Findings on the Worst Forms of Child Labor - South Africa

Child Labor and Forced Labor Reports

South Africa

2016 Findings on the Worst Forms of Child Labor:

Moderate Advancement

In 2016, South Africa made a moderate advancement in efforts to eliminate the worst forms of child labor. During the year, the Government joined the Global Action to Prevent and Address Trafficking in Persons and Smuggling of Migrants partnership; increased funding for the Child Support Grant from $3.2 billion to $3.5 billion; augmented the number of social workers that care for child abuse victims, including child laborers; and increased enforcement efforts to combat the worst forms of child labor. However, children engage in the worst forms of child labor, including in commercial sexual exploitation and forced begging. Government social programs are not sufficient to address the scope of child labor, and barriers to education access remain, especially among children with disabilities. In addition, the Government does not collect comprehensive data on child labor to inform policies and programs.

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Children in South Africa engage in the worst forms of child labor, including in commercial sexual exploitation and forced begging.(1-3) Data on key indicators on children’s work and education are not available from the sources used in this report.

Table 1. Statistics on Children’s Work and Education

Children

Age

Percent

Working (% and population)

7 to 14

Unavailable

Attending School (%)

5 to 14

Unavailable

Combining Work and School (%)

7 to 14

Unavailable

Primary Completion Rate (%)

 

Unavailable

Primary completion rate was unavailable from UNESCO Institute for Statistics, 2016.(4)
Data were unavailable from Understanding Children’s Work Project’s analysis, 2016.(5)

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

Harvesting mangos, lychees, bananas, grapes, citrus, and other fruits (1, 6, 7)

Services

Domestic work (1, 3, 8)

Garbage scavenging for food items and recyclable items† (1, 9)

Food service, activities unknown (2, 3)

Street work, including vending and begging (2, 3, 8)

Categorical Worst Forms of Child Labor‡

Use in illicit activities, including drug trafficking, home burglaries, gang-related activity, and the production and selling of liquor,† sometimes as a result of human trafficking (2, 8)

Commercial sexual exploitation, sometimes as a result of human trafficking (2, 3, 10-15)

Forced labor in domestic work, agriculture, food service, street vending, and begging, each sometimes as a result of human trafficking (2, 3, 8, 13, 16, 17)

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

The Government does not collect comprehensive data on child labor.(3, 8, 18) There are some reports that children in South Africa are trafficked from rural to urban areas in Bloemfontein, Cape Town, Durban, and Johannesburg. Girls are trafficked for commercial sexual exploitation and domestic work, and boys are forced to work in begging, food service, and street vending.(2, 10, 11, 13) Orphaned children in South Africa are more likely to be engaged in child labor than those with a parent or grandparent in their household. Children with disabilities are especially vulnerable to becoming street beggars.(3, 8, 13)

The Department of Home Affairs (DHA) expanded online birth registration at 389 health facilities and also funded 117 mobile units to provide birth registration services to children in remote areas.(19) In addition, the DHA also adopted an annual performance plan to increase birth registrations from 750,000 to 990,000 by 2019.(20) UNICEF’s 2016 data show that 85 percent of children under age 5 in South Africa are registered at birth.(21) According to Chapter 2, Article 5 of the South African Schools Act, education is free through the primary level, but some schools charge fees that vary by municipality and region.(1, 3, 22) The Government has implemented a no-fee school program that covers the poorest primary schools and ordered that the schools in the first to third quintiles (poorest schools) receive school supplies, including books.(1, 23-26) The Government also provides some fee exemptions and reductions to children receiving government grants.(27, 28) The Government provides books and stationery; however, all families must pay for uniforms and other school-related expenses, which may affect children’s access to education.(9, 27, 29)

