JUNE, 2024 Toolkit: Managing Child Labor Risk in Ghana World Bank Projects ACKNOWLEDGEMENTS This toolkit was prepared by the Ghana Social Sustainability and Inclusion team. The core team that prepared the toolkit was led by Nneka Okereke, Senior Social Development Specialist, SAWS1. Abdulai Darimani, Senior Social Development Consultant, SAWS1, provided valuable comments and inputs throughout the processes. Anna Nordenmark Severinsson, Senior Child Labor and Child Protection Consultant, SAWS1 and SAWS4, was the lead author of the toolkit. Adaorah Chisom Oduah, Consultant, proofread and designed the report for publishing. 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. 2 TABLE OF CONTENTS Acknowledgements...............................................................................................................................................2 Abbreviations............................................................................................................................................................4 Definitions....................................................................................................................................................................5 Background.................................................................................................................................................................9 The Bigger Picture.................................................................................................................................................10 Relevance to the Ghana Portfolio..............................................................................................................10 Entry points to addressing child labor in the Ghana portfolio..............................................12 Approach to addressing child labor in the Ghana portfolio....................................................14 Introduction to the toolkit...............................................................................................................................16 Objectives of the toolkit...................................................................................................................................17 Components of the toolkit..............................................................................................................................17 Scope of the toolkit.............................................................................................................................................18 Target Audience.....................................................................................................................................................18 ​ Step 1: Screen projects for child labor risks........................................................................................18 ​ Child labor risk screening...............................................................................................................................22 Step 2: Consider mitigation options.......................................................................................................23 Risk mitigation pathways................................................................................................................................23 ​ Step 3: Select child labor mitigation options...................................................................................25 ​ Option 1: Child labor sensitive sector reforms................................................................................25 Option 2: Labor management.....................................................................................................................28 Option 3: Child labor action plan..............................................................................................................32 Option 4: Stakeholder engagement........................................................................................................37 Option 5: Grievance and Redress Mechanisms adapted to respect a child’s protection rights...................................................................................................................................................38 Step 4: Implement child labor mitigation options........................................................................39 Distribution of responsibility burden for risk management amongst actors ​ involved in implementation..........................................................................................................................39 Good practices to protect children through labor-management procedures.......40 Good practices for upholding children’s rights in prevention, identification, response, and remediation efforts..........................................................................................................44 Good practices in child protection procedures for high-risk cases and child victims.........................................................................................................................................................................46 Step 5: Supervision, monitoring, and evaluation............................................................................47 Annex 1: Questions that can help to assess child labor risk for a project under preparation..............................................................................................................................................................49 Annex 2: Checklist for Including Child Labor risk mitigation in Labor Management Procedures (LMPs) in Ghana projects..................................................................................................56 3 ABBREVIATIONS CMU Country Management Unit DHS Demographic Health Survey DPF Development Policy Financing ESF Environmental and Social Framework ESS Environmental and Social Standards GRM Grievance Redress Mechanism IFP Investment Project Financing ILO International Labour Organization LMP Labor Management Procedures LSMS Living Standards Measurement Survey MICS Multi-Indicators Cluster Survey P-for-R Program-for-Results SEP Stakeholder Engagement Plans SDG Sustainable Development Goals WFCL Worst Forms of Child Labor 4 DEFINITIONS Child  A child means every human being below the age of 18 years unless under the law applicable to the child, maturity is attained earlier.  Permitted / authorized The International Labour Organization’s (ILO) work of children  Minimum Age Convention no. 138 says that children above the minimum working age / minimum age for employment (between 15-18 in most countries) can work full time so long as they are not doing work which is considered a “Worst Form of Child Labour” (see below definition). Developing countries may set a lower general minimum working age of 14. On World Bank projects, the ESS2 defines the minimum age for employment or engagement in connection with the project, which will be the age of 14 unless national law specifies a higher age. Ghana legislation (Children’s Act, 1998) defines the minimum age for employment as 15 years. In this case, Ghana legislation sets a higher standard which means that on a World Bank project, children can be employed at the age of 15 and above only. Specific conditions apply for each age group and are further described in the guidance note.    Child labor  Work that deprives children of their childhood, their potential, and their dignity, that is harmful to physical and mental development and that is mentally, physically, socially, or morally dangerous and harmful to children; and/or that interferes with their schooling by depriving them of the opportunity to attend school; obliging them to leave school prematurely, or requiring them to attempt to combine school attendance with excessively long and heavy work. Work by children is  “child labor” when the child is too young (below the applicable minimum age), or when the type and hours of work performed, or the conditions under which it is performed make such work unsuitable for a person under 18 years.  5 Permissible light work  Light work for children aged 13–15 (for limited hours and not harming their health, safety, or school attendance and achievement), or for those aged 12- 14 if the minimum age is set at 14, can be permitted. Safely helping around the house can be an important part of childhood in some cultures. Light work, however, should not be for more than 14 hours per week. Ghana legislation (Children’s Act 1998) defines the minimum age for light work at 13 years, which means that on a World Bank project, a higher standard of 14 years applies.  Worst Forms of Child Defined by Article 3 of the ILO Convention no. 182 on Labor  the Worst Forms of Child Labour, these forms include all forms of slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage and serfdom, and forced or compulsory labor, including forced or compulsory recruitment of children for use in armed conflict; the use, procuring or offering of a child for prostitution, for the production of  pornography or for pornographic performances; the use, procuring or offering of a child for illicit activities, in particular for the production and trafficking of drugs as defined in the relevant international treaties; work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children.  Hazardous child labor  Within the meaning of Articles 3 of both Conventions no. 138 and no. 182, hazardous work is considered to be work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety, or morals of children. Convention no. 182 classifies hazardous work as one of the Worst Forms of Child Labor.  6 Forced Labor  According to Conventions no. 29 and no. 105 of the ILO on Forced Labor, forced labor is defined as “all work or service exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily”. (NB: consent is never applicable for children)  Child trafficking As per Article 3 of the Protocol to Prevent, Suppress and Punish trafficking in Persons Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (“Palermo Protocol”): "Trafficking in persons" shall mean the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, servitude or the removal of organs; The consent of a victim of trafficking in persons to the intended exploitation set forth in subparagraph (a) of this article shall be irrelevant where any of the means set forth in subparagraph (a) have been used; The recruitment, transportation, transfer, harboring or receipt of a child for the purpose of exploitation shall be considered "trafficking in persons" even if this does not involve any of the means set forth in subparagraph (a) of this article; "Child" shall mean any person under eighteen years of age. In other words, in the case of children no means at all, including coercion, deception or threat, are required to establish the victim status of the child and qualify her/him as trafficked.  7 Vulnerability  According to the United Nations “Palermo Protocol”, “abuse of a position of vulnerability” qualifies as the combination of means through which persons can be subjected to a range of particular actions such as recruitment, transportation, and harboring, for purposes of exploitation. “Vulnerability” is used to refer both to the pre-existing individual and structural factors that may increase the susceptibility of an individual or group to trafficking in persons and to those elements that may be generated by the trafficker to maximize control over the victim in the context in which the exploitation takes place (such as isolation, dependency, and irregular legal status). Copyright All rights reserved by Africanfuturist, Flickr 8 Background 1 1. Child labor is a human rights violation, a global problem, and an African emergency. It is estimated that 160 million children worldwide are involved in child labor. More than half of these children are in sub-Saharan Africa. 1 The current situation and trends risk reversing global progress. The Sustainable Development Goal (SDG) Target 8.7 to “eradicate forced labor, end modern slavery and human trafficking and (...) elimination of the worst forms of child labor”, risks not being reached. 2 1. Barriers to active participation in human and social development, gender inequality, environmental degradation, and lack of access to basic services such as birth registration, health services, clean water, sanitation, and hygiene facilities are root causes of why families continue to live in precarious living conditions and are prone to disease and malnutrition. These are conditions that perpetuate poverty which is one of the main root causes of child labor. Other causes include social norms that condone child labor, lack of decent work opportunities that are compliant with labor standards established by law, and the cost of hired labor. Combined with low access (physical and financial) to education and, the lack of identity documents required for being admitted and/or taking exams in school, parents and children are not able to prioritize education over child labor. Poor quality of education due to lack of relevance of the curricula, shortage of qualified teachers, poor school infrastructure, and inadequate sanitation facilities, and for girls, the perceived risk of being physically and sexually abused at school, leads to early school dropouts, early marriage, and child labor. Tackling child labor requires tackling its root causes. International experience indicates that an effective approach to eliminating child labor must address the complex and interlinked set of economic and social issues in an integrated and coordinated fashion, at the national and local levels. Copyright All rights reserved Fanellino, Flickr 1. 