Findings on the Worst Forms of Child Labor - Comoros

Child Labor and Forced Labor Reports

Comoros

2016 Findings on the Worst Forms of Child Labor:

Moderate Advancement

In 2016, Comoros made a moderate advancement in efforts to eliminate the worst forms of child labor. The Government adopted the National Policy for the Protection of Children, which includes a component to combat the worst forms of child labor. The Government's Monitoring Group for the Fight Against Trafficking in Persons also met several times during the year and drafted a new action plan to combat human trafficking. However, children in Comoros perform dangerous tasks in agriculture. Children also engage in the worst forms of child labor, including in forced domestic work. A gap between the minimum age for work and the age for compulsory education leaves children ages 13 to 15 vulnerable to child labor. In addition, limited resources for the systematic enforcement of child labor laws impede government efforts to protect children from the worst forms of child labor.

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Children in Comoros perform dangerous tasks in agriculture. Children also engage in the worst forms of child labor, including in forced domestic work.(1-6) Table 1 provides key indicators on children’s work and education in Comoros.

Table 1. Statistics on Children’s Work and Education

Children

Age

Percent

Working (% and population)

5 to 14

23.0 (42,145)

Attending School (%)

5 to 14

81.5

Combining Work and School (%)

7 to 14

20.8

Primary Completion Rate (%)

 

76.4

Source for primary completion rate: Data from 2014, published by UNESCO Institute for Statistics, 2016.(7)
Source for all other data: Understanding Children’s Work Project’s analysis of statistics from Demographic and Health Survey (DHS), 2012.(8)

Based on a review of available information, Table 2 provides an overview of children’s work by sector and activity.

Table 2. Overview of Children’s Work by Sector and Activity

Sector/Industry

Activity

Agriculture

Production of manioc,† beans,† vanilla,† cloves,† and ylang-ylang† (1, 5, 6, 9, 10)

Animal husbandry† (3)

Fishing,† activities unknown (3, 5, 6, 9)

Industry

Carpentry,† activities unknown (3)

Extracting and selling marine sand† (6)

Construction,† activities unknown (3)

Services

Domestic work† (1-3, 9, 11, 12)

Street work, activities unknown (3, 5)

Repairing cars and bicycles,† including tire vulcanization† and battery charging† (3)

Categorical Worst Forms of Child Labor‡

Forced labor in domestic work, street vending, baking, fishing, and agriculture (4, 6, 10)

Commercial sexual exploitation, sometimes as a result of human trafficking (2, 4)

† Determined hazardous by national law or regulation.
‡ Child labor understood as the worst forms of child labor per se under Article 3(a)–(c) of ILO C. 182.

Some parents who are unable to care for their children send them to wealthier families that are expected to provide food, shelter, and schooling to the children in exchange for housework. In practice, some of these children receive care and an education, while many become domestic workers and are victims of labor exploitation and abuse.(4-6, 13) In Comoros, it is a traditional practice to send children to Koranic teachers to receive an education. Some Koranic teachers, however, force their students to work; girls usually perform domestic work and boys perform agricultural labor.(4, 6, 13) In nearby Mayotte, which is administered by France, reports indicate that there are over 3,000 unaccompanied children from Comoros, some of whom are exploited in the worst forms of child labor, including commercial sexual exploitation and forced domestic work.(4, 14, 15)

Although the Constitution guarantees free compulsory primary education, this provision is not enforced effectively, and many children, especially girls, do not attend school.(6, 16) Also, the lack of school infrastructure and the limited availability of teachers impede access to education, which may increase the vulnerability of children to the worst forms of child labor.(1, 6, 9, 12, 17)

Comoros has ratified most key international conventions concerning child labor (Table 3).

Table 3. Ratification of International Conventions on Child Labor

Convention

Ratification

ILO C. 138, Minimum Age

ILO C. 182, Worst Forms of Child Labor

UN CRC

UN CRC Optional Protocol on Armed Conflict

 

UN CRC Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography

Palermo Protocol on Trafficking in Persons

 

 

The Government has established laws and regulations related to child labor, including its worst forms (Table 4). The legal framework in Comoros appears to be sufficient to address and protect children from child labor.

