ECLT

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The Eliminating Child Labour in Tobacco-Growing (ECLT) Foundation is a Swiss-based non-profit organisation that describes itself as “independent” and a “global leader in eliminating child labour”. [1]

Funded and Governed by Tobacco Companies

In reality, the ECLT Foundation is both funded and governed by tobacco companies. In 2001 it reported income from members, the bulk of its income source, as CHF247,000 (approximately USD$247,000). In 2018 it reported income from donor contributions of USD $5,778,606. [2][3] Members in 2019 include British American Tobacco (BAT), Imperial Tobacco, Japan Tobacco International (JTI), Philip Morris International and Swedish Match as well as other national tobacco companies and tobacco growers.

ECLT states that its “sole purpose and mandate is to prevent and protect children from child labour wherever tobacco is grown”. It promotes itself and public-private partnerships (PPPs) with the United Nations (UN) as “part of the solution” to tackling child labour in low and middle-income countries. [4]

Partnerships with the UN’s International Labour Organisation and Global Compact

From 2002 until 2018, the ECLT Foundation had a Public-Private Partnership agreement with the International Labour Organisation (ILO). It was an adviser to the Foundation’s board alongside Save the Children Switzerland. Following sustained pressure from the World Health Organisation and more than 100 global groups, the ILO finally announced in November 2018 that it would stop accepting tobacco industry funding for its projects and would also not renew ECLT’s contract, which had expired in June. [5][6]

The ECLT Foundation remains a member of the Child Labour Platform of the voluntary United Nations Global Compact (UNGC) Human Rights and Labour Working Group - for which the ILO provides the secretariat. [7], [8], [9], [10], [11], [12] This is despite the UNGC’s decision in 2017 to permanently sever ties with tobacco companies, following the adoption of a breakthrough UN ECOSOC resolution (E/2017/L.21) that encouraged UN agencies to develop policies to prevent tobacco industry interference. [13]

History

The ECLT Foundation was set up in Geneva in September 2000 as part of a wider strategy by the major tobacco companies, particularly BAT, to protect their corporate reputations and position themselves as “socially responsible”. [14] Its establishment followed high profile exposes of child labour on tobacco farms in the late 1990s, notably in Malawi, and the adoption of ILO Convention No.182 in June 1999 outlawing the “worst forms of child labour”. [15]

The ECLT grew out of a joint agreement in 2000 between BAT and its front group the International Tobacco Growers Association (ITGA),[16] [17] with The International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF) to develop a programme of research and education aimed at eradicating child labour.[18]

Other early ECLT members included Philip Morris, Imperial Tobacco, JTI, Gallaher and Scandinavian Tobacco. [19]

BAT: “A Good Opportunity to Move to the Moral High Ground”

A peer-reviewed 2006 academic study on the ECLT Foundation’s pilot project in Malawi concluded, after analysing relevant BAT internal documents from 1998-2002, that the tobacco giant was using child labour projects as a reputational tool. It argued that

"rather than actively and responsibly working to solve the problem of child labour in growing tobacco, the company acted to co-opt the issue to present themselves over as a 'socially responsible corporation' by releasing a policy statement claiming the company's commitment to end harmful child labour practices, holding a global child labour conference with trade unions and other key stakeholders, and contributing nominal sums of money for development projects largely unrelated to efforts to end child labour." [14]

The study, by Otonez et al, revealed how the IUF, ILO and International Confederation of Free Trade Unions (ICFTU) had commissioned a film that showed children as young as five working on tobacco farms in Malawi during the spring harvest in 1999. The idea was to put pressure on the companies and the Confederation of European Community Cigarette Manufacturers (CECCM) over its denials that child labour was occurring there. Internal BAT documents released to the public through a litigation settlement in America and now online at the Truth Tobacco Industry Documents database show that IUF General Secretary Ron Oswald had promised however, that the film would not be anti-tobacco and “would be consigned to the archives” if the CECCM and companies cooperated and acknowledged the child labour problem in Malawi. [20][14]

The IUF signed a joint declaration on child labour in June 1999 with the ITGA, witnessed by ILO Executive Director Kari Tapiola. [21] Correspondence between BAT and its UK public relations agency Hallmark that year shows a series of revised draft statements between IUF and ITGA. The final published version on the conference website[22] - drafted by Hallmark andBAT – notably dropped the IUF’s proposed inclusion of “respect for worker’s rights to freedom of association (as defined in ILO Convention 97)”. [23]

