TRS and Christmas Savings Club

I wonder if anyone has a view on this.

A Christmas savings account is held by a couple of employees of a firm who receive monies from other employees monthly who want to save for Christmas and the the funds are paid out entirely just before the end of November. Approx 35 - 40 employees. In the interim the monies are held in a treasurers account with a bank. No other documentation.

Is this a registerable bare trust with all the contributors as settlors and beneficiaries?

Any thoughts would be welcome

If there is no documentation, but simply a bank account, this is not an express trust and registration is not required.