White Bay Recruitment Ltd ("White Bay" or "the organisation") operates in Australia, Canada and the United States, connecting employers and skilled professionals. Because recruitment sits at the intersection of people’s careers and employers’ business needs, it carries significant ethical and legal responsibilities. External guidance from professional bodies emphasises that the foundations of ethical recruitment are transparency, honesty and respect, along with strict compliance with employment laws and regulations. Fairness, non‑discrimination and the preservation of human rights underpin international standards for ethical recruitment. White Bay is committed to embedding these values in all recruitment activities.
This policy applies to every director, employee and contractor of White Bay. It covers client engagements, candidate sourcing and placement, and any third‑party recruitment arrangements. Compliance is mandatory across our offices in Australia, Canada and the United States and for any recruitment activity conducted on behalf of White Bay. Breaches of this policy may lead to disciplinary action and termination of contracts.
Guiding Principles
White Bay’s ethical recruitment principles are adapted from the International Recruitment Integrity System (IRIS) standard and industry codes of ethics. The IRIS standard outlines two overarching principles (respect for laws and fundamental rights at work, and professional conduct) and five specific principles: prohibition of recruitment fees to jobseekers; respect for freedom of movement; transparency of terms; confidentiality and data protection; and access to remedy. These principles, together with the values of transparency, honesty and respect, guide every part of White Bay’s recruitment process. All our staff must:
Comply with laws and professional standards: uphold all legislation and regulations relating to employment, human rights, privacy and labour relations, and observe professional codes of ethics;
Treat all individuals with dignity and respect: provide equal employment opportunities without discrimination on the basis of race, colour, religion, sex, gender identity, age, disability or other protected characteristics;
Operate with transparency and honesty: provide open and accurate information about roles, terms and conditions; represent candidates’ qualifications honestly; and foster trust with clients and candidates;
Maintain confidentiality and protect personal data: safeguard candidate and client information in accordance with data‑protection laws and respect privacy;
Avoid conflicts of interest: ensure that personal interests do not influence professional decisions and disclose any potential conflicts;
Promote access to remedy: provide mechanisms for candidates and clients to raise concerns or complaints and ensure they are addressed promptly.
Legal Compliance
White Bay must comply with all applicable laws in each jurisdiction where it operates. In Australia, this includes the Fair Work Act 2009, the Equal Opportunity Act 2010 (where applicable), the Australian Human Rights Commission Act 1986 and the Privacy Act 1988. In Canada, we comply with federal and provincial employment standards legislation, human‑rights codes, the Employment Equity Act 1995 and the Personal Information Protection and Electronic Documents Act. In the United States, we follow the Fair Labor Standards Act, Title VII of the Civil Rights Act, the Americans with Disabilities Act, the Equal Pay Act and relevant state laws. White Bay also upholds international instruments such as the International Labour Organization’s fundamental principles and rights at work, the IRIS standard and the WHO Global Code of Practice on the International Recruitment of Health Personnel (when recruiting health professionals).
Fairness, Equality and Non‑Discrimination
White Bay recognises that fair recruitment practices promote diversity, inclusion and business success. Our staff must:
Provide equal access to employment opportunities based on bona‑fide job requirements, and never discriminate based on race, colour, religion, sex, gender identity, age, marital status, disability, national origin, sexual orientation or any other protected ground.
Treat all applicants and employees with dignity and respect, ensuring that interactions are professional and free of harassment or bias.
Base recruitment decisions on legitimate job‑related criteria such as skills, qualifications and cultural fit, avoiding assumptions or stereotypes.
Provide reasonable accommodations for individuals with disabilities during recruitment and placement.
White Bay’s commitment to fairness also extends to promoting diversity and inclusion within our own workforce and throughout the candidate pools we source. We actively seek diverse talent, recognise the value of varied perspectives and support clients to build inclusive workplaces.
Transparency, Honesty and Disclosure
Transparency and honesty are essential to building trust between recruiters, candidates and clients. Top Echelon’s ethical recruitment guidance emphasises that transparency involves providing full disclosure about job opportunities, candidate qualifications and the recruitment process, while honesty requires truthful representation of job roles and candidate credentials. To uphold these values, White Bay will:
Provide candidates with comprehensive information about the role, including job description, employer identity (where permitted), location, remuneration, hours, benefits, safety requirements, visa and licensing requirements, and any associated costs.
