Conflict of Interest Policy

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

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1. Purpose

The purpose of this policy is to ensure that all employees, contractors, and subcontractors act in the best interests of KPG99 Inc. and its clients. The goal is to prevent situations where personal interests or external relationships could influence, or appear to influence, professional judgment or company decisions.

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2. Scope

This policy applies to all KPG99 Inc. employees, subcontractors, consultants, and anyone representing the company in a professional capacity, whether in the United States or abroad.

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3. Policy Statement

All personnel must avoid any actual, potential, or perceived conflicts of interest between their personal interests and their professional responsibilities at KPG99 Inc..

A conflict of interest occurs when an individual’s personal, financial, or professional interests interfere—or could appear to interfere—with their ability to make fair, objective, and ethical decisions for the company or its clients.

Employees are expected to disclose any potential conflicts immediately to management or the Compliance & Operations Team.

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4. Examples of Conflict of Interest

• Working for or having a financial interest in a competitor, client, or vendor.
• Engaging in outside employment that affects performance or creates divided loyalty.
• Sharing confidential company or client information with unauthorized parties.
• Recruiting candidates or clients through competitors of KPG99 Inc..
• Accepting gifts, favors, or benefits that could influence business decisions.

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5. Disclosure and Approval

Employees and contractors must:

1. Disclose any potential or perceived conflicts of interest during onboarding.
2. Notify the Compliance & Operations Team if a new situation arises during employment.
3. Avoid making decisions that could benefit themselves, friends, or relatives at the expense of the company or its clients.

All disclosures will be reviewed confidentially, and appropriate action will be taken to eliminate or mitigate the conflict.

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6. Compliance and Enforcement

Failure to disclose or resolve a conflict of interest may result in disciplinary action, including suspension or termination of employment or contract. In serious cases, legal action may be pursued.

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7. Review

This policy will be reviewed annually to ensure it reflects current legal, regulatory, and business standards and continues to support ethical business conduct.

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