External Staff Vetting – Level 1 information site

Communication Date: 6 December 2024

As of 1 January 2025, for selected group of countries in the APAC region, UBS amended the source of directorship database search checks in our country specifications.

What’s Changing:

Source/ Tools have been updated to reflect current practices in the following 12 countries:

  • Singapore
  • Thailand
  • Taiwan
  • Australia
  • China
  • Hong Kong
  • India
  • Japan
  • Korea
  • Malaysia
  • New Zealand
  • Philippines

We have also updated the criminal record check requirements in our Monaco country specification to read - Monaco residents only: Self-obtained by the candidate.

What you need to do?

Please familiarize yourself with the changes. If you use a different directorship database source to what we have published, we expect you to inform UBS so that we may assess and confirm the source relative to the check. Failure to notify UBS Supplier Advisory team of the alternative source will be flagged as vetting non-compliance in 2025 level 1 vetting compliance reviews.

If you onboard staff in Monaco, please request your staff to obtain documents at source directly from the Monaco authorities? We will no longer accept the vetting vendor report during level 1 audits.

If you have any questions, please contact us.

Communication Date: 1 August 2024

As of 1 September 2024, UBS will be implementing the below changes which impact the vetting checks you perform as an approved Level 1 supplier. Of course, these checks would only be required where legally permissible in the respective country of UBS onboarding.

What’s Changing:

An additional set of countries UBS will no longer require credit and criminal check for every new joiner. “Enhanced” vetting (where credit and / or criminal checks are required and permissible per local laws and regulations), will only be required for a limited population.

To identify the population requiring “enhanced” vetting, we have updated our "Staff Vetting Supplementary form” to apply to the following additional countries:

  • Japan
  • Taiwan
  • Hong Kong
  • Jersey
  • Monaco
  • Turkey
  • Qatar
  • China
  • South Africa

The new Staff Vetting Supplementary forms are now available when you select the specific country of onboarding under the tab document library on the level 1 webpage.

In addition to this change we have amended the frequency of periodic staff vetting (PSV) in all the country specifications from 3 years to 4 years. This is consistent with the communication you received earlier in the year from the UBS periodic staff vetting team, but now the changes are reflected in the country vetting specifications.

“Document(s) must cover all the jurisdictions / countries where the candidate has resided, was employed, attended school or lived more than 6 months over the period equal to the frequency of periodic vetting (e.g. if the frequency of periodic vetting is 4 years, the check / address history must cover the last 4 years).”

All vetting country specifications have been reviewed and amended to reflect the changes and will be available as of the 2 August 2024.

What you need to do?

Please ensure that your vetting vendor packages are updated and aligned accordingly.

With respect to staff onboarding in the 9 countries listed above, you are expected to initiate vetting after receiving the new “Staff Vetting Supplementary form" from your business contact, as the form will indicate whether or not the role of your staff is expected to have “enhanced” vetting (inclusive of credit and criminal).

All onboarding requests raised within the UBS HR systems as of 1 September 2024 must be vetted according to the newly published country specifications and will be audited accordingly.

Communication Date: 12 April 2024

As of 1 May 2024, UBS has integrated and standardized our vetting requirements for external staff globally, a prerequisite for onboarding any vendor staff to a UBS or CS legal entity. Our expectation to you as level 1 supplier is that you continue to complete the pre-start vetting checks of your staff no earlier than 6 months (3 months for Americas) before the UBS start date.

What’s Changing:

As of 1 May 2024, UBS has integrated and standardized our vetting requirements for external staff globally, a prerequisite for onboarding any vendor staff to a UBS or CS legal entity. Our expectation to you as level 1 supplier is that you continue to complete the pre-start vetting checks of your staff no earlier than 6 months (3 months for Americas) before the UBS start date.

Countries impacted

Countries impacted

Change made

Change made

Countries impacted

Indonesia

Change made

change in source of criminal check to Indonesian Police Certificate (SKCK) issued by the local district Police Office

Countries impacted

Philippines

Change made

change in criminal checks to Philippines National Bureau Investigations (NBI)

Countries impacted

Taiwan

Change made

change in source of credit check to Taiwan Clearing House

Countries impacted

Thailand

Change made

non-material change, the description of police check has been removed

 

Countries impacted

New Countries

Change made

 

Countries impacted

Guernsey

Change made

onboarding currently possible to CS legal entity. UBS legal entity scheduled for 1 June

Countries impacted

Bermudas

Change made

onboarding currently possible to CS legal entity. UBS legal entity scheduled for 1 June

Countries impacted

Lichtenstein

Change made

onboarding currently possible to CS legal entity. UBS legal entity currently not possible, TBD

Countries impacted

Portugal

Change made

onboarding currently possible to CS legal entity. UBS legal entity currently not possible, TBD

In addition to updating/creating the above country specifications, we have amended the following documents which will all be available on our level 1 webpage as of the 19 April 2024.

