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O4.2 SCREEN & SELECT OPERATIONAL PERSONNEL
Select operational personnel based on competence, behavioral traits and past conduct.


Background checks are an essential part of the necessary due diligence to ensure that the entity does not employ personnel in the program with a history of engaging in violations of law or other conduct inconsistent with an effective program. Although the scrutiny given to other operational personnel may not equal that given to high-level personnel, it is important that the program be staffed with competent personnel who do not have a record of ethical and legal compliance violations.

The background and references of all compliance and ethics personnel should be checked for previous internal (e.g., formal reprimands, claims, and complaints) and external (e.g., civil suits, criminal charges, or complaints) issues.
Standards & Guidance
    O4.2.S01
  • Perform due diligence to avoid putting anyone into a position of substantial authority whom the organization knew, or should have known through the exercise of due diligence, to have a history of engaging in violations of law or other conduct inconsistent with an effective program.
    O4.2.S02
  • Consider the relatedness of any individual's illegal activities and other misconduct to the responsibilities to which they may be assigned, as well as the recency of any such conduct.
Core Practices
    O4.2.101
  • Define a process to check the backgrounds of operational personnel including:
    > determinations of any history of violations of law;
    > how recently violations have occurred;
    > how any violations are related to the area of concern for the proposed position of authority;
    > any patterns of violations;
    > any conflicts of interest.
    O4.2.102
  • Obtain approval from legal counsel (employment) regarding the background check methodology.
    O4.2.103
  • For each candidate, document consent to background check.
    O4.2.104
  • For each candidate, document results of background check.
    O4.2.105
  • Select and assign party responsible for background checks.
    O4.2.106
  • Select and assign responsible party for background checks.
Additional Practices
    O4.2.201
  • Conduct background checks for individuals who are transferred into the program, taking into consideration the new job duties and responsibilities.
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