People Group Services Limited Company Number: 11570329

Zero Tolerance Non-Compliance Policy

Policy Statement

People Group Services Ltd (“PGS”, “the Company”) operates a strict zero tolerance approach to non-compliance across all areas of its business, including payroll, taxation, employment practices, data handling, and supply chain management.

The Company is committed to:

• Full compliance with all applicable UK legislation and regulatory requirements
• Upholding the highest standards of ethical conduct
• Protecting workers, agencies, clients, and stakeholders from financial, legal, and reputational risk
• Ensuring transparency and accountability across all operations

Any instance of non-compliance—whether deliberate, negligent, or systemic—will be treated as a serious breach and addressed immediately.

Scope

This policy applies to:

• All employees, workers, and contractors engaged by PGS
• All associated entities within the People Group Services group, including:
  • People Pay Limited
  • People Umbrella Limited
• All recruitment agencies, MSPs, intermediaries, and end clients within the supply chain
• Any third-party providers or partners involved in payroll, onboarding, compliance, or data processing

Definition of Non-Compliance

Non-compliance includes, but is not limited to:

Payroll & Taxation

• Failure to correctly calculate or deduct PAYE tax and National Insurance
• Failure to remit payments to HMRC in accordance with statutory deadlines
• Manipulation or misrepresentation of payslip data
• Use of non-compliant payment models or disguised remuneration schemes

Employment Practices

• Incorrect employment status determination
• Failure to issue compliant contracts or Key Information Documents (KIDs)
• Breaches of worker rights under UK employment legislation

Supply Chain Conduct

• Engagement with non-compliant umbrella companies or payroll providers
• Failure to provide transparency in payroll or HMRC payments
• Withholding or falsifying compliance-related information

Data Protection & Security

• Breach of UK GDPR or Data Protection Act obligations
• Unauthorised sharing or misuse of personal data
• Failure to implement adequate cybersecurity controls

Regulatory & Legal Breaches

• Non-adherence to HMRC guidance or statutory obligations
• Breach of applicable legislation including, but not limited to:
  • Finance Act 2025 (including Joint & Several Liability provisions)
  • Employment Rights Act 2025
  • Agency Conduct Regulations

Zero Tolerance Approach

PGS adopts the following principles:

Immediate Action

Any identified non-compliance will trigger immediate investigation and corrective action.

No Commercial Compromise

Compliance will never be compromised for commercial gain, client retention, or operational convenience.

Supply Chain Accountability

PGS will not engage with, or will terminate relationships with, any organisation that fails to meet required compliance standards.

Transparency First

All compliance processes are designed to be fully transparent and auditable, including:

• Real-time payslip validation against HMRC tools
• Live PAYE account verification
• Granular RTI reporting at worker, agency, and company level
• Full audit trail availability via the PGS portal

Joint & Several Liability (JSL) Compliance

In recognition of the Joint & Several Liability provisions under Chapter 11 ITEPA (Finance Act 2025):

• PGS implements enhanced due diligence across all supply chain partners
• All payroll processes are verified against HMRC systems to ensure accuracy and payment integrity
• Agencies and MSPs are provided with tools to independently verify compliance
• Any risk of non-payment or underpayment to HMRC is treated as a critical compliance failure

Responsibilities

Board of Directors

• Ensure overall compliance strategy and governance
• Promote a culture of compliance without compromise

Compliance & Risk Team

• Monitor adherence to this policy
• Conduct audits and investigations
• Maintain regulatory awareness and updates

Employees & Workers

• Adhere to all policies and procedures
• Report any suspected non-compliance immediately

Agencies & Supply Chain Partners

• Comply with all contractual and regulatory obligations
• Provide full transparency when requested
• Cooperate with audits and compliance checks

Reporting Non-Compliance

All individuals and organisations are required to report suspected or actual non-compliance.

Reports may be made via:

• Internal reporting channels
• Compliance team escalation
• Confidential whistleblowing procedures

PGS guarantees:

• Protection against retaliation for whistleblowers
• Prompt and impartial investigation of all reports

Investigation & Enforcement

Where non-compliance is identified:

1. Immediate risk assessment is conducted
2. A formal investigation is initiated
3. Appropriate remedial action is implemented
4. Relevant stakeholders are informed where required

Disciplinary & Remedial Actions

Depending on severity, actions may include:

• Correction of payroll or financial discrepancies
• Mandatory retraining or procedural changes
• Suspension or termination of contracts
• Removal from approved supplier lists (PSL)
• Reporting to relevant regulatory bodies
• Legal action where appropriate

Continuous Monitoring & Improvement

PGS maintains a proactive compliance framework through:

• Real-time payroll validation systems
• Regular internal and external audits
• Continuous system enhancements
• Ongoing staff training and awareness

Policy Review

This policy will be reviewed:

• At least annually; or
• Immediately following any significant legislative or regulatory change

Acceptance

All relevant parties must acknowledge and adhere to this policy as a condition of engagement with People Group Services Ltd.

Failure to comply will result in immediate action in line with this policy.

Compliance Philosophy

At People Group Services Ltd, our approach is simple:

Compliance Without Compromise

We believe that absolute transparency, HMRC-aligned validation, and proactive risk management are essential to protecting all parties within the supply chain—particularly in light of evolving UK legislation.

Declaration

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

Last updated: 31st March 2026