Appendix 4

Model Corporate Policy

Opportunity to Correct

If a criminal record report contains information that may result in the applicant not being
offered the position for which she has applied, the applicant will be notified and provided:

• Nature of the reported offense
• Date of offense
• Jurisdiction of offense

The applicant will be told that she has the opportunity to challenge any information that is incorrect and the number of days she has to do so.

The notification will be made by e-mail. If the applicant does not have an e-mail address, the notification will be made by the faster available method.

If the applicant indicates that a reported conviction is incorrect, the background checking company will be notified and asked to investigate.

Evidence of Rehabilitation

Applicants will also be given the opportunity to provide evidence that they have rehabilitated themselves and no longer pose an increased risk of harm, including:

• Stable family life
• Stable work history
• Character references
• Community service
• Parole or probation officer statements

If requested, an HR professional will speak to an individual who has information regarding anapplicant’s rehabilitation.

Timing

The applicant will be given at least seven days to provide the above information. The position for which the applicant has applied will not be filled until the applicant has submitted all the information he/she has and this information has been evaluated unless it is imperative that the position be filled sooner.

If the position is filled prior to receipt and evaluation of this information, and it is determined
that the applicant is qualified, he/she shall be notified that they will be offered the next position of this type that becomes open.

Decision

The final hiring decision will be made comparing an applicant with a criminal record to other candidates on all relevant bases, including:

• Education/Training
• Prior work experience/references
• Interview
• Prior conduct, including all material submitted by the applicant

We will choose the candidate that offers the greatest overall strength.

Decision Maker

An HR professional who believes that an applicant with a criminal record is the strongest
candidate for a position has the option of having their choice reviewed by the Vice President of Human Relations.

A decision not to hire an applicant because of his/her criminal record must be reviewed and
approved by the Vice President of Human Resources

Relevance Matrices

To ensure that only relevant criminal record information is considered, a relevance matrix will be created for each open position listing the specific convictions that are relevant for that position and the period of time during which it is relevant.

Background checking suppliers will be provided with the appropriate matrix and instructed to report only convictions that meet the matrix criteria.

Timing

Human resources professionals will be thoroughly trained in this policy, legal requirements,
and risk analysis.

Diversity

The company shall maintain an active diversity program, under the direction of a senior
executive. The diversity director’s reports will include an analysis of how the company’s
decisions regarding candidates with criminal records affected diversity.