  • Level 1 Staff Vetting Declaration Form
  • Basic / Enhanced Vetting Supplementary Form
  • Vetting Finding Guidelines
  • Process flow diagram and step by step guide

What you need to do?

Please familiarize yourself with the changes and implement them in line with your contractual services and your UBS pre- approved vetting approach.

For new countries, currently it is only possible to onboard to existing CS legal entities. However once UBS legal entities are created, onboardings to these entities will be possible.

Thank you for your continued support. If you have any questions, please contact us.

Communication Date: 6 February 2024

In November 2023, we shared with you our UBS vetting expectations resulting from the integration of UBS and Credit Suisse (CS). We informed you that i) as of 1 December 2023 you are expected to apply UBS vetting requirements to all staff newly onboarded to either UBS or CS; and ii) as of 31 January 2024, you required to ‘top up’ checks pertaining to any existing staff currently onboarded at CS (e.g. credit and criminal checks). Lastly, we informed you that as of February 2024 UBS and CS will adopt the same vetting standards and processes for all vendor staff.

What’s Changing:

We are amending our go-live date from 1 February 2024 to 1 May 2024.

The Poland country specification has been updated, effective 1 March 2024, removing the criminal check requirement.

What you need to do?

Your continued support of the UBS vetting requirements is expected under the UBS Agreement to any services that you are providing (or will in the future provide) under the CS Agreement.

If you have not already done so, please confirm compliance with the expectations above inclusive of the 31 January 2024 deadline (or alternative pre-agreed date).

As we approach the go-live date we will reach out to you with more information regarding any process changes.

Communication Date: 4 August 2023

As per the last changes effective as of the 1st of July/August 2023, we would like to amend our communication with a change for the US.

The “Enhanced” vetting (where credit and / or criminal checks are required and permissible per local laws and regulations) being required for a limited population and based on the UBS Line Manager completing a Staff Vetting Supplementary form will NOT be relevant for the USA.

The process for the US will remain unchanged (criminal checks required for every new joiner and credit checks to be performed based on roles, per the US Staff Vetting Supplementary Form Eligibility assessment).

What’s changing:

Effective immediately, UBS has implemented the below changes which impact the frequency of required compliance reviews required by UBS each year.

  • Compliance reviews will move from quarterly to every 6 months for suppliers who have demonstrated compliance over 12 consecutive months (1 audit covering 12 months, and 1 affirmation covering the past 6 months). Should non-compliance be demonstrated in the 6 monthly review, quarterly compliance reviews will be reinstated.
    Note: Where data retention rules are less than 12 months (e.g., UK), the affirmation may be replaced by an audit covering the impacted location only.
  • All compliance reviews will be performed internally by the UBS HR Supplier Vetting Advisory Team effective 1st July 2023. KPMG will no longer be used for these reviews.
  • UBS will always communicate in writing if the frequency of the compliance reviews change.

What you need to do?

  • Your continued dedicated collaboration during the review cycles would be greatly appreciated to ensure UBS vetting requirements and standards are met.

We hope you view these changes as positively as we do and would like to say thank you for your continued diligence.

Communication Date: 2 June 2023

As of 1 July 2023, UBS will be implementing the below changes which impact the vetting checks you perform as an approved Level 1 supplier. Of course, these checks would only be required where legally permissible in the respective country of UBS onboarding.

What’s Changing:

For a select group of countries, UBS will no longer be requiring credit and criminal check for every new joiner. “Enhanced” vetting (where credit and / or criminal checks are required and permissible per local laws and regulations), will only be required for a limited population.

In order to identify the population requiring “enhanced” vetting, we have created a new "Staff Vetting Supplementary form impacting the following countries:

  • Singapore
  • Australia
  • Switzerland
  • Mexico (scheduled for Aug 1st)
  • Brazil (scheduled for Aug 1st)
  • USA (scheduled for Aug 1st)

In addition to this change we have amended the extra jurisdiction checks from 3 months to 6 months and the country specifications now read - document(s) must cover all the jurisdictions / countries where the candidate has resided, was employed, attended school, or lived more than 6 months over the last 5 years (required address history).

