Recommendation: approve an evidence exercise and preparation of a response, while reserving the decision to submit until Northstar has quantified cost, operational and legal impacts. Public Affairs should target proportionate implementation that protects fair worker rights without removing reasonable workforce flexibility.
The DBT consultation is a confirmed primary-source opportunity to shape secondary legislation; the rights are not yet in force. Proposals cover guaranteed hours, reasonable shift notice and payments when shifts are cancelled, moved or curtailed at short notice. They could materially reduce flexibility and increase costs in variable-demand, seasonal and shift-based operations.
Key choices remain open: guaranteed-hours thresholds and reference periods; treatment of seasonal and temporary work; one to four weeks’ notice; cancellation payment rates and exceptions; and agency information duties.
Work required: HR, Operations, Finance, Legal and Procurement should supply hours, notice, cancellation, agency, systems, equality and cost evidence. Public Affairs will use it to test parameters against Northstar’s position: fair protection, proportionate implementation and preserved flexibility, avoiding disproportionate cost and loss of reasonable probation flexibility. The ask is to identify temporary needs, emergency work and seasonal peaks, and provide notice and cancellation patterns.
COO decision: endorse the evidence mobilisation and require the submission recommendation and approval paper before 25 August 2026, 22:59 UTC.