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OO RUEHWEB

DE RUEHAC #0172/01 0821509
ZNR UUUUU ZZH
O 231509Z MAR 09
FM AMEMBASSY ASUNCION
TO RUEHC/DEPT OF LABOR WASHDC IMMEDIATE
RUEHC/SECSTATE WASHDC IMMEDIATE 7693
INFO RUCNMER/MERCOSUR COLLECTIVE PRIORITY
RUEHGV/USMISSION GENEVA PRIORITY 0184

UNCLAS ASUNCION 000172 
 
SIPDIS 
 
PLEASE PASS TO DOL/ILAB TMCCARTER, STATE FOR DRL/ILCSR 
TDANG AND WHA/BSC MDASCHBACH 
 
E.O. 12958: N/A 
TAGS: ELAB EIND ETRD PHUM SOCI USAID PA
SUBJECT: PARAGUAY:  RESPONSE TO REQUEST FOR CHILD LABOR 
INFORMATION 
 
REF: A. 08 STATE 127448 
     ¶B. ASUN 147 
     ¶C. 08 ASUN 505 
     ¶D. ASUN 129 
 
¶1.  (U) This cable responds to the Department of Labor's 
request for information to determine whether Paraguay is 
implementing its international commitments to eliminate the 
worst forms of child labor (ref A). 
 
¶A.  What laws have been promulgated on child labor in the 
country? 
 
The 1993 Labor Code (Law 213/93) and the 2001 Children's and 
Adolescents' Code (Law 1680/01) codify Paraguay's child labor 
laws. The revised Penal Code (Law 3440/08), which goes fully 
into effect on July 16, incorporates these labor codes in 
their entirety.  The Children's and Adolescents' Code 
protects children from exploitation in the workplace and 
prohibits forced or compulsory child labor. 
 
The Labor Code provides for a standard legal work week of 48 
hours (42 hours for night work), with one day of rest. The 
law also allows an annual bonus of one month's salary and a 
minimum of six vacation days a year. The law requires payment 
for overtime.  The Ministry of Justice and Labor established 
a mandatory national private sector minimum wage, 
approximately USD 268 per month (1.34 million guaranies), 
sufficient to maintain a minimally adequate standard of 
living for a worker and family.  The law sets occupational 
health and safety standards stipulating conditions of safety, 
hygiene, and comfort.  Workers have the right to remove 
themselves from situations that endanger their health or 
safety without jeopardy to their continued employment, but 
they may not do so until the Ministries of Justice and Labor 
and Health recognize such conditions.  These laws apply to 
adults and children over age 15 who are allowed to work 
legally. 
 
The revised Penal Code aligns Paraguayan law with the 
international conventions it has ratified, including 
International Labor Organization (ILO) Convention 182 on the 
Worst Forms of Child Labor (ratified in 2001); ILO Convention 
138 on Minimum Age (ratified in 2004); ILO Convention 29 on 
Forced Labor (ratified in 1967); ILO Convention 105 on the 
Abolition of Forced Labor (ratified in 1968); the optional 
protocol to the Convention on the Rights of the Child (CRC) 
on the sale of children, child prostitution, and child 
pornography; and the Protocol to Prevent, Suppress and Punish 
Trafficking in Persons.  The revised Penal Code includes a 
new statute prohibiting trafficking in persons for sexual and 
labor purposes.  The statute complements the 1997 Adoptions 
Law and the 2000 Domestic Violence Law that protect children 
against violence and exploitation. 
 
¶B.  What is the country's minimum age for admission to work? 
 
The country's minimum age for admission to work is 12 per 
Paraguay's ratification of ILO Convention 138 on Minimum Age. 
 Children 12 to 15 years of age and over may work in family 
enterprises, agriculture, or apprenticeships.  The law 
permits minors between 15 and 18 years of age to work with 
parental authorization up to six hours per day in 
nonhazardous working conditions, including industrial work. 
 
¶C.  Are there exceptions to the minimum age law? 
 
There are no exceptions to the minimum age law for children 
under age 12.  However, the laws on legal work hours for 
children over age 12 are conflictive.  The Child and 
Adolescent Code and the Labor Code differ on the number of 
hours per day and times of day children may work between the 
ages of 13 and 18. 
 
