DEF-PB13107_OpGangmsts 10/7/08 10:33 Page 1

communisis The leading print partner C M www.defra.gov.uk Y K LOCATION: PRINERGY 1 DISCLAIMER APPROVER The accuracy and the content of this file is the responsibility of the Approver. Please authorise approval only if you wish to proceed to print. Communisis PMS cannot accept liability for errors once the file has been printed. PRINTER This colour bar is produced manually all end users must check final separations to verify Consultation on the colours before printing. operation of the Gangmasters Licensing (Exclusions) Regulations 2006

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Consu Summ Backg Discu Propo D S S S Quas Supp Pea v Fores Department for Environment, Food and Rural Affairs Nobel House What 17 Smith Square Anne London SW1P 3JR Telephone 020 7238 6000 T Website: www.defra.gov.uk Anne

© Crown copyright 2008 A Copyright in the typographical arrangement and design rests with the Crown. Anne This publication (excluding the royal arms and departmental logos) may be reused free of charge Q in any format or medium provided that it is reused accurately and not used in a misleading Anne context. The material must be acknowledged as crown copyright and the title of the publication specified. P

Information about this publication and further copies are available from: Anne L Gangmasters, and Tenancies Team Area 7E, Millbank c/o Nobel House Defra 17 Smith Square London SW1P 3JR

Email: [email protected]

Tel: 020 7238 5702

This document is available on the Defra website: http://www.defra.gov.uk/corporate/consult/foodfarming.htm

Published by the Department for Environment, Food and Rural Affairs DEF-PB13107_OpGangmsts 10/7/08 10:33 Page 1

Contents

Consultation Letter 2 Summary 5 Background 6 Discussion 7 Proposals made by stakeholders to change the Exclusions Regulations 8 Definitions Short-term farmer to farmer loans Short-term services between farmers involving the use of a worker Specialist workers Quasi public organisations and charities 12 Supply between separate corporate bodies in the same ownership 13 Pea vine co-operatives 14 Forestry industry 15 What to do next 16 Annex A 17 The Gangmasters Licensing (Exclusions) Regulations 2006 Annex B 21 Activities Currently Excluded from the Licensing Scheme Annex C 22 rge Questions asked by this consultation Annex D 23 Partial Impact Assessment Annex E 30 List of consultees

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Consultation Letter

Gangmasters, Employment and Tenancies Team Consu Zone 5E 9 Millbank c/o Nobel House 6. T 17 Smith Square h London SW1P 3JR • Direct Line 020 7238 5702 Fax 020 7238 6553 • Website www.defra.gov.uk Email [email protected] • •

• Dear Consultee Consultation on the operation of the Gangmasters Licensing (Exclusions) Regulations 2006 7. W 1. I am writing to invite views on the operation of the Gangmasters Licensing (Exclusions) E Regulations 2006. a 2. The following documents may be found on Defra’s website at 8. If http://www.defra.gov.uk/corporate/consult/gangmasters-regs/ in re • Consultation letter th • List of consultees 9. P • Consultation paper if • Initial Impact Assessment th W Responses h o 3. Throughout the consultation document and initial Impact Assessment there are specific c questions aimed to help Defra to make an informed assessment of how these regulations are operating. These are listed in Annex C and we would be particularly interested to hear your 10. To views on them. D 4. Please send responses to me at: In L Gangmasters, Employment and Tenancies Team E Defra 1 Zone 5E, 9 Millbank L c/o Nobel House S 17 Smith Square London Te SW1P 3JR E Email: [email protected] P 5. Responses should be received by 20 October 2008.

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Consultation Letter

Consultation criteria 6. This consultation is in line with the Code of Practice on Consultations. This can be found at http://www.berr.gov.uk/bre/ • Consult widely throughout the process, allowing a minimum of 12 weeks for written consultation at least once during the development of the policy • Be clear about what your proposals are, who may be affected, what questions are being asked and the timescale for responses • Ensure that your consultation is clear, concise and widely accessible • Give feedback regarding the responses received and how the consultation process influenced the policy • Monitor your department’s effectiveness at consultation, including through the use of the designated consultation co-ordinator • Ensure your consultation follows better regulation best practice, including carrying out a Regulatory Impact Assessment if appropriate 2006 7. When this consultation ends, we intend to place a copy of the responses in the Defra library at sions) Ergon House, London. This is so that the public can see them. Members of the public may also ask for a copy of responses under freedom of information legislation. 8. If you do not want your response – including your name, contact details and any other personal information – to be publicly available, please say so clearly in writing when you send your response to the consultation. Please note, if your computer includes a confidentiality disclaimer, that won’t count as a confidentiality request. 9. Please explain why you need to keep details confidential. We will take your reasons into account if someone asks for this information under freedom of information legislation. But, because of the law, we cannot promise that we will always be able to keep those details confidential. We will summarise all responses and place this summary on our website at http://www.defra.gov.uk/corporate/consult/gangmasters-regs/. This summary will include a list of names of organisations that responded but not people’s personal names, addresses or other pecific contact details. ns are r your 10. To see consultation responses and summaries, please contact the library at: Defra Information Resource Centre Lower Ground Floor Ergon House 17 Smith Square London SW1P 3JR Telephone 020-7238-6575 Email: [email protected] Please give the library 24 hours’ notice. There is a charge for photocopying and postage.

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Consultation Letter

11. If you have any comments or complaints about the consultation process, please address them Sum to Marjorie Addo, Defra’s Consultation Co-ordinator, Area 7C Nobel House, 17 Smith Square, London SW1P 3JR, or email [email protected]. • 12. Thank you for your help in this matter. If you have any queries please contact us as above. • Yours sincerely

Ian Kelly Department for Environment, Food and Rural Affairs

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Consultation Document

them Summary quare, • Your views are invited on proposals to clarify the terms of the Gangmasters Licensing (Exclusions) Regulations 2006. e. • Feedback received from stakeholders about the way that the 2006 Regulations are operating suggests some refinement may be necessary to fine-tune the range of excluded circumstances. • This consultation also offers you the opportunity to identify any other areas of the Regulations which you consider need refinement. • The Government is not proposing to make substantive changes to the scope of the Gangmasters Licensing Scheme. Therefore this consultation does not seek views on making major revisions to the existing boundary set by the 2006 Regulations.

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Consultation Document

Background Discu 1. The Gangmasters (Licensing) Act 2004 was drafted in broad terms to require all labour providers 3. In operating in agriculture, horticulture, the processing and packaging of agricultural, fish and p shellfish produce, and the gathering of shellfish to obtain a licence. As a result of the way that w the Act was drafted, certain circumstances – which do not involve the activity of labour providers a or where the risk of exploitation of workers and other illegal activity by labour providers is st minimal – are brought within the definition of acting as a gangmaster. n to 2. The Gangmasters Licensing (Exclusions) Regulations 2006 fine-tune the scope of the licensing a arrangements by specifying circumstances where a person does not need to obtain a licence. c Annex A contains a copy of the Regulations and Annex B summarises the principal activities p which the current regulations exclude from the scope of the scheme. b to a 4. T sc in v c th th c re lo

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Discussion viders 3. In broad terms the current arrangements have mapped reasonably accurately those areas where h and providers of gang labour are active, while excluding peripheral labour supply arrangements y that which do not represent the supply of gang labour or where the risk of exploitation of workers viders and other illegal activity by labour providers is low. However feedback received from ders is stakeholders since the Regulations were made in 2006, suggests that some refinement may be necessary to widen the range of excluded circumstances and to clarify the terms we have used to define the current exclusions. The activities which the industry has brought to our attention ensing are discussed in more detail in the remainder of this consultation document. They include cence. circumstances which were never intended to be covered by the licensing system in the first tivities place, such as charities which supply workers into the sectors covered by the Act. It has also been suggested that the terms used to define some of the existing exclusions should be relaxed to exclude informal or co-operative arrangements between farmers which do not involve the activity of mainstream labour providers. 4. The Government is not intending to use this consultation to initiate a fundamental review of the scope of the scheme. We are not seeking views on proposals to extend licensing to other sectors in the food chain, such as the retail and catering industries. Nor is the Government seeking views on proposals to remove the food processing sector from the scope of licensing, which was considered thoroughly at the time of the second consultation on the Exclusion Regulations at the end of 2005. There is general agreement among stakeholders, Government and the GLA that a fundamental review would be unhelpful and disruptive. Rather the focus of this consultation is focused on mainstream agricultural and forestry activities where clarification and revision of the terms of the Regulations could lighten burdens without opening up potential loopholes that could be exploited by those seeking to avoid licensing.

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Proposals made by stakeholders to change the Exclusions Regulations Parag farme 5. Several changes to the terms of the Exclusions Regulations have been suggested by stakeholders. The purpose of these changes can be broadly categorised as follows: 9. P w i) to relieve the burden imposed by licensing on mainstream farming and forestry practices T which do not involve the use of labour providers; i) ii) to remove from the scope of licensing other activities caught by the licensing requirement ii) which do not represent labour provider activity; and ii iii) to clarify and make more transparent the application of the terms used in the Regulations to describe the activities excluded from licensing. T Your views are sought on all of the proposals described in detail below. You are also invited to d identify other areas in the Regulations which you think should be excluded or clarified and to explain why you think such a change is necessary. 10. S fo Definitions used in paragraph 1 of the to the Exclusions Regulations m 6. Paragraph 1 of the Schedule to the Exclusions Regulations (see Annex A) provides definitions of p the terms used in the remaining paragraphs of the Schedule to describe the circumstances (a where a licence is not required. Many of these terms were not previously defined in existing tr legislation when we developed the Regulations and hence were untested in a legal framework. e We think in general that the definitions we have used convey fairly accurately and u unambiguously the meaning of the terms we have used. However, to date no case law has been v established about the operation of these Regulations. th e 7. However, one stakeholder has suggested that the definition of “share farming agreement” used w by these Regulations is unnecessarily restrictive. The current definition is: st “an agreement entered into between two or more persons to share the gross receipts of – 11. In (a) their separate business assets; or fo (b) services for carrying out specified farming operations, fa As divided between them and paid to the business in agreed proportions.” 12. T fl It has been suggested that this definition should be replaced by one where the receipts shared a are “net”, as share farming agreements usually share net receipts for the express purpose of th creating a group working structure while avoiding the need to form a partnership (where the c partners would be jointly and severally liable to the creditors). th Q1. Do you agree that the definitions used in the Regulations convey accurately the terms 13. T used? fo Q2. If not, which definitions need further clarification, and why? A 6 Q3. Do you think the definition of “share farming agreement is too restrictive? If so, p how do you think it should be changed? lo b o 14. A (i c c

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Consultation Document

Paragraph 4 of the Schedule to the Exclusions Regulations – Short-term farmer to farmer loans ed by 9. Paragraph 4 of the Schedule to the Exclusions Regulations specifies those circumstances which do not need to be licensed when workers are loaned between farmers. ctices These circumstances include: i) the short term loan of workers, ement ii) the exceptional loan of workers originally supplied by a labour provider, and iii) the loan of workers on a farm which is the subject of a share farming agreement between ons to the two farmers. The purpose of this exclusion is to exclude from licensing a mainstream farming practice which ted to does not represent gangmaster activity though it is defined as such by the Act. nd to 10. Sub-paragraph 4(b) provides for the exclusion of workers lent by one farmer to another. In order for the lender to qualify for this exclusion, the worker lent must not work for the borrower for more than 20% of the total hours that the worker worked for the lender in the three months ons of prior to the commencement of the loan. Some stakeholders have claimed that this 20% rule ances (as it is known) is too restrictive as it cannot always accommodate the seasonal peaks and xisting troughs of the agricultural cycle. For instance, it is argued that the 20% limit (which broadly 1 work. equates to a maximum period of 2 ⁄2 weeks) is insufficient in the case of workers loaned to y and undertake activities – such as spring cereal sowing, lambing, calving, potato lifting and 1 been vegetable harvesting – which could take considerably longer than 2 ⁄2 weeks. Others argue that this rule, which deters some farmers from employing workers as direct employment is economically viable only when the farmer is able to offset the cost of employment by loaning used workers to other farmers during periods of low activity. In this view the financial benefit stemming from the loan of workers is outweighed by the cost of obtaining a licence. – 11. Information about the frequency of farmer to farmer loans of workers is not collected by any formal survey. Informal soundings taken by one agricultural stakeholder suggest that most farmers who employ workers are caught by the 20% rule. 12. The 20% limit was set at this level as it was thought to balance best the need of farmers for flexibility in running their businesses with the need to ensure that this exclusion does not provide hared a loophole which could be exploited by labour providers in order to avoid licensing. In principle ose of the Government is not opposed to relaxing the 20% limit exclusion if it removes genuine re the constraints on the operation of farm businesses. However, in doing so it will need to be satisfied that it will not allow mainstream labour providers to circumvent the licensing system. terms 13. The terms of this exclusion could be varied in several ways in order to provide greater flexibility for farmer to farmer loans. The 20% rule could be increased to, say, 30%, 40% or 50%. Alternatively, the current reference period of three months could be extended to 6, 9 or 12 months. Combinations of variations in the 20% rule and the length of the reference If so, period could also be used to define the terms of this exclusion. A further option is to allow the loan of one or two workers between farmers without any restriction on the length of the loan but to impose a cap on the supply of more than one or two workers so that the loan of three or more workers would require a licence. 14. At present the terms of paragraph 4(b) only apply to loans of workers between farmers (including businesses engaged in forestry). It has been suggested that the terms of this provision could be extended to cover loans of workers between employers operating in other areas covered by the licensing scheme (such as food manufacturing).