In October 2000, BAT co-organised a conference in Nairobi, Kenya, with the IUF and ITGA, titled ‘Eliminate Child Labour: Establishing Best Practices in Tobacco Farming’.[24][25][26] According to the event brochure, the ILO’s Kari Tapiola was keynote speaker, alongside two BAT staff, the ITGA’s president and the IUF’s Ron Oswald.[24][27] A BAT executive later deemed the conference “a huge success” in countering rising international concern among the UN, OECD, ILO and EU over human rights and labour standards - an agenda BAT described as being pushed by NGOs and other stakeholders “who seemed to be winning”. BAT’s international development affairs manager Shabanji Opukah wrote on 9 November 2000:

“Clearly, the successful launch of the [ECLT] has given us an excellent and rare opportunity to engage with our stakeholders on major platforms around what are today amongst some of the high profile and contentious global issues affecting reputation of international business

adding that:

“Our partnership with the IUF and ITGA gives us a good opportunity to move to the moral high ground on this particular issue and we would like to make use of it in line with the BAT CORA [Consumer and Regulatory Affairs] strategy for recognition as a responsible tobacco company. This strategy identifies corporate conduct and accountability as one of the six reputation management initiatives. Stakeholder engagement and communication is in this platform.[28][14]

According to the minutes of an October 2001 Tobacco Workers Trade Group Meeting at which ECLT’s first Executive Director Marc Hofstetter and project manager Alain Berthoud introduced themselves, the IUF was to hold the rotating presidency of the ECLT Foundation for the first two years. Ron Oswald was its first President. [29]

The IUF is no longer a board member of the ECLT Foundation. An ILO document on its tobacco industry partnerships in 2017 states that, “the IUF served as ECLT’s President until 2013, when it withdrew, citing the viability and success of the Foundation as reasons for its decision to direct its capacity devoted to eliminating child labour elsewhere”.[12]

Funding Agreements with the ILO

In March 2017, the ILO disclosed that it had received more than US$5.3 million from ECLT since 2002, but did not provide details on how this funding was spent. [12] Its relationship with ECLT involved acting as an observer to ECLT’s board, and the following agreements:

  • The first agreement between ILO and ECLT covered the period 2002 to 2010 and aimed to fund research on child labour practices in Indonesia, the Dominican Republic, East Africa, and specifically, eliminate child labour in Tanzania.[30]
  • The second agreement, covering the period between 2011 and 2015, focused on child labour in Malawi.[30]
  • The third agreement from 2015 until June 2018 was aimed at reducing child labour practices in Malawi, Uganda and Tanzania, promoting dialogue among tobacco-growers organisations, and developing advice on hazardous tobacco farming work.[12]

Relationship with UNICEF

From 2003 to 2005, the ECLT Foundation funded a programme to prevent child labour in tobacco growing in the Philippines, in which UNICEF acted as an adviser. [31]

In a study published in the journal Paediatrics on the tobacco industry and children’s rights, the authors describe ECLT as one of several front groups used by the industry to successfully engage with UNICEF.

"After UNICEF’s corporate engagement guidelines were loosened in 2003, tobacco companies successfully engaged with UNICEF directly and via front groups, including the Eliminating Child Labour in Tobacco Growing Foundation. This was part of an overall tobacco industry strategy to improve its corporate image, infiltrate the United Nations, and weaken global tobacco-control efforts.” [32]

Questionable impact on child labour practices

After almost two decades of work by the ECLT, child labour remains entrenched in many tobacco-growing regions and in 2017 was reported to be on the increase.[33] ECLT points to its success in removing over 182,000 children from tobacco farms since 2011 in Kyrgyzstan, Malawi, Mozambique, Tanzania and Uganda, and sending 27,000 to school and vocational training.[33] Critics of the Foundation and its tobacco industry governors meanwhile argue that it has done little to redress or target the structural issues afflicting these regions, instead publicising the positive, and often individually-focused, stories.[31]

Meanwhile a ‘’Guardian’’ investigation in April 2018 found “rampant” child labour in Malawi, Indonesia and Mexico.[33][34]The ILO similarly noted in 2017 that “surveys indicate that child labour is rampant in impoverished tobacco-growing communities”. [12]