¶D.  What is the minimum age for admission to hazardous work, 
and which additional provisions has the country enacted 
regarding children's involvement in hazardous work? 
 
The minimum age for admission to hazardous work is 18.  Law 
1657/01 ratifying ILO Convention 182 and decree number 
4951/05, the List of Work Endangering Children, enacted 
provisions regarding children's involvement in hazardous 
work.  Employing children under age 18 in hazardous work 
and/or employing minors under 12 years is prohibited and 
punishable by fines of at least USD 10.00 per child according 
to the Labor Code. 
¶E.  What laws have been promulgated on the worst forms of 
child labor, such as forced child labor and trafficking or 
child prostitution and pornography? 
 
Paraguay ratified ILO Convention 182 when it passed Law 
1657/01 in 2001, and developed a list of occupations 
considered to be the worst forms of child labor outlined in 
decree number 4951/05 issued in 2005.  Those who violate 
these are subject to prosecution under the Labor Code and the 
Children's and Adolescents' Code.  Those who compel minors to 
engage in the worst forms of child labor can receive up to 
five years in jail or a fine in the event of an industrial 
accident involving child laborers. 
 
Articles 129b and 129c of the revised Penal Code specifically 
punish trafficking in persons with up to 12 years in prison 
depending on the crime committed.  They forbid compelling 
anyone to travel outside the country or compelling a minor 
under 18 to work for purposes of sexual exploitation or 
forced labor. 
 
¶F.  Please specify what worst forms are prohibited and 
describe penalties for violations. 
 
The worst forms of child labor prohibited by decree number 
4951/05 include: 
 
¶1.  Public and private monitoring work that threatens the 
lives and safety of adolescents. 
 
¶2.  Public street work that creates a risk of traffic 
accidents; respiratory, neurological and skin problems due to 
environmental pollution and solar radiation; and risk of 
psychological and sexual abuse, stress, fatigue, and 
psychosomatic disorders, low esteem, social difficulties, 
aggressive and antisocial behavior, depression, drug 
addiction, early pregnancy, and others. 
 
¶3.  Laborers who care for those with illnesses in a capacity 
that threatens their health, safety and morals. 
 
¶4.  Work involving transfers of money and other property. 
 
¶5.  Activities involving exposure to dust, fumes, vapors and 
toxic gases, and contact with products, substances or objects 
of a toxic, combustible, flammable, radioactive, infectious, 
irritating or corrosive nature. 
 
¶6.  Work with agro-chemicals:  handling, transport, sale, 
application and disposal of chemicals. 
 
¶7.  Waste and recyclable materials collection. 
 
¶8.  Work in the manufacture, handling and sale of explosive 
substances or objects or fireworks that produce a risk of 
death, burns, amputations and other injuries. 
 
¶9.  Work in unhealthy conditions. 
 
¶10.  Work in mines, quarries, and underground excavations. 
 
¶11.  Work that leads to exposure to extreme hot or cold 
temperatures. 
 
¶12.  Work that requires the use of machines and manual and 
mechanical tools of a sharp, crushing nature. 
 
¶13.  Work in environments with exposure to constant noise and 
vibrations that produce hand-arm syndrome or semi-lunar bone 
osteolysis. 
 
¶14.  Work in the production, distribution and exclusive sale 
of alcohol or tobacco. 
 
¶15.  Work that involves transiting national borders to other 
countries on a periodic basis. 
 
¶16.  Work that involves moving earth and shaping topography, 
including ditches, pits or holes, canals, water channels, 
artificial embankments, cliffs that have collapsed, or 
landslides. 
 
¶17.  Night work occurring between the hours of 19:00 and 
07:00 the following day. 
 
¶18.  Work with cattle. 
¶19.  Work in eroticized modeling with photography that 
conveys the risk of psychological harassment, early sexual 
stimulation, and of sexual abuse. 
 
¶20.  Work involving the manual handling of heavy loads, 
including lifting and placement. 
 
¶21.  Work done in confined spaces. 
 
¶22.  Work in child domestic servitude. 
 
¶23.  Work that damages health as a result of ergonomic 
posture, isolation, and time pressure. 
 
¶24.  Underwater or river-based work that creates a risk of 
death by drowning, ergonomic injuries, and exposure to 
inappropriate sexual and psychological abuse. 
 
¶25.  Work at heights, including work involving the use of 
scaffolding, harness and life lines. 
 
