Code of Practice for International Recruitment updated

Read about the new updates to the Code of Practice for International Recruitment.

2 August 2022

Today (2 August 2022) the Department of Health and Social Care (DHSC) has published a revised Code of Practice for the ethical international recruitment of health and social care staff in England.

The UK is committed to ensuring ethical recruitment practices operate within the UK’s public and private health and social care sectors through adherence to the Code of Practice for International Recruitment.

Find the revised Code of Practice for International Recruitment of health and social care staff in England.

The new Code is based on the principles set out in the World Health Organisation’s (WHOs) global code of practice, which will ensure effective, fair and ethical treatment of workers which should be embedded across every part of the health and social care systems.

The Code sets out responsibilities for recruiters, employers, and the government on how to maintain ethical recruitment on an ongoing basis.  

Key points of the revised Code of Practice

  • Strengthens the best practice benchmarks to ensure fairness and consistency in employment contracts and set out principles on the use of repayment clauses in employment contracts.
  • Sets out the routes of escalation for concerns about exploitative recruitment or employment practices and breaches of the code.
  • Provides more clarity on how the code applies to different international recruitment models.
  • Introduces a knowledge test for recruiting organisations applying to be on the Ethical Recruiters List.
  • Expands the scenario examples and definitions.

NHS Employers will continue to manage and maintain the list of organisations (now known as the Ethical Recruiters List) that adhere to the Code. This includes processing applications, joint working with government departments such as the Department for Business, Energy, and Industrial Strategy (BEIS) and the Employment Agency Standards (EAS) Inspectorate, monitoring adherence through spot checks, routine data collection on recruitment activity, and regular reporting to DHSC. We are also responsible for conducting investigations if a breach in the Code is suspected.

NHS Employers will be shortly contacting all agencies currently signed up to the old Code to inform them on the changes to the revised Code and ask them to reaffirm their commitment. 

Actions for employers

  • Read the updated Code and become familiar with the revised guiding principles, best practice benchmarks, and the list of countries.
  • Ensure you are working with agencies, organisations, and collaborations on the Ethical Recruiters List and they adhere to the guiding principles. The types of organisations needing to appear on the Ethical Recruiters List have been expanded, and employers should understand which types of organisations should appear on the list. 
  • If you are working in a collaboration for your international recruitment, sign up to the Code.
  • Get in touch with NHS Employers at if you suspect any breaches of the Code.

For more information, please visit our updated Code of Practice webpages, FAQs and our International Recruitment Toolkit.