A/HRC/39/52 and do not therefore seek access to justice. Others endure exploitative conditions because of the pressure to send remittances to their families. VI. The role of private employment agencies 58. Private employment agencies constitute an important global industry composed of private sector actors, such as recruiters and their sub-agents, pre-departure training centres, transport companies and travel agencies, medical screening centres, insurance companies and visa consultancies, among many others. Those various, non-homogeneous businesses profit from the recruitment of migrant workers from one country and their placement in jobs in another.72 59. The lack of regulatory scrutiny over recruitment agencies exacerbates the vulnerability of migrant domestic workers to trafficking, bonded labour, forced labour and servitude.73 Agencies and sub-agents that are not registered are not subject to the applicable laws, which makes it difficult to hold them accountable. In some cases, recruitment agents are close relatives or other persons known to the potential migrants, which often inspires trust and non-identification of the risk of being trafficked for labour exploitation.74 In some cases, dependency on an employer or a recruiter might be seen as a positive aspect and as providing stability and protection.75 60. The complex and non-regulated system of private employment agencies provides an enabling environment for abuse and human rights violations. Exploitative practices among informal agents operating in different geographic regions are well known. 76 Such practices include the provision of false information regarding the type of employment; the conditions to be expected in the receiving country; the charging of illegal recruitment fees, which often lead the migrant to incur large debts; the confiscation of identity documents as a means to control the worker; and threats and intimidation and withholding of wages. 77 Frequently, the employer pays the wage to the recruitment agency, but the worker does not receive the wage. The employer has full control over the domestic worker for the duration of the contract with the recruitment agency and in order to retain and control the worker, coercion, verbal and physical violence are often used.78 Migrant domestic workers who wish to return home are often dependent on the agents who recruited them, who may not be willing to facilitate their return home and so force them to remain and work in the host country. 79 61. In some countries, legislation has been adopted that establishes a maximum amount which recruitment agencies are allowed to charge. In practice, however, many agencies charge more than the legal limit under the respective prevailing monthly salary. This practice makes workers more vulnerable to debt bondage and to exploitation. 62. Some countries have taken measures to prevent abusive practices by private employment agencies. In Lebanon, a code of conduct launched in 2013 provides guidance to recruiting agencies on promoting and protecting the rights of migrant domestic workers in the country.80 Under the code of conduct, labour recruiters are prohibited from charging migrant workers recruitment fees but in practice, fees are charged instead in the home country or there are indirect fees through wage deductions by the employer. 81 In that sense, enforcement of the code of conduct has been limited and complementary measures, such as 72 73 74 75 76 77 78 79 80 81 ILO, “For a fee: the business of recruiting Bangladeshi women for domestic work in Jordan and Lebanon” (Geneva, 2015). Submission of Anti-Slavery International. Jharkhand Anti Trafficking Network, submission for the present report. Ibid. Ibid. Beate Andrees, Alix Nasri and Peter Swiniarski, Regulating Labour Recruitment to Prevent Human Trafficking and to Foster Fair Migration: Models, Challenges and Opportunities (ILO, Geneva 2015). Submission of Jharkhand Anti Trafficking Network. Ibid. See www.ohchr.org/EN/NewsEvents/Pages/LebanonCodeOfConduct.aspx. Submission of Anti-Slavery International. 13