Table 4. Laws and Regulations on Child Labor

Standard

Meets International Standards: Yes/No

Age

Legislation

Minimum Age for Work

No

15

Article 129 of the Labor Code (18)

Minimum Age for Hazardous Work

Yes

18

Article 131(d) of the Labor Code; Article 7 of Law to Combat Child Labor and Trafficking (18, 19)

Identification of Hazardous Occupations or Activities Prohibited for Children

Yes

 

List of Dangerous Occupations; Article 131(d) of the Labor Code; Article 7 of Law to Combat Child Labor and Trafficking (18-20)

Prohibition of Forced Labor

Yes

 

Articles 2.1 and 131 of the Labor Code; Article 13 of the Law to Combat Child Labor and Trafficking (18, 19)

Prohibition of Child Trafficking

Yes

 

Article 131 of the Labor Code; Article 13 of the Law to Combat Child Labor and Trafficking (18, 19)

Prohibition of Commercial Sexual Exploitation of Children

Yes

 

Article 131 of the Labor Code; Articles 8–11 and 13 of the Law to Combat Child Labor and Trafficking; Articles 322 and 323 of the Penal Code (18, 19, 21)

Prohibition of Using Children in Illicit Activities

Yes

 

Article 131(c) of the Labor Code; Article 6(c) of Law to Combat Child Labor and Trafficking (18, 19)

Minimum Age for Compulsory Military Recruitment

 

 

 

State Compulsory

N/A*

 

 

State Voluntary

Yes

18

Article 41 of Law No. 97-06/AF (22)

Non-state Compulsory

Yes

 

Article 6(a) of Law to Combat Child Labor and Trafficking(19)

Compulsory Education Age

Yes

12

Article 2 of the Outline Act on the Education System (23)

Free Public Education

Yes

 

Article 1 of the Outline Act on the Education System; Preamble of the Constitution (23, 24)

* No conscription (25)

The Government has drafted a Penal Code and a Code of Criminal Procedures that increase the penalties for human trafficking crimes and has also submitted a proposal to ratify the Palermo Protocol on Trafficking in Persons; however, neither of these legislative proposals was enacted during the reporting period.(4, 15, 26, 27)

The Labor Code allows children under the minimum age to perform light work in domestic work or agriculture as long as it does not interfere with education or with physical or moral development.(18) The Labor Code, however, does not specify the conditions under which light work may be conducted or limit the number of hours for light work, as defined by international standards on child labor.(28) In addition, children working in unpaid or non-contractual work do not have the same protections under child labor laws and regulations as do children working in contractual employment.(5, 28)

Children in Comoros are required to attend school only up to age 12. This standard makes children ages 13 through 15 vulnerable to the worst forms of child labor as they are not required to attend school but are not legally permitted to work.(29, 30)

The Government has established institutional mechanisms for the enforcement of laws and regulations on child labor, including its worst forms (Table 5). However, gaps in labor law and criminal law enforcement remain and some enforcement information is not available.

Table 5. Agencies Responsible for Child Labor Law Enforcement

Organization/Agency

Role

Ministry of Labor (MOL)

Enforce child labor laws, investigate allegations of child labor, and refer cases of the worst forms of child labor for criminal investigation.(3, 4, 6)

Police Morals and Minors Brigade

Investigate allegations of child abuse, including child trafficking, and refer cases for prosecution.(3, 4)

Ministry of Justice (MOJ)

Prosecute criminal cases, including those related to child trafficking.(3, 15)

National Commission for Human Rights and Freedoms (CNDHL)

Receive complaints of the worst forms of child labor, investigate violations, and refer cases to the MOJ for prosecution.(3, 31)

 

Labor Law Enforcement

In 2016, labor law enforcement agencies in Comoros did not take actions to combat child labor, including its worst forms (Table 6).

Table 6. Labor Law Enforcement Efforts Related to Child Labor

Overview of Labor Law Enforcement

2015

2016

Labor Inspectorate Funding

Unknown

Unknown

Number of Labor Inspectors

4 (10)

4 (3)

Inspectorate Authorized to Assess Penalties

Yes (10)

Yes (10)

Training for Labor Inspectors

 

 

Initial Training for New Employees

No (10)

N/A

Training on New Laws Related to Child Labor

N/A

N/A

Refresher Courses Provided

No (10)

No (3)

Number of Labor Inspections

0 (10)

0 (3)

Number Conducted at Worksite

0 (10)

0 (3)

Number Conducted by Desk Reviews

0 (10)

0 (3)

Number of Child Labor Violations Found

0 (10)

0 (3)

