PwC Screening Requirements

I. Enhanced Identity Verification

To protect PwC and our clients from potential identity misrepresentations, we have engaged a Supplier to enhance the identification verification process designed to confirm an individual's identity at time of screening, onboarding, and on assignment. Identification verification is required for all TPL with limited exceptions.

II. Approved Background Screening Requirements

PwC’s Safety and Security - Background Screening Policy requires all Suppliers to conduct background screening for any Supplier employee or contractor who: requires authorized badge access (unescorted) to PwC Premises or PwC Client premises; will have access to PwC networks or computing systems or PwC client networks or computing systems; may have access to non-public, confidential PwC data, PwC people data or PwC client data, including any support roles that may have access to modify PwC data or client data; or is subject to additional background screening requirements prescribed by a PwC client for an anticipated engagement (collectively, “Resources”). Supplier must complete the background screening prior to the Resource’s assignment to PwC or a PwC client.

All background screenings must be completed with satisfactory results prior to allowing Resources to start on a PwC engagement. All background screenings for Resources must be current within six (6) months of deployment to PwC or a PwC client. Updated background screenings may be required for assignment to particular engagements, even if last conducted within the prior six (6) months. Suppliers with Resources engaged in outsourced work or long-term projects must conduct an updated background screening at least every 5 years.

Upon receipt and review of the results of the background screening report, Supplier will determine, based on the report, the individual’s skill set, prior experience, references and other job-related factors, whether the individual is suitable for a particular engagement with PwC. The decision should be made consistent with applicable law, good judgment, and reasonable and sound business ethics. Should Supplier wish to place Resources with discrepant information (described below) on their background screening reports, they must escalate the matter to PwC's People Operations Team. Supplier is required to comply with the federal Fair Credit Reporting Act and all state and local laws governing background screenings. If Supplier is permitted to subcontract out any portion of its staffing services, Supplier understands and agrees that any Resources screened by a subcontractor are subject to the same requirements as set forth below.

Background Screening Requirements

The background screening must, at a minimum, consist of the following search criteria:

• Social Security Number Trace
• Criminal History Records - 10 years (or the maximum allowable time permitted by law, if less)
  • County Level
  • Federal Level
  • State Level
  • National Criminal Records Locator
• Department of Motor Vehicle Records
• Education Verification - highest degree, must include, at a minimum:
  • High School Degree, GED, or equivalent
• Employment Verification - 10 years
• Government Watch Lists, must include, at a minimum:
  • OFAC
  • FBI
  • OIG
  • GSA
  • Denied Persons List
• Professional License/Certification, if applicable to assignment or reported
• National Sex Offender Registry
• Resume Comparison, if applicable to assignment
• Politically Exposed Persons
• Sanctions & Litigation
  • SEC
  • NASD
  • CFTC
  • Department of Veterans Affairs
  • Department of Justice
  • FDIC
  • Former Federal Home Loan Bank Board
  • RTC
  • FINRA
  • Interpol
  • EAR

PwC clients’ background screening requirements can differ from PwC’s background screening requirements scope and may be predicated on industry regulatory requirements (i.e., FDIC, FINRA, SEC, etc.) imposed on the client. Supplier, at their own cost and expense, must conduct the most stringent background screening required for Resources assigned to PwC or PwC’s clients. If Supplier is unable to fulfill PwC or PwC client’s background screening requirements, they will need to escalate a request to PwC's Background Team at us_pwc_supplier_background_escalations@pwc.com.

PwC’s Approved Screening Vendors

Suppliers are required to use a PwC Approved Screening Vendor. To ensure compliance with PwC's screening standards and requirements, all suppliers, even those with existing private business accounts with a PwC approved screening vendor, must register through the instructions provided below to evaluate candidates for positions at PwC. Existing private business accounts cannot be used for these candidates, as they may not meet PwC's compliance standards. Furthermore, if a PwC client specifies a preferred screening provider, the supplier must register with the vendor chosen by the client.

