ABOUT NORTHSTAR Northstar Group plc is a large UK infrastructure and consumer services group. It is a direct employer and may also be a hirer of agency workers. Confirm location, sector selections and workforce description before completion.
OPENING POSITION Northstar supports fair worker protections and the objective of reducing one-sided flexibility. It asks DBT to ensure that regulations are targeted at genuine insecurity and do not impose disproportionate cost or remove reasonable probation and workforce flexibility. Northstar’s evidence indicates approximately 2,400 shift-based workers, around 15% on variable-hours arrangements, and approximately 400 potentially materially affected roles. These figures should be verified and disaggregated before use.
PART 1 — GUARANTEED HOURS Q1/Q3 and Q34/Q36: Support a targeted threshold within the government’s preferred 8–20 hour range, subject to Northstar evidence. Avoid thresholds that capture workers with a substantial baseline of security or ordinary full-time overtime arrangements. Q4/Q5: Support a 12-week initial reference period only if complemented by protections for seasonal and temporary demand; otherwise assess 26 weeks for roles with material seasonal variation. Q6–Q9: Prefer a longer subsequent reference period, potentially 26 weeks, or a clearly defined gap, to reduce repeated administrative burden and avoid converting short-term peaks into ongoing obligations. Ensure hours worked in any relevant period cannot be manipulated or ignored. Q10–Q17: Support a distribution test plus a minimum excess-hours test, calibrated so occasional overtime does not automatically create an ongoing guarantee, while avoiding a threshold so high that it defeats the protection. Apply proportionately to agency workers. Q18: Answer yes, subject to operational examples. Temporary need should include seasonal demand, planned infrastructure or maintenance programmes, emergency response, unusual but time-limited demand surges and other objectively evidenced temporary requirements. Legal should confirm the examples. Q19/Q23: Do not select mean or median finally until HR/Operations model the effect. A median may better reflect typical hours in highly volatile roles; a mean may better reflect total labour supplied. Seek protection against manipulation and clarity on treatment of leave, sickness, training and other non-working periods. Q20–Q25: Support a clear weekly or monthly allocation option reflecting operational patterns, with a small fixed adjustment margin and transparent controls. Do not allow flexibility to undermine predictability. Q26–Q31: Support narrowly defined exclusions and exceptional exemptions, including genuine temporary need, serious disruption and situations where the agency or another intermediary holds the necessary information and responsibility. Avoid broad exemptions that could undermine workers’ rights. Q32/Q33: Explain potential equality and operational impacts only using Northstar evidence; request guidance, implementation time and a review mechanism.
PART 2 — NOTICE AND PAYMENTS Q34/Q36: Seek a targeted threshold aligned with the guaranteed-hours threshold or a clearly justified separate threshold. Confirm through modelling. Q37/Q40: Support a reasonable presumption that reflects ordinary planning while allowing shorter notice for unforeseeable absence, safety-critical incidents, emergency infrastructure response and genuinely unpredictable demand. Confirm one- or two-week preference after Operations evidence. Q38/Q39 and Q41/Q42: Ask regulations to distinguish between employer-controlled scheduling and events outside reasonable control, and to recognise worker choice to accept or decline shifts. Q44–Q47: Support a simple short-notice framework, with a limited very-short-notice category only if it is administratively workable. Confirm timeframes after analysing cancellation data. Q48–Q52: Prefer a transparent percentage of expected earnings, subject to Finance modelling and a proportionate cap. Avoid committing to a rate without Northstar cost data. Q53/Q54: Support exceptions for worker-initiated changes, voluntary swaps, extreme weather, widespread power outage, safety-critical events, client-driven cancellations outside Northstar’s control and other objectively evidenced exceptional disruption. Legal should refine wording. Q55/Q56: Seek fair allocation of liability in agency arrangements and no duplicate recovery. Confirm Procurement and Legal position. Q57–Q60: Accept the need for effective enforcement but seek clear records, notice, cure and appeal processes before penalties apply. Assess whether the proposed 50% penalty and £100/£5,000 limits are proportionate. Q61/Q62: Add operational and equality evidence once supplied.
PART 3 — AGENCY INFORMATION Q63/Q64: Support mandatory information-sharing in principle, provided the regulations specify minimum data, timing, accuracy, data protection, responsibility for errors and a standard process. This is necessary for hirers to comply where agencies hold contractual and hours information.
CLOSING Northstar supports the policy objective but asks DBT to preserve proportionate workforce flexibility through targeted thresholds, meaningful reference periods, a workable temporary-need provision, clear exceptions, practical agency rules, implementation time, guidance and post-implementation review. This draft requires internal evidence and approval before any external use.