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KIER Engagement Brief
nutral.
Internal · Apr 2026
Engagement Overview · Kier Group plc

Work delivered to date, and what comes next.

A consolidated view of Nutral and Workforce Assured's engagement with Kier across contingent labour, supply chain audit, and compliance — plus the replication opportunity modelled on our Balfour Beatty programme.

Client Kier Group plc
Relationship Start November 2024
Brief Owner Alex Gosney · CEO, Nutral
Status Active · Expanding

Workstreams at a glance

Neutral MSP pitch — NRNN & Transportation Delivered
Workforce Assured accreditation — logistics PSL Live
Site worker interviews Delivered
Sub-contractor composition pilot Live
Payslip audit — London logistics Delivered
Construction / Hays — MSP opportunity Open
01

Engagement snapshot

Headline numbers across the Kier engagement to date — spanning payslip audit, supplier accreditation, and the supply chain composition pilot.

Payslips audited
367
55 workers across 5 logistics subcontractors · Oct–Nov 2025
CIS concentration
84%
Logistics workforce engaged CIS self-employed — high CCO concentration
CIS below £16.50/hr
71%
Below Workforce Assured recommended minimum · 40% at £14 or less
Mgmt systems outcome
1P · 2R · 2F
1 Pass (Avondale) · 2 Referred (Madigan, Munnelly) · 2 Fail (Alandale, O&B)
02

Key Kier contacts

Our three active relationship owners inside Kier. Expansion into Construction / Hays will need an additional sponsor sourced through Gerard.

Executive Sponsor
Gerard Cox
Procurement Director, Kier Group
Owns the group-level view on contingent labour procurement. Primary commercial counterpart for the neutral vend conversation and the expansion narrative across divisions.
Group Procurement MSP Decision Maker
Tax & Risk
Stuart Mulvaney
Employment Tax, Kier
Engaged on CIS, CCO and JSL exposure arising from the logistics audit findings. Natural sponsor for expanding payslip audits across Kier's other sub-contract packages.
Employment Tax CIS / CCO JSL April 2026
Operational Lead
Richard Grey
Supply Chain Lead — London, Kier Construction
Day-to-day operational sponsor for the London logistics audit programme. Route-in for broader London construction supply chain and sub-contract package work.
Construction London Supply Chain
03

Workstreams delivered to date

Five distinct pieces of work have shaped the relationship. Click through each tab for the detail, scope, and outcome.

Delivered11 Nov 2024
ForumBeale & Company, London EC4N
DivisionsNRNN & Transportation
Kier LeadLindsay Cooper

A true neutral-vend proposition for Kier's blue-collar labour

Invited pitch alongside a shortlist of MSP providers. Our response positioned the Nutral model — single source-to-pay platform, independent from agency ownership, combining VMS, accreditation audit, and the Workforce Assured standard.

The addressable population at the time was 903 workers across Transportation (352) and NRNN (551), with only 188 per month actually sourced through the existing model — leaving significant leakage outside managed supply. Our proposal was scoped against both divisions with a phased 12-week implementation timeline.

Where we netted out

NRNN was the primary operational focus following the pitch. Construction (the Hays-managed contingent labour book) remains an active opportunity for replication — see the Next Steps section for routes in.

What we submitted
  • Neutral vend model deck — "Building for a Sustainable World"Deck
  • ITT workbook responses — Quality, Systems, LegislationITT
  • Labour lifecycle: future state visualisationProcess
  • Kier "How it can work" org model with nutral roleModel
  • Sisk labour transformation case studyProof
  • Labour compliance SLA frameworkGovernance
USPs we led with
  • Commercial neutrality — no agency ownershipTrust
  • Workforce Assured as the standard for Tier 2Audit
  • End-to-end source-to-pay on our VMSTech
  • 1,170t CO2e offset against worker commuteESG
ScopeAll 5 logistics subcontractors
Initial auditsAug – Oct 2025
ReassessmentsNov 2025 – Mar 2026
Outcomes1 Pass · 2 Referred · 2 Fail

Management systems audits against the Workforce Assured standard

Each of Kier's London logistics subcontractors was audited at head-office level against the Workforce Assured accreditation standard between August and October 2025, with reassessments running from November 2025 through March 2026. The audit covers policies, processes and governance across temporary labour: ethical labour, tax compliance, supply chain transparency and onboarding controls.

