GRI 408 Child Labour
GRI 408 requires companies to identify operations and suppliers at significant risk for child labour incidents and describe the measures taken to address these risks. For companies with supply chains in high-risk countries or sectors, GRI 408 is a material disclosure with significant reputational consequences.
GRI 408 requires companies to identify operations and suppliers at significant risk for child labour incidents and describe the measures taken to address these risks. GRI 408-1 requires disclosure of: operations and suppliers considered to have significant risk for incidents of child labour; the type of operation (own operations, first-tier supplier, other tier supplier); and the measures taken to address significant risks.
What GRI 408-1 requires
GRI 408-1 requires disclosure of: operations and suppliers considered to have significant risk for incidents of child labour; the type of operation (own operations, first-tier supplier, other tier supplier); and the measures taken to address significant risks.
The disclosure is qualitative — you are not reporting incident counts (which would require knowledge of specific violations). You are disclosing your risk assessment methodology and the mitigation measures in place.
A credible 408-1 disclosure includes: the risk assessment approach used (country risk, sector risk, audit programme); the geographic scope assessed; the audit or verification methodology; and the remediation approach if violations are found.
Risk assessment methodology
Country risk: Use internationally recognised child labour risk indices — the US Department of Labor's List of Goods Produced by Child Labor or Forced Labor; ILO child labour statistics by country; the Maplecroft Child Labour Index.
Sector risk: Agriculture (cocoa, coffee, tobacco, cotton), mining (artisanal gold, mica), garments, electronics assembly, and domestic work are consistently identified as high-risk sectors globally.
Supplier audit programmes: SA8000 certification, SMETA (Sedex Members Ethical Trade Audit), BSCI audits, and Fair Trade certification all include child labour assessment. Tier 1 supplier audit coverage is the baseline; tier 2 screening is increasingly expected for high-risk commodities.
For CSDDD compliance (mandatory from 2027): child labour is one of the priority adverse human rights impacts requiring mandatory due diligence — GRI 408 disclosure provides the evidence trail.
What to do when violations are found
GRI 408-1 requires disclosure of remediation measures — not just risk assessment. If audits identify child labour violations, the response framework matters:
Immediate: Remove the child from the workplace safely; ensure access to education and income replacement for the family (immediate withdrawal without support can worsen outcomes).
Short-term: Require corrective action plan from supplier with timeline; suspend orders pending verification of remediation.
Medium-term: Consider whether to continue the supplier relationship based on remediation commitment and systemic risk.
Long-term: Engage in industry programmes (ILO Better Work, Responsible Business Alliance) that address root causes at sector level.
Disclosure of a violation and credible remediation is better than silence — it demonstrates a functioning due diligence system.
Frequently asked questions
What is the ILO definition of child labour for GRI 408?
The ILO Minimum Age Convention (No. 138) sets 15 as the minimum working age (14 in developing countries with limited educational infrastructure). Hazardous work is prohibited under 18 globally. GRI 408 uses ILO definitions — work that does not interfere with education and is not hazardous may not constitute child labour under ILO standards.
Do we need to report GRI 408 if we only operate in low-risk countries?
Assess before excluding. Your own operations may be low-risk, but your supply chain may source commodities from high-risk countries — agricultural inputs, minerals, electronics components. GRI 408-1 covers supply chain risk, not just own operations.
How does GRI 408 relate to CSDDD?
CSDDD (Corporate Sustainability Due Diligence Directive) requires large EU companies to conduct mandatory human rights due diligence across their supply chains, with child labour as a priority risk. GRI 408 voluntary disclosure provides the framework and documentation for CSDDD compliance on this specific risk.