Executive Brief Ghana’s portfolio-wide child labor risk management pilot: A systematic approach to managing child labor risk in the project cycle Abstract: This note summarizes a systematic approach developed in 2021-2023 by the Social Sustainability and Inclusion (SSI) team of the Ghana Country Management Unit (CMU) to strengthen the management of child labor risk in the portfolio of projects of the CMU. The approach evolved from two processes, namely a portfolio-wide risk mitigation assessment on child labor that identified a potential to strengthen how child labor risk is managed in multiple projects of the CMU portfolio, and the subsequent development of a toolkit to help teams and Project Implementation Units (PIUs) take a systemic approach to how they manage risks related to child labor in projects. The outcomes of these processes were presented to selected managers and professionals in the World Bank and underwent a peer review in 2022. This has been followed by a series of trainings for Project Implementation Units in Ghana in 2022 and 2023, as well as bank-wide dissemination meetings and trainings. The work continues in 2024. Authors: Nneka Okereke, Anna Nordenmark Severinsson, Abdulai Darimani Section 1 - Context THE ENVIRONMENTAL AND SOCIAL FRAMEWORK The Environmental and Social Framework (ESF) came into effect in October 2018. The Environmental and Social Standard 2 (ESS2) defines standards regarding labor and working conditions in investment financing policy projects. Amongst other things, it sets out the principle of preventing child labor. Child labor is caused by socio-economic vulnerability address child labor. The minimum age for and poverty, and also perpetuates children to be involved in light work, poverty into the next generation (ILO, which is limited to helping in economic 2022a; Republic of Ghana, 2017). activities such as for example in the Preventing child labor is therefore family business, and under certain important for the organization’s twin- conditions and to earn pocket money goals to end extreme poverty and boost outside of school hours or during school shared prosperity on a livable planet, as holidays, is 13 years. At age 15, and when well as for the Social Development Goals children have finished their compulsory (SDG). education in Ghana, they can be admitted into employment, but not To better understand the implication of perform hazardous tasks or work in implementing the ESF and ESS2 in the hazardous conditions, for which the Ghana portfolio of projects, the Country minimum age is set to 18 years. Management Unit (CMU) launched a child (Children’s Act, 1998, Act 560). labor risk mitigation assessment of the portfolio in 2021. In the follow-up to the In Ghana, as in many other African findings of this study, the CMU began the countries, the involvement of children in process of implementing a systematic economic activities is a strong and approach to managing child labor risks in prevalent cultural feature (GSS, 2018). the project cycle. This approach is However, not all these activities are child presented in this technical note. labor, as defined internationally and nationally. When children are above the CHILD LABOR IN GHANA minimum age, and their work activities do not negatively affect their health and Sub-Saharan Africa stands out globally personal development, or interfere with with an increase in both the percentage schooling, then their work is generally and absolute number of children in child regarded as positive (ILO, 2022b). labor since 2012. If other regions of the However, children should never be world have made progress in reducing involved in activities that are harmful, child labor, there are now more children dangerous, or exploitative and interfere in child labor in sub-Saharan Africa than with their education. In Ghana, the anywhere else in the world. Indeed, the percentage of children engaged in child incidence of child labor in Africa stands labor is estimated to be 27.9 per cent - at 23.9 per cent on average according to for children aged 5 to 17, - and this ILO and UNICEF estimates from 2020. estimate also includes children engaged (ILO and UNICEF, 2021). Ghana has a in household chores. A large proportion relatively robust legal framework to of these children - 74 per cent of all children involved in child labor, and 20.7 Other factors that contribute to child per cent of the total child population labor exist particularly in the informal aged 5 to 17 - are involved in hazardous sector where there is a lack of child labor (MICS, 2017/18). Hazardous opportunities for exercising labor rights. child labor is considered one of the worst Business practices that create high forms of child labor, set out to be demand for