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GRI 408: Child Labor · 2016

Disclosure GRI 408-1

Operations and suppliers at significant risk for incidents of child labor

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

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Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI

To prepare this disclosure

7datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain where, across its own operations and its supply chain, there is a meaningful risk of child labour incidents. The focus is not on saying child labour has occurred everywhere, but on identifying the parts of the business and supplier base where the risk is significant and therefore needs attention.

In practice, the reporting should cover the organisation’s full footprint rather than only a few well-known sites. It should show how the organisation has identified the higher-risk operations and suppliers, so readers can understand whether the assessment is broad and systematic or limited to selected locations or relationships.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Have you already fixed which parts of your own operations, and which supplier groups, you will treat as higher-risk for child labour checks? For the young-worker / hazardous-task angle, have you decided whether you are assessing the same sites and suppliers, or a different set? When you list the higher-risk operations and suppliers, have you chosen the basis you will use — for example, business type or location — and kept that basis consistent? Have you settled the reporting period and cut-off you will use for the measures you describe, so the figures and actions line up with the same time window? Can every number or list item be traced back to a source you can show, such as a risk review, supplier file, or internal record? Have you agreed which internal definitions you will use for ‘child labour’, ‘young workers’, and ‘hazardous work’ before drafting the answer?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Child labour risk sites List the organisation’s own sites, activities or locations that have been flagged as having a material chance of child labour incidents. Risk assessment, site risk register, audit findings, country or activity screening, compliance review notes. Sustainability / Human Rights / Compliance

Child labour risk suppliers List the supplier groups, categories or sourcing locations that have been identified as having a material chance of child labour incidents. Supplier risk mapping, procurement due diligence, supplier segmentation, audit results, country risk screening. Procurement / Supply Chain / Compliance

Hazardous youth risk sites List the organisation’s own sites, activities or locations where young workers could be exposed to hazardous tasks or conditions. Workplace risk assessments, H&S reviews, incident logs, age-restricted task controls, site audit reports. Health & Safety / HR / Compliance

Hazardous youth risk suppliers List the supplier groups, categories or sourcing locations where young workers could be exposed to hazardous tasks or conditions. Supplier due diligence, audit reports, labour standards assessments, sourcing risk maps, corrective action records. Procurement / Supply Chain / Compliance

High-risk child labour sites Explain which kinds of own operations, or which countries and areas, are treated as higher risk for child labour incidents, and why. Risk methodology, country risk matrix, activity-based risk assessment, internal control review, audit summaries. Sustainability / Human Rights / Compliance

High-risk child labour suppliers Explain which kinds of suppliers, or which countries and areas, are treated as higher risk for child labour incidents, and why. Supplier risk methodology, sourcing country matrix, supplier segmentation rules, due diligence files, audit summaries. Procurement / Supply Chain / Compliance

Child labour action steps Describe the actions taken during the reporting period that were meant to help eliminate child labour in practice. Programme plans, training records, supplier remediation logs, audit follow-up, policy updates, management review minutes. Sustainability / Human Rights / Compliance

＋ Show GRI 408-1 sub-elements (LRA working checklist)

How to prepare it

1Set the boundary first: list the parts of your own business and the supplier base you will assess, then decide which of those sit in the higher-risk group for child labour or for younger workers being put into hazardous tasks.

2Define the basis for that risk call in plain terms. Use the nature of the activity, the country or area involved, or the supplier category, and keep the logic consistent so the same approach is used across the whole disclosure.

3Gather support for each named item. Keep records that show why each operation or supplier was treated as higher risk, and retain the source material behind any judgement used to place it in scope.

4Compile the disclosure content in two parts: the list of higher-risk operations and suppliers, and a separate account of the actions taken during the period that were meant to help eliminate child labour more effectively.

5Explain any exclusions, boundary changes, or reclassifications that affect the current year’s figures or narrative. Make clear what moved in or out of scope and why, so the reader can follow the comparison with prior periods.

6Check the final wording against the official source before sign-off. Confirm that every required item is covered, that the labels match the underlying evidence, and that nothing has been omitted or overstated.

Request the data

Request the supplier and site risk evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which parts of our own operations and supplier base have been flagged internally as higher risk for child labour or for younger workers being put into hazardous tasks, and what actions were taken in the period?

