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Indicator 3.3.1
by Contact on 8 October 2026
Requirement
The UoC shall not engage in child labour. Child labour is work that: – is mentally, physically, socially or morally dangerous and harmful to children; or – interferes with their schooling.
How Do I Interpret This Requirement?
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‘No engagement’ means that child labour does not occur:
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within the UoC’s production sites and facilities
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as a result of actions taken by recruitment agencies for the UoC
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within the UoC’s supply chain.
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A child is anyone under the age of 18.
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Child labour is any unacceptable form of work carried out by children and is prohibited by ASC, including the following:
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all children under the age of 13 taking part in any economic activity;
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all children aged 13 and 14 years old engaged in more than light work as stipulated by national, regional and/or local regulations;
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all children under the age of 18 involved in work that is mentally, physically, socially or morally dangerous and harmful to children or interferes with their schooling.
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Table 2 below shows the ages of children and the type of work that they are permitted to engage in:
Table 2. Ages of children and type of work permitted:
Allowed type of work Hazardous work Non-hazardous work Light work
Adult Employee Allowed Allowed Allowed
aged 18 or older
Young Employee Not allowed Allowed Allowed
between 15 — 17 years old (and older than the age of mandatory schooling)
Child engaged in light work Not allowedNot allowedAllowed**
**between 13 and 14 years old (and anyone younger than the age of mandatory schooling)
Child Not allowedNot allowedNot allowed**
**under 13 years old
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ILO notes: ‘Not all work done by children should be classified as child labour that is to be targeted for elimination. The participation of children or adolescents above the minimum age for admission to employment in work that does not affect their health and personal development or interfere with their schooling, is generally regarded as being something positive. This includes activities such as assisting in a family business or earning pocket money outside school hours and during school holidays. These kinds of activities contribute to children’s development and to the welfare of their families; they provide them with skills and experience, and help to prepare them to be productive members of society during their adult life.’
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If children are assisting at the UoC as part of it being a family business, this would be covered by the scope of this Criterion.
Evidence of Implementation
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age verification records
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employee contracts
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job descriptions of all employees.
Auditors Should Confirm
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presence of general risk factors for child labour in a country;
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NGOs’ or other local organisations’ knowledge of any reports of child labour in the sector in this region;
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human resources personnel’s awareness of any issues in the workplace;
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worker or union representatives’ awareness of any issues in the workplace;
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whether or not any children are present at the UoC;
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that employees and managers have an understanding of what is hazardous work and what is light work;
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confirm life or work histories of employees, when a suspicion exists that the age of an employee does not match the records.
Useful Resources
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What is Child Labour? What is child labour | International Labour Organization (ilo.org)
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Supplier Guidance on Preventing, Identifying and Addressing Child Labour, ILO <https://www.ilo.org/ipec/Informationresources/WCMS_792211/lang–en/index.htm>
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Roundtable on Sustainable Palm Oil Guidance on Child Rights for Palm Oil Producer <https://rspo.org/wp-content/uploads/RSPO-GUI-T08-007_V1_ENG_Guidance_on_Child_Rights_for_PO_Producers.pdf#:~:text=The%20RSPO%20standards%20require%20palm,for%20employees%20and%20their%20families>.
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Rainforest Alliance Child Labor Guide <https://www.rainforest-alliance.org/resource-item/child-labor-guide-an-introduction/>
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FAO Guidance on addressing child labour in fisheries and aquaculture: <https://www.fao.org/3/i3318e/i3318e.pdf>
