WORKFORCE ASSURED

Confidential proposal

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CONFIDENTIAL
Supply chain assurance proposal

See the risk in your subcontract chain. Then prove it's managed.

A two-step programme for Morgan Sindall: a risk assessment that maps how every supplier actually engages its workers, then targeted Workforce Assured Prequalification of the medium and high-risk tier — proportionate, evidenced and defensible.

Risk now flows up the chain JSL live from Apr 2026 Fair Work Agency active 87% of suppliers rely on external labour
Prepared for Morgan Sindall by Workforce Assured

Governance failures in the sub-tier don't stay in the sub-tier

Every unmonitored relationship beneath a contractor creates direct legal, tax and reputational exposure at the top. From April 2026 that exposure is no longer theoretical — it cascades by statute.

Principal Contractor
Carries JSL liability for the entire chain
Main Contractor
73% critical · 93% major NCs
Labour Agency
52% critical · 75% major NCs
Umbrella / CIS
SDC, IR35 & tax risk source
Worker
Potentially misclassified
£

Corporate Criminal Offence

Failure to prevent the facilitation of tax evasion by an associated person — anywhere in the chain.

VAT & missing-trader fraud

Carousel and missing-trader fraud is common in labour-only supply chains operating beyond first-tier visibility.

ID

Illegal workers

Right-to-work obligations extend across the subcontract chain, not just to your direct payroll.

CIS

CIS penalties

New Finance Act 2026 penalties for non-compliance, against a backdrop of increased HMRC enforcement.

JSL

Joint & Several Liability

Umbrella non-compliance can flow unpaid PAYE liability back up to the engaging contractor.

MS

Modern Slavery

Rising governance expectations — evidence of supply-chain due diligence is now the standard, not the policy alone.

What our audits already find — across 183 initial Workforce Assured audits

0
Initial audits completed across agencies, contractors & intermediaries
0
of contractor audits carried at least one Critical non-conformance
0
Contracts & AWR — the most common finding, and the hardest to close at 57%
0
audits flagged Modern Slavery gaps — policy present, underlying risk assessment absent
1Step one · Subcontractor risk assessment

First, see the whole chain — not just the first tier

A standardised, low-burden assessment of every active supplier: how they source labour, how their spend concentrates, and where exposure sits. The figures below are from our Subcontractor Risk Pilot across 385 active UK trade contractors and £503m of monthly labour spend — the same methodology we would run across the Morgan Sindall supply chain.

01 · ASSESS

Capture the model

A standardised questionnaire from each supplier, covering how labour is actually engaged.

  • Delivery routes used per supplier
  • Monthly labour spend by route
  • Self-employed, CIS and workforce-mix flags
02 · SCORE

Two-dimensional scoring

Each supplier scored independently on exposure and reliance, 0–100 each.

  • Exposure — breadth of delivery routes used
  • Reliance — concentration of spend in higher-risk routes
  • Combined score 0–200
03 · TIER & ACT

Most-conservative tiering

Action tier is the most conservative of all three scores — a single high component can't be offset elsewhere.

  • High / Medium / Low priority
  • Drives who is prequalified first
  • Defensible, auditable prioritisation

Where the pilot population landed

385 suppliers · click a tier
25%
49%
26%
High priority96
Exposure ≥ 70 (payroll/CIS intermediary use combined with two or more other routes, or 4–5 routes running simultaneously), or reliance ≥ 70 from CIS/labour-only spend concentration. A single CIS-dominant route can trigger High alone.
Medium priority189
Exposure 40–69 (typically three non-CIS routes, or two routes where self-employed workers are 41%+ of direct temps), or a mixed spend profile weighted to labour-only.
Low priority100
Exposure under 40 (one or two routes — usually subcontract packages or direct/agency labour, no CIS engagement), with spend sitting primarily in direct or agency labour.
⌖ Action tier = most conservative of exposure, reliance and combined score.
0
use external labour
£0
annualised labour spend in the pilot
0
High Priority suppliers (25%)
0
use 3+ delivery routes at once

How labour is sourced — and why subcontract spend hides the most

Subcontract packages dominate spend but tell you nothing about how the workers behind them are engaged. Labour-only and CIS intermediaries carry a small share of spend but the highest concentration of compliance exposure.