Anthropologist Professor Marty Otanez from the University of Colorado, lead author of the previously mentioned 2006 study on BAT and ECLT in Malawi, is a long-standing observer of tobacco farming in that country. Prof Otanez told the ‘’Guardian’’ that welfare projects were “pushing out goodwill on behalf of tobacco companies to address some of the problems but avoid the harder issues of leaf prices and living and earnings”. Tenant farmers on tobacco estates in Malawi, for example, earn just US$224 a year.[33]

In September 2017, the Malawi tobacco farmers’ union TOAWUM wrote “on behalf of hundreds of thousands of Malawi farmers” to the ILO’s Governing Body, asking it to ban public-private partnerships with the tobacco industry at its upcoming 331st meeting. In its letter, TOAWUM stated that initiatives such as the ECLT Foundation,

”insufficiently address root causes of tobacco-related child labour, which is endemic poverty among tobacco farmers. That poverty is exacerbated by contracting schemes developed by the very companies funding some projects for ECLT.” [35]

TOAWUM’s criticism echoes that of the South East Asia Tobacco Control Alliance (SEATCA), which wrote to ILO Director Clarence Thomas in 2013 following its own research into child labour and ECLT’s projects in the ASEAN region. It highlighted the hypocrisy of an industry whose business model perpetuates child labour in its supply chain:

”Unlike other industries that have a zero tolerance for child labour, the tobacco industry has set no such polices or target date for complete eradication of child labour. The tobacco industry, while publicly condemning child labour, continues to purchase and use leaves that are produced by child labour and profits from them. The tobacco industry’s miniscule contributions through so-called corporate social responsibility activities including the ECLT are a whitewash of the problem. The more serious issue is that these CSR activities provide a convenient platform for tobacco companies to gain access to policy makers who are responsible to approve and implement tobacco control measures. The endorsement from IPEC [International Programme on the Elimination of Child Labour] and ILO of ECLT only serves to strengthen and protect the tobacco industry.[31]

Legal Threats Against International Tobacco Control Groups

In July 2018, amid a concerted campaign by the WHO and 100 global NGOs to get the ILO to terminate all its tobacco-related partnerships, the ECLT Foundation instructed a Swiss law firm to issue a “formal notice before legal proceedings” against the US-based NGO Campaign for Tobacco-Free Kids (CTFK).[36]

The legal notice from Capt & Wyss, solicitors for the ECLT, emphasised the organisation’s “independence” as a registered non-profit Swiss organisation, and demanded that CTFK “immediately” delete from a press release posted on its website the “defamatory”, “untrue and misleading” references to ECLT as a:

  • “tobacco-industry-dominated group”;
  • “front group for tobacco industry interests under the guise of a corporate social responsibility initiative” and;
  • that it “represents an alliance of tobacco companies and growers – led exclusively by the tobacco industry”.

In addition, the legal notice stated that ECLT “seeks a public and online apology, respectively rectification, relating to this unlawful publication.”

In his response, CTFK’s President Matthew L. Myers noted that his organisation’s descriptions of ECLT were “well-documented based on the best publicly available information” and “factually accurate” and were also already in the public domain. CTFK received no subsequent response to its reply from either the lawyers or ECLT. [37]

The ECLT had previously issued a press release on its website in May 2018, rejecting “front group assertions” made against it in an April 2018 article published in the American Academy of Pediatrics as “baseless” and “false”. The article on “The Tobacco Industry and Children’s Rights” examines the tobacco industry’s engagement with UNICEF, including ECLT. [38]

ECLT had also published an online rebuttal to an October 2017 press release by the global NGO Framework Convention Alliance on Tobacco Control (FCA) in which it rejected FCA’s “false” assertions that “Reports have repeatedly claimed that ECLT’s work aims to keep farmers dependent on aid from the tobacco industry to avoid them abandoning the sector.(sic)” and that "ECLT allows the tobacco industry to promote a positive public image while continuing the practices that cause labour exploitation in the first place”.[39]The rebuttal was reprinted in Tobacco Reporter.[40]

Following emails from ECLT’s executive director that same month, the FCA later received a ‘cease and desist’ notice from Capt & Wyss in January 2018 specifically noting the first point above and the FCA’s public “Letter to the UN Secretary General on Cooperation between the Tobacco Industry and the ILO”, signed by over 180 organisations in October 2017. [41] Although the FCA did take down both documents as a precautionary response, no further action was taken[42] and these remain in the public domain.[43]

ECLT Team

From its inception, the ECLT Foundation has typically employed highly experienced human rights and development professionals, many of them with solid track records of working within the UN system either as staff or consultants. This strategy appears to have been critical to tobacco companies’ insistence of the organisation’s “independence” and for its dealings with the ILO and other UN agencies such as UNICEF.

