How Adesto operates as an employment business in the UK healthcare recruitment sector, and the legal framework we work within.

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1. Our status: an employment business

Adesto Recruitment Limited ("Adesto", "we", "us", "our") is an employment business (as defined in section 13(3) of the Employment Agencies Act 1973). This means we engage locum workers and supply their services to client organisations, rather than merely introducing candidates for direct employment (which is the role of an employment agency). Locum workers supplied through the platform are engaged by us as workers and are paid by us under PAYE, with tax and National Insurance deductions applied.

2. Conduct of Employment Agencies and Employment Businesses Regulations 2003

We comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (the "Conduct Regulations"), including our obligations to:

• take all reasonably practicable steps to obtain sufficient information about the client's requirements, the working environment, and any risks to health and safety;
• verify a worker's identity, right to work, and relevant qualifications and experience before supplying them;
• provide the client with written details of the worker's identity, relevant experience, training, qualifications and authorisations, and the charges;
• obtain written confirmation from the worker of the terms of the assignment; and
• keep proper records of every work-seeker and hirer.

3. Care sector compliance (CARE Regs 2003 / CQC)

Where we supply staff into care settings that are regulated under the Care Standards Act 2000, we comply with the requirements of the relevant care regulations and the standards set by the Care Quality Commission (CQC). This includes, where applicable:

• ensuring workers are suitable for the role, including appropriate Disclosure and Barring Service (DBS) checks and, where relevant, DBS Update Service checks;
• verifying professional registration (NMC, GMC, HCPC) and mandatory training before a worker is placed;
• complying with safeguarding requirements and reporting concerns to the appropriate authorities;
• assisting clients to meet their obligations in respect of fit and proper persons and safe staffing.

Our compliance verification is carried out in good faith and is designed to support — but not replace — the client's own responsibility to confirm that each worker is suitable for the particular placement.

4. Agency Workers Regulations 2010 (AWR)

Where a worker is supplied to a client that is a "hirer" under the Agency Workers Regulations 2010 (AWR), we comply with the AWR, including the right to equal treatment on pay and basic working conditions after the 12-week qualifying period, and access to collective facilities and job vacancies from day one. Clients are required to provide us with the information needed to comply with the AWR (for example, details of any comparable employees and prior assignments).

5. Working Time Regulations 1998

We comply with the Working Time Regulations 1998, including the 48-hour average working week (unless a worker has opted out in writing), minimum rest breaks, and annual leave. We ask clients to notify us in advance where a worker is required to work more than 48 hours in a week so that the necessary opt-out arrangements are in place.

6. Payment terms (PAYE)

All locum workers supplied through the platform are engaged on a PAYE basis. The client pays our charges for the supply of the worker's services; we pay the worker their agreed rate, subject to PAYE tax and National Insurance deductions. Invoices are issued in line with the client's agreed payment terms, and are subject to VAT where applicable. See our Cancellation & Refund Policy for details of cancellation fees.

7. Temporary-to-permanent ("temp-to-perm") and transfer fees

If a client wishes to engage a worker we have supplied on a permanent basis (or through a different engagement structure) during or shortly after an assignment, a transfer or introduction fee may apply, calculated in accordance with our terms of business and the Conduct Regulations. We will always offer the alternative of an extended period of hire before any transfer fee becomes payable. Please contact us for details of the current fee scale.

8. Client and worker obligations

Clients must provide accurate details of each assignment (including role, hours, location, and any health and safety risks), confirm or cancel bookings promptly, provide a safe working environment, and not circumvent the platform to engage workers directly. Locum workers must hold valid registration and compliance documents, attend booked shifts, and follow client policies. Full details are in our Terms & Conditions and Client Terms & Conditions.

9. Data protection

As a recruitment business we process personal data (including special category data such as health and criminal-conviction information) to verify and manage workers. See our Privacy Policy, Fair Processing Notice and Data Processing Agreement.

10. Contact

Questions about our compliance framework? Contact us at [email protected], or write to Adesto Recruitment Limited, [Registered office address — to be confirmed].

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