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THIRD-PARTY DUE DILIGENCE

STEP 1: COMPANY SPONSOR REQUEST


OrthoPediatrics (the "Company") is a global company that is committed to following the anti‐corruption laws of every country in which we do business. Many of these anti-corruption laws, most notably the US Foreign Corrupt Practices Act and the UK Bribery Act, require us to conduct anti-corruption due diligence on prospective third-party business partners such as representatives, agents, consultants, distributors, re-sellers, joint venture partners, and other parties that may act, communicate, or do business on our behalf ("Third-Parties").


In order to meet this requirement, we have implemented a three-step due diligence process that must be completed before we may enter into or renew an agreement with any Third-Party. The completion of this Company Sponsor Request is the first step in that process, which is explained below:


Step 1: Company Sponsor Request

The Company Sponsor, who is the Company employee who wants the Company to enter into an agreement with a prospective Third-Party, completes and submits this online Company Sponsor Request. Upon the Company Sponsor's submission of this Company Sponsor Request, a link to an online Third-Party Questionnaire automatically is emailed to the prospective Third-Party. The Company Sponsor is copied on the email containing the link.


Step 2: Third-Party Questionnaire

The prospective third-party completes and submits the online Third-Party Questionnaire.

Step 3: Legal Decision

The Company's legal and compliance team analyzes the information provided in response to this Company Sponsor Request and the Third-Party Questionnaire and obtains and evaluates any additional information necessary to conduct sufficient due diligence on the prospective Third-Party. After completing the due diligence review, the Company's legal and compliance team provides legal guidance to the Company Sponsor regarding whether the Company may enter into an agreement with the prospective Third-Party.


The third-party due diligence process may take up to three weeks from a prospective Third-Party's submission of Third-Party Questionnaire responses, depending the the level of legal and compliance risk a prospective Third-Party presents. Higher-risk prospective Third-Parties typically take close to three weeks because they require more extensive due diligence. Lower-risk prospective Third-Parties typically take much less time, sometimes just a few days. The Company Sponsor will be notified upon completion of each step of the due diligence process.


Please complete this Company Sponsor Request to the best of your ability. You may save your answers and resume your request at a later time by clicking on the "Save Answers and Resume Later" tab.


If you have any questions regarding this Company Sponsor Request or the third-party due diligence process, please contact our compliance team by visiting www.taftethics.com/orthopediatrics-help-request.

Important Definitions

Below are definitions for terms used throughout this request.


Company: OrthoPediatrics Corp. and any of its subsidiaries and affiliated companies


Third-Party: The business entity that seeks to enter into a business relationship with the Company and is the subject of this questionnaire


Company Sponsor: The Company employee (often a buyer or category manager) who wants the Company to enter into an agreement with a Third-Party (the person completing this request form should be the Company Sponsor)


Government Entity: Any local, state, provincial, national, or federal government organization, agency, department, court, etc.; international organization, such as the World Trade Organization; or government-owned company


Government Official: An officer, director, employee, or other representative of a Government Entity


Company-Related Business: The products or services a Third-Party provides the Company, any activity a Third-Party does in the course of providing products or services to or on behalf of the Company, or any activity that otherwise involves the Company or the Company's products or services

Information About The Company Sponsor

Company Sponsor's name:*
Is this the first Company Sponsor Request you have submitted for this Third-Party?*
It may take up to three weeks from when a prospective Third-Party submits Third-Party Questionnaire responses for the Company to complete the due diligence process. Do you require a decision regarding whether the Company may enter into an agreement with this Third-Party sooner than three weeks from the third-Party's submission of Third-Party Questionnaire responses?*
By what date do you require a decision?*
In exceptional circumstances, the Company may be able to expedite the due diligence process depending on the prospective Third-Party's background. We will make every effort to complete the due diligence process and to decide whether the Company may hire the prospective Third-Party by the date you provide.

Information About The Third-Party

Please enter the name of the Third-Party exactly as it appears or will appear in the signed agreement between the Company and the Third-Party.
Name of the Third-Party's employee or representative who is our primary point of contact:*
The onlineThird-Party Questionnaire automatically will be emailed to the Third-Party at this email address.

The Company's Relationship With The Third-Party

Does the Company currently work with the Third-Party?*
Has the Company worked with the Third-Party in the past?*
Did anyone introduce or recommend the Third-Party to you or another Company representative?*
Name of the person who introduced or recommended the Third-Party to you or another Company representative:*
Is the person who introduced or recommended the Third-Party a Government Official?*
Please briefly explain why this Third-Party was selected. If the Third-Party was not your first choice, please include additional details.regarding your selection.
What best describes the type of business relationship the Third-Party has or will have with the Company? Select only one.*
For example, if the Third-Party is a service-provider, please include all countries in which the Third-Party will provide services to or on behalf of the Company. If the Third-Party is a distributor, please include all countries in which the Third-Party will distribute Company products. If the Third-Party is a supplier, please include all countries in which the Third-Party produces goods that the Company will purchase.
Is the Third-Party seeking payment for introducing the Company to Government Officials or for providing contacts at Government Entities?*
Will the Third-Party represent or otherwise act on behalf of the Company before any Government Entities or Government Officials?*
Will the Third-Party assist the Company in obtaining any type of government or regulatory permit, certification, registration, license, or approval?*
Is the Third-Party a transport, logistics, or other service provider that will interact with customs agents on the Company's behalf?*
Will the Third-Party sell Company products or services to Government Entities?*
Will the Third-Party submit tenders to enable the sale of Company products or services to Government Entities?*
Will anything of value be provided to any Government Official in the course of the Third-Party conducting Company-Related Business?*

Financial Information

Will the Company pay the Third-Party (e.g. the Third-Party is a supplier) or will the Third-Party pay the Company (e.g. the Third-Party is a reseller or distributor)?*
What is the average amount (in US dollars) that you anticipate the Company will pay the Third-Party each year of the agreement?
What is the average amount (in US dollars) that you anticipate the Third-Party will pay the Company each year of the agreement?
Will compensation be based on performance (i.e. a commission or success fee)?*

Certification

By signing below I certify that I have performed such procedures and inquiries as necessary to ensure that the answers provided in this Company Sponsor Request are accurate and complete to the best of my knowledge.

Please use your mouse or finger to sign.
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