Low Pay Commission Survey of Employers
The Survey
1 For previous reports, we have conducted surveys of employers in low-paying sectors to provide information on how businesses have responded to and coped with the National Minimum Wage. For this report, we conducted a further survey of employers to examine the impact of the October 2005 upratings of the minimum wage and to complement the information we obtained from our research programme, written and oral evidence and official statistics. We consider here the key findings of the survey, including the impact of the upratings on wage bills and differentials, staffing, productivity, prices and profits. We also look at other issues such as the pay of young people and apprentices. In addition this year we have included new questions on the employment of migrant workers, annual leave entitlement and compliance and enforcement. In line with previous surveys, we have also asked additional questions of the social care and textiles and clothing sectors. The survey questionnaire can be found at the end of the Appendix.
2 As with earlier surveys, we have targeted the main low-paying sectors as identified by our analysis of the Annual Survey of Hours and Earnings (ASHE), since they are likely to be the most affected by the minimum wage. In addition to hospitality, retail, social care, textiles and clothing, hairdressing, cleaning, security and leisure, travel and sport1, we have included the agriculture (defined as Standard Industrial Classification (SIC) codes 0105) and food processing (SIC 15.115.8) sectors for the first time in this year's survey.
1 Hereafter referred to as leisure.
3 We commissioned GfK NOP to undertake the administration of the survey on our behalf. A random sample of firms in the low-paying sectors was selected from the Dunn and Bradsheet business database and stratified by firm size, sector and region. Smaller strata (large firms, Scotland, Wales and Northern Ireland, and smaller sectors) were oversampled to allow separate analysis. Over 33,000 postal questionnaires were distributed to employers in June and July 2006. We received 4,174 replies, which gives a response rate of 13 per cent. This is 3 percentage points higher than the response rate achieved in our 2004 survey and similar to that achieved in earlier surveys. We are very grateful to those businesses which took the time to complete and return the questionnaire.
4 Table A3.1 gives the response rates by sector and shows that the highest rate of response was in the childcare and social care sectors, as in previous years, followed by food processing. The response rate in Northern Ireland was lower than in other regions and a higher proportion of medium-sized firms responded to the survey compared with small and large firms2.
Table A3.1
Responses to the 2006 Employers' Survey by Sector

5 Because respondents to the survey are more likely to be affected by the minimum wage than non-respondents, the survey results are not representative of the low-paying sectors as a whole (nor because of the targeted sectors approach, are they representative of the economy as a whole). Quantifying this bias is far from straightforward and we have therefore not corrected for it as in previous years, results are unweighted. Moreover, the number of responses can be very small for specific questions, especially when analysed by individual sectors. For all these reasons, the results of the survey should be interpreted with care.
2 A small firm has fewer than 50 employees, a medium-sized firm employs 50 to 249 people and a large firm employs over 250 people.
6 Table A3.2 shows that the respondent firms employed over 280,000 people. This is around 45,000 more than the number of employees covered in the 2004 survey and reflects the higher response rate. The median number of employees in firms across all sectors is 17, reflecting the high proportion of small businesses in the sample.
Table A3.2
Number of Employees by Sector in the Sample

Base: All firms that provided employee numbers (91 per cent).
7 Table A3.3 illustrates the distribution of respondent firms by size. Around three-quarters of respondents were small firms and one-fifth were medium-sized firms. There is a higher incidence (over 90 per cent) of small firms in the hairdressing and childcare sectors while 10 per cent of the respondent firms in the cleaning and food processing sectors employed over 250 people.
Table A3.3
Size Distribution of Firms by Sector
Base: All firms that provided employee numbers (91 per cent).
Impact
8 Table A3.4 shows that around 42 per cent of respondents said that their business had been affected by the October 2005 increase in the minimum wage in any way. In earlier surveys, the proportion of respondents affected by the 2001 and 2003 upratings was 50 and 46 per cent respectively. However, it is worth noting that the October 2005 uprating, by 4.1 per cent from £4.85 to £5.05, was more modest than the 2001 and 2003 increases in the minimum wage (which were 10.8 and 7.1 per cent respectively). As in the 2004 survey, a higher proportion of respondents were affected in the childcare, hospitality and cleaning sectors.
Table A3.4
Percentage of Firms Affected by the October 2005 Increases in the National Minimum Wage in Any Way
Base: All firms that responded to the question (97 per cent).
