People Group Services Limited Company Number: 11570329

Key Information Document (KID) Governance Policy

Purpose

The purpose of this policy is to establish a robust governance framework for the creation, verification, issuance, storage, and ongoing management of Key Information Documents (KIDs) in accordance with:

• The Conduct of Employment Agencies and Employment Businesses Regulations 2003 (as amended)
• UK Government requirements for pay transparency for agency workers
• HMRC expectations regarding accurate representation of pay and deductions

This policy ensures that all KIDs issued by People Group Services Ltd (“PGS”) are accurate, transparent, compliant, and aligned to actual payroll outcomes, supporting both worker understanding and agency due diligence requirements.

Scope

This policy applies to:

• All umbrella employees (agency workers) engaged via PGS
• All recruitment agencies and MSPs supplying workers through PGS
• All internal departments responsible for:
  • Worker onboarding
  • Payroll processing
  • Compliance and audit
  • Systems and portal management

Definition of a Key Information Document (KID)

A Key Information Document (KID) is a mandatory pre-engagement document that provides a clear, concise illustration of:

• The worker’s pay rate
• All statutory and non-statutory deductions
• The estimated net pay
• The nature of the engagement model (e.g. umbrella employment)
• Any fees, costs, or margins

PGS adopts a per-assignment, per-payslip aligned KID model, ensuring that each KID reflects actual working arrangements and real payroll outcomes.

Core Principles

PGS operates under the following KID governance principles:

Accuracy

All KIDs must:

• Reflect the true assignment rate received
• Accurately model PAYE tax, employee NIC, employer NIC, and Apprenticeship Levy
• Include all known deductions and entitlements

Transparency

• Every deduction is clearly explained in plain English
• No hidden costs or ambiguous terminology are permitted
• KIDs must align with actual payslip outputs

HMRC Alignment

• All calculations are verified against HMRC-compliant methodologies
• Where applicable, calculations are cross-checked against HMRC tools and RTI outputs

Consistency

• KIDs must follow a standardised format and structure
• Terminology must be consistent across:
  • KIDs
  • Payslips
  • Contracts of employment
  • Assignment schedules

Auditability

• Each KID must be:
  • Time-stamped
  • Linked to the specific assignment and worker
  • Retained for audit and compliance purposes

KID Creation Process

Data Inputs

KIDs are generated using:

• Agency-provided assignment details:
  • Assignment rate (PAYE rate)
  • Frequency (daily/hourly)
  • Expected hours/days
• Worker tax status (where applicable)
• Statutory thresholds and current HMRC rates

System Generation

• KIDs are generated via PGS internal systems and portal
• Calculations are automated using HMRC-aligned logic
• Each KID is uniquely linked to:
  • Worker
  • Assignment
  • Agency/MSP

Validation Controls

Before issuance, KIDs undergo:

• Automated validation checks:
  • Gross-to-net reconciliation
  • Deduction integrity checks
• Cross-verification against:
  • Payroll calculation engines
  • HMRC thresholds and bands

Issuance Requirements

PGS ensures that:

• A KID is issued before the worker agrees to the assignment
• Delivery is via:
  • Secure portal access; and/or
  • Email distribution
• Workers must have the opportunity to:
  • Review
  • Query
  • Confirm understanding

Where assignment terms change, a new or updated KID must be issued immediately.

Alignment with Payslips

PGS operates a KID-to-Payslip Alignment Framework, whereby:

• Each payslip is directly comparable to the original KID
• Variances are:
  • Identified automatically
  • Explained where necessary

Additionally:

• Payslips are verified against HMRC calculations post-payroll
• KIDs are therefore not “illustrative only” but operationally accurate representations

Portal Integration and Transparency

PGS provides full visibility of KIDs via its digital platform:

Workers and agencies can:

• View KIDs alongside:
  • Payslips
  • Contracts of employment
  • Assignment details
• Access historical KIDs
• Compare:
  • Estimated vs actual outcomes

Agencies and MSPs benefit from:

• Full audit trails
• Evidence for Joint and Several Liability (JSL) mitigation
• Real-time transparency across their supply chain

Version Control and Change ManagementEach KID is assigned a version number and timestamp

• Changes trigger:
  • New version creation
  • Retention of previous versions
• Material changes include:
  • Pay rate adjustments
  • Tax code changes
  • Statutory rate changes
  • Assignment structure changes

Record Retention

PGS will retain all KIDs for a minimum of:

• 6 years, in line with:
  • HMRC record-keeping requirements
  • Employment and tax legislation

Records are stored securely and are:

• Fully auditable
• Accessible for:
  • Internal audits
  • Agency/MSP due diligence
  • Regulatory review

Compliance and Monitoring

Internal Audits

• Regular audits ensure:
  • Accuracy of KIDs
  • Alignment with payslips
  • Compliance with legislation

Exception Reporting

• Any discrepancies between KID and actual pay are:
  • Flagged
  • Investigated
  • Resolved promptly

Continuous Improvement

• KID models are updated in line with:
  • HMRC changes
  • Legislative updates
  • Industry best practice

Roles and Responsibilities

Risk Management and JSL Mitigation

PGS recognises the importance of KIDs in mitigating Joint and Several Liability (JSL) risks.

This policy supports:

• Full transparency of:
  • Pay
  • Tax
  • Deductions
• Evidence that:
  • Workers are paid correctly
  • HMRC liabilities are properly calculated

KIDs form part of a wider compliance framework including:

• Payslip verification against HMRC
• RTI reporting transparency
• Live HMRC PAYE account validation

Training and Awareness

• All relevant staff receive ongoing training on:
  • KID requirements
  • Legislative updates
  • Internal systems
• Agencies and partners are supported with:
  • Guidance materials
  • Portal demonstrations

Policy Review

This policy will be reviewed:

• Annually, or
• Immediately following:
  • Legislative change
  • HMRC guidance updates
  • Material business or system changes

Declaration

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

Last updated: 25th March 2026