Code of Conduct for Recruitment Partners

1. Status and application

1.1. This Code sets the conditions on which a Recruitment Partner recruits for vacancies of the Company. It is an integral part of the Cooperation Agreement between the Company and the Partner.

1.2. In this Code "the Company" means LIMITED LIABILITY COMPANY «UKRAINE WORKS CONSULTING», which concludes the Cooperation Agreement (clause 5.8 of the Ethical Recruitment Policy), and "the Partner" means the Recruitment Partner that is party to it.

1.3. The Code binds the Partner, its owners, directors, employees and branches, and every person who acts for it. The Partner shall be liable for a breach of this Code by any of them, and by any Sub-agent, as for its own breach.

1.4. Where the law of the Partner's country and this Code set different levels of protection for a Candidate or Worker, the Partner shall apply the provision that gives the greater protection, unless a mandatory rule of that law prevents it; in that case the Partner shall notify the Company in writing before it applies the rule. A rule of local law that allows a recruitment agency to charge a worker is not a defence to a breach of clause 5.

1.5. Where the Cooperation Agreement and this Code conflict, the provision that gives the greater protection to the Candidate or Worker prevails.

1.6. The Cooperation Agreement contains the provisions listed in Schedule 2.

1.7. This Code binds a Partner from the date on which the Partner signs it (clause 23) or on which an additional agreement incorporates it into the Cooperation Agreement. It does not change a Cooperation Agreement for any period before that date.

2. Definitions

2.1. Capitalised terms have the meaning given in clause 3 of the Ethical Recruitment Policy (UW-POL-01), the English text of which is supplied to the Partner with this Code. The definitions used most often in this Code are set out below; where the wording differs from the Policy, it is adapted to this Code and has the same meaning.

Complaints Leaflet means the short description of the Grievance and Remedy Procedure (UW-PRO-01) that the Company publishes for Candidates and Workers under the number UW-LFT-01.

Candidate means a person who has applied, or has been approached, for a vacancy handled by the Company, whether or not the person is later employed.

Offer means the written offer of employment on form UW-F-13, issued to a Candidate by the Employer or by the Company on the Employer's behalf. An Offer is accepted on the date on which the Candidate signs and dates it.

Personal Documents means a passport or other identity document, a temporary residence permit, a visa, a certificate of education or qualification, a driving licence, the person's copy of any contract and of the work permit, and any bank card, bank book or document of title to property.

Recruitment Fees and Related Costs have the meanings given in paragraphs 6 and 9 to 12 of the Definition of Recruitment Fees and Related Costs of the International Labour Organization (2019): any fees or costs incurred in the recruitment process in order for workers to secure employment or placement, regardless of the manner, timing or location of their imposition or collection. Schedule 1 itemises the charges prohibited.

Sub-agent means any person or entity, formal or informal, that finds Candidates for the Partner, refers Candidates to it or handles their applications or documents on its behalf, and is neither the Partner nor its employee.

Worker means a Candidate who has accepted an Offer, from the acceptance until the end of the employment and, where the Worker returns to the country of origin, until the return is completed.

2.2. "Including" means "including without limitation". "In writing" includes electronic mail. For a period that the Partner must observe, "working day" means a day on which the Partner's registered office is open for business under the law of its country.

3. Authorisation and compliance with law

3.1. The Partner shall hold at all times the authorisation required in its country for recruitment for foreign employment: in India, a registration certificate under section 10 of the Emigration Act, 1983; in Nepal, a licence under sections 10 and 11 of the Foreign Employment Act, 2064 (2007).

3.2. The Partner shall comply with the law of its country on emigration, recruitment, labour, data protection, taxation and the prevention of corruption.

3.3. Before a Worker departs, the Partner shall obtain every clearance, approval or permit that the law of its country requires for that Worker and shall give the Company a copy.

3.4. The Partner shall notify the Company in writing within 5 working days if its authorisation is suspended, restricted, not renewed or under investigation, or if a court or a public authority makes a decision against it in a matter that concerns workers.

3.5. From the day on which its authorisation is suspended, cancelled or expires, the Partner shall stop all recruitment for vacancies of the Company and shall send no Worker for departure until the authorisation is restored and the Company has confirmed this in writing.

4. Fundamental rights

4.1. The Partner shall not use, arrange or benefit from forced labour or trafficking in persons, and shall not recruit by threat, pressure, deception or the abuse of a Candidate's debts, family circumstances or lack of information.

