Findings on the Worst Forms of Child Labor - Turkey

Child Labor and Forced Labor Reports

Turkey

2016 Findings on the Worst Forms of Child Labor:

Moderate Advancement

In 2016, Turkey made a moderate advancement in efforts to eliminate the worst forms of child labor. In cooperation with the ILO and other partners, the Government continued to implement a project that provided services to more than 1,000 children working in commercial hazelnut production. It adopted a regulation to improve provision of education and other services to children of mobile seasonal agricultural workers. In addition, security forces established and provided training for 33 new units that will focus on crimes against women and children, including child trafficking. However, children in Turkey perform dangerous tasks in mobile seasonal work in agriculture and in street work. The Government does not have laws that protect children working in agricultural enterprises employing fewer than 50 workers. The Government made important progress in expanding access to education and other services for several hundred thousand Syrian refugee children, although increased economic hardship and limited work opportunities for adult refugees in urban areas left children at increased risk of exploitation in the worst forms of child labor.

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Children in Turkey perform dangerous tasks in mobile seasonal agriculture and in street work.(1-24) Table 1 provides key indicators on children’s work and education in Turkey.

Table 1. Statistics on Children’s Work and Education

Children

Age

Percent

Working (% and population)

6 to 14

2.6 (320,254)

Working children by sector

 

 

Agriculture

 

57.1

Industry

 

15.8

Services

 

27.1

Attending School (%)

6 to 14

92.4

Combining Work and School (%)

6 to 14

1.6

Primary Completion Rate (%)

 

99.8

Source for primary completion rate: Data from 2012, published by UNESCO Institute for Statistics, 2015.(25)
Source for all other data: Understanding Children’s Work Project’s analysis of statistics from Child Labor Survey, 2006.(26)

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 cotton, hazelnuts, citrus fruits, sugar beets, cumin, peanuts, pulses, apricots, melons, and cherries (1-19)

Industry

Production of furniture, bricks, shoes, leather goods, and textiles (9, 11, 16, 18, 20-22, 27-35)

Auto repair† (9, 11, 27)

Mining† (10, 36)

Services

Street work, including vending small items, carrying bundles in market areas, cleaning car windshields, collecting recyclable materials, and begging (9-11, 16, 18, 20-24, 27, 37, 38)

Working in restaurants and small shops (20, 33)

Categorical Worst Forms of Child Labor‡

Commercial sexual exploitation, sometimes as a result of human trafficking (27, 39-41)

Forced recruitment of children by non-state armed groups for use in armed conflict (18)

† 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.

Due to the seasonal nature of agricultural work throughout the country, children engaged in agricultural work often migrate with their families for up to seven months of the year. Significant numbers of these children have limited access to health care and education as a result of migration.(4, 7, 8, 12, 19, 27, 28)

Government and media reports indicated that the recruitment and use of children under age 18 by the Kurdistan Workers’ Party (PKK), a U.S.-designated terrorist organization, continued in 2016.(18) The current number of child soldiers in the PKK and other Kurdish militant groups remains unclear.

Credible academic, media, and other reports continued to suggest growing numbers of child laborers within the increasing Syrian refugee population during the reporting period. There were over 3 million refugees living in Turkey at the end of 2016.(18) Poverty and a lack of meaningful employment opportunities for many adults leave refugee children extremely vulnerable to exploitation in the worst forms of child labor.(19, 37, 38, 42-44) Syrian refugee children engaged in street begging, as well as manufacturing work such as the production of shoes, furniture, and textiles, often working long hours and earning wages as little as half of what an employer would pay an adult.(10, 11, 22, 29, 32-35) Syrian refugee and other children were also vulnerable to exploitation in the agriculture sector, where Syrian families tended to receive lower pay and live in worse conditions than Turkish workers.(12, 18, 19) Monitoring and collecting data on child labor in refugee communities remained a challenge.(10)

