- TDIC and EAA should monitor compliance by contractors and subcontractors through an independent and transparent process that includes interviews with workers in their native language. They should penalize contractors working with agents or sub-agents who are found to have charged workers recruitment fees, and should terminate relationships with contractors that continue to work with agencies or sub-agencies that charge workers fees. The penalties should be severe enough to act as deterrent rather than a routine cost of business. The Guggenheim, the Louvre/AFM, and NYU should seek regular updates on compliance and insist that their development partners enforce penalties for violations and terminate relationships with repeat violators.
- TDIC and the EAA should explicitly commit to reimbursing workers for any recruiting fees they are found to have paid when contractors have failed to do so. If TDIC or the EAA also fails to fulfill this obligation, NYU, the Guggenheim and AFM/the Louvre should step in to reimburse any outstanding recruitment fees paid by workers on their respective sites.
- TDIC and EAA should require all contractors and subcontractors to obtain copies of contracts signed by workers in their home countries, in their native languages, attesting to the terms of their employment. If workers have already held jobs in the UAE and are recruited in-country, contractors should provide signed and notarized undertakings in workers’ native languages that clearly state the terms and conditions of their employment.
- TDIC and EAA should immediately require all contractors, subcontractors, and labor suppliers to return workers’ passports to their physical possession.
- TDIC and EAA should penalize contractors, subcontractors, or labor suppliers who are found to have confiscated passports, and should terminate relationships with those that continue to do so. The Guggenheim, the Louvre/AFM, and NYU should seek regular updates on compliance and insist that their development partners enforce penalties for violations and terminate relationships with repeat violators.
- TDIC and the EAA should release comprehensive information about the terms of reference and methodologies of the monitoring firms they have engaged to demonstrate their respective firms’ independence in auditing and reporting.