4.2. The Partner shall not put forward a Candidate who is under 21 years of age on the day on which the Partner sends the Candidate's profile to the Company. It shall verify the age against the original passport at registration and keep a copy of the data page.

4.3. The Partner shall select Candidates on skills, qualifications, experience and the requirements inherent in the job. It shall make no distinction on the ground of race, colour, ethnicity, caste, national or social origin, nationality, sex, gender identity, sexual orientation, religion or belief, political opinion, trade union membership, disability, state of health, suspected or actual HIV status, pregnancy, marital or family status, family responsibilities, property status, place of residence, language or any other status unrelated to the nature of the work. The Partner shall take age into account only as clause 4.2 requires, and shall apply a requirement as to education, state of health, language or sex only where the job order supplied by the Company states it.

4.4. The Partner shall not require a pregnancy test or an HIV test. It shall request a medical examination only where the law or the nature of the work requires it and shall use the result for that purpose only.

4.5. No agreement or form that the Partner asks a Candidate to sign shall prohibit or discourage joining or forming a trade union or bargaining collectively.

4.6. The Partner shall treat every Candidate and Worker with dignity and respect. It shall not commit, and shall not permit its staff or its Sub-agents to commit, any threat, violence, verbal abuse, sexual harassment, humiliation or other form of harassment, coercion or degrading or inhuman treatment.

5. Recruitment Fees and Related Costs

5.1. The Partner shall not charge, collect or accept from a Candidate or Worker, directly or indirectly, in whole or in part, any Recruitment Fee in connection with a vacancy of the Company, or any Related Cost other than as clauses 5.4 to 5.6 permit. Schedule 1 lists the charges this clause prohibits.

5.2. The prohibition applies whether or not local law allows the charge. In particular, the Partner shall not collect the service charge allowed by rule 25 of the Emigration Rules, 1983 (India) or the service charge and promotional costs allowed under section 24 of the Foreign Employment Act, 2064 (2007) (Nepal).

5.3. The Partner shall accept payment for its services from the Company alone, under the Cooperation Agreement.

5.4. The Partner shall not ask or allow a Candidate to pay any sum in connection with a vacancy of the Company other than an item that the Cost Disclosure Statement (UW-F-02) for the vacancy allocates to the Worker. Where such an item falls due before the Offer is given, the Partner shall first tell the Candidate in writing what the item is, its amount and the payee, and shall enter the item in the Cost Disclosure Statement when the Offer is given.

5.5. The Partner shall arrange for the Candidate to pay such an item directly to the provider, at the provider's actual price and only where the charge is lawful in the country in which it is made.

5.6. Where the Partner pays the provider on the Candidate's behalf, it shall recover from the Candidate the amount shown on the provider's receipt and nothing more, and shall give the Candidate that receipt on the day of recovery.

5.7. The Partner shall give the Cost Disclosure Statement to each Candidate, in a language the Candidate understands, together with the Offer and not less than two full days before the Candidate signs the Offer. It shall add no item and increase no amount afterwards, except a change in an official tariff, of which the Partner shall notify the Candidate in writing before payment.

5.8. The Partner shall state in every advertisement of a vacancy of the Company that neither the Company nor the Partner charges a fee for recruitment and that every cost the Candidate will bear is disclosed in writing before the Candidate's application is presented to an employer, and shall give in it the Company's contacts for reporting a demand for payment: support@ukraineworks.com.ua; telephone, WhatsApp and Telegram +380 99 878 1755.

5.9. The Partner shall not request, accept or make a payment, or give or receive any other benefit, for including a Candidate in a shortlist, for the order of Candidates in it or for removing a Candidate from it.

6. Deposits and loans

6.1. The Partner shall not require or accept from a Candidate or a member of the Candidate's family any deposit, bond, guarantee, promissory note, blank cheque or other security.

6.2. The Partner shall not lend money to a Candidate or arrange a loan for a Candidate. It shall not refer a Candidate to a particular lender, clinic, training centre or travel agent in return for a payment or other benefit.

6.3. The Partner shall charge no penalty to, and claim no costs from, a Candidate who withdraws at any stage.

7. Sub-agents

7.1. The Partner shall recruit through its own employees and offices.

7.2. The Partner shall not use a Sub-agent without the Company's prior written consent. A request for consent shall state the Sub-agent's name, address, registration, the area in which it works and how the Partner pays it.

