Construction Industry Scheme (CIS)
What is CIS?
The Construction Industry Scheme requires contractors to be engaged on a self-employed basis.
As part of the scheme, contractors deduct money from a subcontractor’s payments and transfer it to HM Revenue and Customs.
How can ProPaye CIS help you?
ProPaye CIS has robust processes aligned to the FCSA compliance coding in place to guarantee full compliance with HMRC guidelines. With our competitive margins and public liability insurance, Indemnity Insurance and credit provisions we provide a comprehensive service for all contractors and agencies in the construction industry.
Our fully integrated software streamlines all of the necessary reports and admin to ensure our clients don’t have to. ProPaye also stand by our no tie in period to utilise our services for guaranteed flexibility and accommodation.
At the end of the tax year, you have a full record of your earnings to claim tax back on your business expenses.
For self-employed CIS sub-contractors, we guarantee to:
- Make the appropriate CIS tax deduction – whether that be 20% or 30% from our verification process, plus our margin
- Pay the balance into your bank account by every Friday morning
- Ensure strict compliance at all times
- To consistently offer competitive margins and provide public liability insurance for purchase
- Guarantee any operatives engaged through our service feel supported and are paid accurately and on time
Right to work checks
As a brand ProPaye considers compliance to be integral to success In this industry and consequentially both ProPaye businesses follow the guidelines issued by the UK Visas and Immigration Agency.
We are required to see proof of identification and your right to work in the UK before we manage your outsourced employment/engagement. This process further supports our Modern slavery statement to contribute towards safer supply chains for all entities.
We will accept any one of the documents from List A but please bear in mind we may make yearly checks on documents supplied from List B.
Documents showing you may take any work in the UK:
1. A passport showing that the holder, or a person named in the passport as the child of the holder, is a British citizen or a citizen of the United Kingdom and Colonies, having the right of abode in the United Kingdom.
2. A passport or national identity card showing that the holder, or a person named in the passport as the child of the holder, is a national of the European Economic Area or Switzerland.
3. A residence permit, registration certificate or document certifying or indicating permanent residence issued by the Home Office or the Visas and Immigration Agency to a national of a European Economic Area country or Switzerland.
4. A permanent residence card issued by the Home Office or the Visas and Immigration Agency to the family member of a national of a European Economic Area country or Switzerland.
5. A Biometric Immigration Document issued by the Visas and Immigration Agency to the holder which indicates that the person named in it is allowed to stay indefinitely in the United Kingdom or has no time limit on their stay in the United Kingdom.
6. A passport or other travel document endorsed to show that the holder is exempt from immigration control, is allowed to stay indefinitely in the United Kingdom, has the right of abode in the United Kingdom, or has no time limit on their stay in the United Kingdom.
7. An Immigration Status Document issued by the Home Office or the Visas and Immigration Agency to the holder with an endorsement indicating that the person named in it is allowed to stay indefinitely in the United Kingdom or has no time limit on their stay in the United Kingdom, when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
8. A full birth certificate issued in the United Kingdom which includes the name(s) of at least one of the holder’s parents, when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
9. A full adoption certificate issued in the United Kingdom which includes the name(s) of at least one of the holder’s adoptive parents when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
10. A birth certificate issued in the Channel Islands, the Isle of Man or Ireland, when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
11. An adoption certificate issued in the Channel Islands, the Isle of Man or Ireland, when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
12. A certificate of registration or naturalisation as a British citizen, when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
13. A letter issued by the Home Office or the Visas and Immigration Agency to the holder which indicates that the person named in it is allowed to stay indefinitely in the United Kingdom when produced in combination with an official document giving the person’s permanent National Insurance Number and their name issued by a Government agency or a previous employer.
Documents indicating some restrictions to take work, and requiring regular checks from ProPaye to ensure that you can continue to work with us:
1. A passport or travel document endorsed to show that the holder is allowed to stay in the United Kingdom and is allowed to do the type of work in question, provided that it does not require the issue of a work permit.
2. A Biometric Immigration Document issued by the Visas and Immigration Agency to the holder which indicates that the person named in it can stay in the United Kingdom and is allowed to do the work in question.
