The tendering framework is an EU-wide framework so that companies from anywhere in Europe can bid for work anywhere.
Kent CC delayed initiating the EU framework for quite a while to the benefit of their own Kent Top Temps Ltd company until they were sussed.
I'd suggest that employing "self-employed sub-contractors" would suffice otherwise no taxis in Europe would be permitted to tender for work!
What has happened recently to alter things is that the DfT have "revisited" the tendering guidelines to be "more in line2 (but still not fully complying with) with EU law and test cases regarding entry level requirements for transport operators in an attempt to de-fuse the time bomb of CT operations and the huge subsidies they get from all sources then compete with bus and taxi operators with "unlicenced" drivers, hence the possible change from D to D1 and the requirement for driver CPC.
CT groups are no longer allowed to tender competitively for contracts, it's unfair competition. At blood y last!

Linky here:
https://www.google.co.uk/url?sa=t&rct=j ... 3673,d.d2k