Delivery route
Suppliers using
Share of total spend
Subcontract packages
50%
63% of spend
Labour-only subcontracts
45%
15% · high reliance
Labour agencies
44%
9%
Direct temp labour
35%
6%
Payroll / CIS intermediaries
22%
7% · highest risk per £

The self-employment & capability gap

28%
of suppliers flag self-employed workers in their direct temp pool
53%
in Fit-Out & Interiors — the highest of any sector, a CIS misclassification hotspot
15%
carry a Modern Slavery risk profile (self-employed plus labour-only)
12%
fit a labour-broker profile — temps exceed permanent headcount

CIS / payroll intermediaries — acute risk per pound

61.9
average reliance score (of 100) for CIS users — the highest of any route
44%
of CIS users score HIGH reliance
£418k
average monthly spend per intermediary-reliant supplier
6.7%
of total sector spend — yet the most acute compliance risk
A small share of spend, the greatest concentration of exposure. This is exactly the tier a risk assessment surfaces — and exactly where assurance effort should land first.
2Step two · Workforce Assured Prequalified

Then prequalify the medium and high-risk tier — proportionately

You don't full-audit everyone. The risk assessment tells you where to spend assurance effort. Prequalified is the entry-tier desktop assessment that takes the medium and high-risk suppliers and tests whether the governance and tools to manage that risk actually exist — independently verified, supplier by supplier.

Risk-assess every active supplier
Low-burden questionnaire · full visibility
100%of the chain mapped
Prequalify the medium + high tier
Remote, evidence-based, auditor-verified
~74%where exposure concentrates
Escalate to Accredited where it matters
On-site audit · worker interviews · sub-tier mapping
High tierdeepest assurance

One standard, three tiers of assurance

Each tier deepens the assurance and carries the evidence forward — every answer, artefact and verification from Prequalified becomes the starting point for an Accredited audit.

Tier 1 · Entry

Prequalified

Remote, evidence-based desktop assessment of employment-compliance and ethical-recruitment governance.

This proposal
12-month review cycle
Tier 2

Accredited

On-site audit with worker interviews, payroll sampling, document verification and sub-tier mapping.

Carries Prequalified evidence forward
Tier 3

Certified

Periodic worker-compliance assessments at an agreed cadence — sustained, ongoing assurance.

Agreed cadence

How the assessment is built

Every Yes triggers evidence; every Yes is independently verified by a Workforce Assured auditor before it scores. There is no automatic pass. Same governance shape for a sole trader or a Tier 1 — the auditor calibrates what "adequate" means by company size and risk exposure.

SECTION 0.0 · SCOPE DECLARATION

Who they are, how big, how they engage labour

A structured front-of-form declaration that drives the entire assessment — activating only the relevant routes and calibrating auditor severity. Verified against Companies House. Not scored.

Company identitySize & financialsEngagement model declarationWorkforce volumes
SECTION 0 · CROSS-CUTTING GOVERNANCE

Tested at company level, applied into every route

The three themes that flow up the chain. 29 questions, 14 auditor checklists, always shown.

Modern SlaveryCorporate Criminal OffenceWorker Welfare, B&H & whistleblowing

FIVE DELIVERY ROUTES · 95 QUESTIONS · 20 CHECKLISTS · ACTIVATED BY SCOPE

R1Directly engaged
R2Subcontract packages
R2aLabour-only
R3Agency labour
R4Payroll intermediaries

Route 1 · Directly engaged workers

PAYE & self-employed individuals

Workers engaged directly as individuals — PAYE temporary/fixed-term, or directly engaged self-employed (CIS sole traders, sole traders, PSCs). No sub-tier. Self-employed sub-blocks unlock conditionally from the scope declaration.

Strategy & governanceEngagement & contractsPay & payrollStatus determinationRight to WorkWorker welfareInduction
Critical defaults: no SDS template where PSCs are engaged off-payroll; any worker contribution toward PPE.

Route 2 · Subcontract packages

Let to limited-company subcontractors

Defined work packages let to a limited company with its own employees, labour, materials and supervision. The welfare group splits between principal-contractor and non-PC perspectives, driven by the CDM 2015 status declared in scope.

PSL & procurementPQQ due diligenceSubcontract agreementsCompliance monitoringSub-tier visibilityWorker welfare & ethicsTender & performance
Critical default: failure to require subcontractors to prohibit worker-paid fees anywhere in their chain.

Route 2a · Labour-only subcontracting

Gang-leader crews on price work

The supply chain's most common vehicle for front companies and mini-umbrella schemes. Tests the labour-only-specific controls that distinguish a legitimate subcontract from a disguised employment business, with elevated PQQ, contract and monitoring checklists sitting alongside Route 2.

Labour-only termsLegitimacy testPay-cascade transparencyCIS verification of crewConnected-persons screening (s.993 ITA)
Why it matters: labour-only carries the elevated exploitation and tax-evasion risk the risk assessment flags first.

Route 3 · Agency labour

Recruitment businesses & their sub-tier

Workers sourced through a labour agency under contract with the contractor. Where the agency runs its own payment sub-tier (e.g. umbrella), that sub-tier is tested as part of the route — declared in scope, surfaced through attestation and contractual switch rights.

PSL & requisitionAgency PQQContracts & AWRCompliance monitoringSub-tier visibilityWorker welfare & ethicsPerformance
Critical default: worker-paid fees of any kind not prohibited anywhere in the agency chain.

