Section 01
Purpose
This policy sets out how We Are Care stays compliant with UK tax, employment and labour-supply law, and states unambiguously how our workers are engaged and paid, so that clients, commissioners and our financial partners can rely on the integrity of our supply chain.
Section 02
Scope
Applies to every worker we supply or employ, to all directors and staff, and to any supplier or subcontractor in our supply chain.
Section 03
Our employment model
We Are Care employs and pays carers directly under UK PAYE. Every worker is paid at fair-pay rates, by bank transfer, with income tax, National Insurance and pension auto-enrolment operated correctly at source.
Section 04
Prohibition on umbrella companies and intermediaries
- We do not use umbrella companies for any worker, under any circumstances.
- We do not use personal service companies, self-employment or other intermediary or disguised-remuneration arrangements for the supply of care workers.
- We use no offshore entities, and operate no loan, advance or non-taxable payment scheme other than reimbursed expenses or statutory allowances.
- We do not sub-contract recruitment or labour supply to third parties whose pay and tax practices we cannot directly verify.
Section 05
Tax compliance
- PAYE income tax and Class 1 National Insurance contributions operated on all worker earnings.
- Workplace pension auto-enrolment under the Pensions Act 2008.
- No reliance on off-payroll or IR35 avoidance, as workers are directly employed.
- VAT applied correctly, with the welfare exemption applied to qualifying supplies of care.
Section 06
Anti-facilitation of tax evasion
In line with the Criminal Finances Act 2017, we operate reasonable prevention procedures against the facilitation of tax evasion by anyone acting on our behalf. Suspected facilitation is reported under the Whistleblowing Policy and, where required, to HMRC.
Section 07
Anti-bribery
We operate a zero-tolerance position on bribery and corruption under the Bribery Act 2010. No worker, director, contractor or anyone acting on behalf of We Are Care may offer, give, request or accept any bribe, kickback or improper inducement in connection with our business or our placements. Modest, customary hospitality is acceptable only where it could not reasonably be seen to influence a decision. Suspected breaches are reported under the Whistleblowing Policy.
Section 08
Labour-supply and right-to-work compliance
We comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and the Agency Workers Regulations 2010. Right-to-work checks are completed on every worker before any placement, with no exceptions. See the Safer Recruitment Policy for the full pre-placement checks framework.
Section 09
Supplier and subcontractor compliance
Material suppliers confirm compliance with the Modern Slavery Act 2015 and our payment and tax standards as part of onboarding. We charge no fees to workers under any circumstances.
Section 10
Records, retention and security
Payroll, tax, pension and right-to-work records are retained in line with statutory requirements set out in the central Retention Schedule (RoPA companion sheet); we do not invent per-system retention periods. Information security controls on compliance records are governed by our Information Security Policy (BTN-WAC-IS-2026) (security lead: Joel Dawson).
Section 11
Monitoring and assurance
Compliance is monitored continuously through Baton Compliance, which tracks legislative change and flags risks to the relevant owner with time to act. Payroll, right-to-work and pension controls are checked on a recurring cycle.
Section 12
Responsibilities
The board owns this policy. Finance operates payroll, tax and pension controls. Compliance and operations verify right-to-work and labour-supply requirements. Every worker and manager must report any concern about pay, tax or intermediary arrangements.
Section 13
Use of Baton
Baton Compliance surfaces regulatory change and tracks control completion. Decisions and sign-off remain human-owned.
Published at wearecare.co.uk/policies/compliance.