A special investigation into migrant worker housing

Just over a year ago environmental health officers led an operation to rescue around 100 migrant farm workers from an overcrowded former fireplace showroom that was weeks away from burning down in an electrical fire in North Wales. The landlord, Russell Brown was successfully prosecuted. But the recruitment agency, the farmer and the big retailers were never scrutinised. In a special multimedia investigation, Environmental Health News (EHN) examines the circumstances of the case and asks if these powerful firms should take more responsibility for workers' living conditions and what happens in their supply chains.

By Tom Wall, Environmental Health News digital editor


Police footage of the raid on Hyperion House.
'We were told by the police there might be a riot so we were quite frightened. We had no idea how they were going to react to us going into their personal space. ’

It was a bright morning in the borderlands between England and Wales on Sunday the 22nd March 2015. The sky was powder blue above the muddy fields where workers had been harvesting daffodils and leeks all week long. Bird song and the snorts of horses carried on the breeze. But the large crowd of officials gathering nearby were not there to enjoy the first stirrings of spring – they were there to raid a disused fire place showroom, Hyperion House.

There were nine environmental health officers from Flintshire Council - all of them wearing stab vests under their boiler suits and high-vis vests with EHO scrawled on the back. The mood was apprehensive; they simply did not know what they would find or how the residents would react to them poking around in what was after all their homes.

Jo Seymour, an EHO from Flintshire County Council, who had been previously worked in Manchester, was leading the operation. She had imagined she was settling in something of a rural idyll with few of the problems associated with inner city housing. But she had never dealt with a rented building like Hyperion House before.

'We were told by the police there might be a riot so we were quite frightened. We had no idea how they were going to react to us going into their personal space,' she recalls. ‘The corridors were narrow and you wouldn’t have been able to get out if something had kicked off.’

Alongside the EHOs were police officers, Gangmasters Licensing Authority officials, UK Border Agency staff, National Crime Agency officers and Red Cross workers. The local ambulance and fire service were on standby. It was to be the biggest operation of its kind in Wales.

Earlier that month social services had alerted Jo that an 8-year-old boy was living in the showroom. She had gone to check it out with a colleague but had been confronted by the landlord, Russell Brown and his son, William Brown. Despite having every right under housing legislation, the Browns refused to let them in until they called the police. When Jo finally got to look around, another man working for the Browns filmed her every move.

‘I’d never experienced anything like it in ten years working in environmental health,’ she says. ‘We had a phone and iPad in our faces when we were looking around.’

Despite their tactics, Jo found the boy, who was living with his mum and dad in a cramped single room. The other room she managed to be see was a little larger but home to six people, including a couple and two sisters. They were paying £55 per head per week.

She saw enough to be alarmed: there didn’t seem be anywhere near enough facilities for the people living there and parts of the showroom were a building site. The landlord appeared to constantly partitioning off further sections to create yet more rooms in readiness for the peak picking season.

‘I wasn’t able to see the rooms I needed to see - lots of them were locked. But I knew we needed to return,’ she says.

Now Jo was back and armed with a magistrate’s order. She was determined to find out what lay behind all the other doors.

‘We split into three teams of EHOs with police protection,’ she remembers. ‘As soon we got in the building we realised there were many more people and rooms than we had anticipated.’

The migrants – mostly Romanians but with some Bulgarians and Poles - were more bemused than angry with what must have seemed a very strange invasion of British officialdom. They shuffled out of their rooms obligingly and gathered in huddles to talk anxiously and chain-smoke on the balconies.

Jo went down long dark corridors, where she had to duck down to get past wires hanging from the ceiling and drying work clothes on lines. Shoes and mud encrusted boots lined the walls.

In one overcrowded room, measuring just over 12 square metres, Jo found four Romanian men sleeping in two single beds and a bunk bed. As the building lacked any central heating, they were using electric heaters to keep warm. There were knots of electrical cables on the floor and the light fitting was hanging from the ceiling. Worst still the smoke alarm was not working and the fire door had gaps, which would have allowed smoke and fire to pass through.

In another room Jo found six men sleeping in a room suitable for only two. Again cables criss-crossed the floor for heaters, fridges and mobile phones. They told her they needed appliances in their rooms because the kitchen was always full.

As she made her way around the building the full extent of the overcrowding became apparent. She counted 107 people living in just 32 rooms. They were sharing three kitchens, six toilets and six showers.

