employee-owners submitted a document to the Participation Office challenging those elections. In and order dated June 9, 1989, the Participation Office of the Ministry of Industry declared that the challenge to the elections was well-founded.8 50. Under these circumstances, Mr. Lagos del Campo gave an interview to a journalist from the magazine “La Razón.”9 The interview, published in June, 1989, was entitled “Patronal y Amarillos pretenden Liquidar CI” [Employers’ Association and Company Unions Want to Liquidate CI], and it stated that ¨ Alfredo Lagos del Campo, the president of the electoral committee of the company’s Industrial Community and full delegate to the CONACI [National Confederation of Industrial communities], complained publicly and to the competent authorities of maneuvers by the employers’ association to liquidate the company, using the hesitation of some workers to hold fraudulent elections outside the Electoral Committee and without the majority participation of the employee-owners.¨ 51. The following statements were attributed to the worker: Mr. Lagos, did you agree with the call for elections? I did not, because the company’s Board of Directors has used, and continues to use, blackmail and coercion against the employee-owners, pressuring a particular group of workers to take part in the elections under threat of dismissal. Do you consider the elections to be legal? No, they are not legal. […] In my capacity as president of the Electoral Committee, it was my responsibility to call [the elections]. Nevertheless, management convened three members [of the Committee], and in the industrial relations office—just imagine—in the office of the employers’ association, they called elections for the community, making a mockery of all the legal provisions, and using a group of employee-owners subservient to their interests. With those people they put together a list that was the only one submitted for the elections. Why did the employee-owners not submit another list? For one simple reason: the law on Industrial Community elections established that every list must be made up of employee-owners including both salaried workers and laborers. I would like to clarify something very important. The laborers have a union; this provides them with protection and relative independence. The salaried workers do not have a union (they used to have one, but it was dissolved by the employers’ association, and that is the fault of the employees themselves, for not knowing how to defend their rights). These employees are at the mercy of the employers’ association, and they are under constant threat of blackmail by management. That is why they are afraid to be on a list made up of laborers, who do not enjoy the sympathy of the owners. I think this was the fundamental reason why another list was not submitted. In light of these abuses by the employers’ association, what measures have you taken as president of the electoral committee? First, I have complained of the irregularities that have been encouraged and used by the employers’ association. I submitted this complaint in Official Letter No. 005824 to the Participation Office of the Ministry of Industry and Commerce. What has been the response of the Ministry? Here I must denounce that the Ministry’s bureaucracy responded vaguely, without making any determination, which shows that there is an understanding between the Participation Office that it (sic) managed by Alicia Liñan Núñez and the employers’ association. What measures do you plan to take? 8 Annex 7. Lawsuit filed by Mr. Alfredo Lagos del Campo for wrongful dismissal before the Labor Court of Lima. July 26, 1989. Attachments to the petitioners’ communication of July 23, 1998. 9 Annex 5. La Razón. June 1989. CEPER. Patronal y Amarillos pretenden liquidar CI, p. 10. Attachments to the petitioners’ communication of July 23, 1998. 9

Select target paragraph3