7.3. Where consent is given, the Partner shall bind the Sub-agent in writing to this Code, pay the Sub-agent itself and give the Company a copy of the agreement. It shall ask each Candidate whom the Sub-agent referred whether the Sub-agent asked for or took any payment, and shall record the answer in the Candidate's file.

7.4. The Partner shall record, for each Candidate, every person and entity that took part in the recruitment, and shall send the Company the record of each Worker with the documents under clause 18.2.

8. Advertising and information

8.1. The Partner shall advertise a vacancy only on the terms the Company has supplied in writing: Employer, place of work, position, wage, working hours, duration of the contract, accommodation and costs. It shall send the Company a copy of each advertisement, with the date and the place of publication, not later than the day on which it is published, and shall keep a copy with the records under clause 18.1.

8.2. The Partner shall make no promise beyond those terms. It shall not promise overtime earnings, permanent residence, family reunion or onward travel to another State.

8.3. Together with the Offer and not less than two full days before the Candidate signs the Offer, the Partner shall give every Candidate, in a language the Candidate understands, the Security Information Sheet (UW-F-14) completed by the Company for the vacancy, shall obtain the Candidate's dated signature on a copy and shall send the Company a scan. Where the Company issues an updated sheet, the Partner shall give it, within 2 working days of receiving it, to every Candidate and Worker for the vacancy who has not departed, shall obtain a dated signature on a copy and shall send the Company a scan.

8.4. The Partner shall not ask a Candidate to sign the Offer earlier than two full days after the Candidate received it with the text of the Employment Contract and its translation, or before the contract has been explained under clause 11.2. The Partner shall send the Company a scan of each signed Offer within 2 working days of its signature.

8.5. Before presenting a Candidate's application for a vacancy, the Partner shall give the Candidate a copy of Part A of the job order (UW-F-13) and the preliminary Cost Disclosure Statement completed by the Company for the vacancy, shall explain both in a language the Candidate understands, shall obtain the Candidate's dated signature on the preliminary statement and shall send the Company a scan of it on the same day (clause 15.14 of the Ethical Recruitment Policy). The Partner shall not present an application before it has done so.

9. Recruitment Service Terms

9.1. Before collecting any personal data, the Partner shall give each Candidate, in a language the Candidate understands, the Recruitment Service Terms (UW-F-01), the Privacy Notice for Candidates and Workers (UW-NOT-01) or its plain-language summary in the Candidate's language, and the Complaints Leaflet, and shall explain them.

9.2. The Partner shall then obtain the Candidate's signature on the Recruitment Service Terms and on the Consent to the Processing of Personal Data (UW-F-11). It shall copy the passport data page under clause 4.2 only after both have been signed.

9.3. The Partner shall sign the Recruitment Service Terms on its own behalf and on behalf of the Company, which authorises it to do so by this clause.

9.4. The Partner shall give the Candidate a copy of each signed document.

9.5. The Partner shall not ask a Candidate to sign a blank or incomplete document.

10. Personal Documents

10.1. The Partner shall not withhold, keep for safekeeping, destroy or confiscate a Candidate's Personal Documents. The Candidate's consent does not make such keeping permissible. The Partner shall work from copies.

10.2. Where a consulate, a visa centre or another public authority requires an original document in order to decide an application, the Candidate submits it in person where the procedure allows. Where the Candidate does not submit the document in person and the procedure permits submission through a representative, the Partner shall deliver the document only: with the Candidate's prior written consent on the Document Handover Record (UW-F-05); for the single application named in the record; after giving the Candidate a copy of the document and of the record; and against an entry in its document log showing the purpose, the date of handover, where the document is held and the date of return.

10.3. The Partner shall send the Company a scan of the Document Handover Record within 2 working days of the handover and again within 2 working days of the return.

10.4. The Partner shall return the document to the Candidate on the day on which it collects the document from the authority or, where the Candidate is not present on that day, shall hand it over or dispatch it by tracked delivery not later than the next working day. The Partner shall attach no condition to the return and shall charge nothing for it.

10.5. The Partner shall tell the Candidate, on the same working day on which the Candidate asks, where the document is. Where the Candidate requires its return, the Partner shall apply to the authority for release of the document not later than the next working day and shall return it under clause 10.4. Where the Partner itself holds the document, it shall return it on the same working day.

