Recruitment-fee indicators at Meridia Stitching (synthetic)
Synthetic pilot case. Repeated grouped worker indicators at a single fictional site pointed to placement fees charged by a third-party recruiter. Opened for human review; risk indicators only, not a finding of forced labour.
- Supplier
- Meridia Stitching (synthetic)
- Site
- Gaziantep Stitching Hall (synthetic)
- Owner
- Compliance lead (synthetic)
- Escalated from
- Confidential worker signals
- Opened
- 13 Oct 2026
- Target review
- 28 Nov 2026
- Closed
- —
- Baseline risk
- 44/100
Türkiye · Textile & garments · 480 workers · Third-party labour agency · seasonal migrant workforce
Screening only
Worker-signal aggregate
9 confidential signals · 1 marked severe · 5 indicators
- · recruitment fee or debt
- · wages withheld or deducted
- · identity documents withheld
- · excessive or forced hours
- · threats reported
Aggregated counts only — individual worker messages are never attached to a case
Outcome
Control weakness identified
Why this risk?
Baseline 44/100 · headline HIGH · raised by worker signalsWhat increased the risk
- · Country-level forced-labour prevalence and state-response gap in Türkiye.
- · Textile & garments is a high-intensity sector for forced-labour indicators.
- · Workers are recruited through intermediaries, a recognised debt-bondage pathway.
- · 9 confidential worker signals across 5 indicators.
Evidence that supports it
- · Published country datasets referenced in the score breakdown.
- · Supplier record states recruitment via intermediaries.
- · Aggregated indicator counts from the confidential worker channel.
Evidence that is missing
- · Recruiter identities and recruitment-fee records.
- · Official-list screening result for this supplier.
What to review next
- · Request the recruiter list, recruitment contracts and any fee or deduction records.
- · Run sanctions and import-ban screening on the supplier name.
- · Review the grouped indicator pattern and decide whether a documented case is required.
Evidence contributors
Inherent country risk
Evidence on file · 35/55 ptsTürkiye — published prevalence and state-response data
- · Country prevalence: 15.6 people in modern slavery per 1,000 population · rank 5 of 160
- · State response gap: Government response rated moderate (49/100); ILO Forced Labour Protocol P029 not ratified
Sector risk
Evidence on file · 22/25 ptsTextile & garments — sector exploitation intensity
- · DOL TVPRA: garments, cotton and footwear listed for many sourcing countries
Supplier attributes & intermediaries
Evidence on file · 14/23 ptsRecruitment via intermediaries recorded
- · recruitment via intermediaries (ILO indicator: deception / debt bondage)
- Missing: No recruiter list, recruitment contracts or fee records are recorded in the evidence register.
Official-list intelligence
Evidence on file · 12/22 ptsNo official-list screening recorded for this supplier
- · Goods listed for this country & sector: Textile & garments goods from Türkiye appear on the US DOL forced/child labour list
- Missing: Sanctions / import-ban screening has not been run and stored.
Confidential worker signals
Evidence on file9 confidential signals · 1 marked severe
- · 3× recruitment fee or debt
- · 3× wages withheld or deducted
- · 1× identity documents withheld
- · 1× excessive or forced hours
- · 1× threats reported
Worker-access confidence
Evidence on fileAccess points verified at the last recorded check
- · 5/5 agreed access points available at the last recorded check · Asteron sourcing team (synthetic) · All agreed access points restored and photographed.
Remediation & case history
No evidence availableNo documented case or remediation history for this supplier
These are risk indicators and evidence contributors, not proof of forced labour. The breakdown is generated deterministically from data stored in this workspace; it is not an allegation and it is not a legal finding.
Suggested investigation steps
6 suggestions · human review requiredRequest recruitment contracts and fee records
Suggested firstAsk the supplier for the recruiter agreement, worker contracts and any record of fees, deposits or salary deductions charged to workers in the last 12 months.