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Consultation Document

15. Sub-paragraphs 4(a) and 4(c) provide, respectively, for the supply of workers between farmers Q9. D to do work on a farm which is the subject of a share farming agreement between the two fa farmers (4(a)) and the supply of a gang worker between farmers where the worker has been supplied by a labour provider (4(b)). Unlike the exclusion at sub-paragraph 4(b), the Government Q10. has not received representations that the terms of these exclusions are having an adverse impact on farming practices. Therefore we do not propose to change the terms of these exclusions. Parag Q4. Do you consider that the 20% rule restricts the flexible operation of mainstream 19. T farming practices involving the loan of workers between farmers? If your answer is u yes, do you have evidence to support your response? li Q5. Do you think that the terms of the exclusion for farmer to farmer loans of workers (i should be relaxed? If so, why and how? (i Q6. Should the terms of the exclusion for farmer to farmer loans be extended to short-term loans of workers to undertake non-agricultural activities covered by the Act? Q7. Do you agree that the terms of the Exclusions contained at sub-paragraphs 4(a) and (i 4(c) should remain unchanged? If not, why? (i Paragraph 5 of the Schedule to the Exclusions Regulations – Short-term services between 20. S farmers involving the use of a worker b th 16. This paragraph specifies those circumstances excluded from the scope of licensing when services w involving the use of a worker are supplied between farmers. To qualify for the exclusion the O service supplied must involve a one-off arrangement of less than two weeks (sub-paragraph b 5(a)). Furthermore, where the supplier of the service is using a worker he employs, then the sh 20% rule must be met (5(b)). Where the service involves the use of a worker provided by a th gangmaster, the farmer supplying the service must obtain the agreement of the gangmaster se that the worker can be used to deliver the service (5(c)). b 17. This paragraph largely reflects the terms of the exclusions provided at Paragraph 4 of the Q11. Schedule. This is necessary as the definition of acting as a gangmaster in the 2004 Act includes both the supply of workers and also the supply of services involving the use of workers to deliver that service. The Government is not intending to relax the limit on the duration of services Q12. provided by one farmer to another involving the use of gang workers. However it could be argued (for the same reasons identified in the discussion above about Paragraph 4 of the Schedule) that the limit could be relaxed where the service is delivered by directly Q13. employed workers. 18. It has been argued that condition (c) of the terms of this exclusion can be interpreted as standing on its own and not linked to condition (a). In this interpretation a farmer who provides a service to another farmer with the use of gang labour supplied by a third party is not constrained by the limitation over the length of duration of the service set at (a). Defra disagrees with this interpretation as it is our view that paragraph 5 should be construed in the way that it was intended with (c) being linked to (a). However, we appreciate that to some the meaning could appear ambiguous. In view of this we intend to review the wording of this exclusion in order to remove any ambiguity about its application. Q8. Does the 20% rule restrict the flexible operation of traditional farming practices involving the supply of services? If your answer is yes, what evidence do you have to support your response?

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Consultation Document

rmers Q9. Do you think that the terms of the exclusion for the supply of services between e two farmers should be changed? If so, why and how? been nment Q10. Do you agree that there is a need to review the wording of the exclusion to make it mpact clear that the provisions of the exclusion are interdependent? ons. Paragraph 13 (specialist workers) ream 19. This paragraph provides for the exclusion from licensing of the supply of a specialist worker to wer is undertake agricultural work. In order for the labour provider to qualify for exemption from licensing the worker supplied must meet the following conditions: rkers (i) The worker must be supplied to undertake work in which the worker is specialised, (ii) The labour user requires the worker to hold a qualification at or above NVQ Level 2 -term (or equivalent) which is relevant and necessary for the work the worker is supplied to undertake, ) and (iii) The labour user employs the worker supplied, and (iv) On the day the worker is supplied no other worker is supplied by the labour provider. ween 20. Several stakeholders have argued that the terms of this exclusion are overly prescriptive and should be relaxed. Some have suggested that the current limitation on the number of specialist workers that can be supplied at any one time should be increased from the current limit of one as skilled rvices workers are likely to be better able to protect their employment rights than unskilled workers. n the Others would like to see the removal of the condition which requires that the worker supplied must graph be employed by the labour user. In addition, it has been suggested that the terms of this exclusion n the should be widened to exclude from licensing the supply of workers who have gained their skills by a through practical experience rather than formal . At present labour providers who supply master self-taught workers cannot obtain an exemption from licensing, even though those workers may be performing identical tasks to their formally qualified counterparts. of the Q11. Is the current threshold of one worker supplied at any one time too low? If it is what cludes should it be changed to and why? deliver rvices Q12. Should competences gained through experience also qualify for exclusion uld be from licensing? of the rectly Q13. Should the requirement that the supplied by a labour provider must be employed by the labour user be retained? If not, why not? nding ervice ed by h this t was could der to ctices ve to

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Consultation Document

Quasi public organisations and charities Supp 21. Some charitable organisations and public bodies used by Government to deliver publicly funded 22. T services fall within the definition of acting as a gangmaster in the Gangmasters Licensing Act w 2004. Examples include Remploy, Mencap and various bodies funded by Jobcentre Plus and the T European Social Fund which are engaged – for instance -in preparing the unemployed for work. T Where these bodies place workers with employers in sectors regulated by the Act they are a regarded by the Act as acting as gangmasters. It was never intended that these types of organisations should be regulated by licensing. This review offers the opportunity to regularise 23. T their current position by excluding their activities from the requirement to be licensed. In n excluding these types of organisations we will need to define carefully the terms of the provision re to ensure we do not create a loophole which could be exploited by those claiming to deliver th publicly funded services. b th Q14. Do you agree that charities and public bodies used to deliver charitable services should be excluded from the gangmaster licensing arrangements? 24. B lo Q15. Should there be a blanket exclusion for such organisations, or are there any g organisations which you think should be retained within the scope of the scheme? to If so, why? a in Q16. Which organisation do you suggest should be excluded? Q17.

Q18.

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Supply between separate corporate bodies in the same ownership unded 22. The supply of workers or services involving the use of workers between separate legal entities g Act which are incorporated bodies represents a supply for the purposes of the 2004 Act. nd the Therefore the incorporated body which supplies the worker or service must obtain a licence. work. This requirement applies even when the supply takes place between incorporated bodies which ey are are under the same ownership. pes of ularise 23. The supply of workers or services between separate corporate bodies in the same ownership is ed. In not uncommon in groups of companies where one company in the group is responsible for vision recruiting and organising the labour needs of the other companies in the group. It is argued that deliver this circumstance should be excluded from licensing as workers supplied between separate bodies within the same group are unlikely to be exploited as the supply is undertaken to meet the logistical needs of the group rather than for commercial purposes. rvices 24. By contrast, it could be argued that excluding this circumstance from licensing could open up a loophole through which, for instance, labour providers and users reorganise themselves into a any group of commonly owned incorporated companies under the same holding company in order eme? to avoid licensing. In view of this the Government would need to be satisfied that providing for an exclusion for a supply between corporate bodies in the same ownership does not provide an incentive for avoiding licensing in this way. Q17. Do you think that supplies between corporate bodies within the same ownership should be excluded from licensing? Q18. If we excluded this circumstance do you think it would be easy for labour providers and users to restructure their activities in order to take advantage of this exclusion?

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Pea vine co-operatives Fore 25. It has been argued that members of an agricultural co-operative who provide labour to the 29. T co-operative in order to assist in the cultivation or harvest of the members’ crops should be o excluded from the licensing. in c 26. A typical scenario might involve that of a pea vine or sugar beet co-operative where cooperation (w between growers is necessary in order to purchase and operate expensive and specialised o harvesting equipment. At harvest time the co-operative will hire workers from its members to th harvest the crop of individual members using the machinery acquired by the co-operative. c This might involve the workers and machinery travelling from one holding to the next to is undertake the harvest until all of the holdings had been harvested. This could take 2-3 months w to complete. a 27. This arrangement falls within the definition of gangmaster activity in respect of the supply of a th worker by the co-operative member to the co-operative. In some instances it might be possible th for a member to obtain an exemption under the farmer to farmer loans provision of the 30. L Exclusions Regulations. However it is likely that most loans (due to the length of the harvest) will th fall foul of the 20% rule. re 28. Government policy is to encourage co-operative ventures in farming. In the case of a pea vine T or sugar beet co-operatives the Government would not want to hinder or impose an o unnecessary burden on co-operative effort by making it a requirement that each member of the 31. S co-operative who supplies a worker to the co-operative should obtain a gangmasters licence. fo However, the Government is not proposing to exclude from licensing the labour pools e maintained by co-operatives which are used to meet the day to day labour needs of the re members as these act no differently from mainstream labour providers. a Q19. Do you think that arrangements – such as pea vine co-operatives or sugar beet to co-operatives – where workers are loaned to the co-operative to undertake c harvesting duties for the co-operative should be excluded from the licensing Q20. arrangements?

Q21.

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Forestry industry o the 29. The definition of agricultural work contained in the Gangmasters (Licensing) Act 2004 is based uld be on the definition in the Agricultural Act 1948. This provides that “agriculture” shall include “dairy farming, the production of any consumable produce which is grown for sale or consumption or other use for the purposes of a trade or business or of any other undertaking ration (whether carried on for profit or not) and the use of land as grazing, meadow or pasture land alised or orchard or osier land or woodland or for market gardens or nursery grounds”. In the light of ers to the inclusion in the definition of the use of land as woodland, Defra takes the view that all work rative. connected with the planting, establishment, maintenance and harvesting of woodland or forests ext to is agricultural work. Therefore a person who supplies a worker to do forestry work or uses a onths worker in the supply of a forestry service is regarded by the 2004 Act as acting as a gangmaster and is required to obtain a licence in respect of that activity. The inclusion of forestry within y of a the scope of the Act was confirmed by Defra Ministers during the passage of ossible the Bill. of the 30. Labour providers operating in the forestry industry are entitled to the same exclusions open to st) will their farming and contractor counterparts in agriculture. Probably the provision which is of most relevance to the forestry industry is the exemption of agricultural machinery services. a vine The provisions governing the loan of workers and the supply of specialist workers could also be se an of benefit to some operators in this sector. of the 31. Several stakeholder organisations and individuals in the forestry sector have argued that the cence. forestry sector should be taken out of the scope of the licensing scheme as there is little pools evidence of worker exploitation, the use of gang labour is low and the industry is already closely of the regulated by enforcement bodies such as the Health & Safety Executive. Against this, others argue that there are occasions when large numbers of seasonal and casual workers are supplied beet to undertake forestry work and these workers should be offered the same protection as their rtake counterparts in agriculture. nsing Q20. Do you think forestry should be removed from the scope of the licensing scheme? If yes, why? Q21. Should licensing apply only to part of the forestry sector? If yes, to which activities should it apply?

