First Advantage Corporate Responsibility & Sustainability Policy 

First Advantage Corporation (“First Advantage” or “Company”) believes its commitment to the principles of Corporate Responsibility & Sustainability (CRS) should be powered by our deep understanding and appreciation of our global workforce, align with our corporate mission and values, and also make good business sense. People are at the heart of everything we do at First Advantage. We believe our expertise in human capital drives our growth and is essential to our ongoing success. 

At First Advantage, we strive to deliver a superior customer experience while leveraging leading technology, automation, analytics, and our extensive global capabilities, all supported by our vast employee base. We are committed to continuing to be recognized as an outstanding employer that sustainably fosters and celebrates talent while we act deliberately and mindfully to support our customers in their workforce growth. We believe in the fair treatment of everyone and are steadfast in our commitment to equal employment opportunity. At First Advantage and throughout our supply chain, we prohibit harassment, discrimination, violence, and retaliation of any kind. 

This CRS policy is intended to guide employee behavior by articulating our Company values, commitments, initiatives, and goals relating to the CRS topics discussed herein. This policy sets standards that go beyond mere compliance with the law. Employees should apply this policy in conjunction with our other policies and procedures, some of which set more detailed restrictions and requirements relating to the topics addressed in this policy.

In developing our strategy and setting out our policy, we aim to deliver gradual but continuous improvements in our sustainability performance year over year. As a result, our approach will continue to evolve. The following principles will guide our responsibility and sustainability efforts: 

• As a Company with a distributed workforce model, our goal is to minimize the impact and maximize the benefits that our work has on the environment and people around us and to embed these values into our corporate culture, strategy, and objectives. 
• To integrate responsibility and sustainability into our business decisions as a leading provider of employment background screening and verification solutions and to encourage our business partners to do the same. 
• To comply with and exceed, where practicable, all applicable legislation, regulations, and codes of practice, especially in the areas of human rights and data security. 
• To review, regularly report, and continually strive to improve our CRS performance. 

The development and implementation of this policy is the responsibility of the Corporate Responsibility and Sustainability Board Committee. 

EMPLOYEES 

Benefits and Workplace Wellness 

As a leading provider of employment background screening and verification solutions, First Advantage understands that its employees are the heart of the Company. As a company with a distributed workforce model, First Advantage prioritizes that its employees enjoy their work and have opportunities to be in their best health. First Advantage provides corporate wellness initiatives and supports employees by offering flexible schedules and programs focused on mindfulness and well-being. We champion our employee’s journey to mental and physical health and wellness by: 

• Benefits:
  
  • Comprehensive healthcare for associates, their spouses/domestic partners, and families 
  • Collaborating with local partners across the globe to deliver offerings such as Employee Assistance Programs, telemedicine, sponsored vaccinations, and support for work-life services; 
  • Continually working with healthcare experts to evaluate our Health & Wellness global benefit options; and 
  • Offering employee-driven benefits, including virtual workout events and a free virtual library of meditation, breathwork, and workout classes through the Health Matters program. 
• Compensation:
  
  • Retirement contributions, including 401(k) employer contribution in the U.S. 
  • Employee Stock Purchase Plan in U.S., U.K., & India 
  • Transit Reimbursement Program 
  • Shopping Discount Program 

• Education:
  
  • Tuition reimbursement 
  • Broad range of learning and development resources 
• Time Off:
  
  • Flexible Time Off for salaried U.S. employees 
  • Paid Time Off for hourly U.S. employees 
  • Volunteer Time Off

Occupational Health & Safety 

First Advantage is committed to providing a safe and healthy working environment. In furtherance of this commitment, we have implemented policies, procedures, and employee awareness training to prevent workplace accidents and incidents in accordance with industry standards and local laws. 

Diversity, Equity & Inclusion (DE&I) 

With a large global footprint, the First Advantage team is inherently diverse. Our goal is to maintain an active, dynamic DE&I program that continues to promote an environment that celebrates each individual and provides equality of opportunity. Although the DE&I program initiatives are administered by the DE&I Committee, which is comprised of a taskforce of diverse staff members, every employee is empowered to implement change and ensure that everyone feels included. 

First Advantage champions a people-based approach to DE&I, seeking to ensure a welcoming and inclusive workplace. We believe that promoting diversity plays an important role in attracting and retaining the most expansive pool of qualified applicants, fostering greater innovation and creativity, and enhancing our communication and relationships with customers and the community. By planning and executing prioritized strategies with our employees and customers, we will make self-sustaining changes and have a lasting impact on our business culture. We seek to create an environment where people can be their authentic selves in alignment with our company values. 

DE&I Mission Statement 

Operating with empathy and compassion, First Advantage fosters a global inclusive workforce devoted to the diverse voices that make up our talent and products. Our team members empower each other to be authentic and treat everyone with respect, integrity, and fairness.

Our 4-Part Approach to DE&I 

Through multiple focus groups and with the ongoing support of third-party consultation, we are executing a plan to meaningfully advance DE&I through a focus on: Education, Culture, Geographic Expansion, and People, Processes, and Systems. 