Triggered by: recruitment fee or debt — Recruitment-debt indicators are examined against documentary evidence of who paid what to whom. The ILO no-worker-pays principle is the reference point.
Request payroll and time records
Suggested firstRequest payroll registers, payslips and time records for the affected period, and reconcile hours worked against amounts paid.
Triggered by: wages withheld or deducted — Wage-withholding indicators can only be assessed against payroll and time data; the reconciliation itself is the evidence.
Verify document access and return policy
Suggested firstAsk for the written policy on identity documents, confirm where documents are stored, and confirm workers can retrieve them on request without conditions.
Triggered by: identity documents withheld — Retention of identity documents is an ILO forced-labour indicator; the check is whether workers retain free access, not whether a safe exists.
Request rosters and working-time sheets
Standard stepRequest shift rosters, overtime authorisations and time sheets, and check them against contractual and legal limits and against voluntariness of overtime.
Triggered by: excessive or forced hours — Excessive-hours indicators are assessed against scheduling records and the question of whether overtime can be refused without penalty.
Request the supplier's written response
Standard stepShare the neutral indicator summary with the supplier and record their written response in the evidence register.
Triggered by: case under review — A documented supplier response is standard due-diligence evidence and is suggested for every case under review.
Specialist review and worker-safety precautions before any site contact
Specialist reviewDo not raise the indicator with site management before a safety assessment. Consider specialist or legal review and confirm local emergency and safeguarding routes.
Triggered by: threats reported — Where intimidation indicators are present, an ordinary supplier enquiry can expose workers to retaliation. Libera is not an emergency service.
Suggested review steps are generated from a fixed indicator-to-step template table. They are suggestions for a human reviewer, not findings, allegations or case outcomes, and nothing is added to the case until someone accepts it.
Investigation timeline
Case opened
13 Oct 2026 · 10:12 · Compliance lead (synthetic)
Grouped worker signals across recruitment debt, wages and identity documents crossed the human-review threshold at one site.
Worker-signal pattern reviewed
13 Oct 2026 · 10:12 · Compliance lead (synthetic)
Aggregated indicator counts reviewed. Individual worker messages were not accessed; only grouped counts per indicator are available to management.
Evidence requested
14 Oct 2026 · 10:12 · Compliance lead (synthetic)
Recommended investigation steps accepted by a human reviewer: recruitment contracts, fee records and payroll for the last three months requested.
Supplier contacted
15 Oct 2026 · 10:12 · Responsible sourcing (synthetic)
Supplier notified in writing and asked to nominate a contact for the documentation review.
Evidence received
20 Oct 2026 · 10:12 · Supplier (synthetic)
Recruiter agreement, placement-fee schedule and payroll extract received from the synthetic supplier.
Follow-up review
22 Oct 2026 · 10:12 · Compliance lead (synthetic)
Documentation review in this synthetic scenario indicates a third-party recruiter charged placement fees to incoming workers. Recorded as a control weakness for remediation; not a legal finding.
Remediation action created
23 Oct 2026 · 10:12 · Compliance lead (synthetic)
Four remediation actions created with owners and due dates.
Evidence received
25 Oct 2026 · 10:12 · Responsible sourcing (synthetic)
Worker-access follow-up check recorded 5 of 5 agreed access points available at the site.
Remediation completed
27 Oct 2026 · 10:12 · Responsible sourcing (synthetic)
Fee reimbursement reconciled against the payroll extract and the recruiter agreement terminated.
Status changed
28 Oct 2026 · 10:12 · Compliance lead (synthetic)
Case moved to Monitoring. Follow-up worker check scheduled and the confidential channel remains open at this site.
Evidence register
Aggregated worker-signal summary (synthetic)
Document · 13 Oct 2026Source: Libera confidential channel
Indicator counts only. No individual worker message, identity or contact detail is stored in or accessible from this case.
Worker-access check record (synthetic)
Document · 06 Oct 2026Source: Buyer check
2 of 5 agreed access points available at an unannounced check on day 7.