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What to do next 32. Views and contributions are welcome from all individuals and organisations with an interest in this consultation. Please: (i) read the consultation paper and partial Impact Assessment, (ii) consider the questions asked in this consultation paper (which are listed at Annex C), and (iii) submit your comments using the contact details provided in the covering letter. The 33. Please send your replies by 20 October 2008 at the latest. Made Laid b Comin The S sectio Citati 1.—(1 and c (2 Circu 2. A p the ci

8th M

(a) 2004

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Annex A

STATUTORY INSTRUMENTS rest in 2006 No. 658

EMPLOYMENT and The Gangmasters Licensing (Exclusions) Regulations 2006 Made 8th March 2006 Laid before Parliament 13th March 2006 Coming into force 6th April 2006 The Secretary of State makes the following Regulations in exercise of the powers conferred by section 6(2) of the Gangmasters (Licensing) Act 2004(a): Citation, commencement and interpretation 1.—(1) These Regulations may be cited as the Gangmasters Licensing (Exclusions) Regulations 2006 and come into force on 6th April 2006. (2) In these Regulations, “the 2004 Act” means the Gangmasters (Licensing) Act 2004. Circumstances in which a licence is not required 2. A person does not require a licence to act as a gangmaster under section 6(1) of the 2004 Act in the circumstances specified in paragraphs 2 to 15 of the Schedule.

Bach Parliamentary Under Secretary of State 8th March 2006 Department for Environment, Food and Rural Affairs

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Annex A

Regulation 2 2. T (a Circumstances in which a Licence is not required under the 2004 Act (b 1. In this Schedule— (c “catering establishment” means— (d (a) a restaurant, canteen, club, public house, school kitchen, prison kitchen, hospital kitchen or (e similar establishment (including a vehicle or a fixed or mobile stall) where— 3. T (i) food is cooked or made ready for consumption without further preparation; and w (ii) food is prepared for service to the consumer. p (b) other premises used solely for the purpose of cooking or making food ready for 4. T consumption, without further preparation, after delivery to the consumer; (a “distribution warehouse” means premises where produce is received prior to onward distribution to a wholesale or retail establishment and— (b (a) there is no change in the ownership of the produce concerned between receipt and onward distribution; and (b) the wholesale or retail establishment to which delivery is made is excluded under paragraph (c 2 of this Schedule; and (c) the premises are owned by the same company that owns the retail or wholesale establishment to which the produce is delivered; “farmer” means a person— 5. T (a) who occupies land used for agricultural activities; or b (b) who owns or operates a business that pursues agricultural activities in whole or in part; or (a (c) is an employed person with management responsibility for all or part of a business that pursues agricultural activities; (b “produce” means produce derived from agricultural work, shellfish, fish or products derived from shellfish or fish; (c “Seasonal Agricultural Workers Scheme” means a scheme operated by Work Permits UK, part of the Home Office, which allows farmers and growers in the to recruit overseas workers to undertake work that is both seasonal and agricultural; 6. T “share farming agreement” means an agreement entered into between two or more persons c to share the gross receipts of — 7. T (a) their separate business assets; or a (b) services for carrying out specified farming operations, as divided between them and paid to 8. T the businesses in agreed proportions; (a “wholesale establishment” means a facility operated solely for the purpose of selling produce for the purposes of resale or to a catering establishment, and includes a cash and (b carry warehouse.

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Annex A

2. The supply or use of a worker to process or pack produce if the worker is supplied to — (a) a catering establishment; (b) a shop or other retail establishment; (c) a wholesale market; (d) a wholesale establishment; hen or (e) a distribution warehouse. 3. The supply of a worker to process or pack a product which includes a derivative of produce but where the product being packed is not a food product, pet food product or a product which is primarily an agricultural, fish or shellfish product. y for 4. The supply of a worker for agricultural work by a farmer (A) to another farmer (B) where— (a) the supply is to do work on a farm which is the subject of a share farming agreement nward between A and B; or (b) the total hours the worker works for B are not more than twenty per cent of the total hours nward he worked for A in the three months immediately preceding the commencement of the period of work undertaken for B; or graph (c) the worker has been supplied to A by a person (C) who acts as a gangmaster in making that supply, and the supply by A— lesale (i) is made with C’s agreement to the nature of the work to be undertaken for B; and (ii) is a one-off arrangement of less than two weeks. 5. The use of a worker for agricultural work by a farmer (A) in connection with services provided by him to another farmer (B) where— rt; or (a) the services provided involve a one-off arrangement of less than two weeks; and s that (b) the total hours the worker works delivering services to B are not more than twenty per cent of the total hours he worked for A in the three months immediately preceding the erived commencement of the delivery of services to B; or (c) the worker has been supplied to A by a person (C) who acts as a gangmaster in making that K, part supply, and the use of the worker to deliver services by A is made with C’s agreement to the ecruit nature of the services to be provided to B. 6. The supply of a worker by a farmer to a contractor to operate machinery supplied by that ersons contractor for the purpose of undertaking agricultural work for that farmer. 7. The supply of a worker by a sole operator in the Seasonal Agricultural Workers Scheme to another Seasonal Agricultural Workers Scheme operator. aid to 8. The use of a worker, for agricultural work by a service provider to provide a service to a farmer— (a) where the service involves the use of machinery owned or hired by the service provider; and selling h and (b) the worker is employed by the service provider to operate or to support the operation of that machinery.

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Annex A

9.—(1) The use of a worker by a service provider, in connection with a food and drink processing Activ and packaging service provided to a service user, where the service provider— •S (a) is the worker’s employer; •S (b) owns, hires or leases any equipment, tools or machinery used by the worker which are •E necessary to carry out the service; and •P (c) owns or leases the premises where the work is carried out. •T 10. The use of a worker to harvest crops by a person who has transferred title to the land on which b the crops are grown, but has retained title to the crops. •T 11. The supply of a person licensed under the Welfare of Animals (Slaughter or Killing) Regulations •T 1995(a) to slaughter animals. n 12. The supply of a worker by an educational establishment to undertake agricultural work solely in •T furtherance of education or provided to the worker by that establishment leading to an a agricultural qualification recognised under sections 96 or 97 of the Learning and Skills Act 2000(a). •T 13. The supply by a person (A) to a farmer of a single worker to undertake agricultural work in c which that worker is specialised where— •T (a) the farmer requires the worker to hold a specific qualification at or above National Vocational •T Qualification Level 2 or Scottish National Vocational Qualification Level 2 (as recognised •T under sections 96 and 97 of the Learning and Skills Act 2000), or an equivalent qualification, which is relevant and necessary to ensure the worker can effectively discharge the •T responsibilities he will be required to undertake; and •T (b) the farmer employs the worker following his supply by A; and (c) on the day the supply is made, no other worker is supplied to the farmer by A. 14. The supply or use of a worker to gather shellfish before 1st October 2006. 15. On and after 1st October 2006 the use of a worker (a) to dive with the aid of breathing apparatus to gather shellfish from the sea bed; or (b) to operate a net, dredge or other machinery used to gather shellfish from the sea bed, other than a hand net or hand-held rake, where the worker is using the net, dredge or other machinery on board a fishing vessel which is operating at sea. EXPLANATORY NOTE (This note is not part of the Regulations) These Regulations make provision for the circumstances in which a licence to act as a gangmaster, granted under section 7 of the Gangmasters Licensing Act 2004 (c.11) is not required. The circumstances in which a licence is not required are set out in the Schedule. A Regulatory Impact Assessment of the effect that this instrument will have on the costs of business has been prepared and has been placed in the library of each House of Parliament. Copies may be obtained from the Agricultural Resources Team at the Department for Environment, Food and Rural Affairs, Ergon House, Horseferry Road, London SW1P 2AL.

(a) S.I. 1995/731. (a) 2000 c 21. 20 DEF-PB13107_OpGangmsts 10/7/08 10:33 Page 21

Annex B

essing Activities Currently Excluded from the Licensing Scheme • Share farming arrangements • Short-term farmer to farmer loans of workers ch are • Exceptional farmer to farmer loans of gang workers • Provision of short-term agricultural services between farmers involving the supply of a worker • The supply of a worker by a farmer to an agricultural contractor to operate machinery supplied which by that contractor for use on the farmer’s own premise • The supply of a worker by a sole operator appointed under SAWS to other SAWS operators ations • The provision of sub-contract services which involve the use of labour by the sub-contractor but not the supply of labour by the sub-contractor lely in • The supply of a worker as part of the provision of an agricultural machinery service by an to an agricultural contractor 00(a). • The employment of workers by someone who has sold a farm but retained the ownership of a ork in crop and uses those workers to harvest that crop • The supply of a qualified slaughterman to work in an abattoir tional • The supply of students by an educational establishment gnised • The supply of an individual skilled worker ation, e the • The direct employment of workers to gather shellfish by a fishing vessel • The supply of workers to process and pack in wholesale, retail and catering establishments

bed, other

master,

siness ay be Rural

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Annex C

Questions asked by this consultation

Q1. Do you agree that the definitions used in the Regulations convey accurately the terms used? Depa Q2. If not, which definitions need further clarification and why? Defra Q3. Do you think the definition of “share farming agreement” is too restrictive? If so, how do you think it should be changed? Stag Q4. Do you consider that the 20% rule restricts the flexible operation of mainstream farming Rela practices involving the loan of workers between farmers? If your answer is yes, do you have Regu evidence to support your response? Availa Q5. Do you think that the terms of the exclusion for farmer to farmer loans of workers should be relaxed? If so, why and how? http://w Q6. Should the terms of the exclusion for farmer to farmer loans be extended to short-term loans Conta of workers to undertake non-agricultural activities covered by the Act? Wha Q7. Do you agree that the terms of the Exclusions contained at sub-paragraphs 4(a) and 4(c) The G should remain unchanged? If not, why? by sp some Q8. Does the 20% rule restrict the flexible operation of traditional farming practices involving the certa supply of services? If your answer is yes, what evidence do you have to support your response? Wha Q9. Do you think that the terms of the exclusion for the supply of services between farmers should To cla be changed? If so, why and how? licens Q10. Do you agree that there is a need to review the wording of the exclusion to make it clear that explo the provisions of the exclusion are interdependent? Q11. Is the current threshold of one worker supplied at any one time too low? If it is, what should Wha it be changed to and why? Minis ident Q12. Should competences gained through experience also qualify for exclusion from licensing? brou Q13. Should the requirement that the skilled worker supplied by a labour provider must be possi employed by the labour user be retained? If not, why not? Whe Q14. Do you agree that charities and public bodies used to deliver charitable services should be desir excluded from the gangmaster licensing arrangements? The o Q15. Should there be a blanket exclusion for such organisations, or are there any organisations which you think should be retained within the scope of the scheme? If so, why? Mini Q16. Which organisation do you suggest should be excluded? I Q17. Do you think that supplies between corporate bodies within the same ownership should be it excluded from licensing? Signe Q18. If we excluded this circumstance, do you think it would be easy for labour providers and users Signe to restructure their activities in order to take advantage of this exclusion? Q19. Do you think that arrangements – such as pea vine co-operatives or sugar beet co-operatives – where workers are loaned to the co-operative to undertake harvesting duties for the co- operative should be excluded from the licensing arrangements? 20. Do you think forestry should be removed from the scope of the licensing scheme? If yes, why? Q21. Should licensing apply only to part of the forestry sector? If yes, to which activities should it apply?

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Annex D

Summary: Intervention and Options used? Department /Agency: Title: Defra Impact Assessment of the operation of the Gangmasters Licensing (Exclusions) Regulations 2006 o you : Partial Version: 1 Date: 3 June 2008 rming Related Publications: Consultation paper on the operation of the Gangmasters Licensing (Exclusions) have Regulations 2006

Available to view or download at: uld be http://www.defra.gov.uk/corporate/consult/default.asp loans Contact for enquiries: Ian Kelly Telephone: 0207 238 5702

What is the problem under consideration? Why is government intervention necessary? d 4(c) The Gangmasters Licensing (Exclusions) Regulations 2006 refine the scope of the Gangmasters Licensing Act 2004 by specifying the circumstances where a licence is not required. Since the Regulations came into force, some stakeholders have argued that they need to be revised in order to clarify their application; and to remove ng the certain agricultural activities from the scope of licensing. your

What are the policy objectives and the intended effects? hould To clarify the terms of the Gangmasters Licensing (Exclusions) Regulations 2006; and to remove from the licensing requirements those circumstances which do not represent gangmaster activity or where the risk of r that exploitation is minimal. hould What policy options have been considered? Please justify any preferred option. Ministers have made a public commitment to review the operation of the 2006 Regulations. The circumstances identified in the consultation as possible candidates for exclusion from licensing reflect those that have been g? brought to our attention by stakeholders since the original regulations were laid in Parliament in 2006. It is st be possible that others will be identified during the course of this consultation.

