Code of Conduct Policy

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

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1. Purpose

The purpose of this Code of Conduct Policy is to define the standards of ethical and professional behavior expected from all employees, contractors, and business partners of KPG99 Inc.. Upholding integrity, honesty, and accountability in every action helps maintain the trust of our clients, candidates, and colleagues.

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2. Scope

This policy applies to all employees, subcontractors, consultants, and representatives of KPG99 Inc., across all functions and geographic locations.

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3. Policy Statement

Every individual associated with KPG99 Inc. is expected to:

• Act with honesty, integrity, and professionalism in all business dealings.
• Comply with all applicable laws, company policies, and client requirements.
• Treat all colleagues, candidates, and clients with respect and fairness.
• Protect confidential and proprietary information at all times.
• Avoid conflicts of interest or any action that could harm the company’s reputation.
• Immediately report unethical, illegal, or improper behavior.

Any behavior inconsistent with this policy will result in corrective or disciplinary action, including termination of employment or engagement.

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4. Professional Ethics and Workplace Conduct

• Communicate professionally with clients and candidates.
• Avoid falsifying, altering, or misrepresenting information (such as resumes, credentials, or experience).
• Maintain transparency in candidate submissions and client communication.
• Avoid discriminatory behavior, harassment, or retaliation.
• Use company resources and systems responsibly and only for business purposes.

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5. Conflict of Interest

Employees must not engage in outside activities that create a potential conflict with KPG99 Inc.’s business interests. Any potential conflict must be disclosed to management or the compliance team immediately.

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6. Compliance and Enforcement

Violations of this policy will be taken seriously. Disciplinary actions may include:

• Verbal or written warnings
• Suspension or termination of employment/contract
• Reporting of misconduct to clients or relevant authorities (where applicable)

All reported violations are reviewed confidentially by the Compliance & Operations Team.

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7. Acknowledgment

All employees, subcontractors, and vendors must acknowledge this Code of Conduct Policy during onboarding and agree to comply with its provisions throughout their association with KPG99 Inc..

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8. Review

This policy will be reviewed annually to ensure it remains current with business practices, client expectations, and legal requirements.

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