Explain to candidates before assignment their wage rate, applicable benefits, hours of work and other conditions, and ensure they are promptly paid any wages and benefits due.
Represent candidates accurately to clients, disclosing relevant qualifications, experience and suitability without embellishment or misrepresentation.
Inform clients of any restrictions or conditions that may affect a candidate’s employment (for example, visa restrictions or notice periods).
Communicate openly with clients and candidates throughout the recruitment process, providing timely updates and responding to inquiries.
Prohibition of Recruitment Fees and Costs
IRIS’s first specific principle is the prohibition of recruitment fees to jobseekers. White Bay does not charge, and will not knowingly permit third parties to charge, any fees or costs to candidates for placement or recruitment services. All fees associated with recruitment are paid by clients in accordance with written agreements. Candidates will never be asked to pay placement fees, visa fees or other costs that should be borne by the employer.
Freedom of Movement and Voluntary Employment
White Bay respects workers’ freedom of movement and the right to choose and change employment. In line with the IRIS principle of respect for freedom of movement, White Bay commits to:
Never retain or withhold employees’ identity documents, passports, visas or other personal documents.
Ensure that employees are free to terminate their employment after reasonable notice, without financial penalties beyond those permitted by law.
Not impose unreasonable restrictions on employees’ ability to change jobs, relocate or leave the country (subject to legal or contractual notice requirements).
Confidentiality and Data Protection
Respecting candidate and client confidentiality is integral to ethical recruitment. The IRIS standard emphasises respect for confidentiality and data protection. White Bay will:
Handle all personal data in accordance with the Australian Privacy Act 1988, Canada’s Personal Information Protection and Electronic Documents Act, and U.S. state and federal privacy laws.
Collect, store, use and transfer personal data only for legitimate recruitment purposes, and with candidate consent.
Restrict access to personal data to authorised personnel and ensure that clients agree to similar standards.
Preserve confidentiality of sensitive information (such as medical data, salary history or immigration status) and release it only with the candidate’s permission or as required by law.
Access to Remedy and Grievance Mechanisms
Fair recruitment includes ensuring that workers can seek remedy when their rights are violated. White Bay will:
Provide clear information to candidates about how to raise concerns, complaints or grievances regarding the recruitment process, discrimination, harassment or working conditions.
Respond promptly to any concerns raised by candidates or clients and seek to resolve issues through respectful communication. ASA guidelines stress the importance of taking prompt action to address employee questions, concerns or complaints regarding unsafe work conditions or discrimination.
Co‑operate with relevant authorities or third‑party investigators in cases of alleged ethical breaches.
Support candidates in accessing legal remedies and external support services if needed.
Candidate Support and Well‑Being
White Bay’s responsibility does not end at placement. We follow ASA guidance by explaining wage rates, benefits, hours and assignment conditions before placement and paying wages promptly. We also encourage employee efforts to upgrade their skills. Our commitments include:
Assessing candidates’ experience and qualifications to ensure suitability for the role, and offering honest feedback when candidates are not selected.
Ensuring that work sites are safe and that candidates understand the nature of the work and can perform it without injury.
Providing safety information, training and protective equipment when required, and monitoring client work sites for compliance with occupational health and safety laws.
Offering opportunities for professional development and encouraging candidates to upgrade their skills and training.
Conflict of Interest and Anti‑Bribery
White Bay’s staff must avoid conflicts of interest and maintain integrity. The Top Echelon code of ethics includes guidelines on confidentiality, conflicts of interest, transparency and professional conduct. Accordingly:
Employees must disclose any personal or financial interests that could influence their professional judgement.
Staff must not accept gifts, payments or benefits from candidates or clients that could be perceived as bribes. Modest hospitality may be accepted where culturally appropriate and legally permissible, provided it does not compromise integrity.
Recruitment decisions must never be influenced by personal relationships or expectations of personal gain.
Diversity, Equity and Inclusion
White Bay supports diversity, equity and inclusion across all aspects of recruitment. NALP’s principles stress fairness, transparency and non‑discrimination. We will:
Promote inclusive job advertisements and outreach strategies that attract diverse applicants.
