Introduction

International migrant workers play an increasingly important role in the global economy (Martin 2016). Currently, there are approximately 258 million international migrants in the world and 164 million working in the country to which they have migrated (Popova and Özel 2018), which is 4.7% of global workers (Popova and Özel 2018). Migrant workers are concentrated in the construction, domestic service, hospitality, and agriculture sectors (Lewis et al. 2015).

Migrant agricultural workers play a critical role in global agriculture and food security. Many countries rely on agricultural migrant workers to meet the labor supply that cannot be filled from within their population. This gap in domestic labor is due to demographic changes such as market segmentation, an aging population, and/or disinterest in working in agriculture (International Organization of Migration [IOM] 2020a) and is prominent in high-income countries, such as Canada, the USA, Italy, Spain, Germany, and Australia (Popova and Özel 2018; Martin 2016). Some countries in the Global South (e.g., Thailand) that are more economically developed than other countries in the region have begun to rely heavily on migrant agricultural workers to meet the agricultural labor supply (Bylander 2019). As a result, countries have developed labor migration programs to enable the entrance of essential workers into the country during peak demands of planting and harvesting, bringing with them vital skills and knowledge (Martin 2016). However, despite the critical role migrant agricultural workers play in food production and security, many workers face abuses, exploitation, and precarious employment (Lewis et al. 2015).

Agricultural employers seek flexible contracts and temporary forms of employment to meet labor demands while keeping expenses low (IOM 2020a; International Labour Organization 2019). This flexibility, and seasonal nature of the work, creates challenges when creating and enforcing effective labor migration policies (ILO 2019) and as a result many migrant agricultural workers live and work in precarious circumstances (Augre-Granier 2021), such as poor pay, dangerous working conditions, extremely long working hours, poor living conditions, and a lack of critical personal protective equipment (PPE) (Augre-Granier 2021; Bylander 2019; Hennebry 2012; ILO 2019; Kaur 2010; Lewis et al. 2015). As international migration continues to increase (Martin, 2016), the abuses and exploitation of agricultural migrant workers may become increasingly concerning without vast improvements to national labor migration policy.

The arrival of COVID-19 in 2020 limited the movement of many migrant agricultural workers around the globe, which created a shortfall in migrant agricultural labor that has become the cornerstone of the sector (Dias De Vasconcelos and Pettigrew 2021). Many farmers decided not to plant their crops to avoid further losses and some watched their crops rot in the fields due to insufficient harvesting labor. The agricultural labor shortfall impacted farmers, workers, consumers, and national food security in many countries (Dias De Vasconcelos and Pettigrew  2021). The global impact of COVID-19 also further exacerbated the abuses and exploitation faced by migrant agricultural workers, shining a spotlight on the shortcomings of labor migration policies (IOM 2020a).

In late 2020 the European Office of the World Health Organization (WHO) released a report promoting the health of migrant workers within Europe in response to the COVID-19 pandemic (WHO Europe 2020). The WHO report provides strong policy recommendations, but given its strict focus on Europe, we draw from the International Labour Organization (ILO) policy brief, which focuses on establishing labor standards for migrant workers globally (ILO 2020). The ILO released their policy brief in April 2020 describing specific actions policymakers should take to increase the protection of migrant workers from COVID-19 (ILO 2020). The brief describes migrant workers as among the most vulnerable due to, but not limited to, xenophobia, inadequate living conditions, non-payment of wages, and increased restrictions on movement. To mitigate the risks that COVID-19 poses to migrant workers the ILO highlighted three key actions (ILO 2020) for policymakers, including (1) the inclusion of migrant workers in the COVID-19 policy responses (e.g., income support, health care access, information, ensuring regular status, address housing hazards, legal supports); (2) extending supports to workers and their families to ensure workers “protection, safe return, and effective reintegration into labor markets” (ILO 2020, p. 5); and (3) ensure the voices of workers and worker support organizations are included in the dialogue contributing to the country-level response to COVID-19 (ILO 2020).

As the ILO represents the international community on labor standards and global workers’ rights, these policy guidelines present important considerations for policymakers around the globe as COVID-19 policy responses were being drafted. The WHO and ILO recommendations behooves countries, including Thailand, Italy, and Canada to review and revise their labor migration policies to become more sustainable, with a greater focus on migrant labor and human rights, especially in times of crisis.

Aim of the study

The purpose of this paper is to review and compare the national labor migration policies of Thailand, Italy, and Canada and evaluate each country’s COVID-19 response and treatment of migrant agricultural workers. Although many countries share the need for migrant agricultural workers, this paper prioritized the review of countries with different labor migration policies, from different continents, economic levels, and representation from the Global North and South. The purpose of this paper is therefore to answer the following research questions:

  1. 1.

    How do the migrant agricultural worker policies and demand in Thailand, Italy, and Canada compare?

  2. 2.

    What was the efficacy of the policy responses to COVID-19 in Thailand, Italy, and Canada and how did they compare?

  3. 3.

    Is the treatment of migrant agricultural workers similar in Thailand, Italy, and Canada and did COVID-19 impact these experiences?

Methods

To explore the migrant agricultural policies and context of Thailand, Italy, and Canada, country-level responses to COVID-19, and treatment of migrant agricultural workers we used the documentary method (documentary research method). Therefore, we review publicly accessible documents about government migrant labor policies, shifting legislation, and migrant worker experiences during COVID-19. The documentary method has been employed in diverse fields with a variety of data material (Schmolz 2020). The data material used in this research includes publicly accessible government policies, statistics, reports, international body reports (e.g., WHO, ILO, United Nations), news articles, and advocacy group reports. In addition, we conducted a secondary analysis of peer-review literature and country-level and global data. Per documentary method best practices, materials were assessed for credibility, representativeness, meaning, and authenticity (Payne and Payne 2004).

Our approach included first formulating an interpretation by reading through all data materials, per country, to gain an overview of the content and develop initial themes (Bohnsack, 2014). Followed by the second step of reflective interpretation (Reischl and Plotz 2020), exploring the how and why. The third step involved case description per country where we conduct a thorough context of migrant agricultural worker history, policies, and statistics and then describe the impact of COVID-19 on policies and treatment of migrant agricultural workers. This step allows us to summarize the discourse of the documentation available in the public sphere on COVID-19 and migrant agricultural workers. Then our fourth and final step, upon the completion of the three country case studies, we conducted a comparative analysis (Reischl and Plotz 2020) to explore the themes emerging between countries. We review how each country’s policies, COVID responses, and treatment of migrant agricultural workers are in alignment or differ from one another.