All vetting country specifications have been reviewed and amended to reflect the timing changes and any changes to local laws and will also be available as of the 21st June 2023.

What you need to do?

  • Please ensure that your packages with the respective vetting vendors are updated and aligned accordingly.
  • With respect to staff onboarding in the 6 countries listed above, you are expected to initiate vetting after receiving the new “Staff Vetting Supplementary form" from your business contact, as the form will indicate whether or not the role of your staff is expected to have “enhanced” vetting (inclusive of credit and criminal).
  • The new form (Staff Vetting Supplementary form) will be available in the 'Document library' on the External Staff Vetting webpage as of 21st June 2023.
  • All onboardings that are raised within the UBS HR system as of 1st July 2023 must be vetted according to the newly published country specifications and will be audited accordingly.

Communication Date: 26 May 2023

Improving the vendor contracting and HR onboarding processes

We’d like to make you aware of improvements in how we onboard vendor staff at UBS, starting 29 May 2023. Specifically, Human Resources and Supply Chain have enabled the contracting and HR vetting/onboarding processes to happen in parallel. That means more vendor staff will be able to start services on time, with fewer policy exceptions and start-date moves, and a better overall experience for everyone involved. Here’s what’s changing and what requestors of vendor staff onboardings need to do:

What’s changing

  • External staff onboarding requests may now be initiated on a drafted Contract ID and vetting may be initiated as early as six months before the new joiner’s start date (three months in the Americas)
  • Vendor staff onboarding requests must be paired with a valid Contract ID - master service agreements and invalid contract IDs (e.g., 999999) are not allowed.
  • New joiners can start only after:
    1. successful clearance of UBS vetting requirements (or an approved HR exception)
    2. our contracting tool (Logistics Platform) reflects a contract status of Published, Draft Amendment, or Pending with a start date on or before the new joiner’s start date

If vetting clears earlier than the mandatory lead time, line managers will be notified and may request an earlier start date so long as the contract is active.

What you need to do

  • For suppliers who are approved to perform vetting themselves (Level 1), ensure that you identify the staff you need early and start the vetting process immediately.
  • For Level 2 suppliers, as soon as a draft contract is recorded in the contracting tool, your UBS business contact should submit the external staff onboarding request in UBS’s GetSet tool so HR can start the vetting and GPN-creation process.

We’re doing everything we can to make sure your staff starts when our business needs them. Thanks for your partnership in making this a win-win for everyone involved.

For questions regarding this project, please contact me or your UBS contract manager.

Communication Date: 19 April 2023

Off the back of the last email sent communicating changes effective as of the 1st April 2023, we would like to amend our communication with a change for the Americas.

What has changed?

  • Pre-start vetting checks may now be started no earlier than 6 months (3 months for Americas) before the UBS start date.
  • The documents are expected to be no older than 6 months (3 months for staff onboarded in the Americas) from your direct employee’s or subcontractor’s UBS start date/engagement date. However, where Credit and / or Criminal checks are permissible for staff onboarded outside of the Americas, these document(s) must be original and dated no older than 3 months from vetting case completion (or from the UBS start date, whichever is earlier).

We have amended our SVD and published a new version our level 1 webpage. This is attached as well for easy reference.

In summary there is no change for Americas countries, and you continue to follow the 3 month requirement for all checks.

Communication Date: 24 March 2023

As of 1 April 2023, UBS will be implementing the below changes which impact the vetting checks you perform as an approved Level 1 supplier. The purpose of these changes is to allow vetting to start earlier in an effort to complete the vetting prior to the services being expected and to comply with local legal and regulatory changes.

What specifically is changing?

  • Pre-start vetting checks may now be started no earlier than 6 months before the UBS start date. Previously UBS allowed 90 days before UBS start date.
  • Where a Credit or Criminal is permissible, document(s) need to be original and current, e.g., dated not older than 3 months from vetting case completion (or from the start date, whichever is earlier).
  • Staff Vetting Declaration Form has been amended to reflect the above changes and now includes a field for “Vetting Case Completion date” (e.g., when you have closed your vetting checks for each staff member).
  • Family relationship check has been re-named to Relatives & Relationship.
  • Updated Country Specifications reflecting the timeliness and name changes above.
  • The Staff Confidentiality declaration for each region has been updated with some minor changes.