3. A residence card or document issued by the Home Office or the Visas and Immigration Agency to a family member of a national of a European Economic Area country or Switzerland.
4. A work permit or other approval to take employment issued by the Home Office or the Visas and Immigration Agency when produced in combination with either a passport or another travel document endorsed to show the holder is allowed to stay in the United Kingdom and is allowed to do the work in question, or a letter issued by the Home Office or the Visas and Immigration Agency to the holder or the employer or prospective employer confirming the same.
5. A certificate of application issued by the Home Office or the Visas and Immigration Agency to or for a family member of a national of a European Economic Area country or Switzerland stating that the holder is permitted to take employment which is less than 6 months old when produced in combination with evidence of verification by the Visas and Immigration Agency Employer Checking Service.
6. An Application Registration Card issued by the Home Office or the Visas and Immigration Agency stating that the holder is permitted to take employment, when produced in combination with evidence of verification by the Visas and Immigration Agency Employer Checking Service.
7. Immigration Status Document issued by the Home Office or the Visas and Immigration Agency to the holder with an end
Modern Slavery Act
The Modern Slavery Act gives law enforcement the tools to fight modern slavery, ensure perpetrators can receive suitable ramifications that reflect the serious nature of the crimes whilst also enhancing support and protection for victims. The Act received Royal Assent on Thursday 26 March 2015.
The act as a whole will:
- Require businesses over a certain size to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains
- consolidate and simplify existing offences into a single act
- ensure that perpetrators receive suitably severe punishments for modern slavery crimes (including life sentences)
- enhance the court’s ability to put restrictions on individuals where it’s necessary to protect people from the harm caused by modern slavery offences
- create an independent anti-slavery commissioner to improve and better coordinate the response to modern slavery
- introduce a defence for victims of slavery and trafficking
- place a duty on the secretary of state to produce statutory guidance on victim identification and victim services
- enable the secretary of state to make regulations relating to the identification of and support for victims
- make provision for independent child trafficking advocates
- introduce a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators
- enable law enforcement to stop boats where slaves are suspected of being held or trafficked
The Modern Slavery Act and its explanatory notes are available on the Parliament website
Modern Slavery and Supply Chains:
A provision was introduced to the Modern Slavery Bill in November 2014 which requires businesses with over a certain level of turnover to publish an annual slavery and human trafficking statement.
In this statement a business must describe the steps they have taken to ensure that slavery and human trafficking is not taking place in any of their supply chains or their own business, or they must disclose that they have taken no such steps.
The Modern Slavery Bill also provides for the Home Secretary to produce statutory guidance to help businesses to comply with this requirement.
Supply Chain Transparency
Government is further committed to strengthening section 54 of the Modern Slavery Act 2015 – transparency in supply chains following the release of an Independent Review of the Modern Slavery Act. This review included a consultation to gather opinions on the best ways to increase compliance and visibility of efforts being made regarding this topic. The opportunity to have your say on these matters closed on 17th September 2019.
As it stands there are recommendations under section 54 of the Modern Slavery Act 2015 for what information should be included in company’s modern slavery statements for all companies that meet the £36m turnover criteria, but there isn’t anything which is deemed compulsory to be covered within the statements themselves. This is now subject to change with there being the possibility in the near future of companies being required to report on certain topics which will hopefully lead to consistency in the battle against Modern Slavery and certain actions being able to be prioritised across the country.
One method the Independent Review of the Modern Slavery Transparency thinks would encourage compliance to be upheld would be to introduce the possibility of businesses having to pay civil penalties set as a percentage of turnover. The independent Review briefly covered the chance of a variable monetary penalty capped at a maximum prescribed sum. Penalties would be appealable, in line with other civil penalties. The Home Office has detailed that should this come into force, they would send warning letters prior to formal enforcement action.
The full consultation on Modern Slavery Transparency can be viewed here.
Criminal Finance Act
The Criminal Finances Act gained Royal Assent on 27 April 2017. This gives law enforcement agencies and partners, further capabilities and powers to recover the proceeds of crime, tackle money laundering, tax evasion and corruption, and combat the financing of terrorism.
