Our approach to IR35 compliance is based on a commitment to transparency, communication, and
collaboration.

We recognise that IR35 legislation is complex and that the risks associated with noncompliance
can be significant. As such, we will take a proactive approach to IR35 compliance, ensuring we
have robust policies and procedures to identify and manage potential risks.

Our approach to IR35 compliance and risk mitigation will include:

1. Conducting regular assessments of worker status using the CEST tool to determine whether a worker is
inside or outside the scope of IR35 legislation.

2. Conducting a one-off, pre-contract-start assessment of worker status using QDOS’ IR35 Assessment Tool

3. Ensuring that our contractual terms and working arrangements with contractors and other service
providers are consistent with their status and do not contain any provisions that could be construed as
indicating employment status.

4. Providing guidance and support to contractors and other service providers to ensure that they understand
their obligations under IR35 legislation and are able to work with us in a compliant manner.

5. Arranging appropriate insurance cover to provide protection against any potential litigation related to IR35,
where appropriate.
We believe this approach will enable us to manage our IR35 risks effectively and ensure that our relationships
with contractors and other service providers comply with the relevant legislation. We are committed to working
with all stakeholders to ensure that we maintain high standards of compliance and transparency in all our
business operations.

To support our approach to IR35 risk mitigation, we will provide regular updates and training on the latest developments in IR35 legislation and guidance on best practices for managing IR35 risks. We will also
conduct regular reviews of our policies and procedures to ensure they remain up-to-date and effective in light
of any changes to the legal landscape.

We encourage all members of staff to familiarise themselves with our approach to IR35 risk mitigation and to seek guidance from the relevant teams if they have any questions or concerns.

By working together and maintaining a commitment to compliance and transparency, we can ensure that we continue to operate in a
manner that is ethical, sustainable, and compliant with all relevant legislation.