What we expect from you

With our collective ambition to enable services to start as of the contract start date, timely initiation of the vetting processes and compliance with UBS’s vetting standards remain crucial. Compliance will be monitored via our standard vetting compliance reviews (e.g., our annual audit) whereby we will review the checks performed along with the timeliness of the checks using the dates you provide us on the SVD form.

The updated country specifications and Level 1 staff vetting declaration (SVD) form will be uploaded to our Level 1 webpage and be available for you to use as of the 1 April 2023.

Communication Date: 5 January 2023

To simplify and improve the vetting and onboarding process of external staff, we will implement some changes that become effective during January 2023.

During the month of January 2023 our regional vetting teams will be accepting the old version of the forms. As of 1 February 2023, the new forms listed below will be required and old versions of documents will no longer be accepted. As an approved Level 1 supplier please make sure you are familiar with the below forms and start to use them as of January 2023.

Forms that have been changed

  • The Staff Vetting Declaration (SVD) form has been updated for Level 1 suppliers with the following improvements:
    • Date fields are now dropdown for the day, month, and year (this will help reduce any confusion when including dates)
    • All Level 2 fields have been removed (the form is specific to Level 1 suppliers)
    • Work location country and valid Organizational Unit (OU) in the physical location are now required. This will ensure external staff are only onboarded in the countries from where they will provide services
  • The Staff Declarations forms relating to confidentiality and related matters (aka Declaration of staff member regarding data protection/ privacy and client confidentiality/bank secrecy obligations) are now region-specific (EMEA including UK, APAC, and the Americas countries) rather than country specific.

Cosmetic changes

  • EU UK Staff Vetting Supplementary Form
  • US Staff Vetting Supplementary Form
  • Germany Staff Vetting Supplementary Form

We have also made improvements to our Level 1 webpage. You are now able to select the country of onboarding from the drop down menu via the Document Library page to easily access all required documents related to your staff onboarding request.

All updated documents are now available via the Document Library page.

Communication Date: 26 October 2022

Disclaimer – this communication was intended for suppliers which are only based in Monaco. For “global” Level 1 suppliers with Monaco in their country scope there are no changes.

We would like to inform you about some changes that will come into effect as of the 1st of December 2022.

Currently you have been performing the vetting of all your staff when they are onboarded to UBS. This process has required UBS each year, through our level 1 auditor to perform an audit of a sample of the background checks you have completed to ensure that these checks were inline with UBS vetting requirements in Monaco. This has been challenging as we have identified suppliers where the vetting was not performed correctly and before UBS start date.

What's changing for you?

This has required us to re-evaluate the process in Monaco and we have decided to move all suppliers to our level 2 vetting approach where UBS performs the vetting of each external staff onboarded at UBS. This will mean the following

  • All vetting to be completed by UBS (through our approved vetting vendor HireRight)
  • All checks will continue to be completed pre-UBS start date
  • No audits will be required in the future as vetting is performed by UBS

Please can you support and update and sign the attached level 2 vetting annex and return back to UBS by Friday the 18th November 2022.

Communication Date: 18 January 2022

As of 19 February 2022, UBS will be implementing the below changes which impact the vetting checks you perform as an approved Level 1 supplier.

  • The age of vetting evidence for all checks required for your candidates at the time of start date at UBS is being increased from 60 days to 90 days. All checks encompass registered status, external directorship and family relationship declarations, criminal, credit and external directorship database search.
    The country specifications are updated to read ‘Document(s) need to be original and current; e.g. dated not older than 3 months from UBS start date’.
  • Under Section 3 of the Staff Vetting Declaration (SVD) the proof of evidence has also been updated to read ‘not older than 3 months from your direct employee’s or subcontractor’s UBS start date’
  • For clarification, we also expect for External Directorship Database Search that you look back over the 5 year address history of the respective candidate (and this includes international addresses history of the candidate). The country specifications have been updated to reflect this.

Countries impacted

Countries impacted

Change made

Change made

Countries impacted

All countries

Change made

Country Specification updated to read:
Document(s) need to be original and current; e.g. dated not older than 3 months from UBS start date.

External Directorship Database check updated to read:
The check must cover all the jurisdictions / countries where the candidate has resided, was employed, attended school or lived more than 3 months over the last 5 years (required address history)

Countries impacted

Ireland

Change made

Regulated roles information added

Countries impacted

Luxembourg / France

Change made

Add Periodic Staff Vetting is not Permitted

Communication Date: 31 August 2021

We would like to inform you about some country specifications changes that will come into effect as of the 1st of September 2021.