9 The impact of the 2005 upratings was found to be greater on large firms, with 59 per cent being affected compared with 40 and 53 per cent for small and medium-sized firms respectively.
10 It is important to note that the responses to our survey are likely to overstate the impact of the National Minimum Wage on businesses for two main reasons. First, the survey specifically targeted low-paying sectors, which are likely to be most affected by the minimum wage. Secondly, even within these sectors, those who responded are more likely to have been significantly affected than non-respondents. We tested this hypothesis of an upward bias in our Fourth Report (2003) by conducting a telephone follow-up survey of a random sample of 900 non-respondents to the postal survey. This confirmed that the proportion of those affected in the follow-up survey (27 per cent) was considerably lower than in the main postal survey (50 per cent). They also reported a smaller impact on their wage bill. This implies that the results of the survey are biased towards those who have experienced the greatest impact of the National Minimum Wage and should therefore not be taken to be indicative of the overall impact on businesses, even in low-paying sectors. The survey does, however, provide valuable information on how those affected by increases in the minimum wage have coped and enables comparisons between sectors and size of business.
Total Wage Bill
11 Table A3.5 shows that the majority (56 per cent) of respondents who said they were affected by the October 2005 upratings reported that their total pay bill had increased by more than 5 per cent, with around 41 per cent reporting a wage bill increase of less than 5 per cent and only 4 per cent of respondents reporting no change. This compares with three-quarters of affected respondents reporting pay bill increases over 5 per cent in the 2002 and 2004 surveys. The incidence of those reporting larger increases in their pay bill varied by sector, with the social care, childcare and hairdressing sectors the most affected. Medium-sized and large firms were also more likely to report pay bill increases over 5 per cent than small firms.
Table A3.5
Impact on Total Pay Bill for Firms Affected by the October 2005 Increases in the National Minimum Wage

Base: All firms affected by the October 2005 increases in the National Minimum Wage in any way and that responded to the question (40 per cent).
Differentials
12 Table A3.6 indicates that over two-thirds of those respondents who had to increase their pay rates as a result of the 2005 upratings did so to comply with the new National Minimium Wage rates. A similar result was found in the 2004 survey. The cleaning, hospitality, leisure and retail sectors were particularly affected as three-quarters of firms in these sectors reported that this was the reason for increasing pay rates. This compares with only 53 per cent of respondent businesses in the social care sector.
13 Overall, around 42 per cent of respondents affected by the 2005 upratings reported that they had increased pay rates to maintain pay differentials above the lowest pay rate. This compares with 47 per cent in the 2004 survey. This was particularly the case for the childcare, food processing and textile sectors, but not so much in the hairdressing sector as only 18 per cent of firms invoked this reason to explain pay increases. Similarly, 40 and 30 per cent of affected respondents (down from 51 and 37 per cent in 2004) said that they increased pay rates to maintain pay differentials for more experienced staff and for higher grade staff respectively. In both cases, the childcare sector seemed the most affected.
14 Looking at the type of firms most affected, large firms were more likely to have increased rates to comply with the new National Minimum Wage rates and to maintain pay differentials for the lowest pay rates, while smaller firms were more likely to have increased rates to maintain pay differentials for more experienced staff.
Table A3.6
Impact on Pay Rates for Firms Affected by the October 2005 Increases in the National Minimum Wage
Base: All firms affected by the October 2005 increases in the National Minimum Wage in any way and who responded to the question (40 per cent).
Note: Respondents gave multiple answers and row totals therefore do not add up to 100 per cent.
15 Table A3.7 illustrates the distribution of the highest hourly pay rate increased by businesses to maintain pay differentials as a result of the October 2005 upratings. The median highest hourly pay rate which firms reported increasing was £6.00, while about a third of respondent firms reported that the highest pay rate they increased was below £5.50. By contrast, nearly two-fifths of respondents said that the highest rates increased were above £6.50, compared with 22 per cent in 2004. The data suggest that the effect on the highest rates of pay was most significant in the cleaning, agriculture, social care and childcare sectors. About 47 per cent of large firms responding to the question reported that the highest pay rate increased was above £6.50, compared with 30 per cent of small firms and 43 per cent of medium-sized firms.