In 2007, South Africa ratified the UN Convention on the Rights of Persons with Disabilities that requires the Government to “ensure an inclusive education system at all levels and lifelong learning directed to the development by persons with disabilities of their personality, talents, and creativity, as well as their mental and physical abilities, to their fullest potential.”(30) However, several reports suggest that children in South Africa with disabilities have limited access to education because mainstream educational facilities are not equipped and teachers are not trained to teach children with disabilities. The most recent data received from the Department of Education found that in 2014 there were 447 schools equipped to handle children with disabilities. Since most mainstream schools cannot accommodate children with disabilities, parents are often forced to enroll children in special schools that require fees, thereby increasing the likelihood that these children will not receive an education.(31-35) In 2015, the Minister of Basic Education, Angie Motshekga, made a public statement that the “lack of specialized competencies among educators teaching at special and full-service schools [would be] addressed through multi-year plans for teacher training in areas like Braille, South African Sign Language, autism, augmentative and alternative communication, and effective utilization of assistive technology, among other initiatives.”(36) In 2016, President Zuma stated at the Disability Rights Summit that the goal of the Government is to “ensure that by 2021 no children with disabilities will be out of school; [children with disabilities] should all be able to attend their local neighboring schools and receive the necessary support.”(37) Despite these public declarations, evidence suggests that children with disabilities continue to encounter difficulties accessing education.

South Africa has ratified all 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). However, gaps exist in South Africa’s legal framework to adequately 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

Yes

15

Article 43 of the Basic Conditions of Employment Act (BCEA) (38)

Minimum Age for Hazardous Work

Yes

18

Article 1 of the BCEA; Regulations on Hazardous Work by Children in South Africa (38-40)

Identification of Hazardous Occupations or Activities Prohibited for Children

Yes

 

Articles 4-10 of the Regulations on Work by Children in South Africa; Part II, Articles 6-9 of the BCEA; Regulations on Hazardous Work by Children in South Africa (39, 40)

Prohibition of Forced Labor

Yes

 

Chapter 2 of the Constitution; Article 141 of the Children’s Amendment Act; Article 48 of the BCEA; Criminal Law Amendment Act 32 (40-42)

Prohibition of Child Trafficking

Yes

 

Article 141 of the Children’s Amendment Act; Criminal Law Amendment Act 32 (41, 43)

Prohibition of Commercial Sexual Exploitation of Children

Yes

 

Article 141 of the Children’s Amendment Act (41)

Prohibition of Using Children in Illicit Activities

Yes

 

Article 141 of the Children’s Amendment Act (41)

Minimum Age for Military Recruitment

 

 

 

State Compulsory

N/A*

 

Article 52 of the Defense Act (44)

State Voluntary

Yes

18

Article 52 of the Defense Act (44)

Non-state Compulsory

No

 

 

Compulsory Education Age

Yes

15

Chapter 2, Articles 1–5 of the South African Schools Act (22)

Free Public Education

Yes

 

Chapter 2, Article 5 of the South African Schools Act (22)

* No conscription (44)

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.

Table 5. Agencies Responsible for Child Labor Law Enforcement

Organization/Agency

Role

South African Department of Labor (SADOL)

Enforce child labor laws.(1, 45) Identify via inspectors suspected cases of child labor and human trafficking and forward evidence to South African Police Service (SAPS) officials, who investigate and forward cases to the South African Department of Justice and Constitutional Development for prosecution. Coordinate a report titled State of Child Labor in South Africa.(29) Operates labor centers that each have a designated child labor coordinator who focuses on child labor investigations.(1, 29)

South African Department of Justice and Constitutional Development

Enforce criminal laws on the worst forms of child labor.(1, 45)

National Prosecution Authority

Prosecute criminal cases, including human trafficking cases.(1)

SAPS Human Trafficking Desk

Monitor and evaluate efforts to investigate human trafficking crimes, train investigators, and refer human trafficking cases to provincial SAPS units.(1)

Department of Social Development (DSD)

Provide child protection and social services to vulnerable children, including victims of human trafficking.(46)

Although labor inspectors have civil servant status to ensure job security, their low salaries and lack of opportunities promote high turnovers and transfers to other agencies.(47) However, all labor officers received child labor training during the year.(19)

Labor Law Enforcement

In 2016, labor law enforcement agencies in South Africa took 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

$30 million (25)

$35 million (19)

Number of Labor Inspectors

1,599 (25)

1,533 (19)

Inspectorate Authorized to Assess Penalties

No (25)

No (19)

Training for Labor Inspectors

 

 

Initial Training for New Employees

Yes (25)

Yes (19)

Training on New Laws Related to Child Labor

Yes (25)

Yes (19)

Refresher Courses Provided

Yes (25)

Yes (19)

Number of Labor Inspections

149,847 (25)

146,307 (19)

Number Conducted at Worksite

149,847 (25)

Unknown (19)

Number Conducted by Desk Reviews

Unknown (25)

Unknown (19)