5th Global Conference on the Elimination of Child Labour, Durban, 15-20 May 2022. Online. Available at: https://www.5thchildlabourconf.org/en (Accessed 29 June 2022). 9 The bigger picture 13 Child labor also has a direct causal link with other SDGs (such as SDG 1, 3, 4, 5, 10, 11, 12) as well as with the World Bank’s objectives to “end extreme poverty within a generation and boost shared prosperity on a livable planet”. This is because child labor interferes with children’s school attendance and skills development, which in turn influences their earning capacity and future income. Low incomes increase the probability of the next generation of children having to work too, which perpetuates poverty and child labor. Child labor also lowers the perceived cost of having children thereby boosting fertility. Larger family size in turn fuels the need for the income provided by children, which also contributes to child labor. Child labor in turn decreases a country’s labor productivity, 2 slows down technological progress, growth and social development. Relevance to the World Bank Ghana portfolio of operations 41. The socio-economic vulnerability of children and families, which are known root causes of child labor, is high in the countries covered by the Ghana CMU (Ghana, Sierra Leone, and Liberia). Child labor prevalence is also high in all three countries and most child labor is hazardous. In addition, all three countries have a risk of child trafficking. Children living in traditional and informal “foster care” arrangements are particularly vulnerable. Parents or immediate caregivers send their children via intermediaries to work and live with relatives, where children end up exploited in harsh conditions and in forced labor. Each country has its distinct dynamics depending on demands in predominant economic sectors. Students line up to wash their hands before eating at Kanda Estate Primary School in Accra, Ghana on October 13, 2015. Photo © Dominic Chavez/World Bank 2. Rossana, G. (2001). The Economic Impact of Child Labor. University of Zurich, International Institute for Labor Studies Geneva. 10 Table 1, summarizes information on a few selected indicators of socioeconomic vulnerability that contribute to child labor. Table 1 - Socio economic vulnerability and child labor prevalence in Ghana CMU   Ghana (MICS Liberia (DHS Sierra Leone 2017/18)  2019/20)  (MICS 2017)  Poverty & living standards        Household using unsafe water 14%  16%  32.2%  sources  Health insurance coverage (15- 55.6% (F) 40.2% 4% (F) 7% (M)  2.4% (F) 2.1% 49)  (M)  (M)  Education & awareness        Literate (15-49 yrs)  65% (F) 79.4% (M)  52.2% 41.5% (F) 74.3% (M)  (F) 58.3% (M)  Access to any mass media5 on 77.1% (F) 83.9% (M)  26.5% 42.1% a weekly basis (15-49 yrs)  (F) 42.4% (M)  (F) 63.7% (M)  Children out of school  6%  Not available  18.1%  Survival & Health        Reported disease episodes (0- 25.7% (fever)  25% (fever)  21% (fever)  59 mths) 6  Nutritional status children U5 17.5%  30%  26.4%  (stunted) 7  Birth registration        Children U5 with birth 91.3%  66.3%  71.8%  certificate  Protective family environment Children 1-14 who experiences 16.6%  20.4%  25.5%  severe physical punishment  Living with neither biological 16.6%8  27%  24.9%9  parent (0-17 yrs)  11 Child labor        Child labor (5-17 years old)  27.9%  32%  39%  Hazardous child labor (5-17 20.7%  30%  30.7%  years old)  Child trafficking        Tier in Trafficking in Persons Tier 210  Tier 2 Watch Tier 212  Report  List11  No. of child victims in 2020  417 child trafficking 29 victims in Victim / 499 total. Majority 2020 (child protection to domestic labor victims not 22 children trafficking  known)  (out of 73 cases) Specific vulnerability  Children in traditional /informal “foster care” arrangements Entry points to addressing child labor in the Ghana portfolio 5 1. The World Bank's multisectoral portfolio of projects creates many opportunities for addressing child labor. In fact, the World Bank portfolio in the Ghana CMU corresponds very well with what is included as priorities in 3 the Durban Call to Action 2022, in particular giving people of minimum age access to decent work. The World Bank’s projects in agriculture intervene in the sector with the highest child labor risk, while the projects supporting quality and access to education can strengthen the first line of prevention. Social protection is essential but must be child-friendly. The World Bank also has programs that could help fill the gaps in birth registration and identity documents that facilitate access to education and services, health services, access to nutrition, and water and sanitation facilities that have the potential to improve the health and productivity of the adult workforce. Copyright All rights reserved by Claude Gourlay, Flickr 3. Durban Call to Action on the Elimination of Child Labour (2022). 5th Global Conference on the Elimination of Child Labour. Online. Available at: https://www.5thchildlabourconf.org/sites/default/files/2022-06/Durban_Call_to_Action_EN_20220607_0.pdf (Accessed 29 June 2022) 12 6 1. It is, however, the Environmental and Social Standards (ESS) of the Environmental and Social Framework (ESF) that provide an urgent entry point to address this problem, since it sets out the requirements for borrowers in identifying and assessing environmental and social risks and impacts associated with projects supported by the World Bank. The ESF specifically addresses child labor, and various ESS help regulate child labor risks. Table 2 provides details on the ESS relevance for mitigating child labor risks in the Ghana context. Table 2 - Relevance of ESS for mitigating child labor risks in the Ghana context Standard  Topic  Relevance  Relevance for all sectors of investment, Assessment and especially agriculture projects, mining Management of sector projects, and projects involving ESS1  Environmental and construction work. Annex 1 proposes child Social Risks and labor risk assessment questions that can Impacts  help define risk levels. Potentially relevant for all sectors of investment, especially for projects where workers will be involved in agriculture sector work, mining sector work, and Labor and Working construction work which are sectors with a ESS2  Conditions  high prevalence of child labor and hazardous child labor. Annex 2 proposes key points for reflection in LMPs to make sure child labor risks are identified and mitigated.  Potentially relevant for all sectors of investment, especially projects that create job opportunities. Projects intervening in already known destination areas for forced Community Health ESS4  child labor and child trafficking are at higher and Safety  risk. This includes for example Lake Volta and central regions, mining regions, border towns, and urban and commercial centers across Ghana.   13 Potentially relevant for all sectors of investment, especially for projects where workers will be involved in agriculture sector work, mining sector work, and Stakeholder construction work which are sectors with Engagement and ESS10  high prevalence of child labor and Information hazardous child labor, and projects Disclosure  intervening in already known to be destination areas for forced child labor and child trafficking are at higher risk (see above).   Approach to addressing child labor in the Ghana portfolio 7 1. In Ghana, as in many other African countries, the involvement of children in economic activities is a strong cultural feature and very prevalent, and also necessary for many families. Children's involvement in economic activities increases with age in Ghana. It is the most common for the age group 15-17 (51.1%), which is also the age when children have completed compulsory education. Also, for the group 12-14, involvement in economic activities is very common, 46.9% of children in this age group work, while for the age group 5- 4 11, 21.8% of all children work. Not all of these activities are child labor as defined internationally and nationally. When these economic activities respect working conditions specific to children of different ages and are not hazardous, they can make a positive and important contribution to child development, life skills training, and the transition to adulthood and the world of work. However, children should never be involved in activities that are harmful, dangerous, or exploitative and interfere with their education. Therefore, there are age-specific thresholds for the amount of time a child may work (regulated by law). If children's involvement in economic activities interferes with their education or results in them dropping out of school, this falls under the international definition of child labor. Work by children should also be avoided when it involves hazardous tasks. In this case, it is considered hazardous child labor, which is one of the worst forms of child labor (WFCL), along with forced labor and labor resulting from human trafficking. 8 1. When addressing the child labor risk in projects, it is therefore important to take an inclusive approach and allow children to work, as long as they have reached the minimum age and as long as labor standards and working conditions (non-hazardous work) are respected for each respective age group over the minimum age. World Bank projects in Ghana should prevent and mitigate the risks of children's involvement in child labor and WFCL 4. MICS 2017/18 economic activity of children (not qualified as child labor) 14 1. (including hazardous child labor, forced labor, and trafficking) through the application of the laws, labor standards, and widely consulted national guidance documents that help set maximum working hours for different ages and prohibitions on hazardous work in different sectors. These frameworks have been established to comply with international child rights and labor standards with the aim of respecting children's developmental, educational, and protection rights. 9 1. Taking an inclusive approach that promotes the application of national laws and standards, can go a long way in preventing child labor since many of the children who are involved in child labor have reached the minimum age of employment and have completed the years of compulsory education, but they work under conditions that are harmful to their development. Thus, World Bank projects should promote the participation of children in work that takes into account their age, abilities, and developmental and educational needs. Access to decent work for children who have reached the minimum working age and for young people is also widely seen as a key strategy to combat child labor. If decent work standards for children of minimum age are enforced on a large scale, it will also be less easy to hide forced labor and child trafficking. The challenge for projects in Ghana will be to prevent, mitigate, and ensure capacity to properly identify and remedy cases of child labor, and WFCL (including hazardous child labor, forced labor, and child trafficking). Photo © Dominic Chavez/World Bank 15 Introduction to the toolkit 10 1. The toolkit was developed in 2021/22. It was developed in parallel with and in sync with the OPCS Child Labor Operations Note on Child Labor in the Agriculture Sector. The toolkit was developed with the overall purpose of helping project teams to effectively manage child labor risk in the project cycle, by taking a coherent and comprehensive approach to the project cycle and building in appropriate prevention, mitigation, and remediation measures in project design and safeguards instruments and processes. Each of the components of the toolkit provides a starter for managing child labor risk comprehensively in projects. Several of the components have the potential to be further expanded with additional tools and guidance in the future. As such, the current toolkit provides a framework within which additional tools and guidance can be organized and also represents the beginning of a learning agenda for the World Bank in West Africa that can be progressively built over time. Portrait of children. Ghana. Photo: © Curt Carnemark / World Bank 16 Objectives of the toolkit 11 1. The objectives of this toolkit are four-fold: Help operationalize ESF in the project cycle, especially with regard to child labor risks and in the context of Ghana’s specific situation and legal frameworks; Help with categorization of projects according to risks related to child labor; Provide a menu of options for managing risks related to child labor; Provide tools and guidance for the contents of various risk-management options. Components of the toolkit 12 1. The toolkit has several components that each provide pointers to steps and good practices that can help manage child labor risk within the project cycle. Figure 1 illustrates the components which are: Figure 1 - Components of the toolkit Guidance on how to screen projects for risks related to child labor: a child labor risk screening tool is available as a separate document; Guidance on the options to manage child labor risk, where a hierarchy of risk management pathways is introduced and linked to the risk level identified with the help of the screening process; Guidance on the options for managing risk to be taken into account when selecting child labor prevention and mitigation strategies; Some good practice guidance for implementation of risk management techniques; Some pointers for monitoring and supervision and evaluation of results in relation to child labor risk management. 