1. Education: We recognize that education is crucial for creating awareness and promoting understanding of DE&I issues. We invest in ongoing education and training programs to ensure that all employees have a deep understanding of the importance of diversity, equity, and inclusion. We provide resources, workshops, and seminars that address unconscious bias, cultural competence, and inclusive leadership to empower our workforce with the knowledge and skills necessary for fostering an inclusive environment. 

2. Culture: Creating an inclusive culture is at the heart of our DE&I efforts. We strive to cultivate a workplace where everyone feels valued, respected, and included. We encourage open dialogue, active listening, and feedback to ensure that all voices are heard and respected. Our policies and practices promote equal opportunities for growth and advancement, and we actively celebrate and recognize the diverse backgrounds, experiences, and perspectives of our employees. 

3. Geographic Expansion: We understand that diversity extends beyond individual identities and encompasses different regions, markets, and communities. As we expand our operations geographically, we embrace the opportunity to engage with diverse talent pools, customers, and stakeholders. We adapt our DE&I strategies to specific local contexts, ensuring that our practices are relevant and inclusive in every region where we operate. By embracing diversity across various geographic locations, we enrich our company’s perspectives, ideas, and creativity. 

4. People, Processes, and Systems: To drive meaningful change, we integrate DE&I into our people, processes, and systems. We prioritize diversity in our recruitment and talent acquisition strategies, actively seeking out candidates from underrepresented groups. We regularly review our HR policies and practices to identify and eliminate biases and ensure fairness and inclusivity at all stages of the employee lifecycle. We establish diverse and inclusive teams, foster mentorship programs, and provide equitable opportunities for professional growth and development. Our systems and technologies are designed to support and track our DE&I initiatives, allowing us to measure progress, identify areas for improvement, and hold ourselves accountable. 

Employee Resource Groups (ERGs) 

First Advantage recognizes and values the diverse backgrounds, perspectives, and experiences of our employees. We encourage the formation and active participation of Employee Resource Groups (ERGs) to foster an inclusive and supportive workplace environment. Employees are encouraged to form ERGs based on shared characteristics such as gender, race, ethnicity, religion, age, sexual orientation, disability, veteran status, or any other characteristic protected by applicable laws. 

Freedom of Association 

The Company’s stance on Freedom of Association can be viewed here. 

All employees are informed of their rights in the Global Code of Conduct, which is signed by each employee, including management and executive leadership, upon hire and on an annual basis. 

CYBERSECURITY 

Data privacy and security is one of the highest priorities for First Advantage. We believe in utilizing the leading standards of data protection as a processor of information, despite not being a storage center for data. We are proud of our cybersecurity approach and have built out our program on a risk-likelihood basis informed by the NIST Cybersecurity framework. 

We have robust systems in place to mitigate data breaches to protect our customers. First Advantage has an established an Information Security Risk Program that includes components such as risk assessments, vulnerability threat identification and assessment (process-based and technical testing), an information security management framework, and a risk management lifecycle that defines threat and risk criteria used to prioritize the implementation of controls and remediation. Risk monitoring is ongoing, and the Information Security Risk Program is reviewed annually, or when there are significant changes to the business process. 

The Audit Committee assists our Board of Directors in overseeing our technology security and data privacy programs. 

COMMUNITY 

First Advantage recognizes that people who live their purpose at work are more productive than people who do not. They are also healthier, more resilient, and more likely to stay at the company. Moreover, when employees feel that their purpose is aligned with the organization’s goals, the benefits expand to include stronger employee engagement, heightened loyalty, and a greater willingness to recommend the company to others. To foster this at First Advantage, we have developed a program called FA Cares.

Corporate Volunteerism 

First Advantage encourages its employees to participate in corporate volunteering measures to support the communities we operate in through its FA Cares program. At First Advantage, corporate volunteering is the combination of activities promoted and supported by First Advantage to get employees involved and participating by using their skills and talent to help causes, projects, and not-for-profit organizations to benefit society. 

FA Cares Mission Statement 

The FA Cares global mission is to strengthen the communities we live and work in through volunteerism and philanthropy. Our program serves as a catalyst for our employees to engage meaningfully with the world around them. We strive to foster a culture of compassion, collaboration, and commitment to social responsibility. Through our FA Cares Program, we aim to inspire and mobilize our employees to actively contribute their time, skills, and resources to address the critical needs of our communities. 

We recognize the value of volunteering and its positive impact on society. Therefore, we offer our employees the opportunity to contribute their time and skills to 501(c)(3) charities through our Volunteer Time Off (VTO) program. The VTO program grants time off to U.S. employees (10 hours paid time off to each full-time employee or 6 hours to part-time employees) to participate in a charity event or cause during work hours. VTO allows employees to volunteer around a schedule that works well for them while supporting an event on behalf of First Advantage through their local organization or events hosted by FA Cares or any of the First Advantage ERG groups. 

