Indicator 3.2.3

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Indicator 3.2.3

by Contact on 8 October 2026

Requirement

The UoC shall ensure that where recruitment agencies are used, they comply with applicable legal requirements and are licenced or certified by the relevant authority, where such licensing or certification exist.

How Do I Interpret This Requirement?

  • The UoC is responsible for initial screening of recruitment agencies, including:

    • checking that they comply with relevant regulations, which includes:

      • national labour laws

      • employment rights

      • applicable laws in the country of operation, for example, some countries have specific regulations for recruitment and employment agencies

    • verifying their licence or certificate to operate, where these systems exist:

      • in some countries and sectors, licensing rules apply. For example, in the UK, an agency supplying labour in agriculture, horticulture, shellfish gathering or food processing and packaging may need to be licensed by the Gangmasters & Labour Abuse Authority (GLAA)

    • checking that they comply with the indicators directly addressing recruitment agencies in the ASC Farm Standard:

      • indicator 3.2.4: employees’ original identity documents are not retained

      • indicator 3.2.5: employees are allowed to terminate their employment

      • indicator 3.2.6: employees do not have any part of their salary, property or benefits unlawfully withheld

      • indicator 3.2.7: employees are not charged any fees associated with recruitment

      • indicator 3.2.8: prison labour is not used

      • indicator 3.4.1: no discrimination in recruitment

      • indicator 3.4.3: not testing for pregnancy or virginity

      • indicator 3.4.4: medical tests are only conducted during recruitment if required for the function of the job or by national law;

      • verifying their compliance with any contractual agreements in place between the UoC and the recruitment agency.

  • The UoC is also responsible for continued monitoring of recruitment agencies, including annually reviewing their:

    • licence to operate

    • compliance with applicable regulations

    • compliance with the relevant ASC Farm Standard indicators

    • compliance with any contractual agreements in place.

    • The UoC can outsource this screening and monitoring to subcontracted professionals, such as acknowledged NGO licensing programmes.

    • When recruitment agencies are used for hiring migrant employees, a Memorandum of Understanding (MoU) and terms and conditions can be agreed between the UoC and recruitment agency detailing the conditions under which foreign migrant employees will be hired.

Evidence of Implementation

  • records of screening of recruitment agencies, both upon engagement of the agency and also on an ongoing basis

  • copies of valid, up-to-date licences of recruitment agencies

  • contracts with recruitment agencies

  • employee contracts for those who have been recruited by recruitment agencies.

Auditors Should Confirm

  • whether or not recruitment agencies have been used by the UoC;

  • that a recruitment agency screening process is in place;

  • terms and conditions of employment for those who have been recruited through recruitment agencies;

  • if any foreign migrant employees have been recruited through agencies;

  • if terms and conditions and an MoU are in place for the recruitment of migrant employees;

  • employees’ perceptions of the recruitment process;

  • that recruitment agencies used have not been associated with any bad practices by local labour unions or other organisations.