The Government continued to expand education for refugee children, reducing the number of Syrian refugee children not enrolled in school from an estimated 650,000 in 2015 to fewer than 345,000 in 2016.(11, 33, 45, 46) However, the barriers to education access for hundreds of thousands of Syrian refugee children who live in urban areas remain significant. Some schools for Syrian children charge informal tuition or other fees that many families are unable to afford.(11, 20, 33) Many Syrian children struggle to integrate into Turkish schools due to the language barrier and do not have access to accelerated Turkish language programs.(11) Many families have not received sufficient information on how to enroll their children in Turkish schools, and some schools refuse entry to Syrian children, despite national directives requiring that Syrian children be provided with education.(11)

Turkey 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 Turkey’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

No

15

Article 71 of the Labor Law (47)

Minimum Age for Hazardous Work

Yes

18

Articles 71–73 of the Labor Law; Annex 3 of the Regulation on Methods and Principles for Employment of Children and Young Workers (47, 48)

Identification of Hazardous Occupations or Activities Prohibited for Children

Yes

 

The Regulation on the Principles and Procedures Governing the Employment of Children and Young Workers (48)

Prohibition of Forced Labor

Yes

 

Articles 80 and 117 of the Penal Code (49)

Prohibition of Child Trafficking

Yes

 

Article 80 of the Penal Code (49)

Prohibition of Commercial Sexual Exploitation of Children

Yes

 

Articles 77, 103, 226, and 227 of the Penal Code (49)

Prohibition of Using Children in Illicit Activities

Yes

 

Articles 37–38 and 188 of the Penal Code (49)

Minimum Age for Military Recruitment

 

 

 

State Compulsory

Yes

21

Article 2 of the Law on Military Service (50)

 

State Voluntary

NA*

 

 

 

Non-state Compulsory

No

 

 

 

Minimum Age for Voluntary Military Service

 

 

 

Compulsory Education Age

Yes

17‡

Article 3 of the Primary Education Law; Education Reform Law (51, 52)

Free Public Education

Yes

 

Article 2 of the Primary Education Law; Article 42 of the Constitution of the Republic of Turkey (52, 53)

           

* No voluntary military service (54)
‡ Age calculated based on available information

In March 2016, the Ministry of National Education issued a regulation developed in consultation with the ILO that sets forth a process for closer monitoring of the children of mobile seasonal agricultural workers. Among other things, the regulation established monitoring boards in areas that are both sources of and destinations for seasonal workers.(18) Boards are tasked with providing direct services to children, monitoring school enrollment and attendance, and raising awareness among families. The government reported starting construction on 64 schools in 13 provinces to improve education access for the children of seasonal workers.(18)

Turkey’s Labor Law excludes from coverage agricultural enterprises employing fewer than 50 workers, which are workplaces likely to employ children.(47) This gap in the law leaves children and other workers vulnerable to exploitative conditions without legal protection.(17, 27)

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

Labor Inspection Board Presidency within the Ministry of Labor and Social Security (MOLSS)

Implement laws on child labor and hazardous child labor, including regulating work environments and conditions for children. Monitor the implementation of the Labor Law provisions in workplaces under its jurisdiction.(10) Conduct joint inspections with the Mentoring and Inspection Presidency to find children under legal working age who have dropped out of school, and direct them back into education.(10) Receive complaints about labor law violations, including child labor, via a hotline.(10)

Mentoring and Inspection Presidency Within MOLSS

Monitor compliance with laws related to social security of all workers, including child workers. Conduct joint inspections with the Labor Inspection Board Presidency to find children under legal working age who have dropped out of school and refer them to education services.(10)

Turkish National Police and Gendarmerie General Command (Jandarma)

Enforce the Penal Code, including criminal laws related to the worst forms of child labor.(10, 55) The Gendarmerie General Command (Jandarma) enforces laws in rural areas that are outside of the jurisdiction of National Police.(18, 55)

Department for Protection of Victims of Human Trafficking within the Directorate General for Migration Management

Coordinate the identification of human trafficking victims, including victims of child trafficking.(41) Manage a hotline providing 24-hour, toll-free support in multiple languages for human trafficking victims.(43)

Ministry of Justice

Prosecute cases of child labor and child exploitation.(10)

Ministry of Family and Social Policy (MFSP)