Outside the septic tank was overflowing leaving puddles of raw human sewage around the base of the building. It had simply not been designed to take that amount of waste.

However that was nowhere near the most pressing issue: the electricity supply in the building was looking dangerously overloaded.

‘There were three kitchens for 107 people – there just weren’t enough facilities. It meant that there was quite a lot of cooking equipment like deep fat fryers and microwaves in the rooms, which increases the risk of fires,’ she says. ‘The corridors were long and dark with lots of wellies and work stuff. These can become trip hazards in a fire when people are trying to get out.’

Jo called in an electrician to check the electrics and the alarm system. After examining the partially burnt out fuse box, which was in a cupboard where a man had been sleeping, he made a chilling assessment.

‘The electrics were close to overloading,’ Jo remembers him saying. ‘It was within a week of catching fire and the alarm system wasn’t operational.’

It was then she took the momentous decision to issue what is known as an emergency prohibition notice, which is only used in the worst housing cases when there is an imminent risk of serious harm.

‘The alarm system wasn’t working as it needed to and lots of the escape routes were blocked with their clothing. If there had of been a fire there would be a number of fatalities.’

This immediately created a problem for the officials on the site: they now had over 100 homeless people on their hands. Jo and her colleagues had the unenviable job of explaining to the residents – who were milling around the entrance in a huge crowd – that they had to go somewhere else that night.

‘They were all outside by this point and they didn’t want to go anywhere. Hyperion House is next to where they work – it’s a ten-minute walk. It took a good couple of hours to convince them. We promised to provide transport to get them to and from work.’

Although the council and the Red Cross had planned for this eventuality, there were considerably more migrant workers than they had expected.

‘The council had organised a rest centre for around 50 people. But we had to find other accommodation. Luckily we got the use of a sports hall that day. There was also a building that a housing association had just emptied,’ she says.

Coaches ferried the migrant workers to their temporary homes for the rest of the afternoon and evening. As the last coach drew off one of the weary migrants turned to an even wearier Jo and said something that has stayed with her ever since.

'The last bus left to go to Holywell about 9pm in the evening. I got on to make sure they were okay. One of the guys stood up and said "you need to sit down" and he said "thank you" and then a couple of others said “thank you”.'


'He got a £21,400 fine but that was what he was making in a month!'

The next morning the migrants woke on camp beds in emergency rest centres in nearby Holywell and Rhyl. They were disorientated and tired but Jo was true to her word and they were able to work that day and beyond.

Many found alternative accommodation in the local area. Some were helped to return home because they couldn't afford flights. Others, intent on following the agricultural work, moved elsewhere in the country.

Brown was eventually charged with 12 offences relating to the substandard conditions and risk of fire. In January this year he admitted all the charges at Wrexham Magistrates Court.

The court heard that the migrants were living in the 'wholly inadequate’ building at ‘imminent risk of fire’ and there was a ‘real risk to life’.

The defence claimed the number of people living at the property had spiralled out of Brown’s control. His solicitor added that he might be forced to sell one of his five properties to pay the fine.

Nevertheless, the magistrates fined him £21,400. He was also ordered to pay costs of £56,000 to the council, which reflected the cost of the operation, but it was reduced on appeal to £25,000.

Although Jo was pleased with the conviction, she was not overly impressed with the fine. The court heard he was making an estimated £23,540 a month as the 107 tenants were paying £55 each per week for the privilege of sleeping in Hyperion House.

Indeed for the three month daffodil picking season, which usually runs from January to March, he potentially made £70,620 in rent.

‘He got a £21,400 fine but that was what he was making in a month! The magistrates did the best they could but the law is no deterrent,’ she says.

Brown’s conviction was covered extensively by the local and national media but there were only a few mentions of the employment agency, Staffline, which employed the migrants and featured Hyperion House on a list of accommodation for newly arrived migrants.

And no reporters sought out the owner of the farm where they worked, Emmett UK, or the major supermarkets that sold the produce they picked, Tesco and Waitrose.

Staffline says it does not provide accommodation to workers. It removed Hyperion House as soon as it was alerted about the issues on the site. It now checks landlords and properties before listing them. See the firm's full response in Chapter 5.

The response from Emmett, Tesco and Waitrose is in Chapter 6.

