ISOZOS – MOM Employment Agency Compliance Position
Purpose
This document records ISOZOS’s operating position in relation to the Singapore Employment Agencies Act (Cap. 92) and clarifies why ISOZOS does not operate as an Employment Agency.
1. Nature of Services
ISOZOS provides Employer of Record (EOR) and employment administration services through direct employment arrangements.
All individuals engaged under the ISOZOS model are:
- Employed directly by ISOZOS
- Engaged under a contract of service
- Administered in accordance with applicable Singapore employment laws
ISOZOS does not act as an intermediary between jobseekers and third-party employers.
2. Employment Relationship
ISOZOS is the legal employer and is responsible for:
- Employment contracts and HR policy administration
- Payroll processing and statutory contributions (CPF, SDL, taxes)
- Work pass administration for directly employed personnel
- Employee relations, discipline, and employment risk management
3. Client Relationship
Client engagements are governed by EOR service agreements covering:
- Employment administration scope
- Governance and accountability
- Compliance and documentation
4. Exclusion of Employment Agency Activities
ISOZOS does not perform employment agency work as defined under the Employment Agencies Act.
Specifically, ISOZOS does not:
- Recruit or source candidates for third parties
- Place or refer jobseekers to employers
- Match candidates with job vacancies
- Charge placement or recruitment fees
Accordingly, ISOZOS does not require:
- An Employment Agency licence
- Certified Employment Intermediaries (CEI)
- A Key Appointment Holder (KAH)
5. Governance and Compliance Controls
ISOZOS maintains:
- Clear role delineation between ISOZOS and clients
- Employment governance and oversight frameworks
- Documented employment scope and engagement boundaries
- Audit-ready documentation demonstrating non-agency positioning
Public-facing materials use conservative, employment-anchored language to avoid misinterpretation.
6. Public Disclosure
ISOZOS includes a clear disclaimer on its website on employment agency-related services.
Status:
This document reflects ISOZOS’s current operating model.