Coordinate and provide services to children living or working on the street through the Directorate General of Child Services. Operate a hotline to receive complaints about child rights violations, including child labor.(10)

Labor Law Enforcement

In 2016, labor law enforcement agencies in Turkey 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

Unknown* (10)

Unknown*(18)

Number of Labor Inspectors

977 (10)

1002 (18)

Inspectorate Authorized to Assess Penalties

Yes (10)

Yes (18)

Training for Labor Inspectors

 

 

Initial Training for New Employees

Yes (10)

Yes (18)

Training on New Laws Related to Child Labor

Unknown

Yes (18)

Refresher Courses Provided

No (10)

Yes (18)

Number of Labor Inspections

19,255 (10)

21,329† (18)

Number Conducted at Worksite

19,255 (10)

21,329† (18)

Number Conducted by Desk Reviews

0 (10)

0 (18)

Number of Child Labor Violations Found

Unknown

Unknown* (18)

Number of Child Labor Violations for Which Penalties Were Imposed

27 (10)

71 (18)

Number of Penalties Imposed That Were Collected

Unknown* (10)

Unknown* (18)

Routine Inspections Conducted

Yes (10)

Yes (18)

Routine Inspections Targeted

Yes (10)

Yes (18)

Unannounced Inspections Permitted

Yes (10)

Yes (18)

Unannounced Inspections Conducted

Yes (10)

Yes (18)

Complaint Mechanism Exists

Yes (10)

Yes (18)

Reciprocal Referral Mechanism Exists Between Labor Authorities and Social Services

Yes (10)

Yes (18)

* The Government does not publish this information.
† Data are from January 1, 2016, to November 30, 2016.

In 2016, the number of labor inspectors authorized to conduct inspections remained insufficient for the size of Turkey’s workforce, which includes over 30 million workers. According to the ILO recommendation of 1 labor inspector for every 15,000 workers in industrializing economies, Turkey should employ approximately 1,960 labor inspectors.(56-58) Labor inspectors spend the first 3 years of their careers as assistant inspectors. They receive on-the-job training that includes modules to raise their awareness of child labor and of the legal provisions and enforcement mechanisms to address it.(54)

In 2016, employers who violated prohibitions were subject to administrative fines of approximately $430. Fine amounts are adjusted annually, but generally they are insufficient to deter violations.(18)

Although there is no formal referral mechanism, research found that children discovered to be working illegally during the course of inspections were referred for social services.(10, 54)

Criminal Law Enforcement

In 2016, criminal law enforcement agencies in Turkey 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

Unknown

Unknown

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

Unknown

Unknown

Refresher Courses Provided

Yes (41)

Unknown

Number of Investigations

Unknown

Unknown

Number of Violations Found

Unknown

Unknown

Number of Prosecutions Initiated

Unknown

Unknown

Number of Convictions

Unknown

Unknown

Reciprocal Referral Mechanism Exists Between Criminal Authorities and Social Services

Yes (41)

Yes (18)

Enforcement of laws against child trafficking, particularly pertaining to identification of victims, was insufficient, although the Government continued to improve its victim-identification efforts.(38, 59) The Government reported a 68 percent increase in victims identified during the reporting period, compared to the previous year.(60)

In 2016, the Gendarmerie General Command (Jandarma) established, staffed, and provided two weeks of training for 33 specialized units on crimes against women and children, including child trafficking. By 2019, the Government plans to establish and staff one specialized Jandarma unit in every province.(18) During the reporting period, the Turkish National Police also created a new unit responsible for trafficking in persons.(60)

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

Child Labor Branch of the Employment Policies Directorate Within MOLSS

Coordinate all child labor programs and efforts of the Ministry of Education, the Child Services Directorate General in MFSP, the Ministry of the Interior, the Ministry of Justice, and NGOs.(10)

The Child Services Directorate General Within MFSP

Coordinate services for children living and working on the streets.(10)

Directorate General for Migration Management (DGMM)

Coordinate the implementation of migration law, including laws related to irregular migration, refugees, and human trafficking.(61, 62)

National Task Force on Combating Human Trafficking

Coordinate policy on human trafficking. Chaired by the DGMM, which plans to transition the task force to a national commission under the Ministry of Interior.(38, 41)

