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HOPS Recruitment Fees Policy

Introduction


HOPS is committed to the International Labour Organization Standards and the Employer Pays Principle concerning payment for work. This is communicated with our business partners and clients, along with our zero-tolerance approach to work finding fees being forced on to our seasonal workers. Through frequent auditing and working closely with our business partners, clients, and seasonal workers, where evidence of fee charging is discovered effective action and remediation is ensured.

 

We define recruitment fees and related costs according to the International Labour Organization Standards: workers shall not be charged directly or indirectly, in whole or in part, any fees or related costs for their recruitment.

 

Scope


This policy applies to the recruitment, and subsequent employment/engagement of any seasonal worker recruited by HOPS, including:  

                                                                                           

  • Labour Recruiters.

  • Suppliers and Service Providers.

  • Recruitment Intermediaries and sub-agents.

  • Organisations providing services for workers during recruitment and employment, e.g. health centres, insurance providers, visa processing providers, travel agents, training providers, translation agencies, accommodation agents and any other relevant business partners.

  • Labour User/ clients.

 

HOPS include the principles and terms of implementation of this policy in all contracts and service level agreements with all supply chain business partners and clients, with sanctions in case of violation. 

 

Accountability

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The HOPS Senior Management Team and Compliance have the responsibility to oversee the implementation of this policy throughout the business. Implementation requirements include: 

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  • Overseeing all necessary activities to uphold our business commitment.

  • Provide support and training for all relevant staff, to understand and uphold this policy. 

  • Complete appropriate labour supply chain due diligence. 

  • Investigate suspected or identified cases of illegal fee charging and identify appropriate remediation.

  • Monitor, review, and improve this policy from key learnings.

 

 

Policy Commitments

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  • Ensuring recruitment fees or related costs are not charged directly or indirectly to workers. “Indirectly” in this context means: 

    • Charging workers for purportedly optional services, which are, in fact, integral to the recruitment process.

    • Making the provision of recruitment services conditional on the worker using other services or hiring or purchasing goods supplied by the recruiter/employer or any person connected. 

  • Not charging back or accepting reimbursement from workers to recover any fees in the recruitment or hiring of the worker.

  • Ensuring that any expenses payable by workers that are not included in the definition of recruitment fees or related costs, comply with legal requirements, reflect fair market value, are itemised, and are specified, explained to workers, are optional where relevant and understanding by workers is checked.

  • Ensuring that contracts, offer letters, or any other types of communication with workers clearly state that recruitment fees and related costs will not be charged to them. 

  • Ensuring that all public communications, including our website and job advertisements, clearly indicate our commitment to no work finding fees and advocate for wider adoption of this approach amongst business networks.  

  • Ensuring that our staff understand the importance of workers not paying for work.

  • Providing full transparency of our labour supply chain to customers, and our relevant policies that commit to eliminating recruitment fees.

  • Undertaking our own due diligence to ensure responsible recruitment throughout our labour supply chain.

  • Ensuring contracts, service level agreements, tender documents and guidance documents for business partners contain clear requirements in line with this policy that they and their sub-contractors/agents must conform to.

  • Working collaboratively with business partners to agree on a commercial charge rate that demonstrably covers the full costs of recruitment, including the cost of processing applications, interviewing, worker documentation, worker assessment, placement, orientation, training, and travel to the destination country in the case of migrant workers recruited in their country of origin.

  • Reviewing purchasing practices to ensure there is no unintended impact on charging of recruitment fees such as short lead times, short-term contracts, sudden changes in workload, poor labour planning or unsustainable purchase prices. 

  • Engaging with other industry representatives to share best practices to help identify and eliminate recruitment fees.

  • Terminating contracts with any business partners where there has been a gross violation of terms and explicit intent to exploit workers after ensuring workers will not be negatively impacted by this termination. 


Remediation of Recruitment Fees 


HOPS commit to the following:

  • Proactively engage with workers and encourage communication:

    • HOPS follow our Worker Feedback and Communications Policy:

      • HOPS will regularly interview applicants and workers confidentially and anonymously, to identify cases where workers have paid recruitment fees or related costs. 

      • HOPS regularly send welfare surveys out to workers, which includes reference to fee paying/ costs, and review all feedback provided. 

  • Providing access to all workers, staff, business partners and other stakeholders to report violations of this policy, through the sharing of HOPS contact details. Multiple options are provided.

  • Use the HOPS Complaints Procedure/ Incident Response and Action Plan, which documents an escalation process.

  • Where payment of recruitment fees by workers has been identified, ensuring the following is actioned (but are not limited to):

    • HOPS will treat all cases sensitively and will not compromise the safety and trust of any workers and, will maintain integrity and transparency throughout the process.

    • Conducting a thorough investigation to determine who is responsible for the violation and whether this was within reasonable due diligence control. 

    • Gathering all available evidence relating to the charging of recruitment fees.

    • Recording the outcomes of any investigation and remediation as part of a management systems approach, including a 360 closed loop process.

    • Where evidence of non- compliant fee charging is discovered, workers will be reimbursed by the person/ business that has enforced these charges.

    • Document what remediation has been agreed, with whom and the timeframe for this to take place, using the HOPS Remediation Report Form. 

    • All learnings are discussed and relevant changes implemented into HOPS operational practise, polices and processes.

  • Wilful staff breaches of this policy will be treated as misconduct and will be managed consistently and proportionately.

  • Report breaches directly to the GLAA and where necessary, the Modern Slavery Helpline.

  • Intervention visits will be completed by a HOPS Senior Team member, if a significant issue is identified, where appropriate.

  • Where Modern Slavery or exploitation has been identified, the GLAA, UK Police, Non-Government Organisations and charities who have expert knowledge and experience in supporting potential victims will be informed of such cases.

  • HOPS will support all criminal investigations and suspected victims of Modern Slavery or exploitation.

 

This policy is aligned with the HOPS Remediation Policy.
 

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