People Group Services Limited Company Number: 11570329

Overpayment & Clawback Policy

Purpose

This policy sets out the approach of People Group Services Ltd (“PGS”, “the Company”) in identifying, managing, and recovering any overpayments made to employees, workers, or third parties.

It ensures:

• Legal compliance with UK employment and payroll legislation
• Transparency and fairness in recovery processes
• Protection of Company funds and client monies
• Alignment with HMRC reporting and Real Time Information (RTI) obligations

Scope

This policy applies to:

• All employees engaged by PGS
• Workers engaged via People PAYE Limited, People Umbrella Limited, or any group entity
• Agency workers paid through PGS payroll solutions
• Payments made under PAYE, umbrella, joint employment, or other payroll models

Definition of Overpayment

An overpayment is defined as any payment made in excess of the amount properly due, including but not limited to:

• Salary or wages paid incorrectly
• Holiday pay miscalculations
• Duplicate payments
• Incorrect tax or National Insurance treatment
• Expenses or allowances paid in error
• Incorrect assignment rates or hours
• Payments made after termination of employment or engagement

Legal Framework

This policy is governed by:

• Employment Rights Act 1996
  (Permits recovery of overpayments where there is a prior agreement or lawful basis)
• HM Revenue and Customs requirements for PAYE accuracy and correction
• Contractual provisions within:
  • Contracts of employment
  • Worker agreements
  • Assignment schedules
  • Key Information Documents (KIDs)

Principles

PGS will adhere to the following principles:

• Accuracy First – Prevent overpayments through robust payroll controls
• Transparency – Notify individuals promptly and clearly
• Fairness – Agree reasonable repayment terms where appropriate
• Compliance – Ensure all corrections align with HMRC rules
• Proportionality – Avoid undue financial hardship

Identification of Overpayments

Overpayments may be identified through:

• Payroll audits and reconciliations
• RTI submissions and HMRC alignment checks
• Agency or client reporting
• Worker queries or disputes
• System or administrative errors

PGS operates enhanced verification processes, including:

• Post-payroll validation
• Assignment reconciliation checks
• HMRC-aligned calculations

Notification Process

Upon identification of an overpayment, PGS will:

1. Notify the individual in writing within a reasonable timeframe
2. Provide a clear breakdown including:
   • Amount overpaid
   • Period affected
   • Reason for overpayment
3. Confirm proposed recovery method
4. Provide an opportunity for the individual to query or dispute

Recovery Methods (Clawback)

PGS reserves the right to recover overpayments using one or more of the following methods:

Payroll Deduction

• Deductions from future wages in accordance with contractual consent
• Structured repayment schedules where required

Final Pay Adjustment

• Recovery from final salary, holiday pay, or other payments upon termination

Direct Repayment

• Agreed repayment via bank transfer or instalment plan

Legal Recovery

• Where necessary, recovery through civil proceedings

Repayment Arrangements

PGS will consider:

• The size of the overpayment
• The individual’s financial circumstances
• Whether the overpayment was recent or historic
• Whether the individual could reasonably have identified the error

Repayment plans may include:

• Instalments over an agreed period
• Temporary reduction of repayment amounts
• Deferred recovery in exceptional circumstances

Tax and National Insurance Adjustments

All corrections will be processed in line with HM Revenue and Customs guidance:

• Adjustments made via payroll where possible
• RTI submissions corrected accordingly
• Year-end adjustments handled in line with HMRC procedures
• Where recovery crosses tax years, appropriate reconciliation will be applied

Disputes and Appeals

Individuals have the right to:

• Raise a dispute regarding the overpayment
• Request further clarification or evidence
• Propose alternative repayment arrangements

PGS will:

• Review all disputes promptly
• Provide a written outcome
• Escalate where necessary through formal grievance procedures

Fraud or Deliberate Misrepresentation

Where an overpayment arises due to:

• Fraud
• Misrepresentation
• Deliberate withholding of information

PGS reserves the right to:

• Recover the full amount immediately
• Initiate disciplinary action
• Report matters to relevant authorities

Record Keeping

PGS will maintain records of:

• Overpayment calculations
• Communications issued
• Repayment agreements
• HMRC adjustments

All records will be retained in accordance with:

• Data retention policies
• GDPR requirements

Responsibilities

Payroll Team

• Identify and calculate overpayments
• Process corrections and RTI updates

Compliance Team

• Ensure legal and regulatory adherence
• Review high-risk or complex cases

Finance Team

• Manage recovery tracking and reporting

Workers / Employees

• Notify PGS of suspected overpayments
• Cooperate with recovery processes

Policy Review

This policy will be reviewed:

• Annually; or
• Following changes in legislation or HMRC guidance; or
• Following significant payroll or compliance updates

Declaration

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

Last updated: 31st March 2026