18/09/2026
Arden Child Sphere is your implementing partner for behavior change and child safeguarding — and today, that meant showing up in the room where national policy gets shaped.
We attended the Public Participation Forum on the Review of the National Policy on the Elimination of Child Labour (Sessional Paper No. 1 of 2015), held today at Ofafa Social Hall in Kisumu Town, convened by the Ministry of Labour and Social Protection alongside Kisumu County Government officials, ILO, the Federation of Kenya Employers, The Freedom Fund, ICS, AICS, NIA (Not Invisible Anymore), and CDTD among others
The forum was genuinely participatory — members of the public were given adequate time and space to raise their views on the draft policy, not just observe it being presented.
Ahead of the forum, we had already submitted a formal memorandum on the draft policy by email. A few of the gaps we flagged, from a frontline child safeguarding lens:
🔹 No clear line between "child work" and "child labour." The draft defines child work as a minor's "salutary employment within the family" with no stated minimum age, hours, or supervision threshold — leaving frontline officers, employers, and families to apply a subjective test instead of a consistent one.
🔹 Outdated data underpinning 2030 targets. Core prevalence figures cited go back to a 1999 survey, with no concrete timeline given for a new national child labour survey to establish a credible baseline.
🔹 No mandatory reporting duty or national hotline standard. A reporting mechanism appears only as a county-level function later in the document — we recommended it be elevated to a national policy statement, with counties required to link into one standard, not left to individual discretion.
🔹 No minimum care standards for rescue and rehabilitation centres. The draft references these centres but sets out no staff vetting, care standards, or independent inspection regime — a gap in exactly the settings where children are most vulnerable.
🔹 Data protection is unaddressed for sensitive case data. Nothing in the M&E framework speaks to consent or confidentiality standards for children's case data — trafficking and sexual exploitation survivors included.
Policy sets the direction. But without operational thresholds, referral pathways, and accountability at the child level — not just the system level — good intentions don't translate into protection on the ground. That gap between policy and practice is exactly where we work.
Thank you to the Ministry of Labour and Social Protection, Kisumu County Government, and all stakeholders present — ILO, the Federation of Kenya Employers, The Freedom Fund, ICS, AICS, NIA, and CDTD — for an inclusive, evidence-informed process.
Arden Child Sphere — Your Implementing Partner for Behavior Change & Child Safeguarding
📞 0700 262 719 | ✉️ [email protected]
