FIRST ADVANTAGE CODE OF BUSINESS CONDUCT

The Contractor (herein the “Supplier”) agrees to comply with First Advantage’s Code of Business Conduct which requires as follows:


EMPLOYMENT PRACTICES AND HUMAN RIGHTS

NON DISCRIMINATION

Supplier will not discriminate in its hiring and employment practices such as promotions, rewards, and access to training on grounds of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation, or disability.

TREATMENT WITH DIGNITY

Supplier will prohibit any harsh treatment including physical abuse and mental harassment of employees, and shall treat each employee with dignity.

FREE EMPLOYMENT

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

AVOIDANCE OF CHILD LABOUR

Supplier shall ensure that its hiring practices conform to minimum age requirements laid down by any applicable law. Supplier may operate an apprenticeship program that complies with all applicable legal requirements.

WORKING HOURS

Supplier will not exceed prevailing work hours as per applicable law and will appropriately compensate employees for any overtime worked. Employees should be allowed at least one day off per seven-day week. Work weeks must not exceed the maximum days set by local laws.

WAGES AND BENEFITS

While determining compensation Supplier must comply with all applicable wages laws including without limitation laws related to minimum wages, overtime, bonus, and other benefits. Supplier will not permit deduction in wages as a disciplinary measure. Wages must be paid on regular intervals as per pre-determined pay periods. For each pay period, the Supplier will provide workers with an understandable wage statement that includes sufficient information to verify accurate compensation for work performed.


HEALTH AND SAFETY

Supplier shall strive to minimize the incidence of work-related injury and illness and provide a safe, healthy and hygienic work environment to its employees. Supplier shall establish procedures and systems to manage, track, and report occupational injury and illness.

WORKPLACE VIOLENCE

Employees should have a safe workplace. Supplier shall have policies in place which prohibit workplace violence, including threats, threatening behavior, harassment, intimidation, assaults and similar conduct, and Supplier shall not tolerate or permit such behavior. Any threats or concerns about an employee’s safety or the safety of others should be immediately reported to a manager or the Human Resources department as required by Supplier’s policy.


PROTECTION OF ENVIRONMENT

Supplier shall be committed to reduce the environmental impact of their operations. Supplier must strictly comply with all applicable environmental laws, regulations and standards, such as requirements regarding chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits and environmental reporting. Supplier must obtain, maintain, and keep current all required environmental permits (e.g. discharge monitoring) and registrations and follow the operational and reporting requirements of such permits.


ETHICS

ANTI-CORRUPTION

Supplier shall not offer or accept bribes or other means of obtaining undue or improper advantage. First Advantage expects its suppliers to conduct their business in accordance with the highest ethical standards. Supplier must strictly comply with all laws and regulations on bribery, corruption and prohibited business practices, including but not limited to the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. Supplier will conduct its businesses without engaging in corrupt practices, including public or private bribery, facilitation payments, or kickbacks. Suppliers will maintain integrity, transparency and accuracy in corporate record keeping.

COMPLIANCE

Supplier shall comply with all applicable laws and regulations in all locations where it conducts business.

NO UNFAIR BUSINESS PRACTICES

Supplier will act with integrity while handling of competitive data, proprietary information and other intellectual property, and comply with legal requirements regarding fair competition, antitrust, and accurate and truthful marketing.

FAIR DEALING

Supplier shall deal fairly and in good faith with First Advantage’s customers, suppliers, business partners and competitors. No Supplier shall take unfair advantage of anyone through manipulation, abuse of privileged or confidential information, misrepresentation, fraudulent behavior or any other unethical business practice. It is sound business practice for the Supplier to obtain information about markets in which the Supplier does business, including information about First Advantage competitors, their products and services. However, Supplier may accept competitive information only when there is a reasonable belief that both the receipt and use of the information is lawful. Supplier must never attempt to acquire a competitor’s trade secrets or other proprietary information through unlawful or unethical means.

APPROPRIATE USE OF INFORMATION

Supplier’s employees may use information obtained from First Advantage only for the purposes contractually agreed to. Personal information shall not be repurposed for any other use by the Supplier or its employees, such as to contact data subjects. Sending personal messages in any form, making personal calls, stalking or harassment of any nature will be subject to immediate termination of the contract and appropriate action including but not limited to filing a case with police authorities.

CONFIDENTIALITY

First Advantage regards confidential or proprietary information as an important asset, and prohibits the unauthorized use or disclosure of such information by Supplier, its employees, agents. Supplier shall maintain the confidentiality of business information entrusted to it by First Advantage, its business partners, suppliers, customers or other parties. Such information must not be disclosed to others, except when disclosure is authorized by First Advantage or legally mandated.

Confidential information includes all non-public information that might be of use to competitors or investors or harmful to First Advantage, or its customers, if disclosed.

PROTECTION AND USE OF COMPANY ASSETS

Supplier has a responsibility to protect First Advantage’s assets from loss, theft or misuse. First Advantage seeks to preserve, protect and responsibly use all of its assets to remain competitive and to serve the interest of its shareholders. This includes tangible as well as intangible assets such as trade secrets, business information and intellectual property. All First Advantage assets should be used only for legitimate business purposes.

RECORDS RETENTION

First Advantage has records retention and disposal procedures to ensure that First Advantage data are retained in accordance with First Advantage’s needs and in compliance with applicable legal and regulatory requirements. These records include paper and electronic copies of documents. Supplier is expected to know the specific requirements applicable to his or her area of responsibility. Subject to local requirements and laws, Supplier shall retain documents consistent with daily business needs.

The destruction, shredding, deleting or other alteration of documents or records in order to impede a governmental investigation, lawsuit, audit or examination can result in criminal liability.

USE OF INFORMATION TECHNOLOGY AND ELECTRONIC COMMUNICATION

If computer, network, internet access and data (the “Systems”) are provided to Supplier and other authorized users primarily for business use, use of these resources for purposes other than the execution of First Advantage business must be governed by good judgment and restraint. Users are responsible for the professional, ethical and lawful use of the Systems. First Advantage Systems may not be used to access, disseminate, or store destructive software code, sexually explicit content, slanderous or libelous content, threatening or harassing messages, chain letters, content that could be considered as hostile or in poor taste or any other unauthorized materials. Occasional, limited appropriate personal use of the Systems is permitted if such use does not (a) interfere with the user’s or any other employee’s job performance, (b) negatively affect the Systems’ performance or (c) violate any other policy of First Advantage.

PUBLIC  COMMUNICATIONS

First Advantage is committed, consistent with legal and regulatory requirements, to delivering accurate and reliable information to the media, financial analysts, investors, brokers, and other members of the public. All public disclosures, including forecasts, press releases, speeches and other communications, will be honest, accurate, timely and representative of the facts. When approached for information, Supplier must immediately notify First Advantage of such request and seek necessary approvals with respect to the contents for disclosure. Any presentation made by Supplier of First Advantage that contains First Advantage financial or proprietary information must be approved in advance by First Advantage management.

PRIVACY OF INFORMATION

First Advantage is committed to complying with the laws that govern the collection, use and management of personal information of current and former employees, directors, and suppliers. Laws in many countries govern how employees must handle personal and health related information. Supplier must collect, use, maintain, share and transfer personal information in compliance with applicable law. Personal information in electronic or paper form must be kept confidential and held securely and disclosed only to others who have a legitimate business reason to access the personal information. Transfers of personal information between countries must comply with applicable legal requirements.