UK Modern Slavery Act Statement

INTRODUCTION

The UK Modern Slavery Act 2015 (“MSA”) requires large organizations doing business in the United Kingdom (“UK”) to publish a disclosure statement detailing the steps being taken to monitor and address the risks of “slavery and human trafficking” in its business and supply chains. In this statement, we use the term “modern slavery,” which includes slavery, servitude and forced or compulsory labour and human trafficking, all of which are abuses of a person’s freedoms and rights.

STRUCTURE AND BUSINESS

Accurate Background is a global service company that provides background screening services to organizations across the globe.

This statement is made on behalf of the Accurate Background entities operating in the UK, but all of Accurate Background is committed to ensuring that to the best of our ability and within our control, modern slavery does not take place in any part of our business or our supply chains.

We believe that the risk of modern slavery in our workforce is virtually non-existent.  Our workforce consists of almost entirely skilled professional employees.  We maintain rigorous hiring practices and we have full transparency with respect to employment practices.

As discussed further below, we also believe that the risk of modern slavery at our vendors is virtually non-existent.

OUR POLICIES

We have general policies that provide for fair treatment of workers, ethical business practices and compliance with law and set forth the business standards by which all Accurate Background UK personnel are expected to conduct business. We have mechanisms, including a hotline, for personnel to report violations of law or our policies. Third parties may also contact us. It is important that individuals working for us and our suppliers feel comfortable and supported when reporting suspected legal violations or breaches of our policies.

OUR RISK ASSESSMENT AND RISK MITIGATION PROCESSES

To assess the risk of modern slavery in our business and supply chains, we have considered the type of business we undertake and our supply chains, including our employment practices and our procedures for the selection and approval of third-party vendors. Our key vendors include professional services firms, such as legal, data suppliers, and other service providers. Given the nature of the services provided, we believe that the risk of modern slavery at these vendors is virtually non-existent with respect to the services that they provide to us.

We also purchase off-the-shelf goods such as technology equipment and office supplies and furniture and we believe the risk of modern slavery at these vendors is virtually non-existent in part due to the geographic location of performance.  Given the limited nature of our business relationships with these vendors, we do not have the practical ability to assess each of their employment practices or supply chains.

We are not aware of any incidents of modern slavery in our supply chains to date. If cases of non­compliance are uncovered, Accurate Background will determine the appropriate course of action on a case­ by-case basis. In cases where non-compliance cannot be resolved to Accurate Background’s satisfaction, it may terminate the arrangement with the vendor.

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