People Group Services Limited Company Number: 11570329

Joint Employment Model Policy

Purpose

This policy sets out the framework under which People Group Services Ltd (“PGS”) operates a Joint Employment Model, designed to:

• Ensure full compliance with UK tax, employment, and regulatory obligations
• Provide clarity and transparency across the labour supply chain
• Protect all parties from financial, legal, and reputational risk
• Support compliance with Chapter 11 ITEPA (Joint & Several Liability) introduced under the Finance Act 2025 (effective April 2026)
• Deliver enhanced worker protections in line with evolving employment legislation

Scope

This policy applies to:

• All workers engaged under PGS employment structures
• All recruitment agencies and Managed Service Providers (MSPs)
• End clients receiving services via PGS supply chains
• All PGS group entities, including:
  • People Pay Limited
  • People Umbrella Limited
  • Any future group entities operating payroll or employment solutions

Definition of Joint Employment

For the purposes of this policy, Joint Employment refers to a structured engagement model whereby:

• A worker is employed by a PGS entity, and
• The recruitment agency and/or MSP retains defined responsibilities in relation to:
  • Worker engagement and assignment management
  • Commercial terms and assignment rates
  • Supply chain compliance and due diligence

This model ensures that employment, payroll, and compliance responsibilities are transparently allocated and actively managed across all parties.

Core Principles

PGS operates its Joint Employment Model in accordance with the following principles:

Compliance Without Compromise

All payroll, tax, and employment obligations are:

• Calculated using HMRC-compliant methodologies
• Verified using HMRC tools and real-time validation systems
• Reported through RTI submissions at full granularity

Transparency

PGS provides:

• Real-time payslip validation against HMRC calculations
• Full visibility of deductions (PAYE, Employee NI, Employer NI, Apprenticeship Levy)
• Schedule-to-payment audit trails
• Live confirmation of payments to HMRC via PAYE account verification

Supply Chain Accountability

All parties in the supply chain:

• Understand their responsibilities
• Operate within a compliant contractual framework
• Share relevant data (subject to GDPR and redaction principles)

Worker Protection

Workers engaged under this model receive:

• Full employment rights
• Statutory entitlements (holiday pay, SSP, etc.)
• Key Information Documents (KIDs) for every assignment
• Clear, transparent payslips for every payroll cycle

Roles and Responsibilities

People Group Services Ltd (and Group Entities)

PGS is responsible for:

• Acting as the employer of record
• Operating PAYE in full compliance with HMRC requirements
• Deducting and remitting:
  • Income Tax
  • Employee National Insurance
  • Employer National Insurance
  • Apprenticeship Levy (where applicable)
• Submitting accurate RTI reports
• Issuing:
  • Payslips
  • Key Information Documents (KIDs)
  • Assignment reconciliation schedules
• Maintaining real-time verification systems aligned with HMRC

Recruitment Agencies

Agencies are responsible for:

• Sourcing and supplying workers
• Providing accurate assignment details, including:
  • Pay rates
  • Working hours/days
  • Assignment duration
• Ensuring contractual alignment with MSPs and end clients
• Participating in supply chain compliance processes
• Reviewing payroll outputs where required

Managed Service Providers (MSPs)

Where applicable, MSPs are responsible for:

• Managing supply chains across multiple agencies
• Ensuring compliance with client contractual requirements
• Monitoring payroll and compliance outputs
• Reviewing liability exposure under Joint & Several Liability (JSL)
• Requesting and reviewing HMRC payment verification

End Clients

End clients:

• Engage MSPs or agencies under contractual agreements
• Define assignment requirements and roles
• May request compliance visibility and audit reporting

Workers

Workers:

• Enter into employment contracts with PGS entities
• Agree to:
  • Assignment terms
  • Data sharing for compliance purposes
• Receive full transparency regarding pay and deductions

Contractual Framework

All Joint Employment arrangements are underpinned by:

• Contracts of employment between the worker and PGS
• Agency/MSP agreements defining supply chain roles
• Worker consent clauses covering:
  • Supply chain transparency
  • Data sharing (contracts, payslips, KIDs)
  • Compliance monitoring under JSL legislation

All contracts are:

• Digitally stored within the PGS portal
• Accessible (with appropriate permissions) to authorised parties

Payroll Compliance & HMRC Alignment

PGS ensures:

• All payroll calculations are verified against HMRC’s official tools
• PAYE liabilities are:
  • Calculated accurately
  • Reported via RTI
  • Paid in accordance with HMRC deadlines

PGS operates:

• A real-time payslip validation system
• A live PAYE account verification system confirming payments to HMRC
• Granular reporting at:
  • Worker level
  • Agency level
  • Company level

Joint & Several Liability (JSL) Mitigation

In light of Chapter 11 ITEPA (Finance Act 2025):

PGS supports agencies and MSPs by:

• Providing full audit transparency of payroll and tax payments
• Enabling verification of:
  • Payslip accuracy
  • HMRC payment status
• Maintaining robust compliance systems to reduce risk of liability transfer

Agencies and MSPs are encouraged to:

• Regularly review payroll outputs
• Utilise PGS verification tools
• Maintain documented due diligence

Data Protection & Confidentiality

All data processing complies with:

• UK GDPR
• Data Protection Act 2018

PGS ensures:

• Data is shared only where necessary for compliance
• Non-essential data is redacted
• Secure systems are used for storage and access

Audit & Monitoring

PGS operates continuous monitoring through:

• Internal compliance reviews
• External audits (e.g. Professional Passport, Cyber Essentials Plus)
• Ongoing development of accreditation standards (e.g. SafeRec)

Audit data is available via the PGS portal for authorised users.

Continuous Improvement

PGS is committed to:

• Enhancing transparency tools
• Aligning with evolving HMRC guidance
• Adapting to legislative changes, including employment law reforms
• Supporting industry best practice

Policy Governance

• Owner: Compliance Director, People Group Services Ltd
• Review Frequency: Annually or upon legislative change
• Approval: Board of Directors

Statement of Commitment

People Group Services Ltd is committed to delivering a fully transparent, compliant, and accountable Joint Employment Model, ensuring:

• Workers are treated fairly and lawfully
• Agencies and MSPs are protected from undue risk
• HMRC obligations are met in full and in real time

Declaration

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

Last updated: 30th March 2026