The Criminal Finance Act 2017 makes companies and partnerships criminally liable if they fail to prevent tax evasion by either a member of their staff or an external agent, even where the business was not involved in the act or was unaware of it.
For a company/body to be liable under the Act, there must have been:
- Stage one: The criminal evasion by a taxpayer (either individual or a legal entity) under existing law.
- Stage two: The criminal facilitation of the tax evasion by an ‘associated person’ of the relevant body who is acting in that capacity.
- Stage three: The relevant body failed to prevent its representative from committing the criminal facilitation act.
The rules target deliberate and dishonest behaviour
If you are receiving rebate on prepaid cards – this is seen to be evasion and you could find yourselves on the wrong side of the Criminal Finance Act. If you are a director of your company, and your consultants are receiving some form of rebates either in brown envelopes or on a prepaid card – this is also deemed to be tax evasion and the legislation seems to suggest that the director/employee of that consultant, is the one who will be at risk of a fine.
Propaye have never paid, and will never pay, any incentives/benefits directly to consultants or use prepaid cards as they can lead you down the wrong road to the bribery act path, as well as the criminal finance act. I would suggest you seek your own advice on this as most agencies are still not aware how serious it is.
A business may avoid criminal liability where it can show that it had implemented reasonable prevention procedures, or where it can show that in the circumstances it would have been unreasonable or unrealistic to have expected it to have had procedures in place.
What Companies should do
Companies need to ensure that they have reviewed their current practices and procedures to minimise any risks, and to put in place appropriate monitoring and training of staff at all levels. The Act effectively makes owners and managers responsible for preventing their staff and external agents and consultants from committing tax evasion. And the larger and more complex the business, the greater the risk that an activity may occur that could be caught.
As with all compliance matters continued vigilance and due diligence is key.
The General Data Protection Regulation 2016 replaces the EU Data Protection Directive of 1995. Its purpose is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.
GDPR applies to the processing of personal data wholly or partly by automated means (i.e. by computer) and to the processing other than by automated means of personal data (i.e. paper records) that form part of a filing system or are intended to form part of a filing system.
The GDPR legislation will apply to all controllers that are established in the EU (European Union) who process the personal data of data subjects, in the context of that establishment. It will also apply to controllers outside of the EU that process personal data in order to offer goods and services or monitor the behaviour of data subjects who are resident in the EU.
It is important to ensure you understand the responsibilities surrounding data of those in the supply chain under GDPR and that you are furnished with the appropriate information from entities in your supply chain such as Data Protection Policies, Access request processes, Privacy Notices and Data Breach Plans should such an event ever occur.
The Good Work Plan
The Good Work Plan sets out Governments vision for the future of the UK labour market as well as how the government will implement the recommendations arising from the Taylor Review of Modern Working Practices.
In July 2017 Matthew Taylor published the independent Taylor Review of Modern Working Practices, which looked into the issues in our labour market such as:
- the implications of new forms of work
- the rise of digital platforms
- impacts of new working models
The review made 53 recommendations to government. In February 2018 the government published a full response, accepting a vast majority of the recommendations.
Alongside the response the government also launched 4 consultations to seek stakeholder views on approach to implementation:
- Employment status
- Agency worker recommendations
- Increasing transparency in the labour market
- Enforcement of employment rights recommendations
The Good Work Plan draws on the feedback from these consultations.
Following a commission from government, the Low Pay Commission’s advice on the scale and nature of one-sided flexibility and options to address the issue will be published.
Numerous employment law reforms were set out in the Good Work Plan, published in December 2018. Whist certain circumstances appear to have delayed the formal introduction of any legislation – such as Brexit and the General Election - the overall aim of the plan is to strengthen employment rights and improve working lives. Below are the three main areas of the proposed reforms.
Fair and decent work
The first section makes very tangible changes to the current law and introduces some entirely new entitlements. A few key changes being:
Right to request a more predictable and stable contract
This new right results in an employee being able to request a more predictable and stable contract after they have reached 26 weeks of employment.
An example outcome of this reform could see employees requesting to include a guaranteed minimum number of hours and certainty as to the days on which they will be asked to work.
It is fair to say that this development will predominantly see benefit to individuals who are employed on zero-hour contracts. Should a request be submitted Employers will have three months to make their decision on such a request.
