People Group Services Limited Company Number: 11570329

Ethics, anti-bribery, tax evasion, fraud and conflicts of interest

Introduction

This policy applies to all staff, associated persons, agents, contractors, consultants, suppliers and partners where relevant. 

Ethical standard

PGS conducts business honestly, fairly and with integrity. Bribes, kickbacks, facilitation payments, secret commissions, false records and dishonest manipulation are prohibited. No commercial pressure, client request or management instruction excuses unlawful conduct.

Conflicts, gifts and hospitality

Actual, potential or perceived conflicts must be declared, including family, financial, outside-work, supplier, agency or client relationships. Gifts or hospitality beyond a modest transparent level require prior approval and recording. Cash or equivalents are not accepted.

Tax-evasion facilitation

No person working for or associated with PGS may deliberately and dishonestly facilitate UK or foreign tax evasion. A suspected request must be refused and reported. PGS maintains prevention procedures, due diligence, training and escalation proportionate to risk.

Red flags

• Cash, unexplained offshore or unrelated account, no invoice/receipt, backdated agreement or misleading invoice description.
• Treating an employee as self-employed without genuine change, paying gross where tax should be withheld, or concealing VAT, income, gains or assets.
• Unusual intermediary, side letter, excessive fee, duplicated expense, false timesheet, altered payroll record or redirected wages.
• An agency or supplier refusing ordinary KID, assignment, VAT, PAYE, bank or identity due diligence.

Declaration

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

Last updated: 24th August 2026