When Policy Meets Reality: Obstacles to eliminating debt bondage from responsible recruitment

Authors

  • Ana Maria Soto Bernal
  • Lisa Rende Taylor
  • Mark Taylor

DOI:

https://doi.org/10.14197/atr.201226266

Keywords:

responsible recruitment, Employer Pays Principle, debt bondage, Human rights due diligence (HRDD), supply chains

Abstract

‘Employer Pays Principle’ (EPP) responsible recruitment policies of multinational enterprises (MNEs) aim to reduce risks of forced labour in supply chains by requiring all costs of labour recruitment to be borne by employers, not workers. Based on in-depth interviews with almost 4,000 foreign migrant workers in Japan, Malaysia, and Thailand conducted between 2020 and 2025, this paper investigates how effectively EPP policies were implemented across supply chains. Less than ten per cent of respondents experienced truly zero-fees recruitment. All others had to pay some or all of the costs of recruitment up front, with 14.6 per cent being indebted in the process, and only 12.2 per cent ever receiving reimbursement for some or all fees paid. When significant recruitment fees were discovered, most suppliers resisted reimbursing the full amount. Most MNEs were not willing to require the full amount be repaid to affected workers, nor share the reimbursement costs. The paper concludes by calling on MNEs to adopt more responsible contracting practices to make EPP recruitment possible by suppliers; share responsibility for reimbursing recruitment fees to impacted workers in their supply chains; and consider as not EPP-compliant suppliers employing workers who have paid recruitment fees, even if they reimburse them later.

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Author Biographies

Ana Maria Soto Bernal

Ana Maria Soto Bernal is the Director of Impact and Innovation of Issara Institute. She has worked on human trafficking and forced labour issues for eight years, and has led research on ethical recruitment and recruitment-related fees, empowerment approaches for trafficking survivors, and workers engagement mechanisms in the seafood sector. She holds a Master of Arts Degree in Human Rights from Mahidol University, Thailand.

Lisa Rende Taylor

Dr Lisa Rende Taylor is the Founder and Executive Director of Issara Institute. She has worked on human trafficking and forced labour issues for over 20 years and is a behavioural ecologist with a Ph.D. from the University of Washington.

Mark Taylor

Mark Taylor is Senior Director, Strategy and Global Partnerships of Issara Institute. He holds an MBA from Georgetown University and has been working in Asia for over 20 years on sustainability, private sector development, and business and human rights in global supply chains.

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Published

26-04-2026

How to Cite

Soto Bernal, A. M., Rende Taylor, L., & Taylor, M. (2026). When Policy Meets Reality: Obstacles to eliminating debt bondage from responsible recruitment. Anti-Trafficking Review, (26), 97–115. https://doi.org/10.14197/atr.201226266