Ethical Recruitment & Fair Work Policy

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy establishes Global Talent Pathway’s standards for ethical recruitment and fair work practices in connection with its workforce, recruitment, and platform activities.

It complements the Modern Slavery & Human Trafficking Policy by governing everyday recruitment conduct, not only extreme exploitation.

2. Scope

This policy applies to:

  • Global Talent Pathway’s workforce and recruitment services,

  • candidates and jobseekers,

  • employers, recruiters, and labour hire providers,

  • agents and intermediaries,

  • suppliers involved in recruitment or labour supply,

  • staff and representatives of Global Talent Pathway.

3. Policy Statement

Global Talent Pathway is committed to ethical recruitment practices that are transparent, fair, and lawful.

Recruitment facilitated through our platform or services must not exploit information asymmetry, power imbalance, or worker vulnerability.

4. Ethical Recruitment Principles

Recruitment activities must adhere to the following principles:

4.1 Transparency

  • Job information must be accurate and not misleading.

  • Wages, conditions, location, hours, and role requirements must be clearly represented.

  • No false promises or omissions of material information.

4.2 No Worker-Paid Fees

  • Workers must not pay fees to access employment opportunities.

  • Costs associated with recruitment must not be shifted onto workers.

4.3 Freedom of Choice

  • Workers must be free to accept or decline employment.

  • Workers must be free to leave employment in accordance with applicable law.

4.4 Lawful Work Conditions

  • Employment must comply with applicable labour, employment, and workplace laws.

  • Where relevant, visa and work-rights conditions must be respected.

5. Prohibited Conduct

The following conduct is prohibited:

  • charging recruitment or placement fees to workers,

  • misrepresenting job terms or conditions,

  • pressuring candidates to accept employment,

  • restricting worker mobility through unfair or unlawful means,

  • retaliation against workers who raise concerns.

6. Employer and Recruiter Responsibilities

Employers and recruiters engaging with Global Talent Pathway must:

  • comply with this policy and applicable law,

  • provide accurate job information,

  • cooperate with verification and review processes,

  • address concerns raised in good faith.

Failure to comply may result in suspension or termination of access to the platform.

7. Worker and Candidate Protections

Candidates and workers:

  • may raise concerns without fear of retaliation,

  • may decline opportunities without penalty,

  • may access reporting mechanisms confidentially.

8. Reporting and Enforcement

Breaches or suspected breaches of this policy must be reported through the Complaints & Disclosures Framework.

Global Talent Pathway may take actions including:

  • investigation,

  • corrective action,

  • restriction or termination of relationships.

9. Relationship to Other Policies

This policy operates alongside:

  • Modern Slavery & Human Trafficking Policy,

  • Privacy Policy,

  • Information Security Policy,

  • Complaints & Disclosures Framework.

In the event of inconsistency, Tier 1 policies prevail.

10. Review

This policy will be reviewed annually and updated as required.