Child Labor Policy

Policy Brief & Purpose

The Child Labor Policy of Legero International Group outlines our position on the employment of minors and ensures that Legero International Group, its subsidiaries, and all organizations within our supply chain comply with applicable laws and protect the rights and well-being of children.

Under the UN Convention and ILO Conventions, a child is defined as a person under the age of 18. The entire supply chain of Legero International Group is free of minors under the age of 15, in accordance with ILO Convention 138 on Minimum Age and the Responsible Business Act.

These conventions further define a minor as any individual under 15 years of age, below the age at which compulsory education ends, or below the minimum legal working age in the country of residence. According to ILO Convention 182, young workers aged 15 to 18 may perform only light work, under adult supervision, with strict restrictions on overtime and hazardous tasks.

Legero International Group is committed to operating legally, ethically, and responsibly. Preventing child labor is fundamental to our values. We ensure that our organization does not participate in or contribute to child exploitation and actively supports efforts to eliminate child labor across our operations.

Scope

This policy applies to Legero International Group, all subsidiaries, and all business partners, including suppliers, vendors, contractors, and subcontractors.

The policy is guided by:

  • Child Labour | International Labour Organization
  • Convention on the Rights of the Child | OHCHR
  • ILO Conventions 138 and 182
  • The ILO Declaration on Fundamental Principles and Rights at Work
  • The UN Guiding Principles on Business and Human Rights (UNGPs)

We will always apply the strictest applicable law and require our suppliers, partners, and vendors to do the same. They must also ensure compliance throughout their own supply chains.

In this policy, “children” refers to individuals under 18 years of age, and “young children” refers to individuals under 15. “Child labor” refers to work that harms a child’s physical, mental, or social development, deprives them of schooling, or undermines their dignity.

Policy Elements — Young Children

Children under the age of 15 are not permitted to work at any point within the supply chain of Legero International Group.

ILO Convention 182 allows young workers aged 15 to 18 to perform only light work under adult supervision and prohibits them from engaging in hazardous or strenuous tasks.

Legero International Group adheres to the eight core ILO conventions (29, 87, 98, 100, 105, 111, 138, and 182). All stages of our supply chain—regardless of process step—fall under this policy. We strive for child-labor-free operations throughout all tiers.

Legal Exceptions — Parental Employment

Family-owned businesses may occasionally involve the owner’s children in non-hazardous work outside school hours. If children are exposed to risks or consistently miss school due to work, Legero International Group will terminate the cooperation.

Occasional Learning Activities

Children may occasionally accompany parents to work to learn practical skills or assist with simple, safe tasks. This is acceptable as long as safety is ensured and schooling is not disrupted.

Older Children (15–18 years)

Children aged 15 to 18 may be employed in accordance with applicable laws, provided the work does not endanger their health, safety, development, or education.

Permissible light work may include:

  • Shelf stocking
  • Short-distance package delivery by bicycle
  • Light cleaning duties

Young workers will not operate heavy machinery, hazardous equipment, vehicles, or chemicals. Work hours and wages will strictly follow legal requirements.

Legero International Group will refuse partnerships with any organization that employs children in hazardous conditions or violates legal requirements regarding wages or working hours.

Supply Chain Employment

Legero International Group does not directly operate in high-risk areas. References to “employment” within this policy refer to individuals employed by our first- and second-tier suppliers.

  • First-tier suppliers: Local partners
  • Second-tier suppliers: Agents
  • Lower-tier suppliers: Collection points and subcontractors

Actions and Implementation

To enforce this policy and support the elimination of child labor, Legero International Group commits to:

  • Collaborating with governments and organizations to combat child labor and promote education.
  • Training staff on youth employment laws and reporting procedures.
  • Ensuring HR and hiring managers do not recruit minors below the legal working age and comply with all wage and hour regulations for young workers.
  • Keeping and verifying age documentation for all employees. Where a minor under 18 is identified, we will review applicable laws and adjust working conditions or terminate employment with appropriate support measures.
  • Communicating this policy to all business partners and including relevant requirements in contracts.
  • Conducting regular and ad-hoc audits of suppliers, including unannounced site visits.
  • Immediately terminating cooperation if concealed facilities employing minors are discovered.
  • Requiring suppliers who identify child labor to develop and implement a corrective action plan.
  • Consulting experts on child labor, health and safety standards, and corporate social responsibility when required.

Reprimand Actions

Upon discovery of child labor, Legero International Group will implement the following measures to ensure the minor’s immediate withdrawal from the supply chain:

If the partner refuses to cooperate with prevention measures or if child labor reoccurs, Legero International Group will permanently terminate the business relationship.

Cooperation with the partner involved is immediately suspended.

The child is removed from the work environment without delay.

Detailed information is documented (name, date and place of birth, family situation, education, work start date, total working hours, and wages).

The CEO and the Operations Department of Legero International Group are notified.

The incident is reported through the internal complaint system.

A parent or guardian—and when appropriate, a local NGO specializing in child rights—will be contacted.