When will the policy be reviewed to establish the actual costs and benefits and the achievement of the uld be desired effects? The operation of the licensing scheme is reviewed annually by the GLA. ations

Ministerial Sign-off For consultation stage Impact Assessments: I have read the Impact Assessment and I am satisfied that, given the available evidence, uld be it represents a reasonable view of the likely costs, benefits and impact of the leading options. Signed by the responsible Minister: users Signed Jonathan Shaw, Minister for Marine, Landscape and Rural Affairs Date: 26 June 2008 atives he co-

why? hould

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Annex D

Summary: Analysis and Evidence Policy Option: 2 Description: Consult on the operation of the Gangmasters Licensing [Use t (Exclusions) Regulations detail inform ANNUAL COSTS Description and scale of key monetised costs by ‘main affected groups’ preced One-off (Transition) Yrs Amending the Exclusions Regulations will not increase the total cost of the licensing scheme. However as the scheme is expected Purp £ 00 to be self-financing, the licence costs of remaining licence Average Annual Cost holders may need to rise marginally to make good the reduction Back (excluding one-off) in fee income resulting from the exclusions (see para 11).

COSTS £ 25,250 Total Cost (PV) £ 25,250 1. T Other key non-monetised costs by ‘main affected groups’ 0 a In p w ANNUAL BENEFITS Description and scale of key monetised benefits by ‘main H affected groups’ su One-off Yrs Annual benefit represents savings stemming from not c £ 0 needing to obtain a licence and potential administrative d savings to the GLA. There will also be a very minor h Average Annual Benefit administrative saving to former licensees no longer required to (excluding one-off) renew their annual licenses. Ratio £ up to 83,250 Total Benefit (PV) £ up to 83,250 BENEFITS Other key non-monetised benefits by ‘main affected groups’ 2. G T Cons Key Assumptions/Sensitivities/Risks It is assumed that most of any changes made to the Exclusions Regulations will simply regularise the position of businesses, where there is current scope for differing interpretation as to whether Withi a licence is required. It is also assumed that impact on licence fees will be marginal. 3. D Price Base Time Period Net Benefit Range (NPV) NET BENEFIT (NPV Best estimate) D Year 2006 Years £ £ up to 58,000 in

What is the geographic coverage of the policy/option? UK Publi On what date will the policy be implemented? 1 April 2009 Which organisation(s) will enforce the policy? GLA (no change) 4. A What is the total annual cost of enforcement for these organisations? (no change) th Does enforcement comply with Hampton principles? Yes Will implementation go beyond minimum EU requirements? No Cost What is the value of the proposed offsetting measure per year? £ 0 Bene What is the value of changes in greenhouse gas emissions? £ 0 Will the proposal have a significant impact on competition? No 5. T Annual cost (£-£) per organisation Micro Small Medium Large th (excluding one-off) 0 0 0 0 su Are any of these organisations exempt? No No N/A N/A in th Impact on Admin Burdens Baseline (2005 Prices) (Increase – Decrease) th Increase of £ 0 Decrease of £ 0 Net Impact £ 0 li n Key: Annual costs and benefits: Constant Prices

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Annex D

Evidence Base (for summary sheets) [Use this space (with a recommended maximum of 30 pages) to set out the evidence, analysis and detailed narrative from which you have generated your policy options or proposal. Ensure that the information is organised in such a way as to explain clearly the summary information on the preceding pages of this form.] tal cted Purpose and intended effect of the proposal tion Background 1. The Gangmasters Licensing (Exclusions) Regulations 2006 fine-tune the scope of the licensing arrangements by specifying circumstances where a person does not need to obtain a licence. In broad terms the current arrangements have mapped reasonably accurately those areas where providers of gang labour are active, while excluding peripheral labour supply arrangements which do not represent the supply of gang labour or where the risk of exploitation is low. However feedback received from stakeholders since the Regulations were made in 2006, suggests that some refinement may be necessary to slightly widen the range of excluded circumstances and to clarify the terms we have used to define the current exclusions. These are discussed in more detail in the consultation document. http://www.defra.gov.uk/corporate/consult/gangmasters-regs/ to Rationale for Government intervention 2. Government intervention is necessary to amend the scope of the current Exclusions Regulations. This consultation will canvass views on the need to amend the Regulations. Consultation will ther Within Government 3. Defra has obtained the approval of DA Committee to consult on these proposals. The GLA and DARDNI have also been consulted and the Scottish Executive and the Welsh Assembly have been informed of our intention.

Public Consultation 4. A 13 week public consultation runs from 21 July 2008 to 20 October 2008. The responses to that consultation will be analysed after the consultation is complete.

Costs and benefits

Benefits 5. The principal benefit stemming from a relaxation in the terms of the Exclusions Regulations is e that it should provide greater flexibility for farmers engaged in informal agricultural practices, such as the loan of workers to other farmers. Revising the terms of the regulations is also /A intended to provide greater clarity to those labour providers uncertain as to their status under the scheme. This will enable people to carry out their businesses secure in the knowledge that ase) they are acting in accordance with the legislation. Where the new Regulations confirm that a licence is not required there will be a financial benefit in the annual saving to licence holders of not having to renew their licences. This is likely to be limited as few gangmasters are currently

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Annex D

licensed under the circumstances identified in the consultation paper for exclusion from Costs licensing. According to the GLA no farmers have applied to the GLA for a licence in respect of the loan of workers to other farmers and the GLA is not aware of any agencies involved in the 9. It supply of specialist agricultural workers, quasi public organisations and pea vine and sugar beet p co-operatives having applied for a licence. o b 6. It is thought that two registered charities have applied for a licence. However, these charities are significant providers of labour in their own right and it is not the intention of this consultation 10. It to remove their activities from the scope of the scheme. The GLA is also aware that one in gangmaster is licensed in respect of the supply of workers between separate corporate bodies H within the same ownership. b c 7. In the forestry sector there are around 50 gangmasters licensed to supply workers to undertake to forestry work. The exclusion of this sector from licensing would yield savings to the sector in the form of licence fees that no longer have to be paid. However the savings to the GLA in the form Busin of lower costs to process and monitor licences are likely to be limited as licensed labour providers working in forestry represent around only 4% of the total number of labour providers registered 11. T with the GLA. Furthermore in the short term staff costs are fixed and in practical terms the g reduction in workload stemming from the exclusion of forestry is likely to be used in part by the GLA to increase the amount of compliance work it undertakes in the non-forestry sector. In view Cost of this the level of administrative savings stemming from the exclusion is likely to be modest. On 12. It the basis of the GLA’s forecast expenditure in 2008-09 on compliance activities it is estimated e that the savings to the GLA stemming from the removal of the forestry sector will fall within the a range of £0 to £58,000. it 8. A summary of the potential financial benefits is as follows: Sma Activity Number of Value of one-off Value of annual current licence benefit benefit 13. T holders p Change definitions used in paragraph 1 n/a 0 0 E Short-term farmer to farmer loans 0 0 0 Short-term farmer to farmer services 0 0 0 Com Supply of specialist workers 0 0 0 14. T Quasi public organisations and charities 2 0 3500* li Supply between corporate bodies in the same ownership 1 0 1750* th Pea vine and other types of co-operatives 0 0 0 m Forestry industry – licence fees and GLA administrative fo 50 0 20,000-78,000* cost savings Totals 53 0 20,000-83,250 Equa

*based on annual licence fees of £1750 for quasi public organisations and charities, £3500 for supply between 15. T corporate bodies etc and £400 for gangmasters operating in the forestry sector and GLA administrative savings of up to £58,000. Hum 16. T Scot 17. T S

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Annex D

from Costs ect of in the 9. It is not anticipated that this proposal will impose any substantial costs on business. The principal r beet purpose of this proposal is to clarify the term of the Regulations and to remove from the scope of licensing those activities which do not represent gangmaster activity. This proposal will not bring additional gangmasters with the scope of the licensing scheme. es are tation 10. It is possible that the removal of some gangmasters from the scope of licensing could lead to an t one increase in licence fees as the GLA is required to cover its operating costs through fee income. bodies However, it is thought that the fee increase required to cover the loss of fee income is likely to be marginal. On the basis of around 1200 licence holders and the assumption that other GLA costs and revenues remain unchanged, it is estimated that the loss of fee income would need ertake to be recouped by an average fee increase of up to £20. in the e form Business sectors affected viders stered 11. The licence scheme applies to labour providers who supply labour into the agriculture, shellfish ms the gathering and the food, fish and shellfish processing and packaging sectors in the UK. by the n view Cost to Government st. On 12. It is not anticipated that this proposal will impose additional costs on Government. The GLA is mated expected to cover its operating costs through income derived from licensing. Enforcement costs in the and the cost of providing for an appeals mechanism will continue to be met by Government and it is not anticipated that these will change. Small firms impact test nual 13. The gangmaster industry is largely made up of small firms. Therefore small firms will be the principal beneficiary of any proposal to reduce the scope of the licensing scheme by revising the Exclusions Regulations. Competition Assessment 14. The impact of this proposal on competition in the labour provider industry is expected to be limited. It is possible that the exclusion of quasi public bodies could have an adverse impact on the competitiveness of licensed labour providers. However, this impact is likely to be very marginal as the two types of provider operate in largely separate segments of the industry and for different purposes. 000* 250 Equality and Fairness 15. This proposal will not have any impact on under-represented groups. of up Human Rights 16. This proposal does not raise any human rights issues. Scotland, Wales and Northern Ireland 17. The Gangmasters Licensing (Exclusions) Regulations 2006 apply to England, Scotland and Wales. Separate regulations apply to gangmasters operating in Northern Ireland.

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Annex D

Impact on rural communities, environmental impact, sustainable development Use th 18. No impact on rural communities or the environment is anticipated. The proposal will be neutral policy with respect to sustainable development. Ensur Enforcement, sanctions and legal aid withi

19. The Gangmasters (Licensing) Act 2004 established the GLA to operate a licensing scheme for Type o gangmasters and to maintain a register of licensed gangmasters. The principal offences created by the Act are operating as an unlicensed gangmaster, engaging the service of an unlicensed gangmaster and using false documentation. The maximum penalty created by the Act is Comp imprisonment of up to 10 years. There are no recommendations in this proposal to change these Small offences and sanctions and there are no implications for legal aid. Legal Monitoring and Review Sustai Carbo 20. The GLA is required to keep the operation of the licensing regime under review. Other Summary and Recommendation Health 21. This proposal is expected to generate minor financial benefits to the industry and to impose no Race cost on Government. The principal purpose of the proposal is to clarify the operation of the Disab Exclusions Regulations. This proposal does not intend to make fundamental changes to the Gende scope of the licensing scheme. Huma Rural

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Annex D

Specific Impact Tests: Checklist

Use the table below to demonstrate how broadly you have considered the potential impacts of your eutral policy options. Ensure that the results of any tests that impact on the cost-benefit analysis are contained within the main evidence base; other results may be annexed. me for Type of testing undertaken Results in Evidence Results annexed? eated Base? ensed Act is Competition Assessment Yes No these Small Firms Impact Test Yes No Legal Aid Yes No Sustainable Development Yes No Carbon Assessment Yes No Other Environment Yes No Health Impact Assessment Yes No ose no Race Equality Yes No of the Disability Equality Yes No o the Gender Equality Yes No Human Rights Yes No Rural Proofing Yes No

