People Group Services Limited Company Number: 11570329

Anti-Bribery and Anti-Corruption Policy

Policy Statement

People Group Services Limited (“the Company”) is committed to conducting business with integrity, transparency, and fairness. We operate a zero-tolerance approach to bribery and corruption in all forms.

This Policy is designed to comply with:

• The Bribery Act 2010
• The Serious Fraud Office guidance
• HM Government guidance on “Adequate Procedures”
• Applicable UK criminal law and international anti-corruption standards

Bribery and corruption are criminal offences. Any breach of this Policy may result in disciplinary action, dismissal, and referral to law enforcement authorities.

Scope

This Policy applies to:

• Directors
• Employees (permanent, temporary, and fixed term)
• Contractors and consultants
• Agency workers
• Joint venture partners
• Intermediaries and introducers
• Any third party acting on behalf of People Group Services Limited

It applies across all jurisdictions in which the Company operates.

What is Bribery?

Under the Bribery Act 2010, bribery includes:

1. Offering, promising or giving a financial or other advantage to induce improper performance.
2. Requesting, agreeing to receive, or accepting such an advantage.
3. Bribing a foreign public official.
4. Failure of a commercial organisation to prevent bribery.

A bribe can include (but is not limited to):

• Cash payments
• Gifts
• Hospitality
• Travel
• Loans
• Discounts
• Employment opportunities
• Political or charitable donations made to secure advantage

There is no minimum value threshold — even small payments may constitute bribery if intent exists.

Prohibited Conduct

The following are strictly prohibited:

• Offering or accepting bribes in any form.
• Facilitation payments (unofficial payments to secure routine governmental actions).
• Secret commissions.
• Kickbacks or referral payments that are not transparent and contractually documented.
• Indirect bribery via third parties.

The Company will not tolerate corruption in procurement, payroll services, supply chain relationships, client onboarding, or regulatory interactions.

Gifts and Hospitality

Reasonable and proportionate hospitality may be acceptable where it:

• Is lawful
• Is transparent
• Is proportionate to the business relationship
• Is not intended to influence decision-making
• Could withstand public scrutiny

The following principles apply:

• Cash or cash equivalents are never permitted.
• Hospitality must be pre-approved by a director if above £100 in value.
• All gifts or hospitality above £50 must be recorded in the Gifts & Hospitality Register.
• Repeated hospitality to the same party requires enhanced scrutiny.

Political and Charitable Contributions

People Group Services Limited does not make political donations.

Charitable contributions must:

• Be legitimate and documented.
• Not be used as a vehicle for bribery.
• Be approved by a director.

Third-Party Due Diligence

The Company recognises that risk often arises through third parties.

Before engaging:

• Introducers
• Overseas partners
• Agents
• Umbrella supply partners
• Payroll intermediaries

The Company will conduct appropriate due diligence proportionate to risk, which may include:

• Identity verification
• Company registration checks
• Financial stability review
• Compliance accreditation review
• Contractual anti-bribery clauses

High-risk engagements must be approved at Director level.

Record Keeping

Accurate books and records are mandatory.

The Company will:

• Maintain complete and accurate financial records.
• Ensure invoices reflect genuine services.
• Prohibit false, misleading, or artificial accounting entries.
• Retain documentation in line with statutory retention periods.

False accounting may constitute an offence under the Fraud Act 2006.

Risk Assessment

People Group Services Limited will conduct periodic bribery risk assessments, considering:

• Sector risk (recruitment/payroll supply chain)
• Jurisdictional risk
• Transaction risk
• Business opportunity risk
• Third-party risk

Controls will be adjusted accordingly.

Training and Communication

All relevant staff will receive appropriate training on:

• Recognising bribery risk
• Reporting procedures
• Conflicts of interest
• Gifts and hospitality rules

New employees will receive this Policy during onboarding.

Reporting Concerns (Whistleblowing)

Employees and third parties must report any suspected bribery immediately.

Reports may be made to:

• A Director
• The Compliance Officer
• Confidential reporting channels

Reports will be treated seriously and confidentially. No individual will suffer detriment for raising genuine concerns.

Retaliation against whistleblowers is strictly prohibited.

Investigation and Enforcement

Any suspected breach will be investigated promptly.

Where appropriate, the Company may:

• Suspend individuals pending investigation
• Take disciplinary action
• Terminate contracts
• Report matters to law enforcement

Serious offences may be referred to the Serious Fraud Office or other relevant authorities.

Director Responsibility

The Board of Directors of People Group Services Limited has overall responsibility for:

• Ensuring compliance with this Policy
• Monitoring effectiveness
• Reviewing this Policy annually
• Ensuring “adequate procedures” are maintained under Section 7 of the Bribery Act 2010

Monitoring and Review

This Policy will be reviewed annually or sooner if:

• There are legislative changes
• A material compliance incident occurs
• The Company expands into new jurisdictions

Consequences of Non-Compliance

Breach of this Policy may result in:

• Summary dismissal
• Termination of contracts
• Civil recovery action
• Criminal prosecution

Under the Bribery Act 2010, penalties can include:

• Unlimited fines
• Up to 10 years’ imprisonment
• Director disqualification

 

Declaration

This Policy is approved by the Board of Directors of: People Group Services Limited Company Number: 11570329

Last updated: 20th February 2026