Break in continuous service
As it currently stands, a gap of just one week is enough to break an individual’s continuity of service. Therefore, despite regularly working on and off for the same employer over a long period of time, an individual may not build up any significant length of service.
This break period will be extended from one week to four weeks, helping those employees who work on a sporadic or casual basis to qualify for more employment rights (such as the right not to be unfairly dismissed or the right to statutory maternity pay), which require a particular length of service.
Protecting agency workers
It is not new information that under AWT, after 12 weeks of service, an agency worker is entitled to receive the same level of pay as a permanent worker, unless the agency worker opts out of this right and instead elects to receive a guaranteed level of pay between their temporary assignments (often referred to as “the Swedish derogation”).
However it is new that the opt-out option will be removed (proposed to take effect in April 2020) because it often seen that agency workers are financially worse off by taking the Swedish derogation route (pay between assignments).
Clarity for employers and workers
In this section there is a clear focus on improving communication and reliability in the working relationship. The main reforms include:
Employment status tests
There is a commitment to improve the clarity of the employment status tests for employee, worker and self-employed, although it remains to be seen exactly how and when this will be done. Given the large amount of recent case law (for example, about Uber drivers, Pimlico Plumbers and Deliveroo couriers), most would say that this is a much-needed area of review.
Statement of basic terms
From April 2020, the right to receive a written document setting out their basic terms is extended to workers too in addition to employees. This is a new entitlement that should bring clarity for many workers regarding their contractual terms.
Employers currently have two months in which to provide the written particulars to their employees, but this will change to become a “day-one” right instead. This will ensure that both parties are clear about the main contractual terms from the outset of the relationship.
Further, additional details will need to be included in the documentation, such as details of any paid leave (like maternity or paternity leave), the duration and conditions of any probationary period and information about entitlements to any benefits.
Key terms Information Document
Employment businesses will be required to provide every agency worker with a document known as a “key Information Document”.
The following details will need to be included:
- type of contract they are employed under
- The name of their employer
- the minimum rate of pay
- details of any fees that might be taken
This is intended to help agency workers better understand their basic terms, which can be especially difficult where intermediary umbrella companies are involved.
The holiday pay reference period is to be extended from 12 weeks to 52 weeks commencing April 2020 which is an important development for those who work variable hours. Currently a worker may get different rates of pay during holidays taken, depending on how many hours they worked in the three months previous.
In response to recent case law, it is also believed that there will also be a campaign to ensure that individuals better understand their rights and a new holiday entitlement calculator will be launched.
It is important that all entities in your labour supply chain can support your agency with these changes protecting your workforce.
IR35 – Off-payroll
IR35 is a piece of tax legislation which came into force as a way to combat tax avoidance by workers who were utilising an intermediary, such as their own personal service company, to provide their services to clients. Without that intermediary, the way the worker’s deliver that service and engage with the client would indicate that they should be an employee/employed. A worker who is found to be engaged in this form of tax avoidance is typically known as a disguised employee. Ultimately if a worker was seen to have/receive the same benefits, responsibilities and is under the same control by a client as a permeant employee of that client then that worker would be classed as being inside IR35.
If a worker is classed as being inside IR35 when having been supplying their services through an intermediary, then that worker would be liable for paying over any underpaid PAYE/NIC payments that HMRC are entitled to as that worker under IR35 legislation should have been employed.
Currently, under the private sector it is the responsibility of the worker to ensure that they are supplying their services as a legitimate self-employed individual.
Under the Public sector the responsibility of proving employment status lies with the client. There are reforms to the IR35 legislation coming into force which will make the Private sector also adhere to this practice.
The standard checks which are required to be conducted to ensure a worker who is self-employed is providing their services outside of IR35 are as follows:
Supervision, Direction and Control
Broadly speaking if someone is self-employed then they would be in control of their own working hours, wouldn’t require direction to complete the job and wouldn’t need supervising.
Mutuality of obligation (MOO)
If the working hours are clearly expressed to the worker in exchange of pay without the worker being able to take on additional contracts from other client’s this would heavily indicate towards there being MOO and would mean that worker is inside IR35.
