In August, I made an official complaint against the big companies that Graduate Fog knows have been advertising for unpaid interns.

At least, I tried to.

I’m disappointed to report that — THREE WEEKS, SEVEN EMAILS AND TWO PHONECALLS LATER – I have still been unable to submit my evidence.

As I became tangled in a web of confused staff, conflicting advice and autoresponders you can’t reply to, it became clear that the new ‘streamlined’ system for reporting abuses of the National Minimum Wage laws is not quite as user-friendly as the officials at HMRC think it is.

Yesterday, Graduate Fog revealed that a government document from the Department of Business, Innovation and Skills insists that recent changes to the official procedure have meant that:

“…the burden of navigating the system has been transferred from the worker to the system itself.”


Then why – despite my Herculean efforts – am I still sitting here with my screen shots of ads for lengthy unpaid internships with Tesco, Sainsbury’s, Superdrug, Morrisons, Weight Watchers, Urban Outfitters, Selfridges, Cedar, River, Seven Squared and Result?

I’ll tell you why.

Because nobody at HMRC will take them.

Even getting my story published on the Guardian’s website seems to have done nothing to move things along.

It all started quite well.

My initial conversation with the Pay and Work Rights Helpline was encouraging.

No, I’m not an intern myself, I explained. Yes, I’m happy to go on the record. Yes, I have screenshots of all the ads. And yes, I suppose I can find the postal addresses of each company’s head office, if that’s what you need me to do (weird?!).

They told me to fill in the online form on their website. I would then receive an email that I could reply to, attaching screen shots of the ads. It sounded like a plan.

Once I was sure I had the support of the Graduate Fog tribe, I decided to go for it.

On 13 August – and with great excitement – I filled out the online form to start the complaints procedure:


I rang the helpline about a week ago and was advised to get in touch via this form.

My name is Tanya de Grunwald and I am the founder of a website called, an advice and discussion site used by job-seeking UK graduates.

The unpaid internships issue is something my users feel very strongly about – and in recent weeks my blog has exposed several household-name brands which have publicly advertised for unpaid interns to work for them for long periods of time (over three weeks), paying expenses only. These are Tesco, Sainsbury’s, Weight Watchers, Superdrug, Morrisons, Selfridges and Urban Outfitters.

The first five did not advertise directly. The internships were to work for their in-house magazines, which are produced by River, Cedar, Result and Seven Squared, who posted the job ads on Gorkana and The internships at the last two (Selfridges and Urban Outfitters) were advertised on their own company website, and the jobs were within their own head office.

When I have brought this to these brands’ attention and asked them to explain their actions, they have been uniformly rude, dismissive or completely silent. Having failed to gain an adequate response from them, I am now keen to take this matter further, even taking into account the risk that these internships could be terminated as a result of your investigation. My users are behind me on this.

I believe that expecting interns to ask their employers for pay – and reporting them if they will not provide it – does not work in the best interests of the interns themselves. They are extremely vulnerable workers – and their no1 priority is to make a good impression with the company for which they are interning.

Sadly, I have heard many stories of interns asking for the national minimum wage and being bullied by their bosses or made to feel greedy or arrogant. And I fear the fact that they have even asked for pay will count against them should a vacancy arise at that company in future.

As a result, I asked your colleague whether you would accept intelligence about companies currently breaking the law from sources other than the intern themselves and she said that Yes, you would. Are you prepared to investigate this matter further? If so, I am happy to go on the record as the person who made this complaint.

Most of the ads have been taken down now, but I have screen shots of all of them, which I am happy to submit to you. I would be grateful if you would confirm that you are able to accept this complaint from me and let me know where to email the screen shots of the ads to, as evidence to help with your investigation.

With many thanks,

Tanya de Grunwald


On 16 August, I received this:

Subject: Re: Directgov Enquiry

The interaction id for this email is 129884

Dear Tanya

Thank you for contacting the Pay and Work Rights Helpline.

The Pay and Work Rights Helpline provides information and advice on a number of government enforced employment rights that are there to protect both employers and workers.

Unfortunately, with reference to your recent query, we cannot answer this without obtaining more information from you. However we would be obliged if you would contact us on the phone number below for further assistance.

I hope this information is useful for you.

