Child labor Policy Statement

Use this child labor policy as a basis to set up rules for employing minors to help end children’s exploitation.

1. Policy brief & purpose

Our child labor policy is our position on employing minors and aims to ensure that our company, its subsidiaries and everyone we’re connected with follows the law and cares for children’s interests.

International, local and federal child labor laws are stricter today than they were years ago. But millions of children are still forced to work in bad conditions all around the world, even in developed countries.

As an organisation, we want to do business in a legal, ethical manner adding value to society and the environment instead of doing harm. Helping stop child labor is fundamental to us. We want to make sure that our organisation doesn’t take part in children’s exploitation and also helps end it to the best of our ability.

Under UK law, the following rules on when a child can work, apply:

“Part-time work

The youngest age a child can work part-time is 13, except children involved in areas like:

• television
• theatre
• modelling

Children working in these areas will need a performance licence.

Full-time work

Children can only start full-time work once they’ve reached the minimum school leaving age - they can then work up to a maximum of 40 hours a week.

In England, a young person must be in part-time education or training until they’re 18.”

(Source: https://www.gov.uk/child-employment)

2. Scope

This policy applies to our entire organisation and those we do business or partner with including suppliers, vendors and contractors.

TheInternational Labour Organisation (ILO) and theU.N Convention on the Rights of the Child guide our policy on child labor. When it comes to legal aspects, we always:

• Follow the stricter law if more than one laws apply (e.g. state and federal, local and international).
• Require suppliers, partners and vendors to follow the stricter applicable laws and recognize children’s rights. They must also require their own suppliers, subcontractors and stakeholders to do the same.

In this policy, we refer to “children” as people who are younger than [18] years of age. “Young children” are people younger than [16].

“Child labor” refers to work that deprives children of their childhood and affects their schooling, their potential and their dignity. It’s work that’s harmful to them mentally, physically and socially.

3. Policy elements

Young children

When it comes to young children (younger than [16]), we don’t want to stand in the way of their health, schooling or free time. That’s why we don’t and won’t employ anyone younger than [16 years] of age and require our subsidiaries to do the same, regardless of the country they’re in.

We’re also committed not to do business with any organisation that employs children younger than [13]. We’ll include this condition in every contract we sign and reserve the right to break the contract without penalty if our stakeholder violates this condition and refuses to agree on or follow through with an elimination plan.

Legal exceptions

Agriculture. Many laws make the distinction between agricultural and non-agricultural jobs. Agricultural job requirements for minors may be less strict, especially if a child works at a family-owned farm. In these cases, we’ll follow the law when doing business with agricultural businesses and we’ll make sure that children involved aren’t placed in danger via regular audits and official documentation.

Parental employment. We might occasionally do business with family-owned businesses. Those businesses are usually allowed to employ the owner’s young children as long as the work isn’t too hazardous (e.g. mining, manufacturing). We accept this regulation, but we’ll still dissolve our contract if it comes to our attention that these children are exposed in danger or are working consistently during school hours.

Occasional work. Sometimes, parents bring their children to work to teach them skills and introduce them to a work environment. They may also hand them some tasks to complete (e.g. a painter may ask his child to help with a painting job he’s taken). This is an acceptable practice, as long as it doesn’t deprive children of school on a consistent basis or puts them in any danger. (For example, the painter shouldn’t allow his son to inhale toxic paint or ask him to climb on scaffolding.)

Older children

When it comes to employing children who are older than [16], we’ll always follow the local and international laws. As a general rule, these children can have a job, but they should never do work that jeopardizes their health and safety or affects their schooling and development. They will not use any heavy or dangerous equipment, chemicals or vehicles when working.

We’ll determine their work hours and wage based on applicable laws. We won’t employ children for more than the maximum weekly or daily hours allowed. [For example, according to UK child labor laws, work hours for children between 14 and 16 years old have a limit of part-time work.]

These are mandatory conditions when forming partnerships or other business relationships. We’ll refuse to do business with anyone who employs children of any age in hazardous or exhausting jobs or doesn’t follow applicable laws on working hours or pay. We also expect them to communicate and enforce the no child labor policy to their own contractors.

4. Actions and Implementation

To make sure we enforce this policy and help eliminate child labor, we’re committed to:

• Working with governments and other organisations to end child labor. We may sponsor or organize actions to educate communities, build schools or find ways to ensure children won’t be forced to work to support their families.
• Educating our staff on youth work laws and show them how to report child labor if they see or suspect it.
• Requiring hiring managers and HR to avoid hiring minors under the legal age for working. We also expect them to know and follow this policy and laws on wages and hours for older children.
• Keeping and validating documentation verifying our employees’ age after they’re hired. If we discover that we’ve hired a minor under the age of 16, we’ll review applicable laws and adjust working hours accordingly. If we need to let the child go, we’ll assess their situation and make sure to provide for them to the best of our ability (e.g. pay him or her their would-be salary for a couple of months) when necessary.
• Communicating our no child labor policy to organisations we’re connected with and ensure our contracts have the right stipulations.
• Auditing suppliers and partners (especially those inindustries with high child labor risk) periodically to ensure they aren’t involved in child labor, possibly with unannounced onsite visits too. We’ll require them to provide us with an updated list of all their business locations at all times. If we discover hidden business sites that employ children, we’ll dissolve our contract immediately.
• Demanding and monitoring an elimination plan in cases where suppliers discover child labor in their business. We’ll also work together with the stakeholder to create plans to support children, keeping their best interests in mind, and make efforts to involve them and their families in the process.
• Employing or consulting with experts on topics like child labor, health and safety standards or corporate social responsibility.

Children’s welfare is everyone’s business

We want to grow and thrive as a business, but we’re also committed to do good by the community we belong in. We ask all of our employees and partners to follow this policy, not just because we demand it as an organisation, but because securing a bright future for children is everyone’s duty.

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