Number of Child Labor Violations for Which Penalties Were Imposed

N/A

N/A

Number of Penalties Imposed that Were Collected

N/A

N/A

Routine Inspections Conducted

No (10)

No (10)

Routine Inspections Targeted

N/A

N/A

Unannounced Inspections Permitted

Unknown

Unknown

Unannounced Inspections Conducted

No (10)

No (10)

Complaint Mechanism Exists

Unknown

No (3)

Reciprocal Referral Mechanism Exists Between Labor Authorities and Social Services

Unknown

Unknown

 

In 2016, the Ministry of Labor (MOL) employed four labor inspectors: two in Grand Comore, one for Anjouan, and one for Mohéli.(3) The number of labor inspectors is insufficient for the size of Comoros’s workforce, which includes over 245,000 workers. According to the ILO recommendation of 1 inspector for every 40,000 workers in less developed economies, Comoros should employ about 6 inspectors.(10, 32-34) Reports indicate there is a lack of equipment, transportation, and funding available to conduct child labor inspections and legal proceedings.(3, 6, 15)

Criminal Law Enforcement

In 2016, criminal law enforcement agencies in Comoros did not take actions to combat the worst forms of child labor (Table 7).

Table 7. Criminal Law Enforcement Efforts Related to the Worst Forms of Child Labor

Overview of Criminal Law Enforcement

2015

2016

Training for Investigators

 

 

Initial Training for New Employees

No (10)

No (3)

Training on New Laws Related to the Worst Forms of Child Labor

N/A

N/A

Refresher Courses Provided

No (10)

No (3)

Number of Investigations

0 (35)

0 (3, 15)

Number of Violations Found

0 (35)

0 (3)

Number of Prosecutions Initiated

0 (35)

0 (3, 15)

Number of Convictions

0 (35)

0 (3, 15)

Reciprocal Referral Mechanism Exists Between Criminal Authorities and Social Services

Unknown

No (5)

 

Reports indicate that a lack of trained staff, equipment, transportation, and funding inhibit criminal law enforcement efforts on the worst forms of child labor.(1, 4, 5, 15) Police are unable to open an investigation unless the victim self-reports the alleged crime at the police station and can pay the expenses associated with the investigation, including fuel and telephone fees; therefore, investigations are reactive and depend on the victim’s wealth and knowledge of the criminal justice system, making investigations of cases involving victimized children unlikely.(5)

The Government has established mechanisms to coordinate its efforts to address child labor, including its worst forms (Table 8).

Table 8. Key Mechanisms to Coordinate Government Efforts on Child Labor

Coordinating Body

Role & Description

National Committee Against Child Labor

Coordinate government efforts on child labor, including the implementation of the National Action Plan to Combat Child Labor. Chaired by the Ministry of Labor.(12, 13, 28, 36)

Monitoring Group for the Fight Against Trafficking in Persons

Coordinate actions against human trafficking and implement the Anti-Trafficking in Persons Action Plan. Headed by the Secretary General of the Government and includes representatives from the MOL, MOJ, CNDHL, and police.(4, 5, 10) In 2016, met several times to draft a new Action Plan.(4)

 

The National Committee Against Child Labor was inactive during the reporting period.(37)

The Government has established policies on child labor, including its worst forms (Table 9).

Table 9. Key Policies Related to Child Labor

Policy

Description

Anti-Trafficking in Persons Action Plan

Includes the goals of enhancing the legal framework to prevent human trafficking and commercial sexual exploitation and providing effective protection and care for victims.(5, 13, 38) In 2016, the TIP Task Force drafted a new action plan, which was not validated because of the presidential elections.(4, 15, 35)

National Policy for the Protection of Children (2016–2021)†

Aims to improve child protection in Comoros; includes components to combat the worst forms of child labor, with a focus on child trafficking. Led by the Ministry of Health.(3)

Strategy for Accelerated Growth and Sustainable Development (2015–2019)

Aims to reduce poverty, promote sustainable development, and increase access to social services. Integrates strategies that target child labor.(4, 26, 39)

† Policy was approved during the reporting period.

In 2016, the National Action Plan to Combat Child Labor remained unfunded.(37)

In 2016, the Government of Comoros funded and participated in programs that include the goal of eliminating or preventing child labor, including its worst forms (Table 10).

