Responsible Maritime Recruitment in Practice

Responsible Recruitment in Practice

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.

These pages contain information to help shipping companies detect and eliminate the charging of illegal seafarer recruitment fees in their operations. They cover the following:

  1. What are recruitment fees (this page)
  2. How pervasive is the practice of charging seafarers recruitment fees
  3. What can employers do? [link]

What are recruitment fees? (Heading block no anchor)

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According to the ILO Maritime Labour Convention 2006 (as amended), “no fees or other charges for seafarer recruitment or placement or for providing employment to seafarers are borne directly or indirectly, in whole or in part, by the seafarer, other than the cost of the seafarer obtaining a national statutory medical certificate, the national seafarer’s book and a passport or other similar personal travel documents, not including, however, the cost of visas, which shall be borne by the shipowner…”

In addition to recruitment fees are a host of additional costs whose legitimacy and responsibility are not clear in law. There are also costs and charges that violate not only MLC but anti-corruption norms and national law. The below graphic aims to encapsulate all of these. Costs can accumulate all along the seafarer’s journey from home (1.) through transit (2.) to vessel (3.). It should be noted that the distinction between the various categories is not always easy to define. It is also not always clear who the employer is or where accountability lies.

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Document Abuse — A Separate But Related Violation

Holding Identity Documents

Retaining passports, certificates of competency, or any other identity documents as "security" at any stage of recruitment or employment.

This is not a recruitment fee — it is a separate and serious violation. Document confiscation is a recognised indicator of forced labour and trafficking under ILO Convention No. 29 and the Palermo Protocol.

How prevalent is the practice? (heading block anchor)

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Joint research by IHRB and TURTLE in 2024 surveyed 2,627 seafarers between May and July 2024. The results confirm that illegal recruitment fees remain endemic across ranks, vessel types, and nationalities — and that the vast majority of incidents go unreported.

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Source: IHRB & TURTLE — Seafarers and Illegal Recruitment Fees: 2024 Insights.
Based on 2,627 seafarer responses, May–July 2024.

Seafarers and Illegal Recruitment Fees: 2024 Insights

Read more

The Employer Toolkit — Recruitment Fee Compliance Framework

Subheading

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)?
  • 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

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?

Crewing Agency Due Diligence

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?

Where are seafarers paid — local currency, USD, via which bank?

Do you charge seafarers any fee at any stage of the recruitment process?

When were you last audited — by whom, and what were the findings?

Can we visit your offices and interview seafarers unannounced?

Are all sub-agents under contract and subject to the same standards?

How do you handle a seafarer complaint about recruitment fees?

Are your seafarers aware of MLC Guideline B2.5.1 no-fee provisions?

Do you ever hold seafarer passports, certificates or documents as security at any stage?

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 agency invoices

Quarterly

Seafarer Interviews

  • Confidential, onboard or remote
  • Log responses; escalate any 'yes'

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

Escalation Decision Tree

Structured response protocol when a violation is identified

Trigger 1 — Seafarer Report

A seafarer reports paying a recruitment fee

  • Report via 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 visit 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 independent support if needed: ITF inspectors · ISWAN SeafarerHelp · Mission to Seafarers · ITFShipBeSure.org

Step 2 — 72 Hours

Review agency relationship

  • No new placements during investigate
  • 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

Industry Engagement

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.