Use your organisation’s own labels first, then map them to the disclosure. For example, ask for your high-risk sites, supplier groups, sourcing regions, audit findings, and child-labour prevention actions rather than using framework wording in the request.

Weak request

Please provide the GRI 408-1 evidence for operations and suppliers at significant risk for incidents of child labour, including young workers exposed to hazardous work and measures taken.

Why it fails: This uses framework language that many teams do not use day to day, and it bundles several ideas without telling the owner what internal records to pull. It is harder to answer because it does not point to the team’s own risk register, audit tracker, or action log.

Better request

Please send the current list from your supplier risk register and site risk tracker showing which operations, supplier groups, and sourcing regions your team treats as higher risk for child labour or for younger workers in hazardous tasks, plus the basis for each flag and the actions taken during the reporting period.

Formal email template

Subject: [Reporting period] request for supplier and site risk evidence

Hi [name],

Could you please send the information for [reporting period] on the parts of our operations and supplier base that your team has flagged as higher risk for child labour or for younger workers being assigned hazardous tasks?

Please include:
- the sites, supplier groups, or sourcing regions you treat as higher risk;
- the internal basis used to flag them;
- the actions taken during the period to reduce the risk or respond to findings;
- the source file or system extract, plus any notes needed to interpret the data.

If it is easier, you can return this in the attached table and add any supporting documents or links. Please adapt the wording to your team’s own terms, and check the disclosure source before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name] — could you share the [reporting period] list of our higher-risk sites and supplier groups, plus the basis for the flag and the actions taken in the period? Please use your team’s own terms and attach the source file or tracker. Thanks.

Industry examples

Apparel manufacturing

Context. The business sources from cut-and-sew factories and trims suppliers in several countries.

Adapted request. Please share the [reporting period] extract from the supplier risk register and factory audit tracker showing which factories, labour agencies, and sourcing countries your team classifies as higher risk for child labour or for younger workers in hazardous tasks, plus the checks and remediation actions completed in the period.

Example response. A table listing 14 factories and 3 labour agencies, with country, internal risk label, audit basis, age-check findings, corrective actions, and status; plus links to the audit reports and supplier improvement plans.

Agriculture / food production

Context. The business uses seasonal labour on owned farms and buys from growers and packhouses.

Adapted request. Please provide the [reporting period] list from your farm assurance and supplier oversight records showing which farms, packhouses, grower groups, and sourcing regions are treated as higher risk for child labour or for younger workers doing hazardous tasks, together with the basis for the flag and the actions taken.

Example response. A spreadsheet covering 9 owned farms, 11 grower groups, and 2 packhouses, with region, internal risk category, screening basis, worker-age controls, training delivered, and follow-up actions; plus the assurance tracker reference.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Explain how the organisation defined a higher-risk operation or supplier, including the criteria used to identify risk by activity type and by location, and note whether the assessment covered the full reporting period or a specific cut-off date.

Context note

Set out what the figures show about where child-labour exposure and hazardous-work exposure are most likely to arise, distinguishing the organisation’s own activities from its supplier network and linking the numbers to the places or business lines involved.

Fluctuation statement

If the profile changed from the prior period, describe whether the movement came from changes in the risk screen, shifts in the business or supplier base, or the effect of actions taken to reduce exposure.

Content index entry

GRI 408-1 Operations and suppliers at significant risk for incidents of child labor — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for GRI 408-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

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01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We based the coverage figure on a documented review of the parts of the business we judged most exposed to child-labour risk, rather than on a broad group-wide count.An assurer may test whether the risk screen was applied consistently, whether the chosen boundary was justified, and whether any exposed sites or activities were left out.Risk assessment papers, site or activity lists reviewed, the criteria used to flag exposure, sign-off notes explaining inclusions and exclusions, and any mapping between the risk review and the reported coverage figure.

We compiled the supplier figure from a defined supplier population that we screened for elevated child-labour exposure, using the same selection logic throughout the reporting period.An assurer may probe whether the supplier boundary is complete, whether high-risk vendors were omitted, and whether the screening method was applied consistently across categories and geographies.Supplier master data, risk-ranking methodology, procurement or ESG screening outputs, exception logs, and evidence of management review of the final supplier set.