Case description per country: Thailand, Italy, and Canada

In this section, we begin by describing the historical context and legislated policies concerning migrant agricultural workers per country. Then, the findings per country are summarized to illuminate what the publicly available documents, including legislated policy, government reports, news media, and international bodies, are reporting regarding the experiences of migrant agricultural workers during COVID-19. We begin with Thailand.

Thailand

Labor migration in Thailand began in the 1980s and 1990s when the Thai economy shifted from less-skilled, intensive labor to more high-skilled, technology-driven jobs (Chalamwong et al. 2012). Many Thai citizens began transitioning to skilled labor, in urban areas, to meet the growing demand (Pholphirul 2012). Societal shifts impacted the available workers in the agricultural sector (ILO 2021), where migrants plant, harvest, and spray fertilizers for crops, such as rice, corn, palm oil, sugar cane, cassava, and rubber plantations (Thetkathuek and Daniell 2016). In the mid-1990s, Thailand began to rely heavily on migrant laborers from bordering Southeast Asian countries (Tipayalai 2020), specifically Myanmar, Cambodia, and Laos (Kaur 2010).

In addition to this labor shift, other factors such as political instability, lack of employment opportunities in their countries of origin, and the large wage differential between Thailand and Myanmar, Cambodia, and Laos resulted in a dramatic increase of migrant workers between the mid-1990s and early 2000s (Chalamwong et al. 2012). Thailand’s government struggled to regulate the rapid flow of migrants, which led to high levels of irregular (i.e., illegal or undocumented) migration. An estimated 3,000,000 migrants crossed illegally into Thailand during this time (Tipayalai 2020). In an attempt to curb illegal migration and regularize the migration process, Thailand created two distinct procedures: the migrant worker registration periods and memorandum of understanding (MoU). (Mekong Migration Network 2020).

Thailand’s migrant worker policies and demand

Registration periods

In the late 1990s, Thailand initiated a registration system allowing migrants from Myanmar, Cambodia, and Laos to legally register to work in specific industries and provinces (Mon 2010). Registration periods, held every few years, hoped to reduce the number of irregular migrants by allowing those already working irregularly to register without penalty. Once registered migrants work legally in Thailand for up to 2 years without having to return home (Mekong Migration Network 2020). Registration periods proved to be effective, with the latest period ending in 2018 regularizing over 1.2 million migrants (IOM 2019). Despite the registration period’s relative success in reducing the number of irregular migrants, some aspects negatively impacted migrant workers.

Memorandum of understanding

The second form of migrant legislation in Thailand is the MoU signed with Myanmar, Cambodia, and Laos (Bylander 2019). The MoU created formal migration channels and legal processes Thai employers could use to recruit migrant agricultural workers (Mekong Migration Network 2020) but have been relatively ineffective in increasing regular migration. In 2018, only 850,302 workers had registered entry through MoU, which is much lower than the 2,214,298 migrant workers gaining work permits through registration periods (IOM 2019). The number of irregular workers is still high in Thailand. Of the 3.9 million foreign workers, 811,437, or 20%, are undocumented migrants. Furthermore, it is estimated that 73% of Cambodians, 96% of Lao, and 91% of Myanmar migrants entered Thailand irregularly (IOM 2019).

The extreme cost and wait times faced by migrant workers render the MoU ineffective (Kaur 2010). At regulated border crossings, migrants are required to complete considerable paperwork which leads to delays and large costs for the migrant. In 2020, a 2-year work visa cost $2,900 Thai Bhat, which employers sometimes deduct from migrants’ pay. Migrant workers’ typical daily wage is $120–$150 Thai Bhat ($3.50–$4.50 USD) (Mekong Migration Network 2020), making paying migration fees nearly impossible and disincentivizes legal entry.

Migrant workers can wait 6 months to a year before being legally allowed to work in Thailand (Bylander 2021). In contrast, those crossing illegally into Thailand did so 78 days faster and for an average of $286 USD less (IOM 2019) than those arriving through regular pathways. Therefore, irregular channels into Thailand are faster and less expensive for workers, making it more appealing.

In 2017, Thailand introduced restrictive policies to crack down on irregular labor migrants (Bylander and Reid 2017). As a result, migrants who registered required both permission from their employer to change jobs and to check in with government authorities every three months. This new restriction made it more difficult for documented migrants to change employers, which lead to increased abuse by employers and disincentivize some migrant workers from registering (Bylander 2021).

Thailand’s response to COVID-19

On March 25, 2020, Thailand declared a state of emergency to help control the spread of COVID-19 (Khaliq 2021). Following the declaration, thousands of migrant workers attempted to return home (e.g., Cambodia, Laos, and Myanmar) (IOM 2020b). Due to Thailand’s heavy reliance on migrant labor and the rapid exodus of migrant agricultural workers, Thailand faced severe labor shortages (Leadholm 2020), which strained both Thailand and the wider Southeast Asian supply chain, impacting food security (Gilmour and Lin 2021).

The COVID-19 restrictions exacerbated the abuses and exploitation migrant agricultural workers already faced. Agricultural migrant workers are offered sparse benefits or protections (Gilmour and Lin 2021) and often have no access to sick leave, unemployment benefits, and health benefits. Many migrant agricultural workers also faced precarious situations making them particularly vulnerable to contracting COVID-19. Moreover, migrants in Thailand faced extreme prejudice and were often blamed for bringing the virus to Thailand (Marschke et al. 2021). This prejudice led to questionable policy steps made by Thai government and employers, including putting both COVID-19-positive and negative migrant laborers in the same living quarters, which lead to COVID-19 outbreaks among migrant workers throughout the country (Marschke et al. 2021).

