Child Labour

Business Case

Brand reputation

Proactive child labour prevention protects companies from severe and lasting brand damage, consumer backlash and an erosion of trust that can persist for decades, allowing businesses with robust programmes to avoid the significant reputational costs that follow child labour findings.

Financial resilience

Because child labour findings can lead directly to lost business, consumer boycotts, and the substantial cost of implementing corrective measures across the supply chain, companies recognize that strategic investment in prevention is significantly less costly than the financial fallout of remediation.

Legal and regulatory compliance

With child labour legislation expanding and mandatory due diligence and reporting requirements increasing the compliance burden on companies, those with established prevention programmes are positioned ahead of these evolving regulations and are able to avoid significant fines and legal consequences.

Operational continuity

By establishing due diligence systems, companies can avoid the severe operational disruptions and corresponding costs that occur when responding to child labour findings after the fact, which often requires terminating supplier contracts, relocating sourcing at short notice, urgent supply chain restructuring and dedicating significant internal resources to investigation and remediation.

Stable sourcing communities and sustainable livelihoods

Children attaining education leads to stronger economic development for families and regions, more stable supply and better quality due to increased talent.

Strategy & Planning

Assessment

Initial Action

Identify sectoral exposure, priority product types, products, product components or focus regions and map upstream supply chain actors involved, via collecting data or secondary research on:

  • workforce demographics, such as age profiles, skill threshold required for supplier activities and presence of young workers
  • use of subcontracted, informal, seasonal or home-based labour
  • trends on recruitment practices and age verification processes
  • presence of smallholder farming or artisanal production
  • presence of informal work
  • local regulatory environment on child labour
Intermediate Progress

Conduct a risk assessment annually or as appropriate to categorize and prioritize suppliers by child labour risk level, based on factors such as:

  • sector prevalence of child labour
  • strength of local regulatory enforcement and inspection
  • geographic remoteness or geographic closeness to countries with weak governance
  • degree of informal, seasonal or home-based labour
  • extent of smallholder farming or artisanal production in lower tiers
  • new incident data, audit findings and contextual risk shifts
  • other root‑cause risk drivers such as poverty, school‑attendance barriers and family‑based production
Advanced Practice

Identify gaps in monitoring across high-risk supplier portfolio and develop action plans to address unmonitored categories, regions or supplier groups.

Policy

Initial Action

Define baseline for child labour restrictions to be accepted as the minimum (or higher depending on local laws) in line with International Labour Organization (ILO) convention 138, 182 and United Nations Convention on the Rights of the Child (UNCRC). Establish a policy on child labour prevention and remediation efforts, covering elements in the supplier code of conduct such as:

  • compliance with minimum working age laws
  • age verification procedures at recruitment
  • protections for young workers of legal working age (restrictions on hazardous work, working hours, night work)
  • obligation to report and remediate any identified cases of child labour
Intermediate Progress

Integrate child labour risk criteria into sourcing decisions for high-risk categories, requiring enhanced due diligence on child labour as a condition of supplier approval or contract renewal with mandated due-diligence quality standards, such as:

  • worker and community‑voice integration
  • anti‑falsification controls on age documents
  • third‑party verification of age‑verification systems

For existing suppliers, while focusing on remediation before termination decisions are made, establish a child‑labour escalation protocol with defined consequences and triggers such as:

  • verified child‑labour incidents
  • falsification of age‑verification documents
  • failure to remediate responsibly
  • evidence of hidden subcontracting involving minors
Advanced Practice

Require all suppliers to implement their own child labour zero tolerance policies, due diligence processes and remediation efforts, cascading child labour prevention requirements to their suppliers with clear consequences for violations of policies.

Targets

Initial Action

Set targets on percentage of procurement spend covered by child labour risk screening.

Intermediate Progress

Set targets for percentage of suppliers in high-risk categories assessed on child labour risk or Integrate Child labour assessment targets in the pre-existing supplier risk assessments/audit protocols/due diligence programmes.

Advanced Practice

Set targets for 100% of high-risk suppliers with verified age verification procedures in place.