The management systems audit stream sits alongside the Kier-specific payslip audit stream — together they give Kier both a policy-level and a worker-level view of supplier compliance. Intermediary structures (Stonebridge, Rosewood Tradesman, Bishopsgate, Fairmead, NASA, Pendulum, Navigate Contracting, Ardent Tide, Omnia) and connected-party ownership concerns were identified here before being evidenced in the payslip audit.

Why this matters

With Joint & Several Liability live from April 2026, the accreditation layer is the mechanism by which Kier documents its reasonable-prevention procedures for Corporate Criminal Offence and the new CIS fraud regime. It is the foundation the payslip audit sits on top of.

Accreditation outcomes
  • Avondale Construction Ltd.Pass
  • Madigan Gill Logistics Ltd.Referred
  • Munnelly Support Services Ltd.Referred
  • Alandale Logistics Ltd.Fail
  • O'Neill & Brennan Site ServicesFail
Ongoing audit cadence
  • Weekly — Basic Worker Audit98% SLA
  • Monthly — Enhanced Worker Audit10–100% dip
  • Quarterly — Agency & Umbrella Deep Dive100%
  • Annual — Workforce Assured full audit100%
MethodOn-site face-to-face
SitesLondon logistics deployments
CoverageCross-supplier sample
TriangulatesPayslip & accreditation

Workforce voice — the ground-truth layer behind the audit

Site worker interviews were conducted in-person on Kier logistics deployments to triangulate what the payslips and accreditation audits were telling us about the Tier-2 intermediary supply chain.

The interview programme gave visibility on pay practices as experienced by workers themselves — umbrella margins, admin fees, pay type (CIS vs PAYE), onboarding route and supervision. These findings directly informed the framing of the October–November 2025 payslip audit and the risk narrative that followed.

Value to Kier

This is the evidence base that turns a compliance programme into a genuine modern slavery, CCO and worker-welfare control — the layer that regulators and investors increasingly expect to see.

What we asked
  • Who pays you and who's on your payslip?Chain
  • Are you PAYE, CIS, or something else?Status
  • What rate were you offered vs received?Rate
  • Have you signed agency terms and KID?Onboarding
  • Who directs your work on site?SDC
  • How are grievances raised?Welfare
ScopeSub-contractor workforce composition
FormatData collection pilot
StatusLive — feeding expansion case
OwnerRichard Grey + Nutral

Mapping the true composition of Kier's sub-contract workforce

The composition pilot gives Kier the first real view of its sub-contract workforce as a whole — not just directly engaged contingent labour, but the downstream workforce delivering sub-contract packages.

Composition data covers engagement model (PAYE, CIS, PSC, umbrella), role/skill mix, intermediary supply chain, and geographic distribution. The pilot is proving the methodology before Kier rolls it out as a standard contractual requirement across packages.

Why this is strategic

The composition pilot is the dataset that unlocks a much bigger conversation — with Stuart Mulvaney on tax exposure, with Gerard Cox on procurement design, and with Richard Grey on operational delivery. It's the evidentiary spine of the expansion play.

Pilot outputs
  • Workforce composition submission templateTemplate
  • Intermediary declaration requirementContract
  • Ownership structure disclosureJSL
  • Role classification framework (CIS risk)Framework
  • Supply chain visualisation outputsMI
Blockers we're clearing
  • Supplier data submission qualityIn progress
  • Standardising intermediary fieldsIn progress
PeriodOct – Nov 2025
Payslips367 reviewed
Workers55 across 5 suppliers
Method100% request · HMRC cross-ref

100% payslip request across the London logistics supply chain

Kier engaged Workforce Assured to audit payment practices across its five London logistics subcontractors. Payslips, job roles, and HMRC submissions (RTI, CIS, Onshore Intermediaries) were cross-referenced to validate the data and assess CIS suitability.

The audit landed against a sharpening legislative backdrop: Joint & Several Liability for unpaid tax (April 2026), the CIS fraud regime (April 2026) with five-year loss of gross status, and heightened HMRC activity on Corporate Criminal Offence in construction.

The headline finding

84% CIS usage in a predominantly low-skilled logistics workforce, combined with 40% of CIS workers paid at rates incompatible with genuine self-employment, creates a compound CCO and CIS-fraud exposure that sits with the contracting chain — including Kier.

