Indicator 3.2.7

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Indicator 3.2.7

by Contact on 8 October 2026

Requirement

The UoC shall ensure that employees, whether employed directly or through a recruitment agency, are not charged any fees associated with recruitment, employment or travel and repatriation. **

How Do I Interpret This Requirement?

  • Charging employees fees for recruitment or during employment can lead to debt bondage and makes employees vulnerable to exploitation and coercion.

  • If fees are found, the UoC shall reimburse them as soon as possible.

  • Following are a list of recruitment fees and related costs as determined by the ILO and adapted from their guidance that may be incurred as a result of the recruitment process and that are not to be charged to potential or actual employees:

    • recruitment fees:

      • payment for services provided by a recruitment agency to match employers with applicants for employment

      • payment for the recruitment of potential employees for the purpose of employing them to perform work for a third party

      • payments to sub-agents as a finder’s fee

      • payments required to cover costs of recruitment fees from employees

      • payments to cover costs of recruiting referral and placement services, for example advertising positions or conducting interviews.

    • related costs are expenses related to recruitment and placement within or across national borders, and when related to the recruitment process and initiated by a recruitment agency or employer or an agent acting on behalf of those parties, are not paid by the employee or potential employee. These can include:

      • medical costs: payments for medical examinations, tests or vaccinations

      • insurance costs: costs to insure the life, health or safety of an employee, including enrolment in migrant welfare funds

      • costs for skills and qualification tests, for example: language tests

      • costs for training and orientation: including on-site and pre-departure or post-arrival orientation of new employees

      • travel and lodging costs within the recruitment process, including for training, interviews, consular appointments, relocation, and return or repatriation

      • application and service fees that are required for the recruitment process, including fees for services in preparing, obtaining or legalising workers’ employment contracts, identity documents, passports, visas, background checks, security and exit clearances, banking services, and work and residence permits

      • equipment costs: for tools, uniforms, safety gear and other equipment needed to perform assigned work safely and effectively

      • this list of costs is not exhaustive.

      • Undisclosed costs are also never allowed, such as previously undisclosed cost recovery-fees for expenses after they occur.

      • The UoC is responsible for ensuring that any employees who are working at the UoC but recruited and/or contracted by a recruitment agency have not been charged any fees or costs, as outlined above.

Evidence of Implementation

  • employee contracts

  • contracts with any recruitment agencies that contain an agreement that workers will not be charged any fees towards recruitment at any stage of recruitment

  • payslips and pay records.

Auditors Should Confirm

  • whether a recruitment agency has been used for recruitment;

  • that wage terms listed in contracts match payslips or payroll records and there are no hidden fees being deducted;

  • whether contracts of migrant workers contain clauses about repatriation;

  • employees’ perceptions of the nature and conditions of their recruitment process.

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