Internal BAT documents now online at the Truth Tobacco Industry Documents archive show that BAT, when setting up ECLT in 2000, was “looking for an executive with experience in the UN and NGO sectors and ability to raise funds on a global scale. The individual will also need to have high diplomatic campaigning and lobbying skills and a good span of experience in these areas. Knowledge of French and other UN languages is also desired…”[28]

In one case, ECLT’s new executive director in 2008 came direct from working with the ILO in Tanzania.

Leadership

  • Karima Jambulatova, Executive Director (from May 2019). Has worked with ECLT since 2013.
  • David Hammond, Executive Director (November 2017-April 2019). Barrister and founder of a marine human rights organization. [44]
  • Sonia C. Velázquez, Executive Director (2012-2017). Previously worked with Plan International, America Humane and Save the Children, among others. Was instrumental in gaining ECLT its ECOSOC consultative status and UN Global Compact membership from 2015. [45]
  • Marilyn Blaeser (2008-2011), joined ECLT after working for ILO as Chief Technical Advisor (Child Labour) in Tanzania. CV includes six years with UNICEF and UNHCR. [46]
  • Mark Hofstetter, (2000-2005). Was Head of Delegation at the International Committee of the Red Cross for 13 years before becoming ECLT’s first director. [47]

Project Partners Past and Present

Includes:

  • Winrock International – US-based implementing partner for ECLT “PROSPER” project working with the Government of Tanzania; Tabora Development Fund Trust (TDFT) and the Tanzania Association of Women Leaders in Agriculture and the Environment (TAWLAE).[48] Winrock also works with ECLT member Japan Tobacco International on its child labour programme ARISE.
  • Defense for Children International (DCI) – implementing partner in Guatemala
  • UWESO – implementing partner in Uganda
  • Save the Children Switzerland – appointed as an honorary adviser to the board in 2013; an implementing partner for projects in Malawi and Mozambique [49]
  • Creative Centre for Community Mobilization (CRECCOM) - Malawi 2016-2019
  • Youth Net and Counselling (YONECO) – Malawi 2016-2019
  • iDE and FAA – Mozambique project partners 2019

Board Members

ECLT’s board is mostly made up of industry executives from cigarette manufacturers and tobacco leaf growers. [50]

  • Antonio Abrunhosa, President and Mercedes Vazquez from the International Tobacco Growers Association
  • Kirsty Green-Mann, Vice-President (until April 2018); succeeded by Surinder Sond, Imperial Brands
  • Mike Ligon ECLT Vice-President (from April), Universal Leaf Tobacco corporate affairs. A regular speaker at the Global Tobacco and Nicotine Forum.
  • Marcus McKay, Treasurer (until April 2018); succeeded by Matthew Wilde, Contraf-Nicotex-Tobacco GMBH
  • Simon Green, Treasurer (from April) Alliance One International Inc. An attendee at the Global Tobacco and Nicotine Forum in 2016.
  • Miguel Coleta and Mauro Gonzalez, Philip Morris International
  • Jennie Galbraith, British American Tobacco An attendee at the Global Tobacco and Nicotine Forum in 2013 when she was group head of sustainability at BAT.
  • Kazim Gürel, SUNEL Ticaret Turk A.S. One of Turkey's oldest leaf tobacco dealers and manufactures chewing and smoking tobacco. Its largest customer is PMI.
  • Emmett Harrison, Swedish Match
  • Elaine McKay, Japan Tobacco International and Japan Tobacco Inc, CSR Manager
  • Linda McMurtry, Hail & Cotton Inc, aTobacco leaf dealer, with purchasing and process capabilities to provide Flue Cured, Burley, Dark Fired, Oriental and other tobacco manufacturers.
  • Glyn Morgan, Premium Tobacco
  • Mette Valentin, Scandinavian Tobacco Group[50]