Number of Child Labor Violations Found

4 (25)

0 (19)

Number of Child Labor Violations for Which Penalties Were Imposed

N/A (25)

N/A (19)

Number of Penalties Imposed That Were Collected

N/A (25)

N/A (19)

Routine Inspections Conducted

Yes (25)

Yes (19)

Routine Inspections Targeted

Yes (25)

Yes (19)

Unannounced Inspections Permitted

Yes (25)

Yes (19)

Unannounced Inspections Conducted

Yes (25)

Yes (19)

Complaint Mechanism Exists

Yes (25)

Yes (19)

Reciprocal Referral Mechanism Exists Between Labor Authorities and Social Services

Yes (25)

Yes (19)

The South African Department of Labor (SADOL) inspectors are authorized to issue compliance orders to employers, which are enforced by the Labor Court. In addition, labor inspectors may also issue injunctions that prohibit a business from continuing if there is a health and safety risk to employees.(48) Inspectors are also authorized under Section 65 of the Basic Conditions of Employment Act to enter workplaces where domestic workers are employed, as well as private farms and homes employing one or more workers.(19) However, SADOL lacks a central unit to administer training programs for labor inspectors.(1) A source indicates more inspections are conducted in the formal sector than in the informal sector.(3) Although labor inspectors are legally authorized to inspect private farms, some encounter difficulty accessing farms due to concerns of safety or entering private property. As a result, children possibly working in agriculture on private farms may be left unprotected.(49)

Additionally, SADOL inspectors address labor rights concerns of foreign nationals and refer those cases to the Department of Home Affairs, which then transfers the cases to the South African Department of Social Development for social services. Inspectors also refer cases that may involve child labor to social workers who provide welfare needs, such as child protection and care.(1, 25, 50) The Government reported that the South African Police Service (SAPS) employed forensic social workers to collaborate with investigators and provide care to victims of the worst forms of child labor.(19) The Government funded an NGO-operated hotline that refers child labor complaints to government protection agencies or SAPS.(1) However, it is unknown how many complaints related to child labor were made to the Government-funded hotline, because the labor inspection data are not disaggregated by child labor violations.(49)

Criminal Law Enforcement

In 2016, criminal law enforcement agencies in South Africa took 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

Yes (25)

Yes (19)

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

Yes (25)

Yes (19)

Refresher Courses Provided

Unknown (25)

Yes (19)

Number of Investigations

Unknown* (25)

75 (19)

Number of Violations Found

Unknown* (25)

75 (19)

Number of Prosecutions Initiated

Unknown* (25)

0 (19)

Number of Convictions

Unknown* (25)

3 (19)

Reciprocal Referral Mechanism Exists Between Criminal Authorities and Social Services

Yes (25)

Yes (19)

* The Government does not publish this information.

In 2016, the Government joined the Global Action to Prevent and Address Trafficking in Persons and Smuggling of Migrants partnership with UNICEF, the IOM, and the EU, to coordinate efforts to identify and prosecute traffickers.(51) In July 2016, the South African Police Hawks rescued 16 girls from a human trafficking ring.(52)

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

Implementation Committee on Child Labor

Monitor and support advocacy and awareness-raising; mainstreaming of child labor into government policies; and the implementation of child labor programs, legislation, and enforcement.(1, 45) Chaired by SADOL, members include representatives from commercial agriculture, trade unions, and government agencies, including SAPS.(1) Includes provincial-level child labor coordinating structures.(7) In 2016, the Implementation Committee on Child Labor met on a quarterly basis. However, no reports were published about the progress to implement the National Child Labor Program of Action for South Africa.(49)

Child Labor Intersectoral Support Groups

Facilitate the prevention of all types of child labor, including children scavenging and child labor that occurs as a result of human trafficking. Established by SADOL and managed by child labor coordinators in each province, members include multiple government agencies, including the SADOL Head Office, SADOL Provincial Child Labor Coordinators, the Department of Justice, the National Prosecuting Authority, the Department of Home Affairs (DHA), the DSD, and the Department of Education; NGOs; and labor federations.(1, 29) In 2016, the groups met quarterly, participated in the child protection week, and assisted with the human trafficking awareness campaigns.(49)

