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NOSWEAT.CO.ZA
NOSWEAT.CO.ZA

Anti-Slavery & Human Trafficking Policy

No Sweat Work Media CC
Trading as NoSweat
Registration Number: 2009/090625/23
Website: www.nosweat.co.za
Effective Date: 10 August 2026


1. Our Commitment

NoSweat is committed to conducting business ethically, responsibly and with respect for human dignity.

We have zero tolerance for slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, exploitative recruitment or other forms of modern slavery in our business, platform, placements or business relationships.

Section 13 of the Constitution of the Republic of South Africa provides that no one may be subjected to slavery, servitude or forced labour. South Africa’s Prevention and Combating of Trafficking in Persons Act 7 of 2013 criminalises trafficking in persons and provides measures aimed at preventing trafficking and protecting victims. (Government of South Africa)

NoSweat will not knowingly work with any client, supplier, contractor or other organisation involved in conduct that amounts to slavery, forced labour or human trafficking.


2. About NoSweat

NoSweat is a South African talent platform connecting organisations with freelance, fractional and full-time professionals.

Our platform enables:

  • candidates to create profiles and apply for work;

  • clients to post opportunities and review suitable candidates;

  • NoSweat to facilitate matching and shortlisting;

  • appropriate candidate vetting and verification;

  • freelance and employment placements; and

  • administration associated with certain freelance engagements.

NoSweat’s current platform states that candidates join free of charge, can review the stated rate or salary before applying, and select for themselves whether they wish to apply for an opportunity. (No Sweat)

Because our business operates at the point where organisations and people enter into working relationships, we recognise the importance of fair, transparent and voluntary recruitment practices.


3. Scope of This Policy

This Policy applies to NoSweat’s dealings with:

  • employees;

  • candidates and work seekers;

  • freelancers;

  • independent contractors;

  • clients;

  • suppliers;

  • service providers;

  • business partners; and

  • other persons or organisations working with or through NoSweat.

We expect everyone with whom we do business to respect the principles contained in this Policy.


4. What We Mean by Modern Slavery

For purposes of this Policy, modern slavery includes practices such as:

  • slavery;

  • servitude;

  • forced or compulsory labour;

  • human trafficking;

  • debt bondage;

  • coercive recruitment;

  • withholding wages to force a person to continue working;

  • retention or confiscation of identity or travel documents as a means of control;

  • threats, intimidation or violence used to compel work;

  • restricting a person's ability to leave employment;

  • deceptive recruitment concerning the nature or conditions of work;

  • charging unlawful recruitment fees that contribute to exploitation; and

  • unlawful or exploitative child labour.

South Africa’s Basic Conditions of Employment Act prohibits forced labour, while the trafficking legislation addresses trafficking both within and across South Africa’s borders. (Justice and Constitutional Development)

The International Labour Organization also identifies practices such as deception, restriction of movement, retention of identity documents, withholding wages, debt bondage, abusive conditions and intimidation among indicators that can point to forced labour. (International Labour Organization)


5. Fair and Voluntary Recruitment

NoSweat is committed to recruitment and placement practices based on free choice, transparency and informed participation.

Candidates must be free to:

  • decide whether to join NoSweat;

  • decide whether to apply for a particular opportunity;

  • review relevant job information before applying;

  • decline an opportunity;

  • accept or reject an engagement in accordance with the applicable terms; and

  • leave an employment or contractual relationship subject to lawful contractual obligations.

No person should be coerced, threatened or deceived into accepting or continuing work.


6. No Recruitment Fees to Work Seekers

NoSweat does not charge candidates a fee to join its talent pool or to obtain access to employment opportunities through the platform. NoSweat’s website currently states that joining the talent pool is free. (No Sweat)

This principle is consistent with South Africa’s Employment Services Act 4 of 2014. The Department of Employment and Labour states that a person may not charge a work seeker a fee for employment services, and that a private employment agency may not deduct recruitment or placement charges from an employee’s remuneration. (Government of South Africa)

International fair-recruitment guidance similarly recognises the principle that workers and jobseekers should not bear recruitment fees or related costs, because excessive recruitment costs can contribute to debt bondage, forced labour and human trafficking. (International Labour Organization)

Legitimate statutory deductions, taxes or amounts lawfully associated with an existing work engagement are separate from charging a person for access to employment.