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Annex E

List of consultees: • Abacus and Training •A Services UK Ltd •A • “OSKAR” Agencja Rekrutacyjna • Abbey Forestry •A • 118 Recruitment Ltd • Abbey Personnel Services Limited •A • 1st Call Recruitment Services Ltd • Abbey Recruitment Services Ltd •A • 1st Choice Personnel • Abby Services •A • 1st Choice Recruitment • Abby Services Ltd •A • 1ST Universal Services Limited • ABC Recruitment Services Ltd •A • 247 Staff • ABC Recruitment.net Ltd •A • 2m Recruitment Ltd • Abel Staff Ltd •A • 5 Star Facility Management Limited • Aberdeen University School of Forestry •A • 725 Ltd • Abersenny Ltd •A • 7Y Services Ltd • ABIT Recruitment Ltd •A • A & L Blower • Absolute Recruitment UK Ltd •A • A & M Penman & Sons • AC 1 Recruitment Ltd •A • A & T Active Recruitment Ltd • Accept (Midlands) Ltd •A • A B J Consultancy Service • Access 365 Ltd •A • A D Fisher • Accounting Secretarial and Personnel Ltd •A • A Helping Hand (LLC) UK Limited • Accurate Quality Services Ltd •A • A J Westmore • Ace Appointments Midlands Ltd •A • A K R Services Ltd • Ace Personnel •A • A La Carte Recruitment Ltd • Ace Recruitment (Leeds) Limited •A • A M Workers Ltd • ACE Recruitment (Warrington) Limited •A • A Massie & Son • Ace Recruitment Services •A • A P R Agency • Acer Recruitment Ltd •A • A P S Recruitment Ltd • Acorn Recruitment (South West) Limited •A • A To B Services • Acorn Recruitment Ltd •A • A.S.A.P. (SW) Ltd • Action Contracts East Midlands Ltd •A • A.W. Jenkinson Forest Products • Active Employment Limited •A • A.Z.F (Ireland) Limited • Adam Wilson & Sons Ltd •A • A1 Harvester Limited • Adecco UK Limited •A • A1 Inflight Staff Agency Ltd • ADM Tempforce Ltd •A • A1 Labour • ADS Recruitment Ltd •A • a2z Recruitment Ltd • ADS Recruitment Services Limited •A • A4e Ltd • Adservio Staff Agency Limited •A • Aadept Recruitment Services Ltd • Advale Associates Ltd •A • AAM Staff Ltd • Advance Personnel Limited •A • AAW Contract Services Limited • Advanced Forestry & Garden Services •A • Advantage Recruitment Limited •A • AEP UK LTD •A • Agencja Posrednictwa Pracy Matt-Job •A • Agency 2000 •A

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Annex E

• Agentura Pod Von s.r.o • AOM & Associates • Agentura Venta, s.r.o. • Apollogroup UK Ltd • AGM Recruitment Ltd • Apple Appointments South West Ltd • Agora Recruitment Ltd • Apple Labour Limited • Agrico Workforce Ltd • Apples and Pears Staffing Agency Ltd • Agricultural Labour Services • Aptus Personnel Ltd • Agristaff • Aqumen Recruitment Group Limited • AHW Workforce Ltd • Arbor Vitae • Aims Recruitment Ltd • Arboricultural Association • AJ Blatch Trading as • Arboricultural Association y • AKL LTD • Arboriculture & Forestry Advisory Group • Alan Findlay Ltd • Arbre Energy Ltd • Alan Firmin Limited • ARC Woodlands Ltd • Alba Trees Plc • Archshire Ltd • Alban Personnel Ltd • Ardent Industrial Recruitment Ltd • Albion Services Limited • Ardworkers Agency Limited • Alexander Henderson (Forestry) • Armour Recruitment Ltd Ltd • Alexander Sawmills • Arsara Ltd • Alison Wheeler Associates • AS Rodgers (Kirton) Ltd • All Aspects Labour • ASA International Ltd • All Staff Solutions (UK) Limited • ASAP Recruitment (UK) Limited • Allan Field Workers • ASC Connections (Holdings Limited) d • Alliance Personnel Ltd • Ashcroft Employment Services Ltd • Allied Staff Managment Ltd • Askham Bryan College • Allround Recruitment Solutions Ltd • Aspect Forestry & Rural Management ted • All-Temps Recruitment Limited • Aspen Forestry Limited • Alpha Facilities Management Limited • Aspen Forestry Services • Alternative Woodland Management • Aspire Group • AM2PM Recruitment Solutions Ltd • Associated Employment Services Ltd • Ambitions Personnel Ltd • Association of Bakery Ingredient • AMS Services UK Limited Manufacturers • Andrew Bronwin & Co Ltd • Association of Cereal Food Manufacturers • Andrew Millar Contracts (ACFM) • Andy Stewart (Forest & Estate Services) Ltd • Association of Labour Providers • Angel Human Resources PLC • Association of Landscape Management • Anglian Woodland Project • Association of National Parks Officers • Angus Growers Ltd • Association of Scottish Hardwood Sawmillers • Angus Macdougall • Aston Services Uk Ltd • Animal Aids Ltd • ATJ Industrial Services Limited • Anne Hemphill Resources Ltd • Atlanco Limited • Any Service Bureau Limited • Atlas Industrial Support Limited • Anystaff Recruitment Limited

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Annex E

• ATSL Limited • BERWYN LEWIS EDWARDS •B • Aulina Consulting LTD • Bidwells •B • Aven Ltd • Bio Forest Consultancy •B • Avi Shnapp Tree Planting • BioRegional Development Group •B • Aviation Logistical Services Limited • Birches Consultancy •B • Aviserv Ltd • Biznus Solutions Limited •B • Avon Wildlife Trust • Blue Arrow Ltd •B • Aztec Recruitment Ltd • Blue Mountain Recruitment Ltd •C • B & L Recruitment Ltd • Blue Water Shellfish Suppliers UK Limited •C • B.J. Unwin Forestry Consultancy • Bond Personnel Limited •C • Backup Staff Limited • Bonser Recruitment Services Limited •C • Bailey Employment Services Ltd • Bookright Employment Ltd •C • Baileys Recruitment Agency Ltd • Border Consultants (Forestry) Ltd •C • Bailie and Bailie Limited • Borders Area Services Ltd •C • Bain Employment Services Ltd • Borders College •C • Baker Harding Recruitment • Borders Roguing Limited •C • Balcas Timber Ltd • BOS Recruitment •C • Baltic Services • Bosky Trees Ltd •C • Barker And Exley Ltd • Bowlts’ Chartered Surveyors •C • Barker and Pugh Ltd • Brae Scotland Ltd •C • Barker Estate Management Ltd • Braymale T/A NWES Recruitment •C • Barker Ross Ltd • Brecknock Wildlife Trust •C • Barkley Employment Limited • Bridge Contract Services •C • Barmine Ltd • Brightwork Ltd •C • Barony College • Britannia Recruitment Ltd •C • Barrow & Grundy (UK) Ltd • Brithgwm Woodlands •C • Barry Kilmore • British and Irish Hardwoods Improvement •C • Barway Services Ltd Programme •c • Bawnless Recruitment Ltd • British Assocation of Landscape Industries •C • Baxter Personnel Ltd • British Christmas Tree Growers Association •C • Be Personnel Ltd • British Meat Processors Association •C • Beam (Wales) Ltd • British Oat & Barley Millers Association (N • Bearwood Associates Ltd • British Poultry Council •C • Beaulieu Contracting • British Retail Consortium •C • Beaver Management Services Limited • British Sandwich Association •C • Bede Howell Chartered Forester • British Soft Drinks Association •C • Bell Ingram • British Starch Industry Association •C • Bennett Secretarial Services Ltd • British Trust for Conservation Volunteers •C • Department for Business, Enterprise and • Brook Street UK Limited •C Regulatory Reform • Brooker Farms •C • Berry Recruitment Limited • Brooklands Staff Bureau Ltd •C • Berrys • Bryan Massie Woodland Management Ltd •C

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Annex E

• Bryden Shellfish • Chilled Food Association • BSG Recruitment Agency • Choice Recruitment Limited • BSW Timber • Church Action on Poverty • Bucknell Nurseries • Churches Together in Cumbria • Building Business Bridges Ltd • CIP Recruitment Ltd • Bushley Ltd • City Centre Staff Bureau Ltd • Butchery Solutions Ltd • CJH Farms Limited • C & H Agency • CK Recruitment Specialists Limited ited • C B Recruitment Services Ltd • CKD Galbraith • C E F Recruitment • Claire Gibson and Associates Ltd • C Southerby Poultry Services • Clarkes of Bowley • C.R.B. RECRUITMENT • Class 1 Staff Services • Cairngorm Forestry and Conservation • Classic UK Services Ltd • Caledonian Pine Protection • Claydens Agriculture Contractors and • Cambridgeshire County Council Factory Operatives • Campaign to Protect Rural England • Clinton Devon Estates • Campbell & Co Foresters • Cloud 9 Associates Ltd • Capital Recruitment Services • Cluttons • Carleton Recruitment Solutions Ltd • CMD Recruitment Ltd • Carlton Business Services Ltd • CMV Recruitment Ltd • Cartwright Employment • CNS Recruitment Limited • Caspers Agency Ltd • Cock of the North Ltd • Castle Personnel (Norfolk) Limited • Coed Cadw – The Woodland Trust • Catchwright Poultry Ltd • Coed Cymru – Monmouthshire • Cawdor Forestry County Council • Cawdor Forestry Ltd • Coed Cymru, Isle of Anglesey County Council ment • CC Contractors Ltd • Coleg Llysfasi College • ccms (2000) ltd • Colin Hay tries • Celtic 2000 • Commission for Racial Equality ation • Celtic Countryside Services • Community Forest Secretariat • Central n (North East) Ltd • Community Forest Secretariat • Century Services (UK) Ltd • Community Woodlands Association • CGS Recruitment Agency Ltd • Complete Recruitment (UK) Ltd • Champion Employment Limited • Complete Recruitment Solutions Ltd • Charlie Fulton Woodland Services • Concept Recruitment Solutions Limited • Charlton Abbotts Forestry Ltd • Concept Staffing Ltd ers • Charnwood Harley Limited • Concordia Y S V Ltd • CIPD • Confederation of Forest Industries • Chartley Personnel Limited • Confederation of Paper Industries • Chase Associates Ltd • ConFor t Ltd • Chelmont Labour Supplies Limited • Conik Solutions Limited

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Annex E

• Connect Personnel Ltd • D&V Labour Services Limited •D • Conrac Limited • Daniyal Private Limited •D • Consistent Factory Staff Limited • Daranden Ltd •D • Consulting C N • Department of Agriculture and Rural •D • Contact Industrial Recruitment Ltd Development Northern Ireland •D • Contract Options • Darius Binderis •D • Contract Packers LTD • Darren Harwood Agricultural Services •D • Contract Personnel Limited • Dartmoor National Park Authority •D • Contract Support Services Ltd • Databail T/A CSA Recruitment •D • Conwy Energy Agency • David Bell Forestry •D • Cooper Lomaz Recruitment Limited • David Goss & Associates •D • Coppice Association • David Mackie; Forestry Contracting & •D • Coppice Association Advice •D • Cora Recruitment Ltd • David Nichol Forestry & Landscaping •D • Corepeople Recruitment Ltd • David Rice Forestry •D • Council for National Parks • Davida Limited •D • Country Land & Business Association • DC Recruitment Ltd •D • Country Land and Business Association • DDL Recruitment Ltd •E • Countryside Consultants Ltd • DE & MA Morgans Ltd •E • Cover Recruitment Limited • Dedicated Employment Services Ltd •E • Coyle Personnel • Deepmist Limited •E • Crest Recruitment Services Limited • Defence Estates •E • Creyf’s (UK) Limited • Defra •E • Cropcut Produce • Delton Birmingham Ltd •E • Crown Estate • Deluxe Services Limited •E • Crownwell Recruitment Kent Limited • Denbighshire County Council •E • Crowther and Johnstone Ltd • Design Recruitment Associates Limited •E • CSC Forest Products (Sterling) Ltd • DG Produce Ltd •E • CTS Recruitment Ltd • DGA Forestry •E • Cumbria Wildlife Trust • Dial-A-Worker Ltd •E • Cumbria Woodlands • Diamond Recruitment •E • Curzon Place Recruitment Ltd • Direct Labourer Limited •E • Cutland Contractors • Direct Recruitment (NE) Ltd •E • CV Staff Services Limited • Direct Response Employment Services •E • Cymru Recruitment Ltd • Direct Staff Construction Limited •E • D & C Labour Supplies Ltd • Direct Staff Uk •E • D & K Recruitment • Direct Staff Uk Ltd •E • D & T Staff Solutions • Direct Workforce Ltd •E • D 1 Labour Services Limited • Distribution Support Limited •E • D A Wardell Forestry Establishment • DJ Houghton Catching Services Limited •E Contractor • DJP Poultry Handling Services Limited •E • D Marshall Recruits • DKM Labour Solutions Limited •E