 

The National Steering Committee and Advisory Board on Child Labor were disbanded following the expiration of the Time-Bound National Policy and Program Framework for the Prevention of Child Labor in 2015. Research found that the Government intends to establish a new coordination mechanism in 2017 in concert with the finalization of the new National Program to Combat Child Labor.(18)

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 Rights Strategic Document and Action Plan (2013–2017)

Sets out the framework and actions for promoting services for children in fields such as health care and education.(63) Includes a section addressing child labor issues.(44, 54)

Second National Action Plan on Combating Human Trafficking

Outlines Turkey’s strategy for the prevention of human trafficking. Identifies children as an exceptionally vulnerable group and calls for special security precautions for children at shelters for victims, as well as increased international cooperation on preventing child trafficking.(43, 64)

National Employment Strategy (2014–2023)

Aims to identify and solve labor market issues, with the goal of job creation and sustained economic growth. Includes the prevention of child labor, especially hazardous work in agriculture, as a focus of the plan, and advocates for increased access to education and strengthened social services as a means of preventing child labor.(65)

Tenth Development Plan (2014–2018)

Identifies Turkey’s strategy and goals for economic development. Includes the priorities of alleviating child poverty and increasing equal opportunity in education.(66) Includes provisions for the prevention of the worst forms of child labor.(54)

 

The Government’s primary child labor policy, the Time-Bound National Policy and Program Framework for the Prevention of Child Labor, expired in 2015. The MOLSS continued developing a replacement policy—the National Program to Combat Child Labor—during the reporting period, in consultation with the ILO and other stakeholders.(18) Although this new policy had not been finalized at the end of the reporting period, the Government indicated that it would prioritize addressing street work, work in small- and medium-sized enterprises, and seasonal migratory agriculture.(18)

In 2015, the Government of Turkey 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

Improving Social Integration and Employability of Disadvantaged Persons†

$34 million project jointly funded by the EU and the Government of Turkey. Aims to promote an inclusive labor market with opportunities for disadvantaged persons, with a view to their sustainable integration into the labor force.(67, 68) Also aims to combat all forms of discrimination in the labor market through service and grant components, including allocation of specific grant funds for projects targeting the Roma population.(18, 54, 67, 68) Includes the goal of combating child labor by supporting the entry of working children’s parents into the labor market.(67, 68)

Piloting the USDA Guidelines in the Hazelnut Supply Chain in Turkey

$4.87 million USDOL-funded, 31-month project implemented by the Fair Labor Association, in partnership with Nestle and two of its main hazelnut suppliers, Olam-Progida and Balsu, in Turkey. Aims to pilot a sustainable program to implement the U.S. Department of Agriculture’s Guidelines for Eliminating Child and Forced Labor in Agricultural Supply Chains in 1,000 hazelnut gardens in Duzce, Ordu, and Sakarya, with additional interventions implemented in the environs of Sanliurfa, the source of most seasonal migrant labor in Turkey.(69) In 2016, the project reached 107 families of seasonal agricultural workers and 284 children, 115 of whom were determined to be at risk and received social services.(18) The project engaged with 60 labor contractors, 97 local government representatives and community members, and 101 field owners to raise awareness about child labor.(69) The project also undertook company institutional surveys and worker demographic profiling to inform internal monitoring tools and procedures, as well as harvest remediation activities.(70)

Integrated Model for the Elimination of the Worst Forms of Child Labor in Seasonal Agriculture in Hazelnut Harvesting (2012–2017)

ILO- and MOLSS-implemented project funded by the Association of Chocolate, Biscuit, and Confectionery Industries of Europe (CAOBIISCO). Takes an integrated approach to preventing children from working by increasing access to education and improving living conditions of children vulnerable to the worst forms of child labor in hazelnut harvesting, building capacity of local and national institutions to prevent child labor, and raising awareness among industry stakeholders and the public.(10) In 2016, the project reached 1,200 children, 1,015 of whom were removed from work or placed in school.(18)

Global Action Program on Child Labor Issues Project

USDOL-funded project implemented by the ILO in approximately 40 countries. Aims to improve the evidence base on child labor through data collection and research in Turkey.(71) Additional information is available on the USDOL Web site.