17 Scope of the toolkit 13 1. The toolkit can be used by project teams for any type of World Bank project, regardless of the financing instrument, be that Investment Project Financing (IFP); Development Policy Financing (DPF); and Program-for-Results (P-for- R). The implication of the tool for the different types of financing instruments is particularly important in step 02 when risk mitigation options are considered. Elaboration of the implications for various financing instruments is therefore provided in that section of the toolkit. Target Audience 14 1. The target audience of the toolkit is the Ghana Country Management Unit, Task-Team Leads working on different projects in Ghana that are under preparation or under supervision, and Social Development Specialists. Step 1: Screen projects for child labor risks 15 1. The risks related to child labor that should be considered in World Bank projects in Ghana include all forms of child labor, including (but not only) the worst forms of child labor such as hazardous child labor, forced child labor, and labor resulting from human trafficking. The ESF does not address children’s involvement in household chores that do not conflict with the child’s education and are not harmful-, which is beyond the scope of World Bank projects. However, World Bank projects in Ghana can allow economic activities of children 14 years and older that involve light work. World Bank projects can allow employment of children from 15 years and older, as this is the legally established minimum age for employment in Ghana, provided that children have completed compulsory education. Employment of children 15 years and older must comply with labor standards and must not be hazardous or coerced. 16 1. Country-specific risk of child labor and hazardous child labor: the risk of child labor in Ghana is high. Although estimates vary across sources (due to indicator definitions and measurement tools), child labor is very widespread. According to the Multi Indicators Cluster Survey (MICS), the percentage of 5 children aged 5-17 involved in child labor in 2017/18 was estimated to be at a level of 27.9 per cent (2.5 million) with 20.7 per cent (1.2 million) of these 6 children being engaged in hazardous forms of child labor. According to the Ghana Living Standards Measurement Survey (LSMS) 2016/17, up to 14 percent of all children are engaged in hazardous work, while 21.8 percent are engaged in child labor, severely limiting their development potential (LSMS, 2017). The phenomenon of hazardous child labor is widespread and found in 7 virtually all sectors of the informal economy. The rate of child labor and 18 1. hazardous child labor participation is slightly higher among boys. Child labor and hazardous child labor are almost twice as high in rural areas as in urban areas and highest in the poorest quintile. 17 1. Country-specific risk of child trafficking and forced child labor: the risk of child trafficking is also high. Ghana is part of the ECOWAS region where the right to free movement within the ECOWAS area applies. This means that many economically vulnerable people, including children, travel and work in Ghana. There are few measures in place to protect children from the risks associated with their migration, including the risk of being exploited in employment. As a result, Ghana is both a source, transit, and destination Annex 1 8 country for trafficking, including children. This provides a list of phenomenon is closely related to child labor: Where key questions to there is child labor, there is likely child trafficking. Child assess projects trafficking feeds the demand for cheap and child labor and unregulated labor, some of which is performed by child trafficking children. Because the economic activity of children is risks. so widespread, child trafficking and forced child labor can easily go unnoticed, even if they take place in the open. World Bank projects need to factor in risks for all these different categories of child rights abuses which often occur in parallel. Portrait of young boy. Ghana. Photo: © Curt Carnemark / World Bank 5 MICS 2017/18. The methodology of the MICS Indicator on Child Labor uses three age-specific thresholds for the number of hours children can perform economic activity without being classified as child laborers. A child that performed economic activities during the last week for more than the age-specific number of hours is classified as in child labor: i. age 5-11: 1 hour or more ii. age 12-14: 14 hours or more iii. age 15-17: 43 hours or more Table PR.3.2 presents children’s involvement in household chores. As for economic activity above, the methodology also uses age-specific thresholds for the number of hours children can perform household chores without being classified as child laborers. A child that performed household chores during the last week for more than the age-specific number of hours is classified as in child labor: i. age 5-11 and age 12-14: 28 hours or more ii. age 15-17: 43 hours or more. 6 Ghana Statistical Service. 2020. MICS 2017/2018 7 Child Labour Unit (2016). Hazardous Child Labour Activity Framework for Ghana). Labour Department, Ministry of Employment and Welfare. 8 US Department of State, 2021. 2021 Trafficking in Persons Report: Ghana. Online. Available at: https://www.state.gov/reports/2021-trafficking-in-persons-report/ghana/ (Accessed 8 December 2021). 19 18 1. Sector and geographic risks: The risk of child labor and child trafficking is high in all sectors and highest in agriculture. Child labor is by far the highest in the northern region, followed by the upper western region, and third is the upper eastern region. Most child labor and trafficking-related child labor occurs in agriculture, particularly in the cocoa sector and in aquaculture and fisheries, followed by services (which may have a particular risk of labor influx covered in the ESS4) and industry, particularly mining, but also manufacturing and construction. The cocoa growing regions and the Central and Lake Volta region were specifically singled out for the risk of forced child labor and child trafficking. Table 1 (below) describes the sectoral prevalence of WFCL, specific activities performed by children that should be avoided in World Bank projects, and observed associations with the geographic dynamics of forced child labor and child trafficking. Table 3 – Sector risk for WFCL9 Sector Prevalence Activities performed by Prevalence of Geographic children that involve them child dynamics in hazardous and WFCL trafficking and observed forced labor Producing cocoa, including Yes Children from Agriculture 79.2% land clearing, using northern machetes and cutlasses for regions of weeding, collecting cocoa Ghana (sent pods with a harvesting hook, by parents breaking cocoa pods, who use exposure to pesticides, and intermediaries carrying heavy loads of or relatives) to water (1-3,6-12) work in agriculture in Production of palm oil and Yes the south cotton, including weeding during school and harvesting breaks or the dry season identified as at Herding livestock, including Yes increased risk cattle, hunting, and work in for forced slaughterhouses  labor.  9 The table combines data from the following sources: US Department of Labor, 2021. Child Labor and Forced Labor Reports: Ghana 2020. Online. Available at: https://www.dol.gov/agencies/ilab/resources/reports/child-labor/ghana (Accessed 8 December 2021) 20 Fishing, preparing bait, nets, Lake Volta and and fishing gear, launching, Yes central regions paddling, and draining canoes, (high diving for fish, casting and prevalence of pulling fishing nets and forced labor untangling them underwater, and child sorting and picking, cleaning, trafficking). smoking, transporting and selling fish, cleaning and Many children repairing nets; and building identified in and repairing boats. forced labor in the sector come from other West African countries. Industry 5% Quarrying and small-scale Yes in artisanal Traffickers mining, sometimes for gold, gold mining exploit including using mercury, Ghanaian digging in deep pits, crushing (especially rocks by hand, carrying heavy from northern loads and operating regions) and machinery. Nigerian Manufacturing N/A women and girls in sex Construction and bricklaying N/A trafficking. or carrying bricks Services 15.8% Domestic work Yes Lake Volta and central regions Transporting heavy loads Yes (high as kayayei prevalence of forced labor Work in transportation N/A and child Street work, including begging, Yes trafficking). small-scale vending, and working at restaurants and Many children bars identified in forced labor come from West African countries. 21 Child labor risk screening 19 1. For some projects, it may be useful to screen the risk related to child labor. This risk screening will take place in the broader process of undertaking social and environmental risk assessment. While child labor risk screening is not always necessary, it can be useful in some contexts, for example for projects that fulfill one of the following criteria: If the broader social and environmental risk assessment done at the concept stage brings up any issues and risks related to child labor and/or trafficking, or broader labor-related risks (forced labor) If a project intervenes in agriculture, mining/industry, and/or involves construction work in countries with high CL-prevalence, such as in the case of Ghana. 201. If child labor risk screening is undertaken, it can be used as a supplement for the broader social risk assessment process. The use of a child labor risk screening tool ensures that the risk screening is not ad hoc but provides a coherent overview of how significant the risk is. The level of risk determined and the ultimate score on a child labor risk screening tool is not to be used as a standalone score in the social risk assessment, but as one of several sources of information to inform that score and risk level determination process. 21 1. A child labor risk screening tool is available as a separate document to help screen projects during the identification stage. The results from this result from the initial child labor risk assessment can thereafter be included in Concept ESRS and record risk rating in ESMS. The purpose of the child labor risk assessment tool is to: Ensure systematic information gathering and a minimum level of risk assessment is used early in the project cycle to inform decision making on whether a more robust social risk analysis is needed on child labor; Guide teams on the significance of factors for child labor risk and direct teams to sources of information; Allow an initial screening and classification of projects that apply the “proportionality” principle that is described in the ESF, and through that initial screening and classification of projects risk in the child labor area, apply response & mitigation strategies depending on risk-level; Support the design of mitigation strategies and ensure child labor risk is taken into account from the beginning of the project cycle & integral in the project design; Provide an entry-point rather than the end of a process and is meant to help teams enter into a dialogue with the client as a starting point for broader stakeholder consultation and more robust studies, if applicable. 