10.6. The Partner shall not use possession of, or access to, a Personal Document to secure a Candidate's acceptance of an Offer or a Worker's departure. The Partner shall confirm with each Worker, when the Worker signs the Worker's Pre-Departure Declaration (UW-F-04), that the Worker holds his or her own Personal Documents, and shall not arrange or confirm the departure of a Worker who does not hold them.

10.7. The Partner shall not request or hold a bank card, a bank book, a PIN code or a document of title to property of a Candidate or of a member of the Candidate's family.

11. Employment Contract

11.1. The Partner shall give each Candidate the Offer, with the full text of the Employment Contract and a translation into a language the Candidate understands, not less than two full days before the Candidate signs the Offer.

11.2. The Partner shall explain the contract orally in the Candidate's language, answer the Candidate's questions, and record on form UW-F-03 the date, the manner and the language in which the contract was given and explained.

11.3. The Partner shall not change, replace or add to the terms of the Employment Contract.

11.4. The Partner shall not ask the Worker to sign any other agreement about the employment, except an agreement that the law of the Partner's country requires (in Nepal, the contracts required by section 25 of the Foreign Employment Act, 2064 (2007)). Such an agreement shall contain no term less favourable to the Worker than the draft Employment Contract supplied by the Company and shall impose no payment on the Worker. The Partner shall send the Company a copy before the Worker signs it.

11.5. The Partner shall leave a copy of the contract with the Worker.

12. Pre-departure orientation

12.1. The Partner shall give each Worker pre-departure orientation in the Worker's language, in accordance with form UW-F-03 and the material supplied by the Company. The Partner shall not arrange or confirm a Worker's departure without it.

12.2. The Partner shall check the Worker's understanding by questions, note the answers on the form, and obtain the signatures of the Worker and of the person who gave the orientation. Where an answer shows that the Worker has not understood a topic, the Partner shall explain the topic again, repeat the question and note the answer. The Partner shall not confirm the departure of a Worker who still cannot answer the questions in Part E of the form until it has repeated the orientation and recorded the answers.

12.3. The Partner shall give each Worker, on paper and in the Worker's language, the Complaints Leaflet, the list of bodies in Annex 2 to the Grievance and Remedy Procedure and the contact details of the Worker's embassy or consulate responsible for Ukraine.

12.4. Where the law of the Partner's country requires orientation by an approved institution, that orientation is in addition to the orientation under this clause.

12.5. The Partner shall not be present at, and shall not obstruct, the Company's direct contact with the Worker before departure. It shall give the Company the Worker's own telephone number not later than the day on which the Offer is signed.

13. Lodging and travel before departure

13.1. Where the Partner arranges lodging for a Candidate before departure: (a) the Candidate shall have a separate bed, drinking water and washing and toilet facilities; (b) the Candidate shall keep his or her own Personal Documents and telephone and shall be free to leave at any time; (c) the Partner shall make no charge for lodging that it, its owner, its employee or a Sub-agent provides; and (d) a charge by any other provider shall be an item of the Cost Disclosure Statement and shall be paid as clauses 5.5 and 5.6 require.

13.2. The Partner shall give each Worker, before departure, the itinerary, the tickets and the name and telephone number of the person who will meet the Worker.

14. Personal data

14.1. The Partner shall collect and use Candidates' personal data only for recruitment for vacancies of the Company and only to the extent stated in the Privacy Notice for Candidates and Workers (UW-NOT-01).

14.2. The Partner shall not sell the data. It shall disclose them only to the Company, to the public authorities that need them for the Worker's documents and to providers of the kinds listed in section 7 of the Privacy Notice, in each case to the extent needed for the recruitment.

14.3. The Partner shall keep electronic data in accounts protected by an individual password and paper documents in a locked cabinet, limit access to the staff who work on vacancies of the Company, and notify the Company within 72 hours of any loss, leak or unauthorised access.

14.4. The Partner shall delete or return the data within 10 working days of a request by the Company or the Candidate, except the records it must keep under clause 18 or under its own law, and shall confirm in writing that it has done so.

15. Integrity

15.1. The Partner shall not offer, give, request or accept a bribe, kickback, gift or other improper advantage. This applies to dealings with public officials, Employers, Candidates and the Company's Personnel.

15.2. The Partner shall disclose to the Company in writing any conflict of interest, including a family or business connection with an Employer or with a member of the Company's Personnel.

