Employment / immigration. What does it mean to take on employees?

Transcription

1 Employment / immigration What does it mean to take on employees?

2 Contents Overview...01 Contracts of employment...01 Maximum working hours and holiday entitlement...01 National minimum wage...01 Statutory sick pay Employment protection Redundancy and dismissal Trade union activities, collective bargaining and employee representation Discrimination Part-time workers Fixed term workers Agency workers Employee Shareholders Health and safety at work Pensions Income tax and national insurance Immigration...10

3 01 Overview Taking on employees is an important step in growing a business. But what are the legal obligations on recruitment and during employment? Does an employee need a written contract and what will their holiday entitlement be? Will work permits be required? Will they be entitled to sick pay? What happens if you want to let an employee go? Knowing your rights as an employer and the rights of your employees is vital. This note is intended to provide a brief introduction to employment law issues which apply to employers setting up, or doing business, in England. You should take specific advice whenever an issue arises as employment law provisions do change regularly. Contracts of employment Under the Employment Rights Act 1996, every employee should be given a written statement of certain terms and conditions governing his employment within two months of commencing employment. An employee is also entitled to receive an itemised statement of pay and deductions with each payment of his wages or salary. Maximum working hours and holiday entitlement Workers are protected by a 48 hours maximum working week averaged over a period of 17 weeks. There are derogations for specific sectors such as transport and more general derogations including those for autonomous decision-takers such as those who manage their own time. Employers are required to keep certain records regarding the working time of their workforce. The Working Time Regulations also provide for a minimum of 28 days paid holiday each year (which may include the eight public holidays in the UK). Holiday entitlement accrues from the start of the employment. Pay in respect of holiday taken is usually based on the average pay over the 12 weeks prior to the holiday. National minimum wage All workers benefit from the National Minimum Wage ( NMW ). The genuinely self employed and people under the age of 18 are outside of the scope of the NMW. The basic rate for payment of the NMW is currently 6.31 per hour for workers aged 21 and over. Young workers aged between 18 and 20 are entitled to the NMW at the lower rate of 5.03 and those aged under 18 are entitled to a rate of 3.72 and apprentices aged under 19, or in the first year of their apprenticeship, to Employers are required to keep full records of payments to workers. Basic gross pay, together with incentive and performance pay, bonuses and gratuities, paid through the pay-roll count towards the NMW. The NMW is not paid during lunch breaks or rest periods or when a worker is absent, for example, during a period of holiday or sick leave. Workers can bring a claim through the courts or employment tribunals for non-payment of the NMW. They can also make claims for unfair dismissal or victimisation if the employer sacks or takes action against them to prevent them from being paid the NMW. Companies can be guilty of criminal offences by failing to comply with their duties in relation to the NMW.

4 02 Statutory sick pay All employees (other than some specified exceptions) who are absent from work due to illness or injury are entitled to receive Statutory Sick Pay from their employer for up to 28 weeks in a rolling three-year period. The provisions operate when the employee is absent for at least four consecutive days. Shorter absences would normally, but need not, be paid as salary. To be eligible to receive Statutory Sick Pay an employee must notify his absence to his employer and supply evidence of illness. The level of Statutory Sick Pay is set by statute and is regularly revised. From 6 April 2014 it stands at per week but many employers make up any salary shortfall at least for a specified period of illness. Employers may not contract out of the Statutory Sick Pay provisions and cannot require employees to contribute towards payments. Non-compliance with the Statutory Sick Pay provisions can amount to a criminal offence by an employer. Employers are required to keep records for Statutory Sick Pay purposes. Employment protection The Employment Rights Act 1996 provides for employee protection in general areas, the most important of which are discussed below. Minimum notice An employee is entitled to one week s minimum notice after one month s continuous service. After two years service he becomes entitled to two weeks notice which then increases by one week for each year of service, up to a maximum of 12 weeks notice after 12 years service. These statutory notice requirements apply in the absence of specific contractual notice provisions or where the contractual notice is less than the statutory minimum. The agreed contractual notice must be given if that is the longer period. As a general guideline, employers in the UK often agree to give most employees at least one month s notice from the start of their employment and senior employees between three and six months notice. Suspension on medical grounds An employee who is suspended from work by his employer on medical grounds, in compliance with any law or regulation concerning the health and safety of workers, may be entitled to be paid by his employer while he is suspended, for a period not exceeding 26 weeks. Pregnancy All female employees are entitled to 52 weeks maternity leave. This applies regardless of length of service. During the 52 weeks of maternity leave the contract of employment continues and the employee must continue to receive all her contractual benefits except commission, contractual bonus, wages and salary. Those employees who have at least 26 weeks continuous service with the employer up to and including the 15th week before the Expected Week of Childbirth (EWC) are entitled to 39 weeks statutory maternity pay (SMP). Statutory maternity pay currently stands at 90% of the employee s average earnings for the first six weeks of maternity leave, dropping to for 33 weeks thereafter. Most of the cost of statutory maternity pay can be recouped from the state. Many employers make payments in addition to this statutory minimum. A woman returning to work within the periods set out in the relevant legislation must be reinstated in her former position or, if she takes additional maternity leave (the second 26 weeks), she must be given an equivalent job, unless the employer can bring itself within certain statutory exemptions.