If you require any further information call our helpline on 0800 917 2368 Monday-Friday 8am-8pm and Saturday 9am-1pm.

Kind Regards

Pay and Work Rights Helpline
0800 917 2368

Actually, wasn’t massively useful.

And I’d already spoken to them on the phone – and they’d told me to email. Now they were emailing me — to tell me to phone!

I was confused as to how they were proposing I submit screenshots over the phone? Was I going to have to dictate the text?

So I emailed back:

Thanks for this. I’ve already spoken to somebody on this phone number who told me to email you, which I’ve now done.

Can I email you the screen shots of the advertisements now? Is this the right address?

I’m happy to submit this intelligence but I’m not paid for my time doing any of this so would like this procedure to be as efficient as possible. I’ve already followed the advice given by your telephone operators once and they have told me that emailing all the information is the next step.



A reply arrived:

Re: Directgov Enquiry

The interaction id for this email is 129884

Dear Tanya,

Thank you for contacting the Pay and Work Rights Helpline.

Regarding the intelligence you can provide we can not take it through the means of email. You have the option of submitting the intelligence at the website or alternatively you can contact us by telephone and we will take the information from you. Unfortunately we are unable to take screen shots from you but we are willing to take website links from you. We apologize for you inconvenience but we are very grateful of any intelligence which can be provided.

The Pay and Work Rights helpline provides workers, employers, labour providers and others with information and advice relating to government enforced employment rights.

These are:

The National Minimum Wage – Enforced by H M Revenue and Customs.

Working Time Regulations – Enforced by Health and Safety Executive

Conduct of Employment Agencies – Enforced by the Employment Agency Standards Inspectorate.

Agricultural Wages Order – Enforced by Defra.

Conduct of Gangmasters – Enforced by The Gangmaster Liscensing Authority.

We are able to answer queries relating to the above areas and also pass on complaints about abuse of any of these rights to the relevant enforcement agency. The enforcement agency will then investigate the case and enforce the workers rights as necessary.

I hope this information is useful for you.

If you require any further information call our helpline on 0800 917 2368 Monday-Friday 8am-8pm and Saturday 9am-1pm.

Kind Regards

Pay and Work Rights Helpline

0800 917 2368

Okay, this was getting annoying now.

Submitting links to the ads wasn’t going to work – most of them have been taken down by now. All I wanted was an email address that I could send the screen shots to. Surely their system must have some flexibility on this?

So I rang them again. It did not go well.

Despite me providing the case reference number, the person I spoke to seemed to have no information about my case, so I had to explain again – from scratch – what I was trying to do here and what had happened so far.

By this point, the operator seemed to have sensed that I was becoming pretty annoyed. So he assured me he would be ‘escalating’ this to the ‘complex queries team’ at HMRC – and someone would be in touch within three working days.

This arrived on 20 August, from an email address called ‘National Minimum Wage Helpline’:

(The fact that the subject box contained a typo did not bode well)

Subject: Natioan Minimum Wage/Interns (KMM11871998V15537L0KM)

Dear Tanya,

Thank you for your e-mail in which you query internships and the payment of the national minimum wage.

It might be useful if I first explain a little about the national minimum wage. Nearly all people working in the UK are entitled to be paid at least the minimum wage. A worker is defined at Section 54(3) of the National Minimum Wage Act 1998 as,

“.. an individual who has entered into or works under (or, where the employment has ceased, worked under)

(a) a contract of employment; or

(b) any other contract, whether express or implied and (if it is express) whether oral or in writing, whereby the individual undertakes to do or perform personally any work or services for another party to the contract whose status is not by virtue of the contract that of a client or customer of any profession or business undertaking carried on by the individual;”

The term “intern” is not a term mentioned in NMW legislation. NMW legislation is only concerned with whether the person is a worker and that if a person enters into a worker/employer relationship in the UK then the person will be entitled to NMW.

If an intern takes up a post, and has any concerns about the arrangement and would like the matter to be investigated fully they should contact the Pay & Work Rights Helpline who will arrange for a NMW Compliance Officer to visit the employer concerned and obtain full details.

Again I would like to thank you for the information you have provided and for any information you may want to send to us in the future, it will be used in our risk assessment process but, unfortunately, for reasons of customer confidentiality we will not be able to let you know what, if any, enforcement action we take. Officers of HM Revenue & Customs are subject to a statutory duty of confidentiality provided under section 18 of the Commissioners for Revenue & Customs Act 2005.