In response to a large COVID-19 outbreak, linked to Burmese migrant seafood workers, the Thai government announced on December 29, 2020 that all undocumented migrant workers could register for a two-year work permit (Wongsamuth 2020). The goal of the policy was to curb COVID-19 spread among migrant workers, as irregular workers would no longer have to move between provinces to avoid persecution (Wongsamuth 2020). As of February 2021, 654,864 migrant workers gained amnesty in this way (ILO 2021). This regularization decree, which was a critical piece to the Thai government’s COVID-19 response strategy for migrant workers, was aligned with the ILO recommendation to ensure migrant workers maintain or become regularized. The IOM (2021) found that this strategy was critical as regularized migrant workers were more likely to receive COVID-19 testing, treatment, and vaccinations, all helping curb the spread of COVID-19. However, despite some successes, this regularization also brought significant challenges to migrants seeking regular status. First, the regularization process was employer driven and forced migrants through multiple steps for which they were required to cover the financial cost (IOM 2021). In addition, migrants would not have the opportunity to become legally documented if the employer did not want to register them, which was common among employers that employed irregular migrants. The combination of this program being employer driven and overly expensive made gaining and maintaining regular status difficult for many migrant workers (IOM 2021). Furthermore, migrants have continued to enter Thailand illegally despite increased government enforcement (Charoensuthipan 2021), as this registration period has proved to be only a temporary solution. The Thai government also failed to implement inclusive policies that ensured migrant workers had reliable access to social protection and healthcare, while also failing to provide adequate living conditions. In a study that interviewed migrant workers in Thailand, Kunpeuk et al. (2022) found that many migrant workers did not have access to social or health services and were in overcrowded living conditions. They found that migrant workers in Thailand were “disproportionately affected by COVID-19” (Kunpeuk et al. 2022 p. 11). For Thailand to reduce irregular migration, effort must be invested to reduce the burdens and costs migrants face when attempting to work in Thailand as well as create more inclusive policies and access to social and health security for migrants.

Italy

Italy’s agricultural sector has long ties to labor migration (Rye and Scott 2018). Beginning in the 1960s, Italy’s economy began to industrialize and shift to the tertiary economic sector (Corrado 2018). During this time, Italians pursued higher levels of education, which led to many Italians moving from the field to the office (Devitt 2018). In the 1990s, the Italian population also began to decline, impacting the number of Italians in the labor market. The combination of social, demographic, and economic factors led to a dramatic drop in employment in Italy’s agricultural sector (Devitt 2018).

Migrants from developing countries began entering Italy in the 1970s and increased rapidly into the 1990s replacing Italian workers exiting the industry (Devitt 2018). By 2015, an estimated 405,000 labor migrants were working in the agricultural sector, accounting for 50% of the sector workers; however, an estimated 80% do not have formal contracts (CREA 2017).

In Italy, the largest proportion of migrant workers come from Romania, India, Albania, Morocco, Poland, and Bulgaria, with smaller numbers coming from South Asia and North, West, and Sub-Saharan Africa (Corrado 2017). There are distinct differences in both the types of agricultural work and local culture, leading to regional differences in workers’ experiences. While all of Italy sees irregular migrants, Southern Italy has higher levels of irregular migration, as it is highly seasonal and requires large amounts of casual labor (Corrado 2018). Most employers use the “just in time” method (Perrotta 2015, p. 4), moving migrants throughout Southern Italy following the harvest and production of fruits and vegetables (Perrotta 2015). This intense demand for flexible labor in Southern Italy fosters exploitative conditions for migrants, compared to more stable and long-term working conditions in Northern Italy (Corrado 2018). Over the last 30 years, Italian policies have struggled to address this challenge of irregularity.

Italy’s migrant worker policies and demand

Italy’s labor migration policy consists of two key acts: the 1998 Consolidated Act on Immigration and the 2002 “Bossi-Fini Law” (Amnesty International 2012). The 1998 Consolidated Act on Immigration was responsible for regulating the flow of migration into the country and is used to determine the quota defining the number of migrant workers granted entry each year, also known as the Flows Decree (Amnesty International 2012). Then in 2002, the Bossi-Fini law, named after leaders of the Lega Nord and Alleanza political parties who enacted the law, introduced the most restrictive immigration policies yet in Italy (O’Healy 2019). Since the increase of immigration into Italy beginning in the 1960s, governments have struggled to produce effective immigration policies dealing with migrant workers. The failure to introduce an effective immigration policy helped lead to an influx of undocumented migrant workers into the country, especially in the 1990s (Colombo and Sciortino 2003). Just before the passing of the Bossi-Fini law it was projected that there were one million irregular migrants in Italy (Paparella and Rinolfi 2002). Some people, in large part due to narratives by political parties, such as the Lega Nord, became increasingly intolerant of migrants, especially those who were not legally documented (Paparella and Rinolfi 2002). This messaging and intolerance toward migrants played a significant role in the creation of the Bossi-Fini law. This is clearly demonstrated during the initial introduction of the bill that states that immigration is destructive to the current Italian social order (Colombo and Sciortino 2003). Both the growing intolerance for migrants and the massive increase in illegal migration led to the passing of the Boss-Fini law in 2002, which enacted strict measures to influence the flow of labor migrants into Italy (Caponio and Cappiali 2018). Some of the new measures included ensuring migrants established their residence, place of work, and a long-term contract before being granted a seasonal permit (Ambrosini and Triandafyllidou 2011). The Bossi-Fini law was created to decrease the number of irregular migrants that were in and coming into Italy (Paparella and Rinolfi 2002); however, despite its strict measures, the Bossi-Fini law failed to solve the issue of irregular migration in Italy (Amnesty International 2012; Caponio and Cappiali 2018). This is in large part due to its failure to address the policy issue further discussed below.

The volume of irregular migrants in Italy is generally attributed to two policy-related factors: the annual quota system and the complexity of the process. First, the annual quota system fails to meet employer demand for migrant agricultural workers (Amnesty International 2012). Since 2011, the government annual cap for seasonal workers allowed via the Flows Decree system has been cut in half (Corrado 2018), despite increasing demand for migrant labor. Second, the process to obtain a seasonal work permit is complex and long, taking up to 9 months to process (Lopez-Sala et al. 2016). Both the complex process and an insufficient number of permits granted push employers to seek irregular workers to meet their labor demands (Tagliacozzo et al. 2020).

To fill the labor gap, the recruitment and control of migrant labor, most notably in Southern Italy, are managed by an illegal group known as caporalato, which translates to gangmasters in English (Tagliacozzo et al. 2020). While the caporalato’s role in Southern Italy’s informal economy predates the migrant labor boom, their focus has shifted to recruitment and control of migrant labor in the region (Tagliacozzo et al. 2020), acting as intermediaries between migrant agricultural workers and employers (Corrado 2018) and arranging transportation and housing migrants between locations (Perrotta 2015). In 2015, researchers inspected 8862 Italian agricultural companies and noted 6153 irregular workers and over 700 instances of caporalato involvement (Corrado 2018).

Italy periodically introduced regularization periods during which irregular migrants can become documented (Corrado 2018). However, regularization periods fail to solve the root of Italy’s migrant policy problems and put a disproportionate amount of power in the hands of the employer. Demonstrated in the regularization period of 2009 only allowed employers, not migrants, to apply for registration (Amnesty International 2012) which ultimately gave employers complete power over the migrant agricultural workers and impacted the effectiveness of this program.

