Credit Investigation Policy

Candidates who have accepted an offer of employment in positions with exposure to Company financials, cash management and banking should expect to undergo a credit investigation. The Company will arrange for this investigation and the employee will not be charged. This background check applies to only those individuals who are hired to work in a financial capacity. Your continued employment may be conditional upon the findings of this inquiry.

As required by the federal Fair Credit Reporting Act (FCRA), the Company will provide a clear, standalone written disclosure and obtain the candidate’s written authorization before requesting a credit report. If information in the report may result in an adverse employment decision, the candidate will first receive a pre-adverse action notice (including a copy of the report and a summary of FCRA rights) and an opportunity to dispute inaccuracies before any final adverse action is taken. Because a number of states (including California, Colorado, Connecticut, Hawaii, Illinois, Maryland, Nevada, New York, Oregon, Vermont, and Washington) restrict or prohibit the use of credit history in employment decisions, HR will confirm that the applicable financial-services exemption applies before conducting a credit check in those states.

General information, not legal advice. Treat this as a drafting starting point, not a finished policy — employment law varies by jurisdiction and changes often, so have a licensed attorney tailor it to your situation before you rely on it.

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