Office of the Ombudsman, Samoa‘s National Human Rights Institution Submission to the Committee on the Rights of the Child – September 2015 responsibilities for their families‘ livelihoods—sometimes as the sole breadwinner—as was the case for half97 of the child vendors profiled in the government‘s Child Vendor’s Pilot Study 2005.98 Thus, the NHRI recognises the potential of education to break intergenerational cycles of poverty. In conjunction with better enforcement of the Education Act 2009, the Government needs to deal with the broader issue of poverty99 and ensure that families are empowered to choose education over exploitative labour for their children. Recommendation 19: That the Samoan Government ensure enforcement of the Education Act 2009 as to reduce the amount of school-aged children working as street vendors. 11 Juvenile justice 79. The discussion on juvenile justice takes place at a time of transition and change within the Samoan justice system. The separation of the Ministry of Police and Prisons occurred on 1st January 2015, creating a Ministry of Police and Samoa Prisons and Correction Services. Additionally, both agencies have had new Commissioners appointed within the past 18 months and advanced plans have been made to replace the main Tafaigata prison in 2016 with a facility at Tanumalala. The NHRI is aware of a range of planned initiatives and anticipates a concerted focus on juvenile justice, particularly concerning juvenile detention in the coming reporting period. It is important that all of these developments are undertaken with the requirements of the Convention, the United Nations Standard Minimum Rules for the Treatment of Prisoners (Standard Minimum Rules), UN Rules for the Protection of Juveniles Deprived of their Liberty (Havana Rules), the United Nations Standard Minimum Rules for the Administration of Juvenile Justice (Beijing Rules), United Nations Rules for the Treatment of Female Prisoners and Non-Custodial Measures for Women Offenders ( Bangkok Rules). 80. The NHRI commends the Samoan Government for the enactment of the Prisons and Corrections Act 2013, which includes special procedures for the admission into custody of persons aged 18 or younger100 and to ensure that those persons are treated in accordance with the Convention.101 Additionally, the Act specifies the need for classification of prisoners102, the right to basic 97 This figure refers to 5 out of the 10 total children that were profiled. UNICEF, A situational analysis of children, women and youth, available at: http://www.unicef.org/pacificislands/ Samoa_sitan.pdf [accessed 25 June 2015] at 59. 99 UNICEF, Child Labour and UNICEF in Action: Children at the Centre, available at: http://www.unicef.org/protection/ files/Child_Labour_and_UNICEF_in_Action.pdf [accessed 15 June 2015] at 9. This entails addressing social and economic disparities through social protections such as livelihoods assistance and access to social services. 100 Prisons and Corrections Act 2013. s 28 (1)(b), 101 s 27 (6)(b) 102 s 39 (b)(ii), provided for in more detail by the Prisons and Corrections Regulations 2014, part 6 98 26