low labor costs, combined eliminated by 2025 in the SDG-agenda with weak inspection regimes and law target 8.7 . enforcement, also contribute to increased risks of child labor. This In addition to the prevalence of child combined with the socio-economic labor in Ghana, it is also a country of vulnerability of families and children destination for child trafficking, a creates both push and pull factors that phenomenon that seems to be on the are part of the root causes of child labor. increase. In 2023, the government (ILO, 2022c). identified and referred 573 trafficking victims to services. Most of these - 359 In Ghana, the socio-economic victims were children. Many of these vulnerability of families and children is children are Ghanaian and were trafficked high. Close to 10 per cent of all children within the country for purposes of under 5 have not been registered at birth exploitation in a range of sectors (US (MICS, 2017/18), which negatively impacts Department of State, 2023). their ability to access education and social protection (Government of Ghana THE CAUSES OF CHILD LABOR and UNICEF, 2017). The poor health and nutrition of both adults and children The causes of child labor are generally result in limited access to a healthy recognized to exist at several levels. workforce, and this is also known to Some are related to community- and contribute to child labor (UNICEF, 2018). societal conditions that facilitate child In Ghana, an estimated 17.5 per cent of labor. For example, a generally accepted children under 5 have stunted growth, practice of involving children in work which is an indicator of chronic when they are young can make child malnutrition (MICS, 2017/18). Malnutrition labor difficult to detect. The confusion and health issues in childhood affect about the different types and conditions education outcomes and contribute to of work that are acceptable, and work children dropping out of school and not that is harmful to the health and reaching their full potential. Many primary development of the child, is also a reason school aged children are out of school, why child labor is endemic in many often due to the demands of work. societies and communities. In Ghana, an estimated 6 per cent of with a well-defined institutional and legal school-age children are thought to be framework for leading and coordinating out of school (MICS, 2017/18). the assessment and environmental protection. However, the same level of Understanding the cultural norms that clear, comprehensive, and coordinated encourage work from a young age is also social risk management is lacking in crucial to addressing the prevalence of Ghana. While there are institutions and child labor in Ghana. Cultural norms laws relating to social risk management determine the socialization of children, and child labor, they are dispersed, and especially in rural areas and among poor coordination remains a major challenge. families, and they are a driver of child labor (Chance for Children, MFCS, Safe In the Ghana portfolio, there are currently Child Advocacy, and Street Invest, 2021). numerous projects that risk contributing to child labor, such as: CHILD LABOR RISK IN THE GHANA PROJECT-PORTFOLIO Projects that involve civil works and construction (26 projects). Ghana’s economy is largely dominated Two (2) agriculture/cocoa projects by sectors that are prone to the use of that have known child labor risks and child labor, especially the rural sector and provide opportunities for prevention its specific sub-sectors: agriculture, such and strengthening the risk as cocoa, forestry, fishing, the mining management capacity and sector, and the services sectors. The collaboration between stakeholders informality of production and processing, on this issue. and high levels of manual work, contribute to a higher prevalence of child In addition, international awareness of the labor in these sectors. Agriculture, pervasiveness of child labor, and the lack forestry, and fishing alone are reported to of progress to address this issue, have employed more than half of the especially in Africa (ILO and UNICEF, population of Ghana. Given that the 2021), has created increasing pressure to World Bank is supporting the develop more comprehensive programs Government with several projects in that address the root causes of child these sectors, there is a clear incentive to labor (Durban Call to Action on the prevent the use of child labor in these Elimination of Child Labour, 2022; Ergon, sectors. 