2024

ANTI-CORRUPTION COMMISSION OF SIERRA LEONE

An independent institution established for the prevention, investigation, prosecution and punishment of corruption, corrupt practices and to provide for other related matters. 

Contact us on: +23278832131 or info@anticorruption.gov.sl
Address:  Integrity House, Tower Hill, Freetown Sierra Leone, West Africa.

REVIEW REPORT - MINISTRY OF LABOUR

System & Processes

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20. 20 migrants after investigation was completed to the Immigration Department. The Head of TOCU also mentioned that complainants and suspects with regards to migration fraud often opt for out of court settlements when it concerned monies that were paid and such settlements were normally granted but generally, files are forwarded to the Director of Public Prosecutio n (DPP) for advice before actions were taken. There is no evidence that the Labour Migration Unit of the MLSS are consulted or involved in the process. For example, Suspects who were in detention at the time of review were acting on behalf of a brother who was living in Italy, they had collected monies from prospective migrant workers and monies were sent to the brother in Italy to supposedly process their visas to travel to Albania to work. Both the prospective migrant worker and the suspect who collected the monies were in detention for involving in illegal migration issues. The complainants have requested for out of court settlement but the brother living in Italy has not been cooperating. The suspects have been detained for 28 days as a result of sett lement agreement but the matter has been charged to court since the Sierra Leone Police (SLP) cannot continue to detain them unlawfully. (Section 17(3)(a) of the Constitution of Sierra Leone, Act no. 6 of 1991 states that within 10 days

32. 32 consultants that should be developing the processes for the migrant workers alongside MLSS and the Recruiting Agencies. From our interviews with one of the Managers in the SOS, the Review Team learnt that people within the MLSS were aware th at SOS Labour were involved in the recruiting of candidates travelling to more lucrative countries such as Turkey, Dubai, which functio n and activities had never been part of their mandate as consultant to the GoSL through MLSS. Please note that the SOS is housed in the MLSS. In an interview with the Minister of Labour and Social Security, he intimated the Review Team that even though it was not in the signed MoU between the SOS Labour Ghana and MLSS, he was aware that they (SOS Labour Ghana) were also engaged in recruiting migrant workers. The Terms of Refere nce (ToR) of the consultancy for SOS Ghana was not provided to the Review Team despite several request s for them to do so. The refore, the Review Team could not establish their scope and extent of operations in Sierra Leone. It was further revealed that every successful candidate must pay 240 United S tate Dollars through the recruit ment agencies to the SOS Labour Ghana. In an interview with the

47. 47 workers were not made available to the Team for review and verification. The Review Team observed that there were inconsistencies in the application of specific labour rules, example in article 2(8) of the Agreement between the GoSL represented by the MLSS and the Government of Sultanate of Oman represented by their Ministry of Labour regarding the responsibilities of the Government of Sultanate of Oman states that the Government of Sultanate of Oman sh all facilitate the prompt return of the remains of any Sierra Leonean worker who dies in the country, with immediate settlement of his wages, allowances and his/her personal effect and rewards. However, item 13 in the demand letter from Transguard Group LL C in Dubai UAE states that in the case of death of the worker, the Company/Employer shall dispatch the mortal remains of the deceased migrant to his/her native place at his own expenses and shall settle all dues of the worker(s), in coordination with the C ameroon Mission. A Third - party contract which was in contravention of th e International Labour overseas recruitment. As stated above, relevant provisions applicable to the migrant workers in the Mission policies/laws were not provided to the Review Team. Also, a third country,

1. 1

8. 8 and abuse, human trafficking in persons, forced labour, debt bondage, the issuing of the visa articleNo.20(a house - maid domestic worker visa that subjected a migrant worker to a house) or the (Kafala recruitment system), a system used in mostly the Middle Eastern or Gulf Cooperation Council (GCC) Countries that monitor migrant laborers, working primarily in the construction and domestic sector, unlawful termination of contracts and confiscation of passports. Migrant workers were sometimes lured in to fake contracts that were disproportionate to what they actually applied for etc. It was against this back drop, that the Government of Sierra Leone (GoSL), by a cabinet conclusion placed a moratorium on overseas labour employment in February 2019 . However , in 2021 the Minister of Labour (Mr. Alpha Timbo) , decided to look into the migration portfolio to see how best the process can be reviewed and brought back to light in terms of overseas recruitment. The Ministry then developed a policy on migration. The ban on migrant workers eventually was lifted by the current government. The GoSL through the Labour Migration Unit of the MLSS, on Tuesday, 8 th May, 2021, launched a five - year pilot project to tackle the problem of illegal and uncoordinated labour migration in the country.

25. 25 Attempts to regularized the registration of potential recruitment agencies are so far ineffective and inconsistent. The Review T eam observed that in prev ious years Press Release s were made by MLSS inviting /encouraging Sierra Leonean /local Agencies that were interested in operating Private Employment Agencies (PEA) to apply for licenses through the Office of the Permanent Secretary of MLSS which was a good start but the Review Team also discovered that no such advertisements or Press Releases were put out for the current recruitment of migrant workers. Secondly, the Review Team was reliably informed that each Sierra Leonean Private Employment Agency applyin g for license was asked to pay the sum of Le 5,000,000.00 (Five Million Leones or Currently equivalent to Five Thousand New Leones). No details were given to the Review Team on the required fees and how payments were made and monies accounted for. IMPLICATION Allowing recruiting agencies to operate without registration creates corruption risks and other problems/challenges for the program and migrant workers as most time these agencies operate in secrecy with no proper mechanism in place to hold the m accountable . This was mostly

27. 27 Ministry of Foreign Affairs to create a mechanism to effectively monitor the country ensure that no agency operates without operation. Illegal opera tions should be criminalized. We therefore recommend that the recruitment done by Taju Deen should be looked into and a report sent to ACC for further action. A whistle blowing mechanism should be established to report all forms of illegal operation. A cl ear and detailed criteria and procedure for the registration of Private Employment Agencies should be developed and popularized. The required fees should be clearly spelt out and be uniformed. Operating licenses should be renewed annually as a way of keepi ng tabs on the operational status of these agencies. MANAGEMENT RESPONSE The public notice inviting interested Sierra Leoneans to apply for overseas recruitment license was made public and is dated 21st Septe mber, 2021. The fees paid by Private Employment Agencies (PEA) are Le 5,000,000 for their licenses and is paid to the Consolidated Revenue Fund Bank of Sierra Leone. (See attached evide nce of

18. 18 9 .4 T HE IMMIGRATION DEPARTMENT In a meeting with one of the Directors at the Immigration department, the Review Team was informed that it was the sole responsibility of the SLP to make arrests at the airport and other areas, investigate and follow up on the investigation process of ille gal migration. Management of the Immigration Department noted the observation with respect to passports that were confiscated from migrants. The Director of Administration in the Immigration Department explained to the Team that whenever citizens wanted t o replace lost/stolen passports, there were laid down procedures to follow. These procedures included the owner of the missing passport should visit the nearest police station and make a statement in order to get police clearance which is in - turn presented at the Immigration office before another passport is printed. He also stated that the Immigration Department also had a database of all passport holders which contained their full names, addresses, date of birth, biometrics, etc. When the details of a c itizen are entered into the system, all the information would display to indicate that you once had a passport.