Supplier Selection

Screening

Initial Action

Screen potential suppliers for child labour risk factors, including past incidents of labour violations, sector risk and geographic risk, by adding child labour-related questions to supplier pre-qualification and request for proposals (RFPs):

  • child labour zero tolerance policies
  • confirmation of compliance with minimum working age laws
  • age verification procedures at recruitment
  • policy on young workers of legal working age
  • transparent reporting for identified cases of child labour
Intermediate Progress

Request evidence of child labour prevention practices in supplier pre-qualification and RFPs to validate authenticity and compliance:

  • audit results or assessment reports on child labour
  • age verification documentation (redacted)
  • training programmes on child labour prevention
  • remediation mechanisms in place
  • records of any incidents and corrective actions taken
  • precautions for legal employment of young workers, such as environment safety and protection of young workers from hazardous work
Advanced Practice

Require suppliers to submit the following as a prerequisite to apply for RFP:

  • child labour due diligence policy covering their own supply chain, including independent verification (e.g., third‑party audits) of age‑verification systems
  • evidence of monitoring and audit processes beyond their own operations
  • remediation protocols and records of corrective actions at sub-tier level
  • documentation of how child labour prevention requirements are cascaded to their own suppliers
  • disclosure of any child labour incidents identified across their supply chain in the past 3 years

Selection

Initial Action

Select suppliers that confirm a zero tolerance child labour policy, compliance with minimum age laws and verification of working age.

Intermediate Progress

Only select suppliers that have evidence of child labour prevention measures as a condition of supplier approval or renewal.

Advanced Practice

Select suppliers that can demonstrate child labour prevention measures not only in their own operations but across their own supplier base, with evidence of cascaded due diligence.

Contracts

Initial Action

Include specific clauses against child labour in supplier contracts, covering due diligence, prevention efforts, minimum age requirements, age verification obligations, reporting of any identified cases.

Intermediate Progress

Include enforceable remediation protocols and right-to-audit clauses with defined consequences for non-compliance.

Advanced Practice

Require suppliers to cascade contractual child labour prevention clauses to their own suppliers, with suppliers taking responsibility for compliance across their own supply chains.

Supplier Engagement

Goal Setting

Initial Action

Set targets with suppliers to complete child labour risk assessments of their operations within a defined timeframe.

Intermediate Progress

Set goals with suppliers on specific strategies to strengthen child labour prevention, such as improving monitoring systems, formalizing recruitment processes, implementing ILO recommended remediation procedures or addressing root causes identified through pilot projects.

Advanced Practice

Set goals with Tier 1 suppliers on working with their suppliers (Tier 2 and 3) to ensure child labour prevention measures are in place across the supply chain and require Tier 1 suppliers to establish multi‑year remediation and prevention roadmaps aligned with community‑level improvements (education access, household income, safe youth employment).

Capacity Building

Initial Action

Provide suppliers with guidance or training on child labour prevention, including:

  • recognizing child labour;
  • differentiating between light work, child labour and worst forms of child labour;
  • understanding the root cause of child labour;
  • international standards, responsible procurement practices, company policies
  • grievance mechanisms and remediation processes
  • case studies on effective child labour resolution
Intermediate Progress

Provide in-depth training to suppliers, such as on the following topics:

  • conducting their own child labour risk assessments and due diligence
  • building internal monitoring and reporting systems
  • working with suppliers or specialized agencies on child labour prevention
Advanced Practice

Provide training on strategies to most effectively address root causes of child labour, such as linking child labour prevention to broader community development, livelihood programmes and education access initiatives.

Data

Initial Action

Request data from suppliers on:

  • lowest age of workers in the workforce
  • number and nature of child labour incidents identified
  • remediation actions taken on any identified cases
  • training records on child labour prevention
  • functioning of grievance mechanisms related to child labour
Intermediate Progress

Support suppliers in developing structured monitoring systems to enable tracking of child labour risks, including:

  • audit records and findings on child labour
  • progress on corrective action plans
  • child labour grievances recorded (number and nature)
  • media reports on instances of child labour
  • official inspection outcomes
Advanced Practice

Work with suppliers to develop integrated reporting systems that capture child labour due diligence data across their own supply chains, including audit findings, incident data, remediation outcomes, etc.

Advisory

Initial Action

Provide guidance to suppliers on how to implement child labour prevention measures, such as age verification procedures and young worker protections, as well as effective remediation.

Intermediate Progress

Consult and work with suppliers on how to assess child labour risks in their own supply chains, including screening their own suppliers.

