Scenario: You observe a contractor charging workers recruitment fees; what steps should you take?

• A. Increase recruitment fees for other workers.
• B. Replace workers with new ones without documentation.
• C. Ignore it to avoid delays.
• D. Document the finding, require an immediate corrective action, escalate to the Contracting Officer (CO), and consider audits and sanctions.

Answer: (D)

Observing recruitment fees charged to workers signals a serious trafficking risk and warrants an immediate, formal response. The right approach is to document what you found, require the contractor to take immediate corrective action (such as stopping the recruitment fees, refunding workers, and implementing compliant recruitment practices), escalate the issue to the Contracting Officer for formal oversight and enforcement, and consider audits and sanctions if the behavior does not stop or recurs. This sequence protects workers, ensures contract compliance, and provides a clear path for accountability and remediation.

Increasing fees for other workers would worsen exploitation; replacing workers without proper documentation ignores legal and contractual protections and can hide trafficking; ignoring the finding allows harm to continue and undermines due diligence.