Third-party recruiter service agreement (synthetic)
Contract · 20 Oct 2026Source: Supplier submission
Fee-schedule annex lists a placement charge payable by the worker.
Payroll extract, three months (synthetic)
Payroll record · 20 Oct 2026Source: Supplier submission
Recurring deduction line consistent with repayment of a placement fee.
Supplier written response (synthetic)
Supplier response · 21 Oct 2026Source: Supplier
Supplier confirms the recruiter was engaged for seasonal hiring.
No-worker-pays recruitment policy, signed (synthetic)
Policy · 26 Oct 2026Source: Supplier
Signed policy annex added to the synthetic supplier agreement.
Follow-up worker-access check record (synthetic)
Document · 25 Oct 2026Source: Buyer check
5 of 5 agreed access points available; photographs retained by the synthetic buyer.
Evidence metadata only · confidential worker submissions are never attached
Evidence chain
2 gaps1. Signal / indicator
complete- · recruitment fee or debt
- · wages withheld or deducted
- · identity documents withheld
- · excessive or forced hours
- · threats reported
2. Source / evidence reviewed
complete- · Aggregated worker-signal summary (synthetic) · Libera confidential channel
- · Worker-access check record (synthetic) · Buyer check
- · Third-party recruiter service agreement (synthetic) · Supplier submission
- · Payroll extract, three months (synthetic) · Supplier submission
- · Supplier written response (synthetic) · Supplier
- · No-worker-pays recruitment policy, signed (synthetic) · Supplier
- · Follow-up worker-access check record (synthetic) · Buyer check
3. Investigation step
complete- · Worker-signal pattern reviewed
- · Evidence requested
- · Supplier contacted
- · Evidence received
- · Follow-up review
- · Remediation action created
- · Evidence received
- · Remediation completed
4. Finding / assessment
complete- · Control weakness identified
5. Remediation action
partial- · Reimburse recruitment fees to affected workers · verified
- · Terminate non-compliant recruiter relationship · completed
- · Verify identity documents are held by workers · completed
- · Independent follow-up worker check · not started
1 remediation action(s) still open.
6. Verification / monitoring
partial- · Verified: Reimburse recruitment fees to affected workers
- · Case is under ongoing monitoring
3 remediation action(s) have no independent verification recorded yet.
The chain is assembled from records stored in this case file. A complete chain documents that a step was recorded — it does not certify the quality of the underlying evidence, and it is not a legal conclusion.
Remediation actions
Reimburse recruitment fees to affected workers
VerifiedReimbursement calculated per worker and paid through the regular payroll run. Triggered by: recruitment fee or debt indicators.
Supplier finance (synthetic) · due 27 Oct 2026 · completed 26 Oct 2026
Verification: Reimbursement reconciled against the payroll extract by responsible sourcing (synthetic).
Terminate non-compliant recruiter relationship
CompletedEnd the agreement with the recruiter that charged placement fees.
Supplier management (synthetic) · due 26 Oct 2026 · completed 26 Oct 2026
Verify identity documents are held by workers
CompletedSpot check that passports and permits are in the workers' own possession.
Site management (synthetic) · due 28 Oct 2026 · completed 28 Oct 2026
Independent follow-up worker check
Not startedFollow-up review to confirm the pattern of indicators has stopped.
Compliance lead (synthetic) · due 23 Nov 2026
Remediation effectiveness
Unverified
- · 1 of 4 remediation action(s) are still open. Some verification is on file (1 verified), but effectiveness cannot be assessed until every action is complete.
- · The case is in monitoring, so the status will be reassessed at the next follow-up.
To strengthen the assessment
- · Complete the open actions, then verify each one independently.
Effectiveness is a categorical status derived from records stored in this case file. It reflects what has been documented and verified, not a guarantee that a risk has been eliminated.
Libera provides risk indicators and due-diligence workflow support. It does not make legal findings and does not conclude that forced labour has occurred. Every conclusion in this record is a human judgement made by the case owner.