ETHICS AND HUMAN RIGHTS 

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. We each have an obligation to do what’s right, and that requires compliance with more than laws and regulations. This commitment to ethical behavior encompasses everything from ensuring the dignified treatment of employees without discrimination to establishing solid corporate governance. These principles are memorialized in a variety of policies, some of which are described below. A violation of any of these policies and procedures is considered misconduct and appropriate disciplinary procedures, up to and including termination will be initiated. 

Anti-Slavery Transparency Statement 

As one of the largest workplace human resource screening providers in the world, First Advantage has a presence in 18 countries worldwide supported by 26 offices and, in 2022, performed over 100 million screens on behalf of approximately 33,000 customers spanning the globe and all major industry

verticals. Our solutions cater to organizations of all sizes and locations, providing a true global reach with local insight. 

First Advantage is opposed to all forms of human trafficking, slavery, servitude, forced or compulsory labor, and all other trafficking-related activities. We are committed to fully complying with all applicable international human rights standards, labor and employment laws, rules, and regulations, and to working to mitigate the risks of modern slavery and human trafficking in our business operations and supply chains. Our current Anti-Slavery Transparency Statement can be viewed here. 

First Advantage has also established a Supplier Code of Business Conduct (discussed in greater detail below) by which we require our vendors to maintain a workplace that is free from forced, bonded, indentured or involuntary labor. In addition, every new vendor is vetted through our Supplier Relationship Management Program process, which requires all prospective suppliers/vendors to agree to the prohibitions against using forced labor. 

Global Code of Conduct and Ethics 

The quality of First Advantage’s services and operations affects our reputation, productivity, profitability, and market position. Our objective is to create a work environment that allows and encourages all directors, officers, and employees to perform their duties in an efficient, ethical, and effective manner. Compliance with Global Code of Conduct and Ethics provisions is an essential condition of directorship or employment at First Advantage. In the case of the Company’s non-employee directors, compliance with the Global Code of Conduct and Ethics is subject to the provisions of the Company’s amended and restated certificate of incorporation, amended and restated bylaws, and any stockholders’ agreement with the Company. Our current Global Code of Conduct of Ethics can be viewed here. 

Anti-Bribery and Anti-Corruption 

Our global strength is the foundation for a corporate culture of professional integrity and respect. We are committed to engaging in professional responsibility for our employees, customers, and investors through our mission statement, codes of ethics, and policies. 

Fraud prevention and control is the responsibility of all employees, vendors and contractors, not just a few individuals or departments within First Advantage. Each member of the management team is familiar with the relevant types of improprieties that might occur within his, or her or their area of responsibility and is alert for any indication of irregularity. First Advantage maintains strict policies on security access and privacy guidelines.

First Advantage has also established a whistleblower mechanism for confidential and anonymous submission of concerns through an independent third party. There are several channels through which all employees, directors, officers, and vendors may report their concerns. 

ENVIRONMENTAL 

As a global company, we are keenly aware of the impact that corporate operations can have on the surrounding environment. Our distributed workforce model minimizes our facilities footprint, while optimizing our global reach, and we are systematically seeking ways to manage, reduce, and positively influence our environmental impact. Using a sustainable mindset, we are using a resource management tool to determine our global resource footprint and identify any significant environmental impacts resulting from our operations. We do not have a vehicle fleet or significant direct fuel consumption, which also mitigates our impact on the environment. 

RESPONSIBLE TRADING 

Supplier Code of Business Conduct 

First Advantage is committed to maintaining the highest standards among our suppliers. In furtherance of this commitment, we subject all new suppliers to a comprehensive screening process prior to onboarding. First Advantage requires all its suppliers to comply with First Advantage’s Code of Business Conduct, which addresses ethical employment practices. These ethical practices include, but are not limited to: anti-slavery transparency, human rights, health and safety, and the protection of the environment. 

Supplier Diversity 

First Advantage is committed to Supplier Diversity and strives to purchase products and services from Diverse Suppliers where practical. A Diverse Supplier is a supplier that is 51% owned, operated, and controlled by a person or persons who are part of commonly recognized categories (i.e., minority-owned business, disabled-owned business, veteran-owned business). 

The Diverse Supplier program is designed to create opportunities for Diverse Suppliers of goods and services to compete for business in various areas of First Advantage’s business. Using Diverse Suppliers has been shown to create community goodwill and can become a source of competitive advantage if implemented and managed correctly. First Advantage strives to include Diverse Suppliers in RFx events (i.e., RFI, RFP, RFQ) where practical. First Advantage leverages a third-party platform to track and report on Diverse Supplier spend, as well as to help identify new diverse suppliers. 

Supplier Health & Safety

First Advantage also compels its vendors to minimize work-related injury and illness and provide a safe, healthy, and hygienic work environment for its employees. First Advantage’s vendors must establish procedures and systems to manage, track, and report occupational injury and illness. 

Supplier Environmental Impact 

As outlined in our Code of Business Conduct, First Advantage expects that its Suppliers be committed to reducing the environmental impact of their operations. First Advantage Suppliers must also 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.