15.3. The Company and the Partner shall make every payment between them by bank transfer against an invoice.

16. Grievances and non-retaliation

16.1. The Partner shall inform every Candidate, in writing and in the Candidate's language, how to make a complaint to the Company: support@ukraineworks.com.ua; telephone, WhatsApp and Telegram +380 99 878 1755.

16.2. The Partner shall not obstruct or discourage a complaint and shall take no adverse action against a Candidate, a Worker or a member of their family because of one.

16.3. The Partner shall answer the Company's questions about a complaint within 3 working days and shall cooperate in its investigation.

16.4. The Partner shall keep its own procedure for complaints by Candidates and Workers, shall name to every Candidate a person who receives complaints and speaks the Candidate's language, shall record each complaint and its result, and shall send the Company a copy of every complaint that concerns a vacancy of the Company within 2 working days of receiving it. The Company enters the complaint in its Grievance Register and handles it under the Grievance and Remedy Procedure; the Partner's own handling does not replace this. The Partner shall not investigate or decide a complaint about itself or its Sub-agent; the Company does so (clause 11.4 of that Procedure). The Partner shall not ask a Candidate or Worker to withdraw a complaint or to sign a statement that it is settled.

17. Management of compliance

17.1. The Partner shall name, in the acknowledgement in clause 23, an employee who reports directly to its director or owner and has authority to stop the recruitment of a Candidate. That person is responsible for compliance with this Code and is the Company's point of contact. The Partner shall notify the Company in writing within 5 working days of a change of that person.

17.2. The Partner shall train every employee who deals with Candidates on this Code before that employee works on a vacancy of the Company and at least once every twelve months thereafter, and shall keep a signed record of the training.

18. Records

18.1. For each Worker the Partner shall keep: the copy of the passport data page; the signed Recruitment Service Terms and Consent to the Processing of Personal Data; the signed Offer and Security Information Sheet; the signed Cost Disclosure Statement with the receipts for every payment made by the Worker; the Pre-Departure Orientation Record; the Worker's Pre-Departure Declaration; and any Document Handover Record.

18.2. The Partner shall send the Company a scan of each of those documents before the Worker departs, and the scan of the signed Worker's Pre-Departure Declaration on the day on which the Worker signs it.

18.3. The Partner shall keep the records for 3 years after departure, and the records that concern an open complaint or an unpaid reimbursement until the Company confirms in writing that the matter is closed. It shall delete the records of a Candidate who is not selected or who withdraws within 3 months after the selection for the vacancy is completed, that is, after the day on which the Company informs the Partner in writing that the Employer has made its choice or has withdrawn the vacancy, or, where the Candidate has consented on line 5 of form UW-F-11 to the keeping of the profile for other vacancies, not later than 24 months from the last contact with the Candidate. A record that the law of the Partner's country requires it to keep is kept for that purpose only.

19. Monitoring and audit

19.1. The Company may at any time verify compliance with this Code. It may inspect records, visit the Partner's offices, with or without notice, and interview Candidates and Workers without the Partner present.

19.2. The Partner shall produce the records requested within 5 working days.

19.3. The Partner shall not instruct a Candidate or Worker on what to say to the Company and shall take no adverse action against anyone for what was said.

20. Reporting

20.1. The Partner shall report to the Company in writing, within 2 working days of learning of it, every breach of this Code and each of the following events involving a Candidate or Worker: a death; an injury or illness that requires medical care; a detention or arrest; a missed departure; the loss of a Personal Document; a demand for payment; and any other event that puts the person's life, health or liberty at risk.

21. Breach and remedies

21.1. Where a sum has been taken from a Candidate or Worker in breach of clause 5 or 6, by anyone in the Partner's organisation or by a Sub-agent, the Partner shall repay it in full to the person who paid it within 30 calendar days of the date of the Company's written notice of the finding and shall send the Company proof of repayment. The Partner shall not refuse repayment for want of a receipt where the Company's notice states that the information gathered makes it more likely than not that the payment was made (clause 12.3 of the Grievance and Remedy Procedure). The Partner shall likewise reimburse, within the same period, every sum paid in connection with the recruitment by a Candidate whom it put forward in breach of clause 4.2.