16 Across all sectors, the median increase to the highest rates was 40 pence per hour. The lowest median increase was in the security sector (25 pence) and the highest in the agriculture, hairdressing and hospitality sectors (50 pence).
Table A3.7
Distribution of Highest Hourly Pay Rate Increased to Maintain Pay Differentials
Base: All firms that increased pay rates to maintain differentials and responded to the question (22 per cent).
Benefits
17 We asked firms affected by the October 2005 upratings in the minimum wage whether it led to any benefits for their business. Table A3.8 shows that overall, the majority (over 8 in 10) of respondents who had reported an impact said that the latest upratings did not bring any benefits. Around 14 per cent of businesses claimed to have noted an improvement in their staff motivation, although only one per cent said the change was significant. The childcare and hairdressing sectors were more likely to report increased staff motivation than other sectors. About 13 per cent of businesses affected by the 2005 minimum wage upratings reported that they experienced lower staff turnover, while 8 per cent of respondents were able to fill vacancies more quickly. This is in line with the 2004 survey results.
Table A3.8
Benefits to Businesses from the October 2005 Increases in the National Minimum Wage
Base: All firms that increased pay rates to maintain differentials and responded to the question (39 per cent).
Staffing
18 We asked businesses that had reported being affected by the 2005 minimum wage upratings whether they made any adjustments to staffing and hours as a response. Table A3.9 shows that the most widespread adjustment reported by businesses in response to the National Minimum Wage increase was to reduce overall staffing levels, reported by 34 per cent of affected businesses. This compares with 37 per cent in the 2004 survey. The hospitality and agriculture sectors were the most affected, with 49 and 44 per cent of respondents respectively reporting changes to staffing levels. About a quarter of affected firms also said that they decreased basic hours and overtime hours this is slightly down compared with the previous survey. Around 14 per cent of firms said they reduced overtime rates and incentive payments in response to the upratings.
19 Firms which had reported large (over 5 per cent) increases to their wage bills as a result of the October 2005 upratings were also found to be more likely to make adjustments to staffing and hours than respondents who had experienced small or no wage bill increases.
Table A3.9
Changes Made by Firms as a Result of the October 2005 Increases in the National Minimum Wage

Base: All affected firms responding to the question (37 per cent).
Productivity, Prices and Profits
20 Table A3.10 shows the range of adjustments that affected firms reported they had made following the October 2005 upratings. The greatest impact by far was on profits as 78 per cent of affected respondent firms reported a reduction in their profits, compared with 80 per cent in the 2004 survey. No particular sector stood out compared with others. Around 58 per cent of affected businesses also said that they increased prices in response to the minimum wage upratings. The childcare, cleaning and hairdressing sectors were most likely to increase prices.
21 To a lesser extent, affected businesses also reported having to take measures to control labour costs (29 per cent) and non-labour costs (35 per cent). In particular, 46 per cent of firms in the hospitality sector said they had to adjust non-labour costs. Only a small proportion of businesses said that they responded to the October 2005 upratings by adjusting the quality of goods and services they provided, introducing new products or services or resorting to unskilled/unqualified labour. However, this varied across sectors: for example, one quarter of firms in the agriculture sector said they increased their use of unskilled/unqualified labour.
22 There was also some variation in the incidence of adjustments made to the business across firms of different sizes. For instance, large firms were less likely than small and medium-sized firms to have experienced a fall in profits. The impact on prices was also greater the smaller the size of the firm. The most significant differences in the response of different firm types related to labour costs: around 46 per cent of large firms took measures to control labour costs compared with 36 and 26 per cent of medium-sized and small firms respectively. Finally, small firms were less likely than others to adjust non-labour costs or introduce new technologies or processes.
Table A3.10
Has the October 2005 Increase in the National Minimum Wage Led to any Changes in any of the Following in your Business?
Base: All affected firms responding to the question (38 per cent).
23 As in previous surveys, we asked additional questions of firms in the textiles and clothing sector relating to the impact of the increases in the minimum wage on their incentive pay schemes and productivity. Just over a quarter of textiles and clothing firms reported that they had an incentive pay system (e.g. piece rates or payment by results). This is in line with the results of the 2004 survey. Incentive pay systems were more prevalent in some types of businesses than others. For instance, over half of knitwear and hosiery manufacturers said they had an incentive pay system compared with about 10 per cent of print finishers and soft furnishing manufacturers. Medium-sized and large firms were also more likely to have incentive pay systems than small firms.
