Responsible Recruitment Policy

Executive Summary

Responsible recruitment protects workers at the moment they are most vulnerable: the point of hiring. This policy sets out the fair-recruitment principles Plutonia asks suppliers and their labour intermediaries to follow.

Exploitation often begins with recruitment — through fees, deception, contract substitution, and document retention. Addressing recruitment is one of the most effective ways to prevent forced labour and debt bondage downstream.

This policy is informed by recognised responsible business principles and supports our Forced Labor Policy and Modern Slavery Statement.

Policy Scope

This policy applies across the order chain Plutonia coordinates, including:

• Suppliers, manufacturers, and factories producing goods coordinated by Plutonia
• Subcontractors and second-tier production sites used by those suppliers
• Sourcing agents, trading companies, and intermediaries in the order chain
• Logistics partners, freight forwarders, and warehouse and consolidation providers
• Third-party inspection and testing partners engaged on a project basis
• Plutonia team members involved in sourcing, verification, and logistics coordination

Core Principles

• Workers should not pay for a job (employer-pays principle).
• Recruitment must be honest and free from deception.
• Employment terms must be clear and understandable before work begins.
• Migrant and vulnerable workers receive particular protection.
• Suppliers remain accountable for the conduct of labour intermediaries.

The Employer-Pays Principle

Plutonia supports the principle that the costs of recruitment should be borne by the employer, not the worker. Charging workers recruitment fees that lead to debt is a recognised driver of forced labour and is not acceptable in our network. Where such fees have been charged, suppliers are expected to remediate, including repayment to affected workers.

Clear, Understandable Contracts

• Workers should receive written terms of employment before starting work.
• Terms should be provided in a language the worker understands.
• Wages, working hours, deductions, benefits, and accommodation terms should be disclosed honestly.
• Contract substitution — replacing agreed terms with less favourable ones after arrival — is prohibited.

Migrant and Vulnerable Worker Protection

Migrant workers face higher recruitment risk due to language barriers, unfamiliarity with local law, and reliance on intermediaries. Suppliers must take particular care to protect migrant and other vulnerable workers, must not retain their documents, and must ensure they can resign and leave employment freely.

Licensed Agencies and Recordkeeping

Where recruitment agencies or labour brokers are used, suppliers must use reputable, appropriately licensed intermediaries and remain accountable for their conduct. Suppliers should keep recruitment records that demonstrate fair practices on a risk basis.

Supplier Expectations

Suppliers engaged through the Plutonia network are expected to:

• Apply the employer-pays principle; do not charge workers recruitment fees.
• Provide written, understandable employment terms before work begins.
• Avoid contract substitution and deceptive hiring practices.
• Never retain workers' identity or travel documents.
• Use only reputable, licensed labour intermediaries and remain accountable for them.
• Respect workers' right to resign and leave freely.

Our Due Diligence Approach

Plutonia applies this policy in practice on a risk-based basis, through:

How This Helps International Buyers

Red Flags

On a risk basis, Plutonia watches for practical warning signs relevant to this policy:

• Workers charged recruitment fees or in recruitment debt
• Contract terms changed after the worker arrives
• Contracts in a language the worker cannot read
• Employer retention of passports or identity documents
• Use of unregulated or unlicensed labour brokers
• Workers unable to resign or leave accommodation freely

Corrective Action

Where risks or non-conformities are identified, Plutonia may take the following steps, proportionate to severity:

1. Request clarification and additional information from the supplier
2. Request supporting documentation, records, or evidence of compliance
3. Recommend a time-bound corrective action plan with defined milestones
4. Escalate the finding to the buyer where the order or project is affected
5. Increase verification intensity, including inspection where warranted
6. Suspend new orders pending remediation where risk is significant
7. Reject or remove the supplier where serious issues are not remediated
8. Record findings and actions where required for buyer or tender reporting

Reporting a Concern

Workers, suppliers, clients, logistics partners, and stakeholders may report concerns through Plutonia's grievance mechanism. Reports are treated confidentially, retaliation against good-faith reporters is prohibited, and concerns are reviewed on a risk basis.

Related Policies

Downloadable Resources

PDF documents are placeholders and will be made available here. Each policy can also be read in full online.

Frequently Asked Questions