Conditional Education and Health Care Assistance Program†

Government program that aims to reduce poverty through cash transfers.(72) Also provides milk to all primary school children and distributes books free of charge.(73)

Programs for Syrian Refugee Children

The Government has partnered with various international organizations and foreign governments to fund schools for Syrian refugee children and to provide Syrian refugee child laborers with additional educational and social services.(18)

Programs focused on Human Trafficking†

The EU funded two separate projects, both co-managed by the DGMM, to improve trafficking victim identification and protection through training and capacity-building.(41) The Government also funds shelters for human trafficking victims that provide social services and legal help to victims.(43, 54)

† Program is funded by the Government of Turkey.

Although programs exist to address child labor in the hazelnut sector, the Government generally lacks programs to address child labor in the other areas in which it was most prevalent, including other forms of mobile seasonal agriculture outside of the hazelnut sector, as well as in street work, and small and medium manufacturing enterprises.

Based on the reporting above, suggested actions are identified that would advance the elimination of child labor, including its worst forms, in Turkey (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 provides protections for children working in small agricultural enterprises.

2009 – 2016

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

2015 – 2016

Enforcement

Publish information on the Labor Inspectorate's funding and on the number of violations found and penalties collected.

2015 – 2016

Increase the number of labor inspectors responsible for enforcing laws related to child labor in order to provide adequate coverage of the workforce.

2014 – 2016

Increase the penalties for violation of child labor laws to an amount sufficient to deter violations.

2014 – 2016

Publish disaggregated data on the number of investigations, violations, prosecutions, and convictions related to child trafficking.

2014 – 2016

Ensure that laws prohibiting the trafficking of children are effectively enforced, including by taking sufficient steps to identify victims of child trafficking.

2015 – 2016

Policies

Adopt and implement the successor to the Time-Bound National Policy and Program Framework for the Prevention of Child Labor to address all relevant worst forms of child labor, such as street work, hazardous work in small- and medium-sized enterprises, and seasonal migratory agriculture.

2016

Social Programs

Continue to institute programs to increase access to education and health care for children working in mobile seasonal agriculture, particularly outside the hazelnut sector.

2014 – 2016

Continue to expand the provision of affordable education to Syrian refugee children, including by enforcing national directives affording Syrian children access to the Turkish school system at the local level.

2014 – 2016

Continue to expand programs to address child labor in the sectors in which it is most prevalent, including mobile seasonal agriculture, street work, and small and medium manufacturing enterprises.

2015 – 2016

1.         Development Workshop. Model Action Plan for Children Working in the Harvesting of Hazelnuts in Turkey. Cankaya; June 2012. http://www.kalkinmaatolyesi.org/foto/file/Model%20Action%20Plan%20for%20Children%20Working%20in%20the%20Harvesting%20of%20Hazelnuts%20in%20Turkey.pdf.

2.         ICF Macro. Summary Report In-Country Research on Child Labor and/or Forced Labor in Turkey Researcher's Feedback on the Data Collection Efforts and Summary Report per Good. Summary Report. Calverton, MD; 2012.

3.         Development Workshop. Model Action Plan for Children Working in Sugarbeet Cultivation in Turkey. Cankaya; August 2012. www.kalkinmaatolyesi.org.

4.         Development Workshop. Baseline Study Concerning Children of the 6-14 Age Group Affected by Seasonal Agricultural Migration. Cankaya; July 2012. http://www.kalkinmaatolyesi.org/arsiv.php?page=haber&doc=71.

5.         Development Workshop. Model Action Plan for Children Working in Seasonal Agricultural Labour in the Cukurova Region of Turkey. Cankaya; July 2012. http://www.hatay.gov.tr/uploads/icerik%20dosyalar/KalkinmaAtolyesi/pdf/ENG/CUKUROVA%20ACTION%20PLAN.pdf.

