Hewitt Associates LLC, its subsidiaries, and affiliates ("Hewitt") is committed to bringing the highest quality services to our clients. To serve that effort, Hewitt hires talented, client-oriented, and ethical associates to serve our customer base. Hewitt believes that hiring qualified individuals contributes to our overall success as an organization.

Purpose of Background Checking

A background check is an important part of the selection process at Hewitt, helps promote a safe and secure work environment, and affords additional protection for our clients. Background checks provide additional applicant-related information that helps determine an applicant's eligibility for employment and a current associate's eligibility for continued employment.

The purpose of a background check is twofold — to protect Hewitt, its associates, clients, and data from anything that may threaten the security and/or integrity of Hewitt's work environment and to help assess the qualifications and suitability of an applicant for a position. Hewitt conducts background checks and pre-employment screenings in compliance with all legal and professional standards.

When Background Checking Is Used

New Associates: Hewitt is committed to completing a comprehensive background check on every associate in accordance with the laws and customs of the country in which he or she works. This policy requires that all job applicants to whom an offer of employment has been made pass a background check screening as a condition of employment. Depending on requirements of the position, an applicant's information is reviewed and verified against set criteria to determine eligibility.

Current Associates: Current associates may be required to go through a background check, and the same standards outlined in this policy must be met for continued employment with Hewitt. Circumstances that might necessitate a background check include, but are not limited to, transferring to a client team that requires a more extensive background check, being on a team that implements expanded background checking, or assuming a role that requires driving a Hewitt-owned vehicle. Hewitt reserves the right to conduct a background check on associates at anytime. Background checks may include any of the above mentioned components.

If a current associate does not meet the background checking standards set forth in the policy during the course of his or her employment with Hewitt, he or she will have the same ability to challenge any adverse finding. However, such finding may also result in separation from the firm.

Global Background Checking Standards

The laws and customs of countries vary considerably and, as a consequence, the checks conducted will vary. However, Hewitt has set a global standard that we are working to meet in all locations to the extent allowed by local law including:

1. Verify the most recent educational credentials, employment for the prior 7 years, and criminal history.
2. Use national ID numbers, such as SSNs in the US, to support the criminal check, where such numbers exist.
3. Implement reporting capabilities allowing us to monitor results over time and confirm team member eligibility, if needed, to clients.
4. Provide for a consistent means of validating eligibility across locations (e.g., falsification of educational credentials will be a disqualifying result in all locations, within any local legal limits).

Our ability to complete some components of client-desired background checks varies by country. In addition to legal limitations, the infrastructure may not exist to complete some components (e.g., commercial credit checks are not available in all areas), and Hewitt's background checking program may vary by business segment. To the extent that these checks can be done in each specific country, and are desired by the client, they will be performed at an additional cost. They are not part of our global standard.

Additional optional checks may be completed where they are possible in a specific country and are desired and paid for by the client.

Background Checking Standards for North America

Hewitt's North American background checking policy limits all background check inquiries to information that impacts job performance and the workplace. A consumer report and/or investigative report will be requested as part of the background checking process for all new hires and for current associates as outlined further below. Inquiries are conducted by an outside agency, as hired by Hewitt, in accordance with applicable federal and state/provincial laws, including the Fair Credit Reporting Act (FCRA) (n/a in Canada).

Consumer Reports: A Consumer Report is run for all applicants to whom an offer of employment has been made, with the exception of some business-process outsourcing clients where the contract agreement does not require an additional background check to be run as part of joining Hewitt. It may also be run on an existing associate if he/she is moving to a team which requires it to be run, or if the associate's current team requirements have changed based on client needs.

A Consumer Report consists of information deemed to have a bearing on job performance, and may include information from public and private sources, public records, former employers, and references. The scope of the report may include information concerning the applicant's civil and criminal court records, education, credentials, past addresses, Social Security Number/Social Insurance Number, previous employment, driving record, and personal references.

Investigative Consumer Reports: An Investigative Consumer Report may be run under special circumstances or to investigate inappropriate conduct. This report is based upon interviews that may contain information relating to the applicant's character, general reputation, personal characteristics, or mode of living. Applicants have the right to request additional disclosures of the nature and scope of the investigation and statement of their rights. An Investigative Consumer Report may also include reference checks from former employers or references provided by the job applicant. Any reference check is strictly limited to job-related information of report.

Timing: In North America, Hewitt has a policy of conducting background screening reports on all job applicants as a condition of employment. All checks will be started after an employment offer has been made, prior to a new hire's start date, and employment is contingent upon successful completion of the check. Ideally, all checks will be successfully completed prior to applicant's start date.

Confidentiality: The results of the background check are shared by the vendor with a limited number of associates and only when further action is needed based on the results of the check. Clients may also request an audit of those associates who support their team and have access to their employee personal data. Hewitt's position is to provide aggregate data only confirming that all associates assigned to their team have passed a background check in accordance with the contract requirements.

Type of Check

Criteria

Education Verification	Verify highest degree
Employment Verification	Verify previous seven years of employment, including current employer. Verify salary data on most recent employer, perform due diligence to verify.
Criminal History Check	Based on seven-year residence history or the number of years allowed by the applicable state/provincial laws if less than seven to include: - County by county records check; and - Federal court records check. - Check against national criminal database.
Social Security Trace (n/a in Canada)	Uncovers names and addresses associated with the applicant's social security number (SSN). Data is used to target counties of past/current residence for criminal check investigations.
Government Watch Lists (e.g., DRPL, OFSI)	Search for names of those not authorized to be in the United States.
Motor Vehicle Check	Required annually for any new or existing associates whose job requires driving a Hewitt vehicle, inclusive of new-hires.

Modifications

We reserve the right to modify this global policy statement and any location-specific policies. The effective date of these modifications will be communicated a minimum of 10 business days prior to the change.