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### Viewing cable 03COLOMBO1436, SRI LANKA CHILD LABOR INFORMATION FOR

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Reference ID | Created | Released | Classification | Origin
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03COLOMBO1436 | 2003-08-18 10:06 | 2011-08-25 00:00 | UNCLASSIFIED | Embassy Colombo

`

    This record is a partial extract of the original cable. The full text of the original cable is not available.

` `

    UNCLAS SECTION 01 OF 09 COLOMBO 001436

    SIPDIS

    DEPT FOR DRL/IL MARINDA HARPOLE, SA/INL
    DOL/ILAB FOR TINA FAULKNER

    E.O 12958: N/A
    TAGS: ELAB EIND ETRD PHUM SOCI CE USAID
    SUBJECT:  SRI LANKA CHILD LABOR INFORMATION FOR
    TRADE AND DEVELOPMENT ACT (GSP) REPORTING
    REQUIREMENTS

    REF: STATE 193266

    ¶1. Following is information on Child Labor in Sri
    Lanka for GSP Trade and Development Act.

    ¶2.  Responses are keyed to Reftel.

    (a) Whether the country has adequate laws and
    regulations proscribing the worst forms of child
    labor:

    Sri Lanka has shown its commitment to protecting
    children from various forms of exploitative
    employment and abuse.  Sri Lanka was one of the
    first member countries to ratify the UN convention
    on the rights of the child in 1990.  A Sri Lankan
    "Children's Charter" was adopted in 1992.  In 1997,
    the National Child Protection Authority (NCPA) was
    established under the purview of the President.  The
    Sri Lanka Constitution of 1978, Article 27(13)
    states that "children shall be protected" and
    Article 12(14) states "action shall be taken to
    guarantee this protection".

    -- The government continues to take steps to protect
    children from the worst forms of child labor.  Sri
    Lanka ratified ILO convention 182 for the Immediate
    Elimination of the Worst Forms of Child Labor on
    March 1, 2001.  It entered into force in March 2002.
    The National Child Protection Authority (NCPA), with
    the assistance of the ILO's International Program on
    Elimination of Child Labor (IPEC), is moving to
    implement the convention.  Sri Lanka also ratified
    ILO convention 105 on the abolition of forced labor
    on January 7, 2003.  In 1999, Sri Lanka ratified ILO
    convention 138 on minimum age for admission for
    employment.

    -- The minimum age for employment is set at 14
    years, which is consistent with the age for
    completing school education in Sri Lanka.  The
    Employment of Women, Young Persons and Children Act
    (EWYC) and the Factories Ordinance (FO) govern
    employment of young persons between the ages of 14
    and 18, and lay down guidelines protecting their
    health, safety and welfare.  Penal code amendments
    in 1995 and 1998 provide legal protection to
    children from criminal exploitation.

    -- The worst forms of child labor or hazardous work
    for children between 14 and 18 years are not clearly
    defined.  There are various restrictions, however,
    to protect workers in this age group from dangerous
    work.  Under the EWYC, night work is generally
    prohibited for persons under 18 years; working hours
    of young persons below 16 years and below 18 years
    are limited to 9 hours and 10 hours per day,
    respectively.  Minimum age for employment at sea is
    15 years.  The Factories Ordinance permits
    employment of children 14-18 years.  It calls for
    medical certification of those below 16 and
    prohibits persons below 18 years from engaging in
    harmful employment.

    -- In 2003, the government took further action to
    protect children from exploitative employment
    through amendments to the EWYC Act -- Employment of
    Women and Young Persons and Children (Amendment Act)
    No. 8 of 2003.  Under the amendments, children below
    14 are allowed to work outside school hours only in
    part-time family agricultural work or to engage in
    technical training.  They are prohibited from
    working in any family-operated industrial
    undertaking or in any other vocation.  The
    prohibition on working at sea for children under 15
    years has been extended to cover working in family-
    owned vessels.  The age for public performance,
    endangering life or limb, is increased from 16 to 18
    years.  The age for training for performances of a
    dangerous nature is increased from 14 years to 16
    years.  A special license is required for such
    training by persons aged 16 to 18.
    -- Penal Code amendments in 1995 and 1998 deal with
    child sex workers, child pornography, cruelty and
    grievous hurt, and trafficking of children for
    sexual exploitation, illegal adoption, begging or
    trading in restricted articles.  The Penal Code
    defines a child as a person below 18 years of age,
    in line with convention 182.  The Government intends
    to expand the Penal code coverage on trafficking of
    children to cover trafficking for all types of
    employment.

