Subcontractor Compliance Policy
Barcelona, January 2024
1. Purpose and Governance Context
QforMedia integrates external partners into its operations only under a framework that preserves the company’s standards of integrity, security and regulatory alignment. As part of QforMedia’s broader governance system, this policy defines the principles that govern the engagement and management of subcontractors whose work may influence the company’s operational, technical or creative outputs.
This document forms part of QforMedia’s internal governance manual and is intended to ensure coherent, consistent and accountable practices across all subcontracted relationships.
2. Policy Applicability and Responsibility
The provisions set out in this section apply to all subcontractors, external service providers and independent professionals who participate in processes under QforMedia’s responsibility, whether related to content production, technical services, data-handling or other operational functions.
Ultimate responsibility for compliance lies with QforMedia, which maintains oversight of all subcontracted activity and ensures alignment with the company’s commitments, values and governance standards.
3. Compliance with Legal and Ethical Standards
Subcontractors shall conduct their work in accordance with applicable legislation and with the ethical, professional and regulatory standards recognised within QforMedia’s sector. This includes obligations related to confidentiality, intellectual property, data protection, business ethics, safety and fair labour practices.
All information, materials or systems made available to subcontractors must be treated as confidential and used exclusively for authorised purposes. Subcontractors are expected to uphold practices that safeguard the integrity, security and lawful handling of such information.
4. Confidentiality, Data Protection and Security Requirements
QforMedia requires subcontractors to adopt organisational and technical measures that ensure an adequate level of protection for any data or assets involved in the provision of services. These measures must be proportionate to the sensitivity of the information handled and consistent with recognised industry standards.
Access to confidential information must be strictly controlled and limited. Any unauthorised disclosure, loss or misuse of such information constitutes a violation of this policy and may result in immediate termination of the subcontracted relationship.
5. Onboarding, Acceptance of Obligations and Delegation Controls
Before commencing any engagement, subcontractors must acknowledge and accept the obligations contained in this policy. QforMedia may request formal confirmations, signed undertakings or evidence of internal controls as part of the onboarding process.
Subcontractors may not delegate, transfer or subcontract any portion of the contracted services without QforMedia’s express written authorisation. Any permitted third party must operate under the same obligations and governance principles established in this policy.
6. Oversight, Monitoring and Assurance Mechanisms
QforMedia maintains continuous oversight of subcontracted activities to ensure adherence to its governance standards. This may include periodic assessments, reviews of operational procedures, verification of compliance with confidentiality requirements or evaluations of deliverables and workflows.
Where deficiencies or risks are identified, QforMedia may issue corrective instructions, impose additional controls or, if necessary, terminate the contractual relationship.
7. Policy Review and Evolution
Given the dynamic nature of regulatory frameworks and industry practices, QforMedia periodically reviews its governance policies to ensure continued relevance and adequacy. Updates to this section of the Corporate Governance Manual will apply to all existing and future subcontractor engagements once formally issued.
8. Governance Statement
QforMedia affirms its commitment to responsible management, operational excellence and the protection of the company’s strategic and reputational interests. The standards articulated in this policy ensure that subcontractors contribute to QforMedia’s activities in a manner consistent with the company’s values, governance principles and expectations of professional conduct.
