People Group Services Limited Company Number: 11570329

Agency Workers Regulations (AWR) Compliance Policy

Purpose

This policy sets out the approach adopted by People Group Services to ensure full compliance with the Agency Workers Regulations 2010, ensuring that all temporary agency workers engaged through our umbrella model receive their statutory rights and protections.

This policy is designed to:

• Ensure legal compliance across all supply chains
• Protect agency workers’ statutory entitlements
• Provide transparency and auditability for agencies, end clients, and regulators
• Mitigate risk under wider legislative frameworks including Employment Rights Act 1996 and evolving Joint & Several Liability (JSL) provisions

Scope

This policy applies to:

• All agency workers paid via People Group Services umbrella arrangements
• All recruitment agencies supplying workers through People Group Services
• All end clients receiving services from such workers

Legal Framework

This policy is governed by, and aligned with:

• Agency Workers Regulations 2010
• Employment Rights Act 1996
• Working Time Regulations 1998
• Equality Act 2010

Key Legal Principles:

• Day 1 Rights (Regulation 12): Access to collective facilities and job vacancies
• 12-Week Qualifying Period (Regulation 5): Entitlement to equal treatment in pay and basic working conditions
• Anti-Avoidance Provisions (Regulation 9): Prevent deliberate structuring to avoid qualification

Definitions

• Agency Worker: An individual supplied by a temporary work agency to work temporarily under the supervision and direction of a hirer
• Qualifying Period: A continuous 12-week period in the same role with the same hirer
• Equal Treatment: Comparable pay, working hours, rest periods, and annual leave equivalent to a direct employee

Policy Statement

People Group Services operates a zero-tolerance approach to non-compliance with AWR. Our systems and processes are designed to ensure:

• Workers receive all statutory rights at the correct time
• Agencies are actively prompted and required to confirm compliance
• Payments are controlled to prevent breaches of legislation
• Full audit trails are maintained

Operational Compliance Framework

Assignment Monitoring

Our platform automatically tracks:

• Assignment start dates
• Breaks and continuity
• Role consistency
• Hirer identity

This ensures accurate calculation of the 12-week qualifying period in line with Regulation 7.

Automated AWR Notifications (Weeks 10, 11, 12)

At critical compliance milestones, the system generates automated prompts:

• Week 10 Notification:
  Early warning to the agency that the worker is approaching AWR qualification
• Week 11 Notification:
  Escalation prompt requiring preparation for equal treatment obligations
• Week 12 Notification:
  Confirmation that AWR rights apply and must be implemented

These notifications specifically reference:

• Equal pay requirements
• Holiday entitlement adjustments
• Working time parity

Mandatory Agency Acknowledgement

Agencies must:

• Confirm receipt of each notification
• Acknowledge that AWR obligations have been reviewed
• Confirm that equal treatment has been implemented where required

This forms part of a controlled compliance workflow, ensuring accountability within the supply chain.

Payment Control Mechanism

Where agency acknowledgement is not received:

• The system may automatically withhold worker payment
• Payment is only released upon confirmation of compliance

This mechanism ensures:

• No payment is processed where there is a known compliance risk
• Legal obligations are prioritised over operational convenience

Audit Trail & Record Keeping

The system maintains:

• Timestamped notifications
• Agency acknowledgements
• Assignment data and qualifying calculations

This supports:

• Regulatory audits
• Client due diligence
• Defence against claims under Regulation 18 (liability provisions)

Roles and Responsibilities

People Group Services

• Maintain compliant systems and processes
• Monitor assignments and trigger notifications
• Enforce payment controls where required
• Maintain audit records

Recruitment Agencies

• Provide accurate assignment data
• Respond to AWR notifications
• Ensure equal treatment is implemented
• Confirm compliance formally

End Clients (Hirers)

• Provide comparator information
• Ensure working conditions align with internal employees
• Support agencies in meeting AWR obligations

Equal Treatment Requirements

After 12 weeks, agency workers are entitled to:

• Equal basic pay (including bonuses directly attributable to work performed)
• Equivalent working hours and rest breaks
• Comparable annual leave entitlement

Exclusions (as per Regulation 6):

• Occupational pension schemes
• Redundancy payments
• Sick pay schemes (beyond statutory)

Anti-Avoidance Measures

People Group Services actively monitors for:

• Artificial assignment breaks
• Role manipulation
• Rotations designed to reset the qualifying period

Any such activity may:

• Be flagged for investigation
• Result in suspension of payments
• Be reported to relevant parties

Non-Compliance and Escalation

Failure to comply may result in:

• Payment withholding
• Formal compliance escalation
• Removal from approved supplier lists
• Reporting to regulatory bodies

Liability under AWR may extend to:

• Agencies
• End clients
• Other parties in the supply chain (subject to Regulation 18)

Interaction with Joint & Several Liability (JSL)

While AWR governs worker rights, non-compliance may contribute to wider financial and legal exposure under emerging JSL frameworks, particularly where payroll inaccuracies or underpayments arise.

Our system-driven enforcement model is designed to mitigate these risks.

Policy Review

This policy will be reviewed:

• Annually
• Upon legislative updates
• Following audit findings or compliance incidents

Conclusion

People Group Services combines legislative compliance with automated enforcement, ensuring that AWR obligations are:

• Identified in advance
• Actively managed
• Fully evidenced

This provides a defensible, transparent, and audit-ready framework for all parties within the labour supply chain.

 

Declaration

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

Last updated: 1st May 2026