Scope of Screening Criteria

The scope of background screenings conducted or procured by Supplier for Resources must, at a minimum be consistent with PwC’s Background Screening program requirements or as specified in the Supplier’s contractual agreement with PwC (if applicable).

Escalation Process for Discrepant Information

If Supplier identifies discrepant information on the background screening report for a Resource, Supplier is required to follow applicable law including, in the US, providing the candidate the opportunity to respond to the discrepant finding. The Supplier must complete and issue the “Pre-Adverse Action Notice” that clearly identifies each discrepant finding and affords the candidate a reasonable period to review and respond, in accordance with all applicable laws and regulations, including the Fair Credit Reporting Act. Once a response is received, Supplier must escalate the matter to PwC's People Operations Team. Supplier should provide sufficient information to understand the nature of the discrepant finding, any response from the candidate and an identification of the role for which the candidate is being considered. Supplier must also identify any missing or incomplete items. Supplier will be notified of PwC’s assessment of job-relatedness within 3-5 business days. PwC may request additional information if the information provided is insufficient. In such cases, Supplier will be advised and will need to determine its next steps. It is the Supplier’s responsibility to follow all applicable laws and regulations, including the Fair Credit Reporting Act, when determining a resource’s suitability for assignment with PwC and notifying the candidate of Supplier’s selection or non-selection decision. For a non-selection decision, the Supplier must complete and issue the “Post Adverse Action Notice.”

Pre-Adverse Action Notice

[Review and modify as necessary to apply with applicable law]

Hello,

You have previously completed a disclosure and an authorization for a background investigation related to your employment with or engagement by [SUPPLIER NAME], as part of the process of evaluating your application for assignment to provide services to PwC US Group LLP and/or its direct and indirect subsidiaries and affiliates (collectively, “PwC”).

A complete and satisfactory background investigation is required.

Attached below is a "Summary of Your Rights Under the Fair Credit Reporting Act." It is noted that this report contains discrepant information that may adversely affect your employment status with [SUPPLIER NAME] if left unresolved. It also may be necessary for you to provide additional information in order to complete your file. If you believe the information contained in the report is inaccurate, you may contact the consumer reporting agency which prepared the report for [SUPPLIER NAME].

To help complete your background investigation, please take the following actions:

1. Review and action the issue(s) marked as "Review" in the grid below.

DEADLINE: All information should be submitted by close of business on <5 business days from date of email>, if not sooner to avoid a delay in your start date with [SUPPLIER NAME].

Illinois - 7 business days

San Francisco, CA - 7 business days

Los Angeles, CA – 5 business days, but add 10 more business days if a written request is made by individual for additional time

Philadelphia, Pennsylvania - 10 business days

New Haven, CT - 10 business days

Montgomery County, MD - 10 business days

Prince George County, MD - 10 business days

It is imperative that responses are received by the deadline. If additional time is needed to respond, please advise of the date the response can be expected by. All responses and supporting documentation should be emailed to [insert contact at SUPPLIER NAME].

Post Adverse Action Notice

[Review and modify as necessary to apply with applicable law]

<Date>

<Name of Recipient>

<Address of Recipient>

Dear <Name>:

You have previously completed a disclosure and an authorization for a background investigation related to your employment with or engagement by [SUPPLIER NAME], as part of the process of evaluating your application for assignment to provide services to PwC US Group LLP and/or its direct and indirect subsidiaries and affiliates (collectively, “PwC”).

Based, at least in part, on information contained in a consumer report prepared by [Background Check Vendor], a copy of which was previously provided to you, [SUPPLIER NAME] will be <withdrawing our contingent offer of employment><terminating your employment><postponing your start date><suspending your employment at this time>.

As explained in the "Notice of Consumer Report and Investigative Consumer Report and Summary of Rights under the Fair Credit Reporting Act" that you previously received, you are entitled to obtain a free copy of your consumer report directly from [background check vendor], if requested within 60 days of receipt of this letter. You may contact [background check vendor] at:

[Name]

[Address]

[Telephone Number]

You may also dispute directly with [background check vendor] the accuracy or completeness of any information in the consumer report provided. [Background Check vendor], however, did not make the decision to take this adverse employment action and will be unable to provide the specific reason(s) why this action was taken.