Jenny Prendergast, Flintshire’s environmental health head, who works beside Jo in the council’s imposing town-hall in nearby Mould, believes the case goes far beyond Brown.

She is convinced it raises important questions for all employment agencies supplying migrant workers in the UK.

'Agencies bring workers over here but are they not bothered about where they sleep,' she says.

Currently agencies supplying workers to sectors such as food processing and agriculture must obtain licences from the Gangmasters Licensing Authority (GLA). These licenses require companies to meet tough standards covering health and safety, pay, accommodation and working conditions.

However, the agencies only need to ensure workers’ housing is safe if it is linked to their jobs. This means the agency that recruited the migrants, Staffline, was not under any legal obligation to check Hyperion House met minimum standards.

‘Accommodation is only part of the GLA licensing conditions if it is provided through the wages,’ laments Jo.


Brown is sitting in the dingy office on the ground floor of the now ghostly quiet Hyperion House. Grey daylight seeps in between the stained blinds as he studies CCTV images of vacant rooms on a dusty monitor.

He is bitter about the conviction as he believes he has been made to carry the can for everyone else.

‘If this went to trial this was all going to come out.’

'I couldn't get any of it over in court because I couldn’t go to trial. Or it would have all have come out in court. My back was against the wall because I couldn’t afford to carry on.’

Brown claims he warned Staffline and says the firm's temporary Romanian supervisors held meetings in Hyperion House. 

‘That last four weeks, they were coming in tens and twenties. It was only 35 in the building a few weeks before. They were coming and coming. I says "you can’t bloody come". I says “what you doing here”.’


'Where there is money to be made, people will exploit other human beings.'

Jim Coy, the Welsh Government's anti-slavery co-ordinator for North Wales, stands watching a crew of workers pick leeks in a muddy field while articulated lorries thunder by on the main road behind.

Former senior policeman Coy is charged with uncovering modern day slavery, which encompasses labour exploitation, sexual exploitation and domestic servitude. He has witnessed an exponential growth in the number of Welsh victims reported through the government’s National Referral Mechanism.

'There were 134 victims in Wales in 2015,’ he says. ‘That’s a 91 per cent year on year increase.’

This is no freak aberration. For each of the last four years the number of potential victim have roughly doubled in Wales.

The problem appears to be growing faster in Wales than the UK as a whole, where reports of human slavery rose by 40 per cent last year.

Coy was surprised with the level of exploitation when he took the job, which is thought to be the only one of its kind in the country, three years ago.

‘Wales is one of the safest places for people to live in terms of crime statistics and yet as soon I was in post my job was to go looking for modern slavery. And no sooner did we start looking then we found it and found it a lot closer than we thought, and a lot more often than we thought we would.’

He firmly believes these migrants should not be targeted for immigration offences but should first and foremost be treated as victims.

‘We all used to assume that people in the backs of lorries found on the side of motorways or in ship containers were illegal immigrants and were therefore somehow committing a crime against the state. That may be the case but there is a bigger crime here and it is the crime against the human being themselves.’

Coy was involved in the raid on Hyperion House. He found that the migrants were receiving the minimum wage but they did not have regular employment.

‘The offer that they signed up to online was for at least five days full time work. So people came across hoping to get at least five full days of employment. Now that wasn’t always the case.’

However, he notes employers cannot always provide regular hours and emphasises there was no evidence in this case that anyone was being deceitful. Instead Coy describes Hyperion House as a case of ‘accommodation exploitation’.

‘We’ve all grown up in the UK thinking that sites like that only exist in Eastern Europe or in other countries where the standard of living is not so high as it is in this country. I think it is a wake up call that these things are going on in the UK and we’ve got to do something about it.’

Even though employment agencies have no legal obligation to check unconnected accommodation, Coy says they should take more of an interest in where the migrant workers they bring to the UK are living.

‘Employment agencies act under a government issued licence to do what they do. Agencies should therefore show some due diligence to make sure the accommodation their workers are going to is of an adequate standard.’

Staffline drew up a list of preferred accommodation in the area, including Hyperion House, for newly arrived migrant workers. But Coy points out it never thought to check any of them.

‘Hyperion House was one of their preferred accommodation venues of a list of ten. Now the other nine addresses did exist but when I went to check them physically myself they had never heard of that company. There had never been any contact with that company and certainly no arrangement to house migrant workers. My view is that the preferred accommodation list was something that was taken off a property website.’