    -- Since December 1997, Sri Lanka has been
    participating in the ILO/IPEC program.  Sri Lanka
    also participates in IPEC's Trafficking in Children-
    South Asia (TICSA) program, funded by the USDOL.
    With ILO/IPEC assistance, Sri Lanka is in the
    process of finalizing a list of occupations
    considered to be the worst forms of child labor
    existing in Sri Lanka, as called for in Article 4 of
    the Convention 182.  The list is to be released in
    September 2003.  In order to identify the nature of
    the worst forms of child labor existing in the
    country, rapid assessment studies on trafficking of
    children, child domestic workers and the commercial
    sexual exploitation of children were commissioned by
    IPEC under TICSA-phase I project.  Sri Lanka has
    already done extensive work in combating
    trafficking, which, under IPEC programs, is seen as
    the facilitating mechanism for a wide range of the
    worst forms of child labor.  Sri Lankan authorities
    believe that controlling child labor at its source
    is the most effective way of eliminating child
    labor.

    B) Whether the country has adequate laws and
    regulations for the implementation and enforcement
    of such measures:

    -- Minimum age for employment is set at 14 years,
    which is consistent with the age for completing
    school education.

    --  In March 2003, the Government increased the
    penalties for child labor violations through
    Employment of Women, Young Persons and Children
    (Amendment) Act No. 8 pf 2003. Penalties (fines and
    prison sentences) for violating laws governing
    employment of children below 18 years under the EWYC
    were increased from Rs 1,000 (approx. $10) and/or
    six months imprisonment to Rs 10,000 (approx $100)
    and/or 12 months imprisonment.  In addition, new
    provisions require the offenders to pay compensation
    to the victims.

    -- The Penal Code contains provisions which can be
    used to deal with the problem of child sex workers,
    pornography, trafficking of children for sexual
    exploitation, and illegal adoptions.  Procuring
    children for begging or acting as procurers for
    sexual intercourse and trafficking in restricted
    articles is also punishable under the Penal Code.
    Penalties include imprisonment and fines or both.
    The Police Department and the Attorney General's
    Office are responsible for prosecuting violations of
    the Penal Code.

    -- According to ILO sources, additional laws and
    regulations are necessary to eliminate the worst
    forms of child labor.  The National Child Protection
    Authority (NCPA) appointed a subcommittee on legal
    reforms in October 2002.  This subcommittee has
    recommended new laws governing obscene publications,
    juvenile justice, and legislation to prevent
    exposure of children to pornography through the
    Internet and sexual solicitation.  The committee is
    also striving to introduce child-friendly court
    procedures and to expand the use of video evidence
    in cases involving children.

    --  According to interlocutors, due to various
    governmental and NGO programs, awareness regarding
    child rights and the need to protect children from
    various forms of abuses has increased significantly.
    This is clearly shown by an increase in complaints
    received by the NCPA, which deals with all forms of
    child abuse.  The Department of Labor has observed a
    declining trend in employment of children under 14
    years.  According to sources, enforcement has
    improved, but problems still exist due to lack of
    evidence, false charges and sometimes the lack of
    birth certificates - a common problem with the rural
    poor.  Further, while most of the enforcement
    officers have been trained, enforcement agencies are
    not able to respond adequately to all of the
    complaints due to lack of infrastructure.  Also,
    because of the hidden nature of the child labor problem
    within the informal sectors, enforcement is weak.
    According to the Department of Labor, during routine
    labor department inspections, business premises are
    checked for adherence to labor laws applying to
    children below 18 years.  Under TICSA - Phase II
    which is to begin later this year, judicial follow
    up will be improved to improve law enforcement.  US
    Department of State and Department of Justice
    recently approved grants to GSL agencies to enhance
    investigative techniques, civil and police
    coordination for child trafficking cases and
    assistance in court management.

    C)  Whether the country has established formal
    institutional mechanisms to investigate and address
    complaints relating to allegations of the worst
    forms of child labor:

    --  Institutional mechanisms are in place to
    investigate complaints regarding child labor.  The
    Government, with the assistance of other
    organizations, is continuing to strengthen these
    mechanisms.

