DATE OF LAST UPDATE: JANUARY 19, 2024

Background Check Policy

1. Purpose‍
   The purpose of this Background Check Policy is to establish guidelines and procedures for conducting background checks on individuals seeking employment or currently employed by Finpace. The policy aims to ensure the security and integrity of our workforce by evaluating the suitability of individuals for specific roles and responsibilities, in alignment with the organization's commitment to information security (ISO 27001:2013 Control A.7.1).

2. Scope
   ‍This policy applies to all individuals, including employees, contractors, and third-party personnel, who may have access to sensitive information, information systems, or other critical assets of Finpace.

3. Policy Statements
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   3.1. Background Check Process
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   Pre-Employment Checks:

• All candidates selected for employment will be subject to pre-employment background checks.
• Background checks may include criminal history, employment verification, educational qualifications, and any other checks deemed necessary for the specific role.‍
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  Continuous Employment Checks:

1. Employees may be subject to periodic background checks based on the nature of their roles and responsibilities.
2. This may include checks to ensure ongoing compliance with relevant job requirements.
3. Background checks on all individuals, including employees, contractors and third-party personnel are conducted at least once every two years.‍
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   3.2. Consent and Notification
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   Consent:

• Obtain written consent from individuals before initiating any background checks.
• Clearly communicate the purpose and scope of the background check.‍
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  Notification:

1. Notify individuals of their rights under applicable laws and regulations.
2. Inform individuals of the potential impact of the background check on employment decisions.‍
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   3.3. Confidentiality and Data Security
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   Handling of Information:

• Ensure that all information obtained during background checks is treated confidentially and securely.
• Limit access to background check results to individuals involved in the hiring or employment decision-making process.‍
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  Data Retention:

• Establish clear guidelines for the retention and secure disposal of background check information.

• Responsibilities
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  HR Department:

• Oversee the implementation of background checks in compliance with this policy.
• Maintain records of background checks and related documentation.‍
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  Hiring Managers:

• Work with HR to identify the appropriate background checks for specific roles.
• Ensure that candidates are informed about and provide consent for background checks.

• Review and Compliance
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  Regular Review:

• Periodically review and update this policy to reflect changes in legal requirements, industry standards, and business needs.‍
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  Compliance:

• Ensure that all background checks are conducted in compliance with applicable laws and regulations.

6. Approval and Communication
   ‍This Background Check Policy is approved by the current CEO at Finpace: B. Forrest Tuten. HR is responsible for communicating this policy to all relevant personnel.

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