22 Table 4 - What is considered in a child labor risk screening tool Sensitivity of receiving Borrower capacity and Project characteristics environment commitment Prevalence in target area: Ratification status of Sector prevalence of child child labor, poverty  major conventions related labor, child trafficking, to child labor forced child labor Access to social services: Compliance of legislation Sector specific workforce birth registration, health, with international profile: sufficiency of adult education  standards labor force, family labor Access to nutrition, water Availability of strategy, Project negative influence and sanitation services action plans on child labor on access & availability of and coordination body social services (e.g. schools) Trafficking routes or Borrower and country reliance on migrant prior experience in workforce addressing child labor Recent adverse events Project impact on increasing the Availability and capacity livelihoods socioeconomic of child protection system vulnerability of the and workforce  population: e.g., drought, floods, pandemic  Step 2: Consider mitigation options Risk mitigation pathways 22 Each risk level has a specific mitigation pathway linked to the risk hierarchy defined in the ESF, namely depending on whether the child labor risk is assessed as low, moderate, substantial, or high. The screening tool makes an automatic calculation of a score depending on the answers to the different questions of the tool. Low-risk projects do not need any further analysis, while projects with child labor risk assessed as moderate, substantial, and high should undertake additional information gathering and analysis of the risk. This can be done in the form of a specialized social assessment focusing on child labor. Figure 2 provides an illustration of the hierarchy of risk mitigation pathways depending on risk. The different options are discussed further in subsequent sections of the guidance note. 23 Figure 2 - Hierarchy of risk mitigation pathways depending on risk 24 Step 3: Select child labor mitigation options 23 While this generic risk mitigation pathway model is valid for all types of projects, regardless of financing mechanism (IPF, DPF, and P-for-R), some specific considerations might be useful to keep in mind as the strategies to address risk are chosen. For example: Projects chosen for P-for-R are in theory likely to score lower (low or medium) risk if a child labor risk assessment tool is used. This is because, in theory, P-for-R would not be a preferred financing mechanism for projects with high social risk levels and poor capacity to address the risk, since this would mean that too much attention of the project might go to manage this risk rather than the core of the project. Therefore, if the application of the child labor risk screening tool for a project selected for a P-for-R financing mechanism would result in a score that qualifies a project at the level of “significant” or “high” risk, this could then be reason for reconsidering whether P-for-R is a suitable financing mechanism for the project. After the project child labor risk screening has been undertaken, and if a project is scored at a level of “moderate”, “significant” or “high” risk, the subsequent additional information gathering and analysis might have a different focus, depending on the financial instrument considered. For DPF and P-for-R projects, there might be specific interest in doing a deeper analysis of the country systems to prevent, identify, mitigate, and remediate child labor. This will be of interest for IFP-projects too, but for different purposes. The contents of risk-mitigation strategies at the level of a sector, workplace, and national systems may depend on the type of financing instrument being used for the project. For example: IPF uses ESF, and risk mitigation strategies may therefore include Stakeholder Engagement Plans (SEP) and Labor Management Procedures (LMP), etc. which would not be the case for DPF or P-for-R. Option 1: Child labor sensitive sector reforms 24 1. Manual and labor-intensive work, especially when adult labor is scarce, can increase the risk of child labor. The lack of protective clothing and equipment can also increase the risk of hazards to any worker, including children (e.g., children 15 years of age and older who have the permissible age for employment can be exposed to hazardous child labor). Investment projects that initiate sector modernization and sector reforms to increase productivity and effectiveness can proactively address these hazards and do 25 much to reduce the incidence of child labor and hazardous child labor. In Ghana, some sector-specific hazards have been identified in labor legislation and guidelines on hazardous activities for children. World Bank projects, particularly in agriculture and industry, can proactively ensure that modernization reforms reduce these hazards, replace manual labor, provide protective equipment, more resistant varieties of crops, and eco-friendly pest management methods, etc.). Table 5 - Sector specific hazards which, if reduced, can reduce incidence of 10 child labor and hazardous child labor Sector Pointers of sector-relevant factors that increase the of children to be exposed to hazardous work conditions in Ghanian context Any sector Manual lifting of loads the weight of which exceeds twenty-five kilograms, work at a height exceeding two and a half meters, use of substances and materials that emit radiation, or poisonous gases or fumes, use of dangerous chemicals, excessive noise, the felling of timber; night work exceeding eight continuous hours, exposure to production and screening of pornographic materials, work at areas (of a hotel) which are likely to corrupt the moral development of that young person. Agriculture General: Exposure to weeds, reptiles, rodents, sharp cutlasses, axes and chisels, manual handling, noise from chain saw, stumps, falling trees, agrochemicals.  Grinding & milling: noise, electricity, exhaust fumes, cereal dust  Cattle herding: extreme weather conditions, exposure to dangerous animals, i.e., snake, bee, wasp and scorpions, attack by aggressive cows during milking, attacks by cattle thieves, punishment for farm destruction by cows, long working hours, long travel distances. Fish Mongering: Manual handling, sharp knives, fish fins, salt concentrates, smoke, carbon monoxide.  Industry Sand-winning: Reptiles, weeds, falling trees, cutlasses, pickaxes, shovels, poor working posture, sand dust, silica, manual handling. Small scale mining: Reptiles, weeds, sharp rocks, cutlasses, hammer, chisel, pickaxes, shovel, poor working posture, unhealthy confined underground environment, rock dust, silica, radioactive minerals (radon), manual handling, chemicals (mercury, CO2, hydrochloric acid), falling rocks/sand. 26 Quarrying: Reptiles, weeds, sharp rocks, hammer, chisel, pickaxes, shovel, poor working posture, underground rock dust, radioactive minerals (e.g., radon), manual handling. Small scale sawmills: Manual handling, electricity, sharp tools, slips and falls, exposure to wood dust. Textile industry, e.g., batik/tie and dye: Fire outbreak from overheated wax, exposure to molten wax and wax smoke, inhalation of dye dust and contact with dye (aniline).  Welding: Inhalation of metal fumes and smoke, fire, electricity, sharp objects, intense light, exposure of gas cylinders, manual handling, hammer, chisel, fire, electricity. Aluminum pot manufacturing (dadesan): Manual handling, fire and heat, sand and aluminum dust  Spraying: Manual handling, hand-powered machine, filler and metal dust, isocyanates Portrait of children. Ghana. Photo: © Curt Carnemark / World Bank 10 The list is extracted from Ghana Child Labour Hazardous Activity Framework (2016) and the Labour Regulations, 2007 (LI1833) 27 Option 2: Labor management 251. For IPFs, child labor risks can be managed through the application of the ESS2 and the development of LMPs that define working conditions for children between the ages of 14 and 18 who may be involved in World Bank projects. Ghana has a robust legal framework to address child labor, allowing World Bank projects to apply Ghanaian legislation to manage child labor risks. Box 1: Legislation in Ghana regulating child labor (to be referenced in LMPs) Relevant legislation, regulations, and guidance regulating child labor in Ghana, to be referenced in LMPs of projects that are obliged to have such procedures established, include: Constitution of Ghana (1992) Labour Act No 651 (2003) Labour Regulations Legislative Instrument (Article 7) Human Trafficking Act (2005) National Vocational Training Act No 351 (1970) National Vocational Training Regulations (Executive Instrument 15) Shipping Act No 645 (2003) 261. The minimum age for employment: The minimum age for employment in World Bank projects in Ghana should be 15 years as per the table below. Photo © Dominic Chavez/World Bank 28 Table 6 - Conditions for employing 15+ children on World Bank projects in Ghana 11 Minimum age as per World Bank Under what conditions national legislation project requirements (as per ESS2) Children 15-17 years Same as national Can undertake normal/non- legislation hazardous tasks and be employed (have a labor contract).  Under condition that a medical practitioner has certified that the young person is in good health and is medically fit for work Employers in an industrial undertaking shall keep a register of young persons employed by him or her and their dates of birth or their apparent ages. That age can be verified through different methods (birth registration or ID- card and in the absence of that through a method that triangulates at least two different sources, e.g., school records, interviews with a caretaker and or the child) That weekly rest periods and right to holidays are respected (same as for 18+) The work does not exceed 8 hours of work per day and 43 hours per week. The work should not take place night-time. The Child Act defines “night-time work” (thus prohibited for below 18) as before 6:00 a.m. and after 8:00 p.m. 11 The list of conditions has been developed based on Labour Regulations (2007), Children’s Act (1998), and Child Labour Hazardous Activity Framework (2016) 29 271. The minimum age to perform light work (but not to be employed): children under 15 years of age and over 14 years of age may perform economic activities under World Bank projects if such activities are considered light work and are not harmful. Light work in Ghana is clearly defined for each sector in the Hazardous Child Labour Activity Framework. The minimum age for children performing light work in World Bank projects in Ghana should be set at 14 years (according to ESS2), although Ghanaian legislation allows this type of work from the age of 13. Photo © Terry White, Flickr Table 7 - Conditions for allowing 14+ children to undertake light work on World Bank projects Minimum age as World Bank Under what conditions per national project legislation requirements (as per ESS2) Children 13-14 years From 14 years Can undertake light work limited to helping in economic activities such as for example in the family business, and under certain conditions, e.g., to earn a little pocket money outside of school hours or during school holidays, but cannot be employed (under a labor contract) 30 Should be undertaken under the supervision of an adult, for the purposes of education and social integration of the child. Should not jeopardize the health or physical, mental, moral or social development of the child. Should not compromise the school attendance and participation of the child. This includes should not compromise the child’s possibility to do homework, prepare for tests and benefit fully from education. The work should not take place at night (before 6 a.m. or after 8 p.m.) or during regular school-hours. Although national legislation does not prescribe specific maximum hours of that children can perform economic activities that are light work, the daily working time of actual work should not exceed 2 hours for a school day and 4 hours for a non- school day. The effective weekly working time should not exceed 12 hours for a school week and 14 hours for a non-school week. None of the tasks undertaken should be hazardous tasks. 31 28 1. Prohibited work of children on World Bank Annex 2 projects in Ghana: The use of children under 14 provides a list of key years of age to satisfy labor requirements on points that relate to World Bank projects is prohibited. The child labor that ideally involvement of children below 18 in hazardous can be covered in labor tasks is also prohibited. Box 2 provides a list of management hazardous work prohibited to young persons in procedures (LMPs). Ghana. 