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Despite the growing awareness of and commitments to ethical recruitment, an analysis of CUMULUS Forced Labor Screen™ data from 2019 to the present reveals that fewer than 5% of employers fully absorb the cost of cross-border recruitment, including all fees and related costs. Instead, those costs continue to be passed on to foreign migrant workers. This data is based on a review of more than 600 employers and their recruitment agents, with employers operating in Southeast Asia, the Middle East, the Gulf Cooperation Council region, North Africa, and Europe and in industries as diverse as electronics, apparel, consumer goods, food, logistics, construction, extractives, and hospitality.
Two years since the platform’s launch, some employers have completed a second annual risk screening. Among this small subset, due to the pandemic, the data indicates there may be cause for optimism. Employers that have recruited new cohorts of foreign workers have begun to establish agency relationships, systems, and processes that are foundational to fully absorbing the cost of ethical recruitment—and, significantly, to holding their recruitment agents and other intermediaries accountable for ensuring that workers are not charged for their jobs. The recruitment agents helped client employers recruit and deploy more than 125,000 foreign migrant workers from approximately 40 countries. It’s an important first step toward sustained compliance and safer, fairer labor migration. Others have reimbursed workers for recruitment fees and related costs they should not have been charged.
The CUMULUS Screening Process
The CUMULUS Forced Labor Screen™ is a remote, technology-driven approach to labor supply mapping and predictive forced labor screening in supply chains. CUMULUS gathers information and documents about recruitment practices and recruitment agents from employers (e.g., suppliers, contractors, service providers, franchisees, and other supply chain business partners) via a secure online platform. Verité then analyzes the data using a detailed and targeted Due Diligence Assessment (DDA). DDA focuses on contractual and financial relationships, as well as recruitment, deployment, and management systems specific to migrant worker populations.
Reflective of the international definition of forced labor (Convention 29 of the International Labour Organization), Verité employs a comprehensive framework to flag risks related to the practices of employers and their recruitment agents. Issues that trigger risks include deceptive recruitment, nonexistent or inadequate financial and contractual relationships between employers and agents, ineffective due diligence and controls, induced indebtedness, restrictions on freedom of movement, worksite practices, and lack of transparency. Risks related to recruitment agents, including publicly available information, are confidentially shared on member company dashboards on a limited and source-redacted basis. ™
Ethical Recruitment: the Exception, Not the Norm
Almost 80% of risks across all sectors and regions reported on the platform indicate that ethical recruitment is still very much the exception, while the norm remains that most workers end up paying for the recruitment fees and costs associated with their jobs. While many of the employers claimed they—not workers—paid the recruitment fees and costs, documentary evidence provides clear and convincing proof that the overwhelming majority did not pay all identifiable and quantifiable costs, particularly those incurred in sending countries. A sizeable minority of employers acknowledged that they do not pay all these costs. In other cases, CUMULUS analysts were able to determine that employers had knowledge of collusive and even illegal arrangements between recruitment agents in receiving and sending countries to charge foreign workers up to $5,000 in recruitment fees and costs prior to departure.
CUMULUS data reveals there is very little understanding of the contractual and financial relationship between employers and their agents, the true costs needed to underpin ethical recruitment, let alone the effort needed to change the underlying dynamics. Verification of recruitment fees and related cost payments between employers and recruitment agents has proven to be an objective and scalable technique in assessing the effectiveness of ethical recruitment implementation.