¶26.  Work with electricity, including the assembly, 
adjustment and repair of high voltage electrical 
installations. 
 
The revised Penal Code prohibits the commercial sexual and 
labor exploitation of children and adolescents and provides 
for penalties of up to 12 years for trafficking a person into 
or out of the country for the purpose of sexual and labor 
exploitation.  The revised Penal Code imposes penalties of up 
to eight years in prison for inducing or coercing a minor to 
participate in prostitution, perform sexual acts, or work in 
forced labor conditions.  If the perpetrator uses force or 
enslaves the minor for purposes of sexual or labor 
exploitation, the penalty increases to 12 years (ref B).  The 
production of child pornography, the sponsoring of public or 
private shows including someone under 18 years old, and the 
distribution of child pornographic material is punishable by 
up to five years of incarceration or a fine.  The penalty for 
using children in pornography increases to 10 years in prison 
if the minor is under 14 years of age, the perpetrator is the 
child's guardian, or the perpetrator acts for commercial 
purposes.  Domestic trafficking for purposes of labor or 
sexual exploitation is subject to prosecution under the 
revised Penal Code's pimping statute. 
 
¶G.  What is the country's minimum age for military 
recruitment and/or involvement in armed conflict? 
 
The law requires that men register for military service at 
age 17, and serve one year in the military between the ages 
of 18 and 25.  Congress passed Law 3360/07 in 2007 mandating 
that all military recruits be at least 18 years of age.  The 
law permits individuals to join workforce training programs 
in lieu of military service or obtain exemptions from 
military service as conscientious objectors. 
 
¶H.  If the country has ratified ILO Convention 182 on the 
Worst Forms of Child Labor, has it developed a list of 
occupations considered to be worst forms of child labor, as 
called for in article 4 of the Convention? 
 
Yes.  See responses in 1.E. and 1.F. 
 
¶2.  (U) Regulations for implementation and enforcement of 
proscriptions against the worst forms of child labor.  Please 
provide answers to the following questions: 
 
¶A.  What legal remedies are available to government agencies 
that enforce child labor and worst forms of child labor laws, 
and are they adequate to punish and deter violations? 
 
Government agencies may enforce child labor and worst forms 
of child labor laws through civil fines, criminal penalties, 
and court orders.  Prosecutors may enforce child labor laws 
by bringing legal cases against violators.  The Supreme Court 
and children's civil court have the authority to rule on 
child labor cases and impose criminal penalties and civil 
fines on those convicted of violating labor laws.  Although a 
special children's court handles civil cases involving 
minors, criminal cases involving minors continued to be 
handled in adult criminal courts. 
 
Although the remedies are adequate to punish violations, the 
government did not deter violations due to its failure to 
utilize these remedies.  Child labor exploitation remains a 
problem, particularly in the domestic service, brick and lime 
manufacturing, and in some agricultural sectors.  See 
response in 5.A. 
 
¶B.  To what extent are violations investigated and addressed? 
 
The Ministry of Justice and Labor (MJT) is responsible for 
enforcing child labor laws and inspecting workplaces that 
employ adolescent workers to ensure they are registered with 
municipal-level Defense Councils for the Rights of Children 
and Adolescents (CODENI).  The Public Ministry investigates 
and prosecutes violators based on referrals from the MJT and 
other agencies.  The government did not allocate adequate 
resources to enable these ministries to enforce the law 
effectively. 
 
Resources limited the government's ability to investigate and 
address child labor violations.  Trafficking in persons cases 
for the purpose of sexual or labor exploitation are the only 
child labor crimes investigated and prosecuted in Paraguay. 
In the past year, the Public Ministry investigated 46 TIP 
cases; indicted 11 suspected traffickers and associates 
involved in trafficking 19 victims, including six minors; and 
earned convictions in two cases against four traffickers who 
received six years in prison.  In addition to the four 
traffickers convicted during the reporting period, another 23 
traffickers and 16 associates are currently in prison serving 
sentences for trafficking-related offenses.  Of the 62 
victims involved in trafficking cases opened this year, 54 
were trafficked for purposes of sexual exploitation, six for 
forced labor, and two for arranged marriages. 
 
Prosecutors opened a case in January to investigate 
allegations that four boys and two girls had been trafficked 
to Japan for purposes of labor exploitation. 
 
