Employment Screening for Applicants

The Company requires all applicants who have been made a conditional offer of employment to undergo employment screening as part of the hiring process. Applicants will be required to complete an Application for Employment packet, which will include a Disclosure and Authorization form authorizing the Company to conduct a background check on the applicant.

The applicant must also be given a copy of the document titled “A Summary of Your Rights Under the Fair Credit Reporting Act.” The applicant must complete and sign both the Application for Employment and the Disclosure and Authorization form. These forms may also be provided electronically or via hard copy by a Company vendor. The Company will then request a background report from one of its approved third-party providers for employment screening.

If a Company associate checks an applicant’s references or employment history without using a third party, the background check authorization and the summary of rights forms do not need to be signed by the applicant.

The scope of the employment screening process will be determined by the Company and, at the Company’s discretion, may be narrowed or broadened depending on the particular circumstances of the case. Generally, employment screening will consist of the following elements:

• Social Security Number Trace: Confirming the applicant’s social security number and identifying relevant prior aliases and addresses to assist in the criminal conviction search;

• County Felony/Misdemeanor Criminal Conviction Search: Searching the appropriate court records relating to the applicant’s county of residence for evidence of felony and/or misdemeanor convictions in the previous seven (7)years (this time period may change in order to comply with applicable law);

• Education Confirmation: Confirmation (where available) of attendance, degree and graduation date from the institution where the applicant obtained his or her highest degree;

• Employment Confirmation: Confirmation (where available) of employment, position, pay, reason for leaving and eligibility for rehire from all employers who employed the applicant in the previous five (5) years (this time period may change in order to comply with applicable law); and

• Motor Vehicle Record: Reporting accidents, suspensions and violations from the state in which the applicant is a licensed driver for the maximum period provided by the Department of Motor Vehicles and for no less than the previous three (3) years.

Human Resources will evaluate the background report to ensure there are no discrepancies between the report and the information provided by the applicant on his or her Application for Employment or at any time during the hiring process. A candidate should not be hired if employment screening reveals information not reported or contrary to information that is self-reported during the hiring process (e.g., information reported on the employment application or in an interview), absent justification from the applicant that is acceptable to the Company.

If no inaccurate information is found and no omissions are evident, Human Resources will evaluate the background report to determine whether the valid information contained therein is consistent with the job being sought. In the event Human Resources discovers that an individual has a criminal conviction, Human Resources will consider the nature and gravity of the offense or offenses, the time that has passed since the conviction and/or completion of any related sentence, and the nature of the job assignment prior to making any employment decision.

Information released pursuant to the employment screening process will remain exclusively in the possession of Human Resources and will only be shared with individuals who have a business need to review the information to make employment decisions.