Indicator 3.2.6

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Indicator 3.2.6

by Contact on 8 October 2026

Requirement

The UoC shall ensure that employees, whether employed directly or through a recruitment agency, do not have any part of their salary, property, or benefits unlawfully withheld. **

How Do I Interpret This Requirement?

  • A common tactic in forced labour situations can be to withhold salary, property or benefits, to pressure an employee to stay in employment.

  • Benefits can be:

    • those allowed by law

    • defined by contract

    • defined by collective bargaining agreement

    • inclusive of, for example:

      • paid time off

      • sick leave

      • health insurance

      • private pensions scheme

      • can include bonuses.

  • There are situations where withholding salary, property or benefits are legally required, and so allowed under this indicator. For example:

    • Salary withholdings, as required by the government. For example, part of a salary is sometimes withheld by a government for:

      • statutory pensions

      • health insurance

      • taxes

      • or a government can sometimes require the withholding of salary to pay overdue child-care support costs to another parent

      • or a government can require the withholding of salary to pay overdue taxes.

      • Salary deductions, as defined in a contract or collective bargaining agreement, that are agreed by both parties. For example, an agreed voluntary deduction for housing costs could be allowable.

      • Bonuses, which are considered optional and additional to the agreed salary and benefits. However, if clearly defined performance targets related to a bonus payment have been achieved, then the bonus cannot be withheld.

      • The UoC is responsible for ensuring that any employees who are working at the UoC but recruited and/or contracted by a recruitment agency do not have any parts of their salary, property or benefits withheld unlawfully.

Evidence of Implementation

  • employee contracts that include information about any wage deductions

  • payslips and payroll records

  • evidence that recruitment agencies do not unlawfully withhold any salary, property or benefits.

Auditors Should Confirm

  • contracts do not contain any unlawful deductions;

  • wage terms listed in contracts match payslips or payroll records;

  • any deductions made from wages such as taxes, or social security, are lawful, transparent, and authorised by the employee;

  • employees are aware of the purpose of any deductions being made.