PRE-EMPLOYMENT SCREENING POLICY – POLICY AND GUIDELINES

ENTERPRISE RENT-A-CAR UK LIMITED (the "Company" or "we")

1. Introduction

1.1 This policy sets out a summary of the Company's approach to pre-employment screening (PES) checks. The Company takes the safety and security of its staff and customers very seriously. The purpose of this policy is to reasonably protect the Company's staff and customers, both in relation to their confidential information and making sure that those taking up roles with the Company are suitable and fit persons to carry out the duties assigned to them.

1.2 Because of the nature of Company's business, and in particular the sensitivity of the information provided by customers to which staff necessarily have access in the course of their duties, there is a need for us to request this information at different disclosure levels as part of the recruitment process. The Company carries out background checks for all roles, on the basis that all roles will or may come into contact with military or other sensitive areas of work, confidential information and/or sensitive financial information relating to the business, customers and colleagues. For some roles, this will involve a mandatory higher level of disclosure and means that applicants will need to disclose even spent convictions – where this applies, we will confirm this in writing and will explain the reason for doing so.

2. Who do these checks apply to?

2.1 The Company will carry out PES checks for the following:

(a) staff, including employees, partners, workers, candidates, directors;
(b) interns and work experience placements;
(c) agency workers, temporary workers, consultants / contractors and subcontractors who have access to customer / Company systems and data;
(for the purposes of this policy, "staff").

2.2 Rehires: Employees who have previously worked for and left the Company will need to complete a full PES process prior to their re-hire start date.

3. PES checks

3.1 All offers of employment / engagement are made subject to satisfactory PES checks. The Company is entitled to take any refusal into account when making its final decision where relevant, particularly in relation to any criminal records disclosure checks.

3.2 If a candidate refuses to consent to the proposed PES checks, the Company will consider:

(a) whether the information sought and refused is relevant to the role in question;
(b) whether it needs the information in order to make a decision; and
(c) any reason for refusal given by the candidate.

3.3 Prior to carrying out any PES checks, the Company will:

(a) identify which PES checks apply to staff, including employees, partners, workers, successful applicants, candidates, interns and work experience placements, agency workers, consultants / contractors and directors (for the purposes of this policy, "staff"); and
(b) identify any specific or additional checks to be carried out for certain roles.

The table at the end of this document provides a guide (Appendix 1).

3.4 In preparing to carry out any PES check, the Company will:

(a) consider the role in question and identify the skills and experience needed; and
(b) consider:

(i) what information it needs in order to make a decision regarding the role;
(ii) whether it is entitled / permitted to ask for such information;
(iii) consider whether any mandatory checks are required (such as enhanced disclosure for certain roles);
(iv) if so, what checks it could / must undertake to obtain that information; and
(v) whether such checks are relevant to the role in question.

3.5 As part of the PES check procedure, the Company will:

(a) review original copies of any supporting documents provided by applicants, and make any necessary copies for their personnel files;
(b) once it has selected the final candidate, inform affected candidates that it intends to carry out a background checks relevant to the role, and explain what checks it intends to carry out and the reason(s) for doing so; and
(c) where relevant, seek candidates' consent for any checks it intends to carry out.

3.6 The Company will limit access to background check information to select staff and will check and maintain security of data collected as part of the recruitment process in accordance with its privacy and retention policies.

3.7 The Company has the right to request an up-to-date criminal record check at any point for serving staff members and to use the DBS update service.

4. PES checks – all new hires

4.1 The Company requires the below documentation and background checks for each new hire regardless of level or duration of contract. PES documents shall be kept in the employees HR file and retained for the duration of the HR file, subject to the Company's retention policy. These documents are also subject to internal and external audits.

The following PES checks are requested for all candidates. All offers of employment / engagement are made subject to satisfactory PES checks.

(a) Proof of Right to Work in UK (PORTW)
(b) Proof of Residence (POR) - current only*
(c) Proof of Activity (POA) - Must span at least 2 years from employee start date*
(d) Financial Sanctions Check (as per employment eligibility form)
(e) Financial Probity Check – Completed by 3rd party supplier
(f) Criminal Record Check – Completed by 3rd party supplier
(g) Individual’s Qualifications (if required for role)

The List of Acceptable Documentation is set out at Appendix 1 to this policy.

4.2 Criminal Record and Financial checks will be initiated no earlier than 30 days before start date. No historical checks can be used as a substitute.

4.3 All copies of such original documents must be certified as a true copy, signed and dated by the Company at the time the copy is taken, and must be clear and legible as per the verification of day 1 checks.

4.4 Disclosure will only be requested in the event of an offer of employment being made, although any potential applicants will be made aware of the need for disclosure early on in the process. Any information received or requested will be dealt with in a confidential manner, and only accessed by those people involved in the recruitment process.

4.5 Appropriate Company staff members are trained to verify identification of staff undergoing a criminal record disclosure.

5. Criminal record and financial checks

5.1 Having a criminal record or a CCJ, for example, will not necessarily bar you from working with the Company. This will depend on the nature of the position and the circumstances and background to the record or judgement in question.

