A number of questions have been raised concerning the intent and use of approval to NCP 119. The purpose of NCP 119 is to secure the labour supply chain such that buyers might be assured it is protected from rogue labour which might be unqualified and/or poorly paid and/or present a security risk. NSI is expecting little, if any, effect on its approved companies even where they act in part as labour providers. Other businesses acting as labour providers might choose to seek approval to NCP 119. NCP 119 can be used by a business operating in the security sector in one or more of three distinct ways: 1. As part of a procurement policy by an approved company NSI approved guarding companies are mandated to only use labour from providers approved to NCP 119 from 31st December 2021. This means they should adopt the code and require their providers to adhere to it. 2. As an ‘additional scope’ by an approved company providing labour NSI approved companies that provide labour to other NSI approved companies must also hold approval to NCP 119 in order to do so. It is expected the vast majority of approved companies will not require any change to their audit regime (additional days) by adding this scope of approval. 3. By other labour providers seeking approval Any labour provider seeking approval from NSI will be able to apply for approval to NCP 119 and obtain NSI Silver for Labour Provision. Note: This is a ‘Specialist Services’ approval and NOT a ‘Guarding’ approval. Does NCP 119 apply to all ‘bought in labour’? The short answer is ‘No’, it does not apply to sub-contractors who provide a service to, or on behalf of, main contractors. For example, it does not apply to : a) key-holding service providers who are sub-contractors and who in turn deliver on behalf of an NSI approved company; or b) PSC (Personal Service Companies) who only provide themselves as labour and do not provide other persons where the approved company undertakes due diligence on the PSC, conducts, records and monitors on an ongoing basis the PSC, and can evidence the fact.