Irregular workers have less power to negotiate pay and working conditions and are more vulnerable to coercive employer behaviors, leading to forms of forced labor. Irregular migrants are also paid lower wages than Italian workers, with some migrant agricultural workers making 40% less than their Italian counterparts (Amnesty International 2012). Living conditions are also extremely poor for many migrants, both regular and irregular, especially those from sub-Saharan Africa who sometimes stay on abandoned farms (Ceccarelli and Ciconte 2018; Perrotta 2015), with substandard living conditions (Tagliacozzo et al. 2020).

Italy’s response to COVID-19

Italy declared a state of emergency on January 31, 2020, attempting to curb the spread of the COVID-19 throughout the country (France24 2020). Italy quickly closed its borders and many migrant workers attempted to return to their countries of origin (Barcaccia et al. 2020). Many Eastern European migrant agricultural workers were unable to return to Italy in the spring due to travel restrictions (Pietromarchi 2020), which led to a projected shortage of 250,000–275,000 casual migrant agricultural laborers (Bathke 2020), thus forcing Italy to draft measures to facilitate migrant worker return.

In alignment with the ILO action guidelines (ILO 2020), in May 2020, Italy enacted a decree to regularize current irregular workers (Palumbo and Corrado 2020), which intended to “guarantee adequate protection of individual and collective health” and “facilitate the emergence of irregular employment relationships’’ (Human Rights Watch (HRW) 2020, para. 4). The regularization policy began on June 1, 2020 and had two channels through which migrants could apply (Palumbo and Corrado 2020). The first channel targeted migrants already residing in Italy (pre-March 8) and focused on employer sponsorship to capture those already working irregularly. The second channel was a jobseeker permit, available to individuals who became undocumented before or on October 31, 2019 (HRW 2020). The program ended in August 2020, with limited success, as just over 31,000 agricultural migrants applied for a permit using the first channel, and only 12,986 workers in both agriculture and home care applied through the second channel (HRW 2020). Similar to Thailand, while the overarching idea of a regularization program aligned with the ILO policy recommendations (ILO 2020), numerous issues with the structure of the program limited its overall effectiveness.

Several limitations in the program led to low application rates among agricultural workers. First, the regularization plan was not enough to convince some employers to regularize relationships with their migrant agricultural workers (Palumbo and Corrado 2020). Second, some employers requested migrants pay the 500 Euros registration fee to regularize (Cizmic 2021), which was supposed to be paid by employers, but 44% of workers surveyed reported they were forced to pay (HRW 2020). As many migrants could not afford this registration cost, they were unable to legally register despite being willing.

Finally, reports indicate that regularization did not improve the working conditions for migrants (ANSA 2020). Reports of exploitation increased 10–15% during COVID-19 in 2020 (ANSA 2020). Outbreaks were detected among migrant laborers in Southern Italy, including Bulgarian farmworkers and workers in an industrial meatpacking plant. Outbreaks were largely due to poor living conditions and lack of access to PPE (Palumbo and Corrado 2020). Furthermore, due to mobility restrictions, undocumented migrants were not allowed to move to find new job opportunities (Sanfelici 2021) and were also not eligible to be part of the Ordinary Wage Guarantee, a sustenance program offered to 7 million Italian workers (Sanfelici 2021), pushing workers to continue to work due to lack of social protection (Tagliacozzo et al. 2020).

Failures by policymakers to include irregular agricultural migrant workers in this national income guarantee and social protection directly contradicted the ILO’s policy recommendations (ILO 2020). It also significantly increased hardships on all types of migrant workers; those who lost their job now had no access to any income source (Sanfelici 2021). In addition, the Italian government made little attempt to improve the living conditions of migrant agricultural workers during COVID-19 (Carlotti, 2020), again failing to follow ILO policy recommendations (ILO 2020). It is clear that despite attempts to regularize migrants and improve living conditions, COVID-19 highlighted the weaknesses in Italy’s migration policy and increased mistreatment of migrant agricultural workers.

Canada

Migrant workers have also become an essential part of Canada’s agricultural sector (Caxaj and Cohen 2019). In the middle of the twentieth century, the demand for industrialization, shift to urbanization, and demographic changes meant farmers could no longer rely on domestic workers to meet labor demand (Hennebry 2012). Canadian farmers requested an increase in foreign labor to help stay competitive with other nations, such as the USA, already using foreign worker programs (Hennebry 2012). In response, the Canadian government introduced the Seasonal Agricultural Worker Program (SAWP) in 1966 (Basok and López-sala 2016), which has become the primary avenue for labor migration in Canada’s agriculture sector.

Today, over 69,000 migrants enter Canada to work in agriculture, representing roughly 20% of the sector workers (Statistics Canada 2020). Migrant agricultural workers are primarily found in Canada’s horticulture industry, which includes fruits, vegetables, nurseries, and greenhouses (Statistics Canada 2020). A majority of migrants come from Mexico, Jamaica, and other Caribbean and Latin-American countries (Gabriel and Macdonald 2018). Although all provinces and territories receive migrants (Hennebry 2012), the largest proportions work in Ontario and British Columbia, where labor-intensive crops are most prevalent (Caxaj and Cohen 2019). While some features of Canada’s labor migration policies are considered successful (Basok 2007), many also recognize Canadian policies’ negative impact on migrant agricultural workers (Caxaj and Cohen 2019; Hennebry et al. 2016; Preibisch and Otero 2014; Vosko, 2015). While Canada’s policies are strong in minimizing irregular migration, the structure of the policies creates a state of precarity and vulnerability to potential abuse for migrants (Caxaj and Cohen 2019; Gabriel and MacDonald 2011; Horgan and Liinamaa 2017).

Canada’s migrant worker policies and demand

Canada’s temporary and seasonal labor migration policy is governed through two specific programs: the SAWP and the agricultural stream of the Temporary Foreign Workers Program (TFWP) (Haley et al. 2020). The original and largest of the two streams is the SAWP (Haley et al. 2020) which was founded in 1966. Currently, 12 countries participate in the SAWP (Government of Canada 2021).

The SAWP is founded on an MoU (Reed 2008). The agreements create formal intergovernmental relationships outlining the regulations for recruiting, hiring, and employing workers. In this bilateral agreement, each government has a role in administering the program. Canadian farmers request workers through federally sanctioned bodies (Hennebry 2012) and the sending country’s government recruits the workers (Basok and López-sala 2016). Each sending country is responsible for maintaining a pool of potential workers, ensuring the workers’ documentation, and appointing consular representatives to support workers while in Canada (Government of Canada 2021). Under the SAWP, migrant agricultural workers are limited to contracts no longer than 8 months (Zhang et al. 2021), which forces each migrant worker to return to their home country each year.

