Management response to the evaluation of Evaluation of “Sumangali: Eradication of Extremely Exploitative Working Conditions in Southern India’s Textile Industry” (2019) Introduction - Context, background and findings “Sumangali – Eradication of Extremely Exploitative Working Conditions in Southern India’s Textile Industry” is a project supported by the German Ministry of Economic Cooperation and Development (BMZ) and C&A Foundation. This four-year project (April 2016–Dec 2019) is being implemented in 12 blocks of eight districts of the state of Tamil Nadu by terre des hommes Germany – India Program (tdh) and Community Awareness Research Education Trust (CARE-T), a Coimbatore based NGO. The total budget of the project is € 2,045,056. The project has the following four sub-goals at three levels of intervention: Level Sub goals Micro 1. Rehabilitation of 24,000 girls and young women as survivors of the Sumangali scheme in 12 blocks of Tamil Nadu 2. Prevention of recruitment of girls and young women under the Sumangali scheme in 12 direct blocks and 48 extended blocks Meso 3. Development and implementation of a universal code of conduct and recruitment guidelines by associations of spinning mills and exporters of garment manufacturers through multistakeholder dialogue process with support of German Textile Alliance Macro 4. Discussion of a draft bill (recruitment law) for the termination of the Sumangali scheme in Tamil Nadu State Assembly. The project commissioned the end-term evaluation as part of its accountability mandate and as a learning exercise to understand and inform pathways to eradicate the Sumangali1 system. The evaluation was conducted from mid-January 2019 to February 2019 and followed a qualitative and participative approach. The methodology included desk review, an evaluation workshop with project team, field visits involving discussions with beneficiaries and project team, and key informant interviews with other external stakeholders and experts. The evaluation also reconstructed project’s theory of change and developed a rating system for evaluation purposes. The evaluation used OECD-DAC criteria of assessing relevance, validity of design, effectiveness, efficiency, results and sustainability The evaluation team did not talk local language and had to rely on translators, which was in some cases seen as not satisfactory by beneficiaries.

Recommendations and Action Plan

Recommendation Management Response: (Accepted, Partially Accepted, Not accepted)1: If recommendation is rejected or partially accepted, state reasons:

Action Planned Expected Completion Date

1 The options for response are: • Accepted, meaning Fully Accepted: the organisation thinks that this recommendation should be completely implemented, and the response should

show how and by when that is to be done. • Partially Accepted: the organisation thinks part of the recommendation is in error or not applicable and will not be responding to it,but

1. Rehabilitation strategy: The project should aim to

develop a comprehensive rehabilitation strategy to

provide quality rehabilitation services in a need

based and holistic manner. Some of the specific

recommendations are:

a) Rehabilitation service must follow case

management approach wherein the support

services are provided as per the identified needs

of the survivors.

b) The current need assessment tool must be

revised to assess physical and mental health

status of survivors at the time of identification.

Relevant technical experts must approve the

need assessment tool before its application.

c) The project should adopt life skill building

approach, instead of psychosocial counselling, as

it is more relevant to the beneficiaries and is

also within the delivery capacities of the field

team. The life skills module can be delivered on

a weekly basis over four to six months. The

project should consider a need-based approach

to assess if the life skills training and vocational

training can be delivered simultaneously or one

after the other. Appropriate tools should be

Accepted

The project has accepted to develop the

comprehensive rehabilitation in order to

make the services more need based and

improve it on a holistic manner. The

specific recommendations are accepted

and the following measures are taken up:

-

a) The rehabilitation strategy is

redesigned to follow the Case

management. Therefore, the

rehabilitation service reassess,

plans, implements, coordinates,

monitors and evaluates the options

and services required to meet the

health and human service of the

young girls’ assessed needs.

b) The current need assessment tool

will be revised. It is to assess

physical and mental health status of

survivors at the time of

identification. The technical support

will be obtained from NIMHANS.

Surveys for baseline,

migrant study, end line

study and case

management

There are two surveys,

the base line survey is to

assess the pre-project

stage and situation and

the end line survey is to

measure the progress

made in the fixed

indicators. There are two

parts and the part one of

each of the two surveys

will cover the vulnerable

villages in 9 blocks.