5.2 The Company will consider the role in question and the nature of the offence or judgement. If the Company is prepared to consider the candidate, then the recruitment process should continue. If the Company is not prepared to consider the candidate, then the recruitment process will not continue and the candidate will be notified accordingly.

5.3 There are a number of offence categories that specifically exclude relevant ex-offenders from certain roles. A non-exhaustive list of excluded roles is set out in statute. It is an offence for anyone who is banned from working with certain groups or in certain roles to apply for such a role, and an offence for an employer to hire any such candidate in such role.

5.4 The Company selects candidates for interview based on their skills, qualifications, aptitude and experience. When an applicant makes us aware of a criminal record or financial judgment before interview, and their skills and experience make them eligible for interview, the employing manager will notify the HR Manager that this is the case.

5.5 Should the employing manager, and/or the HR Manager be unclear about whether to proceed, the following individuals should meet to consider the application (the PES Check Review Committee, or "PCRC"):

(a) employing manager;
(b) the HR manager; and
(c) the area manager.

5.6 The PCRC must consider the application, including the following:

(a) the role, and the duties and activities associated with the role;
(b) the nature, severity, timing and circumstances related to the offence; and
(c) the Company's duty to provide a safe environment for staff and other contacts, customers and for the individuals the Company supports.

5.7 The PCRC should consider these matters, and reach a decision. The PCRC should then agree how that decision should best be communicated. The decision should be treated sensitively. Both the HR manager and the employing manager must keep a record of the process, the discussion, the outcome and the feedback.

5.8 The Company reserves the right to request any further information that is relevant and necessary for us to make a decision regarding employment or engagement. The Company reserves the right to withdraw an offer of employment or engagement where applicant fails to reveal information that is directly relevant to the role and where relevant the Company will notify the candidate of the reason for withdrawing any offer of employment or engagement. Further, where the Company discovers that a candidate has either withheld information or provided incorrect information, whether deliberately or negligently, the Company reserves the right to take immediate disciplinary action up to and including summary dismissal.

6. Data Protection

6.1 The Company is committed to the fair treatment of its staff, potential staff or users of its services, regardless of race, gender, religion, sexual orientation, responsibilities for dependants, age, physical/mental disability or offending background. This policy should be read in conjunction with the Company's Equal Opportunities Policy.

6.2 Any information received or requested as part of the recruitment process will be dealt with in a confidential manner, and only by those people involved in the recruitment process. Such information will also be subject to the Company Data Protection and Privacy Policies. The Company may be obliged to disclosure of personal data in compliance with a legal obligation or requirement, or instruction for a court or other regulatory body. Please note that any such information may be transferred to overseas as set out in further detail in the Privacy policy. Where the disclosure or transfer is to a person resident outside the European Economic Area, the Company shall take reasonable steps to ensure that the individual's personal data is handled with appropriate care.

6.3 The Company may amend and/or modify this policy at any time at its discretion. You are responsible for complying with any such amended policy.

Last updated: 23.5.18

APPENDIX 1

Evidence List – Acceptable Documentation

PORTW (Proof of Right to Work)

Any document or combination of documents prescribed by guidance published by the Home Office relating to the Prevention Of Illegal Working.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/286642/summary-guidance.pdf

Please Note:

• Expired British or E.E.A Passports may be presented to prove legal right to work. All other passports and supporting visa documentation must be current.

Financial Sanctions Check

Perform a check in relation to the individual via the HM Treasury’s official website to ensure that the individual does not appear on the list of names on the HM Treasury’s Database of Financial Sanctions Targets.

https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets

Criminal Record Check

Criminal Record Checks are conducted by our PES Supplier in compliance with the DBS regime.

Please Note:

• The check result shall be dated no earlier than thirty (30) days prior to the proposed engagement date. i.e. it must be a recent, rather than a ‘historic’ check.

Individual's Qualifications (if required for role)

Where the individual is required to have specific academic, trade or professional qualifications to perform the role, the Supplier will obtain verification of these qualifications (for example certificates of qualifications) and where appropriate ensure that they are up to date and valid.

POR (Proof of Residence)

Individual to produce one of the following:

• A utility bill for a service where a credit search is conducted prior to service commencing, for example gas, land line telephone or internet access (must be less than three (3) months old, if used for current address); or
• A bank/building society/credit card statement (must be less than three (3) moths old if used for current address)
• A recent mortgage statement (must be less than three (3) months old, if used for current address)
• A council tax bill or payment book for the property at which the individual currently resides (must be less than twelve (12) months old, if used for current address)
• A current benefits book (if address is shown) or original notification letter from the Benefits Agency and/or Job Centre confirming rights to benefits
  HM Revenue & Customs documentation (must be less that twelve (12) months old, if used for current address)
• A Current UK Full Driver's Licence (not expired) - only good for current address
• Provisional Driving Licence where individual is aged 20 and below

For students, verification at their parent’s address (dated within the last three months for the current address or within the period of residence for previous addresses) is sufficient as any linked address will be shown. It is not necessary for the candidate to appear on the electoral roll if suitable documentation is provided.