21.2. For each Candidate or Worker affected by a breach of clause 5, 6 or 10, whether committed by the Partner, by a member of its staff or by a Sub-agent, the Partner shall pay the Company a contractual penalty. Unless the Cooperation Agreement fixes a higher amount, the penalty equals the fee that the Cooperation Agreement fixes for one placement, whether or not the person affected was placed. Where a sum was taken in breach of clause 5 or 6, the penalty is not less than twice that sum. The penalty is payable in addition to repayment under clause 21.1.

21.3. Where the Partner has not repaid within the period in clause 21.1, the Company may withhold the sum from any amount it owes the Partner and pay it to the person concerned.

21.4. Where the Company itself repays a Candidate or Worker a sum that the Partner was bound to repay under clause 21.1, the Partner shall reimburse the Company within 10 working days of the Company's written demand.

21.5. For any other breach the Partner shall submit to the Company, within 10 working days of the Company's notice, a corrective action plan that states the cause, the action, the person responsible and the date for completion.

21.6. The Company may approve the plan or require changes to it. The Partner shall carry out the plan as approved and shall give the Company evidence of completion not later than the date for completion stated in it.

21.7. The Company may suspend the placing of new vacancies with the Partner, and the processing of Candidates who have not departed, while a corrective action plan is open, while the Company investigates an allegation of conduct listed in clause 21.8 or, where such conduct has been found, for the period that the Company fixes in writing. A suspension under this clause is not a breach of the Cooperation Agreement by the Company.

21.8. The Company may terminate the Cooperation Agreement with immediate effect where the Partner: breaches clause 4.1; charges a Candidate in breach of clause 5; takes a deposit or security in breach of clause 6; retains a Personal Document in breach of clause 10; deceives a Candidate; uses a Sub-agent without consent; puts forward a person under 18; gives or takes a bribe; retaliates against a person who made a complaint; obstructs an audit; has its authorisation cancelled or lets it expire; or fails to complete a corrective action plan by the date for completion stated in it.

21.9. Termination does not release the Partner from its obligations to Candidates and Workers already recruited or from the obligations under clauses 21.1, 21.2 and 21.4.

21.10. The Company may report to the competent authority conduct that appears to be an offence under the law of the Partner's country.

22. Obligations of the Company

22.1. The Company shall supply the Partner, for each vacancy, with the terms that the Employer stated on form UW-F-13, the Offer, the Security Information Sheet, the Cost Disclosure Statement and the text of the Employment Contract.

22.2. The Company shall pay the Partner the fee fixed in the Cooperation Agreement within the period fixed there. The Partner confirms that the fee covers the full cost of the services required by this Code and that it will make no claim on a Candidate or Worker if its costs exceed the fee.

22.3. The Company shall supply, in English, the forms, the Privacy Notice and its plain-language summary, the Complaints Leaflet, the orientation material and the training material referred to in this Code, and shall supply the worker-facing texts also in Hindi and Nepali.

22.4. The Company may amend this Code by written notice to the Partner given not less than 30 calendar days before the amendment takes effect. The amended Code binds the Partner from that date unless, before that date, the Partner terminates the Cooperation Agreement by written notice. Clause 21.9 applies to such a termination.

22.5. The Company shall keep confidential the commercial information it obtains in an audit.

23. Acknowledgement

The Partner has read this Code, has explained it to its staff and undertakes to comply with it.

Schedule 1. Charges prohibited by clause 5

The Partner, its staff and its Sub-agents shall not charge, collect or accept from a Candidate or Worker any of the following, whatever it is called and whenever it is taken.

Schedule 2. Provisions that the Cooperation Agreement must contain

1. The fee payable by the Company to the Partner and the terms of payment.
2. The statement that the Partner is paid for its services by the Company alone, charges a Candidate or Worker no Recruitment Fee and no Related Cost other than as clauses 5.4 to 5.6 of this Code permit, and takes no deposit or other security.
3. The incorporation of this Code as an integral part of the agreement.
4. The duty to disclose every Sub-agent and the prohibition of subcontracting without the Company's prior written consent.
5. The Company's right to audit, to inspect records and to interview Candidates and Workers.
6. The contractual penalty under clause 21.2 of this Code, and the Company's rights under clauses 21.3 and 21.4.
7. The duty to repay Candidates and Workers.
8. The grounds for suspension and for termination with immediate effect.
9. The confidentiality and data-protection obligations of both parties.
10. The governing law and the forum for disputes.
11. The Partner's authority to sign the Recruitment Service Terms (UW-F-01) on behalf of the Company.