Tobacco Tactics Resources

Relevant Links

Notes

  1. The Eliminating Child Labour in Tobacco Growing Foundation (ECLT), A Sector Wide Coalition Against Child Labour, website, accessed August 2019
  2. ECLT, Governance, Page archived 14 Nov 2017 at the Internet Archive, accessed August 2019
  3. ECLT Annual Reports 2001/2018, website, reviewed by TobaccoTactics, August 2019
  4. ECLT, Social Dialogue and Collaboration: ECLT Statement at ILO Technical Meeting, Kampala, website, 4 July 2019, accessed August 2019
  5. Framework Convention Alliance, ILO Ends Contracts with Tobacco Companies – Will It Be Forever?, website, 8 November 2018, accessed August 2019
  6. Jenny Lei Ravelo, After 3 deferments, ILO finally decides on tobacco industry-funded projects, Devex, 9 November 2018, accessed August 2019
  7. UN Global Compact, Communication on Engagement 2017-2018 ECLT Foundation, website, 9 July 2017, accessed August 2019
  8. UNGC, ECLT Foundation: UNGC Commitment on Engagement 2017-18, website, 9 July 2019, accessed August 2019
  9. UNGC, ECLT Global Compact Application Letter, 10 April 2015, accessed August 2019
  10. ECLT, ECLT Launches its First Global Compact Communication On Engagement, 15 April 2017, accessed August 2019. ECLT’s next Commitment of Engagement(COE) is due 9 July 2021
  11. UN Global Compact, What is UNGC – Participants, website, accessed August 2019
  12. 12.0 12.1 12.2 12.3 12.4 International Labour Office, Sixth Item on the Agenda ILO cooperation with the tobacco industry in pursuit of the Organization’s social mandate, Governing Body 329th Session, Geneva 9-24 March 2017, accessed August 2019
  13. WHO Framework Convention on Tobacco Control, ECOSOC Resolution calls for the UN agencies to prevent interference from the tobacco industry, website, 10 July 2017, accessed August 2019
  14. 14.0 14.1 14.2 14.3 Otanez M.G, Muggli M.E, Hurt R.D and S.A Glantz, Eliminating child labour in Malawi: a British American Tobacco corporate responsibility project to sidestep tobacco labour exploitation, Tobacco Control 2006;15:224-230, accessed August 2019
  15. ILO, C182 - Worst Forms of Child Labour Convention, 1999 (No. 182) Convention concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour (Entry into force: 19 Nov 2000) Adoption: Geneva, 87th ILC session (17 Jun 1999), accessed August 2019
  16. J.Bloxcidge, Fax from John Bloxcidge to board members of the International Tobacco Information Centre on the ITGA, 11 October 1988, Truth Tobacco Industry Documents, Bates no: 502555416-502555417, accessed October 2019
  17. Committee of Experts on Tobacco Industry Documents, World Health Organization. (2000). Tobacco Company Strategies to Undermine Tobacco Control Activities at the World Health Organization. UCSF: Center for Tobacco Control Research and Education. Retrieved from https://escholarship.org/uc/item/83m9c2wt
  18. The IUF is an international federation of trade unions representing workers employed in agriculture and plantations; the preparation and manufacture of food and beverages; hotels, restaurants and catering services; all stages of tobacco processing. In 2000 the IUF had a membership of 330 trade unions in 120 countries representing nearly 10 million workers, of which 2.5 million were fee-paying according to IUF General Secretary Ron Oswald’s speech at the IUF/ITGA/BAT Child Labour Conference on 8-9 October 2000, accessed August 2019
  19. ECLT, Annual Report 2002, undated, accessed September 2019
  20. Unknown, Report of a Meeting with International Union of Food Geneva, 9 April 1999, Truth Tobacco Industry Documents, Bates no: 321356800-321356802, accessed October 2019
  21. Eliminating Child Labour, Joint Statement by ITGA and IUF, witnessed by the ILO, website, 10 June 1999, screen capture dated 6 April 2001, archived at the Wayback Machine, accessed August 2019
  22. Eliminating Child Labour, Partnership Background website, 10 June 1999, accessed August 2019
