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Indicator 3.4.4
by Contact on 8 October 2026
Requirement
The UoC shall ensure that medical tests are only conducted during the recruitment process if required for the function of the job or by applicable law, including where any recruitment agencies are used. **
How Do I Interpret This Requirement?
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There are occasional situations where the UoC, or the agency involved in recruitment may need to perform medical tests. For example:
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it is required by law.
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if the function of the job requires it.
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for health and safety reasons.
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determining whether a medical test is necessary happens through a health and safety risk assessment (Indicator 3.5.4).
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Examples of when medical tests may be allowed are:
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when the function of a job might require a medical test, such as in the recruitment of divers. A diver may have to undergo a chest x-ray to demonstrate that they are fit enough to dive regularly.
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when an employee is asked to test for COVID-19 before coming into the workplace, to avoid the spread of the disease.
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when a test may be required by national law, such as the existence of laws in 25 countries that make HIV testing mandatory to obtain a work or residence permit: <https://lawsandpolicies.unaids.org/topicresult?i=25&lan=en>.
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Examples of when medical tests may not be allowed are:
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a test for sexually transmitted infections (STI), which could lead to discrimination about someone’s sexual practices and/or ability to work.
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when an HIV test is given outside of the 25 countries that make HIV testing mandatory to obtain a work or residence permit, as they are not relevant for the function of any jobs in aquaculture.
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Evidence of Implementation
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terms of service between recruitment agencies and the UoC
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documents from recruitment processes
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health and safety and food safety risk assessments that require medical testing
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information about which medical tests are required.
Auditors Should Confirm
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where medical tests are required, the decision for these tests has been based on the outcome of a risk assessment;
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employees understand the reasons for the medical tests.