Deliverables produced
  • Executive payslip audit report — 5 supplier chaptersReport
  • Top 5 risks frameworkRisk
  • Six-point recommendations to KierRecs
  • CIS rate-card minimum guidance (£16.50)Policy
  • Connected-party disclosure requirementContract
Risk signals flagged
  • Alandale <> Rosewood Tradesman common ownershipJSL
  • Munnelly <> Bishopsgate joint ownershipJSL
  • Welfare / waste operatives placed on CISCCO
  • Admin fees > 20% of gross pay (short weeks)Ethics
04

Compliance audit — deep dive

Two sequential audit streams across the five London logistics subcontractors. Management systems audit at head-office level (Aug–Oct 2025, reassessments Nov 2025–Mar 2026), followed by a Kier-specific payslip audit (Oct–Nov 2025). Together they deliver a policy-level and a worker-level view of supplier compliance.

Top 5 risks identified
Risk 01

High CIS concentration in low-skilled logistics

84% of the audited workforce on CIS self-employment in roles where genuine self-employment is hard to defend.

Risk 02

CIS rates below self-employment viability

40% of CIS workers paid at levels where statutory benefits and pension would push pay below NMW.

Risk 03

LLW breaches via intermediary fees

15 workers dropped below £13.85 LLW once umbrella margins or admin fees were applied by intermediaries.

Risk 04

Connected-party intermediary structures

Alandale–Rosewood and Munnelly–Bishopsgate common ownership creates direct JSL exposure for Kier.

Risk 05

Combined CCO vulnerability

CIS + low pay + intermediary dependency compound into credible Corporate Criminal Offence exposure.

Audit scorecard — combined management systems & payslip audit
Supplier Mgmt audit Audit date / Reassessment Crit Major Minor Obs LLW breaches Key risk theme
Alandale Logistics Ltd. Fail Sep 25 / Mar 26 0 4 3 1 11 Connected intermediary; below-min pay; CIS fraud risk
O'Neill & Brennan Site Services Fail Oct 25 / Jan 26 0 4 2 2 0 Hybrid model; £5 deduction; entity structure
Madigan Gill Logistics Ltd. Referred Sep 25 / TBA 0 2 4 3 1 HMRC payroll insolvency; CIS misclassification
Munnelly Support Services Ltd. Referred Aug 25 / TBA 0 1 3 0 1 Connected intermediary (Bishopsgate); welfare CIS
Avondale Construction Ltd. Pass Sep 25 / Nov 25 0 0 0 0 3 All conformances resolved; Fairmead margin concern
Supplier-level findings
Madigan Gill
via Stonebridge Contracting
Workers12
Payslips69
CIS9
PAYE3
Alandale Logistics
via Rosewood Tradesman
Workers17
Payslips119
CIS16
PAYE1
Munnelly Support
via Bishopsgate
Workers7
Payslips56
CIS6
PAYE1
Avondale
via Fairmead
Workers7
Payslips42
CIS7
PAYE0
O'Neill & Brennan
Stonebridge / NASA / Pendulum
Workers10
Payslips87
CIS6
PAYE4

Alandale Logistics Ltd.

RISK: HIGH

Management systems audit — outstanding issues
    Payslip audit — Kier worker findings
      Recommended action for Kier
      05

      The MSP pitch — and where we go from here

      Where the November 2024 pitch landed, what's live today, and the divisions still open for a replication of the Sisk / Balfour Beatty model.

      The Pitch · Nov 2024

      True neutral vend for Kier's contingent labour

      Invited pitch to provide neutral vendor management across Kier Transportation (Highways, Rail, Aviation, D&E) and Natural Resources, Nuclear & Networks (Water, Energy, Nuclear, Environment).

      Our submission led on commercial neutrality, single-platform source-to-pay, and the Workforce Assured standard as the compliance layer. Sisk was the featured case study.

      The ITT and our submission are archived — a strong foundation to carry forward for the divisions that remain open.

      Addressable population at pitch

      903 contingent workers across two divisions

      Data from the November 2024 ITT pack. A small share was already running through a sourcing model; the majority was outside, representing the leakage and compliance gap the neutral vend model was designed to close.

