Forced Labour and Recruitment Fees: Understanding the Risks and Taking Action

In recent weeks, news headlines in Finland have included troubling stories about the treatment of migrant workers: substandard pay for Ukrainian refugees, allegations of recruitment fees, long hours, and harassment.

Unfortunately, these are not isolated cases. Recruitment fees charged from migrant workers and the debts that result from them are far from rare. The same goes for excessive working hours, low wages, and a general fear of speaking up.

Forced labour in the Nordics?

The risks of forced labour are very real also here in the Nordic countries. They go far beyond the wild berry supply chains that have often made the news. Similar risks exist across many sectors: catering, cleaning, construction, agriculture, and forestry, to name a few.

As dependence on migrant workers continues to grow, so does the risk of exploitation.

What are recruitment fees?

  • Recruitment fees are any payments or charges that a worker must pay to secure a job. They can be paid to a recruiter, employment agency, employer, or another third party.
  • Recruitment fees also include other expenses connected to the recruitment process. These related costs are for example visa and work permit fees, medical tests, document processing, or pre-departure training fees.
  • Workers often accept these costs as a normal part of international recruitment. Payments are often made to the agencies involved, with no receipts or transparency about what the fees are for.
  • Suppliers and subcontractors employing migrant workers often outsource the recruitment process to third-party agencies, sometimes with little understanding of the risks involved and with very limited oversight.

Why recruitment fees are problematic

→ Recruitment fees can trap workers in debt bondage, which is a key indicator of forced labour. This happens when workers must borrow money to cover recruitment costs, either from the employer, recruitment agents, family members, or moneylenders.

→ Once in debt, workers often feel they cannot leave the job until they have repaid what they owe. In some cases, such as with Thai berry pickers in Finland and Sweden, it may take the entire season just to break even, and those unlucky go home still in debt.

→ When recruitment fees are combined with low pay, withholding of wages, or threats of dismissal, the situation quickly meets multiple ILO indicators of forced labour. Even when not outright coercive, recruitment fees create conditions for exploitation.

→ Workers do not report, because often they don’t know their rights. They may fear losing their job or their right to stay in the country if they speak up. This silence allows unfair practices to continue.

Even companies with strong ethical recruitment policies may fail to detect violations if workers are not reporting abuses.

Charging recruitment fees or related costs is still common practice in many parts of the world.

The Employer Pays Principle (EPP)

The problematic nature of recruitment fees and their link to forced labour have long been recognized by the International Labour Organization (ILO) and others. It is an issue that we at Enact presented in a panel at the 2023 UN Business and Human Rights Forum. To address this issue, the Employer Pays Principles (EPPs) were introduced. Simply put, no worker should pay for a job, but the costs of recruitment should be borne by the employer. Unfortunately, many workers, and even recruiters, are still unaware of this principle or what it means in practice.

What can companies do to tackle recruitment fees?

Eliminating recruitment fees requires further efforts from businesses. Here are some practical steps companies can take:

  1. Commit to the Employer Pays Principle.
  2. Understand how migrant workers are recruited, within your own operations, at your sites, and in your key supply chains.
  3. Set clear expectations for fair recruitment practices for suppliers and recruitment partners – and explain what they mean in practice.
  4. Inform workers about their rights.
  5. Listen to workers experiences – and follow up regularly.
  6. Ensure repayment for any identified recruitment fees.  

Are you ready to ensure that opportunities do not come at the cost of exploitation?


For further reading, see the International Labour Organization’s (ILO) key resources:
ILO Indicators of Forced Labour
Combating Forced Labour: A Handbook for Employers and Business
General Principles and Operational Guidelines for Fair Recruitment