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DCW81-International Recruitment and Employment Policy

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Registration Number: {{org_field_registration_no}}

International Recruitment and Employment Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} recruits and employs international workers in a fair, legal, and ethical manner. We will comply with: the Regulation and Inspection of Social Care (Wales) Act 2016; the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 (as amended); and the Welsh Ministers’ statutory guidance for care homes and domiciliary support services issued under section 29 of the 2016 Act (which service providers and responsible individuals must have regard to). We will also comply with Social Care Wales Codes of Professional Practice (including the Code of Practice for Employers), CIW requirements and inspection expectations, UK employment law, equality and human rights law, data protection law, safeguarding law, and UK immigration law and Home Office sponsor guidance (where sponsorship applies).

This policy ensures that international recruitment supports the delivery of high-quality care services while upholding the rights, dignity, and well-being of international employees. It also ensures that all international staff are appropriately vetted, supported, and integrated into the workforce while safeguarding the interests of service users and maintaining compliance with CIW regulations.

2. Scope

This policy applies to: International applicants seeking employment with {{org_field_name}}. Recruitment agencies and overseas partners involved in international hiring. The HR team, managers, and Responsible Individuals overseeing recruitment. Existing staff supporting international employees in the workplace.

This policy also applies to agency staff, temporary workers, contractors, and any person engaged under a contract for services (including where an agency supplies staff), because CIW expects the same recruitment/fitness checks to be evidenced for non-permanent staff.
Where immigration rules restrict new overseas recruitment, this policy also covers the recruitment of “displaced” international care workers already in the UK who hold appropriate permission to work (including sponsored workers seeking lawful redeployment).

It covers: Ethical recruitment practices. Sponsorship and visa compliance. Pre-employment screening and qualifications verification. Induction and training. Workplace integration and ongoing support. Legal responsibilities and compliance monitoring.

3. Principles of Ethical International Recruitment

3.1 Ethical and Fair Recruitment Practices

{{org_field_name}} is committed to ethical recruitment, ensuring that international workers are not exploited, misled, or unfairly treated. All recruitment processes must comply with the UK Government Code of Practice for the international recruitment of health and social care personnel (including its red/amber list approach), alongside the WHO Global Code of Practice, and any Welsh Government / Social Care Wales requirements applicable in Wales.

This means that: Only Home Office-approved routes and ethical recruitment agencies are used. We will not actively recruit from countries on the Code of Practice red list (and we will follow the Code’s approach for amber list countries), unless a permitted government-to-government agreement or other Code-compliant exception applies. We will document the rationale and the steps taken to ensure compliance for each campaign. No worker is charged recruitment fees or subject to unethical financial agreements. All job offers are clear, transparent, and legally binding. Workers receive fair wages and the same rights as UK-based staff.

3.2 Due diligence of recruitment agencies and labour providers (including modern slavery checks)

{{org_field_name}} will only use recruitment agencies / labour providers that can demonstrate ethical recruitment and compliance with UK law. Before using a new agency, and at least annually thereafter, we will complete and record due diligence checks including:

Where we cannot evidence robust checks, the worker will not be deployed and the agency will not be used. Staff will be reminded of how to report concerns (including to the Modern Slavery & Exploitation Helpline and/or GLAA where appropriate).

3.3 Compliance with Immigration and Sponsorship Requirements

International recruits must have the appropriate right to work in the UK. {{org_field_name}} is a licensed sponsor under the Skilled Worker Visa route and adheres to all sponsorship requirements, including: Issuing Certificates of Sponsorship (CoS) to eligible candidates. Ensuring compliance with salary thresholds and job role eligibility. Keeping accurate records of all sponsored employees. Monitoring visa expiry dates and right-to-work status. Reporting any changes or breaches to UKVI.

Regular audits and compliance checks ensure that {{org_field_name}} meets all UKVI sponsor duties and avoids legal risks.

Immigration routes and eligibility for social care roles can change. Before advertising overseas, issuing a Certificate of Sponsorship, or making any sponsorship commitment, {{org_field_name}} will confirm that the role remains eligible under current Home Office rules and that any Wales-specific guidance has been considered. Where Welsh Government guidance indicates restrictions or changes to overseas recruitment, we will follow that guidance and prioritise lawful recruitment from within the UK labour market, including displaced international care workers already resident in the UK with valid permission to work.

Where we are a licensed sponsor, we will comply with the latest Home Office sponsor guidance on compliance, reporting and record-keeping (including Appendix D). We will keep evidence of right-to-work checks, recruitment/selection evidence, pay evidence, and other required documents for the required retention period, and make them available promptly on request.

3.4 Pre-Employment Checks and Qualification Verification

Before offering employment, {{org_field_name}} ensures that all international candidates undergo thorough pre-employment screening, including: Enhanced DBS (Disclosure and Barring Service) checks to verify suitability for working with vulnerable people. Verification of identity and right-to-work documents using the Home Office online right-to-work service (share code) where applicable, and/or eVisa status, together with any other evidence required by current Home Office guidance (noting BRPs are being replaced by eVisas). Confirmation of professional qualifications and registration with Social Care Wales, where required. References from previous employers and checks on employment history. Health screenings to ensure candidates are fit to work in a care setting.

