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Supplier Compliance

Kyndryl serves its customers with trust, transparency, and integrity. We hold ourselves to the highest ethical standards and expect the same commitment from our suppliers. To ensure suppliers comply with their obligations under Kyndryl agreements and applicable laws, Kyndryl’s Supplier Compliance Audit Team may review certain supplier transactions and processes. If you have any questions or concerns about these requirements, please contact your Procurement focal or Pablo Varela of Ombudsman.

Suppliers must be prepared to demonstrate compliance in the following areas:

Before engaging a subcontractor for Kyndryl’s projects, suppliers must obtain prior Kyndryl Procurement approval and enter into a written contractual agreement with a subcontractor. Such agreements must clearly document the scope of work, responsibilities, and deliverables required from subcontractors.

In addition, subcontractor agreements must include mandatory Kyndryl flow-down terms such as Kyndryl’s Ethical Dealings, Criminal Background Checks, and Audit Rights provisions. 

Record Keeping
Kyndryl’s suppliers are required to retain records supporting Kyndryl business transactions.

Proper record keeping is required for suppliers to demonstrate compliance with applicable regulations and respond to regulatory inquiries or audits effectively. Records serve as a source of accountability and transparency, and effective records management helps deter fraud, misconduct, and unethical behavior by promoting accountability and oversight.

Purchase Order and Contract Change Authorizations
As a Kyndryl supplier, you should only perform work for Kyndryl or its customers after you have received an applicable Kyndryl purchase order for the work in scope.

Any changes to the scope of work must be documented in contract change authorizations with the involvement of Kyndryl Procurement to ensure such changes are appropriately reflected in relevant purchase orders and contracts.

Criminal Background Checks and Contractor Code of Conduct
Kyndryl’s general terms require suppliers who are providing certain types of services to conduct criminal background checks of its personnel and provide proof that such personnel have agreed to comply with Kyndryl’s Contractor Code of Conduct: Contractor code of conduct and safety guidelines (

Criminal Background Checks are frequently required by Kyndryl customers. By conducting required background screenings, suppliers mitigate risks and promote a culture of safety, integrity, and accountability in the supply chain ecosystem.