When Policy Meets Reality

‘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

Debt · Labour supply · Multinational corporation · Reimbursement · Supply chain · Employment and Welfare Studies · Global trade, sustainability, and social impact · International Labor and Employment Law