24 Around 59 per cent of textiles firms with an incentive pay system said that they had been affected by the October 2005 increases in the minimum wage compared with 35 per cent of textiles firms without such a scheme. We asked those firms with an incentive pay system whether they had experienced any of the effects outlined in Table A3.11. Around 62 per cent reported an increase in costs and half reported a significant increase. This compares with 31 per cent in the 2004 survey and in general, fewer firms reported no change in the 2006 survey than they did in the 2004 survey. For instance, 18 per cent of firms in the 2004 survey said the October 2003 upratings had resulted in reduced differentials compared with 44 per cent of respondents reporting an impact on differentials arising from the October 2005 upratings.
Table A3.11
Impact of the National Minimum Wage on Incentive Pay Systems in the Textiles and Clothing Sector
Base: All firms in the textiles and clothing sector with an incentive pay system (26 per cent).
25 As in previous surveys, we sought information from the social care sector on the extent to which businesses in this sector have been able to renegotiate the conditions of public sector contracts following minimum wage upratings. Nearly four in five firms in the social care sector which reported being affected by the October 2005 upratings had public sector contracts and nearly two-thirds of these tried to renegotiate their contracts to take account of increased minimum wage costs. However, 38 per cent of these were not successful while 31 per cent only managed to renegotiate their contracts in part.
Employment and Pay of Young People
26 Table A3.12 shows that 14 per cent of firms responding to the survey said they used age-related pay structures. By comparison, 20 per cent of respondents said they had age-related structures in the 2004 survey. These pay structures were more common in the hospitality and childcare sectors, at 30 and 20 per cent respectively, while the security, social care and cleaning sectors were least likely to make use of age-related pay. The prevalence of age-related pay was also less (at 12 per cent) in small firms compared with medium-sized and large firms.
Table A3.12
Firms with Age-related Pay Structures

Base: All firms that responded to the question (97 per cent).
27 Figure A3.1 gives the distribution of minimum pay rates by age for those firms in the sample which made use of age-related pay. It shows that a sizeable proportion of firms pay employees aged below 22 more than the minimum wage rate applicable for their age and that use of the adult rate clearly increases with employees' age. Over 80 per cent of firms with age-related pay structures paid their 16 and 17 year old employees above the 1617 year old rate of £3.00 per hour, with 30 per cent and 41 per cent of respondent firms respectively paying their 16 and 17 year old employees a minimum hourly rate equal or superior to the then Youth Development Rate of £4.25.
28 Around 26 per cent of businesses with age-related pay systems reported paying their 18 year old employees above the Youth Development Rate and this proportion went up to 57 per cent for 21 year olds.
Figure A3.1
Distribution of Minimum Hourly Pay Rates by Age
Base: All firms with age-related pay structures that responded to the question (810 per cent).
29 We also asked those same respondents (14 per cent of all firms) to state the age from which they paid their adult rate of pay. Table A3.13 shows that 21 per cent of these firms started paying the full adult rate at 18. This is in contrast to the results of the 2004 survey, which showed that 46 per cent of firms paid the full adult rate at 18. Conversely, around 44 per cent of firms reported starting paying the adult rate to employees aged 22 and above, compared with 22 per cent in the 2004 survey. The age at which the adult rate applied varied considerably by sector. The social care and textiles and clothing sectors were the most likely (at over 36 per cent) to start paying the adult rate at 18 compared with 11 per cent of firms in the hairdressing sector.
Table A3.13
Age at which a Worker is Entitled to the Full Adult Rate in Firms with Age-related Pay Structures
Base: All firms with age-related pay structures that responded to the question (13 per cent).
30 Finally, we asked firms with age-related pay structures whether they would be more or less likely to employ young people as a consequence of the October 2005 minimum wage upratings. Overall, the increases had little impact on these employers' decisions regarding the employment of young workers. Table A3.14 shows that around four-fifths of businesses said it had made no difference to their employment of 16 to 21 year olds, with 8 and 13 per cent noting that they were more likely to employ 1617 and 1821 year olds respectively.
Table A3.14
Has the Introduction of a National Minimum Wage for 16 and 17 Year Olds in October 2004 (£3.00), or the 2005 Increase in the Youth Rate for 1821 Year OIds (£4.25) and the Adult Rate (£5.05) Made you More or Less Likely to Employ Workers in Different Age Groups?
