Take action – don’t get caught out
Labour only rogues introduces risk to the public and financial risk to the whole supply chain. + Learn More
This isn't a new issue, awareness is growing and the SIA have formed a joint task force with the HMRC to deal with this issue. In addition the NSI are building their own advice pack.
Its time now to investigate your own supply chain, take action whilst you can privately and resolve your own issues. We recommend three courses of action:
1. Develop your contracting:
Simply excluding use of subcontractors is not enough. Whilst 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
Exclude Labour Only agreements from your supplier contracts without authority
Ensure all Security Officers are PAYE (not self employed)
Ensure a right to audit PAYE/Vetting files etc
Build in a non payment right if issues are discovered – you will need this if you discover HMRC related issue
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 is £300 please follow the link. (Coming Soon) Register an interest + More Info
We have developed a full contracting process that incorporates screening questions and a DocuSign solution. We are able to consult on the development of your own full process. Please make contact here for more details
2. Complete audits
HMRC guidelines are clear you MUST carry out due diligence. Follow those rules (found here). We also suggest the following:
Name, SIA licence number, contact number of all SO’s deployed retained
Periodic PAYE checks
Vetting file checks
Check direct with Security Officers
Want help? No problem (Contact) – David@ssg-net.com
3. Review your Ad-Hoc Security Guarding Strategy
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:
Regional/area support plans
Formal capacity management.
Pre deployment checks