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If your supplier is accredited, you’re in good company

There is a clear appetite to rid our sector of poor practice and, given the current political climate and a raft of media exposure around ethics and exploitation, it will be no surprise to anyone that supply chain compliance is set to get tougher as the government works to clamp down on bad practice.

The Criminal Finances Act (CFA) makes companies criminally liable if they fail to prevent tax evasion by a member of staff or an associate, even if they were unaware of it. Prosecution could lead to criminal conviction and unlimited fines. To protect themselves, recruiters must ensure that their supply chain is not facilitating tax evasion, and should be particularly concerned given the increase in tax avoidance schemes that are capitalising on IR35 changes in the public sector.

The government is also considering the 50+ recommendations made in Matthew Taylor’s Review of modern employment practices.  In addition, the Director of Labour Market Enforcement, Sir David Metcalf is keen to put responsibility on end-hirers, as he outlined in his recently published strategy.

As a recruiter, your business’s good name could be dragged through the mud, damaging your relationships with clients and candidates in the process.

To ensure your house is in order, ask these 3 simple questions of every supplier on your PSL:


  • Is the company you pay the same one that pays your workers?
  • Do you know that they are not contracting with any entity outside of the UK?
  • Do you know the supplier is paying the correct VAT, PAYE tax and NI to HMRC?


If NO is the answer to any of these, you must tighten up your PSL. 

Remember, sometimes things aren’t what they seem, so we would suggest you choose a member of an accredited professional body to ensure that some compliance checks have been undertaken. Make sure you know what the accreditation means in practice, as standards can vary. You can easily find the FCSA’s Code of Compliance because it is published on the website and it shows you what is expected of FCSA Accredited Members.  They must demonstrate compliance with the Code and must have passed an independent assessment by regulated accountants and lawyers. 

Ensure that the employment intermediaries on your PSL operate within the law and provide:


  • National Minimum Wage payments in line with legislation, paid in full as the contractor’s salary;
  • If expenses allowances are too good to be true, then alarm bells should ring – they may not conform to HMRC legislation and guidance;
  • Holiday and statutory payments such as sick pay and maternity/paternity pay;
  • An overarching contract of employment;
  • The provision of guaranteed hours;
  • Access to a workplace pension;
  • Full employment rights.

Any compliant professional employment company will offer the above as a minimum requirement.

Our advice for recruitment agencies is easy; recruiters can minimise their risk by choosing FCSA Accredited Members who are rigorously tested annually for adherence to FCSA’s Code of Compliance.

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