Trafficking in Persons Task Team

Coordinate the Government’s anti-human trafficking efforts, including overseeing strategy and policy decisions made at the provincial level in Gauteng, Mpumalanga, KwaZulu-Natal, Western Cape, Limpopo, and Eastern Cape. Led by the National Prosecution Authority’s Sexual Offenses and Community Affairs Unit and South Africa Department of Justice’s Victim Support Directorate; members include SADOL, the DSD, and the DHA, as well as other representatives of national law enforcement.(1, 8) Research was unable to find information about any coordination activities it conducted during the year.(49)

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

Table 9. Key Policies Related to Child Labor

Policy

Description

National Child Labor Program of Action for South Africa, Phase III (2013–2017)

Serves as the primary policy instrument to prevent and eliminate child labor in South Africa.(26, 53) Promotes government activities and calls for the promotion of new laws against the worst forms of child labor.(1, 53) Also includes a list of indicators to monitor the Government’s efforts against child labor.(53) During the year, government agencies raised awareness about child labor through radio stations, participated in Child Protection Week, and commemorated the National Day Against Child Labor.(49)

The Government has not included child labor elimination and prevention strategies into the South African Education Action Plan or the National Development Plan.(54, 55)

In 2016, the Government 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 Support Grant (CSG)†

Government program, led by the DSD and the South African Social Security Agency, which provides monthly direct cash transfers to primary caregivers who have vulnerable children.(1, 29, 56-58) Helps alleviate economic pressures and lower the cost of raising a child.(1, 57-59) Sources have indicated that as a result of the CSG, recipients may be less likely to send their children away for child labor and children are more likely to have positive educational outcomes.(1, 29, 46) The CSG budget was increased from $3.2 billion to $3.5 billion and benefited 12 million children.(19)

Care Dependency Grants and Foster Care Grants†

Government program that encourages children to remain in school, as a preventive technique to combat child labor, including its worst forms.(1) To date, about 131,040 children received a care dependency grant.(49)

National School Nutrition Program†

Government program funded through a conditional grant that provides school meals to vulnerable children. Targets primary and secondary students.(27, 29, 60) The Government uses tax revenue and continues to provide meals for vulnerable children.(61) During the year, the Government allocated $428,181 to the program.(49)

Food Relief Program†

Food relief program of the DSD and the South African Social Security Agency to assist vulnerable and orphaned children, as well as child-headed households with insufficient income.(25, 26) The program was expanded during the year and funded 140 community nutrition development centers that provided food to half a million people.(49)

Shelters and Care Centers†

DSD program that funds 13 shelters and oversees 17 NGO-operated temporary safe care centers for victims of abuse and human trafficking, including children.(8)

Awareness-raising Campaigns†

Government program that conducts training on anti-human trafficking initiatives and regulations governing social service providers.(8) DSD trainers reached 114 DSD provincial officials, 2 officials from the Commission for Gender Equality, and 35 NGO social service providers. As a result of the campaigns, suspected cases of the worst forms of child labor were identified and investigated.(49)

† Program is funded by the Government of South Africa.

The Government had other social programs that may have included the goal of eliminating or preventing child labor, including its worst forms.(19) Although South Africa has programs that target child labor, and data collected by the South African government indicates the number of children involved in child labor is decreasing, the scope of these programs remains insufficient, including in agriculture and domestic work.

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

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

Area

Suggested Action

Year(s) Suggested

Legal Framework

Ensure that the law criminally prohibits the recruitment of children under 18 by non-state armed groups.

2016

Enforcement

Publish information about the number of labor inspections conducted by worksite visits and desk reviews.

2015 – 2016

Ensure that inspections are carried out in the formal and informal sectors, including on private farms.

2016

Authorize the labor inspectorate to assess penalties.

2015 – 2016

Disaggregate the number of complaints received by the hotline to determine the number of suspected child labor violations reported across the country.

2013 – 2016

Government Policies

Integrate child labor elimination and prevention strategies into existing youth policies.

2013 – 2016

Social Programs

Conduct research and collect comprehensive data on child labor, including its worst forms, to inform policies and programs.

2013 – 2016

Ensure that children with disabilities have equal access to education.

2016

Ensure that children can complete primary school by subsidizing or defraying the cost of books, uniforms, and other fees.

2009 – 2016

Institute programs to address the worst forms of child labor in agriculture and domestic work.