31. 31 10.6 THE RECRUITMENT AND OPERATIONS OF SOS LABOUR GHANA AS CONSULTANT The Review Team examined the role and operation of SOS Labour Ghana in the Labour Migration Program and how their services were procured. It learnt that SOS Labour Ghana was brought in solely as a consultant to the labour migration pr ogram . Documents with respect to whether the requisite procurement process was adhered to i.e. how SOS Ghana was recruited in Sierra Leone were not provided to the Review Team despite several demands. The Review Team was of the view that certain requiremen ts in the procurement process were not met. SOS Ghana were very uncooperative when asked questions relating to this issue. Furthermore, it was reported to the Review Team, that the SOS Labour Ghana was not registered/licensed in Sierra Leone to operate as a recruiting agency but they were alleged to be recruiting migrant workers to send abroad. The SOS Labour Ghana as parts of its Agreement with the GoSL through the MLSS was responsible to bring in job opportunities and the Recruitment Agenci es will bring in the people. It was observed that the SOS Labour was also involved in recruiting migrant workers even though they were

37. 37 was transparent free , and fair, giving all Sierra Leoneans equal opportunity to the migration program. The Review Team observed that some candidates have been successful ly selected and processed and have already travelled to Qatar and Kuwait on the Transfer to Transform progr amme . However, there were allegations that due pro cesses were not followed and the selection process was not free and fair and was heavily influenced by connected or influential people in the socie ty or insider knowledge/information of the programme and the individuals’ ability to pay the minimum sum of Le 10,020,000 for male and Le 10,070,000 for female . The Review Team observed that these applicants were not selected from the job seekers database that was supposed to be in existence as should have been the case. Furthermore, the Review Team noted that t he recruitment process of migrant workers included medical examination of the prospective migrant workers to dete rmine their health status. These blood samples were collected from pr ospective migrant workers at the premises/offices of the CEO of the Recruiting Agencies by lab technicians and then taken to the medical centers for the tests. There wer e allegations that the blood and other samples were taken to the private homes of

3. 3 SLP - Sierra Leone Police SLORRA - Sierra Leo ne Overseas Recruitment Agency TOCU - Transnational Organized Crime Unit UAE - United Arab Emirates

54. 54 collaboration with staff from the MFA (Embassy staff) visited the various locations of the employers to monitor and assess their various hostels and work areas prior to the departure of the migrant workers to their respective destinations. No information or evidence of subsequent visitations by these officials to the areas mentioned was provided to the Review Team. A new policy on National Labour Migration was developed by MLSS which has just been launched and in the process of being popularized to make it effective. Proper monitoring of migrant workers in the country of employment seemed to be totally lacking as no such evidence was provided to the Review Team. No complaint mechanisms exist in our embassies in the employing countries to provide migrant workers a way of making complaints. IMPLICATION Lack of an effective mechanism to monitor workers in the countries of employment will make it difficult to detect and address challenges and abuses faced by workers.

2. 2 ACRONYMS ACA - Anti - Corruption Act ACC - Anti - Corruption Commission CEO - Chief Executive Officer CV - Curriculum Vitae DPP - Director of Public Prosecution GCC - Golf Cooperation Council GoSL - Government of Sierra Leone HIV - H uman Immunodeficiency Virus Ie - That Is ILO - International Labour Organization IOM - International Organization for Migration LMU - Labour Migration Unit MLSS - Ministry of Labour and Social Security Na SSIT - National Social Security and Insurance Trust NMA - National Minerals Agency ONS - Office of National Security RT - Review Team RSLAF - Republic of Sierra Leone Armed Forces SL - Sierra Leone

29. 29 Unit . One of the recruiting Agencies (H P R Global) which was already recruiting for a company in Qatar had its registe red office in Yams Farm which i s in the east end of town but operated in a different location at Victoria Street and Bass Street, Brookfields in the west end of Freetown; in a dwelling house which are not conducive for office operations. IMPLICATION Carrying out recruitment activities in undisclosed addresses different from the registered office premises tend to be dubious and fraudulent. Failure to put mechanisms in place to effectively monitor and regulates recruiting agencies will make difficult for these agencies to be transparent and accountable. RECOMMENDATION The MLSS should create an effective monitoring mechanism to monitor the status and operation s of all recruiting agencies . Private Employment Agencies in Sierra Leone must be registered, regularly vetted, and given license to operate as the exclusive overseas recruitment Agencies in accordance with Article 181 of the ILO Convention 1997.

33. 33 Minister, he briefed the team that these monies were to be used by GoSL for human capital development . No detail was given to the team with regards the amount generated and how these monies are being utilized. IMPLICATION Hand picking consultants for such important program limits the opportunity to access more facilities/services. Failure to follow the requisite procurement laws of Sierra Leone is a crime and creates risks of corruption in the procurement process. The MLSS had made SOS Ghana and the exclusive Consultant , operating as a Recruit ment Agency in Sierra Leone will thereby enable them to compl etely monopolize the programme and even discourage SLORRA and the legally Registered Private Recruitment Agencies in Sierra Leone that had the mandate and license to recruit in Sierra Leone, an action that could be seen as a travesty of justice and uneven level play ground on recruitment. Recruiting migrant workers by the SOS group was in contradiction of their Agreement with the MLSS

17. 17 9 .3 TRANSNATIONAL ORGANISE CRIME UNIT (TO CU) The Transnational Organized Crime Unit (TOCU) is a Multi - Sectoral, Police led Unit that had over 16 partners (partners include Office of National Security, National Drug Law Enforcement Agency, Immigration, RSLAF, NMA, Airport Authority, Pharmacy Board and more). They handle issues of organized crime such as free fraud, drugs, advanced free fraud, organized free fraud, human trafficking, maritime piracy, boarder management (land, sea and air) and more. In the course of duty, they arrest, investigate, prosecute and charge suspects o f the above crimes to court. They also profile deportees and hand them over to IOM for training and reintegration into the societies again. The activities of TOCU are being supervised by two boards – a Management Board and an Advisory Board. The Team wa s informed that TOCU normally acted on reports, information, intelligence unveiling human trafficking from victims, relatives or other stake holders. They carry out investigations with the support of partners.