We identified the operations in scope by looking for places where younger workers could be put into unsafe tasks, and we kept a record of why each site or activity was included.An assurer may challenge whether the hazard screen was robust, whether the judgement about young-worker exposure was evidence-based, and whether the final list matches the underlying review.Hazard assessments, age-related work restrictions or task matrices, site review records, inclusion rationale for each operation, and approval of the final list before publication.

We built the supplier scope from a risk review of supplier type and location, then checked that the final list matched the categories we had marked as exposed.An assurer may ask whether the supplier risk model was complete, whether location and supplier-type factors were applied properly, and whether the published scope is supported by source records.Supplier risk methodology, country or region risk mapping, supplier segmentation reports, procurement records, and evidence of reconciliation between the risk review and the published supplier scope.

We used a documented screening process to decide which parts of the business sat in the higher-risk group for child labour, and we retained the working papers behind those decisions.An assurer may test whether the screening criteria were objective, whether the same approach was used across the business, and whether the reported set reflects the documented assessment.Screening templates, risk criteria, internal review notes, working papers showing how each business area was assessed, and approval records for the final classification.

We applied a similar risk screen to suppliers, using supplier type and operating location to decide which ones belonged in the higher-risk group, and we kept the supporting analysis.An assurer may examine whether the supplier screen was complete and current, whether the risk factors were applied consistently, and whether the published figure is traceable to the underlying analysis.Supplier risk assessment files, location-based risk inputs, supplier categorisation outputs, change logs, and management sign-off on the final supplier grouping.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The team asks a framework lead instead of the business owner who actually knows which sites, suppliers, or countries are treated as higher risk in day-to-day operations.

Framework language only

People collect answers using disclosure labels rather than the organisation’s own site, supplier, or country terms, so the source data cannot be traced back to normal business records.

No clear boundary

The request does not say whether the review covers all operations, only certain business lines, or just selected suppliers, so different teams return different populations.

Wrong time basis

The data pull mixes the current reporting period with older risk assessments or later updates, so the final set does not match one consistent cut-off date.

Mixed counting basis

One team counts individual sites while another counts legal entities or supplier accounts, which makes the totals impossible to compare or combine cleanly.

Source labels lost

Original risk ratings, country tags, or supplier category names are stripped out during consolidation, so no one can see how each item was classified.

Populations merged

Operations and suppliers are blended into one list even though they need to stay separate, which hides where the risk sits and creates double counting.

No evidence trail

The file contains the final list but not the supporting notes, extracts, or sign-off record, so reviewers cannot check who approved the source data or when.

Where judgement is often needed

Setting the cut-off for which sites count as higher risk

Use one clear screening basis for your own sites and explain it, so readers can see why certain locations were included or left out.

Deciding whether a newly bought or sold business is in the year’s scope

State the point at which an acquisition starts to be counted, or a disposal stops being counted, and keep that treatment consistent across the year.

Handling different local age and labour rules across countries

Where local rules differ, explain the rule set or threshold you used to flag exposure to child labour risk and apply it consistently by country or area.

Choosing how to treat borderline worker groups

If a group sits near the boundary of your scope, say whether you included them and why, using the same logic for similar cases.

Separating own operations from supplier screening

Make clear whether a site or supplier was flagged because of the type of activity, the place it operates in, or both, and avoid double counting the same risk driver.

Using estimates where full checks are not available

If you rely on estimates or proxy information for some locations or suppliers, identify that in the explanation and distinguish it from directly checked data.

Rounding and small-number suppression

Round figures in a way that does not change the picture, and note any suppression or grouping used to protect confidentiality.

Aggregating sensitive location detail for privacy

When exact site or supplier names cannot be shown, group them at a higher level and explain the aggregation so the reader understands the basis of the count.

Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Apparel manufacturing

*Synthetic example only.* During the year, we reviewed our own sites and key external suppliers for child-labour exposure, focusing on labour-intensive operations and sourcing locations with weaker age-verification controls. We identified 3 of 18 owned sites (17%) and 5 of 40 direct suppliers (13%) as higher-risk for child labour, and 2 owned sites and 3 suppliers as higher-risk for younger workers being assigned hazardous tasks; in response, we ran age-check refreshers, tightened supplier screening, and carried out follow-up audits in the period. - Our higher-risk own sites were concentrated in cut-and-sew and finishing activities in two countries where we operate in higher-risk labour markets. - Our higher-risk suppliers were mainly first-tier textile processors and trim makers in the same two countries and one neighbouring sourcing hub. - The actions taken were aimed at helping remove child labour from our value chain through prevention, detection, and remediation follow-up.