'Every company in the UK with a turnover in excess of £36m must show due diligence in looking at their supply chain and showing that the people who provide their leeks and daffodils and potatoes however far down the chain are not subject to the type of exploitation that we've seen in this case.’

Hyperion House also raises some awkward questions for the supermarkets supplied by the farmer in Sealand. The Modern Slavery Act, which became law just over a year ago, requires companies with annual turnovers above £36m to publish a statement setting out the steps they are taking to check their supply chains for exploitation.

This means, says Coy, the supermarkets, such as Tesco and Waitrose, selling the leeks and daffodils harvested by the migrants living in Hyperion House, cannot turn a blind eye to exploitation.

‘The modern slavery act was passed in March of last year. Not only should they take an interest, they must now take an interest. Every company in the UK with a turnover in excess of £36m must show due diligence in looking at their supply chain and showing that the people who provide their leeks and daffodils and potatoes however far down the chain are not subject to the type of exploitation that we’ve seen in this case.’

Yet he is in no doubt that there are other migrants still living in equally as bad conditions because the law does not require agencies to check accommodation for migrant workers unless it is provided as part of their work.

‘Where there is money to be made, people will exploit other human beings. I’m sure it is happening in various parts of Wales,’ he says with the bleakness that only an ex-policeman can muster.

Coy has taken the issue up with the government’s independent modern slavery commissioner Kevin Hyland. He helped compose a letter with Flintshire chief executive Colin Everett to Hyland after the raid on Hyperion House.

‘There is a gap in the current legislation which allows people to offer employment and do nothing about accommodation. Surely if people are coming across the world to work here, we must pay due diligence to where they are going to live and the standards of living they are going to receive.’

Bob Mayho, CIEH principal policy officer, shares Coy’s concerns about possible gaps in the regulatory framework.

‘The CIEH calls upon the government to look at the statutory responsibilities of the agencies involved in the licensing regime to ensure that the welfare of migrant workers, in terms of workplace safety, accommodation and general health and wellbeing are protected,’ he says.


'If they choose Hyperion House because they already had friends there, we can't accept any responsibility for that.’

Staffline Group has grown from humble origins in Nottingham into a major employment agency supplying up to 45,000 temporary workers each day to thousands of farms, food processers, warehouses, and care homes across the UK.

The group's full year financial results reveal its revenues are up 40 per cent to £702.2m and its underlying profits are up 52 per cent to £28.3m.

Staffline’s website states the firm is at the forefront of regulatory compliance and ethical standards. Indeed it likes to tell its staff to use what it calls the granny test: if you couldn’t tell your granny what you’ve done then you shouldn’t do it.

Nonetheless there are some important questions that can be asked of Staffline following the prosecution of Brown. Did it know about the conditions in Hyperion House?  What is it doing to avoid it happening again?

EHN catches up with Jimmy Davies, Staffline’s director of agriculture, and Jane Bladon, Staffline’s head of compliance, in a conference call overseen by leading business communications company, Buchanan.

Davies and Bladon accept that Hyperion House was on a list of accommodation - or disclaimer as they prefer to call it - they gave to migrant workers in Sealand.

'There was a poster outside the site saying accommodation £50 a week and a telephone number,’ recalls Davies.

Bladon, who is responsible for the firm’s gangmaster licence, adds that Hyperion House ‘was on there’ because workers recommended it to Staffline.

Did Staffline carry out any checks on Brown or any of the other landlords?

'Back in that time there were no such checks done on any of the people that go on our disclaimers. So it was by word of mouth or reputation. Somebody would tell us that was okay to live at, that the standards were what we looking for and it was affordable,' says Bladon.

She explains that she created the list because workers coming from overseas often needed a helping hand to find accommodation. ‘We provided a helpful list because we had so many people asking us where to live. That process worked for over a year successfully,’ she says.

'If they choose somebody on that list - and they could choose anybody on that list - they give them a call. We don't organise it for them.’

Staffline, she repeatedly stresses, does not organise accommodation for workers: it’s their decision if they contact any of the landlords on the list.

‘If they choose somebody on that list - and they could choose anybody on that list - they give them a call. We don’t organise it for them,’ she says.

This is important because Staffline would have had to ensure the property was safe for the workers if it effectively provided the accommodation as part of their work.