    --  NCPA:  The National Child Protection Authority
    (NCPA) is the national focal point for implementing
    ILO Convention 182.  NCPA legislation defines a
    child as a person under 18, in line with Convention
    ¶182.  The basic goal of the NCPA is the elimination
    of child abuse in all its forms and manifestations.
    The NCPA operates in four main areas: protection,
    advocacy, rehabilitation, and legal reforms.  In
    2001, the NCPA established an anti-trafficking unit.
    It carried out 160 investigations between May 2001
    and December 2002.  NCPA also has a cyber watch unit
    that scans the Internet for pedophiles soliciting
    local children.  Its goal is to protect children
    from child pornography and other forms of commercial
    sexual exploitation.  This unit has been successful
    in tracking down pedophiles.  In October 2002, the
    Government established a special police unit at the
    NCPA to combat child abuse.  The unit is manned by a
    team of 16 trained police personnel, and works
    closely with NCPA on investigation and prosecution.
    NCPA received 276 complaints of child abuse in 2001
    and 386 complaints in 2002.  NCPA has established 11
    district child protection committees.  NCPA reports
    directly to the President.  Direct government
    funding for NCPA has been constrained due to a lack
    of resources and, reportedly, because of political
    differences between the President and the UNF
    government.

    --  In addition to the NCPA, Departments of Police
    (through Women and Children's Desks at all police
    stations and hotline), Labor, Probation and
    Childcare, and District Child Protection committees
    all receive complaints of child labor.  The labor
    department and the probation department have the
    powers to prosecute offenders in the magistrate
    courts under EWYC.  The police department and the
    attorney general's department prosecute violations
    of the Penal Code.  Child prostitution and
    pornography, trafficking of children for sexual
    exploitation, illegal adoptions, and procuring
    children for begging or acting as procurers for
    sexual exploitation and trafficking in restricted
    articles are all punishable offences under the penal
    code.

    --Statistics:

    Table 1

    The following table presents data on child labor
    complaints made to various government departments.

    Year     Dept of Labor(a)  NCPA(c) Police
    2000         194            184  391
    2001         255            276        23
    2002         161            386         0
    2003    102(b)         179(d)      7(e)

    a) Employment of Children below 14 years. In years
    2000, 2001, 2002, and 2003, the number of cases
    prosecuted, respectively, was 7, 42, 26 and 23.
    nd 23.
    About 95 percent of the prosecutions result in
    convictions.  During these years, 127, 141, 72 and
    14 complaints were withdrawn due to lack of evidence
    or false information.
    b) From January to July, 2003
    c) NCPA numbers reflect all forms of abuse against
    children below 18 years.  Most of the complaints are
    on sexual abuse.  In 2002, NCPA received 46
    complaints on child labor, 198 on sexual abuse, and
    84 on physical abuse.
    d) From January to May, 2003
    e) From January to June, 2003
    Sources:  Women's and Children's Division of the
    Department of Labor, Statistics Division of the NCPA
    and the Women's and Children's Division of the
    Department of Police.

    -- The NCPA and the Labor Department continue to
    carry out training programs for judicial, labor,
    medical, education, probation and police officers
    dealing with child labor and for media personnel,
    with the assistance of the ILO/IPEC, UNICEF, Save
    the Children UK and local NGOs.

    -- During 2002, the Labor Department trained 790
    school principals, teachers, and religious leaders
    on the elimination of child labor.  The Department
    also conducted three public awareness seminars
    during the year.  In 2003, the Labor Department
    plans to train over 600 people including police
    officers, probation officers, and labor officers
    charged with investigating child labor, under the
    IPEC program.  It also hopes to conduct a program
    for eliminating child domestic workers with ILO
    assistance.

    -- The NCPA strives to raise awareness of child
    rights through poster campaigns and media.  Some of
    its recent plans to broadcast programs have been
    hampered by the lack of funds.  The NCPA has
    commenced a pilot project to establish Child
    Protection Committees (CPC) in schools.  These
    committees, comprised of parents and students, are
    responsible for creating awareness of child abuse,
    child rights and child labor and attempt to
    strengthen child-family-school interactions.
    Representatives from the NCPA attend CPC meetings,
    present lectures and investigate complaints
    received.  Within the next two years, this project
    is to be expanded to schools across the country.

