Engagement Types
There are certain engagement types which modify the vetting checks required:
1. New UBS engagement.
All checks applicable to the staff category .
2. Vetting requirements for external staff being re-engaged/returning on assignment to UBS
- ID, Right to Work, Rehire and Global Background Checks, Relatives and Relationships Check (self-declaration), External Directorship Checks (self-declaration) and Fingerprinting (US) need to be re-performed in any case before a member of staff is re-hired/re-engaged.
- If an external staff is re-engaged within 6 months (Americas: 3 months) after last engagement ended, Credit, Criminal and Registered Status checks do not have to be re-performed in case documents are not older than 12 months at the time of re-engagement.
- Contract extensions or renewals of engagement do not imply re-performance of checks as long as they have been completed and documented at the time of engagement, the engagement has not been discontinued and the UBS assessment of sensitivity of the role for vetting purposes is unchanged.
- In the event that by the time of re-engagement the vetting requirements have changed then any additional requirements need to be complied with (as permitted by law).
3. Vetting requirements for external staff transferring between countries
External staff transferring between countries – while on UBS engagement - will be subject to locally specific checks required by applicable law
ID, Right to Work and if applicable the check of the Regulatory Status are minimum requirements. In the US additional US Fingerprinting is required.
The required checks have to be successfully completed before starting in the new location.
Checks for staff transferring between countries also apply to staff returning to their home country to work on an engagement with UBS.
4. Change in Staff Category
Change of staff category from Category I to II/III (given there is no break in service) there is no requirement for vetting.
Change from Category III to Category I all vetting checks for Category I have to be conducted.
Change from Category II to either Category I or III all vetting checks required for the respective new external staff category have to be conducted (factually this is treated like a regular onboarding of a new external staff).
5. Change from internal to external staff (e.g. divestitures)
In case of internal staff transitioning to a new company with no break in service, and continuing to have access to UBS systems and/or premises in any non-registered role, there is no UBS vetting requirement. However, contractual agreements must be in place between UBS and the new company inclusive of vetting requirements for both onboarding and periodic vetting.
6. Vendor-to-Vendor change
If an external staff member moves to another supplier (regardless the new/previous levels) without break in service, vetting would not be required. However, UBS would expect that the basic checks (right to work and ID checks) still must be performed to ensure we do not engage undocumented workers.