What's changing for you?

No periodic vetting will be required for the following countries:

  • Sweden
  • Luxembourg and France (Periodic vetting will only apply for staff who move into a regulated role)

For Ireland, a credit check is required for Periodic vetting going forward. Please ensure that your packages with the respective vetting vendors are updated in case you have staff in Ireland that are subject to Periodic Vetting.

Updates, including the amendments to the Vetting Country Specifications, are available on the Level 1 Supplier Webpage.

Communication Date:14 December 2020

As of 20 January 2021, staff are not allowed to start working at UBS until all vetting checks have been successfully completed. The checks include criminal check, credit check and directorship database search (formerly referred to as “post-start” checks). Of course, these checks would only be required where legally permissible in the respective country of UBS onboarding. All vetting country specifications have been reviewed and amended to reflect the timing changes and any changes to local laws. A new "EU | UK Staff Vetting Supplementary form" has been established to be able to identify the population which will require a credit and a criminal check, if permissible in the onboarding country. In addition to the vetting country specification changes(PDF, 436 KB), we would like to inform you about a re-wording in the Staff Vetting Declaration (SVD) Form. German and French versions will be added here on the 31 December 2020.

How does this affect you as a Level 1 supplier?

  • The vetting country specifications for each country have been updated. All country specifications can be found in track changes mode in 'Changes to Country Specification' on the External Staff Vetting webpage for your information only. 
  • Please ensure that your packages with the respective vetting vendors are updated and aligned accordingly.
  • The revised and new forms (Staff Vetting Declaration Form, EU | UK Staff Vetting Supplementary form) will be available on the Supplier webpage in the 'Document library' on the External Staff Vetting webpage as of 20 January. These documents must be used from 20 January 2021 onwards; we will then no longer accept the old forms.
  • You can only start vetting for staff working in a work location in the European Union (Austria, Denmark, France, Germany, Hungary, Ireland, Italy, Luxembourg, Netherlands, Poland, Romania, Spain, Sweden) and the UK after receiving the "EU | UK Staff Vetting Supplementary form" from your Business contact which indicates whether you are allowed to perform criminal and credit check in accordance to the role of your staff at UBS.
  • The onboarding request (incl. all required documents – e.g. Staff Vetting Declaration Form) can only be submitted when all vetting checks have been successfully concluded by you.
  • All onboardings that are raised within the UBS HR system as of 20 January 2021 must be vetted according to the newly published country specifications and will be audited accordingly. 

Communication Date:14 September 2020

We would like to inform you about changes to the Brazil vetting specification that have come into effect as of the 14th September 2020.

What has changed?

Onboarding and Periodic Vetting:

The UBS Vetting Check specifications for Brazil no longer require that the Credit Checks for both on-boarding and periodic vetting be completed. This is due to changes in local Law.

How does this affect you as a Level 1 supplier?

For future audits, you will not be required to provide evidence of completed credit checks for staff on boarded in Brazil. It will also not be required for periodic vetting.

Communication Date: 31 July 2020

We would like to inform you about a vetting country specification change that will come into effect on 1 August 2020.

What's changing for you?

Criminal Check in Poland (for On-boarding and Periodic Vetting)

Current state:
Currently a satisfactory criminal check is required for staff hired in Poland. As part of that check, UBS suppliers are required to obtain document(s) which cover all the jurisdictions / countries where the candidate has resided, was employed, attended school or lived more than 3 months over the last 5 years (required address history).

Change affecting new vetting cases effective 1 August 2020
Effective 1 August 2020, level 1 suppliers are only required to perform the criminal record check for Poland address histories. Completing the criminal check for all non-Polish jurisdictions / countries where the candidate has resided, was employed, attended school or lived more than 3 months over the last 5 years is not required. This is applicable for both Onboarding and Periodic vetting.

Background
UBS Legal reviewed the Polish law “Ustawa o zasadach pozyskiwania informacji o niekaralności” (The Act) which applies to employees in Poland and advised that the Act only permits criminal record checks for Polish criminal offences that are recorded on the Polish National Criminal Register (PNCR). Therefore, while level 1 suppliers are not legally prohibited from checking a non-Polish address against the Polish National Criminal Register, doing so may not be productive because it is unlikely that a person residing outside Poland will have been convicted of a Polish offence recorded on the PNCR. UBS therefore has updated the Poland country vetting specifications.