26. 26 responsible for migrant workers being stranded in various countries, sometimes unable to travel due to incorrect documentation processes and putting the lives of Sierra Leoneans at high risk of abuse. In other situations, t his accounted for exploitation being meted out on citizens as most of these Recruiting Agencies requested for millions of Leones from citizens. Migrant workers were sometimes abandoned and left to strand here in Sierra Leone even after making payments to t hese Recruitment Agencies. A case in point was that the Review Team was reliably informed that one Taju’s Recruitment Agency, with certification registration number 006 was allowed to set up offices and to start the recruitment process right at the premise s of the MLSS, a seemingly suspicious strategy that lured the ordinary citizen s to believe that the process was genuine . Later, it was reported that the program did not materialize and the applicants were left stranded without receiving their monies back and information. RECOMMENDATION The MLSS should ensure that all recruiting agencies are properly registered before conducting recruitment or operations. The MLSS should collaborate with other agencies such as the Sierra Leone Police, Immigration Department and

46. 46 ACC Comment : we note your responses and maintain that all financial matters will be forwarded for investigation by the ACC Investigation department. 10.10 D EMAND LETTERS AND BILATERAL AGREEMENT B E TWEEN EMPLOYING STATES AND THE GOVERNMENT OF SIERRA LEONE Bilateral agreements between employing states and the country of origin is usually necessary proper management of the labour migration programme and the protection of the rights of migrant workers. The Review Team observed that bilateral agreement were not with all employing countries currently benefitt ing from migrant workers from Sierra Leone. Furthermore it was observed that the bilateral agreements entered into were mainly skewed towards the employing Country’s laws and not the harmonization of both countries laws. In examining the documents provid ed by the Ministry, the Team observed that on most of the samples of offer letters provided for the review, references were made to the UAE Labour laws with regards to other benefits, air tickets and even death of emigrant worker but excerpts of the provis ions in the UAE labour laws relevant to the migrant

45. 45 the labour migration. Therefore it is recommended that the cost of recruitment be pegged to a certain percentage or proportion of wages to be earned for each applicant.  All revenue generated for Government in the labour migration program should be fully accounted for. Details of the Le5,000,0 00 and 240 United States Dollars must be provided. Management Response The fees paid by Private Employment Agencies (PEA) are Le5,000,000 for their licenses and is paid to the Consolidated Revenue Fund Bank of Sierra Leone. For Pay2Go programmes, all fees charged by PEAs are verified by the Ministry to prevent extortion, except for those recruited by unlicensed agents. The fees are confirmed in relation to the salary to be paid to migrant workers in the destination country Fees paid as license is paid into the Consolidated Revenue Fund $ 240 account owned by MLSS or SOS Global Investment, such money was never collected. MLSS does not own any account where the said amount is paid. The Ministry is working on opening an account which is known as the Migration Development Fund at the Rokel Commercial Bank.

9. 9 The Prevention Unit of the ACC was invited to conduct a thematic review of the above named programme with a view to ascertain its legitimacy, viability, reliability, scope and extent of the programme and how sustainable it was in curbing the effect of illegal and uncoordinated labour migration in the country amidst the high rate of human trafficking, exploitation and abuse around the world. For the purpose of the review, a liaison official at the MLSS was contacted and he provided copies of documents that were deemed to be the Labour Agreement between the GoSL represented by MLSS and other countries that over the past years have been requesting for migrant workers such as the Government of Sultanate of Oman represented by their Min istry of Labour, UAE, Qatar, Kuwait, etc. He also provided information on the specific department and individuals handling the Transfer to Transform Programme in the Ministry. The Project; titled ‘ Transfer to Transform Project’ was launched in collaboratio n with SOS Labour Ghana (an international recruitment and job placement organization) at the New Brookfields Hotel in Freetown. A book titled ‘ Deadly Work or Decent Work?’ authored by Rev. Dr. Princess Ocansey, the

30. 30 All recruitment activities must be carried out in the registered offices that were verified by MLSS Migration Unit. The MLSS should make mandatory for recruiting agenc ies to report any change in address or other sensitive information. Management Response: All licensed private employment agencies have addresses and can be located in those addresses. The agency in question (Human Resources Global Consultancy) has an add ress in yams farm and an operation point at Victoria Street but has now been relocated at 68 Bass Street, Brookfield’s. The outlet at Victoria Street and later Bass street used by the said agency was communicated to the Ministry. It is clear in the Overse as Employment and Migrant Workers Bill, 2022 that for any change of address the Ministry must be notified and the public informed. ACC Comment : your response has been noted for monitoring action.

24. 24 10.3 CAPACITY OF THE LABOUR MIGRATION UNIT There seemed to be lack of capacity by the Unit to effective ly regulate and un dertake programmes relating to labour migration. For example, limited evidence were available to show that recruiting agencies are being regulated or monitored. IMPLICATION Without a vibrant and well capacitated Unit, the program remains vulnerable to abuse and other related challenges. RECOMMENDATION The Ministry should ensure necessary governance structures required for the programme in line with the National Policy and international treaties/protocols/standards should be established , operationalized and capacitated. 10.4 UNREGISTERED/ILLEGAL RECRUITMENT AGENCIES Despite the fact that the GoSL through the MLSS was trying to regularize and put modalities in place for an effective, transparent and accountable migration process, there were a number of Recruiting Agencies who were still operating without registering with the government through the MLSS.

48. 48 Cameroon was mentioned in the Agreement between the GoSL and that of the United Arab Emirates w hich was not explicit enough and might have some implications for the migrant workers. The Review Team observed that there was no evidence to show that thorough reviews of the labour laws and their interpretation of the employing countries were conducted to assess consistency with our laws and the protection of the rights of migrant workers. It seems that the emphasis is on creating employment at all cost and the benefit derived by recruiting agencies. Example is the visa 20 of the Kafala systems. IMPLICA TION  Both parties to these Agreements had the responsibility to monitor the performance, health and safety, general wellbeing of the migrant workers. This would provide security to the migrant workers as the employers will be aware that the migrant worker s were being monitored regularly.  Without proper knowledge and understanding of the labour laws in various countries, migrant workers would tend to sign in to Agreements that would be of great disadvantage to them.

