Is it time for a Responsible Recruitment Base Code?
The recruitment of migrant workers remains one of the most vulnerable points in global labour supply chains. Too often, workers are charged large recruitment fees before they even begin employment. The ensuing recruitment debt is not just a financial issue. It creates vulnerability. Workers who begin a job already owing significant sums may feel unable to leave poor conditions, challenge abusive treatment, or assert their rights. In this way, exploitation can begin long before workers reach the workplace.
For many years, organisations working to safeguard migrant workers have promoted a different model: the Employer Pays Principle — the simple idea that no worker should pay for a job. Encouragingly, this principle is now supported by a growing number of governments, companies and international organisations.
But despite this progress, the reality is that adoption remains uneven. Commitments on paper do not always translate into practice. One reason is that companies often have limited visibility over the recruitment agencies that supply their workforce. Oversight of complex networks of recruiters and sub-agents is difficult and frequently weak.
Since its inception I have served on the Stakeholder Advisory Panel for the International Organization for Migration IRIS programme, which certifies recruitment agencies that meet the highest standards of ethical recruitment.
IRIS is an important initiative. The standard is robust and comprehensive, developed through extensive consultation with governments, business, trade unions and civil society. Companies working with IRIS-certified agencies can have confidence that those agencies are operating at the highest level of ethical practice.
However, the difficult reality we must face is, only a handful of recruitment agencies have achieved IRIS certification. The process is demanding, time-consuming and expensive. While this “gold standard” rightly recognises agencies operating at the very highest level, it has proved beyond the capacity or resources of most recruitment agencies operating in low-wage migration corridors.
The agencies that have achieved certification deserve recognition. But if the aim is to transform recruitment practices across the industry, we may also need a more accessible starting point.
Perhaps it is time to think about a simpler approach?
Rather than focusing on comprehensive certification schemes for recruitment agencies, could we also promote a set of minimum safeguards that define the basic conditions under which a “recruitment process” itself can be considered responsible?
I believe it may be time to consider another way
The Responsible Recruitment Base Code.
At its core, responsible recruitment rests on four essential safeguards.
No Recruitment Fees - Workers should never pay recruitment fees or related costs. Recruitment should operate under the Employer Pays Principle.
No Document Retention - Workers must retain access to their passports, identity documents and personal documents at all times.
Clear Contracts - Employment contracts must be transparent, understood by workers, and honoured in practice.
Access to Grievance and Remedy - Workers must have access to trusted systems to raise concerns and obtain remedy if problems occur.
These four safeguards address the structural drivers of exploitation in recruitment: debt, coercion, deception and lack of remedy. Without them, recruitment cannot credibly be described as responsible.
Such a code would not certify any agencies or suppliers as fully compliant or otherwise. Instead, it would define the minimum conditions that must be met for recruitment to be considered responsible, and make clear the due diligence thresholds expected on companies and their suppliers in the recruitment process.
The Ethical Trading Initiative Base Code has become a widely recognised benchmark for labour standards in supply chains. Many companies who are not members of ETI will still often follow the Base Code.
A similar Recruitment Base Code could fill an important gap — addressing similar risks that arise before workers even begin their employment.
A Responsible Recruitment Base Code could:
Provide companies with a practical due diligence framework.
Become a key part of the Ethical Recruitment Marketplace currently being developed
Engage mid-tier recruitment agencies without overwhelming them
Support agencies transitioning towards ethical practice
Act as a stepping stone toward higher standards such as IRIS certification
If responsible recruitment is to become the norm rather than the exception, we need both ambitious standards and achievable entry points. A Responsible Recruitment Base Code could be one way to create a new approach.