- Government has finally updated its guidance entitled “Use of labour providers: advice on due diligence” which was last updated on 19 May 2017
- New guidance is now entitled “Advice on applying supply chain due diligence principles to assure your labour supply chains”
- Government has also published a document detailing “10 things about due diligence: supply chain assurance”
- The guidance sets out why performing due diligence is important in maintaining the integrity of the supply chain and the risks (including financial, legal, and reputational) of not performing “proper checks”
- Guidance specifically states that a business performing due diligence on its immediate customers and suppliers may not be sufficient and they may need to delve “below the surface”
- The guidance details the principles of “Check, Act and Review” which, if applied, will help businesses apply effective risk management and robust due diligence to assure the integrity of the supply chains
- As always, the guidance specifically states that it is not a “definitive checklist but are good practice examples”
- HMRC deem that due diligence checks should be “risk-based, relevant, reasonable, proportionate and most importantly, ongoing”
- The guidance also helpfully confirms that if we lose access to the Value Information Exchange System (“VIES”) which many businesses use to check that a supplier holds a valid VAT registration, a new site will be launched on Gov.uk to allow due diligence checks against UK VAT registrations although the guidance does state that businesses should verify the suppliers VAT registration details with HMRC before using them
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