Child Labour Policy for Manya Africa Tours

Purpose

Manya Africa Tours is committed to protecting children’s rights and ensuring that no child is employed, exploited or harmed as a result of our operations, supply chains, tours, or business relationships. This policy sets out our commitment, standards and procedures to prevent child labour and to respond appropriately if child labour is identified.

This policy applies to:

• All employees, contractors, subcontractors, suppliers, partners, tour guides and agents acting on behalf of Manya Africa Tours.
• All activities and locations where Manya Africa Tours operates or arranges services (office operations, tours, supplier facilities, community visits, promotional activities).
• All stages of the supply chain, including accommodations, transport providers, craft vendors, suppliers of goods and services, and partner organisations.

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Definitions
• Child: any person under the age of 18, unless local law sets a higher age for protection.
• Child labour: work that is mentally, physically, socially or morally harmful to children; interferes with schooling; or is hazardous as defined by the International Labour Organization (ILO) Convention No. 138 and No. 182 and by applicable national law.
• Light work: non-hazardous, short-duration activities compatible with schooling and permitted by local law.
• Hazardous work: work that exposes children to physical, psychological or sexual harm or deprives them of education.
Policy statement
Manya Africa Tours will not employ, contract with, or knowingly support the use of child labour. We prohibit: • The direct employment or engagement of children in any form of labour that is illegal, hazardous, or interferes with education.
• The use of accommodation, suppliers, attractions, contractors or partners that use child labour in violation of this policy.
• Tour activities that exploit children or create demand for child labour, including “orphanage tourism” or paying for interactions that encourage children to perform work. We will comply with applicable international standards (including ILO Conventions and the UN Convention on the Rights of the Child) and with all relevant national and local laws regarding minimum age and child protection.
Permitted activities
• Where permitted by law, children may engage in light work that is non-hazardous, does not affect school attendance, and is appropriate for their age. Such activities must be temporary, supervised, and consistent with local legal frameworks and international standards.
Recruitment and age verification
• We will implement age verification procedures for all new hires, contractors and where relevant for tour staff and partners. Acceptable documentation includes birth certificates, national IDs or other reliable documents. Where official documents are not available, we will use a combination of reliable alternative verification methods and local stakeholder engagement, while taking care to avoid harm and stigma.
• We will not hire persons who are under the minimum legal working age or who are subject to hazardous work restrictions.
Supply chain and partner due diligence
• Suppliers, partners and contractors must sign and comply with our Supplier Code of Conduct, which includes a prohibition on child labour.
• We will assess key suppliers and partners for child labour risks during selection and on an ongoing basis. High-risk suppliers will be subject to enhanced due diligence, audits and corrective action plans.
• We will include child labour provisions in contracts and reserve the right to terminate relationships where violations are not corrected promptly.
Tours, community visits and tourism activities
• Guides, staff and clients must not participate in activities that exploit children, including paying for or encouraging children to perform work, posing for staged photos in exchange for money, or visiting institutions where children are exploited for tourism.
• We will avoid and discourage visits to orphanages or institutions where children may be exploited. Where community and school visits are appropriate, they will be planned in partnership with reputable local organisations, respect children’s privacy and dignity, and be educational and non-intrusive.
• We will brief clients before tours on appropriate conduct around children, including photography consent, no gifts or money to children that may create harmful incentives, and guidance on reporting concerns.
Reporting, investigation and escalation
• Staff, partners, clients, suppliers and community members should report any suspected child labour or exploitation immediately.
• All reports will be treated seriously, confidentially and promptly investigated in a manner that prioritizes the safety, best interests and privacy of the child.
• We will cooperate with local authorities, child protection agencies and NGOs as required and permitted by law.
Remediation and support
• When child labour or exploitation is identified, our first priority is the safety and well-being of the child. Remediation steps may include:
• Immediate removal of the child from harmful conditions in cooperation with local child protection services;
• Provision of or referral to appropriate support services (medical, psychological, educational);
• Working with family, community and credible local organisations to identify safe alternatives, including access to education and livelihood support for families;
• A corrective action plan for the supplier/partner, monitored until verified remediation is complete.
• We will not terminate relationships in a way that increases harm to affected children; termination may be used where partners fail to implement remediation.
Training and awareness
• All staff, guides and key partners will receive child protection and child labour awareness training, including how to recognise signs of exploitation and the correct reporting procedures.
• Pre-departure information for clients will include guidance on appropriate interactions with children.
Monitoring, audits and continuous improvement
• We will conduct regular risk assessments of our operations and supply chains to identify child labour risks.
• High-risk areas will be prioritized for audits, monitoring visits and engagement with local stakeholders and NGOs.
• Findings will inform continuous improvement measures and will be integrated into procurement and partner selection processes.
Responsibilities
• Board/Management: Provide leadership, approve the policy and ensure allocation of resources for implementation.
• Designated Child Protection Officer: Oversee implementation, receive reports, coordinate investigations and liaise with authorities and NGOs.
• HR/Recruitment: Implement age verification, maintain records and ensure staff compliance.
• Procurement: Ensure suppliers and partners comply with the policy, include clauses in contracts and perform due diligence.
• All employees, contractors and partners: Comply with this policy, complete required training and report suspected violations.
Recordkeeping and confidentiality
• We will maintain records of age verification, due diligence, risk assessments, training, complaints and investigations in a secure and confidential manner, in line with applicable data protection laws.
• The identity of reporters will be protected to the fullest extent possible. Retaliation against anyone raising concerns in good faith is strictly prohibited.
Non-retaliation
• Manya Africa Tours prohibits retaliation of any kind against employees, partners or community members who report concerns in good faith or participate in investigations.
Review and updates
• This policy will be reviewed at least every two years or sooner if legal or operational changes require. Updates will be communicated to staff, partners and suppliers.
Contact and reporting
• Designated Child Protection Officer: Yvonne Hilgendorf
• Email: info@manyaafricatours.com
• Phone: +256 777 195894
• Anonymous reporting: +256 775 554 791
Approval
This Child Labour Policy was approved by the management of Manya Africa Tours on 22.08.2025, signed by Management

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