People Group Services Limited Company Number: 11570329

Contractor Onboarding Compliance Policy

Purpose

The purpose of this policy is to ensure that all contractors engaged by People Group Services Ltd (“PGS”) are onboarded in a compliant, transparent, and auditable manner in line with:

• UK employment and tax legislation
• HMRC PAYE and RTI requirements
• Data protection laws (UK GDPR & Data Protection Act 2018)
• Anti-money laundering and right-to-work obligations
• Agency Conduct Regulations 2003
• Emerging compliance requirements, including Joint and Several Liability (JSL) (effective April 2026)

This policy ensures that PGS maintains its principle of “Compliance Without Compromise” and provides full auditability across the supply chain.

Scope

This policy applies to:

• All contractors engaged via:
  • Umbrella (PAYE) model
  • Joint Employment / PEO model
  • Direct PAYE engagement
• All recruitment agencies and MSPs supplying contractors to PGS
• All internal staff responsible for onboarding and compliance

Core Compliance Principles

PGS onboarding is built around the following principles:

Full Transparency

• Every contractor onboarding record must be:
  • Digitally stored
  • Time and date stamped
  • Fully auditable via the PGS portal

HMRC Alignment

• All worker engagements must:
  • Be assessed correctly for PAYE
  • Align with HMRC guidance
  • Be capable of validation against HMRC systems

Right First Time

• Contractors must not be paid until:
  • All onboarding checks are complete
  • Compliance documentation is verified

Supply Chain Protection

• All onboarding processes are designed to:
  • Mitigate Joint and Several Liability (JSL) risk
  • Protect agencies, MSPs, and end clients

Pre-Onboarding Requirements

Before onboarding begins, the following must be confirmed:

• Agency/MSP engagement terms in place
• Commercial terms agreed
• Assignment details confirmed:
  • Assignment start date
  • Pay rate (PAYE rate)
  • Pay frequency
  • Role/occupation

Contractor Onboarding Process

Personal Information Collection

All contractors must provide:

• Full legal name (including middle name)
• Date of birth
• National Insurance number
• Contact details (address, email, phone)
• Gender (optional, for reporting purposes)

Identity Verification

PGS will verify identity using:

• Government-issued photo ID (passport or driving licence)
• Proof of address (within last 3 months)

Verification must:

• Follow UK Right to Work guidance
• Be recorded with:
  • Date/time stamp
  • Verifier details
  • Method (in-person / digital)

Right to Work (RTW) Checks

PGS will:

• Conduct RTW checks in line with:
  • Home Office guidance
• Accept:
  • Digital RTW (share code) OR
  • Manual document checks

All RTW checks must:

• Be completed prior to assignment start
• Be retained securely
• Include audit evidence

Agency Documentation

The following must be obtained:

• Agency Contract / Work Finding Terms
• Confirmation of assignment
• Agency postcode and details

Key Information Document (KID)

PGS will:

• Issue a Key Information Document (KID):
  • Specific to the contractor and assignment
  • Prior to engagement

The KID must:

• Clearly outline:
  • Pay rate
  • Deductions (PAYE, NI, margin)
  • Net pay illustration
• Be:
  • Digitally acknowledged by the contractor
  • Stored and linked to each payslip

Contract of Employment

All contractors must:

• Receive a contract of employment
• Confirm acceptance prior to first payment

Contracts must:

• Reflect the correct engagement model
• Include statutory rights and obligations

Banking Verification

PGS will:

• Only pay into:
  • UK-based bank accounts

Verification includes:

• Bank account name match
• Sort code and account number validation

Compliance Documentation Upload

Contractors must upload:

• Identification documents
• RTW evidence
• Agency contract (if applicable)

All documents must:

• Be securely stored
• Be accessible within the portal

Payroll Readiness Controls

Before payroll is processed, PGS must confirm:

• ✔ All onboarding steps completed
• ✔ KID issued and acknowledged
• ✔ Contract signed
• ✔ RTW verified
• ✔ Bank details validated

No payments will be made unless all checks are complete.

Digital Audit Trail & Portal Integration

All onboarding activity is:

• Captured within the PGS portal
• Linked to:
  • Contractor profile
  • Payslips
  • KIDs
  • RTI data

The system provides:

• Full audit logs
• Time-stamped actions
• Downloadable compliance records

HMRC & PAYE Compliance Integration

PGS onboarding integrates with payroll compliance by:

• Ensuring accurate data feeds into:
  • PAYE calculations
  • RTI submissions
• Supporting:
  • Payslip validation against HMRC tools
  • Real-time audit capability

Data Protection & GDPR Compliance

PGS will:

• Process all contractor data in line with:
  • UK GDPR
• Ensure:
  • Data minimisation
  • Secure storage
  • Restricted access

Contractors will:

• Receive a Privacy Notice
• Be informed of their rights

Ongoing Compliance Monitoring

Post-onboarding, PGS will:

• Monitor:
  • Assignment changes
  • Pay rate changes
• Reissue:
  • Updated KIDs where required

Annual or periodic checks include:

• RTW revalidation (where applicable)
• Data accuracy reviews

Non-Compliance & Escalation

Where onboarding requirements are not met:

• Contractor onboarding will be paused
• No payments will be processed

Escalation may include:

• Compliance team review
• Agency notification
• Assignment suspension

Roles and Responsibilities

Compliance Team

• Conduct onboarding checks
• Maintain audit records

Payroll Team

• Ensure onboarding completeness before processing

Agencies/MSPs

• Provide accurate assignment data
• Support compliance documentation

Contractors

• Provide accurate and complete information
• Confirm documentation and agreements

Alignment with JSL (April 2026)

This onboarding process is designed to:

• Provide full visibility of worker engagement
• Ensure correct PAYE treatment from day one
• Support:
  • Audit trails
  • Liability tracking

This significantly reduces risk under:

• Joint and Several Liability legislation

Policy Review

This policy will be reviewed:

• Annually
• Upon changes in:
  • HMRC guidance
  • Employment legislation
  • Industry standards

Declaration

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

Last updated: 25th March 2026