Subcontractor Risk Management 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 subcontractors engaged by KPG99 Inc. meet the company’s ethical, operational, financial, and compliance standards. This policy establishes a framework for evaluating, onboarding, and monitoring subcontractors to minimize risks and maintain service quality and client confidence.

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2. Scope

This policy applies to all subcontractors, vendors, and third-party service providers who supply resources, candidates, or services on behalf of KPG99 Inc., including those operating offshore or remotely.

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3. Policy Statement

KPG99 Inc. is committed to working only with subcontractors who maintain integrity, legal compliance, financial stability, and data protection standards comparable to our own. Subcontractors must comply with all applicable laws, client requirements, and KPG99 Inc. policies, including confidentiality, data protection, anti-fraud, and code of conduct obligations.

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4. Subcontractor Evaluation Process

Before Engagement:

• Verification of business registration and tax compliance.
• Background checks and reputation screening.
• Financial stability assessment (recent bank or tax statements).
• Validation of insurance, if applicable.
• Sanctions or legal checks (as required by client or law).
• Review and acceptance of KPG99 Inc. policies and agreements.

During Engagement:

• Subcontractor performance is monitored regularly for quality, compliance, and payment reliability.
• Periodic audits may be conducted to verify adherence to company and client requirements.
• Any violation or breach is promptly investigated by the Compliance & Operations Team.

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5. Reporting and Escalation

Any concerns about subcontractor misconduct, policy violation, or compliance risk should be reported immediately to the Compliance & Operations Team at compliance@kpgtech.com. All issues will be investigated confidentially, and appropriate corrective actions will be taken.

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6. Non-Compliance

Failure by a subcontractor to comply with KPG99 Inc.’s standards or contractual terms may result in:

• Written warning or probation.
• Suspension or termination of engagement.
• Removal from the approved vendor list.
• Notification to affected clients (if applicable).

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7. Continuous Improvement

KPG99 Inc. reviews subcontractor relationships quarterly to identify performance trends, compliance gaps, and improvement areas. Lessons learned are incorporated into the subcontractor management framework for ongoing enhancement.

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8. Review

This policy will be reviewed annually to ensure alignment with industry standards, legal regulations, and client expectations.

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