28. 28 some receipts . All license Private Employment Agencies recruits under the license issued to them by the Ministr y. The Ministry made the advertisement for Taju’s Recruitment Agency, because it was a license private employment agency. The Ministry supervised the interview process for day 1 & 2 at the Ministry’s Central Employment and Exchange in October, 2021. The re st of the interviews were conducted in their office. Measures have been taken by the Ministry to apprehend and extradite Mr. Taju Deen Turay to answer to his actions. ACC comment : Management notes your response and the recommendations still stand 10.5 REGULATING AND MONITORING REGISTERED RECRUITING AGENCIES The Review Team observed that there is weak monito r ing and regulation of the recruiting agencies by the MLSS. There is no form of obligations on the recruiting agencies to provide annual report or qu arterly report or even status reports by these agencies on migration programs been conducted or facilitated. The Review Team observed that some of the Recruitment Agencies could not be found in the contact addresses given to the Team by MLSS Migration

19. 19 10.0 FINDINGS, IMPLICATION AND R ECOMMENDATIONS 10.1 COLLABORATION BETWEEN KEY S TAKEHOLDERS There seem to be lack of collaboration between stakeholder s in areas that will affect the migration process especially in areas of tackling immigration and passport fraud, human traffics and other migration crimes. For example, in an interview with the Head of TOCU who is a Commissioner of Police, he intimated to the Review Team that they had some men in detention at time of the review that were arrested on issues bothering around illegal migration. He stated in investigations of this nature, passports are often confiscated but mostly people will abandon their co nfiscated passports at the TOCU office and never showed up for further identification and collection of same. The head of TOCU explained that a letter was normally sent to Immigration informing that such passports have been confiscated on alleged illegal migration grounds for investigation but they hardly got support from immigration. It was suspected that some of the people whose passports were confiscated ended up printing new passports at immigration with the explanation that they misplaced same. When the Immigration department was engaged on this, they informed the Review Team that it was the responsibility of the SLP to return passports to such

21. 21 from the date of ar rest in case of capital offences, offences carrying life imprisonment and economic and environmental offences shall be charged to court). IMPLICATIONS Failure to effectively collaborate and complement each other will adversely affect the Nation’s drive to address fraud and crimes related to labour migration and as a result will continue unabatedly. RECOMMENDATION A blueprint for effective collaboration and corporation between agencies of governments, civil society organization s and non - governmental organiza tions in relation to curbing/ addressing crimes relating to labour migration should be developed and implemented. Labour Migration Unit should be informed by law enforcement agencies on all matters relating to labour migration in order to enable them to learn from such matters and device mechanism to forestall/address similar matters in the future. 10.2 LEGAL AND REGULATORY FRAMEWORK The new National Labour Migration Policy is yet to be fully implemented. For example, the policy proposes the

41. 41 the recommendations made earlier remains and will be monitored. 10.8 TRANSPARENCY IN THE RECRUITMENT PROCESS The Team observed that there was little information available to the public on labour migration opportunities and methods and processes of recruitment. Details of the Demand Letter s were not adequatel y disseminated to the general public. Sensitization through Press Release s or other public announcement s of national coverage either on print or electronic media that should precede the recruitment process es were not done for all offers thereby limiting participation nationwide in the programme. No clear information given to the public or prospective migrant workers on the demands made whether they were “free - to - go” or “pay - to - go” programs. Candidates are not fully enlightened on the terms and conditions of the employment s t hereby entering into the employ ment contract s without full appreciation of the obligations of parties.

13. 13 unfavorabl e social determinants of health including employment and wage discriminations, poor working and living conditions, lack of access to social protection and language and cultural barriers , illegal detention, confiscation of passports, sexual exploitation, forced labour, domestic abuse and torture, human trafficking in person, abandonment and even death. 8 .0 POL ICIES GOVERNING THE TRANSFER TO TRANSFORM PROGRAM According to information and documentation provided by the Migration Unit of the MLSS, the Review Team was able to identify various policies that governed the whole process of the Transfer to Transform program such as: - 1. The National Labour Migration Policy of Sierra Leone 2. Eligibility criteria for Agencies: The eligibility criteria provided that private employment Agencies expressing interest for overseas recruitment licenses must submit their applications with the following documents: -  Valid business registration/ License, NaSSIT clearance certificate, Valid Insurance Policy, Police Clearance, N RA Clearance, Recruitment Cooperation Agreement, Resume or

36. 36 standardization of processes working in collaboration with Sierra Leone recruitment agencies in good standing.  Deployment of candidates by SOS Global Investments was all done in collaboration with Sierra Leone locally registered/ license PEAs. SO S Global Investment has never requested nor received $240 from any applicant towards the migration development fund. SOS Global Investment did recommend to the Government of Sierra Leone, that a Government Migration Development Fund be instituted by Govern ment to request each migrant to pay $10/monthly earned income - (amounting to $240 for a two - year contract) - for the sustainability of the migration program.  The Ministry started the process of the account opening at Rokel Commercial Bank for the said amount to be deposited, but the account is yet to be opened, and therefore, the said $240 was never collected. ACC Comment : your response has been noted for moni toring action 10.7 SELECTION AND PROCESSING OF CANDIDATES FOR LABOUR MIGRATION The review also focuse d on the process of recruiting the prospective migrant workers to know whether the process

44. 44 With regards to government generating revenue from the labour migration program, the Review Team was reliably informed that each Sierra Leonean Private Employment Agency applying for licens e was asked to pay the sum of Le5,000,000.00 (Five Million Leones or Currently equivalent to Five Thousand New Leones). In addition, it was reported that all migrant workers were asked to pay 240 United States Dollars to certain bank account owned by MLSS or SOS Labour Ghana. Detai l s of the accou nt and status of revenue generated were not provided to the Review Team despite several requests. IMPLICATION Making random financial demands from prospective migrant workers was a way of exploiting them and even subjecting them to financial and physical torture. Funds kept in undisclosed bank accounts are liable to be misappropriated. RECOMMENDATION  All recruitment fees for any particular programs must be made public by the Ministry and the Legally Private Overse as Recruitment Agencies.  The ministry s hould ensure that the cost borne by candidates do not supersede or surpass the benefits of

