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The growth in the recruitment of medical and care workers from overseas has continued to gather pace for more than a decade. The influx of staff from Asia and South Africa has more than doubled since 2010. Today, one in seven nurses report an Asian nationality. (Source: Commons Library Research Briefing, 21 November 2022)


The speed at which this growth has accelerated has perhaps unsurprisingly, allowed all manner of questionable practices to go unchecked and as a consequence disturbing reports of candidate exploitation are all too common and tend to overshadow the enormous benefit this mass-migration of overseas medical practitioners has delivered.

Historically, a candidate journey from the far reaches of the subcontinent to a role in a reputable NHS Trust or private care provider can be fraught with risk as much of the process it undertaken in the murky backwaters of 3rd world recruitment long before a candidate is cleared for interview with UK employer.

Source: Commons Library Research Briefing, 21 November 2022

However, as the demand for overseas medical recruitment begins to show recent signs of plateauing for the first time in over a decade, the spotlight is beginning to intensify on the true meaning of 'ethics' in ‘ethical recruitment’ and how to it can be effectively applied to such an inherently fragmented and international process.

So perhaps now is the time for change. For improved regulation and a demand for a more transparent and auditable process. But if that is to be achieved, what are the challenges this presents.


The questions arising from how effective checks and balances can be introduced to mitigate the risk to candidates, agents and employers in a recruitment process that spans multiple continents, diverse cultural differences and wild variations in levels of accountability are, not surprisingly, many and inherent with challenges.

To achieve a truly ethical recruitment process, from the initial candidate attraction through to resettlement and pastoral care, even on to their initial employment conditions, every stage must to be able to be checked and audited to reduce the risk of malpractice and ensure candidates are not exploited.

Although the risks of candidate exploitation tend to be higher in the earlier stages of the recruitment process, it is important that every step is monitored and that every stake holder including agencies, training companies, migration service providers, sponsors and employers are accountable and share in the responsibility of ensuring a safe and ethical process for each and every candidate.

A large part of the challenge is dealing more with what we potentially don’t know rather than what we do know. How do we know if a candidate has paid an unscrupulous local agent an unreasonable fee simply for an introduction to another agent long before they reach the point of interview? How do we overcome the void in cultural values where candidates’ families are more than happy to turn a blind eye to any malpractice providing their relatives end up employed in the UK or in some cases, lie about their experiences and the costs at the hands of rogue agents? What do we do when a candidate has paid for language training then refuses to engage with the training provider?

The further back you delve into the journey of overseas candidates, the more difficult it becomes to obtain the visibility and transparency needed to develop the confidence and reassurance that candidates are not being exploited and it is more likely to be in these early stages of the process that the risks are greatest.

There are no shortage of horror stories of families taking on inappropriate levels of debt from unscrupulous lenders to secure their relative passage to the UK, regardless of the lack of authenticity of the migration services they are buying or the appropriation of the money they pay.

As challenging as these many dilemmas are, they all need to be addressed and properly nailed down to ensure a truly ethical process.


Bringing a candidate across from the sub-continent to work in a highly regulated sector in the UK such as healthcare, is, in itself, a complex and protracted process but nonetheless one which has been successfully executed for a number of years. There are an estimated 138,000 Asian and African medical workers in the UK in 2022.

It must follow therefore, that if we can efficiently complete an audit of over 20 points of compliance, including, in some cases, verbal verification from previous employers in order to bring a candidate into the UK then we must be able to work out how we double check the process through which the candidate is cleared for interview, whether by obtaining a declaration directly from the candidate at key points in the process or double-checking credentials by tightening the controls on the supply chain. This must be an intrinsic part of the process.

It is not acceptable for agents or employers to turn a blind eye to the earlier, and possibly murkier stages of the candidate journey simply because they are more difficult to investigate and monitor.

Even in some of the more remote regions, overseas agents can still be subject to regulation and therefore scrutiny. For example, in India recruitment agents should be registered with the Ministry of External Affairs in accordance with India’s Emigration Act 1983 (section 10). As part of this registration process, the individuals involved in the registered recruitment business are individually vetted by the Indian Government under a Character Verification Report and the Company regularly audited by the territorial Protector of Emigrants to ensure that they are operating in accordance with acceptable protocols. These protocols include prescribed fee levels (among many other commitments designed to ensure the protection of candidates) and record keeping.


Other areas that need to be closely monitored are training and migration fees charged to candidates as often a candidate is referred to a recruitment agent via a training and migration company in the same way that universities refer their students to agencies as a channel to employment.

Training packages vary considerably and can include Cultural Training, English Language Training or OSCE Preparation Training required for qualified nurses to obtain the NMC pin to work in the UK as nurse. If a candidate is charged a substantial sum for a package that includes training, the training providers need to be able to demonstrate that the training is both accessible and effective. How good is it and is it commensurate with the fee? - are all questions that need to be asked.