    -- Other NCPA programs:  Induction training program
    on psycho-social counseling for newly recruited
    child care officers funded by ILO/IPEC;
    Multidisciplinary workshop for child care
    professionals; Skills development workshops for
    members of district child protection committees
    funded by ILO/IPEC; NCPA also provided continues
    training to police officers assigned to Children's
    Bureau as well as other professionals working in the
    field.  The training is designed to increase the
    skills required to ensure admissibility of taped
    testimonies into court and skills for communicating
    with children.
    D) Whether social programs exist in the country to
    prevent the engagement of children in the worst
    forms of child labor and assist in the removal of
    children engaged in worst forms of child labor:

    -- Education:  The Government of Sri Lanka
    demonstrates a strong commitment to education and
    strives to eliminate child labor through education.
    The law requires children between ages of 5 and 14
    to attend school.  According to Regaining Sri Lanka,
    a Government policy document prepared in 2002, net
    primary enrollment rate (grades 1 to 9) is about 85-
    90 percent.  The government continues to support
    programs which promote children's access to primary
    schooling as well as quality and relevance of
    schooling.  The government provides universal free
    education from primary school to university level.
    School text-books are provided free of charge to all
    school children following local educational
    curricular.  School uniform material is provided for
    needy students and a school feeding program provides
    one meal daily for 20,800 first year students in
    areas having very high rates of malnutrition.

    Further, scholarships are provided for gifted
    students from needy families.  Health care,
    including immunization, is also free.  In order to
    improve the quality and relevance of education, the
    Ministry of Education began a 6-year primary
    education development plan in 1999, with World Bank
    assistance.  It contained extensive curriculum
    reforms in Grade 1 through Grade 5, which were
    implemented on a staggered basis from 1999-2003.
    All primary school teachers were trained under the
    project.  All parents of grade one students are
    briefed on the importance of education.  These
    measures have helped to promote enrollment and have
    shown a marked decline in dropout rates in the
    primary cycle (through grade 5).  According to the
    Education Ministry, the dropout rate is around 0.1
    percent in the primary cycle.  Secondary education
    reforms are also underway, funded by the World Bank
    and the Asian Development Bank.  Despite budgetary
    constraints, the Government has increased funding
    for education in 2002 and 2003.

    -- Government spending on education (RS million):

    Year          Total Education     Primary Education
    2000          30,929                 NA
    2001          28,286                 8,943
    2002          37,209                 9,962
    2003    42,045  NA
    Exchange rate:  US 1= Rs 75.78(2000), Rs
    89.36(2001),  Rs 95.66 (2002), Rs 96.00 (2003).
    Sources: Ministry of Finance estimates provided to
    the Embassy and Central Bank Annual Report 2002.

    -- World Bank and the Asian Development Bank are the
    major donors assisting government efforts to
    modernize education.  Ongoing World Bank IDA loans
    provide $70 million for general education (with 55%
    of funding allocated for primary education) and $64
    million for teacher education and teacher
    deployment.  In addition, the IDA pipeline includes
    $50 million for general education and $30 million
    for undergraduate education in the next few years.
    ADB has provided $48 million for secondary education
    modernization.  Proposed ADB loans include $50
    million for post-secondary education modernization
    (distance learning) and $40 million for secondary
    dary
    education computerization.

    -- The Government is continuing to sponsor non-
    formal education units to draw non-school going
    children to the education system.  With the rapid
    decrease in school dropout rates in primary classes,
    some of the non-formal education units are being
    upgraded from literacy centers to functional
    literacy centers in order to provide job-oriented
    skills to older students.

    -- UNICEF supports non-formal education centers run
    by the Education Ministry and functional training
    centers run by NGOs.  In early 2003, UNICEF
    conducted two media campaigns on education, focused
    on compulsory education for children below 14 years
    and prevention of sexual and physical abuse of
    children.  The latter included the issue of child
    domestics.  UNICEF also sponsors a pilot program on
    the child-friendly school environment concept in 124
    schools in two districts.  This program focuses on
    reforms, quality of education, improving access to
    education, sanitation, health, protection and child-
    centered learning.