Route 4 · Payroll intermediaries

Umbrella / EoR / CIS intermediary, engaged directly

A payroll intermediary engaged directly for the contractor's own workforce, with no agency in the chain. Finance Act 2026 Joint & Several Liability exposure is acute here, so JSL governance — indemnities, debt monitoring and escalation triggers — is tested explicitly.

Selection & vettingIntermediary PQQContracts & JSL indemnityCompliance monitoringWorker-facing documentation (KIDs)Modern Slavery
Critical defaults: undisclosed rebates/kickbacks; worker-paid fees or unlawful deductions in the intermediary chain.

Scored deterministically — flagged at auditor discretion

Maturity is a clean, automated percentage. Flags are independent, calibrated by the auditor against company size, risk exposure and materiality — so a sole trader and a Tier 1 are held to proportionate standards.

0–25%

Foundational

Governance largely absent or undocumented

26–50%

Developing

Some governance, inconsistent; cycles often missing

51–75%

Established

Documented, named ownership, defined cycles

76–100%

Embedded

Continuous improvement, board reporting, supply-chain cascade

!

Critical flags

Clear legal failures — the contractor's own declaration amounts to a statutory non-compliance. Block directory listing until remediated within 30 days.

  • Modern Slavery Statement not published above £36m turnover
  • No sexual-harassment risk assessment (Worker Protection Act 2023)
  • Worker-paid fees not prohibited across the chain

Major flags

High-risk findings — absent governance, missing templates or self-declared weaknesses that raise exposure. Visible to mandating primes and feed procurement decisions; they don't block listing.

  • Missing supply-chain due-diligence frameworks
  • No sub-tier visibility where intermediaries are in use
  • Absent compliance-monitoring frameworks

What every assessment produces

Headline maturity score & band

A single 0–100 score per supplier, published to the directory.

Per-block breakdown

Three Section 0 topic bands plus a band for each in-scope route.

Flag register

Every Critical and Major flag with auditor narrative and source.

Gap analysis & training plan

A clear route to improvement — and to the next assurance tier.

£995
per sub-contractor

Desktop Prequalified assessment

A single, transparent price per supplier for the full remote assessment — every Yes independently verified by a Workforce Assured auditor, with no automatic pass.

Auditor-verified 12-month review cycle Maturity score & flag register Directory listing

Prequalified once. Recognised by many. The floor rises for everyone.

Workforce Assured isn't a one-off questionnaire that dies in an inbox. Prequalified suppliers join a shared directory of assured contractors that every mandating prime can filter and trust — which is where the real return sits for Morgan Sindall.

01

Proportionate & defensible

Assurance effort lands where the risk concentrates — the medium and high tier — not spread thinly across suppliers who don't warrant it. Every prioritisation decision is evidenced.

02

Evidence that travels

The directory listing is independently verified, not self-attested. And every answer carries forward into an Accredited audit — assurance compounds rather than restarts.

03

Less burden, not more

Suppliers prequalify once and are visible to every prime that mandates the standard. That replaces the duplicate-PQQ treadmill that suppliers — and your own teams — spend so long maintaining.

04

A community standard

As more primes mandate Workforce Assured, the assured-supplier pool grows and the sector floor rises. Good suppliers get rewarded with recognition; the risky tail gets visible.

05

JSL-ready by design

Route 4 tests Finance Act 2026 JSL governance explicitly. When liability cascades, you hold evidenced, supplier-level due diligence — not a folder of unread policies.

06

Achievable for your whole chain

The same governance shape works for a micro gang-leader business and a Tier 1, calibrated by the auditor. No supplier is locked out; none is let off lightly.

⌕ filter: region · trade · route · score · flags
Yorkshire & HumberGroundworksAgency labourScore ≥ 51%0 Critical flags
Supplier
Maturity
Flags
Status
Assured supplier — exampleCH · ●●●●●●●●
82
0 Critical
Embedded
Assured supplier — exampleCH · ●●●●●●●●
64
2 Major
Established
Assured supplier — exampleCH · ●●●●●●●●
58
0 Critical
Established

Illustrative listing. Supplier identities, scores and flags are populated only from completed, auditor-verified assessments.

What it means specifically for Morgan Sindall

Single line of sight beyond Tier 1

Audit rights and flow-down that reach the workers actually doing the work.

Procurement that filters on assurance

Choose and re-tender suppliers on verified maturity and flag count, not gut feel.

An evidenced defence file

For HMRC, the Fair Work Agency and clients — proportionate due diligence, documented.

A standard your peers can adopt too

Shared recognition compounds the value of every supplier you prequalify.

A short pilot proves the model on your own chain

Start with a defined slice of the Morgan Sindall supply chain. Risk-assess it, prequalify the medium and high tier, and review the findings together — before scaling across the wider portfolio.

STEP 01

Scope the pilot

Agree a representative supplier population and the data we'll draw on.

STEP 02

Assess & tier

Run the risk assessment; return a tiered, prioritised view of the chain.

STEP 03

Prequalify & review

Prequalify the medium/high tier and walk the directory output together.