Second part is to status

and training needs of

workers through Human

Resources staffs of textile

mills. Team of staff with

Hired consultant for

guiding the surveys is to

carry out the surveys. A

accepts and will take action for the other part. Note that the reason for a partial acceptance must be given. • Not Accepted: the organisation thinks the recommendation is based on

inaccurate findings or does not address the findings in the appropriate way. The reason for non-acceptance must be stated.

developed and applied to measure the progress

of the beneficiaries. The tools must essentially

include trainer manual to conduct life skill

trainings.

d) Survivors who require clinical attention for

mental health should be referred to

professionals such as clinical psychologists and

psychiatrists. Innovative and cost-efficient

methods such as phone-based therapy can be

explored for this purpose.

e) Selection of trades for alternate livelihood

should be based on block level feasibility

studies. The feasibility studies must focus on

identifying trades and vocational skills based on

market demand, their absorption potential,

salary levels and ability to provide decent

working conditions. The project’s placement

support must ensure issuance of contract letters

detailing terms of employment and benefits.

Adopting a centralised web-based information system to manage opportunities can strengthen the project’s placement strategy. Further, partnership with local placement agencies can be explored. Since employers pay placement agencies for recruitment services, this strategy can be significantly cost effective. Finally, the project team at the RRC level should be given flexibility to innovate and implement strategies to facilitate placement of survivors.

c) The process of building life skill

approach is already carried out to

build the capacities of the

beneficiaries. As per the

recommendations, one more special

life skill education camps will be

conducted for all the needy

beneficiaries before the end of the

project period.

d) The feasibility study for selecting the

appropriate trade will be taken up

during the next phase of the project.

Placement services will be

strengthened.

e) Selection of trades for alternate

livelihood will be based on block

level feasibility studies. It is a good

recommendation for improving our

work. It is planned to be conducted

after the end of the project while

strengthening the existing activities.

The outcome of the feasibility study

will be used for the changed course

of action in the follow up activities.

The recommendations especially on

the identified feasible trade for the

activity groups of young women will

be implemented.

comprehensive baseline

survey is the basis for

monitoring and the

reference for the end line

survey. The baseline

survey is expected to

analyse the basic profile,

emotional level of the

survivors, medical and

trauma related status,

emotional coping level,

skill and educational

level, family conditions

and the vulnerability of

the family. The external

evaluation of the current

project is setting a good

base when deciding what

kind of data is necessary

and how to manage the

data throughout the

project. Two surveys will

be conducted: one in the

project villages and the

second in the mills.

Furthermore, as

recommended in the

evaluation, a feasibility

f) Adopting a centralised web-based

information system to manage

opportunities will be initiated during

the pendency of this project. It is a

good recommendation. As per the

recommendations, one more update

on emotional status before the end

of the project.

As per the recommendations, Profile of

the beneficiaries will be again updated

based on the present economic status.

Medical camp records of the girls and

young women with abnormal HB count

and serious illness are documented. It is

documented and made available in

regional resource centre.

Partially Accepted

Survivors who require clinical attention through innovative and cost efficient methods such as phone therapy is a good recommendation. So far the phone based therapy is not likely to be feasible. This imperative aspect is to considered based on the unwillingness of young women survivors. There are cultural barriers of young women in opening up their mind and sharing it to clinical psychologist whom they don’t know in person. Moreover, even the

study on the status of

female migrants is

conducted. Digital coding

of the beneficiaries,

documentation of their

status at the beginning of

the intervention and at

the end is required to

map the life changing

progress of the

beneficiaries due to the

project intervention.

Periodic data collection

on their psychological,

physical, attitudinal,

educational and

livelihood changes are

recorded and

documented in digital

formats.

Life skill education

Girls are trained in ten

types of life skill

education promoted by

the World Health

Organisation (WHO).

Beneficiaries are selected

by field staff based on

general preference of the clinical psychologists is not in favour of this imperative aspect. Therefore, the existing referral services shall be continued for the time being.

the criteria formulated by

key staff of the project.

The existing training

materials on Life skill

education will be

screened and refined to

suit our project’s target

Life skill education will

be conducted by the

project staff based on a

trainings manual within

the Resource Centres

(RRCs), which were

established in the

previous phase and serve

as a contact point and

training centre for the

victims. Life skill

education is the first step

in the rehabilitation

process of the girls and

sets the ground for

further training. After the

training tailor-made

measures for the

individual development

then it will be offered to

the girls

Feasibility study on job

market, skill

development and micro

enterprises

As recommended in the evaluation, a feasibility study on market demands and employment opportunities is to be conducted by the project team to design the skill development activities for decent employment and educational support. A special look will be given to the emerging developments in organic cotton processing and circular economy approaches with regard to job opportunities and needs for training. There is a need to enhance the capacities in tune with reality. Dynamics of the job market will be analysed in the feasibility study. The study will provide a clearer direction on the current job market situation.

