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VPP Background Check Policy

Verizon Wireless requires that all VPP Members utilizing B360 POS (Point of Sale) must have a completed background check per the requirements below. Once the background check is completed, a copy must be sent to Rick Stapp at rjstapp@conectus.com.

1. For each of the employees that Program Member wishes to assign to perform services for Verizon, Program Member shall certify to Verizon that it has conducted (or caused to be conducted) a background check as described herein (collectively referred to as “background checking”). For purposes of this Section, “employee” shall include Program Member’s employees and any of Program Member’s contract personnel; and “assign” shall include such employee(s) that (i) manage the Program Member’s Verizon account(s), and/or (ii) is provided access to Verizon systems on behalf of the Program Member unless otherwise agreed to by Verizon.

1.1. Where permitted by law, the criminal history check shall consist of a Federal and state check for felony and misdemeanor criminal convictions (or the equivalent thereof under relevant law) in all locations where the assigned employee has resided, has been employed, or has attended school in the immediately preceding seven (7) years, and a check of U.S. Government Specially Designated National (OFAC) and export denial lists. This criminal history check shall include, to the extent available and permitted by law, a check for outstanding warrants and a check for pending felony charges in all such locations. Statewide county searches shall be performed in all states where such search mechanism is available without requiring specialized data (such as fingerprints or DNA), and the National Criminal File database shall also be searched.

1.2. The name to which the employee’s Social Security Number is attributed shall be verified.

1.3. The employee’s citizenship, most recent country of permanent residence, and legal right to work in the jurisdiction in which the employee will be performing services for Verizon shall be verified.

1.4. The employee's driving record (also known as a motor vehicle report [MVR] or driver's license check).

2. For any period of time encompassed in the foregoing background check requirement when the employee was resident outside of the United States, such background checking shall be conducted by a reputable investigative agency that conducts background checking in the relevant country(ies) for transnational technology firms comparable to Verizon, utilizing database checking, field checking and interviews as needed. The criminal convictions check shall include the equivalent, under relevant non-US law, of those convictions described in Section 1.1.

3. Program Member shall comply with all applicable laws in conducting the background check including but not limited to securing from each employee who provides Services to Verizon such employee’s written consent to perform the background checking and to disclose the results thereof to Verizon upon Verizon’s request. Without limitation of the foregoing, Program Member will make all written disclosures to and obtain written consent from each employee to obtain consumer reports as defined in and required by the Fair Credit Reporting Act. Program Member shall provide such results and written consent to Verizon upon request from Verizon. Program Member shall indemnify and hold Verizon harmless from any loss or damage arising from Program Member’s violation of this Section.

4. Without prior review with and consent of Verizon, Program Member shall not assign any employee to provide services to Verizon if such employee:

4.1. has been convicted of a felony or misdemeanor (or the equivalent thereof under relevant law) within the last seven (7) years which, following a review under applicable law and applying the guidelines set forth in Appendix 1, Program Member concludes the circumstances of which are directly job-related to the assignment at Verizon and therefore makes the employee unsuitable for that assignment at Verizon, or for whom a warrant is outstanding, or for whom a felony or misdemeanor charge is currently pending, or is on a U.S. Government Specially Designated National or export denial list. The foregoing shall not apply to a minor traffic violation (a moving traffic violation other than reckless driving, hit and run, driving to endanger, vehicular homicide, driving while intoxicated or other criminal offense involving gross negligence, recklessness, intentional or willful misconduct while operating a motor vehicle), to a conviction that has been legally expunged, or to a conviction for a misdemeanor that occurred while the employee was under the age of twenty-one (21) years; or

4.2. Does not have the legal right to work in the jurisdiction in which the employee will be performing services for Verizon.

5. Program Member shall certify to Verizon that Program Member has caused the foregoing background checking to be performed for each employee assigned to provide service for Verizon within thirty (30) days of the Effective Date of the Agreement between Program Member and Verizon; further, Program Member shall annually certify no later than the anniversary of the Effective Date that it has met the foregoing background checking requirements for all employees then assigned to provide Service for Verizon. Such certifications shall be sent via electronic mail to: Verizon Enterprise Solutions, One Verizon Way, Basking Ridge, New Jersey 07920, Attn: VPP Compliance Office.

6. Without prior review and consent of Verizon, if an employee has been previously assigned to provide Services for Verizon and ceases to provide such Services for more than forty-five (45) days the felony and misdemeanor conviction check, database checks, and right-to-work check specified in Subsection 1 shall be repeated for said employee prior to the resumption of providing Service for Verizon.

7. Program Member shall, in its contracts with all permitted subcontractors and agents in the provision of services to Verizon, flow down the foregoing requirements. Such flow down shall include the requirement that such subcontractors and agents secure consent, from each employee providing services to Verizon and, to perform the background checking. Further, Verizon shall be permitted to audit any subcontractor or agent to verify compliance with the foregoing contractual requirements and to disclose the results thereof to Verizon at Verizon’s request.

VPP Background Check Policy

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