As a result of constraints of the SAWP and the increased use of greenhouses resulting in year-round demand for labor (Gabriel and Macdonald 2018), the Canadian government created an agricultural stream of the TFWP in 2011 (Gabriel and Macdonald 2018) that allowed 1-year work permits with an opportunity to extend (Strauss and McGrath 2017). TFWP differs from the SAWP because employers can recruit migrant agricultural workers directly and therefore employers often use recruitment agencies (Hennebry 2012). The TFWP does not restrict recruitment from specific countries, which has led to an increase in agricultural workers from India and Guatemala (Caxaj and Cohen 2019).

Canada’s labor migrant policies for the agricultural sector have been seen as successful in maintaining a very small overstay rate (1.5%), (The World Bank 2006). Its cooperation with partner countries, and providing access to healthcare for migrants have been noted as model practices (Hennebry and Preibisch 2012); however, there are also concerns with Canada’s labor migrant policy. Canada’s policies create a precarious status for migrant agricultural workers (Gabriel and MacDonald 2011). In addition to workers’ temporary status, policies create a power imbalance between workers and the employer in two ways. First, policy limits access to permanent residency for migrant agricultural workers (Gabriel and Macdonald 2018; Hennebry 2012). Second, a performance evaluation from the migrant’s employer is the primary criteria for workers to be allowed to return the following year (Binford 2019). Therefore, a poor evaluation can result in an inability to return the following year (Preibisch and Otero 2014), leaving the worker beholden to their employer. This gives the employer a disproportionate level of power over the worker ultimately leading to exploitation, labor rights abuses, and discrimination (Horgan and Liinamaa 2017) and minimizes workers’ complaints since complaints might risk poor evaluations (Perry 2018).

In both the SAWP and TFWP agricultural streams, employee work permits are tied to a single employer (Hennebry 2012). As a result, migrant agricultural workers’ ability to stay in Canada is tied to a single employer and those experiencing mistreatment often cannot seek alternative employment. Workers who complain or are unable to work risk deportation before the end of their contract (Horgan and Liinamaa 2017) and threats of deportation are common (Basok et al. 2014). Per the bilateral agreements, the sending country’s consular service is responsible for supporting employee complaints; however, migrants commonly note consular officers focus on appeasing employers instead of protecting the rights of the migrant (Caxaj and Cohen 2019).

Finally, the SAWP mandates migrant agricultural workers’ living accommodations are on the employer’s property (Depatie-Pelletier 2010), which can be problematic for workers’ rights and integration. Employers are often located in rural areas, isolated from nearby communities, and lack public transportation, which creates dependence on employers to transport migrants to receive basic necessities, such as food, healthcare, and groceries (Horgan and Liinamaa 2017). This reliance allows employers to control employees’ schedules and activities, severely limiting their social interaction, and integration into local communities and Canadian society. Although not-for-profits supporting migrant agricultural workers exist, workers’ inability to build social networks increases migrants’ vulnerability, relying solely on fellow migrant agricultural workers (Caxaj and Cohen 2019). Furthermore, living conditions in some migrants’ housing are poor with overcrowding, inadequate sanitation, and lacking indoor plumbing (Preibisch and Otero 2014). Migrant agricultural workers face the threat of deportation, poor working conditions, power imbalances, and social isolation, suggesting Canada’s labor migration policy is failing to protect migrant agricultural workers.

Canada’s response to COVID-19

By March 22, 2020, all 10 provinces and 3 territories in Canada had declared states of emergency in response to COVID-19 (Canadian Civil Liberties Association 2020). Given the bulk of workers arrive in spring for planting, the timing dramatically affected both migrant agricultural workers and farmers (Dias De Vasconcelos and Pettigrew 2021). Due to border closures, many migrant agricultural workers were unable to enter Canada or chose to stay home to mitigate personal health risks (Bolongaro and Hagan 2020), which created a sizable shortage of laborers (Bolongaro and Hagan 2020). March 2020 saw 43% fewer temporary foreign workers coming into Canada compared to 2019 (Falconer 2020). Attempting to mitigate the labor shortage, on March 26, 2020, the Canadian government announced migrant agricultural workers would still be welcomed in Canada (Curtain 2020). However, a labor shortage remained, with many employers putting increased pressure on the migrant agricultural workers present, which led to increases in labor rights violations and hazardous conditions (Landry et al. 2021).

Canada’s COVID-19 response attempted to curb the spread of COVID-19 and to ensure the safety of migrant workers. The Canadian government also mandated a 14-day quarantine period upon arrival for all migrant agricultural workers (Office of the Auditor General of Canada 2021). They also added additional responsibilities to employers to mitigate the risk and spread of COVID-19 toward migrant agricultural workers (Office of the Auditor General of Canada 2021). However, these policies ultimately did not protect agricultural migrant workers as the government did not introduce policies to improve the health and safety of communal living spaces or the removal of barriers to healthcare (Landry et al. 2021). Additionally, most migrant agricultural workers were not eligible for the Canadian Emergency Response Benefit (CERB), which provided wage subsidies to individuals who had to stop working if they tested positive for COVID-19 (James 2021). This response is in clear contradiction to the ILO recommendation to include migrant agricultural workers in national income and social security responses. An independent audit conducted by the Office of the Auditor General of Canada (2021) found that many federal inspectors responsible for inspecting the quality of living and working conditions for migrant agricultural workers often ignored pandemic restrictions.

In 2020, over 1,100 worker complaints were submitted (Migrant Workers Alliance for Change (MWAC) 2020) and included working excessive hours, increased pace of work, and physical injuries (MWAC 2020). Some employers coerced migrant agricultural workers into signing documents restricting their right to leave the employer’s property (Thomas 2020). Migrant agricultural workers also faced increased risk and exposure to COVID-19 due to overcrowding in their bunkhouses, making quarantining and social isolation extremely difficult to perform (George and Basok 2020). In 2020, 12 percent of all migrant farmworkers in the province of Ontario tested positive for COVID-19 which resulted in three reported deaths (Faraday 2021).