7. Transparency of Work Opportunities

We aim to ensure that candidates receive meaningful information about opportunities before accepting work.

Where available and relevant, this may include:

  • the nature of the role;

  • whether it is freelance, fractional or full-time;

  • required skills and experience;

  • work location or remote-working arrangements;

  • start date;

  • anticipated duration;

  • rate, budget or salary; and

  • other material conditions supplied by the client.

NoSweat’s current platform displays key job information including start dates, duration, required skills and remuneration information and allows candidates to decide whether to apply. (No Sweat)

We do not support deliberately misleading candidates about material terms of employment or engagement.


8. Freedom of Movement and Identity Documents

NoSweat does not support:

  • confiscating passports or identity documents;

  • withholding identity documents to prevent a worker from leaving;

  • physically restricting a person's movement;

  • requiring workers to surrender personal documents as security;

  • threats relating to immigration status;

  • withholding wages as a means of coercion; or

  • other practices designed to make a person unable to leave employment freely.

International labour guidance specifically identifies retention of identity documents and coercive financial arrangements as practices associated with forced-labour risk. (International Labour Organization)

Where identity documentation is required for lawful verification, it should only be used for the legitimate verification or administrative purpose for which it was collected and handled in accordance with NoSweat’s privacy and data-protection requirements.


9. Children and Young Persons

NoSweat does not knowingly facilitate unlawful child labour or any form of exploitation of children.

We expect clients and business partners to comply with all South African laws governing the employment of children and young persons.

South African labour legislation includes specific restrictions on the employment of children and protections against forced labour. (Justice and Constitutional Development)

NoSweat's professional talent platform is intended primarily for adults seeking professional freelance, fractional and full-time work.


10. Expectations of Clients

Clients using NoSweat are expected to:

  • comply with applicable labour, employment and human-trafficking laws;

  • provide truthful information concerning opportunities;

  • provide lawful and fair working conditions;

  • treat candidates and workers with dignity;

  • refrain from forced or coercive labour practices;

  • refrain from retaining workers' identity documents as a form of control;

  • pay workers in accordance with agreed and lawful arrangements;

  • not impose unlawful recruitment charges on candidates;

  • respect a person's legal right to terminate their employment or engagement; and

  • cooperate with reasonable enquiries regarding suspected exploitation.

NoSweat reserves the right to decline, suspend or terminate its relationship with a client where there are reasonable grounds to believe that the client is involved in modern slavery, human trafficking or serious labour exploitation.


11. Expectations of Suppliers and Service Providers

We expect suppliers, contractors and service providers acting on NoSweat's behalf to:

  • comply with applicable employment and human-rights laws;

  • prohibit forced and trafficked labour within their own operations;

  • maintain appropriate employment practices;

  • treat workers fairly and lawfully; and

  • take reasonable steps to address modern-slavery risks within their operations where relevant.

The level of due diligence applied may depend on the nature of the service, geography, workforce and assessed risk.


12. Due Diligence and Vetting

Where appropriate to the nature and risk of the relationship, NoSweat may take reasonable steps to understand who it is doing business with.

These steps may include:

  • verifying client information;

  • reviewing job specifications;

  • querying unusual or potentially exploitative working arrangements;

  • requesting clarification of employment or engagement terms;

  • verifying candidate or business identities where appropriate;

  • investigating complaints;

  • reviewing suppliers or service providers where a material risk is identified; and

  • declining or terminating relationships where serious concerns cannot be satisfactorily resolved.

NoSweat does not represent that due diligence can eliminate every risk of exploitation. Our objective is to identify credible warning signs and respond appropriately.


13. Warning Signs

Circumstances that may require further investigation include situations where a worker or candidate:

  • appears unable to leave their employment freely;

  • is threatened or intimidated;

  • has had their passport or identity documents confiscated;

  • appears controlled by another person;

  • has been misled about the nature or remuneration of their work;

  • is required to repay excessive recruitment debts;

  • has wages deliberately withheld as a means of control;

  • appears to be working involuntarily;

  • is prevented from communicating freely;

  • lives or works in abusive or severely exploitative conditions; or

  • appears fearful about discussing their working circumstances.

