Responsible Maritime
Recruitment
Hero

Ending Illegal Recruitment
Fees in Maritime

Illegal recruitment fees push seafarers into debt, erode vessel safety, and expose shipping companies to growing legal and reputational risk. This resource combines the latest research evidence with a practical compliance toolkit for employers.

What can companies do? The Employer Toolkit

This is a risk management and compliance toolkit for shipping companies to help them identify risks in the system of seafarers having to pay illegal fees directly or indirectly, and mitigating those risks effectively.

The framework is structured across five sequential phases — from internal baseline assessment and budget transparency, through crewing agency due diligence and ongoing monitoring, to escalation protocols. Industry engagement, the last box, can go on throughout. The phases move from foundational controls to active oversight, with collective action sitting alongside. The toolkit is designed to be used as a living compliance instrument, not a one-time audit.

Outset Check

Foundational requirements — apply before engaging any crewing agency

Check A

Use only reputable and ethical crewing agencies

  • Check your agency is registered with the relevant national government department
  • Check the agency is not on any banned list

Check B

Engage worker representatives where possible

  • Consult with recognised unions or worker representative bodies where possible
  • Carry out due diligence on the independence of the local union(s)
  • Check that they can engage seafarers confidentially, and raise concerns independently of the employer or agency

1. Carry out internal baseline assessment

Internal audit — conduct before engaging any external agency

Gate A

Has your recruitment & crewing process been independently reviewed for MLC 2006 compliance?

  • Review date on record?
  • Findings documented and remediation tracked?
  • Reviewer independent of crewing function (internal audit, legal, or external party such as LRQA or DNV)?
  • ISO 9001 or equivalent quality system in place? (positive indicator, not required)

Gate B

Is there an accessible, confidential reporting channel — and do seafarers actually know it exists?

  • Channel reachable by seafarers directly?
  • Seafarers informed of it before and during employment?
  • Non-retaliation policy in writing and actively communicated?
  • Process defined for what happens when a report arrives?
  • No reports received? → Verify awareness, not a failure in itself

Gate C

Do your crewing agency contracts contain explicit, enforceable zero-fee clauses?

  • Written prohibition on charging seafarers any recruitment fee?
  • Clause covers sub-agents and third parties used by the agency?
  • Defined consequences for breach — including termination of contract?
  • Contract reviewed and re-signed at every renewal?
  • Legal team has verified enforceability under local law of the agency's country?

Gate D

Do you systematically collect feedback from seafarers — before, during and after the recruitment process — to verify no fees are being charged?

Pre-boarding

  • Asked at sign-on or induction: "Did you pay anything to secure this position?"
  • Responses logged and reviewed — not filed and forgotten

Onboard

  • Confidential survey during the contract — not only at sign-off when seafarers may feel vulnerable
  • Survey accessible in seafarers' own language
  • Results fed back to compliance function

Post-disembarkation

  • Survey sent after contract ends — when seafarers are ashore and feel safer speaking freely
  • Patterns across agencies and nationalities tracked over time

2. Examine budget & cost transparency

Verify all recruitment costs are employer-paid and fully itemised

Gate E

Is your recruitment budget itemised in enough detail to detect if any costs are being passed on to seafarers?

  • Each cost category broken out separately — agency fees, medicals, visa, travel, training, uniforms?
  • Named budget owner accountable for every line?
  • Budget granular enough that a shift of costs onto seafarers would be visible?

Gate F

Do you actively reconcile what agencies invoice against what seafarers are actually paid?

  • Agency invoices cross-checked against seafarer payslip deductions?
  • Manning agent commissions declared and verified against actual charges?
  • STCW renewals, medicals and document fees confirmed as employer-paid?
  • Any gap between what was invoiced to the company and what the seafarer paid treated as a red flag?

