People Group Services Limited Company Number: 11570329

Bank Account Change & Verification Policy

Purpose

The purpose of this policy is to establish a robust, auditable, and secure process for the submission, verification, approval, and implementation of any bank account changes relating to workers, employees, agencies, or suppliers.

This policy is designed to:

• Prevent payroll fraud and unauthorised payment diversion
• Ensure payments are made only to verified UK bank accounts
• Provide full audit transparency across all changes
• Align with HMRC expectations, GDPR, and internal compliance standards

Scope

This policy applies to:

• All contractors, employees, and workers engaged by People Group Services Ltd
• All agency partners and introducers
• All internal staff involved in payroll, onboarding, or finance
• Any third-party payroll providers acting on behalf of People Group Services Ltd

Policy Statement

People Group Services Ltd operates a zero-tolerance approach to payment fraud.

No bank account change will be processed unless it has:

1. Been submitted via an approved secure method
2. Passed all verification checks outlined in this policy
3. Been authorised by an approved member of staff
4. Been logged and recorded within the audit trail

Approved Methods for Bank Detail Submission

Bank account details may only be submitted via:

• The People Group Services secure online portal (preferred method)
• A secure onboarding workflow with identity verification
• A controlled internal process initiated by authorised staff

❌ The following are strictly prohibited:

• Email-only requests without verification
• Verbal requests without recorded confirmation
• Third-party instructions without documented authority

Bank Account Requirements

All payments will only be made to:

• A UK-based bank account
• An account held in the name of the worker or verified legal entity
• Accounts that have successfully passed verification checks

Where discrepancies exist (e.g. name mismatch), additional due diligence will be required.

Verification Process

All bank account changes must undergo the following checks:

Identity Verification

• Confirmation of the individual’s identity using existing onboarding records
• Cross-reference with personal details (name, date of birth, NI number)

Ownership Verification

• Confirmation that the bank account belongs to the individual
• Where applicable, provision of:
  • Bank statement (redacted acceptable)
  • Confirmation via secure portal validation

Multi-Factor Confirmation

At least one of the following must be completed:

• SMS or portal-based verification
• Recorded confirmation via known contact details
• Secondary approval through authenticated login

Change Validation

• Comparison with previously held bank details
• Identification of unusual or high-risk changes (e.g. frequent updates, mismatched names)

Cooling-Off and Timing Controls

To mitigate fraud risk:

• Bank account changes may be subject to a cooling-off period of up to 48 hours
• Changes submitted close to payroll cut-off may be deferred to the next pay cycle
• Same-day changes are not permitted without senior approval

Approval Process

All bank account changes must be:

• Reviewed by a designated payroll or compliance officer
• Approved by an authorised signatory (dual control where applicable)
• Logged with:
  • Date and time of change
  • Method of submission
  • Verification steps completed
  • Approver details

Fraud Prevention Measures

People Group Services Ltd employs the following controls:

• Dual authorisation for high-risk or flagged changes
• Automated alerts for:
  • Last-minute changes before payroll
  • Multiple changes within a short timeframe
• Restriction on overriding controls without senior approval
• Integration with wider Payroll Fraud Prevention Policy

Audit Trail and Record Keeping

All changes must be fully auditable, including:

• Original and updated bank details (securely stored)
• Verification evidence
• Communication records
• System logs (date/time stamped)

Records will be retained in line with the Data Retention Policy and GDPR requirements.

Data Protection and Confidentiality

All personal and banking data will be:

• Processed in accordance with UK GDPR and the Data Protection Act 2018
• Stored securely using encrypted systems
• Accessed only by authorised personnel

Responsibilities

Workers / Contractors

• Provide accurate bank details
• Notify changes via approved channels only

Payroll & Compliance Teams

• Ensure all verification steps are followed
• Maintain accurate records and audit trails

Management

• Ensure appropriate controls and oversight are in place
• Review high-risk or escalated cases

Breach of Policy

Any breach of this policy may result in:

• Suspension of payments
• Internal investigation
• Disciplinary action
• Reporting to relevant authorities where fraud is suspected

Policy Review

This policy will be reviewed:

• Annually; or
• Immediately following any fraud incident or regulatory change

Declaration

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

Last updated: 25th March 2026