A single indicator does not necessarily establish that trafficking or forced labour has occurred. Multiple indicators or serious individual warning signs should, however, be taken seriously. The ILO’s revised indicators are intended to assist organisations in recognising circumstances that warrant further investigation. (International Labour Organization)


14. Reporting a Concern

Anyone who becomes aware of suspected slavery, forced labour, trafficking or serious exploitation connected with NoSweat is encouraged to report the matter.

Reports can be made to:

Sebastian van ’t Hoff
No Sweat Work Media CC
Email: sebastian@nosweat.co.za
Telephone / WhatsApp: +27 81 818 2053

Please provide as much relevant information as reasonably possible to enable us to assess the concern.

Where there is reason to believe that a criminal offence has occurred or that a person is in immediate danger, the matter may also be referred to the appropriate South African authorities.


15. Confidentiality and Non-Retaliation

Reports will be treated sensitively and, where reasonably possible, confidentially.

NoSweat does not tolerate retaliation against a person who raises a genuine concern in good faith regarding suspected slavery, trafficking or worker exploitation.

Deliberately false or malicious allegations are not protected by this principle.


16. Responding to Concerns

Where a credible concern is raised, NoSweat may take steps including:

  • requesting further information;

  • contacting relevant parties;

  • preserving relevant records;

  • suspending a job advertisement or placement;

  • suspending access to the NoSweat platform;

  • declining to make or continue a placement;

  • terminating a commercial relationship;

  • referring the matter to appropriate authorities; or

  • taking other steps appropriate to the circumstances.

Where possible, the wellbeing and safety of potentially affected individuals will be considered when deciding how to respond.


17. Breaches of This Policy

A material breach of this Policy may result in action including:

  • removal of a job posting;

  • cancellation of a placement;

  • suspension or termination of a NoSweat account;

  • termination of a supplier or client relationship;

  • refusal to provide further services; and

  • referral to an appropriate authority where required or justified.

The appropriate response will depend on the nature and seriousness of the concern.


18. Training and Awareness

NoSweat aims to maintain appropriate awareness of modern-slavery and human-trafficking risks relevant to its activities.

As our business and platform develop, appropriate persons involved in candidate matching, client management, vetting, payments or other higher-risk functions may receive guidance regarding:

  • signs of forced labour and trafficking;

  • fair-recruitment principles;

  • escalation procedures;

  • responding to concerns; and

  • NoSweat's obligations under this Policy.


19. Continuous Improvement

Modern slavery and human trafficking are evolving risks.

NoSweat will periodically review its practices and this Policy, taking into account:

  • changes to our business model;

  • new categories of clients or talent;

  • international expansion;

  • regulatory developments;

  • incidents or concerns raised;

  • changes in recruitment practices; and

  • relevant guidance concerning fair recruitment and forced labour.


20. Legal Framework

This Policy has been developed with regard to relevant South African legislation and internationally recognised fair-recruitment principles, including:

  • the Constitution of the Republic of South Africa, 1996, particularly section 13;

  • the Prevention and Combating of Trafficking in Persons Act 7 of 2013;

  • the Basic Conditions of Employment Act 75 of 1997;

  • the Employment Services Act 4 of 2014; and

  • relevant International Labour Organization guidance concerning forced labour and fair recruitment. (Government of South Africa)

South Africa also currently has an Employment Services Amendment Bill (B16–2026) before Parliament. As at August 2026, it is a Bill rather than enacted law, so NoSweat should review this Policy if and when amendments to the Employment Services Act come into force. (Parliament of South Africa)


21. Relationship With Other NoSweat Policies

This Policy should be read together with NoSweat's:

Privacy Policy
POPIA & Data Protection Policy
Cookie Policy
PAIA Manual
Terms and Conditions, where applicable.


22. Policy Review

This Policy may be reviewed and updated from time to time to reflect changes in legislation, NoSweat's services or recognised good practice.

The latest version will be published on www.nosweat.co.za.


23. Contact

Questions or concerns regarding this Policy may be directed to:

No Sweat Work Media CC
Trading as NoSweat

Sebastian van ’t Hoff
Email: sebastian@nosweat.co.za
Telephone / WhatsApp: +27 81 818 2053
Website: www.nosweat.co.za
South Africa

http://www.nosweat.co.za/anti-slavery-human-trafficking-policy