Similarly, migration fees need to be checked to ensure they fall within reasonable parameters. The training and migration companies must be prepared to provide clarity and visibility of the fees they charge. Regular audits need to be undertaken to ensure compliance with the agreed parameters.


The process of finding and securing suitable accommodation is complex, difficult and risky to both candidates and those assisting in the process, whether it be the agents, migration service providers or the employers.

In an ever-tightening UK rental market, overseas candidates are a long way down most landlords preferred tenants list which often means requiring up to 12 months’ rent in advance, increasing the risk to the candidate.

Finding property that meets restrictive criteria in terms of budget, location and proximity to the place of work as well as suitability in terms of safety and comfort is extremely difficult. Allowing candidates to source their own property does allow more flexibility as they can have easier access to more options such as room share or sharing with family or friends, but this also leaves them vulnerable to property scams and fraud.

It is therefore important to support ‘self sourcing’ with landlord and property checks to check the veracity of accommodation as well as checking the practicalities of daily commuting. A policy that allows maximum flexibility by enabling candidates to find their own property but then provides sufficient support for candidates to reduce their risk to scams seems to be the most effective.


A significant factor in determining the speed at which candidates settle into their new environment in the UK is the post arrival process. How the candidates are treated, from the moment of their arrival in the UK through to their induction and on-boarding, needs to carefully planned and executed as the treatment of candidates during their first 24 hours in the UK is fundamental to the time it takes for them to settle into their new employment after their arrival into the UK.

The level of support they receive and the ease of access to help and support in the event that they have problem post arrival cannot be under estimated.

This can present something of a grey area when agents may be responsible for the initial part of the arrival process, perhaps handling meeting and greeting or hotel transfers but the demarcation lines on the responsibility and delivery of this part of the immigration process need to be clearly agreed between the agency and the sponsor or employer to ensure that the candidates are, at no point, left to feel that they have arrived in the UK with no access to help and support.


A significant contributor to the success of bringing candidates into the UK from overseas is the speed at which the pre-arrival or post interview part of the process is completed. The time taken from the point of a successful interview to the booking of flights relies heavily on the speed of response of the employer in providing offer letters, assigning DCoS (the certificate required to apply for a visa) and then completing the compliance process.

Often the agent is responsible for obtaining the relevant compliance documents from the candidates but the employer is then responsible for checking the documents and signing them off as acceptable, all of which should completed in a timely manner to avoid unnecessary delays.


The final part of the process which cannot be overlooked or underestimated as being a crucial step in the ethical migration process is the induction into their new employment. The employers (or sponsor's) commitment to ensuring that once the candidate has arrived in the UK and settled in to their accommodation, everything possible is done to make sure they're suitably welcomed and inducted into their new employment as quickly as possible.

Whilst it is counter-productive for an employer or sponsor to leave a candidate waiting for that first communication from them, even after the candidate has arrived in the UK, it is sensible for appropriate SLA's to be in place to ensure the sponsor is accountable for the post arrival treatment of candidates once a handover has been completed.

The candidate experience can also be severely jeopardised if there are any unforeseen delays in getting the candidate into work, particularly if any such delay forces them in to financial difficulty.

In most cases, sponsor’s are likely to have committed to providing the £1,270 maintenance payment which is designed specifically for such circumstances. However, it is also the stake holder’s responsibility to instruct each candidate to travel with sufficient funds to be able sustain themselves for up to 41 days (11 days specified by the HO to begin employment plus 30 days to receive their first pay).


This in turn raises the question of the true cost of overseas recruitment and who pays for the increase in due diligence throughout the sourcing, recruitment and migration process to ensure its ethicality. Ultimately this must rest with the sponsor and employer and the fees should reflect the additional work required in order that the risk can be effectively mitigated.

Whilst the candidate will often bear the cost of flights, visas and any additional training required, many employers now offer generous migration packages to ease the burden of cost on the candidate.

The financial commitment by employers to the process of overseas recruitment varies considerably. At one end of the scale, there are many employers readily committed to assisting the candidates directly with the costs of migrating to the UK with generous packages covering everything including flights, visa applications, training and resettlement. At the other end of the scale are those employers who, whilst committed to the process offer nothing to assist the candidates in the journey.

The reality is that neither guarantees that the process of recruitment is ethical. Although the more generous packages help reduce the risk of the process failing and may help in candidate attraction, it still requires all the steak holders, including the employer to meet their obligations in all other areas of the process to ensure candidates are not exploited.

It is for the agents to ensure that the fees charged to employers are sufficient to enable the appropriate level of due diligence throughout the migration process.


Harley Medical have been supplying medical professionals to the NHS and private care providers since 2014 and have developed a proven channel for the recruitment of qualified nurses from the sub-continent. For more information email

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