Despite new, more restrictive quarantine policies in spring 2021 (Employment and Social Development Canada 2021), it seems the 2020 growing season lessons were not leveraged to improve safety for the 2021 growing season. Between mid-March and August of 2021, five migrant agricultural workers died in Canada and 4 of them were in quarantine at the time (Grant and Bailey 2021). Research found health and living conditions were substandard and living accommodations were overcrowded, making social isolation impossible (MacLeod 2021), again practices were not aligned with the ILO recommendations (ILO 2020). Furthermore, some migrants were forced to pay for their health examinations, work permits, and PPE (MacLeod 2021). Despite the increased risks faced, many migrants lacked awareness and access to COVID-19 vaccinations due to a lack of transportation and rural locations (Dryden 2021). Despite policy changes, the Canadian government has still failed to address systemic issues with its labor migration policies.

Comparative analysis of Thailand, Italy, and Canada migrant agricultural worker policies, treatment, and COVID responses

In this section, we move beyond the description of the individual cases by country and engage in a comparative analysis (Reischl and Plotz 2020) of the emerging themes related to the existing national labor migration policies impacting agricultural workers in Thailand, Italy, and Canada. We then compare the treatment of migrant agricultural workers and the efficacy of three countries’ responses to the COVID-19 pandemic.

Policy challenges and migrant agricultural worker treatment

Thailand, Italy, and Canada’s labor migration policies display several similarities, with the most prominent being the power imbalance between workers and employers, abuses migrant agricultural workers face due to the structure of labor policy, and the precarious nature of the workers.

Employer–migrant agricultural worker power imbalance

Analyzing the labor migration policy of Thailand, Italy, and Canada reveals all three countries either directly or indirectly put disproportionate power in the hands of the employer (Ambrosini and Triandafyllidou 2011; Bylander 2021; Perry 2018). This power differential increases the risk of employers abusing the rights of their workers. In Canada, the SAWP contributes to the power imbalance by linking employee contracts to only one employer and basing the opportunity for migrants to return the following year almost entirely on performance ratings provided by the employer (Preibisch and Otero 2014). One study of Ontario migrant agricultural workers found that 55% of surveyed workers either feared deportation or had received threats of deportation while working (Basok and Belanger 2016). The risk of deportation or not being allowed to return often forces migrants to put up with poor working conditions and abuses rather than confront their employers (Perry 2018) thus increasing this power imbalance. Similarly, in Italy the employer–worker imbalance is caused by employers’ complete control over migrant agricultural workers’ ability to gain residence permits to legally work in the country. For migrant agricultural workers to extend or renew their work contracts they need to obtain a long-term commitment from an employer (Ambrosini and Triandafyllidou 2011). When employers are unwilling, migrants inevitably end up becoming irregular workers, even if they would like to be legally documented. In Thailand, migrant agricultural workers are also bound to a single employer with virtually no opportunity to change employers within the 2-year contract (Bylander 2021). The Thai government’s 2017 crackdown on irregular migrants introduced a policy only allowing migrants to change jobs with their employer’s permission (Bylander 2021), which seems unlikely when workers are facing abuse. In this situation, irregular workers hold more power than those working legally because irregular workers can leave or change employers if they face abuse and/or exploitation (Bylander 2021). In Thailand, Italy, and Canada, migrant agricultural workers cannot leave an employer on their terms, which allows employers to abuse migrant agricultural workers’ rights.

Migrant agricultural worker mistreatment

It has been widely reported in Thailand, Italy, and Canada that migrant agricultural workers face mistreatment, exploitation, and challenging working conditions. In Canada, the power imbalance mentioned above allows some employers to force migrants to work in unsafe conditions, extremely long hours, or without proper PPE, and if migrants complain, cannot work, or refuse unsafe work employers can have them repatriated before their contract ends (Horgan and Liinamaa 2017). This mistreatment was highlighted in 2020 as MWAC reported migrants filed over 1100 complaints surrounding worker mistreatment (MWAC 2020). One study surveyed agricultural migrant workers in the province of British Columbia found roughly 31% of migrants reported being discriminated against and just over 15% reported being assaulted by their employer (Colindres et al. 2021).

In Italy, the prominence of caporalato in the irregular migrant agricultural workers’ employment, mobility, and housing have proven to degrade the quality of the housing workers live in, with many living on remote, dilapidated farms (Perrotta 2015) with poor health and sanitation conditions (Tagliacozzo et al. 2020). It was estimated that there are roughly 180,000 migrant agricultural workers in Italy were being exploited for their work and many suffer from forms of sexual abuse or violence (Donato, 2022). This mistreatment is not only constrained to physical abuse as Amnesty International (2012) found migrant agricultural workers make on average 40% less than Italian nationals.

In Thailand, systemic problems create insurmountable challenges for migrants to gain the appropriate permits to regularly work in Thailand (Bylander 2019), which puts migrants in exploitative situations where human rights abuses often occur (Bylander 2021). Workers who are both documented and irregular face mistreatment and substandard living conditions, which will be discussed more below concerning COVID-19. One study on migrant agricultural workers in Thailand found on average Thai workers made higher monthly wages than migrant workers (Chantavanich et al. 2007 as cited in ILO 2016). In terms of physical exploitation and abuse, Human Rights Watch found migrant agricultural workers regularly face intimidation and threats (HRW 2016). In addition, the ILO found roughly 33% of migrant workers in agriculture had their identification confiscated and held by their employer, which severely restricts their ability to travel and leave abusive situations (HRW 2016).

Precarious employment of migrant agricultural workers

In addition to a power imbalance and mistreatment, another similarity between each country’s labor migration policies is the precarious nature of their employment. The International Labour Rights Forum (ILRF) (n.d.) defines precarity as “precarious workers are those who fill permanent job needs but are denied permanent employee rights” (para 1) and precarious workers are prone to unstable employment and more dangerous working conditions (ILRF n.d.). Both Italian and Canadian policy requires workers to return to their home country each year. In Italy, workers rely on employers to apply for and pay for their permits to ensure their path to documentation (Amnesty International 2012). In Canada, there is little year after year predictability for workers, especially if one’s return is subject to a manager’s performance evaluation (Preibisch and Otero 2014). A study conducted by the Canadian Council of Refugees (2016) found that migrant agricultural workers being tied to one employer and their inability to gain permanent residence status creates a precarious environment for workers. Nakache (2013) argues that as seasonal agricultural workers do not have access to permanent residency or citizenship, they do not have equal access to social protections, therefore increasing their precarity. These findings are just as relevant today given the pathway to permanent residency and citizenship has not been simplified.