National minimum wage information is legally owned by the Secretary of State for the Department for Business, Enterprise and Regulatory Reform and is also subject to restrictions contained within section 15 of the National Minimum Wage Act 1998.

These restrictions would prevent us from advising you of any action taken regarding the information you have provided.

For security reasons specific personal data may have been removed from this e-mail.

National Minimum Wage eContact team.

Pay & Work Rights Helpline 0800 9172368
Opening hours: 8am ¿ 20.00pm Monday – Friday and 8.00am to 13.00pm on a Saturday. Closed bank holidays.
Web Site:

I could have done without the rights lecture (I know it’s illegal – that’s why I’m trying to complain about it). But there were signs we were making progress.

I also had questions about how I would be able to follow this up later, but they could wait.

This bit was particularly encouraging:

“Again I would like to thank you for the information you have provided and for any information you may want to send to us in the future”

Hurrah! I replied immediately:

Thanks for this – I was beginning to think I had been forgotten!

I have screen shots of all the adverts that I mentioned, for unpaid roles at:

Tesco magazine (Cedar Publishing)
Sainsbury’s magazine (Seven Squared)
Superdrug magazine (River Publishing)
Weight Watchers magazine (River Publishing)
Morrisons magazine (Result Customer Communications)
Urban Outfitters (head office)
Selfridges (head office).

I’m not sure how many attachments I can send per email, but I will start sending them now. Would somebody your end be able to confirm when they have reached you?

With many thanks


But then – DISASTER!

THIS arrived…


The email enquiries address ( is no longer available to send enquiries to National Minimum Wage.

To send us an enquiry via e-mail, please go to & click on the link ‘How do I get more information about the minimum wage?’

The original of this email was scanned for viruses by the Government Secure Intranet virus scanning service supplied by Cable&Wireless Worldwide in partnership with MessageLabs. (CCTM Certificate Number 2009/09/0052.) On leaving the GSi this email was certified virus free.
Communications via the GSi may be automatically logged, monitored and/or recorded for legal purposes.


At this point, I was close to tears. WHY were they making it so hard for me to DO A GOOD THING??!?

I was faced with calling the Pay and Work Rights Helpline AGAIN, to explain the whole thing for a THIRD time…

Or sending another email through their website – which I STILL wouldn’t be able to attach my screenshots to.

Neither option was tempting.

So I contacted my friend Matt Dykes at the TUC to see if he could offer any advice, ideas or help about how we might be able to get this show on the road. (The TUC has been very supportive of the plight of unpaid interns – although we differ slightly on what constitutes good advice to give you on the best way to handle an exploitative employer).

For the last week, Matt has been busy doing some digging for us – and has suggested that the Low Pay Commission might be a better bet than HMRC – apparently they investigate these things.

He’s also chasing things up with his contacts within HMRC, to see why this has been so difficult for me so far – and whether they can budge on being able to accept screen shots as evidence.

But I’m confused. I assumed that ignoring the National Minimum Wage laws would be a LEGAL or CRIMINAL matter, no?

In which case, why is it:

a) So hard to report a possible ‘crime’, and

b) Not definitely a matter for the police, HMRC or someone with equal gravitas? I’m sure the Low Pay Commission are good folks – but are Tesco going to be quaking in their boots at a phonecall from them? I’m not convinced.

The current complaints system seems to be heavily stacked in favour of exploitative employers — and against exploited interns.

Reporting exploitative employers is already a deeply attractive option for most interns, who are desperate to make a good impression in the hope of landing a job with them in the near future. The penalties are not tough enough, exploitative employers’ reputations are given too much protection – and the system for reporting violations of the NMW laws is a shambles.

If HMRC is serious about encouraging interns (and third parties like me) to step forward in the fight to enforce our country’s NMW laws, they MUST make it easier for us to submit our evidence.

Because right now, the message is coming through loud and clear that they don’t really want to know. And interns, you’re on your own...

*Are you shocked that HMRC won’t accept Graduate Fog’s evidence?
Do you agree that HMRC needs to sort out this shambolic system? What would it take to make it work better for interns?

Share via
Copy link
Powered by Social Snap