The OECD’s Due Diligence Guidance for Responsible Supply Chains recommends that companies sourcing from conflict-affected and high-risk areas should have strong policies in place including a model supply chain policy seeking to avoid the worst forms of child labour.

The internationally recognized definition of ILO Convention No. 182, which is also enshrined in national law in the countries of the Great Lakes Region, defines the worst forms of child labour as “work that is likely to harm the health, safety, or morals of children, by its nature or the circumstances in which it is carried out.” The worst forms of child labour are prohibited for anyone under the age of 18 and specifically include mining activities such as work underground, work with dangerous machinery and tools, transport of heavy loads, and work that exposes children to hazardous substances.

Child labour is a reality in some of artisanal mines of the Democratic Republic of Congo (DRC) where boys and girls aged perhaps from five years upward are engaged in an array of work in and around the mines from lower risk, supporting work to some instances of worst forms of labor involving actual mining and mineral processing.

Children work in mines for a wide variety of reasons. They are driven into the mines by poverty and their work is an essential contribution to their families’ overall welfare. A complex array of drivers and factors which span social, cultural, economic, and pragmatic issues are intertwined around the phenomenon and require a sophisticated response.

Companies wishing to ensure make progress towards OECD recommendations are faced with a conundrum. Whilst they do not want to source minerals from areas where children may work, withdrawing from the supply chain and placing embargoes on mines where children operate is a blunt and damaging response which would exacerbate rather than relieve hardship.