Advanced Practice

Consult and work with suppliers in embedding child labour due diligence and supplier engagement into their own procurement practices, including developing their own supplier codes, screening processes and engagement programmes on child labour.

Financial Support

Initial Action

Fund supplier access to child labour risk assessment tools, data and training resources.

Intermediate Progress

Provide commercial incentives to suppliers for improvements in child labour prevention performance, such as price, volume, duration, and preferred supplier status.

Advanced Practice

Link commercial incentives (contract extensions, volume increases, pricing adjustments) to verified progress on eliminating child labour risks across the supplier's own supply chain.

Audits

Initial Action

Require suppliers to complete self-assessment questionnaires on child labour prevention policies and practices, covering workforce age profiles, recruitment procedures, young worker management, remediation, and training.

Intermediate Progress

Conduct on-site assessments of suppliers in high-risk categories or sponsor verified third-party auditing, including collaborative assessment and root cause analysis conducted together with suppliers, and verification that grievance mechanisms are functioning and accessible to all workers. Consider consulting and working with children's organizations to get a full picture of the situation on-site.

Advanced Practice

Work with strategic suppliers to conduct their own supplier audits on child labour and share audit findings, including:

  • forced labour grievances recorded (number and nature)
  • audit findings on ILO forced labour indicators
  • progress on corrective action plans
  • worker interview findings, including off-site and in workers' languages
  • official inspection outcomes

Project Partnerships & Innovation

Initial Action

Launch pilot projects with suppliers in high-risk categories to identify root causes of child labour and develop targeted interventions to address identified issues, finding opportunities to increase educational capacity in the region, offer better payment/fair wages and other initiatives to address the root causes of child labour.

Intermediate Progress

Collaborate with suppliers on targeted interventions developed from pilot project findings, such as community education programmes, school enrollment initiatives or income support for vulnerable families.

Advanced Practice

Scale successful pilot interventions to additional suppliers or categories, partnering with NGOs, industry peers or local organizations to address systemic root causes of child labour in shared supply chains.

Continuous Improvement

Metrics

Initial Action

Track the following: -percentage of procurement spend covered by child labour risk screening.

  • percentage of suppliers that have acknowledged child labour policy
  • number of suppliers that have completed self-assessment questionnaires
  • number of child labour incidents reported by suppliers
  • number of suppliers receiving child labour prevention training
Intermediate Progress

Track progress indicators such as:

  • percentage of suppliers with verified age verification procedures
  • number and outcomes of on-site assessments conducted
  • corrective action plan completion rates
  • remediation outcomes for identified cases
  • capacity building effectiveness metrics, such as responsible‑recruitment knowledge gains for hiring teams
Advanced Practice

Track indicators such as:

  • verified elimination of child labour across direct and key upstream supply chain actors, including performance tracking for Tier 2 and Tier 3 suppliers
  • percentage of strategic suppliers conducting their own child labour due diligence
  • trends in child labour incidents across the supplier portfolio over time

Scorecards

Initial Action

Include child labour compliance as a component in supplier scorecards, covering policy existence and execution, self-assessment completion and incident reporting.

Intermediate Progress

Weigh child labour performance in supplier scorecards, incorporating audit findings, corrective action progress, training completion and prevention‑system maturity.

Advanced Practice

Weigh child labour prevention performance in supplier scorecards, with top performers receiving preferential weighting in tenders and bottom performers required to submit improvement plans.

Impact Verification

Initial Action

Gather feedback from suppliers on effectiveness of engagement programmes.

Intermediate Progress

Assess whether supplier engagement initiatives are improving child labour prevention outcomes, including using worker‑voice checks to validate outcomes (anonymous surveys, off‑site interviews with young workers).

Advanced Practice

Measure improvement in child labour prevention outcomes attributable to engagement programmes and validate impact using independent third‑party evaluations, especially in high‑risk regions. For example, consider:

  • comparing incident rates and audit findings before and after interventions
  • tracking remediation outcomes and recurrence rates over time
  • assessing community-level indicators in areas where intervention programmes operate (e.g. school enrollment rates, household income changes)
  • commissioning independent evaluations of programme effectiveness

Sources consulted

Renewable Energy Procurement (Scope 2) Modern-day Slavery and Forced Labour