6.         ICF Macro. In-Country Research on Child Labor and/or Forced Labor Turkey Report on the Results of Observation of Children in Citrus Harvesting. Calverton, MD; March 8, 2012.

7.         Development Workshop. Seasonal Agricultural Work and Children Problem Analysis and Policy Recommendations. Cankaya; July 2012. www.kalkinmaatolyesi.org.

8.         Fair Labor Association. Assessment of the Hazelnut Supply Chain and Hazelnut Harvest in Turkey. Assessment Report; March 2012. http://www.fairlabor.org/sites/default/files/documents/reports/nestle_hazelnut_report.pdf.

9.         U.S. Department of State. "Turkey," in Country Reports on Human Rights Practices- 2013. Washington, DC; February 27, 2014; http://www.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm?year=2013&dlid=220341#wrapper.

10.       U.S. Embassy- Ankara. reporting, January 22, 2016.

11.       Human Rights Watch. When I Picture My Future, I See Nothing. New York; November 2015. https://www.hrw.org/report/2015/11/08/when-i-picture-my-future-i-see-nothing/barriers-education-syrian-refugee-children.

12.       Support to Life. Seasonal Agricultural Work in Turkey, Survey Report 2014. Istanbul; 2014. http://www.hayatadestek.org/media/files/mevsimlik_gezici_i%C5%9F%C3%A7i_rapor_ing2_revize.pdf.

13.       Support to Life. Frequently Asked Questions About Seasonal Agricultural Child Labor in Turkey, Hayata Destek, [online] 2014 [cited July 9, 2015]; http://buiscocukoyuncagidegil.com/.

14.       Today's Zaman. "42 Turkish child workers killed in first nine months of 2014." todayszaman.com [online] November 20, 2014 [cited August 3, 2015]; http://www.todayszaman.com/business_42turkishchildworkerskilledinfirstninemonthsof2014_364895.html.

15.       Fair Labor Association. Independent External Monitoring of the Nestle, Olam, and Balsu Hazelnut Supply Chain in Turkey: 2014-2015. Washington, DC; 2015. http://www.fairlabor.org/sites/default/files/documents/reports/may-2015-hazelnuts-executive-summary.pdf.

16.       International Trade Union Confederation. Internationally Recognized Core Labour Standards in Turkey, Report for the WTO General Council Review of the Trade Policies of Turkey (Geneva, 21 and 23 February, 2012) Trade Policy Review. Geneva; 2012. http://www.ituc-csi.org/IMG/pdf/tpr_turkey-final_.pdf.

17.       Soguel, D. "How Turkey is tackling child labor in hazelnut harvesting." csmonitor.com [online] September 7, 2015 [cited September 11, 2015]; http://www.csmonitor.com/World/MiddleEast/2015/0907/HowTurkeyistacklingchildlaborinhazelnutharvesting.

18.       U.S. Embassy- Ankara. reporting, January 18, 2017.

19.       Development Workshop. Fertile Lands Bitter Lives: Situation Analysis Report on Syrian Seasonal Agricultural Workers in the Adana Plain. Ankara; November 2016. http://www.kalkinmaatolyesi.org/v2/wp-content/uploads/2016/12/SAW-REPORT.pdf.

20.       Al-Hayat (Pan Arab). "Syrian children forced to work in Turkey." al-monitor.com [online] November 3, 2014 [cited November 12, 2015]; http://www.al-monitor.com/pulse/ar/culture/2014/11/syria-child-labor-turkey-schools-refugees.html.

21.       Onur Burcak Belli. "Syrian child workers 'left behind in life'." aljazeera.com [online] September 16, 2014 [cited November 25, 2015]; http://www.aljazeera.com/news/middleeast/2014/06/syrianchildworkersleftbehindlife20146228011456956.html.

22.       Save the Children, and UNICEF. Small Hands, Heavy Burden: How the Syria Conflict Is Driving More Children into the Workforce. New York; July 2, 2015. https://www.savethechildren.net/sites/default/files/SCIUnicefChildLabourReport_July2015.pdf.

23.       U.S. Department of State. "Turkey," in Trafficking in Persons Report- 2015. Washington, DC; July 27, 2015; http://www.state.gov/j/tip/rls/tiprpt/countries/2015/243553.htm.

