Employer Career Zone

Policy on Unpaid Opportunities (UK Only)


Changes in the student and graduate labour market over the past few years have seen a significant rise in the number of organisations offering unpaid opportunities to graduates and students. In addition, in certain very competitive industries (especially media, PR, and similar industries) it has often been traditional for entrants to start work on an unpaid basis.

There appears to be a growing controversy around the ethical and legal aspects of this question. Various pressure groups have been formed by students and graduates; the matter has been referenced by high-ranking members of the government; and graduates now appear to be more willing to take legal action where they feel their rights have been violated.

In this context, the following policy has been devised to give clear guidance to stakeholders (University staff, employers, students and graduates) concerning the policy of Employment Services when dealing with these issues.

The National Minimum Wage

Entitlement for the National Minimum Wage is based primarily on two criteria:

  1. Whether the individual is a “worker” or not. Essentially this hinges on the question of whether the individual has a contract of employment or any arrangement that can be interpreted as such. Such a “contract” can be in written form, a verbal agreement, formal or informal, explicit or implied – each case would be decided on its individual merits.
  2. If the above applies, the worker will normally be entitled to the National Minimum Wage. However, there are specific exemptions within the legislation.

In this context, terms such as “internship” or “work experience”, etc. have no legal force. What matters is the nature of the relationship between the employer and the worker.

In the vast majority of circumstances, commercial organisations must pay National Minimum Wage in order to remain compliant with the law.

Organisations that wish to engage anyone on an unpaid basis are strongly advised to seek professional legal counsel to ensure they are compliant with the law as they may be putting themselves at risk of legal action.

Further detail on National Minimum Wage legislation can be found here.


The National Minimum Wage framework allows for certain exemptions or circumstances where the NMW will not apply. This section will detail Employment Services policy on the most relevant exemptions for our circumstances.

Each vacancy will be considered on a case-by-case basis. We reserve the right to reject any vacancy even where an exemption may appear to be valid.

The exemptions we normally accept are:

  • Work experience in the curriculum: Work experience required to be undertaken by students as part of UK based higher education courses is exempt from the National Minimum Wage where the arrangement does not exceed one year.

    The specifics for curriculum-based work experience must be discussed with appropriate staff in the relevant Colleges – requirements and procedures may vary depending on course requirements.

    To see if you have an opportunity an Exeter student could undertake as a Placement (in the workplace) or Project (work undertaken at the University) find out what our students are studying in the Academic College and Subject Disciplines.

    Depending on the subject, the hours needed and the start dates will vary e.g. 40 hours in total, over a whole academic year or a 6 month placement. Some Colleges may refuse to promote long-term opportunities offered on an unpaid basis.

    In addition, Employment Services will not advertise any full-time Placement work that exceeds three months unless it meets the current National Minimum Wage rates.

    To discuss whether your business need can match student need, please contact Richard Daniels (R.Daniels@exeter.ac.uk).

  • Volunteering with charities or similar bodies: Charities and certain other organisations (usually voluntary organisations or certain statutory bodies such as a school or hospital) have a special exemption in NMW legislation called the “Voluntary Worker exemption”. This allows such organisations to engage “workers” that would in normal circumstances be entitled to the National Minimum Wage.

  • It is important to note that the provision of benefits (training, payments, benefits in kind, etc.) beyond what is needed for the direct fulfilment of the volunteer worker’s duties could invalidate the exemption.

    Employment Services will normally accept positions from charities registered with the Charity Commission, although we decline positions that last longer than 3 months. Submissions from other organisations will be considered on their individual merit.

  • Work shadowing: This involves a student observing work but not being required or tasked to undertake any work themselves. Because there is no obligation to do work, the situation would not normally require NMW payment. Examples we frequently advertise are "insight" programmes that allow students to rotate around different departments in an organisation to see the various career prospects, work practices, etc.

    Care should be taken to ensure that students are not given tasks or duties of their own to perform.

    We will advertise work shadowing opportunities that do not exceed a maximum of 1 week in duration.

International Vacancies

The above information is relevant to positions offered in the UK. For international positions we will apply relevant legislation, custom and practice of the country in which the internship will take place.


The information on these pages is solely for the purposes of clarifying Employment Services policies concerning advertising unpaid opportunities. These guidelines do not represent any authoritative statement of the law and acceptance or rejection of any vacancy under these guidelines makes should not be taken as a statement regarding the legitimacy of any organisation or vacancy.

Last updated: 8.4.2020