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A comparative study of National Action Plans on Business and Human Rights in Africa : labor rights perspectives
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ganisations(especially from informal sectors or regional branches) appears limited. Based on this assessment, the extent to which organised labour was involved in the con­sultations that were undertaken prior to the drafting of the NAP BHR could be classified as medium . Extent and Quality of Gender Stakeholder Consulta­tion and Input During NAP BHR Development The development of the Uganda NAP BHR shows that gender groups(e.g., women, womens rights organisations, vulnerable gender‐related constituencies) were included to a significant extent in the consultation process. According to the NAP BHR, the consultation process was broad and included a focus onwomen, vulnerable, and marginalised groups as a priority thematic area. For example, among the over 600 participants consulted from 99 districts across 11 subregions in Uganda, women and older persons were mentioned as specific stakeholders targeted for these con­sultations. To ensure that womens issues were captured in the NAP BHR, specific meetings were held with women in mining regions(for example, in the districts of Kaabong and Moroto) to capture gendered risks in extractive and re­lated business operations. Therefore, overall, the representation of gender groups in consultations for Ugandas NAP BHR can be assessed as high , not only because of the recognition and coverage of gender issues in the NAP BHR, but also because womens rights organisations had a seat at the table. Substantive Responsiveness of NAP BHR Content to Labour Rights Deficits and Challenges The role of labour rights cannot be underestimated in the initiation of Ugandas NAP BHR. According to the MGLSD, even though the UPR recommendation was the immediate reason for the launch of the NAP BHR, there were underly­ing factors that compelled the government of Uganda to accept and act upon that recommendation. 27 The govern­ments development planUganda National Development IIIalready attaches greater importance to the private sec­tor as an engine for the socioeconomic transformation of the country, as reflected in the theme of the plan, which is: Sustainable industrialisation for inclusive growth, employ­ment, and wealth creation. 28 To realise this objective, There is a need to foster a dynamic and well-functioning business sector, while protecting labour rights and environ­mental and health standards in accordance with relevant international standards, 29 according to the MGLSD. Hence, issues pertinent to respect for labour rights could be con­sidered as one of the top priorities that necessitated the development of a NAP BHR in Uganda. 30 Among the eight focus areas identified by the Uganda NAP BHR, one is labour rights. Under labour rights, the NAP BHR lists key challenges, including the occupational health and safety of women in manufacturing and produc­tion industries; workers being employed without formal contracts, hence no job security; limited access to remedy for human rights abuses by business operations; delays or lack of compensations in case of workplace accidents; lack of company management support for workers joining trade unions; exploitation of employees by companies to work for long hours and with poor remuneration, especially in plantation and construction companies; lack of compliance among employers in the business sector with the laws guaranteeing labour rights; and the trafficking of persons abroad for work, with women and youth making up the majority of victims. Subsequently, such victims can experi­ence an abuse of rights, physical and psychological vio­lence, and a lack of protection while abroad. Child labour is also identified as a serious issue in Uganda. According to the NAP BHR, at least two million children aged 5–17 are engaged in child labour, with 1.7 million below 14 years of age and 507,000 involved in hazardous work. This includes children working in the agriculture sector, domestic servic­es, and extractive industry(including children involved in artisanal and small-scale mining) and victims of commer­cial sexual exploitation. To mitigate the above challenges, the NAP BHR outlines several strategies and interventions to address labour and workers rights. Some of these key strategies pertinent to labour and workers rights include empowering vulnerable persons to claim their rights, promoting compliance with human rights observance by business actors, and enhanc­ing access to remedies for victims of business-related hu­man rights abuses. For instance, the NAP BHR aims to strengthen the capacity of human resource functions in businesses to observe workers rights, popularise existing labour laws and occupational health and safety standards, and ensure helplines are available for reporting unsafe working conditions and other labour complaints. The NAP BHR also includes provisions for strengthening the capaci­ty of judicial and quasijudicial institutions to provide reme­dies for business-related human rights violations, as well as to provide government-supported legal aid services to vulnerable groups, including workers. Moreover, the desig­nation of the MGLSD as the coordinating body for the NAP BHRs development further emphasises the focus on la­bour-related issues. 27 Interview-7, Ministry of Gender, Labour and Social Development, Republic of Uganda, conducted 19 September 2025. 28 Interview-7 29 Ministry of Gender, Labour and Social Development.(2021). The national action plan on business and human rights. The Republic of Uganda. https://globalNAPBHRs.org/ wpcontent/uploads/2025/03/uganda_approved-national-action-plan-on-business-and-human-rights_august-2021.pdf 30 Interview-2, Uganda Consortium on Corporate Accountability, 18 August 2025. 18 Friedrich-Ebert-Stiftung e.V.