24.       U.S. Department of State. "Turkey," in Country Reports on Human Rights Practices- 2014. Washington, DC; June 25, 2015; http://www.state.gov/documents/organization/236798.pdf.

25.       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.

26.       UCW. Analysis of Child Economic Activity and School Attendance Statistics from National Household or Child Labor Surveys. Original data from Child Labor Survey, 2006. 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.

27.       ILO Committee of Experts. Observation concerning Worst Forms of Child Labor Convention, 1999 (No. 182) Turkey (ratification: 2001) Published 2014; accessed March 14, 2014; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:::.

28.       Gulay Toksoz, Seyhan Erdogdu, and Selmin Kaska. Irregular Labour Migration in Turkey and Situation of Migrant Workers in the Labour Market. Geneva, IOM and Government of Sweden; October 2012. https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB8QFjAA&url=http%3A%2F%2Fwww.turkey.iom.int%2Fdocuments%2FLabour%2FIOM_irregular_labour_migration_eng_05062013.pdf&ei=PKueVaKJGoa7-AGOz52IBQ&usg=AFQjCNFoHanVFUsHeFBaF9-kDgmj6qw64A&sig2=HAvBSwg4s2OU_qUe5NkOgA.

29.       Didem Tali. "As refugees pour in, child labor booms in Turkey." aljazeera.com [online] January 4, 2016 [cited January 10, 2016]; http://america.aljazeera.com/articles/2016/1/4/as-refugees-pour-in-child-labor-booms-in-turkey.html.

30.       Sreenivasan Jain. Children of Kobane: Escaped from ISIS, Into 'Slavery', NDTV, [online] September 29, 2015 [cited February 22, 2016]; http://www.ndtv.com/world-news/children-of-kobane-escaped-from-isis-into-slavery-1224303.

31.       U.S. Embassy- Ankara. reporting, February 23, 2016.

32.       Williams, H. "Refugee children forced into labor in Turkey." cbsnews.com [online] September 22, 2015 [cited September 30, 2015]; http://www.cbsnews.com/news/refugeechildrenforcedintolaborinturkey/.

33.       Stockmans, P. "Syrian child labour, a ticket to Europe." middleeasteye.net [online] February 26, 2015 [cited August 3, 2015]; http://www.middleeasteye.net/indepth/features/syrianchildlabourticketeurope316420410.

34.       Associated Press. "AP PHOTOS: Refugee Children Labor in Turkish Factories." nytimes.com [online] June 10, 2016 [cited June 14, 2016]; http://www.nytimes.com/aponline/2016/06/10/world/europe/apeuturkeychildlaborphotogallery.html.

35.       BBC News. "Child Refugees in Turkey Making Clothes for UK Shops." bbc.com [online] October 24, 2016 [cited November 1, 2016]; http://www.bbc.com/news/business37716463.

36.       Hurriyet Daily News. "Thousands including child workers employed in unlicensed mines in southeastern Turkey." hurriyetdailynews.com [online] July 7, 2014 [cited August 14, 2015]; http://www.hurriyetdailynews.com/thousands-including-child-workers-employed-in-unlicensed-mines-in-southeastern-turkey.aspx?pageID=238&nID=68775&NewsCatID=347.

37.       Center for Middle Eastern Strategic Studies. Effects of the Syrian Refugees on Turkey; January 2015.

38.       U.S. Embassy- Ankara. reporting, February 23, 2015.

39.       United Nations Office of Drugs and Crime. "Turkey," in Global Report on Trafficking in Persons; December 2012; http://www.unodc.org/documents/data-and-analysis/glotip/Country_Profiles_Europe_Central_Asia.pdf.

40.       U.S. Department of State. "Turkey," in Trafficking in Persons Report- 2013. Washington, DC; June 19, 2013; http://www.state.gov/j/tip/rls/tiprpt/countries/2013/215642.htm.

