Hargreaves Lansdown: Off-Payroll Safe case study
After a 12-month delay, the Off-Payroll Working for the Private Sector legislation (OPW) was confirmed to go live in April 2021.
Hargreaves Lansdown is one of the leading wealth management organisations within the UK and is a member of the FTSE 100. As such they take a robust approach to regulatory compliance across all aspects of their operations.
Hargreaves Lansdown has a diverse workforce that includes a number of off-payroll workers and they were also planning a period of digital investment that would inevitably increase these demands.
Hargreaves Lansdown required a supplier who possessed knowledge and expertise with IR35 who could provide an outsourced managed service to them to ensure full regulatory compliance with this new legislation. This included making accurate ‘Inside’ and ‘Outside’ determinations for IR35, in addition to ensuring that off-payroll workers determined as ‘Inside’ IR35 are processing the correct amounts of PAYE and National Insurance.
This service needed to encompass their entire off-payroll workforce, so would also need a solution that could supplier manage their current recruitment suppliers.
RedRock engaged with Hargreaves Lansdown’s People team to understand the different use cases for off-payroll workers across their organisation. This included a risk assessment that captured data on their current off-payroll workforce and existing suppliers.
RedRock modelled a solution whereby it acts as the fee payer for all off-payroll workers that included the facilitation of payments to the 2nd tier suppliers, allowing Hargreaves Lansdown to retain key suppliers whilst ensuring compliance throughout the supply chain. This enabled RedRock to address the challenges associated with longer supply chains from ‘Reasonable Care’ and to also commit to the high levels of warranty that Hargreaves Lansdown required for this managed service.
Dedicated Account Manager
RedRock appointed a dedicated Account Manager who not only understands this legislation but who is also a superuser of RedRock’s approved IR35 status determination tool. The Account Manager engages with stakeholders across Hargreaves Lansdown’s business, to carry out working arrangement assessments with prospective line managers that form a key part of the IR35 status determinations made.
For status determinations that fall ‘Outside’ IR35, RedRock is then able to procure insurance, without a prospect of success clause, that covers all parties within the supply chain. Once the RedRock Account Manager has captured the role requirements and ascertained the appropriate engagement model for IR35, they then oversee the search and selection process, which may include engagement with the 2nd tier suppliers as appropriate.
The Account Manager and Account Director run frequent sessions with Hargreaves Lansdown’s colleagues to educate them on IR35 and OPW.
Ongoing status checks are carried out with all active contractors to ensure that any change in scope is captured. This includes guidance on the ways of working for the different engagement models.
RedRock appointed a dedicated Compliance Manager that ensures full compliance with not just IR35 and OPW, but the wider regulatory environment of engaging with off-payroll workers. This also encompasses best practices around identity checking, reference checking, and DBS checks along with other vetting requirements.
RedRock also introduced a tailored governance model for this managed service that includes SLA’s/OLA’s, customised monthly MI, and an agreed escalation path along with monthly service reviews.
- Managed service swiftly onboarded utilising presentations to large numbers of stakeholders across Hargreaves Lansdown’s organisation along with the production of a service handbook that was made available internally.
- This service has been in place since January 2021, fulfilling all requirements for off-payroll workers in a timely fashion.
- Stakeholders within Hargreaves Lansdown are now better informed with IR35 and OPW.
- Hargreaves Lansdown has enjoyed the support of a large off-payroll population (100+) that are all correctly determined for IR35 and fully compliant with the wider regulatory climate.
- Hargreaves Lansdown have more time to focus on what they do ‘exceptionally’ well!