2010 – 2016

1.         U.S. Consulate- Johannesburg. reporting, February 7, 2014.

2.         U.S. Department of State. "South Africa," in Trafficking in Persons Report- 2015. Washington, DC; July 27, 2015; http://www.state.gov/documents/organization/243561.pdf.

3.         U.S. Department of State. "South Africa," in Country Reports on Human Rights Practices- 2015. Washington, DC; April 13, 2016; http://www.state.gov/g/drl/rls/hrrpt.

4.         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.

5.         UCW. Analysis of Child Economic Activity and School Attendance Statistics from National Household or Child Labor Surveys. 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.

6.         U.S. Department of State. "South Africa," in Country Reports on Human Rights Practices- 2014. Washington, DC; June 25, 2015; http://www.state.gov/documents/organization/236618.pdf.

7.         U.S. Consulate- Johannesburg. reporting, January 31, 2013.

8.         U.S. Embassy- Pretoria. reporting, February 21, 2014.

9.         U.S. Consulate- Johannesburg official. E-mail communication to USDOL official. April 13, 2015.

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11.       Koyana, X. "EC Farmer Handed 15-Year Sentence for Child Prostitution." ewn.co.za [online] May 8, 2015 [cited November 18. 2015]; http://ewn.co.za/2015/05/08/EC-farmer-handed-15-year-jail-sentence-for-child-prostitution.

12.       The Voice of the Cape. "Human trafficking difficult to monitor: Anex." vocfm.co.za [online] July 24, 2015 [cited November 18, 2015]; http://www.vocfm.co.za/human-trafficking-difficult-to-monitor-anex/.

13.       U.S. Department of State. "South Africa," in Trafficking in Persons Report- 2016. Washington, DC; June 30, 2016; http://www.state.gov/j/tip/rls/tiprpt/index.htm.

14.       Graham, S. "Dozens of Children Packed 'Like Goats' in Traffickers' Lorry." The Times, London, July 28, 2016. [source on file].

15.       Mahopo, Z. "Human Traffickers Thriving in Limpopo." Sowetan, South Africa, October 4, 2016. [source on file].

16.       Etheridge, J. "SA human trafficking caseload on the rise - campaign." news24.com [online] July 6, 2015 [cited November 18, 2015]; http://www.news24.com/SouthAfrica/News/SA-human-trafficking-caseload-on-the-rise-campaign-20150706.

17.       Savides, M. "Farms and informal sector exploit thousands of kids." Sunday Times, Johanesburg, March 29, 2015. [source on file].

18.       Gaura, D. "World Day Against Child Labour: South Africa's forgotten children." [online] June 9, 2011 [cited November 11, 2016]; http://www.genderlinks.org.za/article/world-day-against-child-labour-south-africas-forgotten-children-2011-06-09.

19.       U.S. Consulate- Johannesburg. reporting, January 24, 2017.

20.       Department of Home Affairs. Annual Performance Plan to Increase Birth Registration of Children. Pretoria; 2016. http://www.dha.gov.za/files/KPIS_2016_2017/SOs_KPI_sheets%202016/Enabling_doc_birth_smartID.pdf.

21.       UNICEF Data. South Africa; accessed November 7, 2016; https://data.unicef.org/country/zaf/.

22.       Government of South Africa. South African Schools Act, No. 84 of 1996, enacted November 15, 1996. http://www.acts.co.za/south-african-schools-act-1996/index.html.

23.       Minister of Labor, Republic of South Africa. Speech at the Child Labour Conference: The Hague; May 11, 2010.

24.       Minister of Social Development, Republic of South Africa. Speech by the Minister of Social Development, Ms. Bathabile Dlamini, at the Launch of the Food for All Campaign, Makgori Village- North West. Pretoria, Department of Social Development; December 22, 2011. http://www.dsd.gov.za/index.php?option=com_content&task=view&id=373&Itemid=106.

25.       U.S. Consulate- Johannesburg. reporting, January 20, 2016.

26.       U.S. Consulate- Johannesburg. reporting, January 16, 2015.

27.       Department of Education. Pocket Guide to South Africa 2010/2011 Education. Pretoria; 2011.

28.       Government of South Africa. Child Labour: Programme of Action for South Africa: Phase 2: 2008-2012. Pretoria, Department of Labour; 2007.

29.       U.S. Consulate- Johannesburg official. E-mail communication to USDOL official. May 13, 2014.

30.       UN. United Nations Convention on the Rights of Persons with Disabilities A/RES/61/106, enacted December 13, 2006. http://www.un.org/disabilities/documents/convention/convoptprot-e.pdf.

