Labour-only rogues introduce risk to the public and financial risk to the whole supply chain.
This isn't a new issue. Awareness is growing and the SIA has formed a joint task force with the HMRC to tackle it, while NSI is building its own advice pack.
Now is the time to investigate your own supply chain, take action while you can privately and resolve your own issues. We recommend three courses of action:
Simply excluding use of subcontractors is not enough. While you will have an argument in court, the SIA current exclusion of 'labour-only' agreement within sub-contracting will give you some difficulty.
Clarifying your position within your contracts is crucial to eliminate this risk. Also embedding your obligations under HMRC due diligence rules makes sense.
As a minimum we recommend:
We have a contract insert download that covers supply chain management and audit requirements. This satisfies all the requirements of the HMRC and we use this within our supply chain contracts.
This download costs £300. Please contact us to register an interest.
We have developed a full contracting process which incorporates screening questions and a DocuSign solution. We are able to consult on the development of your own full process. Please contact us for more details.
HMRC guidelines are clear. You must carry out due diligence by following these rules. We also suggest the following:
Want help? No problem. Please send us an email.
Fast response, unplanned security officer deployment is risky without a clear strategy. Where do all these vetted officers come from?
Don't be drawn into opaque supply chains to resolve a tactical nightmare. Adopt a strategic approach with you supply chain. We recommend you introduce:
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