be, of have been, below the national minimum wage. Enforcement The NMW is enforceable by HMRC (section 14), or by the worker making a contractual claim or through a "wrongful deduction" claim under Part II of the Employment Rights Act 1996. Section 18 provides for compensation. Employers must not subject their workers to dismissal or any other detriment (section 25 and section 23). In October 2013, new rules to publicise the names of employers paying under the minimum wage were established; the names of most employers issued with a Notice of Underpayment are published. In 2014, the names of 30 employers were released by the Department for Business, Innovation and Skills. In 2017, the names of 852 employers were released by the Department for Business, Energy and Industrial Strategy. Failure to pay underpayments after issue of a notice of underpayment results in payment of a financial penalty to the Secretary of State. In 2016, arrangements were made to ensure that underpayments result in double-level financial penalty. The Low Pay Commission has highlighted that apprentices are particularly exposed to being underpaid. Case law Revenue and Customs Commissioners v Annabel’s (Berkeley Square) Ltd [2009] EWCA Civ 361, [2009] ICR 1123 Spackman v LMU [2007] IRLR 741, entitlement to payment of wages Statistics The Office for National Statistics produces information about the lower end of the earnings distribution and estimates for the number of jobs paid below the national minimum wage. The figures are based on data from the Annual Survey of Hours and Earnings. Perspectives The policy was opposed by the Conservative Party at the time of implementation, who argued that it would create extra costs for businesses and would cause unemployment. In 1996, The Conservative Party's future leader, David Cameron, standing as a prospective Member of Parliament for Stafford, had said that the minimum wage "would send unemployment straight back up". However, in 2005 Cameron stated that: "I think the minimum wage has been a success, yes. It turned out much better than many people expected, including the CBI." It is now Conservative Party policy to support the minimum wage. While Mayor of London, Boris Johnson, future Conservative Prime Minister, supported the London living wage, ensuring that all City Hall employees and subcontracted workers earn at least £7.60 an hour and promoting the wage to employers across the city. In May 2009, his Greater London Authority Economics unit raised the London