A leading European industrial company discovered through audits that migrant workers from Asia were paying substantial recruitment fees to secure employment in Europe. Many workers remained in debt from these payments, creating a situation of potential forced labor. The client was unaware of these practices and sought expert guidance to address both the immediate situation and implement long-term preventive measures. Ksapa provided the client with a comprehensive understanding of recruitment pathways and fee structures, along with a clear remediation plan. This helped the company rectifying recruitment practices and strengthening its ethical labor practices.
CLIENT CHALLENGE
The company faced a complex ethical and operational challenge requiring immediate action while maintaining operational continuity. Specifically, they needed to:
- Understand the full scope of recruitment fee issues across multiple European sites
- Develop appropriate remediation for workers already affected
- Create sustainable solutions to prevent future occurrences
- Address potentially exploitative living conditions managed by subcontractors
- Navigate the sensitive nature of the investigation without endangering workers
OUR Approach
Phase 1: Gap Analysis
- Review of existing procedures
- Production of an internal risk assessment report to inform the client’s strategy and corrective action plan
PHASE 2: ENGAGEMENT
- Establishing initial communication channels between clients and subcontractors
- Assessing satisfaction and improvement areas regularly
PHASE 3: SOCIAL AUDIT
- Production of an internal audit report through management and worker input, and verified by external audit companies
- Production of a corrective action plan
results & impacts
Through structured engagement with approximately 500 workers across multiple European sites, Ksapa delivered:
- Comprehensive understanding of recruitment pathways and fee structures
- Documentation of outstanding debts and their impact on workers’ freedom
- Assessment of living conditions and identification of key improvement areas
- Clear remediation plan including debt forgiveness mechanisms
- Stronger subcontractor management protocols with enhanced screening
- Implementation of an ethical recruitment policy with verification systems
- Training program for procurement and site management teams
- Anonymous reporting channel for ongoing monitoring
The company successfully eliminated recruitment fees for existing workers through financial remediation and transformed their approach to migrant worker recruitment. This not only resolved the immediate situation but positioned the client as an industry leader in ethical labor practices.
TAKE ACTION NOW
Don’t wait for audits to reveal labor rights issues in your supply chain. Our specialized engagement approach helps construction companies identify and address recruitment fee problems before they become compliance failures or reputational risks.
Contact us today to schedule a confidential assessment of your migrant labor practices.
Email: contact@ksapa.org
Schedule a consultation to discuss your specific Human Rights needs
Key Frameworks to Learn more: OECD Due Diligence Guidelines | UN Guiding Principles on Business and Human Rights
