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ILSI — International Legal Support and Investment

Responsible Recruitment

How employers can implement responsible recruitment practices, including the Employer Pays Principle, with ILSI's advisory support.

Recruitment is where most migrant worker exploitation begins, and it is also where employers have some of the greatest power to prevent it. Responsible recruitment means ensuring the channel bringing workers into your organisation does not extract illegal fees, misrepresent the job, or trap workers in debt before they even start.

Core principles

  • No worker-paid recruitment fees. Consistent with the Employer Pays Principle, legitimate recruitment costs should be borne by the employer, not deducted from a worker's future wages.
  • Transparent contracts. Workers should receive a contract in a language they understand, before they pay any fee or travel, matching the terms they were originally offered.
  • Verified agents only. Employers should use only licensed recruitment agents, and should periodically re-verify them — ILSI's agent verification tool can support this.
  • No document retention. Employers and their agents should never hold a worker's passport as a condition of employment.

How ILSI supports employers

ILSI can review your current recruitment channels against these principles, help you identify where a sub-agent may be charging illegal fees without your knowledge, and support you in moving to a fully employer-pays model. This work often overlaps with our due diligence reviews and can lead to ILSI accreditation for employers who meet our standards.

To start a review of your recruitment practices, request a consultation with our employer engagement team.

Why this benefits employers, not only workers

Recruitment fraud and fee abuse are not only a worker protection problem. Employers whose recruitment channels are compromised face real business risk: reputational damage if exploitative practices become public, higher turnover as workers who arrive under false pretences leave at the first opportunity, and increasing scrutiny from buyers and regulators applying labour due diligence requirements further up the supply chain. Responsible recruitment is, in this sense, a risk-management practice as much as an ethical one.

Where sub-agents create hidden risk

Many recruitment problems occur not with an employer's directly contracted agency, but several layers removed — a licensed agency subcontracting to a local sub-agent who is not properly overseen. Employers are often unaware this is happening until a worker complaint or ILSI casework surfaces it. Mapping this full chain, not just the first-tier relationship, is a core part of the review ILSI offers.

Need help, or want to get involved?

Whether you're a worker, a family member, a government partner or an employer, ILSI is ready to support you.