Labour Market Enforcement Strategy 2024 to 2025

I recommend that all three enforcement bodies within my remit seek to collect more and better information on those with protected characteristics to enable analysis of whether those with protected characteristic have increased vulnerability to exploitation. In doing so, this would help demonstrate they are fulfilling their requirement in respect of the public sector equality duty.

I recommend that ODLME and the three enforcement bodies, working with external stakeholders for example from businesses, trade associations or NGOs develop a shared understanding of terminology and clarify mutual understanding of 'data' 'information', and 'intelligence'.

This might usefully include an in-person workshop providing an open forum for discussion to:

- give stakeholders better understanding about what data can be shared

- understand what data stakeholders feel is missing and to what purpose it might be put.

The aim of the workshop is to promote confidence that processes are in place to ensure that complaints are properly investigated and that the activities of the three enforcement bodies are well targeted.

I recommend the three enforcement bodies redouble their efforts to seek out new and potentially shared communication vehicles and maximise opportunities for public messaging, showcasing the results of their work.

I recommend the three enforcement bodies place a greater focus on metrics that assess impact and for work to commence that will provide the information, reporting quarterly to the LME Board.

Such work might draw on expertise within the sponsor departments or where this is not available, the expert guidance the National Audit Office (NAO) may provide.

I recommend the three enforcement bodies engage and work closely with wider work in the artificial intelligence space (AI), either within government, or drawing on expertise in the private business or academic sectors.

Furthermore, I would like the three enforcement bodies to share their learning between each other and with ODLME and the LME Board to enhance wider understanding of the implications of AI within the enforcement bodies remit and ODLME's work.

The enforcement bodies have explained to me that promoting compliance, especially in the SME community is very labour intensive. I believe there may be scope to magnify broadcasting of compliance through forging links with 39 growth hubs in England and equivalent in Scotland, Wales and Northern Ireland. I recommend that the three enforcement bodies pilot the promotion of compliance within the SME community using the reach of growth hubs, perhaps taking one or two hubs each, and reporting back to the LME Board.

I recommend that the three enforcement bodies:

- undertake a combined piece of work to track the entry points and map the processes followed by complainants, particularly when the complaint comes to one agency but requires the attention of another or where one of the three enforcement bodies receives a complaint or report from another statutory body

- report to the LME Board whether/how the processes within the three enforcement bodies might be streamlined.

1) I recommend that EAS/HMRC NMW/DBT establish a stronger evidence base to determine the extent of lack of provision of comprehensive and accessible payslips and/or Key Information Documents.

2) Dependent on the outcome of the above, consider how it can further promote and enforce use of clear, timely and accessible payslips and or more informative, KIDs.

1) I recommend that with the help of community organisations who are promoting workers' rights in the communities they serve, the three enforcement bodies pilot the enhancement of their communications to workers at risk of exploitation by co-producing communications in easy-to-read versions and alternative formats.

2) I recommend ODLME engages with Greater Manchester combined authority and Scottish government to explore how, through existing initiatives, increasing prominence and support for community organisations improve business compliance and prevent labour exploitation.

I recommend that the three enforcement bodies, the SCG and other enforcement providers take further steps to deepen and broaden their interfaces and mutual understanding that go beyond joint working operations. This could include shared learning, threat assessment, promoting compliance.

I recommend that, within the next six months, an assessment should be made of the joint approach associated with adult social care sector, looking at the risk assessments, the collaborative working, the sharing of data, availability of resources, communication and compliance, with a particular focus on the roles of ODLME, its information hub, the three enforcement bodies and other key partners.

I recommend that the three enforcement bodies and the sponsor departments, undertake collective strategic thinking examining the respective impact of different approaches to achieving compliance: e.g. naming and shaming, geographical compliance approach, licensing, penalties, communication campaigns with ODLME playing a facilitation role.