      352
      Transportation contingent workers
      551
      NRNN contingent workers
      188 / mo
      Sourced via existing model
      715
      Sourced outside — the gap we targeted
      Live Operation

      NRNN Division

      Primary operational engagement coming out of the pitch. Water, Energy, Nuclear, Environment — the division we are delivering against.

      Priority Target

      Kier Construction — Hays incumbent

      Blue-collar labour across Kier Construction currently runs through Hays. This is the division we want to replicate what's been done at Balfour Beatty. Gerard Cox is the route in.

      Live Audit

      Construction — London Logistics

      Sub-contractor payslip audit, accreditation, composition pilot. Toehold into Construction; expansion case already evidenced.

      06

      Case study — Balfour Beatty replication

      The blueprint we've built across Balfour Beatty UKCS, TEPMP, and BBV is the natural model to replicate inside Kier Construction. The asset list, the evidence, and the commercial shape are all already in place.

      A working, delivered blueprint for Tier-1 workforce MSP — now ready to replicate.

      Across Balfour Beatty's UK Construction Services, TEPMP, and the BBV joint venture, Nutral has built, operated and iterated the exact neutral-vendor MSP model Kier's Construction division needs — with full workforce analytics, WTR compliance, overtime deep dives, and April 2026 JSL-ready contract architecture.

      UKCS·TEPMP·BBV JV·Regional Civils
      3× BU
      Board packs delivered (UKCS / TEPMP / BBV)
      17,630+
      Rate cards reviewed for NMW compliance
      32 slides
      Regional Civils regional breakdown pack
      5 agencies
      Supplier packs (Hercules, VGC, Fortel, Reliable, McGinley)

      What we've built at BB

      A fully operational neutral-vendor MSP across the Tier-1 UKCS, TEPMP and BBV divisions, with a consolidated supplier base, harmonised rate cards, and a live payslip audit capability operating against 17,630+ rate cards.

      • Workforce analytics: WTR compliance, overtime deep dives, working time analysis
      • JSL / ITEPA 2003 Ch.11 contract architecture ready for April 2026
      • TSA variation clause 5.1A — connected persons prohibition
      • RequiDex VMS delivering continuous compliance MI
      • 592-worker data breach response — full contractual and regulatory handling

      Why it maps onto Kier

      The legislative and operational environment is identical. Kier Construction carries the same CIS, CCO and JSL exposure we've already designed around at Balfour Beatty — and the audit findings from the London logistics programme are the exact trigger that drove BB's contract redesign.

      • Same April 2026 JSL and CIS-fraud exposure
      • Same intermediary and connected-party patterns
      • Same procurement — supply chain — tax triangle (Cox / Grey / Mulvaney)
      • Same need for evidenced audit cadence, not just policy
      • Same opportunity to harmonise rates, margins, and governance

      The replication play

      Kier Construction — currently managed via Hays — is the direct equivalent. The pitch-to-programme journey we ran at BB, and before that at Sisk, is the template: two-stage tender, harmonised commercial, VMS-led MSP, and Workforce Assured as the standard.

      • Stage 1: composition pilot expands to Construction division
      • Stage 2: supplier audit layer — ethical, tax, compliance
      • Stage 3: neutral-vend MSP proposal to Construction leadership
      • Commercial comparables — BB programme benchmarks ready
      • Sisk and BB referenceable case studies — both deliverable today
      07

      Next steps

      Three concrete moves to turn the Kier engagement into a group-level MSP relationship.

      Move 01

      Convert the audit findings into contractual change

      Work with Stuart Mulvaney to codify the six payslip-audit recommendations — connected-persons disclosure, CIS rate floor, role outlaws for CIS, annual audit cadence — into Kier's sub-contract terms ahead of the April 2026 JSL and CIS-fraud commencement.

      Lead · Stuart Mulvaney →
      Move 02

      Extend the composition pilot beyond logistics

      Take the London logistics pilot pattern and extend it across other sub-contract packages — brickwork, concrete, groundworks, carpentry. Use the dataset to build the operational and commercial case for a Construction-division MSP.

      Lead · Richard Grey →
      Move 03

      Reopen the Construction / Hays MSP conversation

      With Gerard Cox, re-present the neutral-vend proposition for Kier Construction's contingent blue-collar book — using the Balfour Beatty delivery as the referenceable proof-point. The 2024 ITT submission and Sisk case study are the opening assets.

      Lead · Gerard Cox →