If the worker is self-employed, they should be able to, at their discretion, provide a substitute to complete any aspect of the job which they are unable to do for any reason. Having a clause in an engagement contract is not enough to support this alone.
Typically, if someone is completing a job as a self-employed worker then they would provide and utilise their own equipment. If a worker who is supposed to be self-employed is utilising the same equipment provided by the client as someone employed by that client to complete similar tasks then that worker would fail IR35.
All work completed should be invoiced for by the worker to the client, if the invoices are regularly sent then the details of the work completed should be stipulated to demonstrate why the ongoing relationship. Any work completed to an unsatisfactory level would have to be finalised at the workers own expense.
If the worker has such a long-standing relationship with the client that they are reflected in the organisations details such as contact information/organisation charts then this heavily indicates this worker is engaged under the capacity of employment rather than self-employment and therefore is under IR35.
Under the current legislation the above checks should all be considered when an individual determining whether a worker is in/outside of IR35 however they are not cut and dry, nor is the above list exhaustive. The legislation is subjective and therefore it is imperative that appropriate due diligence is conducted by all relevant parties as the subsequent liabilities can be substantial should a worker be found to be inside IR35 after wrongly being self-employed.
Supervision, Direction and Control
Supervision, Direction and Control is most commonly known and recognised as one of the tests used to identify whether an individual providing its services through a personal service company (PSC) is deemed an employee for tax purposes and therefore captured by the IR35 rulings.
However, just to make things complicated, if an individual is self employed as a sole trader then IR35 does not apply as this legislation is only applicable for Limited Companies. Nonetheless, Supervision, Direction and Control does apply on it’s own merits under the Agency Legislation. This means that if a sole trader is seen to be completing the job they were engaged for but is doing so under supervision of the client, is receiving direction or is under control – or is seen to be under the right of control - in a manner which indicates they should have been employed to complete this job, then the agency can be liable for underpaid NIC owed along with any interest and employment rights the worker was denied – similarly to the consequences of someone operating as a limited company inside IR35.
To reduce agency risk when providing sole traders to clients, they should ensure that any umbrella/intermediary company can evidence how they preform due diligence on the sole trader to confirm/satisfy that they are indeed self-employed prior to receiving payment. However, this doesn’t guarantee security from being liable for any debt, it just helps towards proving that necessary compliance measures were taken. Unlike the Criminal Finance Act, the responsibility for any debt will remain that of the agency as they are seen as “intermediary 1” in the supply chain.
In the UK, employers are legally required to enrol their employees into a pension scheme, and as a fully compliant outsourced service we ensure that the correct procedure is followed by all employers who engage our clients workforce.
Should you not wish to be enrolled, the legislation does allow you to opt out of the contractor pensions scheme. To do this, you must contact the pension provider rather than your employer to arrange this.
In the case of the employers ProPaye Outsourcing engage with, we understand the typical pensions provider is NEST who can be contacted via www.nestpensions.org.uk or via 0300 020 0090. They are open from 8am to 8pm Monday to Sunday and from 10am to 4pm on Bank Holidays.
Contractor Pensions – FAQs
We want you to fully understand your options and what each route will mean for you and have therefore put together some FAQs below which should help you.
Does this affect me if I’m self-employed?
No, this legislation only applies to employees. If you are self-employed and wish to save for retirement, then you need to make your own arrangements.
Do I have to be enrolled into the scheme?
No. Employers are required by law to enrol you after you have worked for them continuously for three months, however you can then opt out of the scheme by contacting the scheme provider, NEST.
Can I change my mind in the future?
Yes. If you change your mind then please contact your employer and NEST.
If I wish to come out of the scheme, can I get a refund on contributions that I’ve already made?
If you opt out in the first month then it will be possible to refund any deductions taken from your pay. After the first month has passed your employer will have paid the money over to NEST (the Pensions Provider), and so cannot refund it to you.
You can contact them directly, but the legislation clearly states that this money is only then payable to you on retirement.
Does it matter how much I earn?
Initially, yes. Once you earn more than £192 per week ,employers are obliged to enrol you and start making contributions.
How much will be paid across for me each week?
