Recruitment fees and debt bondage risk in supply chains

Debt bondage is one of the ILO's eleven indicators of forced labour. In supply chains it typically follows a recognisable sequence:

1. A worker pays a recruiter or sub-agent to secure a job, often abroad.
2. The fee exceeds savings, so the worker borrows — from family, a moneylender or the recruiter.
3. On arrival, wages are lower than promised (deception) or reduced by deductions for housing, transport or equipment.
4. The debt cannot realistically be repaid within the contract, so the worker cannot afford to leave.

No single step is necessarily unlawful everywhere. Together they produce a worker who is not free to refuse work.

ILO Convention No. 181 provides that private employment agencies shall not charge, directly or indirectly, in whole or in part, any fees or costs to workers (with limited exceptions set by national law). The ILO's general principles and operational guidelines for fair recruitment state that no recruitment fees or related costs should be charged to, or otherwise borne by, workers or jobseekers, and define what counts as fees and related costs.

Many company codes of conduct adopt the same position, often called the employer pays principle. Whether it is legally required depends on the jurisdiction; whether it is followed depends on the whole recruitment chain, not just the direct supplier.

Risk sits in the recruitment model as much as in the country or sector. Questions that separate higher from lower risk:

• Does the site use labour agencies, and are the agencies (and their sub-agents) known by name?
• Are workers recruited across borders or from distant regions?
• Is there a written no-fee policy, and does it cover sub-agents in the sending country?
• Can the supplier show who paid travel, visa and medical costs for a sample of workers?
• Do payroll records show recurring deductions that are not explained in the contract?
• Have fees found to have been paid ever been reimbursed — and how was that verified?

• Establish the amounts with workers directly, not only from agency records.
• Repay workers, not intermediaries, through a channel workers control.
• Record who verified repayment and how — and whether workers confirmed receipt.
• Change the recruitment practice that caused the fee, or the remediation will recur.
• Monitor through follow-up worker voice, not a one-off attestation.

Repayment claimed but not verified with workers should stay open in the record. That is how Libera's remediation tracking treats it.

Libera does not publish proprietary estimates of fee prevalence; we have no such dataset. For prevalence and sector exposure, consult the ILO and the US Department of Labor sources linked below.