Table 10. Key Social Programs to Address Child Labor

Program

Description

Child Protection Units†

Government program that provides social and reintegration services to vulnerable and sexually abused children. Comprises three government-operated units on the islands of Anjouan, Grande Comore, and Mohéli.(4, 5, 26)

Decent Work Country Program (2015–2019)

Program that aims to guarantee labor rights and extend social protection programs for vulnerable populations, including by improving the operational environment for the elimination of child labor and its worst forms.(11) Overseen by the MOL and supported by the ILO. In 2016, conducted raising awareness campaigns to improve access to decent work for youth.(11, 40)

UNICEF Country Program (2015–2019)

$20,885 UNICEF-funded program that supports the Government’s efforts to strengthen children’s rights to survival, development, education, protection, and social inclusion.(1, 26). In 2016, continued to fund shelters for victims of the worst forms of child labor operated by the NGO Service d’Ecoute.(3, 12)

† Program is funded by the Government of Comoros.

Although the Government has in place programs that target child labor, their scope is insufficient to fully address the extent of the problem, particularly in agriculture and domestic work.(15) Comoros also lacks a specific program to assist children exploited by religious instructors.

Based on the reporting above, suggested actions are identified that would advance the elimination of child labor, including its worst forms, in Comoros (Table 11).

Table 11. Suggested Government Actions to Eliminate Child Labor, Including its Worst Forms

Area

Suggested Action

Year(s) Suggested

Legal Framework

Ratify the Palermo Protocol on Trafficking in Persons.

2014 – 2016

Ensure that the law’s light work provisions prescribe the number of hours per week that light work may be undertaken, and specify the conditions under which light work may be conducted, as defined by international standards on child labor.

2012 – 2016

Ensure that the law’s minimum age provisions and protections apply to children in unpaid or non-contractual work.

2015 – 2016

Raise the compulsory education age to 15 to be equivalent to the minimum age for work.

2009 – 2016

Enforcement

Carry out inspections and criminal investigations to enforce compliance with the laws that address child labor.

2009 – 2016

Increase the resources, training, available transportation and equipment, and number of criminal law investigators and labor inspectors responsible for enforcing laws on child labor to provide adequate coverage of the workforce.

2009 – 2016

Publish information on the labor inspectorate’s funding, the number of criminal investigators, law violations and penalties assessed, and criminal investigations, prosecutions, and convictions related to cases of the worst forms of child labor.

2009 – 2016

Establish referral mechanisms between labor and criminal law enforcement agencies and social welfare entities.

2014 – 2016

Coordination

Ensure that the National Committee Against Child Labor actively carries out its responsibilities related to the worst forms of child labor.

2014 – 2016

Government Policies

Fund and implement the National Action Plan to Combat Child Labor.

2016

Social Programs

Enhance efforts to eliminate barriers and make education accessible for all children, including girls, by increasing school infrastructure and teacher availability.

2014 – 2016

Conduct research to determine the activities carried out by children working in fishing, carpentry, construction, and street work to inform policies and programs.

2016

Expand existing programs to address the scope of the child labor problem, particularly in agriculture and domestic work.

2009 – 2016

Implement a program to assist children exploited by religious instructors.

2016

1.         UNICEF. Comoros Country Programme Document Program Report. Geneva; September 11, 2014. http://www.unicef.org/about/execboard/files/2014-PL5_Comoros_CPD-final_approved-EN.pdf.

2.         ILO Committee of Experts. Individual Direct Request Concerning Worst Forms of Child Labour Convention, 1999 (No. 182) Comoros (ratification: 2004) Published: 2015; accessed November 19, 2015; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:3189324.

3.         U.S. Embassy- Antananarivo. reporting, February 02, 2017.

4.         U.S. Department of State. "Comoros," in Trafficking in Persons Report- 2016. Washington, DC; June 30, 2016; http://www.state.gov/j/tip/rls/tiprpt/countries/2016/258746.htm.

5.         UNODC. Trafficking in Persons Assessment, The Union of the Comoros (Grande Comore, Anjouan and Moheli) July 2015. Source on file.

6.         U.S. Department of State. "Comoros," in Country Reports on Human Rights Practices- 2016. Washington, DC; March 03, 2017; http://www.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm?year=2016&dlid=265240.

