Appendix 4

Model Corporate Policy

Sample 2

The following is further discussion of aspects of the above list of actions OUR Co. has taken, or commits to taking periodically as the need arises, as we build OUR Co.’s Second Chance Hiring program:

1. Create an Intentional Hiring Plan

Engage in meaningful conversations about Second Chance hiring at the executive level, and subsequently extending to a broad team of stakeholders from different parts of the organization, including recruiting, HR/employee relations, safety/security, risk/insurance, customer service, marketing, production, and legal. Recruiting and HR plays a crucial role in shaping the hiring process for Second Chance talent and in building a system for candidates to onboard effectively, while OUR Co.’s legal team will aid in facilitating compliance and minimizing risk.

To build the best possible program, it is important to outline the intentions, goals, and metrics that will be indicative of success or shortcomings necessitating course corrections. The following questions can be helpful in doing so:

• What do we hope to accomplish with our Second Chance Hiring program?
• How will this program impact and aid in our diversity, inclusion, and belonging efforts?
• What do we want the hiring process to look and feel like for a Second Chance candidate?
• How many roles are currently open or will open that can be filled by Second Chance talent?
• How should we measure success? For example, should we look at roles filled by Second Chance talent? Or should we look at diversity data overall?
• What does success look like after six months? What about in 12 months and beyond?

2. Connect With Local Partners to Find Top Fair Chance Talent

Engaging in Second Chance hiring is not only an opportunity to diversify OUR Co.’s workforce. It is also a chance to forge meaningful connections with job development experts in the community. Community-based organizations that focus on workforce development for reentry and Second Chance talent are likely right in our backyard. Partnering with local source partners can give OUR Co. strategic access to top talent with arrest and/or conviction records without having to do a manual search yourself.

3. Connect With Local Partners to Find Top Fair Chance Talent

Working to build a strong Second Chance talent pipeline is a crucial step in a successful
hiring process. Many Second Chance candidates who are qualified in terms of fundamental
job performance or readiness skills they possess may not have previous job experience in the specific role they are seeking to be considered for, or may have a lengthy employment gap during their period of incarceration. In a traditional recruiting model, these “assets” and/or “shortcomings” may render the Second Chance candidate invisible to recruiters or, if fortunate enough to be interviewed, may not receive fair consideration. Or, if they successfully navigate the recruiting and interview process and are hired, may not realize fair consideration during the onboarding and initial employment period.

It is therefore critical that OUR Co. adopt a skills-based assessment mindset as we move
through the recruiting, interviewing and onboarding phases of our Second Chance workforce development strategy. Rather than solely focusing on candidates’ academic degrees, certifications or past direct experience in the open position(s) to be filled, we must also focus on transferable skills and willingness to learn so as to place Second Chance talent on a level playing field with other candidates, especially when recent experience and data indicates that reliance on each set of selection criteria can lead to successful hires of highly productive workers.

4. Fairly Assess Charges

When OUR Co. conducts candidate background checks, we will utilize the services of a reputable third party screening service that gathers and reports data that can be properly confirmed, is relevant to the responsibilities and risks related to the position to be filled, and can advise OUR Co. on fair use of such data and effective compliance with statutory and regulatory standards such as the federal Fair Credit Reporting Act (FCRA).

When a candidate background check reveals a conviction record and/or charge that raises concerns due to relevancy as related to the responsibilities of the position to be filled, OUR Co. will implement an “individualized assessment” process to fairly evaluate the impact of the conviction record on the candidate’s qualifications for employment and their ability to effectively fulfill essential job requirements.

The federal Equal Employment Opportunity Commission (EEOC) has prescribed what is known as the nature/time/nature test to apply the individualized assessment test in order to better understand each candidate as an individual. The nature/time/nature test considers three categories of information:

• The nature of a person’s conviction history
• The length of time that has passed since the offense
• The nature of the job for which you’re hiring

If the results of the nature/time/nature test leaves us with continuing concerns of the candidate’s suitability for the position based on the conviction history, a fourth category of information will next be added to the nature/time/nature analysis: “evidence of mitigation” or “rehabilitation”. This refers to a list of positive steps or achievements the candidate may have participated in or completed since their criminal justice system involvement that demonstrates efforts and successes to move beyond the negative consequences of their past mistake(s).

Overall, these more nuanced practices will allow the opportunity to understand what is actually behind a candidate’s record and who he or she really is as an individual person. Most importantly, it will reveal important information that can support their candidacy and open up employment opportunities that would otherwise be missed. Better informed employment decisions will lead to a more productive workforce, successful company and expand economic opportunities for individuals, families and communities.

5. Vendors, Suppliers, Contractors

When feasible, OUR Co. shall strive to inform and educate vendors, suppliers and contractors with whom we conduct business about this Second Chance Hiring Policy, and give favorable consideration to those businesses that are open to implementing these principles as part of their recruiting and employment practices.