If it is necessary to obtain verification for a student address the following are acceptable on the proviso that confirmation is provided that they attended the educational establishment given:

• School Letter on headed paper or with a school stamp
• University/College verification confirming its ownership of the property in question
• Introduction from a recognised UK University/College (as above). Must be addressed to the candidate or the Supplier. Must be on headed paper or carry an appropriate stamp. Must confirm the candidate’s name date of birth & course, be current or dated within the period of the previous address.
• University or Council/Education authority documentation referring to student account information (e.g. university budget account or tuition fees) is acceptable.
• NB: Term to term gaps can be ignored

Please Note:

• Common examples of unacceptable documentation are: Mobile telephone bills, Private (individual) tenancy agreements, P60’s, P45’s, TV licence, NHS cards, Pet Insurance (Essentially documents where a credit search will not have been carried out).
• Only proof of current address is required covering the last 6 months. If residence is less than 6 months old, then previous address history should also be obtained to complete 6 month period.
• Acceptable documents are bank statement or utility bill dated within the last 3 months.
• Utility bill is determined as Gas/Electric/Internet/Phone/Council Tax.

POA (Proof of Activity)

Individual to produce one of the following from the appropriate heading:

• Employment
  - Wages/pay slip
  - P60/P45
  - PAYE Coding Notice
  - Satisfactory Reference in writing/email from the employer
  - For self-employed individuals – HMRC communications e.g. tax returns; bank statements for sole trader status or accountants/solicitors letter confirming activity; audited accounts (i.e. signed/certified/dated by Accountant) that names individual as sole proprietor, partner in a partnership or Director in a Limited Company
  - For Pensioner - proof of receipt of pension payments

• Unemployment - claiming benefits - formal evidence from a government agency e.g.
  - Letter from Benefits Agency confirming payment of benefits to the individual or confirming non-employment status
  - Bank Statement evidencing receipt Jobseekers allowance

• Unemployment – not claiming benefits - evidence of job seeking e.g.
  - Correspondence from potential employers or employment agencies

• Full time Education (at least 20 hours per week) Graduates, University Leaver, Mature Students
  - University/College letter of acceptance. Must be on headed paper. Must be issued by a recognised UK University/College (i.e. Government LEA/SAAS funded) and not a language school (unless an international student). Must confirm acceptance of student onto course and address must match that on AFE (or dated in period of previous address)
  - Student Loan Company/LEA/SAAS Award letter. Must show loan taken up, not just offered.
  - Educational Certificates
  - Confirmation of withdrawal from University including relevant dates
  - Introduction from a recognised UK University/College (as above). Must be addressed to the individual or the Supplier. Must be on headed paper or carry an appropriate stamp. Must confirm the individuals name date of birth & course, be current or dated within the period of the previous address
  Gap Year Students
  - See the relevant section of the sub-category Travelling under No Economic Activity
  Distance Learning
  - Confirmation of enrolment to a course
  - Feedback in respect of modules studied

• No Economic Activity for more than 6 months

• Maternity Leave
  - Child’s birth certificate within the period, up to 16 years max
  - Notice of Award of child benefit payments during the period or formal confirmation of award of child tax credit in respect of the birth of the child
  - If not parent, a link to relationship must be established with documentary evidence

• Redundancy
  - P60/P45 or pay slip
  - Tax payments
  - Formal documentation relating to the terms of redundancy

• Travelling
  - Receipts - hotel, car hire & credit cards
  - Sole bank statement evidencing overseas transactions during the period
  - Inoculation record or Immigration stamp in passport for the period concerned
  - Formal documentation from a recognised travel company /airline for booking or travel during the period in question (included train, boat tickets or car hire)
  - Bank account statement showing transactions in relevant currency if combined with additional verification which supports

• Sabbaticals
  - Sponsored - Formal documentation from employer outlining terms
  - Non Sponsored - Treat as No Economic Activity - Lifestyle Project (below)
  - Evidence of allowances received
  - Power of attorney, doctors note/communication

• Lifestyle Projects
  Evidence of the project e.g.;
  - Planning Permission/Supplier invoices/Inspection cert
  - Inspection certificates/project receipts or evidence of equipment hired
  - Evidence in spouse’s name acceptable if link verified by marriage certificate

• Caring for others
  - Evidence of allowances received
  - Power of attorney, doctors note/communication

• Voluntary Work
  -Written evidence of voluntary work during the period on the headed paper of the institution concerned

• Illness (Including institutions/rehab etc)
  - Medical certificate covering the period
  - Documentation from a medical practitioner or establishment that verifies that the individual was undergoing treatment during the period

Please Note:

• For all periods of activity only one (1) document will be required as evidence.
• Current or last - this must include the three (3) month period immediately prior to their start date and be references from previous employment, and/or degree certificate.
• Must span at least 2 years from employee start date.
• There must be no gaps in references or documentation greater than 2 months.
• It candidate is without professional references please refer to the POA list below for acceptable documentation.
• Personal references are not sufficient evidence without additional documents from the POA list.

APPENDIX 2