7.         UNESCO Institute for Statistics. Gross intake ratio to the last grade of primary education, both sexes (%). [accessed December 16, 2016]; http://data.uis.unesco.org/. Data provided is the gross intake ratio to the last grade of primary education. This measure is a proxy measure for primary completion. This ratio is the total number of new entrants in the last grade of primary education, regardless of age, expressed as a percentage of the population at the theoretical entrance age to the last grade of primary education. A high ratio indicates a high degree of current primary education completion. The calculation includes all new entrants to the last grade (regardless of age). Therefore, the ratio can exceed 100 percent, due to over-aged and under-aged children who enter primary school late/early and/or repeat grades. For more information, please see “Children's Work and Education Statistics: Sources and Definitions” in the Reference Materials section of this report.

8.         UCW. Analysis of Child Economic Activity and School Attendance Statistics from National Household or Child Labor Surveys. Original data from Demographic and Health Survey (DHS), 2012. Analysis received December 15, 2016. Reliable statistical data on the worst forms of child labor are especially difficult to collect given the often hidden or illegal nature of the worst forms. As a result, statistics on children’s work in general are reported in this chart, which may or may not include the worst forms of child labor. For more information, please see “Children's Work and Education Statistics: Sources and Definitions” in the Reference Materials section of this report.

9.         ILO Committee of Experts. Individual Direct Request Concerning Minimum Age Convention, 1973 (No. 138) Comoros (ratification: 2004) Published: 2014; accessed November 5, 2014; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:3146874.

10.       U.S. Embassy - Antananarivo. reporting, April 1, 2016.

11.       ILO. Programme Pays pour le Travail Décent Comores 2015-2019. Geneva; 2015. http://www.ilo.org/public/english/bureau/program/dwcp/download/comores2015-19.pdf.

12.       Government of Comoros. Politique Nationale de Protection de I'Enfant en Union des Comores. Moroni; October 13, 2016. Source on file.

13.       U.S. Embassy- Antananarivo. reporting, January 24, 2014.

14.       U.S. Embassy- Antananarivo. reporting, January 13, 2017.

15.       U.S. Embassy- Antananarivo. reporting, February 13, 2017.

16.       UN. Concluding Observations of the Committee on the Elimination of Discrimination Against Women. New York; October 24, 2012. http://www2.ohchr.org/english/bodies/cedaw/docs/co/CEDAW.COM.CO.1-4.pdf.

17.       Ministry of Education, Research, Culture and Arts, in Charge of Youth and Sports. Diagnostic du Système éducatif comorien pour une politique nouvelle dans le cadre de l’EPT: Rapport d’Etat du Système Educatif Comorien (RESEN). Moroni; February 12, 2012. http://www.unicef.org/evaldatabase/files/Comoros_RESEN_2012-101_vf.pdf.

18.       Government of Comoros. Loi N° 12- Abrogeant, Modifiant et Complétant Certaines Dispositions de la Loi N 84-108/PR Portant Code du Travail, 84-108/PR, enacted June 28, 2012. http://www.ilo.org/dyn/natlex/docs/MONOGRAPH/91298/105824/F-496652550/COM-91298.pdf.

19.       Government of Comoros. Loi N° 14- 034/AU Portant lutte contre le travail et la traite des enfants enacted December 22, 2014. http://www.ilo.org/dyn/natlex/docs/MONOGRAPH/98176/116722/F962391713/COM-98176.pdf.

20.       Government of Comoros. Liste des travaux dangereux aux Comores, enacted 2012.

21.       Government of Comoros. LOI N° 082/PAF-LOI 95-012/AF portant Code Pénal, enacted September 18, 1995. http://www.wipo.int/wipolex/en/text.jsp?file_id=208475.

22.       Government of Comoros. Loi N° 97- 006/AF Portant Statut des personnels militaires de la République Fédérale Islamique des Comores, enacted July 21, 1997.

23.       Government of Comoros. Loi N°94-035/AF Portant orientation sur l’éducation, enacted January 20, 1995.

24.       Government of Comoros. Constitution, enacted December 23, 2001. http://www.ilo.org/dyn/natlex/docs/ELECTRONIC/72696/74026/F-92095240/COM-72696.pdf.

25.       Child Soldiers International. Louder than words: An Agenda for Action to End State Use of Child Soldiers. London; 2013. https://www.child-soldiers.org/shop/louder-than-words-1.

26.       UNICEF. UNICEF Annual Report 2014 Comoros. New York; June 11, 2015. http://www.unicef.org/about/annualreport/files/Comoros_Annual_Report_2014.pdf.

27.       U.S. Embassy- Antananarivo. reporting, February 03, 2017.

28.       ILO Committee of Experts. Individual Direct Request Concerning Minimum Age Convention, 1973 (No. 138) Comoros (ratification: 2004) Published: 2015; accessed November 19, 2015; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:3189321.