51. 51 migrant worker, it is the responsibility of the Company/Employer to dispatch the mortal remains of the deceased emigrant to his/her native place (country of origin) at his/her (Company/Employer) own expenses and shall settle all dues of the worker(s) in coordination with the Sierra Leone Mission. This is not done at the expense of the worker expenses as stated in the report.  Cameroon was indeed mentioned in the agreement between Sierra Leone and the prospective migrant to be deployed in UAE. This was a typographical; these employment contracts are shared in many African countries, there is the possibil ity for them to edit the documents properly be for e sending.  It is well noted. - MOST IMPORTANTLY, Sierra Leone no longer uses Visa 20 but Visa 18. ACC Comments : We note your comments however these responses will be verified by the monitoring department. 10.11 SIERRA LEONE OVERSEAS RECRUITMENT AGENCIES ASSOCIATIO N (SLORRA) The Review Team observed that there was a Sierra Leone Overseas Recruitment Agencies Association (SLORRA). A registered entity with both the Ministry of Social Welfare

52. 52 (MoSW) and the MLSS respectively. ( SLORRA) has its mandate and was established in 2018, in accordance with the International Labour Convention Article 181 of 1997, The National Labour Migration Policy and the Sierra Leone Local Content Policy. No regard was given to th is organization in the entire recruitment exercise despite demands made from the organization. IMPLICATION SLORRA can complement government’s recruitment drive and can be used to regulate private recruitment agencies operations. RECOMMENDATION  The Review Team recommends that the Sierra Leone Overseas Recruitment Agencies Association (SLORRA), through Registered Private Employment Agencies in Sierra Leone should be the exclusive registered recruiting entity in Sierra Leone.  This will be in accor dance with the International Labour Convention Article 181 of 1997, The National Labour Migration Policy and the Sierra Leone Local Content Policy respectively. The MLSS and any Consultants should only coordinate the affairs and monitor the entire recruitm ent

56. 56 November 2021, and is just about one (1) year now; to visit work places is cost effective and has to be well budget for before undertaken it.  Monitoring of work places can be done by next financial year (2023). Communication channel were opened for migrant workers - WhatsA pp group, contacts of MLSS staff, SOS, and Agency staff to report any challenges faced in the country of destination.  A case in point is the repatriation of two migrant workers from Dubai who faced some difficulties and when asked they said they want to come back and it was done. ACC Comment Response noted to be verified by monitoring. 11. 0 CONCLUSION From our findings above it is apparent by all indications that there were fundamental flaws in the overall process and activities that constituted the Transfer to Transform programme. Numerous risks of corruption were identified throughout the programme fr om issues of governance of the programme to processes and procedures of approving candidates and monitoring.

10. 10 Chief Executive Officer of SOS Labour Gha na, was also launched. Initially, the Consultant Rev. Dr. Princess Ocansey categorically stated that the first project which was “Transfer to Transform”, which was specifically for women was free, and the proposed project was for Saudi Arabia. It was meant for Sierra Leonean migrant workers (Women) between the ages of 18 – 25. Initially, our review Team discovered that they said program was for 500 (Five Hundred Sierra Leonean Female domestic workers). This was what warranted the Minister to request all legal ly registered Private Recruiting Companies in Sierra Leone to re - register their Companies, and go through the verification process, and to start the recruitment process immediately. According to the Minister, that the said recruitment was going to be a tes t case for all private recruiting Companies that were registered in Sierra Leone with the Ministry of Labour. The project comprised of three key components; the ‘Decent Work in Gulf States, the Diasporan National Service and the Graduate Work - Study’. 4.0 OBJECTIVES The objective of this review was to evaluate/assess the Labour migration programme

6. 6 1.0 INTRODUCTION A “migrant worker” according to the International Labour Organization (ILO) instruments is defined as persons who migrates from one country to another (or who has migrated from one country to another) with a view to being employed other than on his own account, and includes any person frequently admitted as a migrant for employment. Labour migration is the movement of people from their home Country to another S tate for the purpose of employment . Today, millions of people worldwide are working in various foreign countries other than their country of birth. The government of Sierra Leone, through the Ministry of Labour and Social Security (MLSS) has coordinated employment offers over the years and Sierra Leone now has its citizens working in countries all over the world especially in Kuwait, Iraq, Qatar, Oman, Turkey, UAE, Saudi Arabia etc. 2.0 BACKGROUND The ACC Report Center, between the months of February and Mar ch of 2022, received complaint of massive corruption, extortion and lack of following due process in the overseas employment recruitment process by the MLSS. The report was forwarded to the Prevention Department to conduct a review

53. 53 process for transparency, accountability and for global recruitment best practices.  The Review Team recommends that SLORRA in collaboration with the MLSS should be encouraged to build a framework for effective regulation as provided by the ILO's Priva te Employment Agencies Convention, 1997 (No. 181) - “C181, A scheme that will support better corresponding of labour supply and demand”. This shall enhance cooperation between public and private employment service providers in areas such as information - shar ing, basic job matching services, and active support. Management Response Convention 181 - Private Employment Agencies of - 1997 The Ministry has collaborated with SLOORA by inviting them on several occasions to discuss the way forward on labour migration m anagement taken into consideration their strategic position in the overseas recruitment activities ACC Comments : Response well noted 10.12 MONITORING MECHANISM Based on information obtained from MLSS, the Review Team learnt that the MLSS Migration Unit Staff in

38. 38 Lab T echnicians who had the reagents at home to conduct the tests. Most of the tests ended up not being satisfactory as a result of poor handling of blood and other samples. Prospective migrant workers who were g iven test results that stated positive for Hepa titis, HIV or tuberculosis for example had to go for confirmatory tests in other hospitals which turned out to be negative thereby adding to the transactional cost of the recruitment process. IMPLICATION Without a clearly defined recruitment process and safeguards against abuse, applicants are vulnerable to abuse. RECOMMENDATION  The MLSS and recruiting agencies must develop recruitment and hiring manual for all labour migration programmes. The manual must clearly state the procedures and processes of h iring/recruiting. It should clearly define the obligations of the recruiting agencies, the employers and the candidates. The manual should be popularized and operationalized.  The MLSS should make it mandatory for recruiting agencies to get approval from the MLSS before commencing any recruitment.