Bladon and Davies say they were shocked when the council raided the building.

‘I never went there,’ says Davies. ‘I’m not aware of anybody attending or seeing it.’

He adds temporary Staffline workers such as team leaders, quality controllers and supervisors may have lived in Hyperion House. However these people are not Staffline managers but ‘temporary workers fulfilling a role in a client’s business.’

They emphasise Staffline did not send people to Hyperion House.

‘We don’t send workers,’ Bladon says. ‘They would have chosen Hyperion. It was definitely not the only one on the disclaimer. There has to be as many as possible so workers can freely choose. If they choose Hyperion House because they already had friends there, we can’t accept any responsibility for that.’

This year, however, Staffline has introduced a new system for helping migrants find accommodation to ensure they are not dealing with ‘disreputable companies’.

‘We are going to meet the accommodation provider, which is something we have never done before and make sure we are going to be happy with what they are supplying to workers. We are going to audit a sample of their accommodation. If they aren’t up to scratch then we aren’t going to put them on the disclaimer,’ says Bladon. ‘So we are going a little bit further than we ever did before.’

Bladon says there was nothing wrong with the old approach. ‘We didn’t think it was inadequate. We did as much as possible without effectively providing accommodation,’ she says.

While they admit farm work is hard and unreliable, Davies and Bladon maintain that the migrant workers knew what they were letting themselves in for and would have left if they were not receiving regular hours.

When people living abroad express an interest in working in the UK, they attend what Davies calls ‘gore and all’ presentations usually held in a local university. Once they are in the UK they are paid the minimum wage, with bonuses for productivity.

‘The leek and daffodil pickers would be paid an hourly rate and then a weekly bonus on top for productivity. Good flower pickers would do £12 an hour and a good leek cutter would do £9-10 an hour averaged across the week. You will always get a proportion who struggle to meet the productively levels.’

The work depends on the vagaries of the British weather and consumer demand. ‘We are completely in the hands of weather conditions. We are also completely in the hands of supermarket promotions for the products.’

Later the firm issues a statement to EHN:

‘With regards to accommodation, we do not place workers in accommodation either directly or effectively in line with the governing regulations. However, we do try to help the workers as much as we can within these constraints and, having consulted the guidance offered by Gangmasters Licensing Authority's Brief 38, we therefore collate a list of potential accommodation for workers to refer to when they are finding and selecting their own accommodation.’


Deeside farm where the migrants worked is a short walk down a muddy, pock-marked road from Hyperion House. Articulated lorries draw-up beside a modern looking agricultural facility and are loaded with produce bound for supermarkets around the UK.

The farm, which covers 600 acres, is run by Emmett UK, a specialist agricultural business, with farms in Nottinghamshire, Lincolnshire and Spain.

'We are also pleased that the landlord who was responsible for providing accommodation in such a shocking state has been brought to justice with a subsequent conviction.'

The privately owned firm maintains it only became aware of the conditions in Hyperion House when Staffline alerted it to the raid.

'We were notified of the issue by Staffline when it first came to light, and we were reassured to see that swift action was being taken by all parties and authorities involved,' the firm said in a statement.

‘We are also pleased that the landlord who was responsible for providing accommodation in such a shocking state has been brought to justice with a subsequent conviction.’

Emmett added that it takes worker welfare very seriously.

‘Ensuring that our workers are protected will remain a top priority for us and we will continue to partner with our suppliers, our customers and the relevant authorities such as the Gangmaster Licensing Authority to prevent any exploitation.’

Customers buying daffodils in Tesco stores and leeks in Waitrose stores may never spare a thought for the workers in the fields in Sealand but big supermarkets are now required to make public their efforts to eradicate all forms of modern slavery.

Waitrose said it was not responsible for where migrant workers rented but said it had been in touch with Staffline and Emmett.

‘We take workers’ welfare very seriously and although we could never be held responsible for accommodation that workers privately rent we are in contact with our supplier and the recruitment agency they use to ensure they are doing all they can to support workers,’ it stated.

Tesco said it was a private relationship between the workers and the landlord.

‘We are looking into this incident, but we understand that the accommodation in this case was a private arrangement between the workers and landlord, not organised by our supplier or the labour agency. As a founder member of the Ethical Trading Initiative, we take these issues very seriously and work closely with the Gangmasters Licensing Authority and other organisations to ensure good practice in our own supply chain.’