12 Option 3: Child labor action plan 291. Most projects are not primarily designed to reduce child labor. However, sometimes sectoral reforms that give due consideration to reducing sector- specific factors that increase the risk of child labor and hazardous child labor are not sufficient to mitigate the risks of child labor and child trafficking. This is particularly the case in areas where families and children are highly vulnerable and face multiple deprivations (e.g., lack of access to birth registration, health and nutrition, lack of access to education and social protection, high poverty rates, etc.). Moderate and high-risk projects may therefore need to strengthen capacity for prevention, identification, and intervention (including remediation) in child labor cases. Box 2: Prohibited hazardous work for young people in Ghana (to be referenced in LMPs) Manual lifting of loads the weight of which exceeds twenty-five kilograms Work on scaffolds and other structures at a height exceeding two and a half meters, The use of substances and materials that emit (i) radiation, or (ii) poisonous gases or fumes, The use of dangerous chemicals, Excessive noise, The felling of timber, Night work exceeding eight continuous hours, or Other situations considered by the Chief Labour Officer as hazardous. Production and screening of pornographic materials, or Work at areas in a hotel that are likely to corrupt the moral development of that young person. Source: Ghana Labour Regulations, 2007 (LI1833 12 The list comes from Labour Regulations, 2007 (LI1833) 32 301. A child labor action plan should be comprehensive, rights based, and address root causes. Comprehensive: it is recommended to map out what the government and other organizations are doing to address child labor in the area, identify the gaps in the already existing response framework, and plan to support the filling of those gaps. Root causes: when families and children are highly vulnerable, sector- specific policies alone may not have a lasting impact on child labor. For example, if changes are introduced in one sector of the economy that reduces labor intensity and demand for child labor, or if labor inspection becomes stricter in one sector, child labor may simply shift to another sector that is less strictly supervised. This is often referred to as "child labor displacement", which means that children move to other sectors where the demand for child labor remains high. Addressing the root causes means addressing the multiple deprivations of children and families that lead to socioeconomic vulnerability and poverty. These may include lack of birth registration, lack of access to health and nutrition, poor access and/or quality of education, lack of access to social protection, etc. Figure 3 below provides an illustration of how addressing root causes can help reduce child labor prevalence in a lasting way Copyright All rights reserved by Pejasar, Flickr 33 Figure 3 – Addressing root causes to child trafficking and child labor 34 Rights based: This means always respecting children's best interests. If children are involved in any form of child labor, each case needs to be considered through an assessment that provides the basis for how to proceed to ensure that the child is not made more vulnerable when removed from child labor. If the child may be made more vulnerable, remediation efforts must help overcome this risk. Children who are removed from child labor also need to have their psychological, care, and protection needs covered. Table 7 below provides ideas of what kind of capacity might be required to ensure sufficient capacity for prevention, identification, and intervention in cases of child labor and WFCL. Table 8 – Components of an action plan to build national capacity to prevent, identify and intervene (removal and remediation) in cases of child labor and WFCL Capacity required Types of activities / strategies to strengthen capacity Central oversight Data collection activities (survey, specialized studies, capacity for mapping of community interventions etc.) coordination and Development of planning tools (action plans, monitoring management information systems, databases) Development of monitoring systems (human resources, skills, data collection instruments and procedures, digital platforms etc.) Evaluations Community capacity Improving birth registration and people’s access to to provide services identity documents and supports which Reducing poverty, increasing access to decent work can address root opportunities, social protection, health insurance, causes of child labor access to credit etc. Improving access to health, nutrition, water and sanitation Improving access to quality education for all age- groups Awareness General community awareness campaigns Targeted awareness for employers / workers of the project Identification  Capacity building of labor inspector services (mandate for the formal sector) and/or  Capacity building of members of Social Services Subcommittees of the Rural Development's District Assemblies (mandate for the informal sector) 35 Removal of cases of General community awareness campaigns or child labor and WFCL targeted awareness for employers / workers of the project Direct remediation Care and protection services for children Access to legal support and justice Indirect remediation Education Income support Referrals to social protection, civil services (e.g., for birth registration) 31 Capacity strengthening for direct remediation (care and protection) in cases of forced child labor and child trafficking: Cases of forced child labor and child trafficking require additional capacity for direct remediation in accordance with what the Children's Bill of Ghana (available in draft form to replace the Children's Act 1998) refers to as "care and protection." Any project intervening in a sector where forced child labor and child trafficking have been identified should therefore ensure that there is sufficient capacity in the project's geographic intervention area to provide care and protection for such cases. This includes ensuring the capacity of the (by law defined) "designated authorized statutory agency" and the availability of temporary protection and care services for children who need them. This statutory agency is the Social Welfare and Development Department of the Ministry of Gender, Children, and Social Protection. This department will assign a Probation Officer or Social Welfare Officer accompanied by the police in such cases. Projects operating in geographic areas and sectors at high risk for forced child labor and trafficking have an interest in ensuring that there is sufficient capacity to deal with such cases should they be identified in connection with the World Bank Investment Project. Portrait of mother and child. Ghana. Photo: © Curt Carnemark / World Bank 36 Table 9 - Components of an action plan to build national capacity to strengthen indirect and direct remediation capacity Capacity required Types of activities / strategies to strengthen capacity Case management Investigation and assessment, family tracing and reunification, including to other regions of the country and/or countries of origin. Ensuring sufficient numbers of Probation Officers and Social Welfare Officers. Skills-building and training for this workforce. Operational budgets for outreach work. Crime investigation Ensuring sufficient human resource capacity within the Ghana Police Service’s Domestic Violence and Victim Support Unit and Anti-Human Trafficking Unit with a mandate to investigate cases and provide support to victims.  Skills-building and training for this workforce. Operational budgets for outreach work. Protective care Contracts with providers of alternative care (shelter and/or foster care families). Victim care and support Contracts with service providers for psychological support, medical care, legal aid. Option 4: Stakeholder engagement 321. Child labor is the mandate of multiple stakeholders. In Ghana, work to prevent, monitor, identify, and respond to child labor cases has been going on for a long time. There are several important stakeholders, such as ILO, UNICEF, USAID, US Department of Labor, European Union, bilateral donors, Civil Society Organizations, the private sector that are involved. Their work has contributed to strengthening capacity and developing community- based models in line with the priorities established in the National Plan of Action Phase II (NPA2) for the Elimination of the Worst Forms of Child Labour in Ghana (2017 – 2021). However, the implementation of this national plan has suffered from a lack of resources and a mismatch between the goals and targets of the plan and the prioritized sectoral interventions of various 37 ministries. The role and capacity of the central government in leading, providing oversight, and coordinating efforts to address child labor needs strengthening. The Child Labor Unit of the Ministry of Employment and Labour Relations has a mandate to coordinate government interventions related to child labor, however, the unit does not have sufficient leveraging capacity with other ministries and stakeholders. There is also a gap between the centrally defined goals and the capacity available at the local level, especially at the district level where several of the implementation mandates sit. 1. Addressing child labor, which is a complex issue, requires concerted action. 33 Yet, in Ghana as in many other countries, the work of development partners and other stakeholders has often been small, “siloed and disjointed”. The World Bank is in a unique position to scale up successful and small-scale pilot projects and strengthen the government's capacity to provide the enabling system environment for such initiatives to be effective, sustainable, and have greater impact. Stakeholder engagement processes should identify early in the process if any multi-stakeholder initiatives are available in the sector of the project that is paying attention to the issue of child labor, map out and identify contributions of others, and try to complement these efforts both to ensure balanced investments in a continuum from prevention to response & remediation and to help scale up successful initiatives. Option 5: Grievance and Redress Mechanisms adapted to respect a child’s protection rights 341. World Bank projects under the ESF are required to establish grievance mechanisms (both in the project and in the workplace). Identification and reporting of child labor cases can be done by the children themselves, but also by various stakeholders such as teachers, parents, village leaders, community health workers, labor inspectors, police, etc. Grievance mechanisms must be prepared to deal with different types of child labor cases, as described in Box 3 below. When a child labor case is reported, they should be able to make a preliminary assessment to determine if a referral is needed. If a child whose case has been reported to the grievance mechanism is found to be at high risk (e.g. a child who is severely socioeconomically vulnerable, experiences multiple deprivations, is under 15 years of age is out- of-school, suspected victim of forced labor, or child trafficking), the case must be referred to the formal child protection system, which in Ghana is represented in the first instance by a Probation Officer or a Social Welfare Officer, and in the case of suspected child trafficking, also by the Domestic Violence and Victim Support Unit and the Anti-Trafficking Unit of the Ghana Police Service. 38 Box 3: Child-cases to be reported to Grievance Redress Mechanism (GRM): The grievance mechanism should address cases of children younger than the minimum age for employment (under 15) and for light work (under 14). If a child is above the legal minimum age for employment (15+), the grievance mechanism would apply if working conditions are not respected, including the special working conditions defined for children between 15 and 18. In the event that a child, regardless of age, performs hazardous work, is suspected of being forced to work, or is to be a victim of child trafficking, the project or labor grievance mechanism would become relevant. Suspicion of forced child labor and/or child trafficking exists when the work is performed under the coercion of a third party, when the child is working as a direct result of the forced labor of his or her parents, when the child is from another country or region and is not with his or her primary caregivers and appears to be working under the pressure or coercion of a third party, when the employer appears to be taking advantage of the child's possible socioeconomic weakness, when the child's family has been exploited, and/or when an imbalance of power between the child and the employer has been abused. In the event that the child has been a victim of violence or abuse at the worksite of a World Bank project, the labor grievance mechanism applies (although a complaint could also be made to the project grievance mechanism). Step 4: Implement child labor mitigation options Distribution of responsibility burden for risk management amongst actors involved in implementation 351. While an LMP, action plan, and other project documents developed during project preparation provide the frameworks defining the responsibility for implementation of prevention and risk management strategies, this will need to be further detailed in procurement documents and feed into the due diligence processes of contractors and third parties that will hire personnel during implementation. In those processes: The World Bank is responsible for providing guidance, mapping national systems and specialized agencies that can help provide expertise, and aid in monitoring the due diligence processes of the Borrower. The Borrower, on the other hand, is responsible for conducting due diligence on contractors, and ensuring that contract management and enforcement include standards and indicators on child labor. 