1. Purpose and field of application

Assuming that Cleca refuses to resort forms of child labor, the purpose of this procedure is:

  • to define the methods by which the company remedies to child labor situations identified in entities connected by supply contract or subcontracting
  • to define the methods by which the company promotes the education of children, which are part of ILO138 Agreement and Recommendation 146.

Furthermore this procedure defines how Cleca manages possible employment relationships with young workers (including apprentices and trainees) at its headquarterse.


1.1 Riferimenti 

Rule SA 8000 – latest version available.


1.2 Definitions

Child: Any person under 15 years of age, unless local laws on minimum age determine for a greater age for work or compulsory schooling, in which case the highest age applies.

Child labour: Any work carried out by a child under the age specified in the above definition of ‘child’ above.

Young worker: – Any person aged between 15 and 18 years who carries out a paid job.

Remedial action against child labour: Any form of support and actions needed to guarantee safety, education, and development of children who have been subject to child labour, as defined above, and have terminated such labour.


1.3 Responsibility

The Management commits not to hire workers under the age of 18.


The Senior Management is responsible for ensuring that no workers under 18 are hired.


1.4 General aspects

In line with the principles and values described in regulation SA 8000, Cleca commits not to resort to workers defined as children, as determined in the Italian regulations in force. To safeguard children as exhaustively as possible, the following procedure contains and describes the activities that Cleca would put in place to recover children who are used as workers – by mistake or on purpose – by its suppliers.


As for young workers, Cleca collaborates with entities engaged in vocational training to host stages at its premises, and it commits to refrain from exposing young workers to situations that are hazardous, risky, or harmful for their health, also complying with indications contained in stage conventions and the regulations in force.


1.5 Operational methods

Upon hiring a new employee, it is the task of the Senior Management to check that the employee is not a child, by carefully examining his/her personal details, requesting, and checking an identity document or a birth certificate. In case the person is under 18, the Senior Management shall refuse to hire him/her.


In case the company gets to know about suppliers who resort to child labour, it is bound to:

  • check the age of workers
  • check the need for work
  • check the access to transportation to school
  • check the type of work (whether heavy or light)
  • check the total amount of work, and whether it is full-time or part-time
  • check any risks for health

After checking the existence of the problem, and trying – as much as possible – to involve the organization involved, the SPT drafts a plan for child recovery, defining:

  • The critical aspects of the child’s situation;
  • The recovery actions to put in place, identifying the best for the specific situation;  


Regardless of what has been mentioned above, the maximum protection must be given to children, preventing their potential exposure to risks that may jeopardize their health and safety. Whenever possible, the working relationship with the child should immediately stop, and the child can be hired again as soon as he/she has the minimum requirements, in the meantime the company shall find alternative solutions.

Aware of the difficulties in managing the situation, Cleca can have the support of associations such as Telefono Azzurro, local NGOs etc...), which may give indications on the most suitable methods to develop a relationship with children and their families.

In case of young workers in the company or hired by suppliers, it is necessary to check and monitor whether such workers are being exposed to hazardous or harmful tasks, as well as compliance with the indications contained in the stage conventions and in the regulations in force.

The Senior Management shall be responsible for such activities, in collaboration with the administration.

Refusal of child labour is communicated to all levels (both inside and outside the Company) in the Code of Ethics and in the Policy for Social Accountability SA8000.

During audit procedures, both inside the company and at suppliers, the presence of child or young workers must be checked.