43. 43 interviews/ pre - departure orientations. SOS Global Investments always clearly states full job prospectus on its posters and flyers from the start of any job offers to ensure expectations of prospective candidates are seamlessly managed.  SOS posts flyers of job offers on WhatsApp pages and social media platforms.  All Prospective Migrants are properly oriented before departure, and employment contracts are explained to them, are given basic Arabic lectures for those travelling to Arab Countries/States. ACC Comments : your responses have been noted for verification by the monitoring unit of the ACC 10.9 PAYMENTS AND CLAIMS OF EXTORTION Random and seemingly unregulated financial demands were made on prospective migrant workers amounting to millions of L eones depending on the country from which the employment demand was made. Candidates interviewed revealed that the cost of acquiring the employment is usually high to the point they benefit very little from the employment. They intimated that some of these cost are bor ne by candidate throughout the period of employment.

22. 22 development and implementation of update - to - date and comprehensive legislative instruments that cover the mandate of state institutions and societal actors responsible for the managing of labour migration. No evidence was provided to show that this has bee n achieved. There is no comprehensive Standards of Operation manual for recruiting agencies to guide and regulate their operations apart from one - page eligibility criteria for registration. IMPLICATION Failure to fully implement the Policy leaves the labou r migration process vulnerable to various challenges and corruption risks as the various strategies and structures required to carry out or handle labour migration programmes are lacking. RECOMMENDATION  The Policy should be popularized and fully implemented to provide proper guidelines to recruiters and “would be” migrant workers.  All the necessary legislations and legal instruments relating to labour migration should be developed or reviewed to address the various gaps and shortfalls i n the Nation’s ability to effective ly carry out such programmes.

40. 40 campaign - this is open to all qualifying citizens who are publicly in vited to apply through multimedia platforms - mostly radio, TV, Facebook, etc.  We then set up an initial screening process, per international recruitment standards, and derive our professional shortlist. To date, SOS Global Investment has not yet deployed any candidates to QATAR; SOS Global Investment has deployed migrant workers to the Sultan Center in Kuwait. Shortlisted candidates are coached to prepare them for employer interviews.  The employer is the final authority on the final selections and hiring outcomes. The employer’s selected candidates are informed to continue with t he rest of the processes to complete their successful deployment overseas.  To select from the database at the Ministry can be determined by the job specification, e.g. the drivers interviewed at the employment exchange, some were selected from the databa se The issue of the medical with specific reference to HRG is well noted. ACC Comment : We note your responses, however, the list attached shows details of migrant workers who have been sent to destination countries which is different from the database of workers who apply for labour migration therefore

58. 58 costs are being levied on migrant workers by unlicensed/underground agents.  T he charged fees are confirmed in relation to the salary to be paid to migrant workers in the destination country SOS Global Investment recommended to the Government of Sierra Leone, that a Government Migration Development Fund be instituted by Government t o request each migrant to pay $10/monthly earned income - (amounting to $240 for a two - year contract) for the sustainability of the migration program.  $240 account owned by MLSS or SOS Global Investment does not exist.  The Ministry is working on opening an account which is known as the Migration Development Fund at the Rokel Commercial Bank but the account is yet to be opened, therefore, the alleged $240 was never collected from any migrant worker.  The Ministry of Labour and Social Security has duly not ed some of the recommendations proffered in the draft Thematic Review report by the ACC and welcomes the idea of reviewing (not to overhaul) the process to make it more accessible.

15. 15 emplo yers and their Recruitment Agencies and also conduct inspection of their offices and hostels.  To facilitate the registration and license process of the Recruitment Agencies based on set criteria.  The MLSS ensured/facilitated recruitment and basic trainings for the migrant workers.  The MLSS in collaboration with the Recruitment Agencies/employers ensured that the successful job seekers were issued with valid visas to enable them travel to the various countries where their services were required.  MLSS ensured that the contractual obligations of both the employers and the employees were monitored from time to time to ensure full compliance within the contractual period. 9 .2 SOS GHANA SOS Labour is a Limited Company registered and licensed in Accra, Ghana and Alberta, Canada. It is a job placement specialist company, specializing in placing redundant and excess African workers in excellent and well - paid job positions overseas. Current ly, SOS Labour has 11 client companies in Canada and contacts with Recruitment Agencies and companies in the UK, and Australia and is actively working to create ties with Recruitment Agencies and

7. 7 on the Transfer to Trans form Program to ascertain the transparency and accountability of the program. This review was conducted in accordance with the Section 7sub.2f, g, h of the ACA 2008 as amended in 2019. It clearly espoused that: Without prejudice to the generality of subsection (1) it shall be the function of the Commission -  To examine the practices and procedures of Public Bodies, identify weaknesses and gaps and proffer recomme ndations.  To advise and assist any person, authority, public body or private sector institution on changes in practices or procedures.  To issue instructions to public bodies of changes in practices or procedures which are necessary to reduce or eliminate the occurrence of corrupt practices. 3.0 THE ORIGI N OF THE TRANSFER TO TRANSFORM PROGRAMME In the past years, it has been reported that migrant workers from Sierra Leone have been subjected to unfavorable living and working conditions. Migrant workers had to go through inhuman, degrading treatments and poor living conditions, being subjected to slavery lifestyle, torture, sexual exploitat ion

16. 16 companies in other countries abroad particularly Spain and N orway. Three months of background work was done in Canada by the CEO of SOS Labour, where she met with government labour officials, Canadian immigration officials, Recruitment Agencies, Union Leaders and employers and other officials. A thorough study w as made of the laws, rules and regulations regarding Temporary Foreign Workers in Canada, and the Stringent Certification Process for Alberta. From the review interview, the Review Team learnt that SOS Labour was contracted as Consultants by the MLSS to he lp put modalities in place to see how the ban on migration will be lifted. The functions of SOS Labour in collaboration with MLSS included: -  To provide exit permit for migrants through MLSS  To collate data on migrants  Manage the portal that is being deve loped  Bring in job opportunities and the Recruitment Agencies bring in people  Work towards getting investors to invest in Sierra Leone as a nation and not just the MLSS