5 03 All pregnant women are entitled to reasonable time-off to attend ante-natal clinics. Parents may take up to 18 weeks unpaid parental leave per child up to the age of five years (18 years if the child is disabled) in blocks of up to four weeks per year. Dismissal on grounds of pregnancy is automatically unfair and would also amount to sex discrimination. Adoption leave and pay Adoption leave and pay rights are available to parents and civil partners with 26 weeks continuous service who adopt a child up to 18 years of age where the child is newly placed. To qualify for statutory adoption pay, an employee must have been continuously employed for at least 26 weeks, ending with the week in which the child s adopter is notified of being matched with the child. Eligible employees will be entitled to 52 weeks ordinary adoption leave. Statutory adoption pay is paid for 39 weeks at the rate of 90% of the employee s earnings for the first six weeks and for 33 weeks thereafter. Most of the cost of statutory adoption pay can be recouped from the state. Paternity leave and pay Eligible employees can currently take two weeks paid ordinary paternity leave within eight weeks of a child s birth in blocks of a week. To be eligible for ordinary paternity leave, an employee must have 26 weeks continuous service ending with the 15th week before the EWC, have or expect to have responsibility for the upbringing of the child and be the biological father of the child or married to, or the civil partner or the partner of the child s mother. Eligible employees are also able to take up to 26 weeks additional paternity leave. To be eligible for additional paternity leave (APL), an employee must fulfil the criteria in the paragraph above and, in addition, must have continued in employment with the same employer up to the date on which they intend to take APL and the mother (or adopter if applicable) of the child must return to work having not exhausted their entitlement to statutory maternity or adoption leave. The baby must be at least 20 weeks old before the employee s additional paternity leave begins and some of the leave may be paid if the mother has returned to work before the end of her SMP period. Paternity pay is currently per week or 90% of the employee s average weekly earnings if this is less. Flexible working Employees with at least 26 weeks continuous employment who have the appropriate parental relationship with, or are married to the partner or civil partner and have responsibility for the upbringing of, a child under 17, (or 18 if disabled) or an adult relative, are able to make an application to work flexibly by altering the terms of their contract of employment with respect to: the number of hours worked; the times required to work; where work is carried out (i.e. to work from home). An employer must take the request seriously by following a statutory procedure in dealing with the application. An employer may refuse the application on objective business grounds, these being:

6 04 the burden of additional costs; detrimental effect on ability to meet customer demand; inability to re-organise work among existing staff; detrimental impact on quality; detrimental impact on performance; insufficiency of work during the periods the employee proposes to work; and planned structural changes. An employee may bring a claim in the Employment Tribunal if an employer fails to follow the procedure or bases its decision to refuse an application for flexible working not on one of the objective business grounds or on incorrect facts. Right to request time off for study or training Employees with at least 26 weeks continuous employment also have a statutory right to request time off to undertake study or training. This applies to employers with 250 or more employees. The procedure is similar to that used in flexible working requests. Deduction from wages An employer cannot deduct any amount (for example, loan repayments) from an employee s salary unless that deduction is authorised by law or by the employee in writing. Redundancy and dismissal An employee with two years continuous service has a right to compensation if he is dismissed because of redundancy, even if there is not an unfair dismissal (see below). Redundancy payments are calculated on a sliding scale depending on age and length of service. The maximum redundancy payment is 1½ weeks pay up to a maximum of 464 per week for each year of employment up to a maximum of 20 years (this amounts to a maximum payment of 13,920). An employee who is offered suitable alternative employment and unreasonably refuses such employment is not entitled to a redundancy payment. Under the Employment Rights Act 1996, compensation may be payable to employees who have completed a qualifying period of two years continuous service at their date of dismissal if they are unfairly dismissed. The period of service is usually only continuous where it is with the same employer, however it may also be continuous where there is some connection between the two employers, for example, they are associated or there has been a business transfer. Complaints of unfair dismissal are made to an Employment Tribunal. The concept of unfair dismissal is well established in the UK. Statute sets out five reasons for dismissals which are potentially fair as follows: capability; conduct; redundancy; continued employment would contravene any restriction imposed by an enactment; and some other substantial reason. A dismissal for any other reason would be unfair. Prior to 6 April 2011, retirement used to be a fair reason for dismissal. For the dismissal to be fair not only must the reason for dismissal be one of the above five fair reasons, but the employer must also follow a fair procedure in reaching the decision to dismiss. If either employer or the employee unreasonably fails to follow the code of practice on disciplinary and dismissal procedures, compensation may be increased or decreased by up to 25%, subject still to the unfair dismissal cap of 76,574.

7 05 Employers which choose to have a compulsory retirement age from April 2011 need to objectively justify it under the Equality Act If employees are found to have been unfairly dismissed they may be compensated by a basic award and a compensatory award. The basic award is calculated on the same basis as a redundancy payment. The current maximum compensatory award for unfair dismissal is 76,574. This may be paid in addition to any sums due in respect of an employee s period of notice. In theory, the right not to be unfairly dismissed is intended to protect the job of the employee. An employee who has been unfairly dismissed therefore has the right to request reinstatement or re-engagement by his employer. In practice, this right is rarely granted by Employment Tribunals. Where the right is granted, the employer may be exposed to an award for earnings which would have been paid which is not limited by the maximum figures for the basic award and compensatory award referred to above. In the case of multiple dismissals, there are various notification and consultation procedures which must be satisfied where 20 or more employees are to be dismissed within a period of 90 days or less. Trade union activities, collective bargaining and employee representation There are recent requirements in the UK that an employer must recognise a trade union for collective bargaining purposes where certain criteria are met. There are also general requirements to inform and consult with employees, or appropriate representatives, in the case of collective dismissals (dismissals of 20 or more employees) or in the case of a transfer of an undertaking. The detailed requirements for information and consultation are beyond the scope of this memorandum, but an employer failing to comply with its obligations may be exposed to obligations to pay compensation. A failure to inform and consult may also make it more likely that there will be a finding of unfair dismissal (see Redundancy and Dismissal). Collective bargaining agreements are relatively uncommon in the UK and in any event do not have the same status and authority as in many other European countries. Generally speaking, collective bargaining agreements are not intended to have legal effect unless there is a specific statement to the contrary in the agreement. However, it is possible for collective bargaining arrangements to be included in individual employees contracts of employment, whether expressly (verbally or in writing) or as a result of custom and practice. Where there have been negotiations or agreements with employee representatives in any business, the situation may need careful examination to establish whether there are binding individual contractual rights in respect of this. It is unlawful to refuse a person employment on the grounds of membership or non-membership of a trade union. Peaceful picketing during industrial action is generally allowed but must in general be restricted to the employees own place of work. Neither individuals nor unions can be sued for properly constituted strike action. The European Works Council Directive ( EWCD ) applies to companies that: employ more than 1,000 employees within the European Economic Area; and employ 150 of those in each of two member states.

