Supply Chain · Track B · Implementation

Recruitment fee remediation

Migrant worker recruitment fee assessment, repayment programme design and Employer Pays Principle implementation across Southeast Asia.

Who this is for

  • Manufacturers and plantations employing migrant workers in Malaysia
  • Electronics suppliers with RBA findings on fees
  • Brands with fee findings in their supply chain
  • Employers adopting the Employer Pays Principle

How this fits our independence policy

This is implementation work. If we implement a standard for you, we will not also assess you against it. An independent party does that.

Our independence policy

What we do

  1. Survey workersConfidential interviews on what each worker paid, to whom and when.
  2. Map the recruitment chainAgencies and sub-agents in sending and receiving countries.
  3. Calculate fees owedA defensible repayment calculation per worker.
  4. Design and verify repaymentA payment plan, with confirmation that workers received the money.
  5. Prevent recurrenceEmployer Pays policy, agency contracts and monitoring.

What you receive

  • Worker fee survey results
  • A recruitment chain map
  • A repayment calculation per worker
  • A repayment plan and payment verification
  • An Employer Pays policy
  • Revised agency contract clauses

Standards and frameworks referenced

  • Employer Pays Principle
  • ILO indicators of forced labour
  • RBA Code of Conduct requirements on fees

Repayment decisions and payments are made by the employer. We design the programme and verify the outcome.

Typical sequence

Every engagement is planned around your deadline. You receive a dated plan with the written scope.

  1. Survey
  2. Map
  3. Calculate
  4. Repay
  5. Prevent

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Risk assessment, traceability review and evidence files for the EU Forced Labour Regulation and US UFLPA exposure across your supply base.

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Worker grievance mechanism — build and operate

Design, launch and ongoing operation of an independent grievance channel — independence is easier to demonstrate when the channel is outsourced.

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RBA Code readiness for electronics

Self-assessment support, Validated Assessment Programme readiness and closure planning for electronics manufacturers and their suppliers.

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Where we deliver

  • Malaysia
  • Indonesia
  • India

Frequently asked questions

What is the Employer Pays Principle?

The principle that no worker should pay for a job. The costs of recruitment are borne by the employer, not the worker.

Why are recruitment fees a forced labour risk?

Debts from fees can tie workers to an employer, which is one of the ILO indicators of forced labour.

How do you confirm workers were repaid?

Through payment records and follow-up interviews with workers.

Is this mainly an issue in Malaysia?

It is the dominant social compliance exposure there, and it also appears wherever migrant workers are recruited through agents.

Request a scoping call

Tell us your sites, markets and deadline. We reply with a written scope.