First Advantage Modern Slavery Statement

First Advantage is a significant international business listed on NASDAQ, with its headquarters in Atlanta, Georgia USA.

First Advantage recognizes its responsibility, as a global corporate citizen, to give back to and produce an enduring, positive impact on the communities in which we operate. This commitment to corporate social responsibility encompasses operating responsibly and adhering to the highest ethical standards. Consistent with this principle, First Advantage takes a zero-tolerance approach to any form of modern slavery in its operations or supply chains.
This statement is intended to meet First Advantage’s obligations under the applicable Global Modern Slavery legislation including but not limited to the requirements of section 54 of the Modern Slavery Act 2015 (UK) and the Commonwealth Modern Slavery Act 2018 (Australia). This statement constitutes our modern slavery statement for the [2022/2023] financial year.

First Advantage is committed to ensuring that the people and communities that support our business are treated with dignity and respect. We do not tolerate the use of child labour, forced labour, or human trafficking in any form—including slave labour, prison labour, indentured servitude, or bonded labour—in our operations or supply chain.

Our commitment and approach are informed by leading international standards and frameworks developed by the United Nations (UN) and International Labour Organization. First Advantage is committed to respecting and supporting the UN Guiding Principles on Business and Human Rights, UN Universal Declaration of Human Rights, UN Global Compact, UN Sustainable Development Goals, Core Conventions of the ILO, and ILO Declaration on Fundamental Principles and Rights at Work.

Our Business

First Advantage is one of the largest workplace human resource screening providers in the world, First Advantage has offices in 25 locations across 17 countries worldwide and conducts over 55 million international background screens annually to 19 million applicants. It has more than 30,000 customers in over 200 countries.

First Advantage is a leading provider of employment background screening, identity, and verification solutions. The company delivers innovative services and insights that help customers manage risk and hire the best talent. Enabled by its proprietary technology, First Advantage helps companies protect their brands and provide safer environments for their customers and their most important resources: employees, contractors, contingent workers, tenants, and drivers.

To assist in the delivery of its services, First Advantage works with an extensive network of suppliers, subcontractors and agents.

Our supply chain includes:

• Promotional merchandise and marketing
• IT Hardware, Systems and Software
• Marketing
• Facilities Management & General Administration
• HR Services
• Consultancies
• Professional Services
• Insurance
• Travel & Entertainment
• Financial Services

Our policies and procedures

First Advantage takes a zero-tolerance approach to any form of modern slavery within its business operations and supply chain. In support of this statement, we take the following steps to identify and manage risks of modern slavery:

1. Policies and Procedures

First Advantage has in place a number of policies which are designed to identify, assess, raise awareness and manage the risks of modern slavery in our business activities. Our relevant policies include:

A. The First Advantage Global Code of Business Conduct and Ethics

First Advantage has in place a Global Code of Conduct and Ethics (“the Code”). The Code sets out principles that relate to legal and ethical standards of conduct. This includes policies relating to compliance, anti-corruption, non-discrimination, equal employment opportunities, equitable and fair treatment and safe, secure and healthy working conditions. The Code applies to all directors, officers and employees, of First Advantage (“Business Associates”).

The Code is published on our website and can be found at this link:

• First Advantage Global Code of Business Conduct and Ethics

B. The First Advantage Corporate Governance Guidelines

First Advantage has a set of Corporate Governance Guidelines (“the Guidelines”) that provide governance standards for the First Advantage Board of Directors. The Guidelines include a requirement that the Board of Directors comply at all times with and enforce the Code.

The Guidelines are published on our website and can be found at this link:

• First Advantage Corporate Governance Guidelines

C. The First Advantage Code of Business Conduct

First Advantage has a code of business conduct (“the Conduct Code”) that applies to all contractors and suppliers to First Advantage (“Suppliers”). The Conduct Code provides amongst other things that:

1. Suppliers shall not use any forced, bonded or indentured labour or involuntary prison labour;
2. employment must be voluntary, and employees shall be free to leave upon reasonable notice;
3. employees shall not be required to hand over government-issued identification, passports or work permits to Suppliers as a condition of employment unless required to do so by local law; and
4. Suppliers shall comply with the UK Modern Slavery Act of 2015 and/or the Australian Modern Slavery Act of 2018 to the extent applicable to their business.

The Conduct Code is published on our website and can be found at this link:

• First Advantage Code of Business Conduct

D. Whistleblowing and Grievance Policies

First Advantage operates a whistleblowing and ethics hotline and platform for individuals to raise concerns relating to their employment, suspected misconduct, breaches of the Code or the Conduct Code or any other human rights violations including modern slavery and human trafficking. All allegations received are taken seriously and investigated as appropriate. Individuals can opt to remain anonymous. Details of our whistleblowing and ethics hotline are on our website and can be found at this link:

• First Advantage whistleblowing and ethics hotline

First Advantage takes a timely and proportionate approach to implementing corrective or disciplinary actions and learnings which arise as a result of disclosures to the whistleblowing and ethics hotline.

2. Training and building awareness

In order to ensure understanding and compliance with the Code, all employees and where appropriate, current and new franchisees receive compliance training as part of the induction process, which is followed up by mandatory annual online training and consequently sign an acknowledgement that they have read and understood the Code.