12. 12  Face to face interviews with key stakeholders and beneficiaries  Review of relevant documents, demand letters, contracts (Policies, Legislation etc.)  Corroborating and authenticating evidence/information where possible.  Review of best practices in other jurisdictions The scope of the review covered the whole of the Transfer to Transform programme fr om 2021 - 2022 6.0 THE REASONS FOR LABOUR MIGRATION Generally, labour migration was mostly influenced by social structures and pattern of development. Uneven development was the main reason of migration along with factors like poverty, landholding system and fragmentati ons of land, lack of employment opportunities, large family - sizes and natural calamities . There are however positive effects of labour migration on migrants' households, such as improved health and nutrition status, increased purchasing powe r, remittances and diversified consumption capacity of family members, etc. 7.0 RISKS ASSOCIATED WITH MIGRANT WORKERS Migrant workers can be at high risk of exposure to workplace hazards and could face additional work - related risk factors,

14. 14 CV of the head of the Applying Agency and copy of passport of the head of Applying Agency. 9 .0 KEY STAKEHOLDERS IN THE MIGRATION PROCESS 9 .1 Labour Migration Unit o f t he Ministry o f Labour a nd Social Security The role of MLSS in the Transfer to Transform scheme was to coordinate all activities relating to the recruitment, movement and wellbeing of job seekers within and outside of the country (overseas employers). The activities included: -  DA TABASE: - The Ministry maintained a database of job seekers who regularly came to the Ministry to register for recruitment purposes.  The MLSS ensured that there was a standing legal agreement between the Ministry of Labour of the employing country and the MLSS of Sierra Leone detailing the responsibilities of both parties.  Registered job seekers are contacted whenever there were job openings.  The MLSS in collaboration with the Ministry of Foreign Affairs (MFA) conduct background checks on prospective

57. 57 T he whole system of the “Transfer to Transform” recruitment project at the MLSS was not transparent and was marred with so many irregularities and therefore should be revamped and closely monitored. Finally, the R eview T eam intends the review report to serve as catalyst for the complete overhaul of the entire overseas recruitment activities . Management Response The Ministry is of the strong view that there is limited flaw in the overall process and activities that constitute the Transfer2Transform Programme as follows:  The process has been largely transparent as Job Offers are made public (advertised) by issuing out flyers on social media.  The Ministry of Labour and Social Security monitors the recruitment processes of SOS Global Investment and other PEAs Fees paid by Private Employment Agencies (PEAs) for license are paid into the Consolidated Revenue Fund at the Bank of Sierra Leone.  App licants are only required to pay some cost for Pay2Go programmes.  All fees charged by PEAs for Pay2Go programmes, are verified by the Ministry to prevent extortion. Excessive

50. 50  Full details of the Demand Note must be made to the public to strengthen transparency and prevent extortion from prospective migrant workers. Management Response  The Ministry of Labour and Social Security has instituted mechanisms to address all issues of abuse or exploitation faced by migrant workers recruited under those licenses. Those who may have been faced with such situations have either been repatriated or transferred to another home or workplace.  Migrant workers facing abuse or exploitation for which disturbing videos are making rounds on social media were not recruited through the Ministry (SOS Global Investment or any registered/licensed Recruitment Ag ency) but rather by unregistered individuals or agents.  The destination country is mentioned in demand letters because they are the destination country; Sierra Leone cannot use their labour law in employment contracts, for example in Kuwait.  In the cas e of an MOU you can refer to both countries labour laws. The demand letter of Transguard Group LLC in Dubai, UAE which states that in the case of death of a

34. 34 RECOMMENDATION  The RT recommends that the procurement of the consultancy with SOS Labour Ghana should be reviewed and any case of non - adherence to the procurement laws should be investigated.  If the consultancy contract of SOS Ghana is maintained, it should be reviewed to clearly state it s scope and obligations and must address any inconsistencies with a legal consultancy work.  Furthermore, modalities should be put in place to ensure full compliance and any breach of the TOR should be investigated and punished.  The MLSS and SOS Labour Ghana should provide details on financial obligations relating to contract agreement and on the payments of 240 United States Dollars made by individual candidates of the Transfer and Transform . Grounds f o r the payments and government’s sta ke must be clearly specifie d and financial records including bank statements must be reviewed. Any form of corruption discovered must be investigated .  The MLSS and SOS Labour Ghana must ensure that implementation of the contract must be done in a transpar ent and accountable manner and proper records of finance and other operations must be kept. Activities of

35. 35 SOS must be monitored to ensure adherence to terms of the contract agreement.  The MLSS should ensure that any form of recruitment of consultancy must be conduct ed in line with the procurement laws and regulations of Sierra Leone. Management Response  The Bill on Overseas Employment and Migrant Workers will adequately address the issue of those who are engaged or may want to engage in illegal recruitment.  The Cabinet Conclusion approves the lifting of the ban and the recruitment of sierra Leoneans . SOS Global Investment was duly approved by Cabinet to assist the Government of Sierra Leone to carry out recruitment of migrant workers.  SOS Globa l Investment does not have the “exclusive right” to carry out recruitment the recruitment of migrant workers as stated in the report. If so, the Ministry would not have issued any license to other recruitment agencies.  SOS Global Investment is the Cabine t Approved Consultant together with a Sierra Leone registered operational arm, the duly registered SOS Global Investments Limited, SL - with a mandate to perform recruitment activities, Decent Work procurement overseas with social protection as well as gen erating

49. 49 Having different policies/provisions in l aws can be confusing and misleading. RECOMMENDATION  The Government of Sierra Leone should enter into bila teral agreements with all employing countries with clear provisions and obligations on promoting labour migration and the protection of the human rights of all workers.  Every detail of the demand letter /Contracts must be made known to the prospective migrant workers to give full detail and understanding to all parties concerned.  The GoSL must put a ban on all recruitment of visa 20 or the kafala sy stem as it is inhumane, degrading and had greater tendency of sexual exploitation, and other forms of abuse and human right violations.  All provisions/laws that have a bearing on the migrant workers must be clearly spelt out and made known to the workers b efore agreements are signed as the signing of such documents makes it a legally binding tool.  All policies/provisions in laws must be corroborated and made simple to fit best practice.  All visas, contract letters, written in other languages must be transla ted before commencements of any recruitment process in Sierra Leone.

