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Recruitment and Hiring - Child Labor

  • Updated

Each question below includes its SLCP/FSLM key and the related recommendation. In some cases, the same guidance applies to multiple IDs.

Table of Contents

 

Does the facility verify minimum age requirements prior to hiring workers?

cl-1

Recommendations

  • Require official identification documents (e.g., birth certificates, national IDs, school records) before hiring any worker. 
  • Cross-check age information with government databases if available. 
  • Maintain secure, digital, and physical records of age verification documents 
  • Automate age checks within HR software to flag underage applicants. 
  • Conduct manual verification by HR personnel as an additional safeguard

 

What is the age of the youngest worker in the facility?

cl-1--2

Recommendations

  • Identify and immediately remove the child worker from employment while ensuring that the child is not left in a vulnerable situation. 
  • Collaborate with local NGOs, government bodies, or social programs to support the child’s education and well-being. 
  • Conduct a thorough investigation to determine how the child was employed, whether through falsified documents, lack of age verification, or recruitment agency failures.
  • Strengthen recruitment and documentation processes to ensure proper age verification (e.g., government-issued IDs, biometric verification). 
  • Provide training for HR, management, and workers on legal requirements and ethical hiring practices. 
  • Develop a robust internal monitoring mechanism to prevent future violations. 
  • Establish a transparent reporting mechanism for potential child labor concerns

 

Does the facility have a remediation system in place for when children (those under the legal minimum working age) are found to be working in the facility?

cl-2

Recommendations

  • Create a formal, written remediation policy outlining the steps to take if a child worker is found. 
  • Ensure that the policy aligns with ILO, Fair Wear, and Social Labour Convergence guidelines. 
  • Partner with local NGOs, government agencies, and educational institutions to provide educational and vocational support for affected children 
  • Ensure a robust hiring system that includes strict age verification using government-issued IDs, biometric records, or digital databases. 
  • Require all recruitment agencies and subcontractors to comply with the factory’s child labor prevention and remediation policy

 

Are protective restrictions for workers under the age of 18 in line with legal requirements?

cl-4--10

Recommendations

  • Review all protective restrictions for workers under 18 to ensure compliance with national and international labor laws. 
  • Update the facility’s policies to reflect legal requirements on the types of work and conditions that young workers can be exposed to. 
  • Ensure that specific restrictions are clearly defined, implemented, and monitored to prevent any violations. 
  • Regular audits should be performed to maintain compliance.

 

Does the facility monitor the working hours of all workers under the age of 18 separately?

cl-4--11

Recommendations

  • Implement a separate tracking system for the working hours of young workers to ensure that they are not overworked. This system should adhere to the legal standards set by national authorities and ILO guidelines. 
  • The monitoring process should be automated, ensuring compliance with both daily and weekly working hour limits.
  •  Regular checks and audits should be conducted to ensure that the working hours of young workers are always within legal and ethical limits.

 

Work in a hazardous environment and/or work that is hazardous in nature in violation of legal standards

cl-4--12-1x

Recommendations

  • Review all job roles for workers under 18 to ensure that they are not involved in hazardous work. 
  • Implement a risk assessment program to identify hazardous tasks and eliminate them for young workers. 
  • Any work that could jeopardize their safety, health, or development must be removed from their job description. 
  • Provide appropriate training and supervision to all workers under 18 to ensure they are not exposed to dangerous conditions.

 

Night Work

cl-4--12-3x

Recommendations

  • Ensure that young workers are not engaged in night shifts or work outside of legally allowed hours. 
  • Implement internal policies that restrict the scheduling of young workers during night hours. 
  • Regularly audit shift schedules to ensure compliance with national labor laws and ILO standards. 
  • Where night work is necessary for business operations, ensure that alternative arrangements are made for workers under 18, such as avoiding shifts that extend past legal curfews.

 

Does the facility maintain parental permission of workers under the age of 18 to work in the facility in line with legal requirements?

cl-4--2

Recommendations

  • Conduct a legal review of national labor laws regarding parental consent for workers under 18. 
  • Ensure factory policies meet the specific age thresholds and conditions required by law
  • Develop a standard parental permission form that includes: 
    • Worker’s verified age documentation (birth certificate, national ID). 
    • Guardian’s signed consent acknowledging awareness of employment terms.
  • Clear working conditions, including hours, wages, and job responsibilities. 
    • Ensure all new hires under 18 have proper parental consent forms on file before starting work 
    • Store all parental permission documents securely and ensure they are available for labor inspections or brand audits. 
    • Conduct periodic HR audits to verify compliance and update records if necessary

 

Does the facility provide the list/register of workers under age 18 to government authorities in line with legal requirements?