In both Italy and Thailand, migrant agricultural workers are in a consistent state of precarity primarily due to each country’s labor policy failing to create conditions where migrant agricultural workers can become properly documented to work in the country legally. When looking at Italy, it is believed that there are roughly 500,000 migrant workers in the agricultural sector (UNCHR 2020). Of all workers without contracts, 80% are migrant workers and over 130,000 of these would be classified as working in incredibly vulnerable situations (Meo & Omizzolo 2018). Thailand faces a similar issue with one report estimating there are over 800,000 irregular migrant workers working in low-skilled sectors (Tao et al. n.d.), which would include agriculture. In both countries, the work permit process is complicated, lengthy, and expensive and gives disproportionate power to employers to control the migrant agricultural workers’ legal status and forces many migrants to work irregularly (Amnesty International 2012; IOM 2019). Working irregularly stokes precarity because it offers no job stability and limited labor rights. Furthermore, in Italy, irregular migrants are consistently uprooted and moved from farm to farm by the caporalato (Perrotta 2015), which leads migrant agricultural workers to be in a constant state of mobility and change. Additionally, once in Italy, irregular migrants are only able to obtain legal documentation during a national regularization period, but even during regularization windows employers still have discretion over their migrant agricultural workers’ ability to become documented and many employers do not allow their migrants to do so. As evidenced during the 2020 regularization period (Palumbo and Corrado 2020), many migrant agricultural workers stay irregular despite their wishes to gain legal documentation to work in Italy (Corrado 2018), keeping many migrant agricultural workers in a constant state of precarity. Very similar features also contribute to precarious employment for migrant agricultural workers in Thailand.

Divergent migrant worker contexts in Thailand, Italy, and Canada

Several distinct differences between migrant agricultural worker policies and contexts in Thailand, Italy, and Canada’s labor migration policies emerged, including the proportion of irregular migrant agricultural workers, the processes through which migrant workers navigate, and the geographic and geopolitical landscapes of each country.

Proportion of irregular migrant agricultural workers

The primary distinction between the three countries is the relatively small number of irregular migrants in Canada compared to Thailand and Italy. As discussed previously, the World Bank (2006) reported only 1.5% of seasonal agricultural workers to overstay their contracts in Canada, which is much lower than the proportion of irregular migrant agricultural workers in other countries. In contrast, it is estimated that 79% of migrants working in agriculture entered Thailand through irregular channels (IOM 2019) and 80% of migrant agricultural workers in Italy did not have formal work contracts (CREA 2017). This review suggests the large proportion of irregular workers in Italy and Thailand is caused by Italy’s failure to meet the demand for migrant agricultural workers and Thailand’s overly complicated and expensive migration process.

Migration processes

As mentioned, there are a large number of irregular migrants in Italy and Thailand, largely due to the complexity and inefficiency of the formers’ legal migration processes. Canada’s labor migration process through the SAWP is heavily supported by both the Canadian and partner governments. Employers in Canada can submit their application for migrant agricultural workers through the Government of Canada each year (Government of Canada 2021) and partner countries’ governments in return are responsible for recruiting and supporting workers (Government of Canada 2021). The formal partnerships between Canadian and partner governments help improve communication and ensure stakeholders understand what is required and ensure workers do not face unexpected costs. Additionally, the SAWP program is demand driven; therefore, as long as demand is proven by the employer, farmers are allocated an appropriate number of migrant agricultural workers without the limiting quotas seen in Italy (Hennebry and Preibisch 2012). Meeting labor demands through legal avenues eliminates the need to find workers outside the legal system.

In Italy, the challenge with irregular workers begins with their annual flows decrees system putting a cap on the number of workers granted entry each year, often failing to meet employers’ labor needs (Amnesty International 2012). In addition, recruiting a foreign worker is complicated, cumbersome, and time consuming, which leads employers to irregular workers to fulfill their labor needs (Amnesty International 2012). The Thai experience is similar. Workers face complex and lengthy processes to obtain legal documentation, which is a major driver of irregular workers (IOM 2019; Mekong Migration Network 2020). In addition, the cost for employers to register migrant agricultural workers through an MoU is often passed on to the worker (Mekong Migration Network 2020). Due to this relatively low pay, many migrant agricultural workers are unable to find the funds to meet the payment or are forced into debt. Thus, in both Italy and Thailand, challenges inevitably lead to migrant agricultural workers entering through illegal channels to begin work faster and avoid paying fees for documentation. Policy adaptation, as in Canada, which reduces the barriers to entry for the workers and employers, would be strongly recommended if the goal is to reduce irregular workers in Thailand and Italy.

Geographic and geopolitical differences

Canada tends to have fewer irregular workers; however, it is important to note that natural geographic barriers and surrounding geopolitical climates also give Canada an advantage in managing irregular labor migration. Thailand and Italy do not have this same natural geographic advantage. Thailand has a natural land border with Cambodia, Laos, and Myanmar, which increases the ease and possibility of migrants entering the country irregularly. Italy is also relatively easy to access from Eastern Europe and is accessible to African migrants crossing the Mediterranean Sea. This route of entry into Italy is extremely dangerous, but the 2017 European Migrant Crisis demonstrated this trip is frequently undertaken despite the risk (Alfred 2017). This Mediterranean crossing has often been referred to as the “world’s deadliest migration route” (Bathke 2022). The Missing Migrant Project conducted by IOM estimated that in 2021 over 1,500 migrants drowned in the Mediterranean, although it is widely assumed the real number is much higher (IOM 2022). The geographic position of both Italy and Thailand in relation to their neighbors increases the ability for migrants to irregularly enter when compared to Canada.

In addition to the geographic location of countries, the geopolitical climates of neighboring countries also impact irregular migration in Thailand and Italy. Push factors that drive migration include economic difficulties, fear of violence or persecution, political unrest, and insufficient employment opportunities, and pull factors driving migration include increased safety and security, as well as employment opportunities (United Nations (UN) Office on Drugs and Crime, n.d.). Both the USA and Canada are classified as high-income and developed countries (World Economic Situation and Prospects (WESP) 2014) and also rank relatively high in stability and human rights (The Fund for Peace 2021). This similarity between rankings leaves almost no push to migrate to Canada from the USA, especially in an illegal manner. The same cannot be said for the geopolitical stability of the countries surrounding Thailand and Italy.

Thailand is classified as a middle-income country (WESP 2014) with a 2021 GDP of $534.78 billion USD (International Monetary Fund (IMF), 2021). In contrast, Cambodia, Laos, and Myanmar are all classified as the least developed countries (WESP 2014) and have combined GDPs of only $123.88 billion USD (IMF 2021). Thailand’s relatively higher rank on the fragile state index (The Fund for Peace 2021) and Human Development Index (UN Development Program 2020) compared to bordering countries means labor migration to Thailand stems from the increased opportunities offered by Thailand’s political stability and economic opportunity (Chalamwong et al. 2012).