Illustrative disclosure showing how a reporter can describe where child-labour risk sits in its own operations and supply chain, include young-worker hazardous-work exposure, and summarise actions taken in the year.

Illustrative (synthetic) example — Food processing

*Synthetic example only.* We screened our plants and purchased-agriculture suppliers for age-related labour risk, with particular attention to seasonal work, manual handling, and countries where enforcement is less consistent. On that basis, 4 of 22 plants (18%) and 6 of 55 suppliers (11%) were treated as higher-risk for child labour, while 1 plant and 2 suppliers were flagged for possible exposure of younger workers to hazardous duties; during the period we updated contractor onboarding, retrained site managers, and required corrective plans from the suppliers concerned. - The plant risk was linked to seasonal packing and maintenance work in two operating countries. - The supplier risk was linked to farm-gate aggregators and labour brokers in three sourcing countries. - Our year-end actions were designed to support the effective elimination of child labour across the business and its supply chain.

Illustrative disclosure showing a different sector and risk profile, while still covering own operations, suppliers, young-worker hazardous-work exposure, and measures taken in the reporting period.

Company reports

How companies report GRI 408-1

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

London Luton Airport Operations Ltd.

Air Transportation — Airport Services · United Kingdom · 2024

Open report →

London Luton Airport Operations Ltd.’s Sustainability Report 2024 provides data on operations and suppliers at significant risk for incidents of child labour, as noted on page 71. The report also includes figures on the total number of suppliers, with 895 and 1,242 reported on page 49. However, there is no quotable evidence found in the report regarding other specific narrative items or detailed disclosures related to this topic.

SK Chemicals Co.,Ltd

Chemicals · Republic of Korea · 2024

Open report →

SK Chemicals Co., Ltd’s 2024 Sustainability Report includes coverage of child labor risks in operations and suppliers, specifically referencing significant risk incidents on page 186. The report also details supply chain management results and ESG risk assessments with corrective actions on page 118, alongside a supply chain capability enhancement program targeting business partner participation on the same page. However, there is no quotable evidence found regarding other narrative items such as broader labor practices or specific compliance details elsewhere in the report.

China Airlines, Ltd.

Air Transportation — Airlines · Taiwan · 2024

Open report →

China Airlines’ 2024 Sustainability Report includes coverage of child labor risks in operations and suppliers, specifically noting significant risk areas on page 184. The report also details supply chain sustainability assessment implementation for critical tier-one suppliers across 2022 to 2024 on page 81, and references a Supplier Code of Conduct with geographic breakdowns on page 76. However, there is no quotable evidence found regarding other specific narrative items or detailed corrective actions related to child labor beyond these points.

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Check your understanding

Scenarios to work through

A manufacturer runs a metal-finishing site in a country where the labour market includes many school-age workers, and it also buys packaging from a small local converter near that site. The team has flagged both the site and the converter as needing closer review, but the draft report only names the site.

QShould the disclosure cover both the site and the converter, and should the team explain why each was treated as higher risk?

Reveal model answer →

A retailer sources garments from two factories. One is in a region where the company has previously found underage workers in the wider sector; the other is in a country with no known sector issue, but it uses many temporary labour brokers. The preparer is unsure whether to mention only the country risk or also the supplier type risk.

QHow should the team decide what to include when the risk comes from both where the supplier is located and what kind of supplier it is?

Reveal model answer →

A mining group has a remote processing plant and a warehouse in the same country. The plant is flagged because young workers could be exposed to hazardous tasks, while the warehouse is not. The draft narrative groups both together as one high-risk operation.

QIs it acceptable to bundle the two sites together, or should the preparer separate the one with the hazardous-work concern from the one without it?

Reveal model answer →

A food company spent the year tightening supplier screening, adding age-verification checks for labour brokers, and training procurement staff in two high-risk sourcing countries. No child labour case was found, but the team is unsure whether these actions belong in the disclosure because they are preventive rather than remedial.

QShould the report include these actions, even though no incident was confirmed during the year?

Reveal model answer →

Framework references