3. Carry out due diligence on crewing agency(ies)/operations

Apply before onboarding and at every contract renewal

Mandatory questions to ask every crewing agency

  • How many seafarers do you currently place, by rank and nationality?
  • When were you last audited — by whom, and what were the findings?
  • How do you handle a seafarer complaint about recruitment fees?
  • Where are seafarers paid — local currency, USD, via which bank?
  • Can we visit your offices and interview seafarers unannounced?
  • Are your seafarers aware of MLC Guideline B2.5.1 no-fee provisions?
  • Do you charge seafarers any fee at any stage of the recruitment process?
  • What measures do you have in place to ensure that sub-agents are not charging recruitment fees?
  • Do you ever hold seafarer passports, certificates or documents as security at any stage?

Apply enhanced controls in higher-risk geographies — Where recruitment fee risks are known to be higher and/or more widespread (see research https://www.ihrb.org/resources/seafarers-and-illegal-recruitment-fees), companies should apply enhanced due diligence, closer oversight of sub-agents, stronger worker feedback mechanisms, and more frequent monitoring.

4. Carry out ongoing monitoring

Structured controls at monthly, quarterly and annual intervals

Monthly

Payslip Spot-Check

  • Sample 10% of seafarer payslips
  • Flag any unlabelled deductions
  • Cross-reference with seafarer invoices

N.B. Not needed if you're issuing the payslips

Quarterly

Seafarer Interviews

  • Confidential, onboard or remote
  • Log responses - investigate any instances of fee-paying

Annually

Agency Audit Visit

  • Physical site visit — announced & unannounced
  • Review agency’s own seafarer files
  • Interview agency staff independently
  • Make sure your company is on the register
  • Advocate for your approved agencies to join

Continuous

Hotline Monitoring

  • Reports reviewed within 48 hours
  • Seafarers informed of outcome
  • Trends reported to board quarterly

Continuous

Digital Verification

  • Support the development of digital document verification services, such as ICS's ISF Verify.

Monitoring should be proportionate to risk. Agencies operating in higher-risk geographies (see research https://www.ihrb.org/resources/seafarers-and-illegal-recruitment-fees), or through more complex subcontracting chains, may require more frequent checks and deeper worker engagement.

5. Follow escalation decision tree

Structured response protocol when a violation is identified

Trigger 1 — Seafarer Report

A seafarer reports paying a recruitment fee

  • Report via a hotline, survey or direct disclosure
  • Report made during or after employment
  • Report made anonymously or by name

Trigger 2 — Internal Detection

Evidence identified through internal controls

  • Payslip spot-check reveals unexplained deductions
  • Invoice reconciliation uncovers discrepancy
  • Onboard or post-disembarkation survey flags a pattern

Trigger 3 — Agency Incident

Violation detected at a manning or crewing agency

  • Audit or unannounced inspection reveals fee-charging
  • Sub-agent found operating outside contracted standards
  • Agency appears on government suspended list or industry alert
  • Third party (ITF, NGO, port authority) flags the agency

Step 1 — Immediate

Protect the seafarer

  • Ensure no retaliation risk — document protection given
  • Reimburse any fees paid — record transaction
  • Seafarer's employment not affected by report
  • Return any withheld documents immediately
  • Connect seafarer to support if needed: ITF, Mission to Seafarers, ISWAN — more information can be found here.

Step 2 — 72 Hours

Review agency relationship

  • No new placements during investigation
  • Notify agency in writing — request full disclosure
  • Internal legal & HR informed

Step 3 — Investigation

Investigate

  • Independent investigator appointed where appropriate
  • Evidence documented — consider legal advice if systemic
  • Work with agency to remove recruitment fees
  • Review agency relationship based on findings
  • Report to flag state / ITF if systemic

Engage With Industry

Beyond internal compliance — contributing to sector-wide change

Make a Declaration

Commit publicly to a no recruitment fee policy.

Join the Action Group

Peer accountability with fellow shipping companies, insurers, investors and other stakeholders. Share intelligence on high-risk agencies and geographies.

📋

Responsible Recruitment Register

Make sure your company is on the Register. Advocate for your approved agencies to join. Drives industry-wide standards upward.

Share Case Studies

Anonymised experiences help others identify patterns. Your compliance journey is intelligence for the entire sector.

Get in touch

Contact

Francesca Fairbairn
Shipping and Commodities
IHRB
[email protected] ihrb.org
Isabelle Rickmers
CEO
TURTLE
[email protected] go-turtle.com