Where necessary, additional English language proficiency assessments are conducted to ensure workers can communicate effectively with service users and colleagues.

All recruitment/fitness information and documentation required by Regulation 35 and Part 1 of Schedule 1 (including DBS evidence, identity, employment history, references and qualifications evidence) will be obtained and retained in a form that is available for inspection by CIW. For domiciliary care roles that require Social Care Wales registration, we will ensure registration is completed by the statutory “relevant date” and we will evidence ongoing registration status checks.

3.5 Induction and Training for International Workers

To ensure a smooth transition and high-quality care delivery, all international recruits must complete a comprehensive induction and training programme that includes: An introduction to UK social care legislation, CIW regulations, and Social Care Wales Codes of Practice. Training in person-centred care, safeguarding, medication administration, and infection control. A review of UK workplace rights, health and safety, and employment expectations. Support with cultural adaptation and communication in care settings.

Newly recruited international workers are assigned a mentor or buddy to provide practical and emotional support during their first months of employment.

Induction will include the specific information CIW expects staff to receive and understand, including: the ethos and culture of the service; staff roles/responsibilities and line accountability; policies and procedures; record-keeping requirements; confidentiality and data protection requirements; safeguarding reporting arrangements; and lone-working arrangements. Staff must confirm they have read and understood key policies during induction, and understanding will be revisited through supervision and performance review.

3.6 Workplace Integration and Ongoing Support

International staff must feel welcomed, valued, and supported in their roles. {{org_field_name}} ensures effective integration by: Providing clear employment contracts, outlining rights, responsibilities, and benefits. Offering language support and professional development opportunities. Encouraging cultural exchange and inclusivity in the workplace. Providing access to employee assistance programmes, mental health support, and pastoral care. Ensuring fair shift patterns, pay, and access to career progression.

Regular one-to-one check-ins with HR and management help identify any concerns, allowing for proactive resolution of workplace challenges.

3.7 Addressing Challenges and Preventing Exploitation

International employees may face challenges such as cultural adaptation, housing issues, or financial concerns. {{org_field_name}} actively prevents exploitation and mistreatment by: Ensuring all contracts comply with UK employment law, providing clear and fair terms. Supporting employees in securing suitable accommodation and local services. Providing access to independent legal and employment rights advice. Encouraging an open-door policy where staff can report concerns confidentially. Taking swift action against any form of discrimination, unfair treatment, or abuse.

{{org_field_name}} will not retain workers’ passports/identity documents and will not allow any third party to do so. We will not impose unlawful deductions, coercive accommodation arrangements, or financial penalties that could create debt bondage or restrict freedom to change employer. Any accommodation support offered will be voluntary, transparent, and documented separately from the employment contract.

Managers will be trained to recognise CIW-highlighted warning signs of modern slavery/exploitation. Where concerns arise, we will take immediate safeguarding and employment-law appropriate action and support the worker to report concerns (including via the Modern Slavery & Exploitation Helpline and/or GLAA, and to CIW where relevant).

If an employee feels pressured, underpaid, or mistreated, they have the right to report concerns internally or to external bodies such as CIW, ACAS, or the Home Office.

3.8 Monitoring Compliance and Continuous Improvement

{{org_field_name}} ensures ongoing compliance with international recruitment standards through: Regular audits of recruitment and employment records. Annual reviews of sponsorship obligations. Internal feedback mechanisms to assess the experiences of international workers. Engagement with industry best practices and updates on immigration laws. Collaboration with Social Care Wales and CIW for workforce planning.

By continuously improving our recruitment, training, and support systems, {{org_field_name}} upholds high standards of care while ensuring international workers have a positive, safe, and rewarding career.

3.9 Record keeping, retention and data protection

{{org_field_name}} will keep complete, accurate and accessible recruitment, employment and sponsorship records. Records will be stored securely and processed in line with the Data Protection Act 2018 and UK GDPR, and only retained for as long as necessary for legal, regulatory and safeguarding purposes.

Where sponsorship applies, we will meet the Home Office record-keeping duties set out in Sponsor Guidance Appendix D, including retaining evidence of right-to-work checks, recruitment evidence, salary/pay evidence and other required documents for the required retention period, and making them available promptly on request.

Recruitment/fitness records required under Welsh regulations (including Schedule 1 evidence) will be maintained in a form suitable for CIW inspection.

4. Efficiency in Managing International Recruitment and Employment

To ensure efficiency, {{org_field_name}} implements: A structured onboarding system, streamlining visa applications, background checks, and contract processing. Dedicated HR personnel trained in international recruitment and compliance. Digital tracking systems to monitor visa statuses, work permits, and contract renewals. Centralised documentation management, ensuring all legal and employment records are easily accessible. Proactive workforce planning, ensuring recruitment aligns with service user needs and business sustainability.

These measures allow {{org_field_name}} to manage international recruitment legally, ethically, and efficiently, avoiding delays and ensuring high standards of care delivery.

5. Related Policies

This policy should be read alongside:

6. Policy Review

This policy will be reviewed at least annually and additionally within 30 days of any material change to:

UK immigration rules and/or Home Office sponsor guidance affecting social care recruitment or sponsorship.

Welsh social care legislation/statutory guidance or CIW requirements

Social Care Wales Codes/registration requirements

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

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