39 36 1. During implementation, due attention should be given to ensure that procurement documents address prohibition of child labor and standards related to prevention, protection and remediation (e.g., procurement documents). Due diligence by the Bank of contractors and third parties is another significant issue to pay attention to for labor management to prevent and mitigate child labor. Figure 4 provides an overview for how the responsibility burden is cascaded down through various processes to different actors involved during implementation. Figure 4 - Responsibility for implementation of risk management techniques Good practices to protect children through labor management procedures 37 1. The following good practices (table 10) can be recorded as good practices for workplaces where children over the age of 15 may be employed on World Bank projects. 40 Table 10 - Good practices to mitigate child labor to be captured in LMPs Mitigation measure What it should include / entail Age verification Through birth certificate or ID card and if this is not available through a triangulation of at least two different sources which can include: an assessment based on the statement of the child and his/her parents' legal guardian  health record or statement of a physician education record The principle of “positive presumption of age” in the interest of the protection of the child should be applied if there is any doubt. This means that if there is any doubt in the age assessment and judging from the statement of the child, parents, and/or guardian that the child has reached the minimum age, then it should be presumed that the child is below the minimum age unless it is proven otherwise through other means.  Workplace child This plan should define how the organization where labor awareness children may engage in economic activities or be and training plan employed will create awareness within its’ own structure on the minimum working ages (for socializing work and for employment) as well as the authorized working conditions for children from 14+ (socializing work) and 15+ (prevention of the worst forms of work). Child safeguarding A child protection policy should specify how an and protection organization that is involved in a World Bank project policy on worksites where children may be engaged or employed, plans to prevent and respond to all kinds of violence, exploitation, and abuse of children engaged in the implementation of tasks on worksites of the project. This is important because children’s wellbeing and rights do not just relate to protection from child labor but also, children have a right to be protected from violence and abuse, including sexual abuse. 41 Monitoring and A monitoring and supervision plan of each organization supervision plan involved in a World Bank project will monitor that children 14+ only undertake light activities and that working conditions for 14+ and 15+ respect national labor standards and are not hazardous. To facilitate monitoring, the monitoring and supervision plan should describe the tasks which (in the workplace) could harm the health of a child and which, therefore, must be excluded for each child even if the child is engaged for educational purposes (e.g., through an apprenticeship programme) and for his or her social integration. Records For the implementation of the monitoring and supervision plan, the organization should set up lists / records with identifying information, such as name and age of the child and that specifies for workers under 18 years old the tasks to be accomplished. Responsible for A person responsible for implementing the monitoring supervising working and supervision plan should be appointed within the conditions organization of the employer. He / she should make spot checks, with direct consultations with young workers. He / she should establish a control report that specifies the working conditions as well as remediation activities that are put in place in the event that these conditions have not been respected. Lessons learned from spot-checks should be shared within other employers engaged for the implementation of the project, and with authorities and the Bank. Sharing information and lessons learned will enable these authorities to provide assistance, such as awareness raising in areas surrounding the project if child labor is a problem. Policy and plan for Since child labor often occurs in an unplanned way, for health and safety example, to replace an adult who has fallen ill, each at work employer engaged in the project can prevent child labor by establishing a policy regarding the health and safety of workers, adults and children alike, in order to reduce health problems for all workers.  If a worker is injured on the worksite, the organization should provide financial assistance to the worker, in the interest of preventing replacement child labor. 42 Code of conduct to Given that labor standards for children can be difficult facilitate the due to find/are often missed, these can also be captured diligence of and referenced in a  code of conduct  to be signed by contractors those managing the workforce and all employees working on the project.  This can help the PIU and also the WB in doing their due diligence on contractors and holds everyone accountable for the protection of children. Children are often involved in work in the informal Written parental sector where there is a lack of tools to regulate their consent for the work. Giving parents the opportunity to provide their involvement of informed and written consent (signing a form for children above parental consent), when children are to be engaged as minimum age and part of the workforce can help the Banks’ Task Team below 18  and PIUs with their due diligence. An additional advantage of standardizing a procedure for parental consent, is the "formalization" of engaging children, even if this is done in a very informal sector. It can also have an empowering effect on vulnerable segments of the population. Child protection A child protection procedure should be defined before procedure the project begins, which clarifies the responsibility of project stakeholders, versus the stakeholders of the national child protection system, when it comes to remediating and protecting children who have become victims of child labor. Copyright All rights reserved by Trevor Ambrico, Flickr 43 Good practices for upholding children’s rights in prevention, identification, response and remediation efforts 381. It is recognized that a comprehensive strategy to address child labor and child trafficking intervenes at the level of prevention to reduce the chances for children to be recruited into an exploitative labor or trafficking situation. Prevention ideally addresses both the pull factors (e.g., awareness about the risks of sending children away for work) and the push factors (e.g., lack of opportunities for decent work, lack of access to education). A comprehensive strategy also includes measures to ensure identification of a child who is in an exploitative situation, and response/remediation through support to receive appropriate care, protection, reintegration, and rehabilitation. Programmes and projects that intervene in any of the steps of this continuum ideally need to be operational both in areas/countries of origin, from where a child may migrate for work or may be recruited into trafficking, in locations or situations of transit, in the destination, where the child ends up being exploited. Programmes also need to look at return elements and processes, e.g., when a child who has been identified as a victim of trafficking needs to be safely reunified with his/her family and returned to the area of origin. 39 1. For each child victim of trafficking or forced labor, the journey into exploitation is unique. One child may come from and live in the same place where he or she is being exploited. Another child may have originated from elsewhere in the same country, or from another country. Comprehensive programmes take into account the need to address each child’s unique situation in the care arrangement, protection, reintegration, and rehabilitation. Figure 2 captures the essence of what international legislation and standards identify as the “rights of children” and the best practice standards that should be upheld for children who are in any of the phases where they might need prevention interventions, identification, or response and remediation interventions. Portrait of children. Ghana. Photo: © Curt Carnemark / World Bank 44 Figure 5 - Upholding children's rights in efforts to prevent, identify, respond to and remediate child labor 45 Good practices in child protection procedures for high-risk cases and child victims 401. If a case of suspected forced child labor or child trafficking is identified on a World Bank project or a child is identified in child labor and a preliminary assessment by the employer or grievance mechanisms for the case to be high-risk, Ghanaian law states that the case should be referred to statutory agencies. This means that stakeholders, such as an employer, a grievance mechanism, or a PIU are not authorized to deal with these cases without the involvement of an authorized statutory agency for protecting the best interests of the child. 41 1. In Ghana, the government agency with the legal mandate to handle high-risk child protection cases is the Social Welfare and Development Department of the Ministry of Gender, Children, and Social Protection. This department will assign a Probation Officer or Social Welfare Officer to the case and if it is a criminal case this officer will be accompanied by the police in such cases. They will conduct the necessary social and risk assessments to support a decision in the best interests of the child, as well as criminal investigations. In Ghana, there are Standard Operating Procedures (SOPs) for Child Protection and Family Welfare cases that define the pathways and obligations of different stakeholders with regard to referrals. These SOPs also apply to the World Bank. Box 3 provides an idea of the implications and referral pathways from a World Bank project in Ghana to the national child protection system. Copyright All rights reserved by Terry White, Flickr 46 Step 5: Supervision, monitoring and evaluation Box 3- Referral pathway from a World Bank projects to the national child protection system High-risk cases can be identified in connection with a project by several different stakeholders, as illustrated below. They may be identified by the PIU on a supervision mission, by the employer or a contractor, through a grievance mechanism, by a labor inspector, or by a social services subcommittee that has a mandate in child labor monitoring in the informal sector. If a high-risk case is identified, in accordance with the Inter-Sectoral Standard Operating Procedures (SOP) for Child Protection and Family Welfare, there are timelines that need to be respected for further referral. Higher risk levels, that are defined in the SOP, require immediate reporting and a response within 24 hours. Medium risk cases, which are also defined in the SOP, should be reported within 48 hours and responded to within a week. Lower-risk cases are to be reported within a week and the response begins within a month. 421. Supervision, monitoring, and evaluation will need to capture all the distribution of responsibility as illustrated in Figure 3. Tools to help supervise and monitor the proper implementation of that responsibility remain to be developed in subsequent steps of expanding on this toolkit. As a starting point though, clarity on the definitions of child labor will need to be ensured amongst all actors involved in a project and when a common understanding has been developed, this will pave the way also for monitoring and supervision. 431. Identifying child labor can be difficult, especially in countries where child involvement in economic activities is common, as in Ghana. It is important to note that adequate opportunities for children who have reached the minimum age for light economic activities (14 years of age and older) and employment (15 years of age and older) are important for both child development and family living standards, as well as for combating child labor. Therefore, when identifying child labor, definitions should be carefully considered and, ideally, frameworks for identifying and measuring child labor should be followed and implemented by professionals who are trained to do so. For professionals not responsible for measuring child labor, Figure 3 below provides some basic rules of thumb that can be used by community stakeholders or social specialists of the World Bank on inspection visits. When third parties are contracted to conduct monitoring or an independent professional assessment is undertaken, the World Bank should require more specific tools to be used and trained professionals for child labor identification and measurement to accurately identify child labor. 