Child Labour Policy

Child labour is work that deprives children of their childhood, their potential, and their dignity, and that is harmful to physical and mental development. MACVAD has will not accept Child Labour in any part of the supply chain.

Child: MACVAD interprets a Child to be any human being below the age of 18 years

Minimum Working Age:  MACVAD follows the ILO convention that states that no person younger than 15 shall work. However, where local law states a higher age, the local law is to prevail.

 Juvenile worker: According to the ILO, a ‘juvenile worker’ is defined as a worker who has reached the minimum working age but is not yet 18 years old.

Child labour: Child labour at a production facility includes:

• Any child below the legal minimum working age engaged in work
• Any person below the age of 18 working in hazardous conditions

Hazardous conditions: Include, but not limited to, night shifts, overtime, moving heavy objects, exposure to extreme temperature and noise, and handling dangerous machinery.

This policy serves to state our understanding of child labour and expectations of our business partners. It serves to ensure that child labour does not occur along our supply chain by providing guidance on preventing child labour as well as on identifying and remediating situations where children are at risk in production facilities

Children below the minimum working age should not be situated in production areas in production facilities, even when they are not working. A clear delineation between non-production areas (e.g. childcare facilities) and production areas should be ensured. Any children found in production areas of production facilities will be considered a suspected case of child labour

Production facilities should have policies in place for juvenile workers that meet all local laws and (as a minimum) include,

Age Verification: Minimum working age and worker age verification mechanisms to be applied when recruiting new employees. Personal interviews should be mandatory for applicants.

Appropriate verification: Exclusion of medical examinations as an age verification mechanism

Appropriate Placement and rostering Clearly defined age-appropriate roles for Juvenile workers so that they do not engage in Hazardous work and schedules enable at least twelve hours of rest per day and one day off work per week

Segregated documentation: Personnel files of juvenile workers should be kept separate from those of other workers and include a list of all relevant files which should include:

• Copies of age verification documents
• Letter of consent from the worker’s parents/guardians (if required by national law)
• Registration with local authority (if required by national law)
• Updated records of medical examinations (if required by national law)
• Labour contract stating limitations on type of work

Training Apprenticeships/traineeships should be managed as per local law

Suppliers must proactively inform MACVAD about any suspected or confirmed case of child labour at production facilities within 24 hours.

Where MACVAD staff identify a case of child labour in a production facility during an onsite visit they are to follow ‘The Immediate steps upon identification of child labour’ process defined in MACVAD Social Assessment Procedures as

Where MACVAD staff identify a case of Juvenile workers involved in hazardous work during an onsite visit they are to follow ‘The steps upon identification of Juvenile workers involved in hazardous work’ process defined in MACVAD Social Assessment Procedures as

In all cases of suspected Child labour, a systematic and transparent remediation process will be initiated.

MACVAD is to inform Customers with production relationships with facility within 24 hours and to actively work with the customer and and a local expert organisation to jointly assess the situation and develop and implement remediation measures.

 The process is to always take the best interests of the child and their family into account and includes:

Specific remediation of the situation of the children involved

• A joint assessment by MACVAD and the local expert organisation on-site to identify whether the child has been involved in any work. If the child has been involved in work, interviews with stakeholders such as the child, their family and the management of the production facility should be conducted, to understand the root causes of the child labour case.
• Remediation measures include ensuring that any outstanding wages are settled, and that the child is no longer engaged in work, is enrolled in an educational programme, and is provided with a living allowance in line with the minimum living costs or minimum wage of the respective region.
• If a child below the minimum working age is found to be performing hazardous work, remediation measures also include performing a medical examination of the child to establish whether they have experienced any negative consequences as a result of the work carried out. These examinations should only be carried out with the consent of the child and without incurring any costs on them or the family. Based on the results additional remediation measures should be initiated as required.

Remediation at production facility level

• MACVAD and affected Customers will agree on corrective measures tailored to fit the situation at production facility level. This may include the analysis of root causes and the development of an action plan to ensure the prevention of child labour or the revision of the recruiting or age verification system. MACVAD must ensure that the agreed measures are implemented by the Production site Management and must proactively report to the affected Customers

Suppliers and Production sites must keep the following documents on file operational premises:

• Copies of the production facilities’ child labour policy signed by senior management
• Copies of verified proof-of-age documents in the workers’ personnel files (national identity card or birth certificate, local school records or educational certificates, which can be used to cross-check applicants’ age if the ID card is not available)
• Documentation of any previous child labour cases identified and investigated (including details of remediation steps taken)
• Documentation of training sessions conducted and employee communication on employment policies and guidelines
• Permits, licenses, parental consent forms and other documents related to the employment of juvenile workers (e.g. apprentices, trainees and employees under the age of 18)
• Documentation of working conditions of juvenile workers