“Some work may be acceptable for children, but Ghana’s unlicensed gold mines are very dangerous places where no child should work,” said Juliane Kippenberg, senior children rights researcher at Human Rights Watch and the author of the report. “Companies buying gold in Ghana should exert control over their whole supply chain to make sure they’re not benefiting from child labor.”

Human Rights Watch has conducted field research into the use of children in gold mining in Western, Central, and Ashanti Regions since 2013. Researchers visited 10 artisanal and small-scale gold mining and processing sites, and interviewed over 160 people, including 44 child miners between the ages of 9 and 17. Human Rights Watch also met with 20 gold traders in Ghana and gold refining companies outside the country.

Children have been injured – and, in at least one case, killed – in mine collapses, and suffered from pain and respiratory problems caused by their work. They also risk brain damage and other life-long disabilities from mercury poisoning. Most children who work in mining attend school, and some work specifically to cover school-related costs. However, many attend school irregularly or drop out.

Major international gold refiners from Switzerland, the United Arab Emirates, and other countries use artisanally mined gold from Ghana, one of the world’s top 10 gold producers. The supply chain resembles a funnel, with many traders buying gold from many mining sites, and with fewer and fewer companies involved as it moves along the supply chain until it reaches a small number of international refiners. After the gold is refined, it is sold to banks, jewelry businesses, the electronics industry, and other enterprises.

Human Rights Watch examined the “due diligence” policies and procedures of six international refiners that buy gold from Ghana: Metalor (Switzerland), Produits Artistiques Métaux Précieux (PAMP) (Switzerland), Kaloti Jewellery International (UAE), Emirates Gold (UAE), Kundan (India), and Rand Refinery (South Africa). Several of them have weaknesses in their procedures – lacking control over their supply chain or failing to report publicly on their due diligence measures, for example, or not carrying out systematic child labor monitoring. Human Rights Watch provided its findings to the companies and received written responses from MetalorKaloti, PAMP, and Rand Refinery, which stopped buying gold from Ghana in 2014, and met with Emirates Gold, Kaloti, and PAMP.

Companies should have clear policies against child labor, require regular monitoring with unannounced inspections by people knowledgeable about child labor and full chain-of-custody documentation, and ensure that all contracts with suppliers include specific language prohibiting child labor, Human Rights Watch said.

Many local gold traders have done little to determine whether the gold they buy is produced with child labor, and regularly bought at unlicensed mining sites, where child labor often occurs, Human Rights Watch said. Three of Ghana’s largest four gold exporting companies said that they had sometimes bought gold they could not trace back to the mine. Only one said that it was exclusively buying gold at licensed mines.

The Ghanaian government-owned gold trading company, the Precious Metals Marketing Company, has no procedures to determine whether children have been involved in producing the gold it purchases. It provides trading licenses to about 700 individual buying agents and trading companies without obliging traders to use any human rights criteria, including regarding child labor, when purchasing gold. The government Minerals Commission provides export licenses without requiring human rights monitoring, though it informed Human Rights Watch it is considering such a step.

“Governments should make human rights due diligence a requirement in producing countries like Ghana and where the gold gets traded and refined, such as Switzerland and the United Arab Emirates,” Kippenberg said.

Artisanal and small-scale gold mining is poorly regulated in Ghana, Human Rights Watch said. The majority of mines operate without mining licenses, which are costly and difficult to obtain. Labor, environment, and other regulations are often not enforced. In addition, Ghanaian law allows the use of mercury for artisanal gold mining. Although it is particularly harmful to children, mercury is available in gold trading shops and provided by gold traders to child laborers. An international treaty, the Minamata Convention on Mercury of 2013, sets out steps to reduce mercury exposure, but Ghana has not ratified it.

“The government of Ghana has done far too little to protect its citizens from this toxic chemical,” Kippenberg said. “It should promptly start introducing mercury-free gold processing techniques, and ratify the Minamata Convention and put its requirements into effect.”

Ghana’s child labor inspections are not systematic, and government institutions dealing with child labor and protection are inadequate, Human Rights Watch said. While school enrollment rates in Ghana have risen to above the regional average over the last two decades, funds for free public education are inadequate and schools levy various fees.

Ghana’s Children’s Act prohibits mining work for anyone under 18. Child labor in mining also violates Ghana’s international legal obligations. The International Labour Organization (ILO) defines child labor as work that deprives children of their childhood, their potential and their dignity, that is harmful to their physical and mental development, and that interferes with their schooling. ILO Convention No. 182 prohibits the “worst forms of child labor” for anyone under 18, and specifically includes certain mining activities, such as work with dangerous chemicals, in its ban.

The government of Ghana should address underlying causes of child labor through cash transfer programs, appropriate youth employment options, and measures to make free primary education a reality. The government should also undertake fundamental reforms to regulate, professionalize, and formalize the artisanal and small-scale mining sector, and to address child labor in mining, Human Rights Watch said.

“Ghana should lead the way in Africa by developing a comprehensive strategy for safe, professional, and child labor-free gold mining,” Kippenberg said. “That way, Ghana’s gold can truly improve the lives of Ghanaian children.”

Read the full report here.