47 Figure 6 - Identifying child labor during supervision, through stakeholder engagement. 13 13 The illustration in the figure has been adapted from tools developed by the organization Action against Child Exploitation (ACE), to guide child labor identification on the ongoing Child Labor Free Zones pilot-project in Ghana. It is a simplified scheme. 48 Annex 1: Questions that can help to assess child labor risk for a project under preparation Questions Rationale for question/methodological considerations  Sensitivity of the receiving environment What is the child labor This refers to child labor prevalence in a geographic prevalence in the geographic area, without considering that there is often higher or areas of project lower prevalence in different economic sectors. The implementation? reason for considering the overall prevalence (regardless of the sector of intervention of the project (which is covered below under project specific indicators) is because of a phenomenon often referred to as "child labor displacement". Child labor displacement refers to situations when children shift sectors of work as a result of changes in the external environment. For example, a sector may have lower child labor prevalence rates, that suddenly go up due to more stringent enforcement of labor standards in another sector. High child labor prevalence in a geographic area, increases the risk for child labor in any sector. This risk is then further increased if a project is intervening in a sector with higher child labor prevalence (assessed additionally under project indicators). Sub-Saharan Africa has the highest percentage among any region of children in labor, at 21% What is the poverty Poverty and low standard of living is a root cause to prevalence of people living in child labor. Impoverished parents/caregivers, with low the geographic areas of levels of education themselves, often chose to send project implementation? their children to work as a coping mechanism  to supplement household income by involving children in economic activities.  What is the level of access Lack of birth registration and lack of access to identity to birth registration in the papers is a root cause of child labor as it influences geographic areas of project access to education, social protection, and other implementation? services. MICS and DHS are often implemented in a complementary manner (either one or the other) and include  similar indicators so either data source can be used, depending on the availability of data and which survey is more recent 49 (if both are implemented in a specific country). Click on the links to find out data availability for a specific country. Once the more recent survey has been identified, search for national data or region-specific data on the indicator: "Children under whose birth has been registered with civil authorities", under the section for "Birth registration".  What is the level of access Lack of access or poor quality of education is an to education in the important factor contributing to child labor. There are geographic areas of project many different data sources and indicators that can implementation? be used. It is suggested to use survey data that capture out of school children. There is also an SDG Indicator 4.1.4: on the "Proportion of children and young people in the official age range for the given level of education who are not enrolled in pre-primary, primary, secondary or higher levels of education" that is available for many countries. UNESCO Institute for Statistics includes country level data on the indicator on "Children out of school (% of primary school age)".  If data is not available there, MICS or DHS can provide data on out of school children in the section on "Primary school attendance and children out of school", indicator capturing the total percentage of children "Out of school". Data for the indicator may be available for national level or also sub-national levels depending on the data source used. In 2017, it was estimated by the UNESCO Institute for Statistics that 9% of primary school age (typically 6–11 years) children were out of school. This is used as the benchmark for the response options to this question. What is the prevalence of In many countries, sending children away to live children not living with the outside the nuclear family is a cultural practice that is nuclear family in the areas of rooted in strong trust in the extended families and project implementation? tribal and religious attachment, and a belief that sending children into the care of another family will help secure a better education and working opportunities for them. However, this practice has also been found to create a fertile ground for exploitation in child labor and forced labor. For example, the US State Department TIP report has often commented on child trafficking cases where traditional/informal “foster care” arrangement seems to have made 50 children vulnerable to forced labor and child trafficking. In those cases, parents / immediate caregivers have sent their children via intermediaries to work / live in with relatives, where children end up exploited in harsh conditions and forced labor. MICS and DHS surveys include a section on children's living arrangements. Once the most recent survey has been identified, search for national data or region specific data on the indicator: "MICS survey findings on children’s living arrangements” and "children who live with neither of their biological parents”. Will the project intervene in Child labor exploitation and child trafficking are closely an area that is known for linked, with all trafficking victims typically ending up in high levels of migrant work labor exploitation. This question can be responded to force and/or in known through a rapid review of qualitative assessments, trafficking route? such as the US State Department's TIP report which provides information on a country-by-country basis, and on identified trafficking victims in specific geographic areas within a country. If a project will be implemented in any of those geographic areas, the risk rating will be higher. UNICEF and IOM also regularly undertake studies of the prevalence of trafficking. Their websites can be consulted for such resources, to complement data provided in the TIP report. Borrower capacity and commitment Has the Borrower ratified the The two fundamental conventions are: ILO Convention main international No.138 on Minimum Age and ILO Convention No. 182 on conventions related to child the Worst Forms of Child Labour. The one fundamental labor?  child rights convention includes: UN Convention on the Rights of the Child (almost universal global ratification with the exception of Somalia and USA) . Others include: ILO Convention 29 (1930) on Forced Labour; ILO Convention 105, Abolition of Forced Labour; UN Protocol to Prevent, Suppress & Punish Trafficking in Persons, especially Women and Children (2000) ("The Palermo Protocol"); UN Optional Protocol to the Convention on the Rights of the Child on the Sale of Children, Child Prostitution and Child Pornography; Optional Protocol to the Convention on the Rights of the Child in Armed Conflict (for fragile or conflict settings).   51 Does the Borrower's ILO distinguishes between the minimum age for light legislation specify the socializing work and minimum age for employment. minimum age for light Minimum Age Convention, 1973 (No. 138)  sets the socializing work; minimum general minimum age for admission to employment or age for employment and work at 15 years (13 for light work) and the minimum includes a prohibition of age for hazardous work at 18 (16 under certain strict hazardous work for persons conditions). It provides for the possibility of initially below 18 years? setting the general minimum age at 14 (12 for light work) where the economy and educational facilities are insufficiently developed. These are key aspects of compliance of national legislation with international standards.   Does the Borrower have a A national plan or strategy that addresses child labor national plan or strategy in can be either a broader child rights or child protection place that addresses child strategy or plan with components on child labor. It can labor prevention and also be a child labor specific action plan or strategy, or mitigation?  it can be a sector strategy or action plan in the project's sector (e.g. agriculture, industry or services) that recognizes the problem of child labor within the sector and outlines measures to address the problem. Regardless of the scope and focus of the plan or strategy, it should be an expression of the fact that the Government has identified child labor as problem, the magnitude of the problem and has expressed its vision to work to reduce the problem through a number of strategies and activities, identified the various stakeholders to be involved in implementation, and sometimes also the resource allocation needed for implementation. Does the Borrower have a Child labor is an issue that needs to be addressed national coordinating body through concerted action and across multiple sectors. with a mandate to Many countries that are giving higher political priority coordinate stakeholders to the issue have therefore established national involved in child labor-work? coordinating bodies / steering committees to facilitate coordination amongst the stakeholders involved. Sometimes such coordinating body has a specific child labor mandate, other times coordinating bodies have a broader mandate to coordinate issues around child protection or child rights. The Committee on the Rights of the Child, in examining States parties’ reports, usually encourages coordination of government to ensure effective implementation:  coordination among central government departments, among different provinces and regions, between central and other levels of government and between Government and civil society.  52 Has the Borrower already In many countries, there are already multiple implemented initiatives stakeholders involved in addressing child labor since towards the elimination of many years, but often these initiatives remain small child labor at sufficient scale pilots with poor linkages with government systems and relevance to effectively and services. While small community-based pilots reduce child labor represent an opportunity to identify good practices prevalence, either nationally that may have an impact and could be built upon in a or locally (in selected national programme, many will still be at a stage where geographic areas)? they are fully dependent on donor support, will not be sustainable if such support was withdrawn and the government has poor oversight and ownership of the programme. Other times, pilot initiatives have been anchored in government adopted guidance documents, and/or standards and there may for example be a national steering committee in place that oversees the implementation of the pilot and monitors its progress. The Government has thus shown full ownership of the pilot or project, even though it may be fully funded by a donor or a group of donors. Finally, there are also pilot initiatives and programmes that are both owned by the government and where government may be providing some of the funding, even though it may not have national scale or be implemented everywhere. The ownership and commitment of the government is here what we perceive as an indicator of capacity, and what the question refers to.  Does the Borrower have a Child protection systems are the very important child protection system in (multi-sectoral) systems that need to be strong to place with a sufficiently play a role in prevention, mitigation and remediation of strong professional child victims, highly vulnerable children and children at workforce at local level to risk. They usually rely on a workforce of "social implement case workers" / "child protectors" / "child protection management for children officers" that may go under different names in found in child labor? different countries. This workforce is  the "spine" of the child protection system and their role is in most countries regulated by Law that gives they a statutory mandate to represent the child's best interests. As such they are responsible for undertaking individual case management, assessing the situation of the child and defining a plan to help the child and sometimes also the family. For children who are without parental care or an immediate care giver (which would sometimes be the case for example for trafficking victims), the case manager acts to find an emergency placement, to give the child access to emergency health care, take contacts from the child community of origin to explore opportunities for return, family reunification and reintegration etc. The child protection workforce is thus important do defend the 53 rights of children who are extremely vulnerable or at risk (e.g. living and/or working on the street), or who have been victims of some of the worst forms of child labor. Project characteristics What is the child labor This refers to child labor prevalence in the sector of prevalence rate in the sector the project (which is different from the indicator in line where the project will 4 that considers all economic activities or household intervene / sector for which chores undertaken by children that qualify as child the project will use labor labor in all sectors of the country, including the force?  