2020). The World Bank's multisectoral portfolio of projects in Ghana creates Over the years Ghana has developed a many opportunities for addressing the comprehensive and integrated approach root causes of child labor and for for environmental impact assessments purposefully managing the child labor risk in the country. The World Bank in Ghana through a programmatic approach. A therefore has an opportunity to both help programmatic approach both manages increase awareness of child labor and risk project-by-project, and also promote practices that reduce child leverages human development projects labor risk in high-risk sectors, as well as for prevention in geographic areas where the potential to leverage the prevention- the child labor risk is high. The portfolio effect of human development projects. currently includes opportunities in: These can be designed with a child labor prevention lens in mind, and targeted to Seven (7) projects: 3 in health, 1 in regions where the child labor risk is the education, and 3 in social protection highest. that are already promoting child rights, child welfare, and child development through improved social Figure 1: Ghana’s portfolio of projects in performance. the context of regional child labor Four (4) projects in finance, prevalence competitiveness, and innovation that provide opportunities for child labor prevention through innovative policymaking and financing mechanisms. Studies of electrification impacts on women's entrepreneurship, and child exposure to domestic use of natural gas are potential interventions in the 2 energy projects for child labor prevention. Two (2) digital projects that have the potential to provide lessons for the development of protocols on indecent exposure of children. Looking at the geographic distribution of projects, Figure 1 illustrates how multiple projects intervene in regions with the highest child labor prevalence rates Section 2 - Managing child labor risks related to child labor, and the risk in the project cycle provision of options and guidance tools for managing this risk. A TOOLKIT FOR STEP-BY-STEP GUIDANCE The toolkit includes five sections with guidance, tools, and templates for each To help project teams manage child labor project cycle step. The first three steps risk more systematically, a toolkit was are focused on the project conception developed in 2021/22 by the Ghana and preparation phase, namely how and Social Sustainability and Inclusion (SSI) what to do to (1) screen projects for child team. This toolkit provides step-by-step labor risk; (2) consider child labor guidance to ensure that risk management mitigation options; (3) select child labor is implemented systematically mitigation strategies; and two steps throughout the project cycle, in line with aimed for the project implementation the ESF and ESS2. The toolkit is intended phase, namely what to think about and to be used by project task teams, social how to (5) implement risk mitigation specialists, and PIUs and will help with the techniques; and (6) monitor and evaluate categorization of projects according to results. Figure 2: Components of toolkit to manage child labor risk PROJECT CONCEPTION AND Guide teams on the significance of PREPARATION PHASE factors for child labor risk; Do an initial classification of projects Step 1: Screen for child labor risk with a that allows the application of the project risk screening tool. The risks “proportionality”-principle described related to child labor that should be in the ESF; considered in World Bank projects in Support the design of mitigation Ghana include all forms of child labor, strategies and ensure that child labor including the worst forms of child labor risk is taken into account from the such as hazardous child labor, forced beginning of the project cycle and child labor, and labor resulting from integral in the project design; human trafficking. A child labor risk Provide an entry point to address screening tool helps to screen projects child labor and engage in dialogue during the project-identification stage. with the client as a starting point for The purpose of the child labor risk broader stakeholder consultations screening tool is to ensure: and more robust studies, as and if needed. Systematic information gathering and informed decision making on whether a more robust analysis is needed to understand risks related to child labor and capacities to manage this risk; Box 1: Indicators to determine child labor risk in a project Sensitivity of receiving environment, such as child labor prevalence, access to social services, recent adverse events influencing socio-economic vulnerability in the project intervention areas; Borrower capacity and commitment, such as ratification status of major international legal frameworks related to child labor, laws, strategies, and prior experience in implementing child labor prevention interventions; Project characteristics, such as sector prevalence of child labor, workforce