Background Check Policy

1. Background Check Policy

   1. The purpose of this Background Check Policy (“Policy”) is to establish the background check requirements and processes for solutionXchg prospective employees, current employees, and certain volunteers and contractors to protect employees, clients, and assets.

2. Applicability

   1. This Policy applies to all employees and contractors.

3. Definitions

   1. Applicants are current, former, or prospective employees who submit information to be considered for positions at solutionXchg, including individuals not currently employed by solutionXchg. This Policy shall apply to all Applicants for the following types of positions at solutionXchg:
      • All full and part-time employees;
      • All Officers and Partners;
      • All exempt professionals.
      • Temporary position employees
      • Anyone else solutionXchg employs.
   2. Background Check means the process of gathering and reviewing criminal history records.
   3. Conviction means a guilty verdict, a guilty plea or a plea of Nolo Contendere (“No Contest”) of felony or misdemeanor, other than minor traffic offenses.
   4. Criminal History Check means the process of gathering and reviewing criminal history records or information furnished by a criminal justice agency or third party vendor in the business of obtaining and providing criminal history records relating to an individual’s criminal convictions. A criminal history record does not include an individual’s conviction records that have been sealed by court order. Criminal records include in-state, out-of-state and international criminal history, including misdemeanor and felony convictions.

4. General

   1. Roles and Responsibilities:
      1. The Managing Partners are solely authorized to conduct and oversee the Background Check process necessitated pursuant to this Policy on behalf of solutionXchg.
      2. All solutionXchg employees are responsible for ensuring the integrity and confidentiality of the Background Check process.
   2. Background Check General Requirements
      1. Type of Background Check Required: Employees on sensitive project must consent to a Background Check to be considered for assignment to the project or may not be permitted to participate or share in information on sensitive client projects.
         
      2. Type of Background Check Required:
         
         1. SSN verification
            
         2. Address verification
         3. Local and federal Criminal Background Check
      3. When Background Checks Are Conducted: Background Checks are conducted on all employees that have access to, or are assigned to a project where client requests a background check on hired personnel.
         
   3. POLICY AND PROCEDURE FOR REVIEWING BACKGROUND CHECK RECORDS AND INFORMATION
      1. Arrests Not Considered, Charges and Convictions are Considered
 solutionXchg will not consider arrest information unless the arrest resulted in pending criminal charges. In such circumstances, solutionXchg will contact the employee, and may contact other parties, to obtain further information in order to assess reliability of the charge information. solutionXchg will consider any information revealed regarding convictions, although a conviction shall not automatically preclude initial or continued employment.
         
      2. Job-relation and Business Necessity Criteria When considering pending charges and convictions, solutionXchg will evaluate the time frame, nature, gravity, and relevancy of the conviction or charge offense as it relates to the job duties and solutionXchg’s business necessities.
   4. ADVERSE ACTION NOTIFICATION PROCEDURES
      1. If information is revealed in a Criminal History report that could potentially result in an adverse employment decision, solutionXchg shall take the following steps:
         1. Pre-Adverse Action Notice: solutionXchg will notify the employee or in writing that negative information was revealed during the Background Check process which may impact the employment or project assignment decision and will provide a copy of the supporting report to the applicant or employee. The applicant or employee will be provided no less than five days to challenge the information provided in the report and take steps to correct inaccuracies or provide explanation.
         2. Decision Stay: A final employment decision shall not be made until the Applicant’s or employee’s new information has been considered or such time that the Applicant or employee fails to respond as required.
   5. SECURITY SENSITIVE CONTRACTORS
      1. Contractor: Contractors or subcontracted employees performing Security Sensitive work are treated the same as employees.
   6. Employee Self-Disclosure Requirements
      1. Criminal Conviction or Felony Charge: All current employees that have been asked to participate in a client project that requires a background check on file are required to self-disclose criminal Convictions or felony charges filed against them that occur on or after the Effective Date of this Policy within three business days of the Conviction or felony charge to solutionXchg. Employees failing to self-disclose may be subject to disciplinary action, up to and including termination.