s control shall be safe and pose no risk to staff health. Where necessary, the Managing Entity shall provide adequate clothing and protective equipment. Workers and workers’ representatives shall be given appropriate training in occupational safety and health.

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5.12.5 The Managing Entity ensures that all employees and workers are trained in the basic requirements of occupational health and safety and relevant health protection immediately before starting any new job. Employees and workers that are engaged in potentially hazardous work are trained according to the tasks they carry out at least once a year. The training includes the proper use of personal protective equipment (PPE). All employees and workers are made aware of their right to remove themselves from unsafe situations without seeking permission or being penalised for doing so. Regular refresher training takes place at least once a year. The Managing Entity keeps records of the training activities, indicating training topics, time, duration, and the names of attendees and trainers.

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CRITERION 5.12

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CRITERION 5.15 The Managing Entity provides all employees and workers with clean drinking water, sanitation facilities, changing rooms, and areas for rest and food consumption. 5.15.1 All employees and workers have access to drinking water in sufficient quantity and close to the working area. The rest or food-consumption area has clearly labelled drinking-water facilities. The water quality is monitored, and monitoring results are documented.

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5.15.3 All employees and workers have access to adequate rest areas, food-consumption areas, canteens, and/or food-storage facilities. Rest and eating areas are clean, well maintained, and, as much as possible, free of pests. There are hand-washing facilities close to the food-consumption areas.

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5.15.2 All employees and workers have access to clean toilets with hand-washing facilities and changing rooms. Lockable storage facilities are provided for staff. Toilets and changing rooms are separate for women and men, and the number of toilets and hand-washing facilities are in proportion to the number of employees and workers. All facilities are well maintained and cleaned regularly.

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CRITERION 5.15

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1.1.4 The Managing Entity has a written anti-corruption policy, which is documented and communicated to all levels of the workforce and operations. 1.1.5 The Managing Entity is not involved in any act of corruption, extortion, or embezzlement nor in any form of bribery, including but not limited to the promising, offering, giving, or accepting of any improper monetary or non-monetary incentive.

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CRITERION 1.1