Addressing trafficking and exploitation by recruiters and recruitment agencies,

CPA UK Modern Slavery Team will work with Prof. Parosha Chandran and Commonwealth parliaments to produce a Model Guidelines Document with legal recommendations and examples of provisions to prevent trafficking and slavery by recruiters and recruitment agencies, through forced labour.

Following the successful delivery of the Modern Slavery Project (2016-2020), some Commonwealth parliaments identified abusive and fraudulent recruitment agencies and agents as an important issue happening in their jurisdictions and currently not captured in their legislation.

Labour mobility, while being a positive development as such, comes at a price if it is not properly regulated. All across the world, a disturbing number of reports have emerged about the exploitation and abuse of workers, especially migrants’ workers, by unscrupulous labour recruiters and fraudulent and abusive employment agencies. In some cases, these abuses amount to trafficking in persons for the purpose of forced or compulsory labour.

The ILO highlights the relationship between inadequate mechanisms of recruitment and forced labour, stating that ‘there is growing awareness that many present-day arrangements for recruiting temporary workers display serious deficiencies’. In part, these derive from loopholes in existing labour laws, which fail to articulate the respective responsibilities of recruiting agents and final employers in providing safeguards against abusive, including forced labour. There are also many cases where detailed regulations on fee charging are simply not enforced and workers can, in practice, find themselves paying ten times or more the maximum amount provided for in national laws and regulations.

The existing gaps in the legislative framework alongside the lack of understanding on fraudulent recruitment practices - as a mechanism to trafficking - have left the law enforcement and the judiciary powerless. On several occasions, parliamentarians and legislative drafters have requested CPA UK to support their knowledge on the matter as well as encourage learning exchange across the Commonwealth.

This project is aiming to fulfil this concrete request by assisting and informing parliamentarians and drafters on the issue of fraudulent and abusive recruitment agencies.

Further details on the project will be shared in October 2021. Should you be interested in the project and if you would like to hear more about it, please do not hesitate to contact Adeline Dumoulin at


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Hon. Zeb Jaffar MNA (PAKISTAN)

Hon. Zeb Jaffar MNA (PAKISTAN)

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Micheal Aniekan (NIGERIA)

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