42. 42 IMPLICATION  Suspicion of fraudulent practices was perceived right from the start, given that the programmes were not advertised to the general public.  The lack of transparency in the overall process is a cause for concern given that the evidence of corruption seemed to be evident in all aspects of the programme and might have serious consequences on the reputation of government and Ministry if action was not put in place to regularize the situation. RECOMMENDATION  It is recommended that pre - employment orientation and intensified information campaigns are done, especially in rural communities, to provide applicants with sufficient information to prevent abuses.  All applicants should be enlightened on terms and conditions of contract before signing the employment agreem ent.  A service charter on the labour migration programme should be developed and published by the MLSS. Management Response  All license PEAs are given clearance before commencing any recruitment and the Labour Migration Unit monitors

39. 39  The MLSS and other public and private stakeholders should be actively involved in all recruitments to guide the process and ensure fairness.  Medical examinations must be conducted in reputable, recognized cente rs and not at private recruiting houses to reduce the risk blood samples or result be tampered with .  The Migrant workers data base to be regularly updated on a quarterly basis to give opportunity to new applicants.  A grievance redress mechanism should be established at the ministry to deal with complaints against recruiting agencies. Management Response  Detailed list of all migrant workers sent by the Ministry in collaboration with SOS Global and other local PEAs to destination countries .  All Sierra Leone ans were given equal opportunities as the programmes were advertised through radio discussions by the Minister, Dr. Ocansey (consultant) and some PEAs. Per SOS Global Investment standard operating procedures - upon receipt of a demand letter, we seek appr oval from MLSS on content, fees, full job description, requirements and timeline. Based on this, SOS Global Investment creates a poster and sets up an appropriate multimedia advertising

55. 55 RECOMMENDATION  Mechanisms must be put in place for regular monitoring of the migrant workers whilst in the overseas countries.  Reports should be sent to MLSS regularly for prompt action.  Griev ance Redress Mechanism should be established in all our embassies of employing countries. Management Response  The Minister of Labour and Social Security and the Deputy Secretary only visited United Arab Emirates. Similar visits have not been carried out to other destination countries as a result of tight fiscal space.  The Ministry had recommended for Labour Attaché to be posted at our Diplomat ic Mission to be monitoring the statuses of Sierra Leonean migrant workers in destination countries, but this has not been achieved so far.  However, the Diplomatic Missions have been carrying out the monitoring exercise s on behalf of the Ministry especially when there are issues with the migrant workers. A new policy on labour migration – The National Labour Migration Policy was launched in 2018 and popularized in 2019 Deployment actually started in

23. 23  A comprehensive standard of operation /guide for recruiting agencies should be developed to create uniformity and predictability and enhance transparency and accountability in the recruitment process. Management Response  The Ministry has developed the ‘’Overseas Employment and Migrant Workers Bill 2022’’ which has been approved by Cabinet and sent to the Government Printing Department for printing. It would then be laid before Parliam ent for enactment into an Act.  There is a draft code of conduct for Private Employment Agencies (PEA) –  There is also the Regulatory/Mechanism or framework for overseas recruitment.  The implementation of the Labour Migration policy is ongoing and the policy was popularized in eleven (11) districts in 2019 ACC Comment : we note your comment; this will be monitored by the Monitoring Staff.

5. 5 10.6 THE RECRUITMENT AND OPERATION OF SOS LABOUR GHANA AS CONSULTANT ..... .......................................... ... 3 1 10.7 SELECTION AND PROCESSING OF CANDIDATES FOR LABOUR MIGRATION...... .......... .................................... ... . 3 6 10.8 TRANSPARENCY IN THE RECRUITMENT PROCESS...... . . . 4 1 10.9 PAYMENTS AND CLAIMS OF EXTORTION...... . ............ ... . . 4 3 10.10 DEMAND LETTERS AND BILATERAL AGREEMENT BETWEEN EMPLOYING STATES AND THE GOVERNMENT OF SIERRA LEONE ......................................................... ... . 4 6 10.11 SIERRA LEONE OVERSEAS RECRUITMENT AGENCIES ASSOCIATION (SLORAA)...... ....... ................................. .... . 51 10.12 MONITORING MECHANISM......... .. .............................. ...... 5 3 1 1 .0 CONCLUSION... ... ......................................................... ...... . 5 6

11. 11 Sub Objectives include:  The accountability and transparency of the “Transfer to Transform” programme.  The welfare of migrants  The effectiveness of the policies  Evaluate the recruitment process: o The recruitment Agencies o The prospective migrant workers o To recommend and proffer best overseas recruitment practices that are in line with global best practices, and are in accordance with the international Labour Migrati on and the safe passage and recruitment of migrant workers.  Ascertain the level of monitoring mechanisms incorporated within the overall programme  To proffer recommendations that will improve on overall processes in the programme and subsequent ones  The ap proach was based on qualitative review methodology 5. 0 METHODOLOGY AND SCOPE This included: -  Assessment of the capacity of the Agencies involved:  Desk review

4. 4 CONTENT ACRONYMS.................................................................................... . 2 1.0 INTRODUCTION..................................................................... 6 2.0 BACKGROUND........................................................................ 6 3.0 THE ORIGIN OF THE TRANSFER TO TRANSFORM PROGRAMM ........................................ ............ ...................... 7 4.0 OBJECTIVES...... . ............................................................... .. .1 0 5.0 METHODOLOGY AND SCOPE....................................... ... .....11 6.0 THE REASONS FOR LABOUR MIGRATION...........................12 7.0 RISKS ASSOCIA TED WITH MIGRANT WORKERS............... . 12 8.0 POLICIES GOVERNING THE TRANSFR TO TRANSFORM PROGRAM .............................................................................. 1 3 9.0 KEY STAKEHOLDE RS IN THE MIGRATION PROCESS...... .... 1 4 9.1 LABOUR MIGRATION UNIT OF THE MINISTRY OF LABOUR AND SOCIAL SECURITY................................................... ... .14 9.2 SOS GHANA ...... ..... ......................................................... .... .15 9.3 TRANSNATIONAL ORGANISE CRIME UNIT (TOCU)... .. ... ... 17 9.4 THE IMMIGRATION DEPARTMENT......... . ........................ .... 18 10.0 FINDINGS, IMPLICATIONS AND RECOMMENDATIONS ... .. 1 9 10.1 COLLABORATION BETWEEN KEY STAKEHOLDERS... .. ... .. .19 10.2 LEGAL AND REGULATORY FRAMEWORK.................. .. ... ... .2 1 10.3 CAPACITY OF THE LABOUR MIGRATION UNIT......... ... ... . . 2 4 10.4 UNREGISTERED/ILLEGAL RECRUITMENT AGENCY...... .... .2 4 10.5 REGULATING AND MO NITORING REGISTERED RECRUITING AGENCIES... .. ... ........... ................................. . 2 8

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