8 06 The EWCD states that employers should inform and consult their employees in relation to a wide range of business related decisions taken by the employer. The EWCD has been implemented in other member states for some time. Consequently many UK companies have had to take steps to comply with the EWCD as they employ significant numbers of people in member states already covered by the directive. Undertakings with 50 or more employees are obliged to inform and consult staff who request it. Employees have the right to be informed and consulted about the business they work for. This can include potential changes to employment and developments affecting the employer s activities and economic situation. However, an employer is not obliged to do anything unless it receives a valid request from at least 10% of the workforce. If it receives a valid request, the employer must begin negotiations with a view to introducing a system of information and consultation, unless it already has such an agreement in writing. If there is no suitable preexisting agreement, the employer and the employee have six months to negotiate and conclude an agreement with employee representatives. If a negotiated agreement can not be concluded, a default systems kicks in, in which case a statutory agreement applies. Discrimination Protected characteristics It is unlawful for an employer to discriminate against employees, workers or applicants for employment because of: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race (including colour, nationality or ethnic or national origin); religion or belief; sex; or sexual orientation. There are different types of discrimination, as described below. Not all types of discrimination are unlawful in respect of each protected characteristic. Direct discrimination It is unlawful for employers to treat a person less favourably than others because of any protected characteristic they possess. Except in the case of marriage and civil partnership, or pregnancy and maternity, it is also unlawful to directly discriminate against a person because either they are perceived to possess a protected characteristic, or they associate with another person who possesses any protected characteristic. Unlike other forms of direct discrimination, direct discrimination because of age is permitted if it can be justified objectively as a proportionate means of achieving a legitimate aim. Indirect discrimination Indirect discrimination takes place where a provision, criterion or practice which applies to all employees but disadvantages those with a particular protected characteristic (except pregnancy and maternity) for example, the exclusion of part-time workers from pension schemes, which would be likely to have a disproportionate effect on women. Such a rule will be indirectly discriminatory unless it can be objectively justified as a proportionate means of achieving a legitimate aim.

9 07 Harassment Harassment is unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. Individuals can complain of behaviour they find offensive even if it is not directed at them, they do not have that protected characteristic or are perceived to do so or associated with a person who does. Employers can be liable even if they do not employ the harasser if the employer is aware that the behaviour has happened at least twice before and taken no steps to prevent a recurrence. This type of discrimination does not apply to marriage and civil partnership or pregnancy and maternity. Victimisation It is also unlawful to victimise an employee because they have made or supported a complaint or grievance relating to an instance of discrimination because of a protected characteristic. Employers have to take reasonable steps, including modifying premises, to accommodate the needs of disabled employees or potential employees. It is also unlawful to discriminate against a disabled person because of something arising in consequence of their disability (for example, a tendency to make spelling mistakes arising from dyslexia) unless that less favourable treatment can be objectively justified. There is no limit on compensation for any of the above categories of discrimination, unlike the general limit in connection with unfair dismissal. An employer will be liable for any acts of discrimination committed by its employees during the course of their employment, whether or not it was done with the employer s knowledge or consent, unless the employer can show it took such steps as were reasonably practicable to prevent the conduct. Part-time workers The contractual terms and conditions on which an employer may engage a part-time worker are affected by legislation which aims to prevent part-time workers terms and conditions being less favourable than those of comparable full-time workers in relation to: hours of work; promotion; rates of pay; overtime; profit sharing / share option schemes; contractual sick pay / maternity pay; access to occupational pension schemes; access to training; redundancy; other contractual benefits; and time off work. In some cases, an employer may be able to justify the different treatment on objective grounds, (for example, if it can show that the different treatment is necessary and appropriate to achieve a legitimate business objective). Legal advice should be sought if an employer intends to offer different treatment to a part-time worker to assess whether the reason for the different treatment is likely to fall within the scope of this exception.

