7. Recommendations 7.1 Recommendations to Employers • Review the enforceability and proportionality of resignation penalty clauses, and apply them transparently and consistently. Where a resignation penalty clause is structured as reimbursement of actual costs rather than a fixed fine, provide workers with an itemized breakdown and supporting receipts as a matter of course, and exclude recruitment agency fees from such claims in line with the internationally recognized Employer Pays Principle. • Respond to formal written complaints of harassment or grievance with a substantive, documented reply within a reasonable timeframe, regardless of whether an unrelated dispute with the same worker has already been resolved. • Establish an independent, confidential channel for reviewing medical certificates that does not require disclosing the employee’s identity to their direct supervisor. • Audit the consistency and transparency of wage calculations and KPI/attendance systems, and communicate proactively rather than only when corrections are flagged. • For roles performed under company-set schedules, supervision, and KPIs, review whether “independent contractor” agreements reflect the substance of an employment relationship, regardless of the label used in the contract. • Do not permit a manager who is the subject of an active HR investigation to unilaterally issue disciplinary action on the same matter under review. • Do not tie an individual worker’s contractual rights or entitlements to the outcome of negotiations with other workers. • Disclose all material shift conditions, tool requirements, and training arrangements at the recruitment stage, before the contract is signed. 7.2 Recommendations to Regulators and OECD NCPs • Treat the patterns in this report as indicative of structural, sector-wide practices rather than isolated complaints, given that they recur across multiple independent employers. • Consider coordinated review where the same parent company appears across multiple NCP jurisdictions. • Ensure that the 2023 amendments to Malaysian labor law, which provide for compensation where an employer-caused delay pushes back a worker’s contractual start date, are implemented for foreign workers as well, including at the visa-processing stage. • Within LHDN, ensure that corrections to residency status arising from documented counter-level misguidance are resolved within the agency’s own published service standards, and that a written acknowledgment of administrative error by a responsible officer triggers prompt internal escalation rather than leaving the correction in the ordinary queue. Case 7 of this report demonstrates the current gap in concrete terms: a correction that remained in the ordinary queue for more than five months despite a written acknowledgment of error was completed within days once a representative negotiated in person — an outcome that should not depend on physical presence or professional representation. 7.3 Recommendations to Human Rights and Labor Organizations • Treat skilled workers and professional-visa holders (Employment Pass holders) as a distinct, under-monitored category whose vulnerability in the corporate sector differs from — but is no less serious than — that of traditional low-wage migrant labor. • Support the development of shared, anonymized case-referral protocols between independent practitioners such as Sukimare Consulting and established NGOs such as Tenaganita. Sukimare Consulting — White Paper (July 2026) Page 16