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People Group Services Limited
Company Number: 11570329

Conflict of Interest Policy

Policy Statement 

People Group Services is committed to conducting its business with integrity, transparency and objectivity. This policy is designed to help individuals identify, disclose and appropriately manage situations where personal interests could conflict, or appear to conflict, with the best interests of People Group Services.

All individuals are expected to act in a manner that protects People Group Services ’s reputation and avoids improper influence on business decisions. 

Scope 

This policy applies to all: 

  • Employees 
  • Directors and officers 
  • Contractors and consultants 
  • Agency workers 
  • Anyone acting on behalf of People Group Services  

Compliance with this policy is mandatory. 

Legal Framework 

This policy is aligned with: 

  • Companies Act 2006 
  • Employment Rights Act 1996 
  • Bribery Act 2010 
  • UK GDPR & Data Protection Act 2018 (where disclosure involves personal data) 

What Is a Conflict of Interest 

A conflict of interest arises where an individual’s personal, financial or other interests could interfere with, or be perceived to interfere with, their duty to act in People Group Services ’s best interests. 

Conflicts may be: 

  • Actual 
  • Potential 
  • Perceived 
  • All three must be disclosed. 

Examples of Conflicts of Interest 

Examples include, but are not limited to: 

  • Financial interests in suppliers, competitors or clients 
  • Outside employment or consultancy that overlaps with People Group Services ’s business 
  • Personal relationships influencing business decisions 
  • Use of People Group Services information or resources for personal gain 
  • Gifts or hospitality that could influence impartiality  

Duty to Disclose 

All individuals must: 

  • Declare any actual, potential or perceived conflict of interest immediately 
  • Update disclosures if circumstances change 
  • Cooperate fully in managing the conflict 

Failure to disclose a conflict may be treated as a disciplinary matter. 

Disclosure Process 

Conflicts should be disclosed to management or the designated contact in writing. 

Disclosures will be: 

  • Reviewed objectively 
  • Handled confidentially where possible 
  • Assessed for risk and impact 

Managing Conflicts of Interest 

People Group Services may manage conflicts by: 

  • Reassigning duties 
  • Restricting access to information 
  • Requiring withdrawal from decision-making 
  • Ending or restructuring external arrangements 

The approach taken will be proportionate and documented.  

Gifts, Hospitality and Benefits 

Any gifts, hospitality or benefits must: 

  • Be reasonable, proportionate and infrequent 
  • Not influence business decisions 
  • Be declared where required 

People Group Services has a zero-tolerance approach to bribery or inducement. 

Confidentiality 

All disclosures and related records will be handled in accordance with data protection legislation and retained only as long as necessary. 

Breaches of Policy 

Failure to comply with this policy may result in: 

  • Disciplinary action 
  • Termination of employment or engagement 
  • Legal or regulatory action where appropriate 

Declaration

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

Last updated: 20th February 2026