The current minimum contribution is 8%. A 5% contribution is made by the employee and 3% by the employer, meaning a total of 8% is paid across.
The Apprenticeship Levy
Introduced in April 2017, the Apprenticeship Levy came into force to generate funding for apprenticeships. With an aim to provide 3 million more apprenticeships by 2020 as well as improving the quality of apprenticeship and training schemes available.
More information on the levy is available on the government’s website.
The levy and umbrella services
The cost of the levy to Umbrella companies is significant, and in order to offset the cost of this typically a small margin is made via charging the outsourced employees to that umbrella company 0.5% of PAYE per week, this should be included in overall umbrella margins for transparency.
What will happen to the funds collected under the levy?
The money collected by the government from the levy is allocated to an apprenticeship training fund. There are constraints on how this money can be spent.
Realistically any Umbrella company should not benefit financially from the additional 0.5% margin and should not spend this money on anything other than training for apprentices. Any funds which aren’t spent should be retained by the government.
Who is affected?
Anyone who is paid PAYE.
Self-employed workers are not affected by the change so if you currently operate your own PSC/ Limited Company or are registered on our CIS scheme you will not be impacted.
Is it time to consider your options?
If this latest legislation has an impact on you then it might be a good time to review your current situation and the way you receive your pay. For many contractors our umbrella scheme will still be the best approach and umbrella employees can continue to benefit from employment status and all the benefits that go with it.
Public Liability Insurance
What is public liability insurance?
Public liability insurance protects a business in the event that someone makes a claim against you for causing accidental damage or injury, whether to individuals or property. This claim could be made due to circumstances which took place either at your premises, or as a result of your business activities.
Self-employed public liability insurance
All self-employed subcontractors need public liability insurance.
As a fully compliant company, ProPaye CIS will request proof that you have public liability cover in place in the form of signing a declaration which will include referencing details of your insurance policy.
In the event that you don’t already have a policy in place, we will cover you under the ProPaye CIS policy and will increase our margin by £3 per week. Should you then organise your own cover in the future, please contact us, send in proof, and we will immediately remove you from our cover and reduce the margin retained by £3 per week.
The Kittel Principle
A piece of legislation which has recently been receiving a lot of attention is the Kittel Principle.
The Kittel Principle is often referred to as the “should have known – could have known” which heavily reinforces the importance of all businesses doing their due diligence on anyone in their supply chain that they engage with.
In short, the principle operates on the basis that a VAT-registered business can be denied otherwise legitimate input tax relief if the business was aware or is deemed to be in the position that they should have been aware, that the underlying transactions were fraudulent. The name of this piece of legislation comes from a Belgian case of 2008.
It is worth noting that this principle has been applied to businesses from multiple sectors and the investigations into the companies in question can span months, with the purpose being for legal entities to see how much due diligence was conducted on the way either party operates, ultimately leading to a decision being made on who should have known the activity was fraudulent.
So, bear this in mind that if the intermediary you are considering working with is offering rebates / kickbacks, is this being funded by underpayments in tax, NI or through use of VAT incentives? Ensure that all monies due to HMRC are being paid over correctly, in full and on time by requesting copies of their VAT submissions and PAYE/RTI to ensure you can demonstrate your due diligence efforts. (Agencies should be aware of the risks of financial links).
If the intermediary denies your request for this information, seems reluctant or you aren’t satisfied with what you do receive, consider the risks posed to your business if you continue to engage with this intermediary.
More information on this can be found at the Gov. website.
Is your compliance locked down? ProPaye Outsourcing’s services follow stringent compliance practises. This stems from the ProPaye brands belief that compliance is key to being successful in the industry that we operate in. We are always following changes in legislation to not only protect our services but our clients and their workforce too.
With there being so much spotlighting on safety in labour supply chains, and the fact that there seem to be consistently big changes being made to important pieces of employment law, it has never been more prudent to know who you’re partnering with and where they stand on matters of compliance.
Please feel free to view our compliance library listed on this page to help us with our mission of ensuring there is safety in our labour supply chains.
If you have any questions about some of the legislation listed here – or something that isn’t, please feel free to contact our offices and ask to be put in touch with our Compliance Manager directly:
Call: 01543 220 903