We keep our whistleblowing and ethics hotline, platform and reporting procedures under regular review and strive for continuous improvement.

3. Managing our relationships with third parties

Engaging third parties is a necessary part of our business. However, we understand that any illegal acts they carry out while conducting business for us may impose risks on First Advantage. In order to mitigate this risk, we take the following steps when engaging third parties:

First Advantage standard contractual terms and conditions

Wherever possible, we seek to impose contractual terms on our suppliers requiring them to comply with our Conduct Code and/or any applicable laws which includes those relating to human rights and modern slavery. We continuously review and update our contractual terms to ensure they align with our internal policies and external laws and regulations.

Due diligence

Modern slavery can affect any industry and any country. To have the greatest impact on the lives of vulnerable workers, we are taking targeted action where the risks of exploitation are the most severe, salient and strategic – in line with the UN Guiding Principles on Business and Human Rights.

Our procurement and compliance teams review and approve all vendors as per our due diligence process, which can be divided into 3 main stages:

Our compliance team perform due diligence on our vendors based on our risk assessment for each vendor. Our due diligence includes denied party screening and enhanced due diligence.

(a) Know Your Supplier (KYS):

• All new suppliers and vendors are required to complete a compliance questionnaire (which is regularly reviewed) before we can open a new account.
• Our compliance questionnaire requires the collection of information about the supplier’s/ vendor’s ownership, the business and its reputation. Our vendor compliance questionnaire contains an acknowledgement of our Conduct Code;

(b) Third Party Risk Assessment:

We assess potential suppliers against the following risk factors:

• Country risk – for example, manufacturing in countries with poor records of human rights abuse.
• Industry type – we are alert when securing services from industry sectors with poor reputations for upholding worker’s rights and safeguarding their welfare.
• Nature of the workforce – for example, we recognise there is an elevated risk associated with businesses having a high dependency on low-skilled temporary work.
• Context of the supply chain – for example, taking into account the elevated risk when the supply is from countries with weak labour laws and high levels of poverty.

(c) Enhanced due Diligence:

We perform or request an enhanced due diligence process on third parties identified as” moderate-high” and “high” on the Third- Party Risk Assessment score. Depending on the outcome of the enhanced due diligence process we proceed with one of the following options:

1. we reject the third party and do not do business with them for a variety of reasons, including where the assessment demonstrates that the third party does not adhere to our supply chain standards;
2. we engage the third party but continue to monitor them with ongoing due diligence, as outlined above, to mitigate any risk.

Managing our relationships with third parties: Steps taken:

We keep our third-party relationships and our internal processes for managing third party relationships under continuous review, evaluating whether any areas can be updated and improved.

Performance monitoring

First Advantage reserves the right to monitor and audit its suppliers’ performance against key modern slavery-related benchmarks and policy requirements to evaluate compliance with appropriate standards for trafficking and slavery in supply chains.

4. Potential risks in our operations and supply chains

First Advantage’s suppliers come from all across the world. First Advantage recognises that this increases the risk that modern slavery practices could unknowingly become embedded in its supply chain.

To control and mitigate this risk, First Advantage is committed to engaging capable suppliers that, as a condition of their engagement, undertake to comply with strict standards, including a requirement that they:

• conduct their business lawfully, including by complying with all laws regarding slavery and human trafficking in the countries in which they do business;
• engage in practices that are not just commercially efficient, but which also see workers treated ethically and fairly;
• confirm that materials incorporated into supplied products comply with the laws regarding slavery and human trafficking of the country or countries in which the suppliers are doing business;
• do not make use of forced, prison or indentured labour;
• provide workers with a safe and healthy working environment;
• take responsibility for the ethical behaviours of their supply chains; and
• contractually confirm that they ensure that their workers are trained to recognise potential signs of forced labour and other modern slavery non-compliance and are made aware of how to report and investigate suspicions of improper conduct.

First Advantage’s accountability standards mean that where First Advantage’s assessment of its supplier practices reveals unacceptable performance against key benchmarks, First Advantage will, depending on the nature of the identified non-compliance, either engage with the relevant third-party supplier to ensure that it is urgently corrected or, if appropriate, otherwise terminate the third party supplier’s engagement.

5. Measuring Effectiveness, Continuous Improvement and next steps

First Advantage recognizes the need to build on its understanding, oversight and management of modern slavery risks in its operations and supply chains on an ongoing basis. Good progress has been made and we continue to take new steps to manage the risks of modern slavery and human trafficking taking place in our business and supply chains. With that in mind, we set out below our focus areas for the next 12 months:

• Keeping our grievance mechanisms for employees and third parties including supply chain workers under review and continuing to engage with suppliers to, where necessary, improve grievance and reporting processes within our supply chain;
• Continuing to review and, if necessary, updating our employment policies and procedures to maintain appropriate safeguards against modern slavery;
• Continuing to develop internal training and awareness on modern slavery and human rights.
• Continue to keep our contractual terms under review to ensure compliance with applicable modern slavery laws and a right to audit them where relevant and appropriate.