People Group Services Limited Company Number: 11570329

Insolvency Protection & Business Continuity Policy

Policy Statement

People Group Services Ltd (“PGS”) is committed to maintaining the highest standards of financial resilience, operational continuity, and supply chain protection.

This policy establishes the framework through which PGS:

• Protects workers, agencies, MSPs, and end clients from financial disruption
• Ensures continuity of payroll and statutory obligations
• Mitigates risk under Joint and Several Liability (JSL) provisions introduced under Chapter 11 ITEPA (Finance Act 2025)
• Maintains full transparency and auditability of payroll operations

PGS operates on the principle of “Compliance Without Compromise”, ensuring that insolvency risk is proactively managed and structurally mitigated.

Scope

This policy applies to:

• People Group Services Ltd
• All associated group entities including:
  • People Paye Limited
  • People Umbrella Limited
• All workers engaged under PAYE employment models
• All recruitment agencies, MSPs, and end clients within the supply chain

Policy Objectives

The objectives of this policy are to:

1. Ensure uninterrupted payroll delivery
2. Safeguard worker wages and statutory payments
3. Protect agencies and MSPs from financial and compliance exposure
4. Provide clear contingency measures in the event of financial distress
5. Deliver real-time transparency over payroll liabilities and payments
6. Reduce exposure to upstream liability under JSL legislation

Financial Stability Framework

PGS maintains a robust financial structure designed to minimise insolvency risk:

Capital & Funding

• Access to external funding facilities, including FCA-backed credit lines
• Ongoing relationships with major financial institutions (e.g. Barclays)
• Exploration and utilisation of alternative funding partners (e.g. Sonovate)

Payroll Funding Model

• Ability to fund payroll in advance of client receipt where required
• Optional credit arrangements available to agencies and MSPs
• Rolling funding capability based on volume and risk profile

Cash Flow Management

• Daily monitoring of payroll liabilities
• Segregation of operational funds and payroll obligations where appropriate
• Forecasting aligned to RTI submissions and HMRC payment cycles

Payroll Protection Measures

PGS implements the following controls to protect workers and the supply chain:

Ring-Fenced Payroll Processes

• Payroll calculations verified prior to payment
• Funds allocated specifically for:
  • Net wages
  • PAYE tax
  • Employee & Employer National Insurance
  • Apprenticeship Levy

HMRC Alignment

• RTI submissions completed in real time
• Payments aligned with HMRC deadlines (typically by the 22nd of the following month)
• Continuous reconciliation against HMRC liabilities

Worker Protection

• Workers are prioritised in all payment scenarios
• Payroll continuity maintained even in the event of client delay (subject to agreed funding terms)

Transparency & Verification Controls

PGS provides industry-leading transparency to mitigate insolvency and compliance risk:

HMRC Verification

• Use of HMRC’s own systems and calculators to validate payroll calculations
• Live PAYE account checking to evidence payments made

Real-Time Reporting

• Granular RTI reporting available at:
  • Company level
  • Agency level
  • Individual worker level

Portal Access

Agencies and MSPs have 24/7 access to:

• Payslips and Key Information Documents (KIDs)
• Assignment reconciliation schedules
• Payment tracking (schedule → payroll → HMRC)
• Audit-ready data

Insolvency Risk Mitigation

PGS proactively mitigates insolvency risk through:

Continuous Monitoring

• Financial health monitoring of internal operations
• Supply chain risk assessments

Compliance Accreditation

• Professional Passport (audited)
• APSCo Trusted Partner
• Cyber Essentials Plus certified
• SafeRec accreditation (in progress)

Operational Controls

• No reliance on aggressive tax models or artificial arrangements
• Full PAYE compliance across all engagements

Business Continuity Planning

PGS maintains a comprehensive Business Continuity Plan (BCP):

Key Continuity Measures

• Redundant payroll systems and infrastructure
• Cloud-based systems with secure backups
• Remote operational capability

Critical Function Protection

The following functions are prioritised:

1. Payroll processing
2. Worker payments
3. HMRC reporting and payments
4. Client and agency communications

Disaster Recovery

• Rapid system recovery protocols
• Data redundancy and secure backups
• Defined incident response procedures

Contingency in the Event of Financial Distress

In the unlikely event of financial distress:

Immediate Actions

• Protection of worker wages as first priority
• Notification to key stakeholders (agencies, MSPs, clients)
• Activation of continuity funding arrangements

Stakeholder Communication

• Transparent and timely communication
• Provision of supporting financial and operational data

Transition Support

• Assistance with orderly transfer of payroll where required
• Full provision of payroll records, RTI data, and worker information

Supply Chain Protection (JSL Mitigation)

To support agencies and MSPs under JSL legislation:

• Full visibility of payroll calculations and HMRC liabilities
• Evidence of payment to HMRC via real-time verification tools
• Audit trail demonstrating compliance at every stage
• Ability for agencies/MSPs to independently verify data

This framework is designed to provide a defensible position against potential liability transfer.

Governance & Responsibility

Responsibility

• Board of Directors: Overall accountability
• Finance Director: Financial resilience and funding
• Compliance Team: Regulatory adherence
• IT & Operations: System continuity

Policy Review

• Reviewed annually or upon regulatory change
• Updated in line with:
  • HMRC guidance
  • Legislative changes (including JSL developments)
  • Industry best practice

Policy Assurance

PGS confirms that:

• Worker payments are prioritised and protected
• HMRC liabilities are calculated, reported, and paid accurately
• Financial and operational controls are in place to prevent disruption
• Transparency is available at all times to relevant stakeholders

Conclusion

People Group Services Ltd operates a financially resilient, fully transparent, and compliance-driven payroll model designed to:

• Protect workers
• Safeguard agencies and MSPs
• Ensure continuity under all reasonable scenarios
• Provide industry-leading assurance in the evolving regulatory landscape

Declaration

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

Last updated: 1st May 2026