2. Prevention strategy: The prevention strategy

must focus on addressing systemic issues at the

individual, family, societal and workplace levels to

eradicate exploitative conditions in the textile

industry.

a) The prevention strategy should continue to work

on filling the information gap related to

negative impact of the Sumangali system.

Additionally, the awareness must be created on

labour rights especially on minimum wages,

leaves, freedom of movement, anti sexual

harassment laws, and need for collectivisation.

b) The current strategy to promote two kinds of

groups needs to be revisited to ensure coverage

of all the villages, promotion of women and

youth leadership, and a linkage with block level

group using federation structure. The capacity

development of the groups must focus on

eradication of social norms, labour rights, and

participation in decentralised self-governance

mechanisms and also in policy advocacy

initiatives at the meso and macro levels. The

project must work out sustainability strategy of

the groups in consultation with survivors and

other key stakeholders.

The prevention strategy must include engagement with factories to improve working conditions and implementation of existing laws.. It can advocate for setting up of Village level systems to prevent

Partially accepted.

a) The prevention strategy is planned

to combine awareness on the

negative impact of Sumangali system

with continued awareness on labour

rights especially on minimum wages,

leaves, freedom of movement and

anti-sexual harassment laws.

Awareness on labour rights,

minimum wages and freedom of

movement is an ongoing process.

b) As per the recommendations of the

evaluation, one more round up of

explanation on roles and

responsibilities will be made to all

community structures before the end

of the project.

c) Resolutions are passed in programme

village councils on maintenance of

migration register. It is available in

many programme villages. Now, the

petitions on maintenance of

migration are submitted in other

villages where the programme is

implemented during the

Independence Day.

Engagement with factories will be initiated the engagement with the factories such as explaining the

Prevention work in

vulnerable source areas

Girls and women in

deprived areas will be

supported through

informal education on

child rights, gender and

labour rights to prevent

their drop out of school

and unfair recruitment

for exploitative work.

They will participate in

village council meetings

and speak out for girls’

rights to education and

for preventing

recruitment into

exploitative labour and

pass resolutions on

special public village

council meetings.

Children (aged 11 to 17)

will be supported with

proper education and as

they are vulnerable to

become early age workers

Strengthening groups of

girls and young women

unsafe migration and to raise voice against the exploitative conditions. For example: -Village level in maintenance of migration registers.

prevention methods to improve the working conditions are started. And in the due course it will be explained to other textile mills in upcoming project period.

Activity Groups (AG) will

create an action plan for

each group in defending

the rights of girl children

and young women. AG are

joining hands and support

each other on village

level and at block level

with the network of AGs.

They monitor the

prevention of unsafe

recruitment of forced

labour. It will lead to

structural sustainability.

Interaction by female

workers with village

They will meet with

labour brokers and the

communities to inform

about working and living

conditions in the spinning

mills. a) Organized as

activity groups will

establish contacts with

key persons in the

community; b) Once in a

month approach the key

persons; c) Then short list

the recruiters; d) Conduct

meetings with the

recruiters once in two

months and Follow up.

Knowledge building for peer workers on ICC, hostel law, Mill Codex: - Peers of the factory workers with articulation and potentials will be selected and trained in order to build knowledge on ICC, Hostel Law and Mill Codex.

3. Development of Mill Codex: The project must

initiate engagement with employer associations like

SIMA at the earliest with the overall goal of

developing universal code of recruitment in a

stakeholder driven manner.

a) The project needs to develop human resource

capacities to engage with employer associations

to facilitate multi-stakeholder dialogue process

either by bringing in relevant experts in the

team or by tdh playing a bigger role at this

level.

b) With the objective of building trust, the project

should also identify and disseminate good

practices of recruitment and working conditions.

The project must use existing platforms like Tamil Nadu Alliance (TNA) and Multi Stakeholder Initiative

Accepted

The project will initiate engagement

employers’ associations. Draft Mill Codex

is shared with the employers of large

textile manufacturing factory unit. Mill

Codex has identified and explained all the

good practices of recruitment and fair

treatment of workers by employers.

a) The engagement with employers

association will be carried out after

organizing the German level round

table with the select brands

representatives with textile supply

chain link in Tamil Nadu. The

positive outcome of the round table

Round table conferences

with the managers of the

textile supply chain

management staff

(responsible for human

resources) of the mills

are sensitized for the

importance of best

business practices in

recruitment and

employment, the

effective relationships

between sustainable

human resources, and the

productivity at workplace

and the progress in

–Tamil Nadu (MSI-TN), and engage with worker organisations to create larger demand for the universal Mill Codex.

will be helpful in advancing the

advocacy effort with the employers.