Provide cultural competence training to recruiters and hiring managers to mitigate implicit bias and foster inclusive interview practices.
Ensure accessibility for people with disabilities and provide reasonable accommodations during recruitment.
Encourage clients to create inclusive workplaces and support them in implementing diversity and inclusion initiatives.
Social and Environmental Responsibility
Although not explicit in most recruitment codes of ethics, White Bay recognises our broader social and environmental responsibilities. We strive to minimise our environmental footprint through sustainable office practices and to contribute positively to the communities in which we operate. We support clients who share similar commitments and prioritise partners who adhere to ethical and sustainable practices.
Modern Slavery and Human Trafficking
Modern slavery, human trafficking, forced or compulsory labour and other forms of exploitation have no place in our business or the businesses of those with whom we work. White Bay adopts a zero‑tolerance approach and will not knowingly engage in or facilitate any activity that constitutes modern slavery. We expect the same commitment from our clients, suppliers and other business partners. To uphold this pledge, White Bay will:
Comply with modern slavery laws: adhere to all applicable modern slavery and anti‑trafficking legislation, including the Modern Slavery Act 2018 (Cth) in Australia, section 54 of the Modern Slavery Act 2015 (UK) and relevant federal and provincial laws in Canada and the United States.
Assess and manage risk: conduct due diligence and assess the risk of modern slavery in our supply chains and recruitment partnerships before entering into contracts, and monitor compliance throughout the relationship.
Ensure voluntary and fair labour: verify that all employees, contractors, suppliers and clients are of legal working age and work voluntarily under fair and lawful conditions. We will not tolerate practices such as servitude, debt bondage, involuntary prison labour or the withholding of identity documents.
Prohibit exploitative recruitment practices: forbid the payment of recruitment fees by workers and prevent the use of misleading or fraudulent recruitment methods. We will disclose all terms and conditions of employment in a clear, accessible format and language and ensure workers are not misled about wages, benefits, working conditions or the location and nature of the work.
Educate our people: provide training to help staff recognise signs of modern slavery and human trafficking and understand how to respond appropriately. Training will form part of induction programmes and will be refreshed on a regular basis.
Encourage reporting: foster an environment in which concerns about modern slavery can be raised confidentially through whistleblowing procedures. We will investigate all reports promptly and, where appropriate, alert the relevant authorities and support affected individuals.
Work with responsible partners: engage only with suppliers, contractors and clients who share our commitment to eradicating modern slavery. We reserve the right to terminate relationships with any party found to be engaging in modern slavery or failing to take adequate steps to prevent it.
By embedding these measures into our operations and supply chains, White Bay contributes to the global effort to eliminate modern slavery and protect the fundamental rights of workers.
Implementation, Training and Monitoring
Ethical recruitment is an ongoing process requiring education and accountability. To embed this policy, White Bay will:
Provide regular training for all recruiters and managers on legal compliance, ethical standards, diversity and inclusion, privacy and data protection, and conflict‑of‑interest management. ASA guidelines emphasise the need to ensure that recruiters are knowledgeable about their organisation and trained to avoid bias and harassment.
Incorporate ethical objectives into performance reviews and reward ethical behaviour.
Monitor compliance through audits of recruitment processes and regular reporting to senior management. A clear process will be in place for investigating alleged breaches and enforcing corrective measures.
Review and update this policy at least every two years, or earlier if there are changes to relevant laws or industry standards.
Accountability and Enforcement
White Bay’s leadership is responsible for championing this policy and ensuring that adequate resources are allocated to its implementation. All staff are accountable for adhering to the policy and reporting any concerns or potential violations. Clients and candidates may also report concerns regarding White Bay’s conduct. Breaches of this policy may result in disciplinary action up to and including termination of employment or contracts, and may be reported to regulatory authorities.
Conclusion
White Bay’s success depends on trust from candidates who entrust us with their careers and clients who rely on us to provide talent. By embedding ethical recruitment practices based on international standards and industry codes, we honour that trust. This policy sets out our commitment to legal compliance, fairness, transparency, candidate protection, and continuous improvement. Adhering to these principles will help White Bay build long‑term relationships, protect our reputation and, most importantly, contribute to a more just and equitable recruitment landscape.