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Annex E

• DL & LE Davis • Empire World Trade • Draefern Limited • Employ EURO LTD • DRAIG PERSONNEL LTD • Employment Of London Limited • Drake Personnel Ltd • Encore Personnel Services Limited • Driffield Poultry Handling Service • Engage Appointments Limited • Drive Rite Support Services Ltd • English Heritage • Driver Hire Group Services Ltd • English National Park Authorities’ • Driverline (GB) Limited Association • Driving Edge Ltd • Enterprise Personnel Ltd • DSL Workforce • Environment Systems • DTB Recruitment Ltd • Environmental Advice Centre Ltd • Ducas Ltd • Environmental and Landscape • Duchy of Cornwall Management Services • Duncan Matthews Forestry Contractor • Epton Employment Services Limited • Dundee Employment and Aftercare Project • Equality People Limited • Department for Work and • Eric Boyd Forestry Limited • Dysons Poultry Services • Eric Boyd Forestry Ltd • E Campbell Forestry & Agricultural Services • Stanley Duncan & Son • E+R Solutions Ltd • ES Recruitment Ltd • Eamonn Wall & Co. • Esprit People Ltd • East Lancashire Services Ltd • ESS Employment Limited • East Northern Services • Essential Recruitment & Personnel Limited • East To West Recruitment Limited • EST Employment Services • Eastern Sea Fisheries Joint Committee • Estate Employment Ltd • Eastwood Forest Services Ltd • ETCI Ltd • Easyjob (UK) Ltd • Ethan Labour Force Limited d • Echo Personnel Ltd • EU Evolution Limited • Eco Tech Ecological Consultancy • Euresource Limited • Ecolcogical Tree and Woodland Services • Euro Contracts Services Limited • EcoSylva • Euro Labour (Boston) Limited • Edinburgh University School of Forestry • Euro Link Schemes (UK) Limited • Edistone Ltd • Euro Resources Ltd • EDS Recruitment Ltd • Eurofest Ltd • Effective Contracts Limited • Euroforest • EGGER (UK) Limited • Eurokraft • Egger (UK) Ltd • Europa Personnel Limited • EI John Services • European Operatives Limited • ELL Recruitment Limited • Europeople Limited • Elmwood College • Euroployment Ltd ed • ELS Recruitment Ltd • Eurostaff • EMP Solutions Ltd • Eurostaffing Ltd • EMP Solutions Ltd • Everyday Recruitment Agency Ltd

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Annex E

• Evolution Personnel Limited • First In Hospitality •F • EWOS Recruitment Limited • First people Recruitment Ltd •F • ExCAL Ltd • First Recruitment Ltd •F • Exchange People Ltd • First Recruitment UK Ltd •F • Express Staff Limited • Five Star Deployment Limited •F • Extra Force Staffing Limited • Five Star Recruitment •F • Extra Personnel Group Limited • Flame Employment (Industrial Ltd) •F • Extraman Ltd • Flare Recruitment Ltd •F • Extrastaff Limited • Flat Cap Forestry Limited A • F E Woodlands • Flex Employment •F • Faccenda Ltd • Flex Recruitment Limited •F • Fairtree Farm • Flexible Employment Agency •F • Fairview Poultry Services • Flintshire Cockles •F • Farm & Countryside Liaison Services • Flintshire Woodlands Ltd •F • Farm Force • Flowers Plus •F • Farm Relief Services Ltd • Focus Staffing Solutions Limited •F • Farm Services • Food and Drink Federation •F • Farmer to Farmer • Forde Recruitment ltd •F • Farmers’ Union of Wales • Fordside Ltd •FW • Farming & Wildlife Advisory Group • Forest Enterprise •Fy • Farming & Wildlife Advisory Group, • Forest Fact •G FWAG Cymru • Forest Garden •G • Farming and Wildlife Advisory Group • Forest House Partnership •G • Fast Lane Personnel Limited • Forest of Avon •G • Fast Track Recruitment (London) Ltd • Forest of Bowland AONB •G • Fasttrack Personnel Limited • Forest of Cardiff Ltd/Treescene Ltd •G • FBS Woodland Solutions Ltd • Forest of Marston Vale •G • Forestry Commission • Forest of Mercia •G • Federation of Bakers • Forester and Arborist Services •G • Federation of Small Businesses • Forestry Business Services (UK) Ltd •G • FFR Ltd • Forestry Commission Wales •G • Field Force GB • Forestry Contractors Association •G • Field Studies Council • Forestry Services Ltd •G • Fieldwork • Forscot Limited •G • Firefox Resources Ltd • Forward Recruitment •G • First 4 Labour Limited • Fountain Forestry •G • First Call Contract Services Limited • Fountain Forestry Ltd •G • First Choice Recruitment • Fountain Forestry Plc •G • First Choice Selection Services Limited • Fountains Contracting Ltd •G • First Contact (SW) Ltd • Fountains Plc •G • First Food Services Limited • Fox Resourcing Ltd •G • First Impression Recruitment Ltd • Foxwell Ltd •g

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Annex E

• FP Contracts Limited • Georgian Recruitment Services Limited • Fred Bassett & Son • G-Force Employment Services LTD • Fresh Produce Consortium • Gill Cooke Personnel Ltd • Fresh Start Recruitment (UK) Ltd • Global Temps Ltd • Friday Bridge International Farm Camp Ltd • Globus Services (UK) Limited • Friends of the Lake District • Glyn Lloyd Forestry Contractor • Frontline Recruitment Ltd • GMB • Frozen & Chilled Potato Processors’ • Gold Recruitment Limited Association • Golden Transfer Personnel • Fruitful Ltd • Goldline Express Limited • FSC Enterprises • Goldstock Poultry Services • Furlong Forest Surveys • Goldteam Recruitment Limited • Fusion Personnel Ltd • Goose Recruit Ltd • Fusion Recruitment Services Ltd • Gordon MacFarlane Ltd • Fusion Resources Ltd • Gospodarka Lesna, Szkolkarstwo Lesne, • Future Forests Sprzedaz Detaliczna • Futures Recruitment Services • Gourmet Personnel Limited • Futurestep Resources Limited • Grafton Recruitment Ltd • FWAG Cymru • Grant Caswell Forestry • Fyfe Forestry • Grapevine Corporate Limited • G A Lloyd • Gravity Personnel • G L Labour • Great North Forest • G M Contracts • Great Western Community Forest • G M Recruitment Agency Ltd • Green Park Consultants Limited • G M’s (Slough) Ltd Oddzial W Polsce • G P Recruitment Ltd • Green Wood Centre • G Valued Ltd • Greenland Contractors • G.A.P. Recruitment • Greenwood Community Forest • G.R.Mckenna • Griffin Recruitment Limited • GA Recruitment Limited • Griffiths Forestry Associates Ltd • Galaxy Personnel Ltd • Groundwork • Gallagher Contracts • Growing Heart Workers Co-operative • Galloway Forest Conservation • Gurkha’s UK Limited (the) • Gap Personnel Holdings Limited • Gwenyn A Choed • Gateway Recruitment Services • Gypsey Employment Agency Ltd • GB Resourcing (UK) LTD • H A Snell & Sons • GD(2000) LTD • H C Recruitment Ltd • Geest Bourne Salads • H.S.H Agriculture Contractors • Geest Dips & Dressings (Main Site) • H2 Contracts Ltd • Gemini Resourcing (UK) Ltd • Habitat Matters Ltd • Genesis Supply Solutions • Habitat Practice • geoff stone forestry ltd • Hades Limited

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Annex E

• Hammond Forestry & Arboriculture • HR GO Nottingham Ltd •In • Hans Personnel Ltd • HR Go Sandwell Ltd •In • HAP Recruitment Agency Ltd • HR Go Wells Ltd •In • Hardcastle Associates Ltd • HR Partners Limited •In • Harris Brothers (Bromyard) Ltd • HR Services •In • Hastings & Co • HRGO (Great Yarmouth) Limited •In • Haven Employment & Training Limited • HRGO Newcastle Ltd •In • Hawkeswood Ecology • HRGO Norwich LTD •In • Hayes Staff Recruitment Limited • HRGO Preston •In • Heads Recruitment Limited • HRGO Stockport Limited •IN • Health Food Manufacturers’ Association • HS Recruitment Ltd •IN • Helping Hand Asset Management Limited • Health & Safety Executive •In • He-Man Personnel • Hugh McGregor •In • Heta S V • Hugh Wheeldon & Co •IN • Hexagon Recruitment Services Ltd • Human Factor Solutions Limited E • High Class Recruitment Limited • Hunsley Conservation •In • Highfield Forestry Ltd • Hunter Skill Recruitment Ltd •In • Highland Agricultural Labour • Hunters Solutions Ltd •IW Services Limited • Hutton Landscape & Forestry Services •J • Highland Birchwoods • I & P Management Services Limited •J • Highland Employment Services Limited • Ian Smith Agricultural Contractor •J • Highland Forestry Services Ltd • ICDS recruitment (UK) Ltd •J • Hire Staff 4 U Ltd • Ice Cream Alliance •J • HMRC • Ice Cream Federation C • Holecroft Ltd • Icon Personnel Soultions Ltd •J • Home Office • Ideal Ventures Limited •J • Hope International Recruitment • International Exchange Programme UK Ltd •J Services Limited • Iggesund Paperboard Ltd •J • HOPS Labour Solutions part of NFYFC • IJ Labour •J • Horizon Recruitment plc • Impact Labour Limited •J • Horticultural Trades Association • Impact Personnel Solutions Limited •J • Howes Percival Ltd • Impact Recruitment Ltd •J • Howie Forest Products • Imperial-Agenja Posrednictwa i Uslug •J • HR Consultancy Bartosz Chojnacki •J • HR Essentials Ltd • Improva Ltd •J • HR Go (Bishop’s Stortford) Ltd • Inca Recruitment Ltd •J. • HR GO (Crawley) Ltd • Independent •Ja • HR GO (Doncaster) Ltd • Industria Personnel Services Ltd •Ja • HR Go (Havant) Ltd • Industrial Staffing Solutions Ltd •Ja • HR GO (Kent) Ltd • Industrial Temps Ltd •Ja • HR Go (Liverpool) Ltd • Industry Resource Services Ltd •JA • HR GO Northampton Limited • Infant and Dietetic Food Association •Ja

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Annex E

• Infinity HR Limited • Javelin Recruitment Ltd • Insight Consulting • Jayko • Institute of Chartered Foresters • Jigsaw Recruitment Limited • Institute of Occupational Safety and Health • Jigsaw Staff Recruitment S W Ltd • Institute of Water and Environment • Job Done (Leeds) Ltd • Insurgo Consulting Limited • Job Link (Soham) Ltd • Integrity Plus Ltd • Job Shop Recruitment Services SW Ltd • Inter Continental Labour Ltd • Jobcorp Ltd • Interaction Recruitment PLC • 4 E U Ltd • INTERecruit (GB) LTD • Jobsearch North West Limited • INTERecruit (uk) LTD • Joe Carter Limited • Interim Recruitment Ltd • John Clegg Consulting Ltd • Interlet Limited • John Lee Packing Services • INTERNATIONAL AGRICULTURAL • Johnston Accounting Services EXCHANGE ASSOCIATION • Jonas Handling Limited • International Recruitment Centre • Jones and Jones • International Tree Foundation • Jones Peckover • IWONA Services Ltd • JP Day t/a Harpur Contract Recruitment • J & R Forestry Services • JP Recruitment Ltd • J Cordiner & Son Ltd • JPM Labour Services Ltd • J E & C Swift (Treework) • JR & JD Smith • J E Bain • JSD Recruitment Services Ltd • J E Jones Forestry and Agricultural • JT Recruit Limited Contractor • Just Ecology • J E T and S L George • JW Associates • J Johnstone Forestry Contractor • K & L Poultry Services Limited K Ltd • J K Employement • K & M McCabe • J Kirkwood • K T 1 Labour Recruitment Ltd • J Lloyd • K2 Recruitment Ltd • J P Services • KAB Labour • J Pilawski – Revolution Nursery Contractors • Katie Rawlinson • J S C “Pasaulio Krastas” • KBM Foodstaff Ltd • J S Morris Agricultural Contractors • Kea Trading Ltd • J T Industrial Services Ltd • Keith Grimes Ltd •J Ward • Kelly Services (UK) Limited • J.T. Friskney Ltd • Kent Gurkha Company Ltd • Jadepark Industrial Limited • Kent Recruitment Limited • James Callander & Son Limited • Kent Staff Services 2000 Limited • James Jones & Sons Ltd • Kernow Labour Ltd • Jann UK Limited • Kernow Recruitment (Launceston) Ltd • JARK Recruitment Ltd • Kettle Ltd • Jasper Corporation Ltd • Kettle Produce Ltd