41.       U.S. Embassy- Ankara. reporting, February 16, 2016.

42.       U.S. Embassy- Ankara. reporting, January 31, 2014.

43.       U.S. Embassy- Ankara. reporting, March 18, 2014.

44.       U.S. Embassy- Ankara official. E-mail communication to USDOL official. April 29, 2015.

45.       UNHCR. 3RP Regional Refugee & Resilience Plan 2017-2018 In Response to the Syria Crisis; 2016. https://data.unhcr.org/syrianrefugees/download.php?id=12492.

46.       U.S. Embassy- Ankara official. E-mail communication to USDOL official. June 6, 2017.

47.       Government of Turkey. Labor Act of Turkey, No. 4857, enacted May 22, 2003.

48.       Government of Turkey. Regulation on the Principles and Procedures Governing the Employment of Child and Young Workers, No. 25425, enacted April 6, 2004.

49.       Penal Code, Law No. 5327, enacted September 26, 2004. http://www.wipo.int/edocs/lexdocs/laws/en/tr/tr113en.pdf.

50.       Government of Turkey. Law on Military Service, No. 1111, enacted March 20, 1927. http://www.refworld.org/docid/3ae6b4d020.html.

51.       Government of Turkey. Education Reform Law, No. 6287, enacted March 30, 2012. http://www.tbmm.gov.tr/kanunlar/k6287.html.

52.       Government of Turkey. Primary Education Law, No. 222, enacted May 1, 1961. http://mevzuat.meb.gov.tr/html/24.html.

53.       Government of Turkey. Constitution of the Republic of Turkey, enacted 1982. http://global.tbmm.gov.tr/docs/constitution_en.pdf.

54.       U.S. Embassy- Ankara. reporting, January 14, 2015.

55.       Gendarmerie General Command. "Jandarma Definition, Liability and Duties." http://www.jandarma.gov.tr/ [online] [cited February 10, 2017]; http://www.jandarma.gov.tr/.

56.       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.

57.       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.

58.       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.

59.       ILO Committee of Experts. Direct Request concerning Worst Forms of Child Labor Convention, 1999 (No. 182) Turkey (ratification: 2001) Published 2014; accessed March 14, 2014; http://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:3172649.

60.       U.S. Embassy- Ankara. reporting, February 15, 2017.

61.       U.S. Embassy- Ankara. reporting, November 17, 2014.

62.       Kilberg, R. Turkey's Evolving Migration IdentityMigration Policy Institute; July 24, 2014. http://www.migrationpolicy.org/article/turkeys-evolving-migration-identity.

63.       European Commission. Turkey Progress Report. Brussels; September 8, 2014. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52014SC0307&from=en.

64.       Government of the Republic of Turkey. National Action Plan: Strengthening Institutions in the Fight Against Human Trafficking. Ankara; 2009.

65.       Government of Turkey. National Employment Strategy, enacted May 6, 2014. http://www.uis.gov.tr/Media/Books/UIS-en.pdf.

66.       Government of Turkey. Tenth Development Plan Brochure; 2014. http://www.mod.gov.tr/Lists/DevelopmentPlans/Attachments/4/Brochure%20of%20Tenth%20Development%20Plan%20%282014-2018%29.pdf.

67.       European Union and the Government of Republic of Turkey. Improving Social Integration and Employability of Disadvantaged Persons Grant Scheme; March 25, 2014. http://ihale.ikg.gov.tr/list.aspx?lang=en.

68.       U.S. Embassy- Ankara official. E-mail communication to USDOL official. June 6, 2014.

69.       ILO. Partnership to Reduce Child and Forced Labor in Imported Agricultural Products: Piloting the USDA Guidelines in Turkey’s Hazelnut Supply Chain. Technical Progress Report. Washington, DC; October 2016.

70.       ILO. Partnership to Reduce Child and Forced Labor in Imported Agricultural Products: Piloting the USDA Guidelines in Turkey’s Hazelnut Supply Chain. Technical Progress Report. Washington, DC; January 2017.

71.       ILO. Global Action Program on Child Labour Issues. Technical Progress Report. Geneva; October 28, 2016.

72.       U.S. Embassy- Ankara. reporting, February 14, 2012.

73.       U.S. Embassy- Ankara. reporting, February 5, 2013.

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