Here are a few of the checks auditors can use, depending on the situation: - Auditors should read through the terms of engagement/MoU's signed between factories and agents for providing the service. - Verify whether or not the agent is registered with local authorities and meets ALL requirements of local law for providing services... - Speak to stakeholders and other interested parties, including local NGOs and unions. - Ask HR staff to explain the process and see if it meets the written arrangement/MoU. - Ask workers how much they pay recruitment agents. If HR malpractice is identified, it will require a very tactful and astute auditor to break the news to top management.