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Annex E

• Kevin Doughty • Lantra Landscape •M • Kevin Harrold Contracts Ltd • Lauras Gang •M • Key Appointments North West Ltd • Laurent Bienfait Harvesting •M • Key Recruitment Ltd • Lawlor & Associates Recruitment Limited •M • Keyo Agricultural Services Ltd • Linking Environment and Farming (LEAF) •M • KHS Personnel Ltd • Leda & Co (Northern) LTD •M • Kiloforce Ltd • Lee Hill Contracting •M • Kinetic plc • Leisure Recruit Ltd •M • Kingfisher Seafoods Limited • Liam Stuart •M • Kingston Facilities Management Ltd • Libra Recruitment Agency Limited •M • Kirton Agricultural Services Limited • Lightyear Recruitment (Wigan) Ltd •M • Kirton Labour Supply Ltd • Lincolnshire Labour Ltd •M • Knipe Contracts Ltd • Lincolnshire Machinery Ring Ltd •M • Kool Runnin Ltd • Lincolnshire Staff Services •M • KPJ Design & Draughting Ltd • Linear Recruitment Ltd •M • Kristinos Mazeikienes firma • Link Recruitment •M • Kwik Corporation Limited • Linklife Limited •M • L & G Forestry • Link-up U K Ltd •M • L A Union Limited • Linx Labour Ltd •M • L Bienfait Harvesting • Liquid Recruitment LTD (M • L F UK Recruitment Services Ltd • List Recruitment (Midlands) Ltd •M • L S Recruitment • LKL Relief Services Ltd •M • La Gente Recruitment Ltd • Llanelli Shellfish 3000 Limited •M • LABAS Recruitment • LMR Services Ltd •M • Labour Direct • Local Authority of Coordinators of •M • Regulatory Services •M • Labour Ready Temporary Services UK Ltd • Local Government Association •M • Labour Relief Ltd • Loch Ness Tree Planters •M • Labour Source Limited • Lockhart Garratt Ltd •M • Labourforce • Logistics and Manufacturing •M • Labourforce Solutions Ltd Recruitment Limited •M • Labourpool UK Limited • LOL Contracts Ltd •M • Lake District National Park Authority • London Staff Bureau Ltd •M • Lamyman Grange Contractors • Longley Limited •M • Land Access and Recreation Association • Lonsdale Forestry Ltd. •M (LARA) • Louise Hewett Recruitment Ltd •M • Land Management Solutions Limited • Lovelace Recruitment Limited •M • Land Restoration Trust • Lowther Forestry Group Ltd •M • Land Use Consultants • LSJ Agencja Pracy sp. z o.o. •M • Langham Recruitment (UK) Ltd • LSN Services Ltd •M • Lanos Ltd • Lukas Labour Agency •M • LANTRA • Lusostaff Ltd •M

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Annex E

• M & M Agri Staff • McCartneys LLP • M & M Farm Services • MCK Labour • M A S Recruitment • MCN Recruitment Ltd. ted • M C Personnel Limited • MDR Staffing Ltd AF) • M C Services Leicester Limited • Mearns & Angus Services Ltd • M G & J A Vines • Meat and Livestock Commission • M I Johnson Ltd • Melrose Forestry • M J Hague (Extrastaff) Ltd • Melville Agricultural Contractors Limited • M K Personnel Solutions Ltd • Melville Contractors Limited • M M Agriculture Contractors • Mencap • M M Fencing Limited • Mercury Personnel Solutions Ltd • M MacPherson Contractor • Meridian Business Support Limited • M P A Recruitment • Mersey Forest • M S Agricultural Services Ltd • Meyer Scott Recruitment • M Smith Agricultural Labour Services • MHS Labour Services • M&M Workforce Limited • Michael Todd Forestry Contracts • M. K. Distributers Limited • Midland Labour Supplies Limited • M.F. Warman • Miles Recruitment Limited • Macaulay Land Use Research Institute • Miller Land Management (MLURI) • Moat Recruitment Ltd • Mach Ltd • Monitor Hygiene Services Ltd • Magian Ltd • Monitor Services Ltd • Mainline Employment Ltd • Montgomeryshire Wildlife Trust • Major Recruitment Ltd • Moore & Burrell Ltd • Malcolm McLarty Forestry Contractor • Moss Staffing Ltd • MAM Contracting Ltd • Mostyn Estates Ltd • Management Recruitment Consultants • Mountains of Boston Ltd. • Manpower UK Ltd • MPC CZ Ltd • March Recruitment Bureau Limited • MPES Labour Agency • Marches Woodland Initiative • Mploy Staffing Solutions Ltd • Marcus Cowling Labour Services Ltd. • Mr Desmond Lee Patterson • Margaret Hodge Recruitment Ltd • MTrec Ltd • Margarine and Spreads Association • Mushroom Growers Association • Maria Recruitment Solutions Limited • MWB Recruitment Ltd • Mark Lawton Ltd • Mynydd Timber Service Ltd • Mark Skipworth Agricultural Contractor • N & A Ammar • Marton Recruitment Limited • N Hall-Gardiner Forestry Services • Maureen Lynn Recruitment Ltd • N V Gang Work • Maximum Recruitment Agency • N&W Mack Ltd • Maxwell Bruce Ltd • Napier Recruitment Ltd • Mayday Employment Limited • NAS Recruitment Services (Scotland) Ltd • Mayfair Recruitment Bureau Limited

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Annex E

• National Association of Agricultural • Northmoor Trust •P Contractors • Nova Recruitment Services Ltd •P • National Association of British & Irish Millers • Nu-Staff Group Limited •P • National Association of Citizens Advice • K Private Enterprise Limited •P Bureau • Oasis Recruitment Group Ltd •P • National Association of Master Bakers • Octavian Recruitment Ltd •P • National Association of Tree Officers • Olympic Staff R • National Farmers Union • Omega Resource Group Ltd •P • National Farmers Union of Scotland • On-Call Recruitment Limited •P • National Forest Company • One Call Recruitment Ltd •P • National Pig Association • One on One Recruitment Ltd •P • National School of Forestry • Online Personnel Solutions Ltd •P • National Urban Forestry Unit • Opiecare Services Limited •P • ND Crowhurst Transport Limited • Opus Agencies Ltd •P • NE Tree Company • Orbital Recruitment (Derby) Limited •P • NE Woodlands • Organic Food Federation •P • Neaves & Neat Employment Services Ltd • Origin Associates Ltd •P • New Beginnings Corby Ltd • Orion Engineering Services Limited •P • New European Staff .com • Orkney Business Ring – Labour Agency Ltd •P • New Farm Produce • Orton Park Recruitment Services •P • New Farm Produce Ltd • Osmond Coote Martin Ltd •P • New Personnel Network • OSR Recruitment Services •P • Newtex Ltd • Osrodek Pozaszkolnej Nauki Jezykow •P • Newtex UK Limited Obcych, Usl. Lingwistycznych •P • Newton Employment Limited • OTTO Work Force Limited •P • Next Step Recruitment Ltd • Owen Payne Recruitment Services Ltd •P • Nexus Personnel Ltd • OZ Recruitment •P • NFU of Wales • P & L C Fendyke •P • NFU Scotland • P & M Groundworks Limited •P • Nick Okseniuk • P A G Recruitment Ltd •P • Nicks Recruitment Services Ltd • P C Jackson •P • Norbord Ltd • P G Agricultural Ltd •P • North & South Recruitment Limited • P H U Norbik •P • North East Community Forests • P K R Contract Services •P • North East Workforce Ltd • P M R Direct Ltd •P • North Highland Forest Trust • P S Employment •P • North Kesteven Agricultural Services • P. J. Massam Agricultural Services •P • North Western & North Wales Sea • P. Wood Catching Services Ltd •P Fisheries Committee • P.D.S. •P • North York Moors National Park Authority • Paisley Secretarial Services •P • Northern Employment Services Limited • Paradise Solutions Ltd •P • Northern Recruitment Group PLC • Paramount Personnel Limited •P

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Annex E

• Paramount Recruitment (Wales) Ltd • Polana sp. z o.o. • Parc Newydd • Poleposition Recruitment UK Limited • Paris Services Limited • Police Superintendents Association • Park Royal Workforce Limited • Polish Connection Limited • Parkhouse Personnel Limited • Polish Workforce (UK) limited • Partners Employment European • Polished Multitask Agency Ltd Recruitment Ltd • Pol-UK Recruitment Ltd. • Partners Employment Services Limited • Poplar Tree Company • Pat McSorley Forestry Contractor • Positive Solutions Recruitment • Patrick Frazer & Son Ltd • Postmodern Recruitment • PCS (Campden Ltd) • Poul’s Gang • Pembrokeshire Coast NPA • Poultry Catchers Ltd • Pendle Personnel Limited • Poultry Division Ltd • Penrose Personnel Ltd • Poultry Handling Services ltd • People Direct • Poultry Services Limited • People People Recruitment • Powerforce Contract Support Services Ltd • People Plus Recruitment Limited • Powerstaff Recruitment Limited • Peopleforwork Limited • Powys County Council y Ltd • Perinet Limited • Premier Employment Ltd • Limited • Premier Network Resources Limited • Personnel In Europe • Premier Placement Services Limited • Personnel Plus Recruitment Limited • Premier Recruitment Ltd • Personnel Selection Associates Limited • Premier Recruitment Solutions • Pertemps Recruitment Partnership Ltd • Premier Work Support • Pertemps Scotland Limited • Premiere Employment Group Limited • Pertemps South West • Premium People Ltd • Pet Food Manufacturers Association • Pre-packed Flour Association • Peter Smith Recruitment Limited • Prepared Fish Products Association • Philip Ferguson MRICS • Prestige Recruitment Ltd • Phoenix Property (Scotland) Ltd • Prestige Recruitment Specialists Ltd • Piccadilly Workforce Limited • Prestons of Sleaford Ltd • Pilot Sp. z o.o. • Pride Management Service Limited • Pinkmead Farm • Prime Appointments Ltd • Piper Associates Ltd • Prime Staff Services Limited • Piper X Limited • Prime Time Recruitment Limited • PJL Recruitment • Primeval Ltd • Place Them • Pro Driver Services Ltd • Plain Recruitment Limited • Pro Personnel • Plas Muriau Woodlands • Proactive Personnel (West Midlands) Ltd. • Plus One Personnel Ltd • Proactive Personnel Ltd. • PMP Recruitment • Proactive Recruitment Ltd • Point Professional Recruitment Ltd • Processed Vegetable Growers Association

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Annex E

• Prochoice Recruitment Limited • Reaction Employment Ltd. •R • Production Line Recruitment Agency Ltd • Real Recruitment Partnership Ltd •R • Profile (SE) Ltd • REC •R • Pro-Force Ltd • Recroot Ltd •R • Project Scotland Volunteers • Recruit Employment Services •R • Pryor & Rickett Silviculture Ltd • Recruit Solutions (UK) Ltd •R • PTE UK Limited • Recruiting Solutions (East Midlands) Ltd •R • Pure Recruitment Solutions • Recruitment Holdings Limited •R • QAS Copak Ltd • Recruitment Prospects Limited •R • QLS Management Ltd • Recruitment Solutions (South West) Ltd •R • QTR Services Ltd. • Recruitment Solutions Wales Ltd •R • Quality Contract Personnel Ltd. • Recruitment South West Ltd •R • Quality Personnel Ltd • Recruitmentfinder Limited •R • Qualitycourse Limited • Red Berry Recruitment Ltd •R • Qubic Recruitment Solutions Ltd • Red Eagle Ltd •R • Quest Employment Ltd • Red Recruitment 24/7 Ltd •R • Quick Recruitment Ltd • Red Rock Forestry •R • R & I Limited • Red Rock On Site Services L L P •R • R & J M Place LTD • Red Rose Community Forest •R • R E Personnel Limited • Redwood Resources Limited •R • R H & D H Allan • Reed Employment •R • R N Agricultural Services Ltd • Rees Richards and Partners •R • R P Employment Agency Ltd Chartered Surveyors •R • R S Landscaping Ltd • Reforesting Scotland •R • R S Recruitment Limited • Reids Poultry Transport Limited •R • R Saunders Forestry Contractor • Relay (holdings) Ltd in • R&G Services Ltd • Relay Recruitment Group Ltd •R • Radnorshire Wildlife Trust • Reliance Employment Ltd •R • Ramsak Ltd • Remploy •S • Ramsgate Consultants Ltd • Renavatio Limited •S • Randstad Employment Bureau Limited • Resolve Interim Solutions Limited •S • Rania Farm Services Limited • Response Personnel Limited •S • Rapid Employment and Recruitment Ltd • Response Recruitment Ltd •S • Rapid Personnel Ltd • RFC Recruitment Solutions Ltd •S • Rapid Recruit Ltd • Riada Recruitment Ltd. •S • Rapier Recruitment Ltd • Riccadonna Produce •S • Ray Turner Labour Ltd • Rice Association •S • Rayment Recruitment Ltd • Right Direction (UK) Ltd in • Raymond-Barker & Co • Right Recruitment UK Limited •S • RDT Woodlands East Ltd • Right Staff •S • React Recruitment Ltd • Right4staff Ltd •S • React Staffing Agency • Rightspec Recruitment Ltd •S