cl-4--3

Recommendations

  • Conduct a legal review to confirm the specific national requirements for reporting young workers to labor authorities. 
  • Identify the relevant government department(s) responsible for labor compliance and reporting. 
  • Designate a compliance officer or HR manager to handle government reporting obligations. 
  • Establish a structured timeline and internal approval process for reporting young worker data to the authorities. 
  • Keep documented proof of submissions (emails, stamped receipts, or acknowledgment letters) for audit purposes

 

Does the facility arrange health checks for all workers under the age of 18?

cl-4--5

Recommendations

  • Review national labor laws and industry-specific health regulations to ensure that the facility meets all health check requirements and performs checks that are legally mandated. 
  • Ensure medical confidentiality and informed consent are part of the process, with data protection measures in place .
  • By instituting pre-employment health checks, the facility will ensure worker health and safety, meet legal and ethical requirements, and demonstrate a commitment to protecting young workers and maintaining a responsible workplace. 
  • This process will help reduce the medium risk associated with health and safety non-compliance and build stronger relationships with stakeholders, including buyers, regulators, and workers

 

Does the facility comply with legal requirements regarding health checks for workers under the age of 18?

cl-4--6

Recommendations

  • The facility should implement a robust health check program for workers under 18, ensuring it aligns with national regulations and ILO standards. 
  • Regular health assessments should be conducted, including pre-assignment, periodic, and post-employment checks, to ensure the health and well-being of young workers. Any gaps in compliance should be immediately addressed

 

Does the facility provide special Health and Safety trainings (separate from normal adult training) to workers under the age of 18?

cl-4--7

Recommendations

The facility should implement specialized Health and Safety (HS) training for young workers. This training should be designed separately from the training provided to adult workers, with a focus on the specific risks young workers might face (e.g., ergonomics, machine handling). The training should be a regular and integral part of the onboarding and continuous education for young employees. Additionally, the facility should track and document the completion of these training sessions.

 

Is the facility's practice of providing special Health and Safety trainings (separate from normal adult training) to workers under the age of 18 in line with legal requirements?

cl-4--8

Recommendations

The facility should review national labor laws to verify that its specialized Health and Safety training meets or exceeds the required standards for young workers. The facility should document the training content, frequency, and method of delivery to ensure it aligns with legal mandates. Continuous monitoring and updates to the training program may be necessary to maintain compliance and improve the safety of young workers.

 

Does the facility have special protective restrictions for workers under the age of 18?

cl-4--9

Recommendations

The facility should investigate whether there are protective restrictions in place for young workers, particularly in terms of limiting the types of work and the hours they are allowed to work. If such restrictions are not currently in place, the facility must introduce appropriate measures (e.g., limiting hazardous tasks, night shifts, long working hours) in line with ILO guidelines. The facility should also document and communicate these restrictions to ensure that young workers' health and safety are not compromised.

 

Have there been any incidences of forced labor, including sale and trafficking, prostitution, pornography, or illegal activities involving workers under age 18, or work that exposes them to physical, psychological or sexual abuse?

rh-chi-11

Recommendations

The facility must ensure that all workers are free from any form of forced labor, trafficking, or exploitation. This includes implementing robust reporting mechanisms for workers to report abuses and conducting regular audits to prevent such violations. Any incidence of forced labor or trafficking must be reported immediately to authorities, and corrective actions should be taken to address the situation swiftly. Management should be trained on recognizing signs of exploitation, and anti-trafficking policies should be enforced.

 

Is the facility failing to comply with any legal requirements not covered elsewhere regarding Child Labor?

rh-chi-12

Recommendations

The facility should conduct a thorough review of its child labor practices to ensure full compliance with national and international legal requirements. Even if violations are minor, they should be corrected promptly. Regular internal audits should be conducted to check for compliance with child labor laws, and management should be regularly trained on how to identify and address gaps in legal compliance.

 

Does the facility maintain a list/register of workers under age 18 in line with legal requirements?

rh-chi-7

Recommendations

  1. Develop & Maintain a Legally Compliant Young Worker Register Create a formal register listing all workers under 18 with the following details: -Full name and date of birth (verified by official ID). -Parental/guardian consent records (if legally required). -Job role and department to ensure they are assigned non-hazardous tasks.
    • Work schedule and hours to comply with legal limits. -Health and safety training records, if applicable. 
    • Ensure the register is updated regularly and accessible for audits.
  2. Align with National & International Labor Laws -Conduct a legal review to confirm the minimum age for employment and restrictions for young workers. 
    • Ensure that the register meets all national legal requirements and buyer-specific compliance expectations

 

More hours than permitted by law

rh-chi-9x

Recommendations

The facility must adhere strictly to national laws and ILO guidelines regarding working hours for young workers. Overtime should be prohibited for workers under the age of 18, and regular monitoring of working hours should be implemented. Management should be trained to recognize the importance of ensuring that young workers’ working hours do not exceed legal limits, and internal audits should be performed to check compliance.

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