¶C. What level of resources does the government devote to 
investigating child labor and worst forms of child labor 
cases throughout the country? 
 
The 200 public defenders in country, including approximately 
50 in Asuncion, work for the Public Ministry and local 
ombudsman's offices on many types of cases, including child 
labor cases.  However, they lack sufficient resources to 
perform their jobs and have investigated few cases related to 
child labor. 
 
¶D. How many inspectors does the government employ to address 
child labor issues? 
 
Paraguay ratified ILO Convention 81 on Work Inspections when 
it passed Law 1235/67 in 1967.  The MJT employs some 
inspectors to address labor issues, but they do not focus 
solely on child labor issues.  CODENIs work with the ILO to 
address child labor issues at a local level.  About half of 
municipalities nationwide have CODENIs, and many of these 
lack basic resources to address child labor issues. 
 
¶E.  How many police or other law enforcement officials 
address worst forms of child labor issues? 
 
Although Paraguay does not employ police or other law 
enforcement officials specifically to address the worst forms 
of child labor, the government has dedicated resources to 
fight trafficking in women, children, and adolescents for 
purposes of sexual and labor exploitation.  The government's 
Inter-Institutional Roundtable for the Prevention and Combat 
of Trafficking in Persons is an inter-agency commission 
managed by the Foreign Ministry that coordinates government 
agencies' efforts to fight TIP.  The Public Ministry 
established an anti-TIP unit in October 2008 with three 
prosecutors and six assistants dedicated to fighting 
trafficking in persons.  The Interior Ministry has two 
anti-TIP investigators assigned to Interpol to investigate 
international trafficking cases.  The National Police has a 
three-member anti-TIP unit that investigates domestic 
trafficking cases. 
 
¶F.  How many child labor investigations have been conducted 
over the past year and how many have resulted in fines, 
penalties, or convictions? 
 
The only child labor investigations conducted over the past 
year are related to TIP cases.  The results of these 
investigations are listed in 2.B. 
 
¶G.  How many investigations into worst forms of child labor 
violations have been conducted over the past year and how 
many have resulted in prosecutions and convictions? 
 
The only investigations into the worst forms of child labor 
violations conducted over the past year are related to TIP 
cases.  The results of these investigations are listed in 2.B. 
 
¶H.  Has the government provided awareness-raising and/or 
training activities for officials charged with enforcing 
child labor laws or worst forms of child labor laws? 
 
The government did not provide awareness-raising or training 
activities for officials specifically charged with enforcing 
child labor laws or worst forms of child labor laws. 
However, the government provides general awareness of child 
labor laws to officials through training activities in 
conjunction with the ILO and the Organization for 
International Migration (IOM).  The Ministry of Education and 
Culture (MEC) hosted a seminar in May 2008 on raising general 
awareness of child labor and the worst forms of child labor. 
 
¶3.  (U) Whether there are social programs specifically 
designed to prevent and withdraw children from the worst 
forms of child labor. Please provide answers to the following 
questions: 
 
¶A.  What initiatives has the government supported to prevent 
children from entering exploitive work situations, to 
withdraw children engaged in such labor, and to advocate on 
behalf of children involved in such employment and their 
families? 
 
The government, with the help of the ILO and UNICEF, supports 
several initiatives to prevent children from laboring in 
exploitative work situations and advocate on behalf of 
children involved in such employment.  These programs focus 
on improving educational opportunities for youths and 
reducing the need for children and adolescents to work. 
 
"Vision 2020":  The MEC launched Vision 2020, a program 
designed to improve children's access to education and 
accountability of children, in June 2008.  In addition to 
improving school conditions, the MEC requires that all 
schools gather information on the working status of children. 
 
 
"Well-being" Program ("Tekopora," in Guarani):  The Social 
Action Secretariat (SAS) provides financial assistance to 
families living in rural communities in Concepcion, San 
Pedro, Canindeyu, Caaguazu, and Caazapa departments.  In 
exchange for a commitment to send their children to school, 
each family receives about USD 40 (200,000 guaranies) in 
financial assistance monthly from the SAS to cover food and 
education expenses.  According to the International Poverty 
Centre's March 2008 study of the program, the program aims to 
reduce work disincentives among adults, and to encourage 
human capital accumulation among the young, while meeting 
some basic needs. 
 
