Anti-Fraud Policy

Effective Date: 01/02/2025
Approved By: President, KPG99 Inc.

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1. Purpose

The purpose of this policy is to define KPG99 Inc.’s commitment to preventing, detecting, and responding to any form of fraud, misrepresentation, or unethical financial behavior. KPG99 Inc. maintains zero tolerance for fraudulent activity in all aspects of its operations, including recruitment, payroll, finance, and client interactions.

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2. Scope

This policy applies to all employees, subcontractors, vendors, and any third-party partners associated with KPG99 Inc.. It covers all business activities, both internal and external, including dealings with candidates, clients, and service providers.

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3. Policy Statement

Fraud is any intentional act of deception designed to obtain an unauthorized benefit—financial or otherwise—for oneself or another party.

Examples of fraud include, but are not limited to:

• Submitting falsified or altered candidate resumes or documents.
• Misrepresentation of candidate experience or qualifications.
• Unauthorized use of company or client funds, resources, or data.
• Manipulation of billing, timecards, or payments.
• Collusion with competitors or subcontractors for personal gain.

All employees and contractors are required to conduct business with honesty, accuracy, and transparency. Any suspected fraud must be reported immediately.

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4. Reporting Fraud

Suspected fraud should be reported confidentially through one of the following channels:

• Email: compliance@kpgtech.com
• Directly to a Manager, HR, or Delivery Head
• Through the Whistleblower mechanism (anonymous reporting allowed)

All reports are treated with strict confidentiality and investigated promptly.

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5. Investigation and Response

• Upon receiving a fraud report, the Compliance & Operations Team will initiate an investigation.
• All findings will be documented and reviewed with senior management.
• Confirmed cases of fraud will lead to disciplinary action, including termination, recovery of losses, and possible legal proceedings.
• Preventive steps will be taken to close identified process gaps.

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6. Preventive Measures

KPG99 Inc. employs multiple fraud prevention measures, including:

• Candidate identity and background verification.
• Client submission review by senior delivery staff.
• Financial audits and transaction monitoring.
• Restricted access to sensitive systems and data.
• Compliance awareness and periodic training.

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7. Disciplinary Actions

Individuals found engaging in or facilitating fraud will face disciplinary measures such as:

• Written warning or suspension
• Termination of employment or contract
• Legal action or client notification (as applicable)

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8. Training and Awareness

All personnel receive anti-fraud and ethical conduct training during onboarding. Refresher sessions are conducted periodically to reinforce vigilance and ethical awareness.

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9. Review

This policy will be reviewed annually to ensure continued relevance and effectiveness in preventing and addressing fraudulent activity.

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Approved and Authorized by:
Puneet Gulati
President, KPG99 Inc.
Date: 01/02/2025