Base: All firms with age-related pay structures that responded to the question (13 per cent).
Apprentices
31 Table A3.15 shows that one in ten of the surveyed firms employed apprentices. This is similar to the 2004 survey. However, this varied significantly across sectors, with one third of respondents in the hairdressing sector and over one fifth of respondents in childcare employing apprentices. The social care, textiles and agriculture sectors were least likely to do so.
Table A3.15
Firms Employing Apprentices

Base: All firms (100 per cent).
32 Table A3.16 shows the distribution of apprentices by age group across all sectors and in those sectors employing a high proportion of apprentices. Overall, a third of apprentices were aged 16 to 17 and just under half were aged 18 to 19. Only 8 per cent of apprentices were aged 22 and above. The age distribution varied across sectors; over half of apprentices in hairdressing businesses were aged 1617, compared with 22 per cent in the retail sector. Large firms were also found to be less likely than small and medium-sized firms to employ 1617 year old apprentices.
Table A3.16
Distribution of Apprentices by Age Group
Base: All firms that responded to the question (10 per cent).
33 Table A3.17 shows the average (median) hourly rate of pay for apprentices across all sectors and in the three sectors that employed a high proportion of apprentices. The average hourly wage for a first-year apprentice was £3.60, rising to £4.25 and £5.00 in the second and third years respectively. The hairdressing sector, at £3.00, had lower than average apprentice pay in year 1 and 2, possibly reflecting the very high proportion of 1617 year old apprentices in that sector.
Table A3.17
Average Hourly Rate of Pay for Apprentices
Base: All firms that responded to the question (10 per cent).
Migrant Workers
34 We asked businesses whether they employed migrant workers and whether this was becoming a more frequent occurrence. As shown in Table A3.18, over a quarter of respondent firms reported employing migrants. This was much more prevalent in the food processing and hospitality sectors where about half of respondents said they employed migrant workers. The childcare, hairdressing and retail sectors were least likely to do so. One-fifth of respondents employing migrant workers said that they had started to employ migrants in the last year, predominantly in the hairdressing and retail sectors, while 42 per cent reported that the number of their migrant employees was increasing, notably in the food processing, agriculture and cleaning sectors. Finally, a third of businesses said the number of migrant employees had not changed.
35 The data suggest that only 18 per cent of small firms employed migrant workers compared with 57 per cent of medium-sized firms and 73 per cent of large firms. Among these, 30 per cent of small firms reported having started to employ migrants in the last 12 months. The employment of migrant workers was slightly more prevalent in Northern Ireland and England than in Wales and Scotland.
Table A3.18
Firms Employing Migrant Workers
Base: All firms that responded to the question (91 per cent).
36 We asked businesses what were the main reasons for employing migrant workers and, as shown in Table A3.19, the great majority (64 per cent) did so because of shortages in the labour market. The security, social care, agriculture and cleaning sectors were most affected. Around 23 per cent of employers employed migrant workers because of their efficiency, especially in the childcare and textiles and clothing sectors. Only 6 per cent of respondents said they employed migrant workers because they were more qualified/skilled or to control wage costs. Of those who gave other reasons, around half said it was because they were equal opportunity employers and had recruited the best candidate for the job.
Table A3.19
Main Reasons for Employing Migrant Workers

Base: All respondent firms employing migrant workers (26 per cent).
Note: Respondents gave multiple answers and row totals therefore do not add up to 100 per cent.
Bank Holidays
37 To assess the likely impact of the forthcoming legislation on annual leave entitlement, we asked businesses whether their full-time employees were entitled to paid leave on Public or Bank Holidays (or alternative days in lieu) on top of their statutory leave entitlement currently 20 days. As indicated in Table A3.20, nearly three-quarters of respondents said that their staff were entitled to paid leave on Bank or Public Holidays. However, fewer businesses did so in the hospitality and security sectors (55 per cent) and in the social care sector (63 per cent). Those firms which reported a larger impact of the October 2005 upratings on their pay bill were less likely to provide paid leave on these days. Employees in large firms were more likely to be entitled to paid leave on Bank Holidays than those employed by medium-sized and small firms. Only 67 per cent of Welsh businesses said that their employees were entitled to paid leave on Bank Holidays compared with 80 per cent of firms in Northern Ireland.