Therefore, the employers understand

more about the relationship between

our project and the international

business implications. The

recognition of our work by the

employers’ association also requires

some external business inputs from

the top level of the textile supply

chain.

The Mill Codex is already shared with the employers of large textile manufacturers. The employers have listened to the explanations on the various components of the Mill Codex. They have expressed their apprehension on the expected business value for implementation of all the components of the Mill Codex. They have agreed to implement the hostel laws and they have started registering their hostels as per the law. The evaluation was taken up in Jan-Feb 2019.Many activities were taken up after the evaluation.

business in textile supply

chain. Round Table

Conferences are related

to recruitment and

employment.

Engagement for revising SIMA guidelines in tune with Mill Codex The project will connect

with SIMA as they have

developed their own

guidelines to improve

working and living

conditions in the mills.

Multi-stakeholder

dialogues on the Mill

Codex and relevant

themes

Conference for managers will deal with the Ministry of Corporate Affairs New Delhi has developed National Action Plan on the UN Guidelines on Human Rights and Business. Periodic dialogue with the employers, government representatives is enhancing to create models of best social

practices in textile supply chain. In a participatory process the employers will be supported during the dialogue events to develop action plans for the improvement of working and living conditions. Best textile practise is assessed by the effective application of components of Mill Codex even if it takes place gradually and incrementally.

4. Policy advocacy at the macro level: The project

should explore alternate methods of policy advocacy

to address the legal loopholes in place formulating a

new law, which is a long-term and resource

intensive strategy. Few alternatives to be

considered are:

a) Advocacy for inclusion of textile industry

(including spinning mills) in the list of hazardous

industry through public interest litigation.

b) Adopt evidence based policy advocacy strategy

at the local, regional and state levels to

highlight the exploitative working conditions in

the textile industry. For this purpose, the

project can utilise needs assessment survey data

Agreed in principle but strategy varies.

Project network is founding member of

TNA. The project network is actively

participating and cooperating with TNA

since its inception in 2017 as a platform

of all networks including Ethical Trading

Initiatives of Tamil Nadu Multi Stake

Holder Initiative (TNMSI). ETI’s TNMSI is

founded since 2014 and is a founding

member of TNA. Already Tamil Nadu

Alliance has the engagement with TPF

(Tirupur Peoples Forum for environment

and labour rights), ETIs TNMSI (Tamil

Nadu Multi Stakeholder Initiative),

Migrant Workers forum,

Appraisal on the

incidence of violations

Appraisal on the

incidence of violations is

conducted by supporting

the victims. Evidences

are gathered and

submitted along with the

petitions seeking justice

and compensation.

Victims or families of

victims are provided

moral, operational

(petitions) and legal

support. Resolvable

and also further collect relevant data using

TPF’s network of community organisations.

c) Advocate for activating District Monitoring

Committee and implementation of its

recommendations in partnership with other

stakeholders like TNA.

d) Support the TNA’s efforts to develop policy for

women workers in textile industry government

bodies. It is to be noted that TNA is working

with State Commission for Women and

Department of Labour to develop this policy.

TPF’s support can be in form of creating

grassroot level demand for such a policy. It can

further support TNA to influence the state level

policy makers by providing evidence in form of

data and field stories to highlight the situation

of women workers.

Design and implement a communications and media

strategy to deliver the key messages around the

negative impacts of the Sumangali system, its

systemic factors and policy asks in a sustained and

consistent manner.

MSI-TN and Campaign against Camp

Coolie System (CACS.)This will be

strengthened for better policy advocacy.

a) Not accepted. Textile production

process was in the hazardous sector

in the past. But the government of

India has changed in to the non

hazardous sector

It is a good recommendation but the

advocacy on the inclusion of textile

industry is considered as a sensitive

and offending issue by the

employers. The project agrees the

importance of the listing the textile

industry as a hazardous industry at a

policy level but it is not immediately

possible only by a stakeholder like

our project in changing the mindsets

of the employers. It is a time bound

and long term advocacy work. Also,

it is not advisable for our project as

we are entering the phase of

intensively working on factory

engagement. The project should not

antagonize the employers at one side

and work with them on the other

side. Practically, the project is not

grievances are directed to

the management by

petitions and in case of

failures, other avenues

for justice are explored.