'I wrote to the local authority shortly after this issue was uncovered by the council and I agreed it is an area where workers can be exploited.'

Most of the senior officials responsible for uncovering exploitation in 21st century Britain, seem to be former police officers. Paul Broadbent, the head of the Gangmaster Licensing Authority, which was established after 21 Chinese cockle pickers drowned off Morecombe Bay in 2004, is no exception. He was previously an assistant chief constable in Nottinghamshire.

GLA staff were present during the raid on Hyperion House and Broadbent is aware of the loophole in the current licensing regime, which allows agencies to bring workers to the UK without taking responsibility for where they live.

'I wrote to the local authority shortly after this issue was uncovered by the council and I agreed it is an area where workers can be exploited,' he says. ‘However, the GLA is limited as to what it can do under current UK law and regulations unless the workers’ accommodation is being provided directly by one of the agencies we licence.’

Broadbent treads carefully when asked if he will be raising the matter with ministers.

‘Discussions are ongoing on a number of levels and we will continue to do whatever we can, legally and ethically, to prevent worker exploitation and protect vulnerable people.’

‘As a government regulator we are bound by statute and not opinion and the fact remains that there is no requirement in current legislation for companies to check out any accommodation that it ‘recommends’.’

But he is clear that major firms still have a responsibility for what happens in their supply chains.

‘Under the provisions of the recently introduced Modern Slavery Act, businesses with a turnover of £36 million or more are obliged to publish a statement that describes what they are doing to eradicate modern slavery. The GLA supports this transparency in the supply chain agenda and will continue to work relentlessly to identify exploiters and bring them to justice.’

The government’s independent anti-slavery commissioner, Kevin Hyland, another former policeman, has responded to the letter from Flintshire County Council. His office said he considered the points raised by the council to be ‘extremely valid’ and agrees that ‘opportunities for prevention must be better explored’.

'This is not a loophole - existing legislation and housing standards offer strong protection to those who rent from private landlords.'

The Home Office, however, denies there are any gaps in the gangmaster licensing regime. It argues councils can use powers under housing legislation to crack down on rogue private landlords exploiting migrant workers.

'This is not a loophole - existing legislation and housing standards offer strong protection to those who rent from private landlords,’ said a spokesperson. ‘We are determined to crack down on rogue landlords and the housing bill will introduce banning orders, fines and a database for the worst offenders.’


'If a worker is brought into this country someone needs to take responsibility for where they are going to live and that those properties are up to standard. Until that happens Hyperion House might occur again.'

Hyperion House now stands empty. Grass pokes through cracks in the concrete forecourt and the only noise comes from the rustle of the tall fir-trees shielding it from the main road. The local reporters and TV cameras have long-ago moved on to other stories.

Yet the issue of migrant worker accommodation is not about to go away. Thousands of workers are brought to the UK by agencies every year to meet the seasonal demands of Britain's fresh food industries.

It is estimated 550,000 temporary workers are employed at peak times in the sectors the GLA regulates. Many are supplied by the nearly 1000 licensed gangmasters operating in the UK.

No one knows how many of these workers are housed in dangerous and unhealthy accommodation. But we do know migrant worker are often not in a position to complain as they are in lowly paid, precarious jobs.

'Where we can tackle this particular problem is with central government legislating specifically around accommodation for workers who come from outside of the UK.'

The workers at Sealand didn’t know how much work they would have from week to week. They couldn’t stray far from Hyperion House because there was little in the way of public transport and they lacked their own cars.

Flintshire environmental health head, Jenny Prendergast, recalls that the workers she met during the raid were isolated and vulnerable.

'Some of them said to me they hadn’t had work. I said "are you guaranteed work" and they said “no it is as they want us”. You might get the minimum wage but if you are only working two days a week that’s your rent. What are you left with?’

While Staffline is now checking accommodation before recommending it to workers, other employment agencies may not be so conscientious.

Jo worries she will face another case like Hyperion House unless action is taken: ‘If a worker is brought into this country someone needs to take responsibility for where they are going to live and that those properties are up to standard. Until that happens Hyperion House might occur again.’

Coy is even more direct: ‘Where we can tackle this particular problem is with central government legislating specifically around accommodation for workers who come from outside of the UK.’