CHILD LABOUR POLICY


Old Windsor Logistics Ltd acknowledges the fact that child labour occurs in many countries. However, Old Windsor Logistics Ltd does not accept child labour, and works actively against it. The complexity of the child labour issue requires a consistent, long-term effort to create sustainable and broad-based solutions in order to reach our goal; that no products delivered to Old Windsor Logistics Ltd are produced by child labour. Old Windsor Logistics Ltd respects different cultures and values in countries where Old Windsor Logistics Ltd operates and sources its products, but does not compromise on the basic requirements regarding the Rights of the Child.

Old Windsor Logistics Ltd Child Labour Policy has been established in order to make Old Windsor Logistics Ltd position clear to suppliers and their co-workers, as well as any other parties. The requirements in this code of conduct are mandatory to all suppliers and their sub-contractors.


1. General Principle

Old Windsor Logistics Ltd does not accept child labour. Old Windsor Logistics Ltd supports the United Nations (U.N.) Convention on the Rights of the Child (1989).

Old Windsor Logistics Ltd child labour policy is based on this Convention, which stipulates:
 

• “All actions concerning the child shall take full account of his or her best interests.” Article 3.

• “The right of the child to be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral or social development”.  Article 32.1.

In addition, this policy is based on the International Labour Organisation (ILO) Minimum Age Convention no. 138 (1973). According to this convention, the word “Child” is defined as any person below fifteen (15) years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply. If, however, the local minimum working age is set at fourteen (14) years of age in accordance with exceptions for developing countries, the lower age will apply.

This Policy also incorporates the ILO Convention on the Worst Forms of Child Labour no. 182 (1999).
 

2. Implementation

All actions to avoid child labour shall be implemented by taking the child’s best interests into account. Old Windsor Logistics Ltd requires that all suppliers shall recognise the U.N. Convention on the Rights of the Child, and that the suppliers comply with all relevant national and international laws, regulations and provisions applicable in the country of production. Suppliers are obliged to take the appropriate measures to ensure that no child labour occurs at suppliers’ and their sub-contractors’ places of production. If child labour is found in any place of production, Old Windsor Logistics Ltd will require the supplier to implement a corrective action plan. If corrective action is not implemented within the agreed time-frame, or if repeated violations occur, Old Windsor Logistics Ltd will terminate all business with the supplier concerned. The corrective action plan shall take the child’s best interests into consideration, i.e. family and social situation and level of education. Care shall be taken not merely to move child labour from one supplier’s workplace to another, but to enable more viable and sustainable alternatives for the child’s development.

The supplier shall effectively communicate to all its sub-contractors, as well as to its own coworkers, the content of Old Windsor Logistics Ltd Child Labour Policy, and ensure that all measures required are implemented accordingly.
 

3. Labour force register

The supplier shall maintain documentation for every worker verifying the worker’s date of birth. In countries where such official documents are not available, the supplier must use appropriate assessment methods as per local practice and law.
 

4. Monitoring

All suppliers are obliged to keep Old Windsor Logistics Ltd informed at all times about all places of production (including their sub-contractors). Any undisclosed production centres found would constitute a violation of this code of conduct. Through the General Purchasing Conditions for the supply of products to Old Windsor Logistics Ltd, Old Windsor Logistics Ltd has reserved the right to make unannounced visits at any time to all places of production (including their sub-contractors) for goods intended for supply to Old Windsor Logistics Ltd. Furthermore, Old Windsor Logistics Ltd reserves the right to assign, at its sole discretion, an independent third party to conduct inspections in order to ensure compliance with Old Windsor Logistics Ltd Child Labour policy.
 

5. Remediation

If child labour is found in the supply chains of Old Windsor Logistics Ltd, it will seek to work in partnership with the supplier and appropriately qualified organisations to develop a responsible solution that is in the best long-term interests of the children. The supplier and Old Windsor Logistics Ltd will agree a corrective action plan, which may comprise the following actions:
 

• Collate a list of all potential child labourers and young workers

• Seek advice and help from a recognised local non-governmental organisation that deals with child labour or the welfare of children

• Develop a remediation plan that secures the children’s education and protects their economic well-being, in consultation with Old Windsor Logistics Ltd and where possible a local NGO, and in consultation with and respecting the views of the child

• Explain the legal requirements and restrictions on working ages to the children and assure them that, if they wish, they will be employed when they reach working age

• Understand the children’s desires and explore the opportunities for them to re-enter education.

• Whether the child contributes to the livelihoods of their family or they are self-dependent, his or her wage should continue be paid until they reach working age, or until an alternative long-term solution has been agreed with the child and their family (for example employment of an unemployed adult family member in place of the child labourer).

  • Ensure that the child worker has adequate accommodation and living conditions.

  • Document all actions

  • Develop processes to prevent recurrence

  • Do not:

    • Expel any of the suspected or confirmed child labourers and/or young workers

    • Threaten the children or their families or hamper the progress of investigation and remediation

    • Conceal or falsify any documentation
       

Such actions will be considered by Old Windsor Logistics Ltd as evidence that the supplier is not committed to child labour remediation, in breach of this Child Labour Policy.

Daniel Sheehy 

MD

© Old Windsor Logistics 2020