profile, project expected impact on livelihoods, and social services access in project target areas. Child labor risk screening will necessarily workforce of the project. Risk mitigation take place in the broader process of may also require strengthening of undertaking a social and environmental national systems that may go beyond the risk assessment. While child labor risk specific sector or ministry responsible for screening is not always necessary, it can managing the project. be useful in some contexts, for example, if: The higher the risk, the more actions and stakeholders might need to be involved The broader social and environmental in the risk management strategies. For risk assessment done at the concept example, low-risk projects may not need stage brings up any issues and risks any further analysis. However, projects related to child labor, trafficking, or with child labor risk assessed as broader labor related risks such as moderate, substantial, and high, could forced labor; benefit from additional information A project intervenes in agriculture, gathering and analysis including analyses mining/industry, and/or involves of the capacities in place to manage this construction work in countries with risk within the sector and areas of high child labor prevalence, such as in implementation of the project. The Ghana. options chosen to manage child labor risk would depend on the level of risk and the A tool to help screen projects and outcomes of more detailed studies. determine the extent to which a project Figure 3 illustrates risk-mitigation requires risk management strategies is pathways depending on the level of included in the toolkit and includes assessed risk of a project. indicators as outlined in Box 1. Step 2: Consider child labor mitigation options. Based on the answers to the series of questions included in the risk screening step, the tool will help project teams calculate a score that will categorize a project as low, moderate, substantial, or high risk. Each risk-level has a specific pathway of recommended actions that are linked to the risk- hierarchy defined in the ESF. Actions to mitigate the risks can be implemented within the sectors of intervention of the project, in workplaces or within the Figure 3 – Hierarchy of risk mitigation pathways depending on risk level Step 3: Select and design child labor especially when adult labor is scarce, can mitigation options. This part of the increase the risk of child labor. Projects toolkit includes guidance for risk that initiate sector modernization and management options and suggestions for sector reforms to increase productivity their design and contents. The toolkit and effectiveness can proactively unpacks and provides examples, address these hazards and do much to checklists, and template-language that reduce the incidence of child labor and consider domestic laws and regulations hazardous child labor. In Ghana, some for the design of risk management and sector-specific hazards have been prevention strategies. In line with the risk identified in labor legislation and mitigation hierarchy, strategies to guidelines on hazardous activities for strengthen risk management include: children (Children’s Act, 1998, Act 560; Child Labour Unit, 2016; Ghana Labour Child labor sensitive sector reforms: Regulations, 2007, LI1833). World Bank Manual and labor-intensive work, projects, particularly in agriculture and industry, can proactively ensure that modernization reforms reduce these the application of the ESS2 and the hazards, by introducing machinery to development of Labor Management replace manual labor, providing Procedures (LMPs) that define working protective equipment, introducing more conditions for children between the ages resistant varieties of crops, using eco- of 14 and 18 who may be involved in friendly pest management methods, and World Bank projects. In Ghana, the other mitigations. On the other hand, minimum age for employment in World projects that support the human Bank projects is 15 years, and the development agenda, such as expanding minimum age to perform light work education, health, nutrition, safe water activities is 14 years, as long as these and sanitation facilities, and social activities do not jeopardize the health protection, can contribute to holistic and development of children (Children’s prevention programmes, especially Act, 1998, Act 560). implemented as a comprehensive package in communities where child Box 2 includes some examples of what labor risk and prevalence is the highest conditions to put in place for children (Republic of Ghana, 2017). over 14 and 15 to be able to engage in economic activities, or be employed, Workplace labor management: For IPFs, without risk. child