estimate the number to be closer to 7 million.1415 Children are reportedly payed significantly less than adults16, which may encourage the employment of children as cheaper labour. Despite the existence of labour inspectors exercising monitoring functions pursuant to the Labor Code and the International Labor Organization Convention, 1718 private companies have reportedly escaped governmental scrutiny, notably waste disposal services informally employed by municipal authorities. 19 In 2016 the Committee on the Rights of the Child raised serious concerns about “the large number of children employed under hazardous conditions, such as garbage collection, brick kilns and industrial workshops, without protective clothing and for very low pay”20 in spite of the existence of labour inspectors. A number of NGOs reported children working in poor and hazardous conditions in the Islamic Republic of Iran, notably in waste management and often employed by municipality contractors or city hall staff.21 The Iran Labor News Agency has reported that more than 120,000 children are hired to work at waste management facilities, including recycling centres which are, primarily, run by municipality contractors.22 Similar reports indicated that juveniles between the ages of 12 and 15 have been hired by companies contracted by the municipality of Tehran to collect recycling and garbage.23 The municipality of Tehran has denied any responsibility for hiring child labour in 2014.24 The fact that Iranian authorities appear to condone the employment of child workers may well limit accountability for perpetrators and redress and rehabilitation for victims. 25 In June 2020, the Iranian Guardian Council passed child protection legislation that, inter alia, requires social workers from the State Welfare Organization to promptly investigate children in situations of “extreme danger” from abuse, exploitation, or situations resulting in children not 14 Center for Human Rights in Iran, https://iranhumanrights.org/2019/07/fact-sheet-children-in-iran-are-unprotected-from-abuseand-severe-rights-violations/ 15 Radio Farda, https://en.radiofarda.com/a/rubbish-children-iran/28713558.html 16 CRC/C/IRN/CO/3-4, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=CRC%2fC%2fIRN%2fCO%2f34&Lang=en 17 CRC/C/IRN/CO/3-4, para. 87, https://undocs.org/en/CRC/C/IRN/CO/3-4 18 https://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=16940&LangID=E 19 Center for Human Rights in Iran, https://www.iranhumanrights.org/wp-content/uploads/Days-to-remember-low.pdf 20 CRC/C/IRN/CO/3-4, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=CRC%2fC%2fIRN%2fCO%2f34&Lang=en 21 Radio Farda, https://en.radiofarda.com/a/rubbish-children-iran/28713558.html 22 Radio Farda, https://en.radiofarda.com/a/rubbish-children-iran/28713558.html 23 Child Labor in Municipality Contractors, Islamic Republic News Agency Published on 20 November 2014 http:// www.irna.ir/fa/News/81394069/ 24 Head of Tehran Municipality inspection’s section: Municipality does not have a direct responsibility in death of Mr. Cheraghi, Iranian Labor News Agency published on 19 November 2014 http://ilna.ir/news/news.cfm?id=225126 25 See more: Civil society report to the CRC, 2016, Coalition Impact Iran, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=INT%2fCRC%2fNGO%2fIRN%2f19809 &Lang=en 2

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