Objective-

The company recognizes that many people have made mistakes that result in a criminal record and that people with a criminal record are often capable of becoming valuable employees.

We consider criminal records as only one factor in the hiring decision process. A criminal record is not a disqualification for employment unless:

1. The record consists of a conviction or pending prosecution
2. There is a connection between the nature of the offense and the nature of the job
3. The offense is recent enough to be of concern
4. There is insufficient evidence of rehabilitation
5. The risk posed by the criminal record outweighs the applicant’s qualifications

Policy

Timing of Criminal Record Check

There will be no questions about criminal records on employment application forms or during the initial interview.

A criminal records check will be conducted after the initial interview if the applicant is considered a strong candidate for the position.

Qualified Suppliers

All contracts to conduct criminal record checks will be awarded to highly qualified suppliers that maintain strict quality standards, including:

• a. Confirming all information from data bases with the original criminal record
• b. Reporting a record only when the full name and at least one additional identifier match
• c. Reporting current disposition of all charges
• d. Reporting all charges from a single incident as a single entry
• e. Strict quality control standards including human review
• f. Certification of reliability from most reputable certifying organization

Suppliers will not be selected on the basis of price.

Content of Criminal Record Reports

An applicant’s criminal record will be considered only when:

• a. An arrest resulted in conviction or is a pending prosecution
• b. The nature of the prior offense has a direct relation to the risks associated with the position sought
• c. The offense is recent enough to indicate a significant present risk

Risk analysis will be performed by trained professionals, taking into consideration data about risk reduction as the number of years since an offense has been committed increases.

Relevance Matrices

To ensure that only relevant criminal record information is considered, a relevance matrix will be created for each open position listing the specific convictions that are relevant for that position and the period of time during which it is relevant.

Background checking suppliers will be provided with the appropriate matrix and instructed to report only convictions that meet the matrix criteria.

Notice of Criminal Record Check

Prior to conducting a criminal record check, the applicant will be informed that he/she is considered a serious candidate for the position, that the criminal record check will be performed, and the relevance matrix that will be used.

The candidate will be offered the opportunity to provide information about his/her criminal record that fits the relevance matrix.

Opportunity to Correct

If a criminal record report contains information that may result in the applicant not being offered the position for which she has applied, the applicant will be notified and provided:

• a. Nature of the reported offense
• b. Date of offense
• c. Jurisdiction of offense

The applicant will be told that she has the opportunity to challenge any information that is incorrect and the number of days she has to do so.

The notification will be made by e-mail. If the applicant does not have an e-mail address, the notification will be made by the faster available method.

If the applicant indicates that a reported conviction is incorrect, the background checking company will be notified and asked to investigate.

Opportunity to Mitigate

An applicant will also be permitted to provide information indicating that the conduct involved in the prior offense is not as serious as the title of the offense indicates including:

• a. Degree of force involved
• b. Extent of physical harm to the victim
• c. Magnitude of monetary lossv
• d. Diminished capacity at the time of the offense

No decision regarding the applicant will be made while the investigation is pending.

Evidence of Rehabilitation

Applicants will also be given the opportunity to provide evidence that they have rehabilitated themselves and no longer pose an increased risk of harm, including:

• a. Stable family life
• b. Stable work history
• c. Character references
• d. Community service
• e. Parole or probation officer statements

If requested, an HR professional will speak to an individual who has information regarding an applicant’s rehabilitation.

Timing

The applicant will be given at least seven days to provide the above information. The position for which the applicant has applied will not be filled until applicant has submitted all the information he/she has and this information has been evaluated unless it is imperative that the position be filled sooner.

If the position is filled prior to receipt and evaluation of this information, and it is determined that the applicant is qualified, he/she shall be notified that they will be offered the next position of this type that becomes open.

Decision

The final hiring decision will be made comparing an applicant with a criminal record to other candidates on all relevant bases, including:

• a. Education/Training
• b. Prior work experience/references
• c. Interview
• d. Prior conduct, including all material submitted by the applicant.

We will choose the candidate that offers the greatest overall strength.

Decision Maker

An HR professional who believes that an applicant with a criminal record is the strongest candidate for a position has the option of having their choice reviewed by the Vice President of Human Relations.

A decision not to hire an applicant because of his/her criminal record must be reviewed and approved by the Vice President of Human Resources.

Training

Human resources professionals will be thoroughly trained in this policy, legal requirements, and risk analysis.

Diversity

The company shall maintain an active diversity program, under the direction of a senior executive. The diversity director’s reports will include an analysis of how the company’s decisions regarding candidates with criminal records affected diversity.