Compliance framework

Compliance is not a footer link at Koromanda. It is the product. This page explains the legal framework we operate under, what we audit before any worker is deployed, and what documentation clients receive per deployment. It is written to be read by procurement, legal, and operations leads.

This page is maintained as the canonical compliance document. Last reviewed: 18 March 2026. Next scheduled review: 18 September 2026. Material changes will be versioned and dated.

Legal framework

Dutch labour leasing law

Koromanda operates as an Employer of Record under a Waadi-registered structure delivered in partnership with ThisWorks. The Waadi (Waadi: Wet allocatie arbeidskrachten door intermediairs) and Wtta (Wet toelating terbeschikkingstelling van arbeidskrachten) regulate the lending of workers in the Netherlands. Operating without compliant registration is a serious offence and creates client-side exposure as the user undertaking.

What this means for clients: the worker is employed by Koromanda. The client is the user undertaking, not the employer. CAO obligations, wage tax, social security, and continued-pay obligations sit with Koromanda. The client receives capacity.

EU Pay Transparency Directive

The Directive (EU) 2023/970 requires pay to be benchmarked to comparable roles within the user undertaking and discloses pay structures to workers and authorities on request. Wage arbitrage models that pay deployed workers below market for the same work are not compliant.

Koromanda's position: every deployed worker is paid at or above the applicable CAO scale for the role and seniority. Pay differentials versus domestic workers exist only where they reflect documented role, experience, or certification differences — never country of origin.

IND immigration

We operate within the IND (Immigratie- en Naturalisatiedienst) Recognised Sponsor framework. [verification pending — current Koromanda or ThisWorks sponsor status to be confirmed before launch.] Recognised Sponsor status enables expedited processing under the Highly Skilled Migrant scheme where role salary thresholds are met, and standard work-permit pathways otherwise.

Energy Efficiency Directive (EED)

The recast EED ((EU) 2023/1791) requires large enterprises to conduct energy audits and report on energy management. Koromanda offers EED-aligned audit and reporting services, offered separately from workforce deployment. Workforce deployment is the core revenue stream; EED is a structured way to begin a relationship with energy-intensive operators before a workforce engagement is on the table.

What we audit before deployment

Every candidate completes the following verification before being shortlisted for client interview:

1. Identity and right-to-work documentation — passport validity, prior visa history, criminal-record self-declaration with police clearance certificate
2. Qualification verification — original certificates and transcripts cross-checked against issuing institution where possible; NLQF mapping recorded
3. Experience verification — prior employer references, project documentation, role-complexity assessment
4. Safety certification — VCA programme enrolment and completion (B-VCA for general; VOL-VCA for supervisors)
5. Electrical competency (where applicable) — NEN 3140 VP theory completion in India; practical assessment on arrival. NEN 3840 VP for HV roles
6. Role-specific certification — F-gas, IPAF, MEWP, or client-defined competencies as required
7. Language baseline — English B1 minimum verified at intake; Dutch A2 delivered through structured programme pre-departure
8. Medical fitness — fit-to-work certification per industry standard

What clients receive per worker

A compliance pack is provided for every deployed worker, including:

• Verified qualification documentation with NLQF mapping
• VCA and electrical certifications with issuing-body validation
• Right-to-work documentation and IND case reference
• Employment contract under Koromanda EOR structure with applicable CAO scale referenced
• Insurance certificates (employer liability, health, AOV/disability where applicable)
• Pre-departure briefing record and language assessment
• On-arrival induction completion record

Documents are available in a per-deployment digital folder. Audit access is granted to operator compliance, security, and uptime teams on request — including read-only review during Tier III/IV certification cycles.

Insurance and liability

The EOR structure separates the employer (Koromanda) from the user undertaking (client). Standard liability allocation under this structure:

• Koromanda holds: employer liability for the worker, wage payment, social security remittance, employment-law obligations, pre-departure programme delivery, immigration compliance.
• Client holds: workplace safety as user undertaking under Dutch Arbo law, site-specific supervision, equipment provision, operational direction.

This allocation is documented per engagement in the master services agreement. Where a project introduces unusual risk allocation — for example, working at height, offshore deployment, live-load HV switching, or restricted-access data-hall work — bespoke insurance arrangements are agreed in writing before deployment.

Background checks and access for data-centre operators

Data-centre operators typically require background-check standards beyond general industrial baseline. Koromanda supports BS 7858 (or equivalent national standard) where the operator requires it; the check is conducted before deployment and refreshed on the operator's cycle. NDAs and confidentiality terms flow through to deployed staff via the Koromanda EOR contract — no second negotiation with each technician is required. Where a site is governed by hyperscaler tenancy with vendor-escort or unaccompanied-access tiers, the operator's access protocol is respected; Koromanda does not contract around it.

What we do not do

A short list of things we have explicitly chosen not to do, because they create unacceptable legal or ethical risk:

• Charge candidates placement fees. Aligned with WHO ethical recruitment principles. Certification costs are carried against the deployment contract.
• Pay below CAO scale. Wage arbitrage is not the business.
• Deploy uncertified workers. Pre-departure certification completion is a precondition of travel.
• Operate as a labour agency outside the Waadi/Wtta framework. Every engagement is structured EOR.
• Place workers from WHO safeguards-list source countries into healthcare roles via private channels. India is currently on this list for healthcare. Healthcare corridors require government-to-government mediation. We do not bypass this.

Document status

• Last reviewed: 18 March 2026
• Next scheduled review: 18 September 2026
• Maintained by: Koromanda compliance lead
• For questions: compliance@koromanda.com