We wish you the best of luck in your career endeavors.

New York City Fair Chance Act

For resources working in or residing in New York City the New York City Fair Chance Act must be followed. To follow the New York City Fair Chance Act all non-criminal matters will be reviewed and resolved first. Once the non-criminal matters have been resolved then the Supplier must send the below email to the resource. Only thereafter will criminally background checks be reviewed.

New York City Fair Chance Act Email

Email to be sent by Supplier once review of non-criminal portion of background check completed.

[DATE]

Dear [Name of Applicant],

We are writing to inform you that you have successfully completed nearly all steps in [Supplier’s] pre-employment screening process, including as part of the process of evaluating your application for assignment to provide services to PwC US Group LLP and/or its direct and indirect subsidiaries and affiliates. The final step is to review the results of the criminal background and driving record/abstract check that has been obtained pursuant to your prior authorization.

We will be in touch if we have any questions or further steps are required as part of this review process. Otherwise we will let you know once the criminal background and driving record/abstract check review is completed.

If you have any questions, please do not hesitate to contact me.

Sincerely,

[Supplier Contact Person]
[Supplier Phone Number and/or Email Address]

Certification of Background Screening

Upon completion of PwC’s review of an individual's background screening report and assessment of job-relatedness, Supplier must complete the “TPL Supplier Certification Letter” naming each Resource selected for assignment to PwC or a PwC client and upload it to the TPL system. For questions regarding this process, please contact a member of PwC's Background Team at us_pwc_supplier_background_escalations@pwc.com.

(To be placed on Supplier's letterhead)

[Name of Supplier] Certification of Background Screening and Verification

This letter will serve as certification to PwC that [Name of Supplier] ("Supplier") has conducted background screening on its personnel or subcontractor listed below who will: (1) require badge access to PwC site or a PwC client site; (2) have access to PwC networks or computing systems or PwC client networks or computing systems; (3) who will have access to PwC data, PwC people data or PwC client data; and/or (4) be subject to additional background screening requirements prescribed by a client for an anticipated engagement, in conformance with the areas of inquiry set forth in the Agreement dated [Date] between Supplier and PwC.

Background Screening

By signing below, Supplier certifies that:

• The results of the screening produced no discrepant information sufficient to disqualify the placement of such personnel with PwC and has been performed within six (6) months of deployment to PwC assignment or at such other time required by the applicable MSA or SoW.
• In conducting the screening, Supplier complied with the Fair Credit Reporting Act (if applicable) and all applicable state & local laws.
• The personnel listed below have complied with the employment eligibility verification requirements of the Immigration Reform and Control Act of 1986, including obtaining a fully completed I-9 form (if applicable). Supplier certifies that it is unaware of any facts leading it to believe that the personnel listed below are not authorized to work in the United States.
• Secondary documentation (e.g., diplomas, school transcripts, W2s, payroll stubs, tax transcripts, relieving letters, and/or offer/termination letters) has been used only as specified below.
  • For Verified Employment: Please select one of the following:
    ☐ Secondary documentation was not utilized.
    ☐ Secondary documentation was utilized to verify less than 50% of employment history.
    ☐ Secondary documentation was utilized to verify 50% or more of employment history and use of such information was approved by PwC’s People Operations team.
  • For Verified Education: Please select one of the following:
    ☐ Secondary documentation was not utilized.
    ☐ Secondary documentation was utilized and use of such documentation was approved by PwC’s People Operations team.

Supplier Representative Name: ___________________________

Supplier Signature: ___________________________ Date: ___________________________

Title: ___________________________

Tel #: ___________________________

Email Address: ___________________________

Supplier has determined, based on its review, that the above personnel are suitable for placement on assignment with PwC and/or its clients.

PwC reserves the right to update these terms from time to time.

Last updated March 2026