Table A3.20
Firms in Which Employees are Entitled to Paid Leave on Public or Bank Holidays (or Days in Lieu)

Base: All firms that responded to the question (95 per cent).
38 Table A3.21 shows that in the great majority (79 per cent) of businesses offering paid leave on some Bank Holidays, employees were entitled to 7 or more Bank Holidays as paid leave and in 13 per cent of respondent firms, employees were entitled to 56 days paid leave. In only 7 per cent of firms were employees entitled to fewer than 4 days paid leave on Bank Holidays. However, the position varied across sectors. For instance, employees were entitled to 4 days paid leave or fewer in up to 20 per cent of respondent firms in the hospitality sector, one of the sectors with already the lowest proportion of firms granting paid leave on Bank Holidays. In the textiles and security sectors on the other hand, employees were entitled to 7 or more Bank Holidays as paid leave in 88 and 93 per cent of firms respectively. Large firms were also more likely to pay for 7 days or more (93 per cent compared with 63 per cent of small firms).
Table A3.21
How Many Public or Bank Holidays (or Other Days in Lieu) are your Full-time Employees Entitled to as Paid Leave?
Base: All respondent firms with employees entitled to paid leave on Public/Bank holidays (68 per cent).
Compliance and Enforcement
39 We asked businesses whether they were aware of any other businesses in their local area not complying with National Minimum Wage requirements. As shown in Table A3.22, only 5 per cent of respondent firms reported that they were aware of non-compliance in their area. The most affected sectors were hospitality and security with about one in ten firms being aware of potential non-compliance.
Table A3.22
Percentage of Firms Aware of Non-compliance with National Minimum Wage Requirements in their Local Area

Base: All firms that responded to the question (97 per cent).
40 Among those aware of non-compliance, very few firms were also aware of any actions by HM Revenue and Customs (HMRC) to enforce the National Minimum Wage, including those sectors with a high proportion of firms which said that some of their competitors were not complying. However, awareness of enforcement activities was highest (42 per cent) in hairdressing, a sector which HMRC minimum wage enforcement teams targeted in 2005 in a year-long campaign of education and enforcement. Firms in the food processing and leisure sectors were also more likely to be aware of enforcement actions.
Table A3.23
Percentage of Firms Aware of Enforcement Actions by HMRC
Base: All respondent firms aware of non-compliance (5 per cent).
Conclusion
41 As in previous years, our survey has provided valuable information about the impact of the 2005 upratings on those sectors most affected by the minimum wage.
42 Just over 40 per cent of respondents to the survey said that their business had been affected by the October 2005 upratings and over half of these firms reported that their wage bill had increased by 5 per cent or more. The proportion affected is smaller than in the previous surveys. However, the 2005 minimum wage upratings were more modest than the 2001 and 2003 increases.
43 There is some evidence of the minimum wage upratings having an impact on pay differentials, with about a third of affected firms reporting having to increase pay rates to maintain differentials. Few firms affected by the 2005 minimum wage upratings reported that these had led to benefits for their business such as lower staff turnover. However, nearly four out of five affected firms said that they had experienced a decline in profits as a result of the upratings. Over half also reported an increase in prices. A quarter to a third of affected firms also responded to the October 2005 upratings by reducing their overall levels of staff and basic and overtime hours.
44 As in previous years, the survey highlighted that limited use is made of age-related pay structures, with only 16 per cent of respondents having age-related pay systems. However, 44 per cent of these firms reported starting paying the adult rate at 22, a substantial increase compared with the 2004 survey.
45 For the first time this year, we asked businesses about their employment of migrant workers. Just over a quarter of respondents reported employing migrant workers, and the great majority of these said they had started doing so, or had increased the number of such employees, in the last year. Nearly four in five businesses that employed migrant workers said they did so because of shortages in the local labour market.
46 The survey highlighted that employees were entitled to paid leave on Public or Bank Holidays in three-quarters of the businesses surveyed and the majority of these granted 7 or more such days to their employees. However, a substantial proportion of businesses in the security, hairdressing and hospitality sectors were less likely to do so.
47 Only 5 per cent of businesses reported being aware of non-compliance in their sector and among these, few, with the exception of the hairdressing sector, said they were aware of HMRC enforcement activity.
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