"Hugs" Program ("Programa Abrazos," in Spanish):  This 
SAS-administered program provides financial assistance to 
families in Asuncion, Ciudad del Este, and Central Department 
with street children under 14 years of age.  In exchange for 
a commitment to send their children to school, each family 
receives about USD 20 (200,000 guaranies) in financial 
assistance monthly from the SAS to cover food and education 
expenses.  Program administrators also monitor street 
children and offer them educational, hygiene and health, food 
and recreation assistance. 
 
"Help Us" Program ("Nopytyvo," in Guarani):  This 
SAS-administered program provides financial assistance to 
families in the Chaco region.  It is similar in nature to the 
SAS's "Well-being" Program. 
 
"Scream":  MEC adopted the ILO's "Scream" child labor 
intervention campaign in June 2008.  The MEC plans to 
implement the ILO's methodology to assist administrators and 
public school teachers in identifying child laborers and 
protecting them from exploitation.  MEC occasionally holds 
seminars to educate its staff about the issue of child labor 
within the framework of "Scream." 
 
"Extended School" (Escuela Extendida, in Spanish):  This is a 
program developed by the ILO and UNICEF now under 
consideration by the MEC.  The program would pay parents a 
stipend to send their children to school to participate in 
extracurricular activities. 
 
"Southern Child" (Nino Sur, in Spanish):  This is a Mercosur 
initiative that defends the rights of children in the region. 
 Paraguay has participated in this initiative by 
participating in public campaigns against commercial sexual 
exploitation, trafficking, and child labor; benchmarking its 
laws with international and Mercosur standards on child 
labor; and exchanging best practices related to victim 
protection and assistance with other Mercosur states. 
 
The Children's and Adolescents' Secretariat provides funding 
to the NGO Center for Attention, Prevention, and Surveillance 
of Boys, Girls, and Adolescents (CEAPRA) in Ciudad del Este 
to assist children who have been trafficked and subjected to 
sexual exploitation.  The Secretariat has also supported the 
efforts of NGO Grupo Luna Nueva to assist child and 
adolescent trafficking victims in Asuncion. 
 
Some local labor unions have programs designed to help 
children avoid child labor exploitation.  The National Union 
of Educators supports the MEC's nationwide child registration 
program, and the Paraguayan Workers' Confederation runs a 
youth community center in Asuncion. 
 
¶4.  (U) Does the country have a comprehensive policy aimed at 
the elimination of the worst forms of child labor? Please 
provide answers to the following questions: 
 
¶A. Does the country have a comprehensive policy or national 
program of action on child labor or specific forms of child 
labor? 
 
The National Policy for Childhood and Adolescence outlines 
the country's comprehensive policy on child labor.  This 
policy includes two plans specifically focusing on child 
labor:  The National Plan for the Eradication and Prevention 
of Child Labor; and the National Plan for the Prevention and 
Eradication of Child Sexual Exploitation. 
 
The national policy is administered by the National 
Commission to Prevent and Eradicate the Exploitation of 
Children (CONAETI).   CONAETI members include representatives 
from the Ministry of Justice and Labor (MJT), Children's and 
Adolescents' Secretariat (SNNA), Ministry of Health and 
Social Welfare (MSPyBS), Ministry of Education and Culture 
(MEC), Social Action Secretariat (SAS), Women's Secretariat 
(SMPR), Secretariat of Development for the Repatriated and 
Conational Refugees (SEDERREC), National Directorate of 
Surveys, Statistics, and Censuses (DGEEC), Technical Planning 
Secretariat and CODENI.   The ILO, UNICEF, and some labor 
unions, industry associations, and NGOs are also members of 
CONAETI. 
 
CONAETI's national plan of action on child labor includes 
protecting children from abuse through the National System of 
Comprehensive Protection and Promotion for Children and 
Adolescents; improving data collection on child laborers; 
diagnosing the national child labor situation; increasing 
awareness of child labor exploitation; creating policies to 
support prevention and detection of child labor exploitation; 
improving the government's institutional capacity to respond 
to child labor issues; enhancing legal protections for 
children; supporting efforts to help prevent sexual 
exploitation and help victims child labor abuses; 
implementing a system to monitor child labor; stepping up 
intervention efforts to reduce child labor; and monitoring 
and evaluate the government's progress in eliminating 
exploitative child labor.  CONAETI achieves this by 
administering or supporting programs listed in 3.B. 
 