10 08 Fixed term workers Employees on fixed term contracts or hired to complete a specific project or task cannot be treated less favourably than comparable permanent employees on the grounds they are fixed term employees, unless this is objectively justified. This right applies both in terms of contractual terms (including pay and pensions), and to any other detrimental treatment by an employer. The use of successive fixed-term contracts is limited to four years, unless the use of further fixed term contracts is justified on objective grounds. If a fixed term contract is renewed after the four-year period, it will be treated as a contract for an indefinite period. Agency workers Agency workers have the right to the same pay and other basic working conditions as equivalent permanent staff after a 12-week qualifying period and access to collective facilities and to information about employment vacancies from day one of their assignment. Employee Shareholders Employee shareholder (rather than simply employees who have also a shareholding in their employer) is a specific form of employment status which came into force on 1 September The specifics of employee shareholder status are beyond this memorandum but, briefly, an employee shareholder is an individual who, having received independent legal advice, has agreed with the employer that he or she will be an employee shareholder and in return has been given fully paid up shares in that company (or its parent) worth a minimum of 2,000. Employee shareholders are still employees. They do not have certain statutory rights of employees, including the right to claim unfair dismissal or to receive a redundancy payment, but they retain many key rights including protection against discrimination. For more information please see the Taylor Wessing brochure on employee shareholders. Health and safety at work An employer is under a general direct duty to have regard to the safety of all employees. The employer is also liable for accidents caused by acts of employees where the employees were acting in the course of their employment. An employer owes specific statutory duties to its own employees, members of the public who are affected by the activities of the employer and other people s employees working on the employer s premises. The Health and Safety at Work Act 1974 imposes certain duties on employers to safeguard the health and safety of employees. There may be civil liability and criminal liability for failure to observe health and safety responsibilities. The officers of a company in breach of the legislation may be personally liable, in addition to the company itself. An employer is obliged to maintain insurance, under one or more approved policies with an authorised insurer, against liability for bodily injury or disease sustained by employees and arising out of and in the course of their employment. There are detailed regulations setting out specific requirements for employers to assess risks to health and safety at work, and sometimes members of the public, and for the publication of written statements of an employer s health and safety policy and for employees to be notified of general matters under health and safety law. Employees should also be informed of adequate

11 09 first aid provisions. This is a very complex and detailed area of law and specific advice should be sought. Smoking in enclosed workplaces in England is not permitted. Pensions Under pensions legislation which began to be phased in on and from 1 October 2012 (depending, broadly, on the size of the employer s HMRC PAYE listing as at 1 April 2012), employers are legally obliged to: automatically enrol certain workers into pension arrangements and make minimum contributions with respect to those workers; and provide access to pension arrangements for certain other types of worker. The date from which these legal requirements first apply to an employer is known as the Staging Date. This regime is generally known as auto-enrolment. The legal obligations are complex and there are a number of options available to employers as to how to comply with them. Employers who start to make payments of salary under PAYE after 1 April 2012 will have a Staging Date on or after 1 May 2017 (the actual date depending on when those payments start). Other than as described above, employers are not usually obliged to provide a pension scheme for employees or to make contributions to a personal pension plan on behalf of their employees, but many choose to do so. Size of and cost to the employer are important factors in the decision, as is market practice. In practice, however, it is likely that whatever pension arrangements an employer puts in place will be dictated by what it is legally obliged to provide under the requirements described above. Income tax and national insurance An employer is primarily responsible for the deduction of an employee s income tax and national insurance contributions from the employee s salary and for the payment of these sums to HM Revenue & Customs on a regular basis. This system is known as Pay As You Earn, or PAYE. The employer must register with the appropriate authorities for PAYE. If the employer does not make these deductions from salaries and payments to the relevant authorities, the employer may be subject to liability for the sums which ought to have been deducted in respect of the amounts paid and for penalties and interest on the unpaid sums. An employee has a personal income tax allowance for which no income tax need be paid. This is currently 10,000 for the tax year 2014/2015. However, the from personal income tax allowance is reduced for those with incomes over 100,000, tapering down to zero. The rates of income tax for the year 2014/2015 are as follows: 0-31,865 20% 31, ,000 40% Over 150,000 45% In addition, an employer will be obliged to pay employer s national insurance contributions at a flat rate of 13.8% of the salary (above a minimum limit). In addition there is a liability for the employer to deduct employee s national insurance contributions from the employee s salary. Broadly the employee s national insurance contributions are at a rate of 12% for salary between 153 to 805 per week and at a flat rate of 2% above 805 per week.