Staff and local activists

will approach the textile

mills along with

beneficiaries. Then, in

case of failures in

achieving the results then

it will be taken to

concerned authorities.

Legal advice in labour

disputes

Legal advice will be

facilitated for the

affected young women

workers in labour disputes

to claim the rights

(payments of

compensation in case of

sickness, suicides and

attempted suicides;

regular payment of

salaries). Identified cases

of mill owners trespassing

labour laws are discussed

making any immediate demand for

the inclusion of textile industry.

b) An evidence based policy advocacy is

already taken up and more will be

taken up during the next phase of

the project.

c) Advocating for activating District

Monitoring Committee and

implementation of its

recommendations in partnership with

other stakeholders will be done.

d) Designing and implementing a

communications and media strategy

to deliver the key messages around

the negative impacts of the

Sumangali system, its systemic

factors and policy asks in a sustained

and consistent manner.

The project is associated with Tirupur

Peoples Forum for environment and

labour rights. It is a founder member of

Tamil Nadu Alliance. Our project has

ddocumented unresolved cases and it has

produced it before the State Women

Commission and it is following up with the

State Women Commission jointly with the

Tamil Nadu Alliance. Majority of the

cases produced through Tamil Nadu

with advisory persons

from the legal advisory

institutions.

Engaging with free legal

aid authority and state

commissions for women

and children, and

others: - The project will

support the reported

victims by engaging with

Human Rights Instruments

and mechanism at state

level such as State Human

Rights, Women, Child,

Scheduled Caste,

Scheduled Tribes,

Backward Class and

Minority Commissions.

Proactive intervention by

the Judiciary has a

snowballing effect on

resolution of the cases.

There is an urgent need

to enhance the

engagement with free

legal aid authority for

comparatively faster

Alliance belongs to our project. The

intervention through State Women

Commission has resulted in immediate

justice to the survivors and the family of

the survivors. There will be more such

efforts besides follow ups to influence

the state level policy.

delivery of justice and

compensation.

Cooperation with District

law enforcement

mechanisms

Coordination meetings

with the district level

officials are conducted

with them for effective

implementation of laws

defending girls and

women at workplace and

hostels. Registration of

hostels run by the

spinning mills under the

law is pursued through

the pressures of the

officials. Officials at

State level with mandate

to work for the welfare of

labour, women, children,

marginalized

communities. Officials of

the relevant departments

of the district meet

project staff and AG

leaders.

District level workshops

for leaders of CSOs

district level workshops

for the leaders of

CSOs/trade unions and

Schools on engagements

with the enforcement

officials for the

implementation of legal

mechanisms to protect

children and women

officials for effective

implementation of laws

defending girls and

women in particular at

workplace, hostels and

schools are conducted. In

each workshop an action

plan is developed to

record next steps how the

stakeholder can support

decent working conditions

for girls and young

women. In the following

meetings the

implementation of the

action plans will be

monitored.

State level engagements

with administration

The state level

engagement team will

share information, hand

in petitions and follow up

with elected

representatives on topics

like prevention of school

dropout, ratio of high

school girls in government

schools and a faster

mechanism for licensing

hostels in textile mills.

The team will meet with

state departments of the

relevant ministry on

gender and labour issues

of garment industry,

developing policy for

adolescent girl children,

and state level

coordination with the

representatives of trade

unions, media advocacy

for the welfare of girls

and young women and

networking with CSO

working on gender issues.

Networking with Civil

Society Networks

CARE-T is the facilitator

of Tirupur Peoples Forum

for environment and

labour rights (TPF). It is

engaged in working for

the improvement in

working and living

conditions in the textile

supply chain. TPF acts in

association with more

than 41 civil society

organizations located in

21 districts. TPF is the

founding member of

Tamil Nadu Alliance

(TNA). TNA is a focal

point for advocacy

activities of CSOs to

advance the rights of

young women and

migrant workers at state

level. The project is in

direct communication

with the convenor of

TNA. There is a clear

distinction on the

activities proposed by this

project and the activities

proposed by TNA

coalition. Our project and

its network TPF has a

wider geographical

working area. There is a

good solidarity between

our project, TPF and the

TNA secretariat.

Networking with ETI’s

Tamil Nadu Multi

Stakeholder Initiatives

(TNMSI) is developed

further with workshops

for CSOs, employers’

associations and

government agencies for

convergence of relevant

officials on

implementation existing

legislations. TPF will

strengthen its networking

with Tamil Nadu Women

Movement (TNWM).

