People Group Services Limited Company Number: 11570329

HMRC Enquiry & Investigation Response Policy

Policy Statement

People Group Services Ltd (“PGS”) is committed to full transparency, compliance, and cooperation with HM Revenue & Customs (“HMRC”) in respect of all enquiries, reviews, and formal investigations.

PGS operates under a strict “Compliance Without Compromise” philosophy and maintains systems, controls, and processes designed to ensure that all PAYE, National Insurance Contributions (NICs), Apprenticeship Levy, and associated obligations are calculated, reported, and paid accurately and on time.

This policy sets out the procedures to be followed in the event of any HMRC enquiry or investigation and ensures a consistent, controlled, and auditable response.

Scope

This policy applies to:

• People Group Services Ltd and all group entities including:
  • People Pay Limited
  • People Umbrella Limited
• All directors, employees, contractors, and authorised representatives
• All payroll operations, including:
  • PAYE processing
  • RTI submissions
  • CIS (where applicable)
  • Joint Employment arrangements
  • MSP and agency supply chains

 Types of HMRC Enquiries Covered

This policy applies to all forms of HMRC engagement, including but not limited to:

• Routine compliance checks
• PAYE/NIC audits
• Employer compliance reviews
• VAT inspections (where applicable)
• Requests for information (Schedule 36 FA 2008)
• Joint & Several Liability (JSL) related enquiries under Chapter 11 ITEPA (Finance Act 2025)
• Fraud or criminal investigations

Governance & Responsibility

Designated Responsible Officer

PGS will appoint a Responsible Compliance Officer (RCO) who will:

• Act as the primary point of contact with HMRC
• Coordinate all responses and communications
• Maintain a full audit trail of all correspondence
• Escalate material risks to the Board

 Internal Response Team

Depending on the nature of the enquiry, the following may be involved:

• Compliance Team
• Payroll Operations
• Finance Department
• Legal Advisors
• IT/Data Security Team

No employee is authorised to respond directly to HMRC without prior approval from the RCO.

Core Principles of Response

PGS will adhere to the following principles:

Transparency

• Full and accurate disclosure of requested information
• No withholding of material facts

Accuracy

• All data provided must be verified against:
  • HMRC calculations
  • Internal payroll systems
  • RTI submissions

Timeliness

• All HMRC deadlines will be strictly adhered to
• Responses prioritised based on statutory timeframes

Consistency

• All communications centrally controlled to avoid conflicting responses

Auditability

• Full records retained of:
  • Requests
  • Responses
  • Supporting documentation

Enquiry Handling Procedure

Receipt of Enquiry

Upon receipt of any HMRC correspondence:

• Log immediately in the HMRC Enquiry Register
• Notify the Responsible Compliance Officer within 1 business day
• Assess urgency and statutory deadlines

Initial Assessment

The RCO will:

• Determine the scope and nature of the enquiry
• Identify affected entities, agencies, or workers
• Assess potential exposure (financial, operational, reputational)
• Assign internal stakeholders

Document Collection & Verification

Relevant documentation may include:

• Payslips and Key Information Documents (KIDs)
• RTI submissions (FPS/EPS)
• Payroll reconciliation reports
• HMRC payment confirmations
• Employment contracts and assignment schedules
• Agency/MSP agreements
• Bank payment records

All data must be:

• Cross-checked against HMRC tools
• Verified “to the penny” where applicable

Response Preparation

Responses must:

• Be clear, factual, and professionally presented
• Directly address HMRC’s request
• Include supporting evidence
• Avoid speculative or ambiguous statements

Where appropriate, responses will highlight:

• Use of HMRC-aligned calculation systems
• Real-time payslip validation processes
• Evidence of payments via PAYE account verification

Submission to HMRC

• All responses issued centrally via the RCO
• Submitted via secure and traceable channels
• Confirmation of receipt retained

Ongoing Engagement

Where enquiries are ongoing:

• Maintain structured dialogue with HMRC
• Provide additional information promptly
• Record all meetings, calls, and correspondence

Use of Technology & Systems

PGS utilises advanced systems to support enquiry responses, including:

• HMRC-aligned payslip verification tools
• Real-time PAYE account validation systems
• Granular RTI reporting (worker, agency, company level)
• Assignment reconciliation schedules per payslip

These systems provide:

• Immediate evidence of compliance
• Full transparency across the supply chain
• Audit-ready documentation at all times

Joint & Several Liability (JSL) Considerations

In the context of Chapter 11 ITEPA:

• PGS will provide full visibility of:
  • PAYE/NIC calculations
  • HMRC payment evidence
  • Worker-level reporting
• Where enquiries relate to supply chain partners:
  • Relevant MSPs/agencies may be engaged (subject to data protection controls)
  • Data shared will be limited to what is necessary and proportionate

Data Protection & Confidentiality

All disclosures to HMRC will:

• Comply with UK GDPR and Data Protection Act 2018
• Be limited to relevant and necessary information
• Include redaction of non-essential personal data where appropriate

Escalation & Risk Management

Matters will be escalated to senior management where:

• Financial exposure is identified
• Potential penalties or sanctions arise
• Criminal investigation risk is present
• Reputational impact is likely

External legal or tax advisors will be engaged where necessary.

Record Keeping

PGS will retain:

• All HMRC correspondence
• Internal communications and working papers
• Supporting evidence and submissions

Retention period: minimum 6 years (or longer where required by law)

Training & Awareness

Relevant staff will receive training on:

• HMRC enquiry handling procedures
• Data accuracy and record keeping
• Escalation protocols
• JSL implications

Policy Review

This policy will be reviewed:

• Annually; or
• Following significant legislative or regulatory changes; or
• After any major HMRC investigation

Conclusion

People Group Services Ltd adopts a proactive, transparent, and fully auditable approach to HMRC enquiries. Through robust systems, governance, and real-time verification processes, PGS ensures that it is always in a position to respond confidently, accurately, and promptly to any HMRC engagement.

Declaration

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

Last updated: 31st March 2026