Background Check Policy

1. Purpose and Relationship to Governing Documents

This Background Check Policy ("Policy") is published by VA WORKS, LLC ("Consultant") and forms part of the Governing Policies referenced in the Master Service Agreement (MSA), the MSA Terms and Conditions (https://vaworks.com/MasterServiceAgreement), and any applicable Scope of Work Terms and Conditions (https://vaworks.com/SOWSelection). In the event of conflict, priority shall be determined in accordance with the MSA.

The purpose of this Policy is to ensure a secure and trustworthy workforce by requiring background checks for all personnel before they are assigned to Company client accounts.

2. Scope

This Policy applies to all new hires, contractors, and remote personnel located in any foreign country who will access Non-Public Personal Information (NPI) or perform services related to regulated mortgage or client activities.

3. Background Check Procedure

• Timing: Background checks are conducted prior to final onboarding and before personnel are granted access to client systems.
• Provider: All checks are performed through a vetted third-party screening provider.
• Jurisdiction & Compliance: Background checks are conducted in the country of residence and/or employment, including any foreign country where personnel are engaged, and are performed in accordance with all applicable local labor, employment, and privacy laws of that jurisdiction. Consultant ensures that no background check is performed in a manner inconsistent with governing legal requirements.

4. Screening Components

Depending on the role and client requirements, background checks may include:

• Identity verification
• Criminal history (local and federal, where available)
• Employment history verification
• Education verification (if required for the role)
• Reference checks
• Drug screening (if specifically required by the client contract)

5. Consent and Privacy

All candidates must provide written consent before a background check is performed. Screening results are treated as confidential and shared only with authorized Consultant personnel or, where required, the requesting client.

6. Disqualification Criteria

Employment or engagement may be denied based on results that conflict with:

• Client risk tolerance requirements;
• Applicable laws or regulations; or
• The sensitivity of the role.

Each case is reviewed individually by HR and management to ensure fair and lawful evaluation.

7. Recordkeeping

All background check documentation is securely stored in the personnel file and retained for at least three (3) years, or longer if required under client agreements or applicable law.