    -- The NCPA also assists children affected by the
    worst forms of child labor.  It has established a
    rehabilitation center and offers vocational training
    and counseling for victims of trafficking.  The NCPA
    also hopes to launch community empowerment and
    family empowerment programs to curb trafficking and
    the worst forms of child labor.  ILO/IPEC and UNICEF
    are working with Don Bosco Center, a local NGO in
    conducting remedial classes for children at risk in
    areas bordering conflict zones.  ILO/IPEC also runs
    similar programs together with trade unions on the
    plantations.

    -- The plantation sector has been identified by
    various studies as an area of origination for
    trafficked children, especially for domestic
    employment.  Under ILO/IPEC, 30 social mobilizers in
    the plantation areas have been trained to campaign
    against child trafficking and raise trade union
    awareness.  They are expected to reach 3000
    plantation families.

    -- Children in north and east: Sri Lanka continues
    to face problems with recruitment of children for
    armed conflict by the Liberation Tigers of Tamil
    Ealam (LTTE).  The LTTE uses child soldiers and
    recruits children, sometimes forcibly, for use in
    battlefield support and in combat.  In May 1998, the
    LTTE gave assurances to the Special Representative
    of the UN Secretary General for Children in armed
    combat, that it would not recruit children under the
    age of 17.  The LTTE has not honored this pledge.
    With the announcement of a cease-fire in February
    2002, there is considerable international and
    domestic pressure on the LTTE to stop recruiting
    child soldiers and to release child soldiers to
    their parents.  As of August 2003, credible reports of child
    conscription by the LTTE continue.

    -- The peace negotiations have given rise to new
    challenges and opportunities for the protection of
    children affected by conflict as well as child
    soldiers recruited by the LTTE.  It has given access
    to government, international organizations and NGOs
    to previously unaccessible areas affected by war.
    UNICEF is scaling up its response to address the
    rights of children affected by armed conflict and to
    meet the immediate needs of returning internally
    displaced persons.  UNICEF has focused its strategic
    response on education, water and sanitation and
    child protection.  In collaboration with WHO, UNICEF
    will also support maternal and child health recovery
    programs in areas with a high number of returnees.

    -- In April 2003, UNICEF facilitated a workshop
    between the Government of Sri Lanka, the LTTE, and
    local and international organizations to agree on a
    plan of action to address the needs of children
    affected by war.  The plan aims to restore and
    ensure normalcy to these children, including child
    recruits.  Child rights training to LTTE, Government
    armed forces and communities is one component of the
    plan.  It will also provide for the release and re-
    integration of child soldiers with UNICEF
    assistance.  UNICEF is supporting transit centers
    for child recruits released by the LTTE.

    -- Sexual exploitation of children, including
    commercial sexual exploitation, has come into focus
    recently.  In 2002, NCPA received 198 complaints on
    child sexual abuse.  A further 84 cases involved
    physical abuse.  According to UNICEF and NCPA, most
    sexual exploitation and abuse occurs within the
    privacy of family.  Sexual activity is often seen as
    a private matter, which makes communities reluctant
    to act and intervene.  UNICEF and other NGOs are
    working actively to raise awareness of how to
    prevent sexual exploitation of children.  They are
    also engaged in rehabilitating and counseling
    children at risk.  To end the tolerance of sexual
    abuse, UNICEF acts to improve community attitudes,
    customs and practices towards children and their
    rights via TV, radio and newspapers.

    E) Whether the country has a comprehensive policy
    for the elimination of the worst forms of child
    labor:

    -- The Government has ratified ILO convention 182 on
    the elimination of worst forms of child labor.  As a
    first step, the NCPA has adopted a comprehensive
    national policy and a national action plan on
    elimination of trafficking of children for
    exploitative employment.  It hopes to combat
    trafficking of children for exploitative employment
    over a period of 10 years.  The plan is being
    implemented through various agencies.

    -- The NCPA and other stakeholders with ILO/IPEC
    assistance is in the process of identifying the
    worst forms of child labor existing in Sri Lanka.
    In order to determine the nature of worst forms of
    child labor, rapid assessment research was completed
    on child trafficking, commercial sexual exploitation
    and child domestic workers under TICSA project.
    Stakeholder consultations to draft the national
    policy on worst forms of child labor have also
    commenced.  The draft plan will be discussed at a
    workshop later this year.