labor risks can be managed through Box 2: Protecting children through labor management may include: Age verification procedures, development of a workplace child labor awareness and training plan, child safeguarding and protection policy on worksites; Monitoring and supervision plan, establishment of logbooks on worksites, naming and making someone responsible for supervising working conditions, Establishing a policy and plan for health and safety at work; Having contractors sign codes of conduct to facilitate the due diligence of contractors; Making it compulsory to have written parental consent for the involvement of children above minimum age and below 18; Establishing child protection procedures in workplaces. High-risk cases of forced child labor, trafficking, and severe vulnerability of a child labor case, are to be managed in accordance with the Government of Ghana’s Inter-Sectoral Standard Operating Procedures for Child Protection and Family Welfare. The Government of Ghana with UNICEF support developed an Inter-Sectoral Standard Operating Procedure for child protection and family welfare (ISSOP) If World Bank projects increase systematizes both a programmatic awareness of child labor risk, and approach to child labor prevention implement appropriate labor through planning for convergence with management, this can contribute to other projects, interventions increased decent work opportunities and implemented by other stakeholders, and reduced vulnerability for young people a project-by-project risk management entering the country’s labor market. This approach. is an important strategy to prevent child labor (Durban Call to Action on the The tools to mainstream these strategies Elimination of Child Labour, 2022). include labor management procedures, child labor action plans, stakeholder Capacity strengthening for the broader engagement processes, procurement national systems: Most projects are not processes and documents, grievance and primarily designed to reduce child labor. redress mechanisms and processes. Similarly, sectoral reforms aimed at reducing sector-specific factors that PROJECT IMPLEMENTATION PHASE increase the risk of child labor and hazardous child labor do not always Step 4: Implementation of child labor sufficiently mitigate the risks of child risk management techniques. The labor and child trafficking. This is responsibility for implementing child particularly the case in areas where labor management techniques falls upon families and children are highly vulnerable different stakeholders, including the and face multiple deprivations. Some World Bank, the Borrower, and Third projects may therefore need to Parties. This section of the toolkit clarifies strengthen capacity for prevention, the responsibilities of various identification, and remediation of child stakeholders and offers room for the labor cases. This can be done in close expansion of the toolkit with additional coordination with other stakeholders who checklists and guidance regarding each are already specialized in the field of of the recommended actions for various child protection and child labor. stakeholders involved. Figure 4 Stakeholder engagement processes can summarizes the responsibilities of the be planned and implemented to design World Bank, the borrower, and Third mutually reinforcing and complementary Parties in the implementation of child interventions to prevent child labor. The labor risk management strategies. Ghana child labor risk management Responsibilities held by social toolkit therefore promotes and development specialists and PIUs. Figure 4: Responsibilities for implementation of risk management techniques Step 5: Supervision, monitoring, and be carefully considered and, ideally, evaluation. Identifying child labor can be frameworks for identifying and difficult, especially in countries where monitoring child labor should be followed children’s involvement in economic and implemented by professionals who activities is common, as in Ghana. It is are trained to do so. For professionals not important to note that adequate responsible for monitoring child labor, opportunities for children who have further guidance and tools will be reached the minimum age for light developed to help field observations, economic activities (14 years and older in undertake Focus Group Discussions World Bank projects in Ghana) and (FGDs), interviews with young workers, employment (15 years and older) are adult workers, communities, and other important for both child development stakeholders to facilitate a continuous and family living standards, as well as for assessment of risk, relevance of combating child labor. Therefore, when mitigation options and impact during identifying child