Similarly in Italy, its location both in southern Europe and on the Mediterranean increases exposure to irregular migrants and those seeking asylum and refugee status (ANSA 2018). For example, in 2017 Italy reported over 130,000 asylum applications (Ministero dell’Interno, 2021), while Canada had just over 50,000 the same year (Immigration, Refugee and Citizenship Canada 2022), despite its larger landmass.

Comparing Thailand, Italy, and Canada’s responses to COVID-19

COVID-19 had a dramatic impact on the agriculture sector, labor migration policies, and labor movement in Thailand, Italy, and Canada. Each country responded in a unique way relative to its existing policies. For example, both Thailand and Italy established national registration periods in an attempt to document irregular migrants already within their countries, while Canada focused its efforts on improving quarantine and testing protocols for migrant agricultural workers upon arrival. Despite distinct responses to COVID-19, two similar and critical themes were exposed in the three countries reviewed: the immensely important role migrant agricultural workers play in the agriculture sector in each country and how COVID-19 highlighted the exploitation, abuse, and poor working conditions of migrant agricultural workers face.

While migrant workers in agriculture were viewed as a critical component of the agriculture sector and supply chain before COVID-19 (Martin 2016), the struggle in accessing migrant agricultural workers during the pandemic only further demonstrated the importance they bring to each country. In Canada, the supply of migrant agricultural workers decreased in 2020, which led to labor shortages for many farmers across the country (Dias De Vasconcelos and Pettigrew 2021; Falconer 2020). In total Falconer (2020) found in 2020, there was a 14% drop in the number of migrant laborers in the Canadian agricultural sector compared to 2019, which strained farmers as they struggled to meet the labor supply. In Italy, which is historically inadequate in meeting employer demand for migrant agricultural workers, an additional shortage of roughly 250,000 workers made farmers struggle to meet the labor supply in previous years (Bathke 2020). Similar to both Canada and Italy, the rapid decrease of migrant agricultural workers was detrimental to Thailand’s agricultural sector as many farmers were unable to meet the labor supply as workers returned to their home countries (IOM 2020b), which led to failed crops and food shortage in many areas of the country (Gilmour and Lin 2021).

Despite the marked differences in labor migration policies across Thailand, Italy, and Canada, the marked labor shortage and strain on the agricultural sector caused by COVID-19 demonstrates the vital role migrant agricultural workers play in the food supply and security of all countries. Thailand, Italy, and Canada were all unable to replace the vital labor supply migrant agricultural workers typically fill. Unfortunately, despite the recognized importance of migrant agricultural workers, COVID-19 only seems to have exacerbated the abuses and exploitation they already faced in each country (Marschke et al. 2021; Migrant Workers Alliance for Change 2020; Palumbo and Corrado 2020).

In Canada, migrant agricultural workers reported more complaints and abuses, including working excessive hours at an increased pace (Migrant Workers Alliance for Change 2020), likely a result of farmers being short-handed. Additionally, some employers pressured migrants to sign documents restricting their movement and requiring them to stay on the farm at all times (Thomas 2020) in an attempt to slow COVID’s spread. Moreover, cramped living conditions in bunkhouses made social distancing impossible and increased the possibility of contracting COVID-19. Similar to Canada, close living quarters, poor sanitation, and lack of PPE greatly increased the risk of contracting COVID-19 in Italy (Palumbo and Corrado 2020). In Thailand, migrant agricultural workers were confined to their living quarters, but COVID-19-negative and positive workers were forced to live together (Marschke et al. 2021). Additionally, many migrant agricultural workers in all three countries complained of insufficient or lack of PPE to protect them (Gilmour and Lin 2021; MacLeod 2021; Palumbo and Corrado 2020). These conditions led to infection and death among migrant agricultural workers, both legal and irregular. Given the critical role migrant agricultural workers play in Thailand, Italy, and Canada, each country needs to enact policy changes, in line with the ILO recommendations (ILO 2020), that provide migrant workers in agriculture with the rights and conditions they deserve.

Limitations and future research

Future research should extend the documentary method employed here with surveys and/or focus groups in Thailand, Italy, and Canada. Given the fast-evolving nature of COVID-19, we felt the documentary method was a timely way of capturing the discourse in available documents on migrant agricultural workers during the first several years of the COVID-19 pandemic. Although the documentary method is a worthy endeavor on its own (Payne and Payne 2004), further methodological approaches to extend this important topic would be valuable.

There are several potential limitations with the documentary method. First, there is a risk that the documents reviewed are not exhaustive or that the publicly accessible documents may only be a sub-sample of the information on the subject (Payne and Payne 2004). On a similar note, there is a risk of subjectivity in both the selection of documents or data to be analyzed and the analysis itself (Reischl and Plotz 2020). However, for this reason, we rely heavily on credible documents WHO, ILO, and IOM, as well as peer-reviewed research.

Conclusion

International migrants continue to play an increasingly critical role in agricultural production and security across the world (Popova and Özel 2018). Using the documentary method, we summarized and compared the migrant agricultural worker policies of Thailand, Italy, and Canada, while also analyzing each country’s COVID-19 response and impact on the treatment of migrant agricultural workers. This research makes an important contribution to the fields of labor mobility and international migration by exploring both the Global North and South in analyzing Thailand, Italy, and Canada and bringing awareness to labor mobility policies, and the treatment of migrant agricultural workers during COVID-19 in vastly different regions and countries in stages of economic development.

Unfortunately, migrant agricultural workers in all three countries face abuses, stemming from large power imbalances between migrant agricultural workers and employers and also the precarious employment created by policies. COVID-19 only worsened the abuses faced by migrant agricultural workers, while simultaneously demonstrating just how vital migrant agricultural workers are in food production and security in each country. This paper has identified numerous policy failures by the Thai, Italian, and Canadian governments to protect the rights of agricultural migrant workers both prior and during COVID-19. Additionally, through using a comparative analysis it has been able to identify similar policy failures and consequences on migrant agricultural workers in each country despite their socio-political and geographic differences. This should create an urgency for countries to use greater cooperation in order to create policies that protect the rights of migrant agricultural workers. Moving forward, countries need to re-evaluate their current labor mobility policies, but with a particular focus on removing the power imbalance between employer and migrant, decreasing precarity, and ensuring the rights of all migrant agricultural workers are upheld as recommended in the ILO (ILO 2020). As Thailand, Italy, and Canada all face similar challenges, building stronger multilateral partnerships to share knowledge and create best policy practices could be valuable for each country despite their regional and economic differences.