Overview

Recruitment is one of the points where exploitation happens. Fees charged to the wrong person, a passport held, a contract that changes after someone has moved country: these are the mechanics of forced labour, and they run through recruiters.

This policy sets out what we will not do and what we check. Our separate Human Rights Policy covers fair treatment and equal opportunity more broadly. Read them together.

1. Scope

This policy applies to ScaleUp Recruitment, our directors, our staff, and anyone working on our behalf, across our own operations and our supply chain.

We are an Australian business working across Australia and internationally. We comply with Australian law, including the Modern Slavery Act 2018 (Cth) and the equivalent state legislation, and with the applicable law of any country where we place a candidate or engage a supplier. Where a local standard is lower than the commitments in this policy, we apply this policy.

Our approach reflects the ILO General Principles and Operational Guidelines for Fair Recruitment.

2. Zero tolerance

We do not tolerate human trafficking, forced labour, bonded or debt labour, child labour, or any other form of modern slavery, in our business or in our supply chain.

This is not a statement of intent. The sections below are the specific things we do and do not do.

3. Recruitment fees are never paid by the candidate

This is the most important commitment in this policy, because worker-paid fees are the most common route into debt bondage.

We do not charge a candidate any fee for finding, securing or keeping work, and we never have. Not a placement fee, not an application fee, not a registration, administration, training, assessment or visa processing charge, and not a deduction from their pay once they start.

Our fees are paid by the client who engages us, in every market we work in.

We do not accept a referral, commission or kickback from a third party that is funded by a charge to the candidate.

Where a supplier or partner in a placement charges candidates a fee, we stop working with them.

4. Identity documents and freedom of movement

We may need to see a passport, visa or identity document to confirm someone's right to work. We sight the original, hand it straight back, and keep a copy on file as the record of that check. Copies are held securely and handled under our Privacy Policy.

We never retain original identity documents. We never hold any document, original or copy, as security for a fee, a debt, or the completion of a contract, and we never use one as leverage over a candidate or contractor. Holding a person's papers is a recognised indicator of forced labour, which is why the line is drawn here rather than left to judgement.

We do not place anyone into an arrangement that restricts their freedom of movement, their ability to leave the employment, or their ability to seek other work.

5. Terms in writing, before they commit

Every candidate receives the terms of a role in writing, in plain language, before they accept it: the work, the pay, the hours, the location, the employer and the duration.

We do not allow a contract to be substituted for worse terms after a candidate has accepted, and if a client attempts it we tell the candidate.

This matters most when someone is relocating, because by the time they arrive it is too late to walk away.

6. Our supply chain

We assess the risk of modern slavery in the suppliers and partners we engage, weighted towards higher-risk factors: jurisdictions with weaker labour protections, low-wage and low-skill labour, and any arrangement involving migrant workers.

We expect our suppliers and partners to meet the standards in this policy, and to hold their own suppliers to them.

Where we identify a risk, we raise it, we ask for it to be remediated, and we end the relationship if it is not.

7. Working with clients

We satisfy ourselves that a client is a genuine business with a genuine role before we introduce anyone to them.

We take extra care where a role involves relocation, sponsorship, or workers on temporary visas, because those are the arrangements where dependence on an employer is highest.

Where a client's practice would breach this policy, we decline the work. We would rather lose a fee than place someone into an arrangement we would not defend.

8. Reporting a concern

If you suspect trafficking, forced labour or exploitation in anything connected to ScaleUp Recruitment, tell us. This applies to candidates, contractors, clients, suppliers and our own staff.

Contact us using the details below. We will investigate promptly and take appropriate action, including referring the matter to the relevant authority where that is warranted.

We protect anyone who reports in good faith. There will be no retaliation, and a candidate who raises a concern will not be treated differently by us because of it.

You do not have to come to us first. In Australia, human trafficking and modern slavery can be reported to the Australian Federal Police on 131 237. If someone is in immediate danger, call 000 and ask for police.

9. Training

Our staff review and acknowledge this policy when they join us.

We brief our people on the indicators of trafficking and forced labour, so that the person most likely to spot a problem, the consultant actually talking to the candidate, knows what they are looking at.

10. Governance and review

This policy is owned by the Director of ScaleUp Recruitment, who is accountable for its application.

We review our policies, procedures and practices at least annually, and sooner if we enter a new market or the law changes.

Where we find a gap, we fix it and record what we changed.

Contacting us

ScaleUp Recruitment

Email: info@scaleuprecruitment.com.au

Telephone: +61 2 8358 2491

This policy takes effect on 14 September 2026.