Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance

4. Child Labour and Young Workers
CODE REQUIREMENTS
4.1 There shall be no new recruitment of child labour. 4.2 Companies shall develop or participate in and
contribute to policies and programmes which provide for the transition of any child found to be performing child
labour to enable her or him to attend and remain in quality education until no longer a child. 4.3 Children and
young persons under 18 shall not be employed at night or in hazardous conditions. 4.4 These policies and
procedures shall conform to the provisions of the relevant ILO Standards.
Notes: Definition of ‘a child’ is in accordance to the ILO Conventions for minimum ages (C138) and child labour
(C182). This states that no person will be employed or engaged in work if they are younger than 15 (or 14 in
some developing countries). Light work may be allowed for 12 and 13 year-olds in most developing countries
provided it does not interfere with schooling. However if the legal minimum age is higher than the ILO
conventions then no person may be employed or work if they are younger than the legal minimum age for work
in the country of manufacture, this also applies to persons engaged in a workplace apprenticeship programme.
AUDIT CHECKS AND EVIDENCE GATHERING
Document and system checks including management interview.
Auditors examine policies and written procedures in conjunction with relevant managers. In this section
the auditor checks whether the site knows, and is up to date with, relevant local and national law, the
ETI Code and the standards required. The auditor checks and reports on:
4.1. Whether the site has a policy on child labour and written procedures on how to ensure that children are
not employed at the site.
4.2. Whether the policy on child labour is clear, communicated to workers and displayed.
4.3. That there are systems in place to check the age of all workers particularly at the point of recruitment.
Notes: This should be systematic and the site should retain documentary evidence such as copies of original ID
cards or other evidence that has been produced. However, this should not be used as an excuse to retain
workers’ identity papers. (See Appendix 1: “Guidance by Clause”, clause 1 “Forced Labour”. on Employment
Freely Chosen). The evidence produced will vary from country to country, and wherever possible should be
cross-referenced to an independent source. Management should also be questioned to check whether they are
aware of how to check for fraudulent documents.
4.4. That all personnel files contain copies of proof of age for each worker such as:
a. Worker ID with photo.
b. Birth certificate.
c. Notary or medical checks / examination prior to employment.
d. National insurance or social insurance numbers.
e. Ration cards.
f. Written documents / affidavits.
g. School leaving certificates.
h. School diplomas.
i. And that such documentation is valid and genuine.
SMETA Best Practice Guidance (4-Pillar Version 4.0, May 2012)
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