domestic environment). Sectors with highest child labor prevalence are often sectors that offer informal job opportunities that are less regulated (e.g. the agriculture sector in many countries, the domestic sector) and/or sectors where family labor is common (e.g. work is undertaken on a family farm, in a family shop). Has child trafficking and/or "Economic sector(s) of the project" should be forced child labor cases interpreted broadly to include both a sector for which been identified before in the a project may influence a reform (e.g. agriculture economic sector(s) of the sector) and a sector from which a project may employ project? a labor force. This means that if a project would support a reform of a sector with no trafficking / forced child labor cases, but will include construction elements and employ a labor force from the construction sector that has seen prior child trafficking and/or forced child labor cases, the answer to the question should be "yes" even if the main sector of investment is not known for child trafficking or forced child labor. It is suggested to look at the last 3 years TIP reports, under the section "trafficking profile" Can the project ensure There is a higher risk of child labor in sectors and jobs sufficient adult labor force to where there is not enough adult labor available. This meet the labor needs of the can happen in very labor-intensive sectors, requiring a project?  lot of manual work, where jobs require low or no skills, and when pay is low (adults may choose to work in better paid jobs). Absence of adult labor supply can also be a regularly occurring feature because of gaps in health and safety of adult workers and/or when the overall workplace is hazardous for all workers. If adult laborers fall sick or get injured, children can be pushed to step in (sometimes temporarily) to replace a parent or another adult laborer. When responding to this question, consider if these risk factors exist in the 54 sector of the project or the area of implementation. If the assessment is that any of the risk factors are present (manual labor-intensive work, low skills and low paid work, generally hazardous work, generally poorly regulated or difficult to regulate health and safety of workers), the response in the drop-down menu should be yes. Does the project have a This would refer to situations where the project, e.g. potential to negatively due to construction elements such as the building of impact access to social infrastructure elements (e.g., roads, a dam) has a risk services? of changing people's access to school buildings, water points, health facilities because these facilities and services have to be moved/removed, or the travel time or any other factor influencing access will be affected by the project. Lack of access to social services, such as schools and health care centers is a key factor influencing adults’ and children’s socio- economic outcomes and poor socio-economic outcomes are a root cause of child labor.  Does the project have a This would refer to situations where the project would potential to adversely remove or move facilities that employ people in an impact labor force area, thus risks making people living in the area lose requirements in the sector their jobs or source of income. It would also refer to which is the main source of projects which have plans to resettle community livelihoods in the project members to locations where they have to find new area, leading to more livelihoods. The loss of income or the risk of losing an demand for child labor? income of an adult family member may push families into poverty. Poverty in turn is a root cause of child labor.  55 Annex 2: Checklist for including Child Labor risk mitigation in Labor Management Procedures (LMPs) in Ghana projects Section of LMP  Overview of labor use on the project Identify project workers who may be between 14 and 18 years and are: Employed with a labor contract (only 15+) Engaged in light work activities (14+) without being employed Identify the timing when children between 14 and 15 (authorized for light work without being employed) and between 15 and 18 (authorized for employment) may be involved in the project’s Labor Requirements. For example: Is there a specific project phase when children between 14 and 15 may be found to be engaged in economic activities (light work)? Is there a specific project phase when children between 15 and 18 may be employed to support the project’s labor requirements? Assessment of key potential labor risks Is the location of the project in a geographic area identified with high child labor risk (see lines 11-18 in tool "2. Project risk assessment tool")? Is the project taking place in a sector with high child labor risk (see lines 3-8 in tool "2. Project risk assessment tool"? What are the hazardous tasks often observed in this sector and to be avoided for children? 56 Is the project intervening in a sector and in a geographic area known for high levels of migrants and victims of trafficking and forced labor, amongst which child victims of trafficking and forced labor have been previously identified? Will the project stimulate demand for services around the project sites (e.g. street vending)?  Brief overview of labor legislation: terms and conditions List all relevant legislation and regulations and specific requirements related to minimum age Are the key legislative frameworks, regulations and national guidance, and negotiated best-practice documents that regulate children's rights and employment mentioned? Is it clearly stated that the minimum age for employment is 15 years and when the child has completed compulsory education? Are the conditions for children's (15+) employment detailed? Is it clearly stated that the minimum age for undertaking light work (but not be employed) is 14 years (as per ESS2) on the World Bank project, even though 13 years is the minimum age as per national legislation? Are conditions for children's involvement in light work (14+) detailed? Brief overview of labor legislation: Occupational health and safety Key aspects of the national labor legislation with regards to occupational health and safety Does the description of occupational health and safety issues reflect hazardous (prohibited) tasks for children below 18? Does the description of occupational health and safety issues reflect hazardous (prohibited) tasks for the specific sector, as defined in the Child Labor Hazardous Activity Framework (2016) of Ghana? 57 Responsible staff Functions and/or individuals within the project responsible for various issues Is someone named responsible for awareness and training of on child labor? Is someone named responsible to ensure that contractors do not engage child labor and children 15+ for hazardous work Is someone named responsible for age-verification? Is someone named responsible for child safeguarding? Is someone named responsible for supervising and monitoring that child labor is not employed on the project? Is someone named responsible for addressing and monitoring grievance cases related to child labor and child abuse? Policies and procedures Policies and procedures to prevent child labor and WFCL Is there an obligation defined for employers to establish an awareness and training plan that will increase awareness on what child labor is, and what to do in case child labor is identified? Is there an obligation defined for employers to establish a child safeguarding and protection policy on worksites? Is there an obligation defined for employers to put in place a plan to monitor and supervise that no child is involved in child labor? Is there an obligation defined for employers to establish logs with identifying information, such as name, age of the child that specifies for workers under 18 years old, the tasks to be accomplished and forbidden? 58 Is there an obligation defined for employers to appoint someone responsible for supervising working conditions on the worksite? Is there an obligation defined for employers to establish a policy and plan for health and safety at work? Age of employment Is it specified that the minimum age for employment on a project is 15 years? Terms and conditions Working conditions for children who have the minimum age of employment (15+) Do the terms and conditions define that children 15+ can only be employed under condition that a medical practitioner has certified that the young person is in good health and is medically fit for work? If the project is in the industry sector, do terms and conditions specify that employers in an industrial undertaking shall keep a register of young persons employed by him or her and their dates of birth or their apparent ages? Do the terms and conditions define the obligation to verify a person's age before employment and in the case of any doubt of the age, to make a positive presumption of a lower age to protect the child from any risk? Do the terms and conditions specify that the work of an employed child 15+ should not exceed 8 hours of work per day and 43 hours per week if the work is light and if the work takes place in heavy manual work occupations such as fishing, agriculture, and mining, that the work should not exceed 4 hours per day and 25 hours per week? Do the terms and conditions specify that children are never allowed to work at night, namely before 6:00 a.m. and after 8:00 p.m. Grievance mechanism Details of the specific provisions for children in grievance mechanisms  59 Does the description of the grievance mechanism describe that it should apply to children below 18 and what specific provisions should be in place for children?  Does the description of the grievance mechanism allow children to report cases to the grievance mechanism? Does the grievance mechanism define that any case of suspected child labor or exploitation should be reported to the grievance mechanism? Does the grievance mechanism specify what kind of information needs to be gathered on the case in order to do a preliminary assessment of the next steps and any eventual need for referral? Does the grievance mechanism specify where referrals should be made if a preliminary assessment of the grievance mechanism finds that the child is vulnerable (high socio-economic vulnerability, being below age of 15 and out of school, suspected to be victim of forced labor or child trafficking)? Contract management Procedure for managing and monitoring the performance of contractors Do procedures describe how to manage and monitor the performance of contractors ensure that these respect standards related to the non-use of child labor? Community workers Terms and conditions for work If community workers are used, are procedures defined to supervise that no child below 14 is engaged? If community workers are used, are procedures defined for reporting and removal of any child below 14 who may be engaged? If community workers are used, are procedures defined for the process to verify that any engagement of 14+ is voluntary and fulfills strictly conditions for 14+ engagement in light work? 60 If community workers are used, are procedures defined to verify that any engagement of 14+ which violates standards for 14+ engagement in light work are reported and remediated? Primary supply workers Child labor risk (incl. WFCL) and safety issues Are procedures defined for monitoring that primary supply workers are not below the minimum age for employment (15+)? Are procedures defined for monitoring that primary supply workers who are 15+ but below 18 years of age are not involved in hazardous tasks? Are procedures defined for reporting on the number of 15+ children who are employed as primary supply workers? Are procedures defined for reporting on any case of children below 15 years of age who may have been engaged as primary supply workers, or children who may have been forced to work, or be victims of trafficking (child labor and WFCL-cases)? Are procedures defined for reporting on any case of children 15+ but below 18 years of age who may have been found doing hazardous tasks on the work site? 61 Contact Information Address: The World Bank Dr. Isert Road 69 North Ridge Residential Area Accra, Ghana Email: afwssiplatform@worldbank.org