GCA considers all five modifications to be non-substantial within the meaning of Regulation 72(1)(e) PCR 2015. To include (a) Service Levels/PIs for the Resource Augmentation Service and Permanent Recruitment Service, (b) clarifying the application of the MSP Fee to the Permanent Recruitment Service. (c) updating the applicable data-processing and retention provisions, (d) to clarify drafting errors and improve clarity and (e) inclusion of PPN 021 - Payment Spot Checks in the supply chain. The change will have no impact on the commercials and does not change the nature of the Framework. Nor are these changes considered material.