5. Project management: The project management

systems must focus on developing appropriate tools

to efficiently monitor, to facilitate internal learning,

adaptive management and enhancing the

effectiveness of the implementation strategies. The

recommendations in this direction are:

a) The project should develop a manual for the

project team to develop common understanding

of the objectives, strategies, terminologies,

processes, quality control measures, indicators

and targets. This shall also contribute to

standardisation of activities across blocks.

Better remuneration structure for project staff

should be considered to enable the partners to hire

staff with required capacity and skills.

Partially Accepted.

a) The project will develop a manual

for the project team to develop

common understanding of the

objectives, strategies, terminologies,

processes, quality control measures,

indicators and targets, training

manuals for all key trainings to the

direct and indirect beneficiaries and

it will contribute the standardisation

of activities across blocks. It is an

ongoing process

b) The existing remuneration structure

for the project staff is not adequate

considering their experience and

dedication.

Capacity building programmes for the

existing staff and new staff for the future

Staff training in PCM,

project concept,

baseline, end line

survey, data

management,

engagement with

stakeholders: - Project

staffs are trained in the

project cycle

management, the project

concept, implementation

strategy, baseline design

and implementation, data

management and analysis

planning and reporting.

Residential training of

key staffs of the project

on engagements to

prepare and conduct

engagement meetings

with government

representatives.

Negotiating skills will be

trained in the regard to

the Mill Codex as

practical example.

Manuals on career

guidance, labour and

human resources

training: - Therefore

uniform capacity building

among the target group

takes place. Personnel

costs: -Better

remuneration structure

for the project staff is

developed.

6. Validity of project design The project design is weak in terms of logical connect between the levels of results (i.e. the connect between outputs, outcomes and overall goal).

Not accepted. The project design was

developed by experts from BENGO and

BMZ, C&A Foundation and TdH Germany

in cooperation with the partner Care-T

7. Under sub-goal 2, the project targeted to stop recruitment under Sumangali scheme in all the 12 project blocks completely, however, the strategy and corresponding activities are inadequate to comprehensively cover the entire project area. The prevention strategy focused on filling the information gap related to negative impacts of the Sumangali system and overlooked other systemic issues like safety concerns for girls in the villages, economic deprivation, social norms. Further, the operational strategy to organise survivors and stakeholders into groups is not clear. There is an absence of interrelatedness between the different activities, which makes it ambiguous as to how the overall objective of eradicating the Sumangali scheme in the entire block shall be achieved.

Partially accepted,

There is absolutely no reference to .

Under sub-goal 2, that the project

targeted to stop recruitment under

Sumangali scheme in all the 12 project

blocks completely.

8.To develop the recruitment guidelines under sub-goal 3, the project design rightly suggested of a multi-stakeholder approach. However, the design made assumptions about participation of different stakeholders and did not identify challenges and risks of the dialogue process adequately. The project design to draft the new law under sub-goal 4 is not stakeholder driven and is inadequate to having the law discussed in the Tamil Nadu State Assembly.

Partially accepted.

This effort is driven by concerns at the grass root level activists and subsequently it is a concern of the families of victims. It is not easy to expect the support of employers on a draft bill and discussion at the legislative assembly. Gaining political support for this work is an attempt to bring structural change on this prolonged issue. It is an attempt to bring a legal change. (Draft bill is now ready and meeting with political and administrative set up has been planned in2019). Yes, there was no stakeholder driven advocacy towards the draft bill, as during the project it turned out to be not possible to include employers association and/or politicians right now, as there is a lot of political repression and the TN government is denying the existence of contemporary form of modern slavery practices. Nevertheless we drafted the bill – to have a draft at hand for future work. In next phase the difficulties are reflected and the speed is much more humble. Tdh Germany is not directly involved in drafting the bill, but supporting the Mill Codex and the issue through advocacy on with relevant stakeholders in Germany,

like the Sustainable Textile Alliance and its business members, sourcing in TN.

10. Effectiveness and results The project achieved outcome level results only at the micro level. At the meso level, the recruitment guidelines is drafted, however, it is yet to be introduced to employer associations. At the macro level, the proposed anti-Sumangali law is yet to be drafted. The key findings related to effectiveness and results are as below:

Not accepted.

The evaluation took place a year before

the project phase ends. Subsequently,

activities have to be continued to reach

the planned results. For example: As

reported in the Half Yearly Report on

the period from January 1st to June

30th, introduction to employers took

place.