labor, definitions should project implementation. Acknowledgements: The authors are grateful to Nicolas Perrin and Senait Nigiru Assefa, current and former Practice Managers, SAWS1 and Michelle Keane and Agata Pawlowska, current and former Operations Managers as well as Pierre Laporte, Ghana Country Director, AWCW1 who provided senior leadership of the process. The team is also grateful to Dan Owen, Lead Social Development Specialist and Global Focal Point on Child Labor, SAES3, for providing valuable inputs and comments; Chukwudi Okafor, Lead Social Development Specialist, SAWS1; Sarah Antwi Boasiako, Senior Social Development Specialist, SAWS1; Una Meades, Lead Environmental and Social Standards Specialist, OPSEF; Jelena Lucic, Senior Social Development Specialist, SCASO; and Harjot Kaur, Senior Social Development Specialist, SSAS2, Joost Kooijmans and Johanna Selth, OPSEF for comments on the toolkit and for supporting its dissemination. The development of this systematic approach to preventing and managing child labor risk has also benefited from cross-fertilization of lessons learned with the Côte d’Ivoire CMU, where child labor work has been spearheaded and led by Alexandra Niesslein, Senior Social Development Specialist, SAWS4, Kristyna Bishop, Lead Social Development Specialist, SAWS4, and Pia Peeters and Aly Sulficar Rahim, current and former Practice Manager, SAWS4. Bibliography: Ghana Labour Regulations (2007), LI1833. Gazette notification 8 June 2007. Chance for Children, MFCS, Safe Child Ministry of Manpower, Youth and Advocacy and Street Invest (2021). Employment. Headcount of street connected children in the central business district and Government of Ghana and UNICEF (2017). surrounding areas of Kumasi. Birth Registration in Ghana: A Bottleneck analysis for Improved Coverage that Children’s Act, 1998, Act 560. Gazette Leave No Child Out. Online. notification, 5 February 1999. Act of https://www.unicef.org/ghana/media/931/ Parliament. Ghana. file/Birth%20Registration%20in%20Ghan a%20- Child Labour Unit (2016). Hazardous Child %20A%20Bottleneck%20Analysis.pdf Labour Activity Framework for Ghana, (Accessed 30 April 2024). 2016. Labour Department, Ministry of Employment and Social Welfare. Online. ILO (2022a). The elimination of child Available at: labour and its root causes – the guidance https://www.cocoainitiative.org/sites/def offered by the ILO MNE Declaration. ault/files/resources/Hazardous-Activity- Online. Available at: Framework_2016-002.pdf. Accessed 30 https://www.ilo.org/wcmsp5/groups/publi April 2024. c/---ed_emp/---emp_ent/--- multi/documents/publication/wcms_844 Durban Call to Action on the Elimination 331.pdf (Accessed 30 April 2024). of Child Labour (2022). 5th Global Conference on the Elimination of Child ILO (2022b). What is child labour. Online. Labour. Online. Available at: Available at: https://www.5thchildlabourconf.org/sites https://www.ilo.org/ipec/facts/lang-- /default/files/2022- en/index.htm Accessed 10 August 2022. 06/Durban_Call_to_Action_EN_202206 (Accessed 30 April 2024). 07_0.pdf (Accessed 30 April 2024) Republic of Ghana (2023). Ghana Ergon (2020). Research summary: Accelerated Action Plan Against Child Building on lessons learned from child Labour. National Plan of Action for labour interventions worldwide. Report Elimination of Child Labour 2023-2027. for the World Bank. London. Online. Available at: https://melr.gov.gh/files/publications/Gha na_Accelerated_Action_Plan_Against_C hild_Labour.pdf. (Accessed 30 April 2024). ILO (2022c). ILO Brief: The elimination of child labour and its root causes – the guidance offered to by the ILO MNE Declaration. Online. Available at: https://www.ilo.org/wcmsp5/groups/publi c/---ed_emp/---emp_ent/--- multi/documents/publication/wcms_844 For more information visit: the AFWSSI- 331.pdf. (Accessed 30 April 2024). Platform ILO and UNICEF (2021). Child Labour May 2024. Global Estimates 2020, Trends and the Road forward. Online. Available at: https://www.ilo.org/wcmsp5/groups/publi c/---ed_norm/--- ipec/documents/publication/wcms_7975 15.pdf. (Accessed 30 April 2024). MICS (2017/18). Snapshot of key findings: Ghana Multiple Indicator Cluster Survey 2017/18. Online. Available at: https://www.unicef.org/ghana/media/576 /file/Ghana%20Multiple%20Cluster%20In dicator%20Survey.pdf. (Accessed 30 April 2024). UNICEF (2018). Children’s Rights in Cocoa-Growing Communities of Cote d’Ivoire. Online. Available at: https://sites.unicef.org/csr/css/synthesis -report-children-rights-cocoa- communities-en.pdf. (Accessed 30 April 2024). U.S. Department of State (2023). Trafficking in Persons Report: Ghana. Online. Available at: https://www.state.gov/reports/2023- trafficking-in-persons-report/ghana/ (Accessed 30 April 2024).