    F) Whether the country is making continual progress
    toward eliminating the worst forms of child labor:

    -- Sri Lanka is one of few developing countries that
    does not employ children in the formal sector.
    There are no reports that children are employed in
    the Export Processing Zones, the garment industry,
    or any other export industry, although children
    sometimes are employed during harvest periods in the
    plantation sectors and in non-plantation
    agriculture.  Although there is much concern about
    the need to eliminate child labor, child labor still
    exists in the informal sector, and the magnitude of
    the problem cannot be fully assessed, as much of it
    remains hidden.  According to a child activity
    survey carried out in 1998 and 1999 by the
    Department of Census, the estimated child population
    of the years 5 to 14 years was 3.2 million in 1999.
    The survey found that almost 11,000 children of this
    age group were working full time and another 15,000
    were engaged in both economic activity and
    housekeeping without attending school.  This
    represented about .8 percent of the child
    population.  The survey found 450,000 children
    employed part-time by their families, primarily in
    seasonal agricultural work, while attending school.
    These statistics have not been updated since then.

    -- Some Sri Lankan children are trafficked
    internally to work as domestics and for sexual
    exploitation. Many NGOs attribute the problem of
    child exploitation to weaknesses in law enforcement.
    According to the child activity survey, over 19,000
    children below 18 years worked as child domestics,
    although this situation is not regulated or
    documented. A 1997 study reported that child
    domestic servants are employed in 8.6 percent of
    homes in the Southern Province.  The same study
    reported that child laborers in the domestic service
    sector often are deprived of an education.  Many
    child domestics reportedly are subjected to
    physical, sexual, and emotional abuse, and work long
    hours.  Consequently, there is discussion currently
    among child right activists regarding inclusion of
    domestic service in the list of worst forms of child
    labor existing in Sri Lanka.  Regular employment of
    children also occurs in the informal sector and in
    family enterprises such as family farms, crafts,
    small trade establishments, restaurants, and repair
    shops.  Government inspections have been unable to
    eliminate these forms of child labor, although an
    awareness campaign coupled with the establishment of
    hot lines for reporting child labor has led to an
    increase in complaints regarding child labor
    violations.  According to the Department of Labor,
    employment of children below 14 years is on a
    declining trend.

    -- Children are also exploited for sex activities.
    Protecting Environment and Children Everywhere
    (PEACE), a domestic NGO engaged in combating
    hazardous child work, estimated that in 2003 there
    were 5,000-6,000 children between the ages of 8 and
    15 years who were engaged as sex workers.  About 70%
    of them are boys.  They belong to socially deprived
    communities living in poverty, and usually live in
    urban slums.  Overall, awareness, reporting and
    prosecution of child sexual abuse cases have
    increased according to PEACE.  PEACE also reports
    that protection given to children has expanded due
    to increased awareness.  Although the country has a
    reputation as a destination for foreign pedophiles,
    most clients are locals.  The government has
    occasionally prosecuted foreign pedophiles, and
    there have been some convictions; however there were
    no such convictions during 2002.  Arrests of
    foreigners for child abuse were 4 in 1999, 4 in
    2000, 2 in 2001 0 in 2002, and there is one ongoing
    case in 2003.  No information was given about
    convictions resulting from these arrests.  There was
    evidence of continuing, but reduced, international
    interest in Sri Lankan children for the sex trade as
    evidenced in tourism by foreign pedophiles, and in
    Internet sites featuring child pornography involving
    the country's children.

    -- The LTTE continued to use high school-age
    children for work as cooks, messengers, and clerks.
    In some cases, the children reportedly help build
    fortifications.  Despite repeated claims to the
    contrary by the LTTE, there were credible reports
    that the LTTE continued to forcibly recruit children
    throughout 2002 and 2003.  The government, together
    with UNICEF and other international donors, is
    continuing to press for the release of child
    recruits.

    ¶3. As requested, post will send via diplomatic pouch
    to DOL/ILAB Tina Faulkner the following supporting
    document:
    ¶1.  Employment of Women, Young Persons and Children
    (Amendment) Act, No 8 of 2003.
    ¶2.  Report on trafficking in children for
    exploitative employment including sexual
    exploitation published by the ILO/IPEC project.
    Contains national plan of action to combat
    trafficking of children for exploitative employment
    in Sri Lanka.
    ¶3.  The Commercial Sexual Exploitation of Children:
    A Rapid Assessment- Sri Lanka published by the ILO
    ENTWISTLE

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