- International migration provides much-needed incomes and remittances which support source countries.
- But the often-complex recruitment of international migrants creates challenges to responsible supply chains and can lead to severe violations of human rights, including modern slavery and forced labour.
- In late 2018, reports surfaced in the UK that the NHS was using rubber gloves made in Malaysian factories where migrants are allegedly subjected to forced labour. In July 2020, the US Customs and Border Protection
- Companies must work hard to ensure steps are taken so that the initial stages of the recruitment process are fair and transparent.
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Increasing regulatory pressure
The plight of migrant workers
What can companies do
• Set clear requirements for labour providers and recruitment agencies to ensure workers receive correct information and pay no fees for securing employment.
• Set general principles for remediation of policy violations, including repatriation and compensation for costs incurred by workers.
• Ensure that migrant workers are not excluded
Mapping and due diligence
• Establish traceability and assessment of labour providers operating in the source country. Consider partnering with local organisations.
• Establish long-term relationships with recruitment agencies to draw on their expertise and jointly develop risk mitigation.
• Ensure that due diligence processes recognise the different circumstances facing workers due to gender, nationality and ethnicity and adopt appropriate responses.
• Ensure that terms of employment presented to prospective employees in their home countries are correct, legal and match the actual job offered.
• Ensure documentation is kept of all costs incurred by the worker, to ensure adherence to the “employer pays” principle.
• Develop a trusted grievance communication channel so that workers can raise cases of fees-for-work or other noncompliances.
• Companies should report in a structured way how they develop and implement governance, strategy, risk management and performance indicators for recruitment processes in their supply chains.
BMO GAM’s work to build understanding of workers’ rights to freedom of association and collective bargaining is a much-needed step for investment stewardship.