31.       Human Rights Watch. "South Africa," in World Report; 2016; https://www.hrw.org/world-report/2016/country-chapters/south-africa.

32.       U.S. Department of State. "South Africa," in Country Reports on Human Rights Practices- 2016. Washington, DC; March 20, 2017; https://www.state.gov/documents/organization/265514.pdf.

33.       Section27. Too Many Children Left Behind: Exclusion in the South African Inclusive Education System With a focus on the Umkhanyakude District, KwaZulu-Na. Report; 2016. http://section27.org.za/wp-content/uploads/2016/08/Umkhanyakude-Report-Final-08082016-1.pdf.

34.       BBC. "South Africa disabled children excluded from school " bbc.com [online] August 18, 2015 [cited March 21, 2017]; http://www.bbc.com/news/world-africa-33972359.

35.       Shikwambane, N. "South Africa: The Education System Is Leaving Children With Disabilities Behind." August 24, 2016. http://allafrica.com/stories/201608241101.html.

36.       Mathshediso, M. "Changing the game for special needs education." sanews.gov.za [online] November 23, 2015 [cited March 21, 2017]; http://www.sanews.gov.za/south-africa/changing-game-special-needs-education.

37.       Human Rights Watch. "South Africa: Crisis for Children with Disabilities Parliament Should Act Urgently to Mandate Inclusive Education." [online] March 14, 2016 [cited March 21, 2017]; https://www.hrw.org/news/2016/03/14/south-africa-crisis-children-disabilities.

38.       Government of South Africa. Basic Conditions of Employment Act, No. 75 of 1997, enacted December 5, 1997. www.justice.gov.za/labourcourt/docs/1997-075.pdf.

39.       Department of Labour. Regulations on Hazardous Work By Children. Pretoria; n.d. https://www.labour.gov.za/downloads/documents/useful-documents/basic-conditions-of-employment/childlabourooklet2012.pdf.

40.       Government of South Africa. Basic Conditions of Employment Act (75 of 1997): Regulations on Hazardous Work by Children in South Africa, No. 32862, enacted January 15, 2010. http://www.polity.org.za/article/basic-conditions-of-employment-act-751997-regulations-on-hazardous-work-by-children-in-south-africa-gazette-no-32862-regulation-7-2010-01-28.

41.       Government of South Africa. The Children's Amendment Act of 2007, enacted March 2008.

42.       Government of South Africa. Constitution, enacted 1996. http://www.justice.gov.za/legislation/constitution/constitution.htm.

43.       ILO Committee of Experts. Individual Direct Request concerning Worst Forms of Child Labour Convention, 1999 (No. 182) South Africa (ratification: 2000) Submitted: 2010; accessed October 26, 2012; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:2309446.

44.       Government of South Africa. Defense Act 42 of 2002, No. 42, enacted February 2003. http://bit.ly/zF64Vj

45.       U.S. Consulate- Johannesburg official. E-mail communication to USDOL official. May 31, 2013.

46.       U.S. Department of State. "South Africa," in Country Reports on Human Rights Practices- 2013. Washington, DC; February 27, 2014; http://www.state.gov/j/drl/rls/hrrpt/.

47.       LABADMIN. South Africa, ILO, [online] [cited November 17, 2015]; http://www.ilo.org/labadmin/info/WCMS_150917/lang--en/index.htm.

48.       LABADMIN. Labour Inspection Country Profile: South Africa, ILO, [online] December 31, 2010 [cited November 2, 2014]; http://www.ilo.org/labadmin/info/WCMS_150917/lang--en/index.htm.

49.       U.S. Consulate- Johannesburg official. E-mail communicaiton to USDOL official. April 7, 2017.

50.       Hweshe, F. "Government beefs up social work studies." Vuk'uzenzele, Pretoria, January 26, 2011; Regulars. http://www.info.gov.za/vukuzenzele/2011/number40/regulars_1111social_studies.htm.

51.       UNODC. South Africa joins UNODC global initiative on human trafficking and migrant smuggling. Press Release; September 26, 2016. http://www.unodc.org/unodc/en/frontpage/2016/September/south-africa-joins-unodc-global-initiative-on-human-trafficking-and-migrant-smuggling.html.

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