People Group Services Limited Company Number: 11570329

Referral & Introducer Transparency Policy

Purpose

The purpose of this policy is to ensure full transparency, compliance, and accountability in all referral and introducer arrangements operated by People Group Services Ltd (“PGS”).

This policy establishes clear standards governing how introducers and referral partners engage with PGS, ensuring that all such arrangements:

• Are lawful, ethical, and transparent
• Do not compromise compliance with HMRC regulations
• Do not create conflicts of interest within the labour supply chain
• Support the integrity of payroll, employment, and financial processes

Scope

This policy applies to:

• All employees, officers, and representatives of PGS
• All third-party introducers, referrers, and intermediaries
• Recruitment agencies, MSPs, and other supply chain partners
• Any entity or individual receiving financial or non-financial benefit for introductions to PGS

Definition of an Introducer

An Introducer is any individual or organisation that:

• Refers workers, agencies, MSPs, or clients to PGS; and/or
• Receives (or expects to receive) any form of benefit for such introductions

This includes, but is not limited to:

• Recruitment businesses
• Consultants or advisors
• Existing clients or workers
• Third-party intermediaries

Core Principles

PGS operates all referral and introducer arrangements in accordance with the following principles:

Transparency

All introducer relationships must be:

• Fully disclosed to relevant parties within the supply chain
• Clearly documented and auditable
• Visible where required within the PGS portal or supporting documentation

Compliance First

Introducer arrangements must:

• Not influence or override compliance obligations
• Not create incentives that conflict with correct PAYE, NIC, or RTI reporting
• Align with HMRC guidance and applicable legislation, including Joint and Several Liability (JSL) provisions under Chapter 11 ITEPA

No Hidden Payments

PGS prohibits:

• Undisclosed commissions
• Hidden margins or rebates
• Any financial arrangement that could distort worker pay, tax treatment, or supply chain integrity

Fairness and Integrity

All referral arrangements must:

• Be commercially reasonable
• Not disadvantage workers
• Not create artificial structures or disguised remuneration

Disclosure Requirements

PGS requires that:

Supply Chain Disclosure

• Introducer relationships must be declared to relevant agencies, MSPs, or end clients where applicable
• Any financial benefit paid must be transparent upon reasonable request

Worker Transparency

• Workers must not be subject to hidden deductions linked to referral arrangements
• Any costs associated with employment must be clearly disclosed within Key Information Documents (KIDs)

Internal Recording

• All introducer agreements must be formally recorded
• Payment structures must be documented and auditable
• Records must be retained in accordance with PGS Data Retention Policy

Payment of Referral Fees

Permitted Payments

PGS may pay referral or introducer fees where:

• The arrangement is formally agreed in writing
• The payment structure is clear and transparent
• It does not affect worker pay or statutory entitlements

Prohibited Structures

PGS strictly prohibits:

• Payments contingent on tax outcomes or take-home pay manipulation
• Payments linked to non-compliant payroll models
• Any arrangement designed to circumvent HMRC rules

Payment Controls

• All introducer payments must be approved internally
• Payments must be processed through official financial systems
• Payments must be traceable and subject to audit

Conflicts of Interest

All parties must:

• Declare any potential conflicts of interest
• Avoid arrangements where introducers influence payroll decisions improperly
• Ensure independence of compliance and payroll operations

PGS reserves the right to terminate any arrangement where a conflict is identified.

Due Diligence

PGS will conduct appropriate due diligence on all introducers, including:

• Identity verification
• Business legitimacy checks
• Compliance history review
• Assessment of reputational risk

Where necessary, enhanced due diligence will be applied.

Monitoring and Audit

PGS maintains ongoing oversight of introducer arrangements through:

• Internal audits
• Portal-based transparency tools
• Financial reconciliation processes
• HMRC-aligned verification checks

This ensures that all arrangements remain compliant and transparent at all times.

Breach of Policy

Any breach of this policy may result in:

• Immediate suspension or termination of the introducer relationship
• Withholding of payments
• Reporting to relevant authorities where required
• Removal from the PGS supply chain

Alignment with Wider Compliance Framework

This policy should be read in conjunction with:

• Supply Chain Due Diligence Policy
• Real-Time Payroll Data Transparency Policy
• PAYE Reconciliation & HMRC Alignment Policy
• Anti-Bribery & Anti-Corruption Policy
• Contractor Onboarding Compliance Policy

Governance and Review

• This policy is owned by the Compliance Function at PGS
• It will be reviewed annually or in line with legislative changes
• Updates will reflect evolving HMRC guidance and industry standards

Statement of Commitment

People Group Services Ltd is committed to full transparency across the labour supply chain, ensuring that all referral and introducer arrangements operate with integrity, visibility, and compliance.

We believe that transparency is fundamental to:

• Protecting workers
• Supporting agencies and MSPs
• Mitigating risk under evolving legislation
• Upholding our principle of Compliance Without Compromise

Declaration

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

Last updated: 31st March 2026