Management should establish a hiring process and program-related screening criteria for each job/role. In particular, management should ensure that personnel who have the authority to exercise a substantial amount of discretion are appropriately screened (this includes high-level personnel, those with supervisory roles, or non-management personnel who nevertheless have authority to bind the organization).

Management should conduct background checks for prior misconduct on employees with program responsibilities and/or substantial authority within the entity. Background checks are an essential part of the necessary due diligence to ensure that the entity does not employ personnel with substantial authority within the organization (i.e., those individuals with substantial supervisory authority or who may exercise substantial discretion in the performance of their jobs) with a history of engaging in violations of law or other conduct inconsistent with a high-performing program. It may also be appropriate to check the background of candidates for a job/role that involves sufficient program responsibilities. Backgrounds should be checked for previous internal (e.g., formal reprimands, claims, and complaints) and external (e.g., civil suits, criminal charges, or complaints) issues.

Hiring the right people can be one of the most effective techniques for realizing high performance. This includes preventing the acquisition of human capital with a history of non-compliance or unethical behavior, as well as preventing the acquisition of human capital who are not aligned with the entity's mission/vision/values. Misalignment can sometimes contribute to poor job performance and low levels of integrity.