Holding the EBRD accountable for human rights violations
In 2021, Indorama Agro secured USD 130 million in loans from the EBRD and the International Finance Corporation (IFC) to modernise cotton production and enhance environmental and operational standards. However, the project has faced intense scrutiny over allegations of human rights violations and retaliatory actions against workers and independent rights monitors.
In 2023, after three years of engaging with multilateral development banks and Indorama Agro management, the Uzbek Forum for Human Rights (Uzbek Forum) and Bankwatch filed a formal complaint with IPAM. The complaint detailed grave concerns, including land confiscations, loss of livelihoods for local farmers, mass lay-offs, exploitative labour practices, reprisals against workers, union-busting tactics, and inadequate environmental and social impact assessments.
In November 2024, IPAM deemed these allegations credible and initiated an investigation, which is expected to conclude by the end of 2025. The review will assess whether the EBRD acted in accordance with its environmental and social policy. If the EBRD is found to have violated its own performance standards, IPAM will make recommendations to EBRD management to ensure project compliance and remedy the harm done.
Notably, this is the second complaint filed against Indorama in Uzbekistan to the accountability mechanisms of multilateral development banks. In 2016, Uzbek Forum submitted a complaint to the IFC’s accountability mechanism, alleging the use of child and forced labour by Indorama Kokand Textile throughout its supply chain.
Economic displacement of thousands
In 2018, the Uzbek government transferred 54,000 hectares of land in the Kashkadarya and Syrdarya regions to Indorama Agro. Project impact assessment documents indicated that this decision would potentially affect 1,068 farms, leading to the economic displacement of 5,418 permanent workers and the loss of 9,070 seasonal jobs. Indorama Agro claimed the land was acquired through negotiated settlements with affected farmers, who were offered employment in exchange for terminating their land lease agreements – an arrangement to which the farmers ‘voluntarily’ agreed. However, independent rights monitoring revealed that farmers whose land leases were terminated were given no choice but to sign voluntary land lease terminations under threat of penalty by local authorities. A recent report on land grabbing in Uzbekistan documents cases where farmers did not even know they had lost their land until they arrived at their fields. Because the land lease terminations were deemed voluntary, there was no obligation on the part of the company or the government to pay compensation for losses or damages, including loss of profit.
A 2020 livelihood restoration plan commissioned by Indorama Agro proposed employment as the primary mitigation measure despite evidence that many affected households either declined job offers or were excluded due to reduced labour demand. The document revealed a significant lack of data on project-affected people, calling into question the EBRD and IFC’s due diligence and the effectiveness of proposed mitigation measures.
Nevertheless, both the EBRD and IFC approved loans to Indorama Agro, attaching conditions for livelihood restoration outlined in an environmental and social action plan. By March 2021, Indorama Agro was required to profile affected farm leaders and workers, assess impacts, and develop a revised livelihood restoration plan. Although these conditions had not been met by then, funding was disbursed regardless.
Limited livelihood restoration
The updated livelihood restoration plan, eventually disclosed in May 2024, revealed that 1,062 farms were affected. These were classified as small businesses, averaging one full-time equivalent worker per 10 hectares of cotton land. However, the plan focused solely on the livelihood restoration of farm leaders, excluding farm workers who lost access to land and employment. In fact, the land had been used not only for cotton farming but also for grazing livestock and cultivating vegetables, providing sustenance for entire families. As a result, the loss of land had far broader economic consequences beyond the loss of employment.
Yet, Indorama Agro identified only 1,062 individuals as project-affected, considerably fewer than the at least 5,418 farmer workers impacted by the land appropriation. The number of project-affected people was further reduced for various reasons, with only 90 individuals ultimately acknowledged as eligible for livelihood restoration benefits. Notably, pensioners were excluded on the basis that they receive a monthly pension of approximately USD 58, which was deemed sufficient to sustain their livelihood.
The livelihood restoration measures proposed by Indorama Agro included providing greenhouses, establishing horticulture initiatives, and covering vocational training costs. However, rural residents previously reported that many greenhouses were poorly constructed and collapsed soon after completion. Others stated they were unaware of the greenhouses or how to access them. Additionally, the company’s proposal to engage affected people in silk farming through mulberry plantations has drawn criticism since the silk sector remains under government control and relies on the forced labour of farmers to produce silkworm cocoons.
Concerningly, the company has yet to conduct a comprehensive analysis of the individuals affected by the project, including gender-disaggregated data and other vulnerability criteria, as well as a clear justification for the proposed eligibility criteria. Overall, previous efforts and current measures have not been adequately assessed, casting serious doubt on the sufficiency of the proposed livelihood restoration plan.
Years of exploitative working conditions
Out of almost 15,000 permanent workers and seasonal jobs affected by the project, only 575 individuals were employed by Indorama Agro. Since the project began, there have been regular reports of mass redundancies, low wages, exploitative working conditions, and the misclassification of employees as ‘service providers.’ These ‘service providers’ were given new contracts under a scheme called ‘Nano Unit Contractor’ (NUC), which significantly reduced their rights and benefits, including their eligibility for membership in the trade union. These issues raise questions about whether the economic benefits of working for Indorama outweigh the loss of farmers’ livelihoods. The company has also been implicated in actively undermining Uzbekistan’s only known democratically elected trade union, established in March 2021.
Independent labour assessments conducted at the request of the lenders revealed multiple deficiencies: payment inconsistencies, a lack of transparency and direct communication about contractual changes, misuse of civil contracts, lack of workers’ access to their contracts, excessive shifts and unrecorded overtime, unsafe working conditions, intimidation, and ineffective grievance mechanisms.
The assessment identified flaws with Indorama Agro’s operational health and safety measures, including improper use of personal protective equipment for handling fertilisers and chemicals, weak oversight, such as inadequate inspections and enforcement of safety protocols, insufficient worker training, the absence of fire prevention equipment and evacuation plans, and a lack of accessible information on chemicals management in the Uzbek language. In particular, improper storage and handling of hazardous materials were underlined.
Workers hired by so-called nano unit contractors faced significant challenges concerning working conditions, including inadequate equipment, food, and hygiene facilities, and delayed wages. Female workers lacked separate dressing facilities. Fear of contract termination discouraged these workers from expressing complaints, and the company reportedly failed to adequately supervise or protect their rights.
Ongoing retaliation
Over the past three years, civil society organisations have documented at least 80 retaliation cases against Indorama Agro workers and monitors. Security services, government officials, and company representatives have systematically harassed and intimidated those who attempt to speak out, making it extremely difficult to document these rights violations. Workers and farmers have faced threats and coercion, while security agents have physically obstructed them from attending labour rights workshops and union activities. Human rights monitors have also been threatened with criminal charges for their legitimate work in monitoring the project.
The evidence unequivocally demonstrates widespread human rights violations at the Indorama Agro cotton project and non-compliance with EBRD and IFC safeguards, which have not been adequately addressed. The IPAM investigation is a crucial step to secure effective remedial measures for all project-affected farmers and workers in Uzbekistan, as well as institutional learnings for the EBRD to prevent similar situations in the future.