Despite the growing awareness of, and commitments to, ethical recruitment, an analysis of CUMULUS data from early 2019 to the present reveals that less than five percent of employers fully absorb the true cost of cross border recruitment, including all recruitment fees and related costs. Instead, those costs continue to be passed on to foreign migrant workers. This data point is based on a review of nearly 150 employers and several hundred of their recruitment agents across multiple regions and industries, with employers operating in Southeast Asia, the Middle East, the Gulf Cooperation Council region, North Africa, and Europe; they employ workers in industries as diverse as electronics, apparel, consumer goods, food, logistics, and hospitality. Their recruitment agents recruited and deployed tens of thousands of foreign migrant workers from more than a dozen countries.
Eighteen months since the platform’s launch, some employers have now completed a second annual risk screening. Among this subset, the data indicates there may be cause for optimism. Employers who have recruited new cohorts of foreign workers have begun to establish agency relationships, systems, and processes that are foundational to fully absorbing the true 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. It’s an important first step toward sustained compliance and safer, fairer labor migration.
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 (typically 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). The 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 risk framework to flag risks related to the practices of employers and their recruitment agents. Issues that trigger risks include deceptive recruitment, non-existent 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 also confidentially shared on member company dashboards on a limited and source-redacted basis.
Ethical Recruitment: The Exception, Not the Norm
Almost 80 percent of all risks across all sectors and regions reported on the platform indicate that ethical recruitment is still very much the exception, while the norm remains: most workers pay for 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 readily acknowledged that they do not pay all of 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 USD 5,000 in recruitment fees and costs prior to departure.
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