  23. T. Watson, Child Labour, 7 June 1999, Hallmark Public Relations/BAT correspondence, 7 June 1999, Truth Tobacco Industry Documents, Bates no: 321309579-321309582, accessed August 2019
  24. 24.0 24.1 BAT, Eliminating Child Labour Conference Brochure, 8 October 2000, Truth Tobacco Industry Documents, Bates no: 325065715-325065720, accessed August 2019
  25. Eliminating Child Labour, Establishing Best Practice in Action in Tobacco Farming Nairobi, Kenya - 8 & 9 October 2000 website, 2001, accessed August 2019
  26. Eliminating Child Labour, Conference Speakers, website, undated, accessed August 2019
  27. Eliminating Child Labour, Kari Tapiola Keynote Speech at IUF/BAT/ITGA Conference, 8-9 October 2000, accessed August 2019
  28. 28.0 28.1 S. Opukah, British American Tobacco. Partnership on Eliminating Child Labour in Tobacco Growing: Progress Report and Next Steps for Action, 9 Nov 2000, Truth Tobacco Industry Documents, Bates no: 325245823-325245826, accessed August 2019
  29. IUF, Tobacco Workers Trade Group Meeting October 10, 2001, website, 1 November 2001, accessed August 2019
  30. 30.0 30.1 International Labour Office, Fifth Item on the Agenda ILO cooperation with the tobacco industry in pursuit of the Organization’s social mandate, Governing Body 331st Session, Geneva 26 October - 9 November 2017, accessed November 2017
  31. 31.0 31.1 31.2 See Southeast Asia Tobacco Control Alliance (SEATCA), Letter to Constance Thomas, ILO Director, 13 August 2013, BMJ Blogs, 2016, accessed August 2019
  32. Y. van der Eijk, S. Bialous, S. A. Glantz The Tobacco Industry and Children's Rights, Pediatrics.2018 May;141(5), accessed August 2019
  33. 33.0 33.1 33.2 33.3 S.Boseley, The children working the tobacco fields: 'I wanted to be a nurse', ‘The Guardian’, June 2018, citing an ILO report, accessed August 2019
  34. M. Wurth and J. Buchanan, How we can fight child labour in the tobacco industry, Guardian, 27 June 2018, accessed August 2019
  35. Tobacco and Allied Farmers Workers’ Union Malawi, Tobacco workers to ILO: Quit Tobacco Industry, website, 29 September 2017, Global Center for Governance in Tobacco Control, accessed August 2019
  36. Campaign for Tobacco Free Kids, ECLT Legal Notice of Proceedings, Capt & Wyss, dated 25 July 2018, released by CTFK to TobaccoTactics, August 2019
  37. M.L. Myers, Response to the July 25, 2018 letter entitled, “ECLT Foundation vs Campaign for Tabacco(Sic)-Free Kids, Formal notice before legal proceedings, 27 July 2018, released by CTFK to TobaccoTactics, August 2019
  38. ECLT, ECLT Executive Director Rejects “Front Group” Assertions, website, 4 May 2018, accessed September 2019
  39. ECLT Foundation, ECLT rebuts FCA assertions that Swiss Foundation encourages child labour practices, 22 October 2019
  40. Tobacco Reporter, Child labor dispute, November 2, 2017, accessed October 2019
  41. Letter to Governments government memberso f the ILO Governing Body, published at the Unfair Tobacco website, 16 October 2017, accessed October 2019
  42. TobaccoTactics personal communication with Mischa Terzyk, Policy and Advocacy Officer at the Framework Convention Alliance, October 2019
  43. Unfair Tobacco, amongst last UN Agencies accepting money from ‘Big Tobacco’, “Press release of the Framework Convention Alliance, the international tobacco control network that we are a member of”, website, undated, accessed October 2019
  44. David Hammond, Linkedin, accessed August 2019
  45. Sonia Velazquez, Linkedin, accessed August 2019
  46. Marilyn Blaeser, Linkedin, accessed August 2019
  47. Mark Hofstetter, LinkedIn profile, accessed August 2019
  48. Winrock International, Reducing Child Labor In Tanzania PROSPER Program, undated, accessed August 2019
  49. ECLT, [1], website, undated, accessed September 2019
  50. 50.0 50.1 ECLT, Annual Report 2018, website, accessed August 2019