Department-level governments and municipal CODENI assist 
children who are victims of child labor.  However, they do 
not have comprehensive programs designed to prevent and 
withdraw children from the worst forms of child labor. 
 
¶B.  (U) Does the country incorporate child labor specifically 
as an issue to be addressed in poverty reduction, 
development, educational or other social policies or 
programs, such as Poverty Reduction Strategy Papers, etc? 
 
The country's social policies and programs focus primarily on 
the education and social welfare of children and adolescents. 
 However, CONAETI members refer to the National Policy for 
Childhood and Adolescence to design and implement these 
policies and programs to reduce child labor and child sexual 
exploitation. 
Since taking office in August 2008, the Lugo administration 
has prioritized issues relevant to child welfare.  The 
Children's and Adolescents' Secretariat prioritizes assisting 
street children and opened in December 2008 a new assistance 
center in Asuncion for street children.  The Women's 
Secretariat is shifting its focus to domestic violence, 
including violence against child domestic servants.  The 
Social Action Secretariat prioritizes campesinos issues, 
including rural children.  Although the administration has 
not placed a high priority on child labor issues, it hopes to 
improve conditions for children who may be affected by 
exploitative child labor. 
 
¶C.  (U) If so, to what degree has the country implemented the 
policy and/or program of action and achieved its goals and 
objectives? 
 
The government has implemented the programs outlined in 3.A. 
to varying degrees.  The IPC study noted that the SAS' 
"Well-being" Program has been moderately successful.  The 
program assisted 19,500 families as of June 2008.  According 
to the International Poverty Centre, many families 
participating in the program have been able to put their 
childen in school and generate income without their 
children's assistance.  Paraguay plans to expand this program 
this year to assist up to 120,000 families.  Other similar 
programs such as the "Hugs" and "Help Us" programs have also 
been moderately successful in assisting families with 
children and adolescents vulnerable to child labor 
exploitation.  "Vision 2020" and "Scream" are new MEC 
programs, and "Extended School" is still under consideration. 
 
These programs are limited in scope and have not yet achieved 
their goals and objectives in reducing or eliminating 
exploitative child labor.  Nevertheless, in general these 
programs have not yet succeeded because they lack sufficient 
resources to assist most Paraguayan families in need.  In 
addition, UNICEF and ILO reported that some families who 
receive assistance do not follow through with their 
commitment to put their children through school. 
 
¶D.  (U) Is education free in law and in practice?  Is 
education compulsory in law and in practice? 
 
Education is free and compulsory in law but not in practice. 
Children in public schools typically attend school four hours 
per day, five days per week.  However, the ILO estimated in 
2008 that approximately 15 percent of children between the 
ages of five and 17 did not attend school.  Most children did 
not attend school because they work to support their families 
or themselves, do not have access to public school, or lack 
basic resources needed to pay for miscellaneous school 
expenses. 
 
¶5.  (U) Is Paraguay making continual progress toward 
eliminating the worst forms of child labor? 
 
Paraguay has made some progress toward eliminating the worst 
forms of child labor.  In recent years, Paraguay ratified all 
ILO conventions related to child labor and the worst forms of 
child labor, and codified these into law.  The country 
continues to work closely with the ILO, IOM, UNICEF, and 
other governmental organizations to adopt international labor 
standards and raise awareness of child labor issues through 
seminars and reports.  It is also increasing its focus on 
social welfare programs that could help reduce child labor. 
Paraguay's efforts are a good start, but much work remains to 
eliminate the worst forms of child labor in Paraguay. 
 
¶A.  What are the specific sectors/work activities/goods in 
which children work, and how has this changed over the past 
year? 
 
Paraguay's child labor situation has not changed 
substantially over the past year.  Evidence shows that some 
children work as laborers in the brick and lime industries, 
picking cotton, harvesting sugar cane, and are photographed 
for pornographic purposes.   Some evidence suggests that 
children work to produce sugar cane, corn, soy, sesame, 
wheat, mandioca, and stevia, although whether they work 
illegally in these sectors is inconclusive.  Refs C and D 
discuss post's position on goods produced using child labor. 
 
Please visit us at     http://www.state.sgov.gov/p/wha/asuncion 
 
AYALDE