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Annex E

• Rimec Contracting Ltd • S.A.M. Recruitment Limited • Ringlink (Scotland) Ltd • SAC (Scottish Agricultural College) • Ringlink (Scotland) Ltd • Salamandra Ture Ltd • Rise Scotland Ltd • Sales Staff Uk Ltd • Riverside Recruitment Ltd • Salt Manufacturers Association • Riverside Recruitment(UK) Ltd • Samclean Services Ltd td • RJ Recruitment Services Limited • SAOS Ltd • Roadhogs • Saph-Hire Agency Ltd • Rob Marsh Woodland Services • Saphire Lee td • Robert Dare (forestry) • Saphire Trading Ltd • Robert McCrindle (Forestry Contractor) • SASTAK • Roberto Mac Ltd • Sastak Services Ltd • Rolfe Resources Ltd • Satchwell Associates Limited • Rosegar Limited • Savills • Rotherwood Recruitment LLP • Saviour Recruitment Ltd • Royal Agricultural College • Sayer-Martin Ltd • Royal Institute of Chartered Surveyors • SC Good Work Solutions SRL • Royal Scottish Forestry Society (RSFS) • SC Lanerock Corporate S R L • Royal Society for the Protection of Birds • Scantec Personnel Ltd • RSS (Wessex) Ltd • Scott Murdoch Arran Footpaths • RTS Ltd • Scottish Agricultural Organisation Society • Rullion Personnel Services Limited • Scottish Bedding Plant Association • Rural Development Initiatives • Scottish Food and Drink Federation • Rural Devleopment Services Ltd • Scottish Machinery Ring Association • Rural Group of Churches Together • Scottish School of Forestry in England • Scottish Seafood Processors Federation • Rutledge Recruitment and Training Ltd • Scottish Woodlands • Ryan Ltd • Scottish Woodlands Ltd • S & A Poultry’s • Sea Fish Industry Authority • S & A Produce (UK) Ltd • Seafood Shetland • S & J McCurry Limited • Sean Fletcher Forestry Contractor • S A Poultry Services • Search Consultancy Limited • S C Access U K Employment S R L • Seed Crushers’ & Oil Processors’ • S E B I Recruitment Limited Association • S F C Personnel Limited • Selby Boatman Services Ltd • S G M Recruitment Limited • Selective Recruitment Ltd • S I A “Jauniesu un studentu starptautiska • Senate Recruitment Solutions Ltd informacijas un nodarb • SES Recruitment Consultants Ltd • S J C Recruitment Ltd • Seven Star Recruitment Ltd • S J Services (UK) Ltd • Sharp Industrial Flexible Staffing • S L R Poultry Limited Solutions Ltd • S M S Ipswich Ltd • Shellfish Association of Great Britain

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Annex E

• Shire Employment Limited • Staffsign (Bradford) Limited •T • Shorterm Engineers Ltd • Staffsmart UK Ltd •TA • Shropshire Group • Staff-U-Like Limited •Ta • Sica Agency • Staff-Vader Ltd •Ta • Silverline Europa Ltd • Staffwise Holdings Plc •Ta • Simply Services limited • Staggar Recruitment •Ta • Simply Recruit Ltd • Star Work Force Limited •Ta • Skills & Labour Limited • Steelend Contracts Ltd •Ta • Skillsco U K Ltd • Stephen Colhoun Limited •Ta • Sky Personnel Ltd • Steve Wright (Poultry) Limited •Ta • Slender Contracting Ltd • Stewart Gardening Services •Ta • SLS Services Limited • Stonehouse Recruitment Ltd •Ta • Small Farms Association • Stonetouch Ltd •Te • Small Woods Association • Storm Personnel Services Ltd •Te • Smart Solutions (Recruitment) Ltd • Storm Recruitment Ltd •Te • Smarter Recruitment Limited • Stour Valley Group Ltd •Te • Smiths Gore • Stratec Business Contracts Ltd •Te • Snowdonia National Park Authority • Strutt & Parker •Te • Soil Association • STUC •Te • Soma Recruitment Ltd • Sudnik Employment Agency •Te • SOS Recruitment Consultancy Ltd • Sue’s Land Services Ltd •Te • Source Recruitment Limited • Suffolk Recruitment Limited •Te • South Devon Organic Producers Ltd • Summer Job Ltd •Te • South Hams Workforce Limited • Sunrise East Ltd •Te • South West Forest • Sunrise Solutions UK.com Ltd •Te • South West Recruitment Ltd • Supertroopers Recruitment •Te • South Yorkshire Forest • Supreme Staff Ltd •Te • Southampton Recruitment Solutions Ltd • Supreme Workforce Ltd •Te • Southern Silviculture • Sure Staff Recruitment Limited •T • Spectrum Personnel Ltd • Surestaff Recruitment •T • Spinnaker Recruitment • Sustainable Forest Management •T • Spring Personnel • Swann Personnel Limited •T • SRP Personnel Ltd • Swanstaff Recruitment Limited C • SRS Recruitment Ltd • Swift Recruitment (eastern) Limited •T • Staff 2 Work Ltd • Swift Recruitment Solutions •T • Staff Box Recruitment Ltd • Sylvan Resources Ltd C • Staff Finders (UK) Ltd • Sylvascape •T • Staff Select Ltd • Sylvestrus Limited •T • Stafflex Limited • System Recruitment (Carlisle) Ltd •T • Staffline Recruitment Ltd • T G T Solutions •T • Stafforce Personnel Ltd • T H Brown Ltd •T • Staffpoint Temp Staff Ltd • T H Clements & Son Ltd •T

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Annex E

• T. Ruck Agricultural Labour Suppliers Ltd • The National Edible Oil Distributors’ • TA Gangmasters Limited Association • Taber Recruitment Services Limited • The National Forest Company • Tailor-Made Temps Ltd • The National Trust • Talisdale Ltd • The Paterson Group • Taskmaster Resources Ltd • The Personnel People • Taurus Recruitment Limited • The Pink Corporation • Tayforth Machinery Ring • The Royal Forestry Society • Taylor Gordon & Co Ltd • The Royal Forestry Society • Taylor Made Services • The Royal Horticultural Society • Taylor Made Services UK Limited • The Scottish Executive • Taylor’s Poultry Services • The Silvanus Trust • Team Support Services Ltd • The Solway Shellfish Management • Team Support Services Plc Association • Teamwork LLC ltd • The Superior Service Co Ltd • Teamwork Resource Limited • The Welsh Assembly Government • Teamwork Selection Ltd • The Wildlife Trusts • Tees Forest • The Wise Agency Ltd • Temp Recruitment Ltd • The Woodland Stewardship Company Ltd • Tempco Staffing Ltd • The Woodland Trust • Templine Employement Agency • The Woodland Trust • Temploy Recruitment Services Limited • The Woodland Trust • Temps Direct • The Workers Agency • Temps Direct 24/7 Ltd • The Workshop (Wisbech) Ltd • Temps Ltd • There For Recruitment • Temp-Team Limited • Thomas Whittle Contracts Limited • Tenant Farmers Association • Thorn Baker Ltd • Tennants (Elgin) Ltd • Thornlands Gangmasters Limited • TFR Ltd • Thorns Workforce Ltd • Thames Chase Community Forest • Three Way Solutions Ltd • The Best Connection Group Ltd • Tilhill Economic Forestry • The Biscuit, Cake, Chocolate and • Tilhill Forestry Confectionery Association • Tim Lewis Consultancy Ltd • The Buccleuch Estates Limited • Tim Lewis Recruitment Ltd • The Church of England Archbishops’ • Timber Trade Federation Council • Timberland Homes Ltd • The Edge Recruitment Cafes Ltd • Time Recruitment Solutions Ltd • The Employment Corporation Ltd • Toad Hill Ltd • The Game Conservancy Trust • Todorov & Co Limited • The Industrial Work Solutions Ltd • Tony Housley • The Labour Bureau • Top Banana Recruitment Agency • The National Association of AONBs • Top Gear Recruitment

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Annex E

• Top UK Ltd • United Employment Ltd •W • Top Up Personnel Ltd • United Kingdom Forest Products •W • Topstaff Employment Ltd Association ( UKFPA ) •W • Toryen Ltd • United Labour Limited •W • Total Catering Solutions Recruitment Ltd • United Recruitment Services Ltd •W • Total Employment Ltd • United Workforce UK •W • Total Healthcare Ltd • Universal Personnel (East Anglia) Ltd •W • Total Labour Solutions • Universal Recruitment Solutions Limited •W • Total Quality Staff Ltd • University of Cambridge Institute for •w • Total Recruitment (Scotland) Limited Manufacturing •W • Trade Recruitment (Eastern) Limited • Uniwork •W • Trades Union Congress • Up & Working Limited •W • Trak Employment Solutions Limited • Uplands Recruitment Agency Ltd •W • Travail Employment Group Ltd • UPM Kymmene UK Ltd Caledonian Paper •W • Tree Council • USDAW •W • Tree-Tec • Vale of Glamorgan council •W • Tre-Newydd Estates • Vane Limited •W • Trevor Paul Hanson • vanStomp •W • Triangle Recruitment Ltd • Velcourt Ltd •W • Triplenine Recruitment Ltd • Victor Foster Poultry Contracts Ltd. •W • TRS Personnel Limited • Victor Wolf Limited •W • TS Developments Ltd • Vines Bros Ltd •W • Tuckwitts’ Tea + Toast Ltd • Vital Recruitment (Peterborough) Ltd •W • Tudor Employment Agency Ltd • Vital Recruitment (UK) Ltd •w • Turnaround Staff Ltd • VJE Employment •W • Turner Stubbs Limited • Voluntary People Limited •W • Twenty-Four Seven Industrial • W H Recruitment Limited •X Recruitment Ltd • W Shorthouse Forestry Contractor •Y • Twenty-Four Seven Recruitment Services Ltd • Weir Forestry •Y • Two Chips Limited • Westaff (UK) Ltd •Z • UAB Grand Turas • Westcoast Environmental •Z • UCATT Scottish Region • Westgate Recruitment Ltd. •Z • UK Association of Frozen Food Producers • Westray Recruitment Consultants Ltd •6 • UK Association of Manufacturers of • WFM Labour Services Limited tr Bakers’ Yeast • Whitelands Environmental Mediation • UK Labour Ltd • Whitewoods • UK Recruitment Agency • Wilcock Agricultural Ltd • UK Timber Frame Association • Wild Recruitment • UK Vineyards Association • Wildife & Countryside Services • UKFPA • Wildways • Ultimate Innovations (Oxford) Limited • Wildwood Consulting • Unite • William McCormick

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Annex E

• Williams Labour Services Ltd • Will-Power U K Ltd • Windymains Sawmill Ltd • Wingate Preston Ltd • Winners Personnel Limited • Wise Employment (Swindon) Limited • WMS Recruitment Ltd ed • Women’s Food and Farming Union • wood.for good limited • Woodland Improvement Ltd • Woodland Trust • Work Force Plus (UK) Ltd • Work With Us Limited aper • Workers Limited • Workflex Limited • Workforce Consultants Ltd. • Workforce Recruitment (NW) Ltd • Workmates Premier Limited • Ltd • WR Industrial Ltd • Wrekin Recruitment Ltd • Wright Employment Limited • Wullzer Ltd • www.wowo.co.uk • Wykeham Staff Services • Wykeham Staff Services • Xtrawork Ltd • Yorkshire Repak Ltd • Yourstaff • Zenith Recruitment Ltd • Zoneday Recruitment Ltd • Zumark • 62 private individuals and individuals who trade in their own names

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