29.       African Committee of Experts on the Rights and Welfare of the Child (ACERWC). Harmonisation of Children's Laws in Comoros. Country Brief. Addis Ababa; May 15, 2012. http://www.africanchildforum.org/clr/Harmonisation%20of%20Laws%20in%20Africa/Publications/supplementary-acpf-harmonisation-cb-es_en.pdf.

30.       ILO Committee of Experts. Individual Direct Request Concerning Worst Forms of Child, 1999 (No. 182) Comoros (ratification: 2004) Published: 2014; accessed November 6, 2014; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:3147123.

31.       Comores Droit. L'UNICEF équipe la Commission Nationale des Droits de l'Homme et des Libertes (CNDHL). January 15, 2016. http://www.comores-infos.net/lunicef-equipe-la-commission-nationale-des-droits-de-lhomme-et-des-libertes-cndhl/.

32.       CIA. The World Factbook, [online] [cited March 18, 2017]; https://www.cia.gov/library/publications/the-world-factbook/fields/2095.html#131. Data provided is the most recent estimate of the country’s total labor force. This number is used to calculate a “sufficient number” of labor inspectors based on the country’s level of development as determined by the UN.

33.       ILO. Strategies and Practice for Labour Inspection. Geneva, Committee on Employment and Social Policy; November 2006. http://www.ilo.org/public/english/standards/relm/gb/docs/gb297/pdf/esp-3.pdf. Article 10 of ILO Convention No. 81 calls for a “sufficient number” of inspectors to do the work required. As each country assigns different priorities of enforcement to its inspectors, there is no official definition for a “sufficient” number of inspectors. Amongst the factors that need to be taken into account are the number and size of establishments and the total size of the workforce. No single measure is sufficient but in many countries the available data sources are weak. The number of inspectors per worker is currently the only internationally comparable indicator available. In its policy and technical advisory services, the ILO has taken as reasonable benchmarks that the number of labor inspectors in relation to workers should approach: 1/10,000 in industrial market economies; 1/15,000 in industrializing economies; 1/20,000 in transition economies; and 1/40,000 in less developed countries.

34.       UN. World Economic Situation and Prospects 2012 Statistical Annex. New York; 2012. http://www.un.org/en/development/desa/policy/wesp/wesp_current/2012country_class.pdf. For analytical purposes, the Development Policy and Analysis Division (DPAD) of the Department of Economic and Social Affairs of the United Nations Secretariat (UN/DESA) classifies all countries of the world into one of three broad categories: developed economies, economies in transition, and developing countries. The composition of these groupings is intended to reflect basic economic country conditions. Several countries (in particular the economies in transition) have characteristics that could place them in more than one category; however, for purposes of analysis, the groupings have been made mutually exclusive. The list of the least developed countries is decided upon by the United Nations Economic and Social Council and, ultimately, by the General Assembly, on the basis of recommendations made by the Committee for Development Policy. The basic criteria for inclusion require that certain thresholds be met with regard to per capita GNI, a human assets index and an economic vulnerability index. For the purposes of the Findings on the Worst Forms of Child Labor Report, “developed economies” equate to the ILO’s classification of “industrial market economies; “economies in transition” to “transition economies,” “developing countries” to “industrializing economies, and “the least developed countries” equates to “less developed countries.” For countries that appear on both “developing countries” and “least developed countries” lists, they will be considered “least developed countries” for the purpose of calculating a “sufficient number” of labor inspectors.

35.       U.S. Embassy- Antananarivo. reporting, February 26, 2016.

36.       Ministère de l'Economie du Travail de l'Emploi du Commerce Exterieur. Plan d'Action National pour l'Elimination des Pires Formes de Travail des Enfants aux Comores: 2010-2015. Moroni; October 2009. source on file.

37.       U.S. Embassy- Antananarivo. reporting, March 02, 2017.

38.       Government of Comoros. Lettre d'engagment et plan d'action sur la traite des être humains. Moroni; May 24, 2013. source on file.

39.       Government of Comoros. Strategie de Croissance Acceleree et de Developpement Durable (SCA2D). Moroni; January 27, 2015. Source on file.

40.       International Trade Union Confederation. World Day for Decent Work-CTC Comores. September 20, 2016. http://www.ituc-csi.org/ctc-comores.

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