HMRC ASSURANCE AUDIT – REVISED CWU EXPENSES POLICIES AND PROCEDURES
Through various LTB’s, branch briefings and Motions at General Conference branches will be aware of the HMRC Assurance Audit that had been instigated by that body against the CWU in May 2011. This resulted in HMRC issuing, following lengthy discussion and negotiation, a new and revised dispensation to cover a number of areas. This was issued to the CWU in November 2014.
Since then the NEC has discussed the best way to compile and determine how we need to operate to ensure we comply with the terms of the dispensation which are, de facto, an instruction from HMRC.
To achieve this The NEC determined that we should set up a working group to consider the dispensation and incorporate the outcomes into a set of mandatory policies and procedures applicable to all within the CWU. The working group comprised Branch, Regional and National Representatives. They conducted an extensive review of the existing policies and procedures that govern the way that we administer and control the payment of expenses to our representatives and employees and we would like to take this opportunity to thank everyone for their valuable contributions.
Our aim was to make the review as inclusive and wide ranging as possible. We sought and obtained views from all areas of the CWU structure and at the conclusion of the review in December 2015 a revised set of policies and procedures was approved by the National Executive Committee at their meeting held on the 26th November 2015. These policies and procedures are reproduced in this document/booklet for your information.
As a result, all payments made from Union funds from 1st January 2016 must be made in strict accordance with these policies and procedures which are based on the overriding principle that every CWU representative and CWU employee are covered by the same set of policies and procedures irrespective of whether you are a local/unit/shift or workplace representative or whether you are a national representative of the Union.
The review took into account legislative directives which we are required to comply with and included advice, guidance and specific instructions which we have received from HMRC as a result of their recent Assurance Audit.
As you will see certain paragraphs of the policies and procedures are deliberately formatted in italics. We have done this for ease of reference as these are direct extracts from the HMRC dispensation issued to the CWU.
The purpose of a dispensation is to allow the Union to make payments to its representatives and employees (provided they are made under the circumstances described) without the requirement for further declaration to HMRC i.e. they would not be subject to tax and National Insurance. Everybody should be aware that HMRC are very clear in that should the Union make payments that are not in line with the circumstances described and as set out in the policies and procedures then the dispensation would be revoked.
The very time consuming and difficult process we have been through over a number of years is something we, collectively, should ensure we avoid a repetition of. We do this by way of taking the appropriate action, as outlined in the attached mandatory policies and procedures and by a continual monitoring and assessment process.
The impact and success of the revised policies and procedures will be subject to further review by the NEC in the New Year and further detail on this will follow once these new procedures are introduced.
If branches require any additional information particularly around areas not specifically or expressly stated in the policies and procedures these should be referred to the Senior Deputy General Secretary for further guidance and advice.
Any enquiries regarding this LTB should be addressed to the Senior Deputy General Secretary’s Department on telephone number 020 8971 7237 or email address sdgs@cwu.org.
Yours sincerely
Tony Kearns
Senior Deputy General Secretary

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