Right To Work In The UK Policy - Preventing Illegal Working

This policy applies to all persons working for, or on behalf of, Fox Brothers Holdings Limited (Fox Group) in any capacity, including current employees, new employees, or employees joining the company under TUPE regulations and applies regardless of race, gender, religious belief, age, sexual orientation or disability.

The Company is legally obliged to comply with the requirements set by the UK Border Agency, to ensure that new staff and current staff are eligible to work in the UK and to adhere to any restrictions on their employment.

The prevention of illegal migrant working in the UK is governed by sections 15 to 25 of the Immigration, Asylum and Nationality Act 2006, section 24B of the Immigration Act 1971, and Schedule 6 of the Immigration Act 2016.

Proof of Right to Work in the UK

Using an Identity Service Provider (IDSP)

Fox Group use Identity Document Validation Technology (IDVT) via the services of an identity service provider (IDSP) to complete the digital identity verification element of right to work checks. This is for British and Irish citizens who hold a valid passport (including Irish passport cards).

Digital identity verification conducted by IDSPs is the process of obtaining evidence of the prospective employee’s identity, checking that it is valid and belongs to the person who is claiming it.

Using the Home Office online right to work check

Holders of an eVisa, Biometric Residence Card (BRC), Biometric Residence Permit (BRP) or Frontier Worker Permit (FWP) will be assessed via the Home Office online service. It will not be possible to conduct a Home Office online right to work check in all circumstances, as not all individuals will have an immigration status that can be checked online. In circumstances in which an online check is not possible, Fox Group will perform a manual check.

Conducting a manual document-based right to work check

The Home Office, via the UK Border Agency, have compiled a list of documents, which prove that someone has the RTW in the UK. Documents will fall into either List A or List B and these are attached as appendices.

An employee will need to provide:

One document from List A, these documents show an on-going RTW in the UK.

If they cannot produce a document from List A then relevant document(s) from List B must be produced. These documents show a RTW in the UK for up to twelve months.

These must be original copies; photocopies, scanned documents and faxes for example are not acceptable.

A copy of the relevant page(s) of the documents provided will be retained in a format which cannot subsequently be altered, for example a photocopy or a scanned document. In the case of a passport or other travel document, the following parts must be photocopied or scanned:

The document’s front cover and any page containing the holder’s personal details. In particular, any page will be copied that provides details of nationality, photograph, date of birth, signature, date of expiry or biometric details, and

Any page containing UK Government endorsements indicating that the holder has an entitlement to be in the UK and is entitled to undertake the work in question.

Other documents will be copied in their entirety. Any documents will be kept securely for the duration of the licence and for a further two years after the expiry of the last licence if renewal is not sought. This is in line with legislation which requires employers to retain copies of documents relating to individuals they have employed.

If further verification is required this will be specified in a letter detailing the exact requirements.

All relevant documentation will be retained for a minimum of two years after an employee has ended their employment with the Company.

The fair way to check

It is illegal to discriminate on grounds of race, colour, ethnic or national origin, or nationality. No presumptions about a person’s RTW in the UK will be made based on a person’s background, appearance or accent. Each applicant will be required to comply with the RTW Policy and provide the necessary documentation.

Reporting of illegal workers to the relevant authorities

If the Company has any concerns that an employee has been working in the UK illegally then this information will be reported to the Home Office, Border and Immigration Agency and UK Border Agency.

Need further information?

Further information about working in the UK, legislation and advice to employers can be found on the Home Office website:

Homeoffice.gov.uk/sitecontent/documents/employersandsponsors/preventingillegalworking

Name: Paul Fox

Position: CEO

Date: 12th May 2025

Appendix 1: Lists of acceptable documents for manual right to work checks

If the applicant can produce a satisfactory document from List A, eligibility to work in the UK will have been established and will not need to be checked again. If an application is made after a licence has expired then proof of a person’s RTW in the UK will be required again.

List A – Acceptable documents to establish a continuous statutory excuse

  1. A passport (current or expired) showing the holder is a British citizen or a citizen of the UK and Colonies having the right of abode in the UK.
  2. A passport or passport card (in either case, whether current or expired) showing that the holder is an Irish citizen.
  3. A document issued by the Bailiwick of Jersey, the Bailiwick of Guernsey or the Isle of Man, which has been verified as valid by the Home Office Employer Checking Service, showing that the holder has been granted unlimited leave to enter or remain.
  4. A current passport endorsed to show that the holder is exempt from immigration control, is allowed to stay indefinitely in the UK, has the right of abode in the UK, or has no time limit on their stay in the UK.
  5. A current Immigration Status Document issued by the Home Office, indicating that the named person is allowed to stay indefinitely in the UK, with an official document showing their National Insurance number and name.
  6. A birth or adoption certificate issued in the UK, with an official document showing their National Insurance number and name.
  7. A birth or adoption certificate issued in the Channel Islands, the Isle of Man or Ireland, with an official document showing their National Insurance number and name.
  8. A certificate of registration or naturalisation as a British citizen, with an official document showing their National Insurance number and name.

*Includes full birth certificate issued by a UK diplomatic mission (British Embassy or British High Commission).

If an applicant produces any document from List B then the document must be re-verified at least every 12 months to produce evidence of eligibility to work in the UK.

List B Group 1 – Time-limited statutory excuse until permission expiry

  1. A current passport endorsed to show that the holder is allowed to stay in the UK and is currently allowed to do the type of work in question.*
  2. A document from Jersey, Guernsey, or the Isle of Man showing limited leave, verified by the Employer Checking Service.
  3. An Immigration Status Document with a valid endorsement, and an official document showing the National Insurance number and name.

List B Group 2 – Time-limited statutory excuse for six months

  1. A Home Office document showing application under the EU Settlement Scheme on or before 30 June 2021 with a Positive Verification Notice.
  2. A Certificate of Application under the EU Settlement Scheme (post 1 July 2021), with a Positive Verification Notice.
  3. A document from Jersey, Guernsey, or the Isle of Man for leave to remain, with a Positive Verification Notice.
  4. An Application Registration Card from the Home Office stating employment is permitted, with a Positive Verification Notice.
  5. A Positive Verification Notice from the Home Office Employer Checking Service confirming permission to work.

*Includes a current passport with a stamp showing leave granted with no work-related conditions.