Background Check Policy

Policy governing employment background checks, including authorization, disclosure, adverse action procedures, and record retention requirements under the FCRA.

Purpose

• This policy establishes the rules for obtaining and using employment background checks in a manner that is fair, job-related, and compliant with the **Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq.** It also supports compliance with EEOC guidance, applicable state fair-chance laws, and any jurisdiction-specific notice or waiting-period requirements.

Scope

• This policy applies to all U.S. applicants, interns, contingent workers, and employees when the Company requests a consumer report or investigative consumer report for employment purposes. **California employees:** screening and notice practices must also be reviewed for compliance with California’s fair chance and privacy requirements. **New York employees:** any applicable state and local fair-chance rules must be followed. **Illinois employees:** screening must not conflict with state anti-discrimination and privacy requirements.

Definitions

• Key terms used in this policy are defined in the **Definitions** section above. Additional terms may be defined in the applicable background check authorization, disclosure, or adverse action notices provided to the individual.

Policy Statement

• The Company may conduct background checks only when the screening is job-related, consistent with business necessity, and approved for the applicable role. Background checks may include identity verification, employment verification, education verification, criminal history, motor vehicle records, professional license verification, and other lawful checks relevant to the position. The Company will not use background information in a way that unlawfully discriminates on the basis of race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, or genetic information.

Procedure

• 1. **Pre-screen approval:** HR or the designated policy holder confirms the screening type is permitted for the role and jurisdiction. 2. **Standalone disclosure and authorization:** Before ordering a consumer report, the individual must receive a clear, standalone FCRA disclosure and provide written authorization. 3. **Vendor engagement:** The Company may use only approved consumer reporting agencies that contractually agree to maintain confidentiality, security, and lawful reporting practices. 4. **Review of results:** HR and the hiring manager may review results only to the extent necessary to determine job-related suitability. 5. **Good-faith individualized assessment:** Before any adverse action based on criminal history or other potentially disqualifying information, the Company will conduct a good-faith review of the information, the job duties, and any applicable legal requirements. 6. **Pre-adverse action notice:** If the Company is considering adverse action, it will provide the required pre-adverse action notice, a copy of the report, and a summary of FCRA rights, and allow a reasonable period for response where required by law or company practice. 7. **Final adverse action notice:** After the review period, if the Company proceeds, it will issue the final adverse action notice identifying the CRA and required contact information. 8. **Record retention:** Screening authorizations, disclosures, notices, and related decision records will be retained securely for the period required by law or company retention schedule, whichever is longer.

Roles & Responsibilities

• **HR / Talent Acquisition:** administer disclosures, collect authorizations, coordinate with the CRA, and maintain records. **Hiring Manager:** evaluate only job-related criteria and avoid unauthorized use of background information. **Compliance Officer / Legal:** review jurisdiction-specific requirements, adverse action language, and vendor agreements. **Policy holder:** owns this policy, approves exceptions, and ensures annual review. **Consumer Reporting Agency:** provide accurate reports, required notices, and dispute handling information as contractually required.

Compliance and Discipline

• Failure to follow this policy may result in disciplinary action, up to and including termination of employment, and may also expose the Company to regulatory, civil, or contractual liability. Any employee who bypasses required disclosures, authorizations, or adverse action steps may be subject to a documented warning, retraining, removal from hiring responsibilities, or a PIP, depending on the severity and impact of the violation.

Exceptions

• Any exception to this policy must be approved in writing by HR and Legal before a report is requested or a hiring decision is made. Exceptions may not be used to bypass FCRA notice, authorization, or adverse action requirements. Jurisdiction-specific rules, including state fair-chance laws, must always be followed.

Review and Revision

• This policy will be reviewed at least annually and whenever the FCRA, EEOC guidance, or applicable state or local law changes. The policy holder is responsible for updating forms, vendor requirements, retention periods, and adverse action templates as needed.