The Nobles of Global Trade

Anti-Child Labor Policy

ANTI-CHILD LABOR POLICY

Scope

This policy applies to the Davis Trade & Commodities and its subsidiaries. Davis Trade & Commodities communicates this policy to its suppliers.

Objective

DR Congo and international organizations agree that child labor in the mining sector, including artisanal operations, is a major problem. The Davis Trade & Commodities acknowledges that child labor is also found in the production of tantalum, tin, tungsten, and gold in the Democratic Republic of Congo (DRC) and other conflict nations, where Davis Trade & Commodities could possibly operate. As such, Davis Trade & Commodities is committed to eliminating cases of child labor in its operations and supply chains.

DEFINITIONS

In accordance with Ministerial Order No. 12/CAB. MIN/TPSI/045/08 of 08 August 2008 setting the working conditions of children, Davis Trade & Commodities adheres particularly to Articles X and XIII relating to the working conditions of children aged 16 to under 18. This is particularly the case for load transport conditions set at 15kg for boys and 10kg for girls.

Davis Trade & Commodities recognizes that within the meaning of Ministerial Order 12/CAB. MIN/TPSI/045/08 of August 8, 2008 setting the conditions of child labor, which a child refers to anyone under the age of 18. Under this order, no child under the age of 16 may perform any form of work.

Davis Trade & Commodities prohibits children from occupying work that is greater than their strength, exposing them to student risks or which by their nature or by the conditions in which they are performed, are likely to injure their morals.

Davis Trade & Commodities undertakes, in accordance with Article XIII to arrest him as a minister above, not to have resorted to the work of children under the age of 18 in order to:

      • Work that takes place underground, underwater or in confined spaces.
      • All work for driving engines, vehicles, and mechanical machinery.
      • Work that takes place under particularly difficult conditions; for example, for long hours, or at night, or for which the child is unjustifiably detained on the employer's premises.
      • Generally, any work prohibited because of its dangerous and unsanitary nature by the labor inspector who emerges.

Policy

In accordance with THE ILO Conventions 138 (Regarding the minimum age of employment in 1973) and 182 (Regarding the prohibition of the worst forms of child labor and immediate action in in view of their 1999 elimination), the OECD Guide to The Duty of Care for Responsible Ore Supply Chains from Conflict or High Risk Zones (3rd Edition), the OECD Practical Action for Companies to Identify and Address the Worst Forms of Child Labor in Mineral Supply Chains", the DRC Labor Code and Its Law No. 015/2002 of 16 October 2002 16/010 of 15 July 2016 amending and completing Labor Code Act 015-2002 and Ministerial Order No. 12/CAB. MIN/TPSI/045/08 of 08 August 2008 setting child working conditions, Davis Trade & Commodities confirms its long-term commitment not to tolerate and work on the elimination of child labor in its operations and supply chains.

In accordance with our duty of care on the supply chain, Davis Trade & Commodities is vigilant and considers the severity of the risk of child labor, as recommended by the OECD.

Given the work between Davis Trade & Commodities and other mining partners and the National and International Civil Society (Children Voice, ASSODIP, ETN and Pact/iTSCI) since 2016 on child labor in its mineral supply chain,

Precisely:

  • Davis Trade & Commodities is working with the government and other organizations to end child labor.
  • Davis Trade & Commodities educates its staff and partners on child labor laws and explains how to report on child labor bodies if they witness or suspect child labor.
  • Davis Trade & Commodities retains and validates all age verification documentation of our employees following their hiring. If we discover that we have hired a minor under the age of 18, we check the applicable laws and adjust the hours and nature of work accordingly.
  • Davis Trade & Commodities communicates its policy against child labor to other organizations to which it is connected and guarantees that its contracts contain appropriate clauses.
  • Davis Trade & Commodities conducts due diligence in accordance with the OECD Guide to its leading suppliers with a focus on the risks associated with child labor.
  • Davis Trade & Commodities requests and monitors plans to eliminate child labor in cases where providers have discovered child labor bodies.
  • Davis Trade & Commodities consults with experts on topics such as child labor.
  • Davis Trade & Commodities regularly conducts workshops on the phenomenon of work on its own or in conjunction with other actors in evaluation descents. Reports with recommendations are written on this. These recommendations are updates to this policy.