12 10 Immigration Introduction Particularly given the global economic climate in recent years a number of countries, including the UK, have tightened their immigration laws. With a talent shortage in certain sectors and more complex rules, arranging UK work visas for key non-european hires is an important HR issue for UK employers. Most citizens of the European Economic Area (EEA) have the right to work in the UK without restriction. Some non-eea citizens may be able to start work in the UK immediately if they have a general UK visa already, such as a partner/spouse visa or a personal skilled Tier 1 visa. If not, they will need a new work visa. Business travel Non-European employees frequently want to travel to the UK for business reasons. They may visit the UK, but citizens of certain countries are required to apply for a visit visa prior to travel (they are known as visa nationals ). In all cases, the visitor must only perform permissible business activities (e.g. business meetings) while in the UK and only come to the UK for short trips, even though a legally compliant visitor can technically stay in the UK for up to six months cumulatively in any 12 month period. It is important that the business visitor does not perform productive work and does not appear to the UK authorities to be working. Visa Applications Generally, initial visa applications must be made to the British Embassy/Consulate in the applicant s country of nationality or residency (if different) visitors to the UK cannot apply in the UK for full visas. Family members of applicants getting Tier 1 or Tier 2 visas can obtain dependants visas too and the applicant s qualifying partner or spouse can work in the UK without restriction. Sole Representative Visa This visa is only available for an overseas business that does not yet have a presence in the UK. It allows one senior and established employee of the overseas entity who owns 50% or less of the business to come to the UK to set up and run a new wholly owned UK subsidiary or registered UK establishment. Prior to applying for this visa there must not be any trading presence or employees already in the UK, although a shell company without employees is permitted. Sponsor Licence A UK employer that wants to hire a non-eea citizen on a work visa will need to apply for a sponsor licence so that it can sponsor Tier 2 work permits. It cannot do this until the UK office has at least one employee on the ground working full-time in the UK to oversee and take responsibility for the licence. This person can be any nationality provided that he/she has the right to work in the UK for that business. There are minimum skill and salary levels for all Tier 2 visas and other eligibility and compliance conditions for the UK employer.

13 11 Tier 2 General Visa A sponsor licence is required before an employee can apply for this visa. Tier 2 General is used for new non-eea hires into the UK business, for example the recruitment of an employee currently sponsored on a Tier 2 General visa with another UK employer. It is particularly beneficial for migrants wanting to have the option of UK permanent residency after five years, as this is not available to Tier 2 ICT employees. However, the sponsor may have to go through additional process and delay, because often it must advertise the role to the resident workforce for at least 28 days and request permission from the UK s immigration authorities to hire against the UK s immigration cap if the employee is resident outside the UK. Tier 2 Intra Company Transfer (ICT) Visa Once a sponsor licence has been obtained, an overseas office linked to the UK business can transfer employees (usually with at least 12 months employment service) to the UK on Tier 2 ICT visas so that they can work for the UK entity. Tier 2 ICT visas do not lead to permanent residency and the total visa duration is capped. The benefit of this visa is that the UK entity will be exempt from having to advertise the positions in the UK and from the UK s immigration cap. This is the most flexible and usual work visa route for international businesses. Tier 1 Entrepreneur Visa This is a personal visa. No sponsor licence is needed and therefore it can be arranged faster than a Tier 2 visa. The visa is ideal for individuals wanting ownership or involvement with a UK business. The visa requires personal investment of at least 200,000 ( 50,000 in some limited cases) into a new or existing UK business, registration as self-employed or a UK director and creation of two or more full-time jobs for settled workers lasting at least 12 months each. Work is permitted for the business that receives the investment, but unlike a Tier 2 visa, work is not a condition of the visa. As part of the visa application process, the UK immigration authorities will assess the entrepreneur s prior track record and future plans in a genuine entrepreneur test. Other visas There are other temporary and long-term UK visa options, which will depend on the applicant s circumstances and objectives. Advice should always be sought to determine the appropriate visa route in each case. Compliance The UK immigration authorities are focusing on enforcement and are targeting rogue employers or those perceived to abuse the system. Penalties for employers who employ illegal workers include a civil penalty of up to 20,000 per illegal worker plus a criminal offence of knowingly employing illegal workers, which attracts a custodial sentence of up to two years. As a result, the checks made on employers and individuals applying for UK visas are thorough, and there limited rights of appeal. A UK employer that holds a sponsor licence is subject to additional specific obligations, including in relation to record keeping and reporting duties. UK Visas & Immigration has the right to conduct unannounced visits/audits on sponsors at any time, so it is essential for the UK business to conduct regular immigration compliance health checks. UK Visas & Immigration regularly updates the immigration rules and changes can come with little or no notice. Immigration advice should always be sought before an application is made. April 2014

14 Europe > Middle East > Asia Taylor Wessing LLP 2014 This publication is intended for general public guidance and to highlight issues. It is not intended to apply to specific circumstances or to constitute legal advice. Taylor Wessing s international offices operate as one firm but are established as distinct legal entities. For further information about our offices and the regulatory regimes that apply to them, please refer to: NB_001035_03.14