Updates, including the amendments to the Vetting Country Specifications for Poland, are available on the Level 1 Supplier Webpage

Communication Date: 13 May 2020

Changes to Staff Vetting Declaration Form effective June 2020 / COVID-19 workarounds

Today we would like to inform you about changes to the Staff Declaration Form and also provide you with an update on COVID-19 impacts.

Staff Declaration Form (revised and effective as of June 2020)

UBS’s vetting policy and minimum standards clearly require that all external staff (inclusive of subcontractors / 4th party staff) who have access to UBS systems and premises, must be vetted to the same standard as UBS requires for internal staff performing similar roles. In order to demonstrate to examiners that this requirement is met, UBS is obliged to distinguish between 3rd party (e.g. your direct employees) and 4th party (subcontractor) staff and, for 4th party staff, to record the subcontractor company name. In order to do this, we have amended the Staff Declaration Form to collect this information. It is mandatory for you to fill in this information accordingly. If the information is not provided, UBS will revert to you which may delay the onboarding process.

In addition to the new subcontractor information we are collecting, we took the opportunity to improve the layout for your convenience. The revised Staff Declaration Form will be available on the Level 1 Supplier Webpage as of 14th May 2020.

You can use the revised form with immediate effect, but latest as of 14/06/2020. After this date we can no longer accept the old version.

COVID-19 workarounds

In March, we communicated with all our level 1 suppliers regarding the uncertainty surrounding COVID-19 (Coronavirus) and your ability to comply with UBS’s vetting requirements (e.g. completing criminal/credit checks within 4 weeks of the individual’s UBS start date).

We asked that you use the specific email channels we publish on our level 1 webpage and make our External Staff Vetting Teams aware of any delays. We expect these delays to continue and require you to continue to communicate with UBS about the delays expressing that they are covid-related and being monitored. We also expect you to inform our vetting teams as soon as the checks are completed so that they may inform the business about vetting completion. Any failure to notify UBS will be a failure of the audit/reviews for vendor compliance.

A temporary covid workaround identified for the UK is for Criminal Checks. In the interim UBS will accept the DBS check which will temporarily replace the Scotland Disclosure. The proposal is to be used as workarounds effective for covid delayed cases from 1 Jan '20 until further notice.

Thank you for your partnership and stay well during these challenging times.

Communication Date: 24 March 2020

COVID-19 (Coronavirus) information

We are aware of the increasing uncertainty surrounding COVID-19 (Coronavirus) and the impact it is having Globally. We are also aware of the affect it will have on your ability to comply with UBS’s vetting requirements (e.g. completing criminal/credit checks within 4 weeks of the individual’s UBS start date).

In order to be properly prepared for your audit and quarterly reviews, we would like to remind you that any delay in completing the checks within the timeline needs to be communicated to UBS via the specific email channels we publish on our level 1 webpage. You should retain these emails to evidence for KPMG and actively monitor the completion of these checks.

Thank you for your partnership and stay well during these challenging times.

Communication Date: 28 November 2019

We would like to inform you about some vetting changes that will come into effect on 3 January 2020.

What's changing for you?

Periodic Vetting – Criminal and Credit Check:

  • As of today: The UBS Vetting Check specifications require that Criminal and Credit Checks for both on-boarding vetting and periodic vetting must cover all the jurisdictions / countries where the candidate has resided, was employed, attended school or lived more than 3 months over the last 5 years. Nevertheless, a significant part of risk-sensitive staff is subject to periodic vetting on a 3 year frequency. The current process includes an overlap of 2 years for which the checks may be duplicated.
  • As of 3 January 2020: UBS will align the period to be covered for periodic vetting with the re-vetting frequency, removing the overlap in place with risk-sensitive staff who are in-scope of periodic vetting (e.g. if the frequency of periodic vetting is 3 years, Criminal- and Credit-Checks must cover the last 3 years). Any exceptions to this rule would be communicated on a case-by-case base.

Criminal Check in Poland (for On-boarding and Periodic Vetting)

  • Current state: Criminal check is not being conducted for staff hired in Poland.
  • Change effecting new vetting cases effective 1 January 2020: As of 12th of April 2018, the Criminal record certificate may be requested from candidates as well as current employees (Article 1.1. ; 2 of Ustawa z dnia 12 kwietnia 2018 r. o zasadach pozyskiwania informacji o niekaralności osób ubiegających się o zatrudnienie i osób zatrudnionych w podmiotach sektora finansowego).

UBS BSC Meets criteria of "Banking supporting entity" and is eligible to implement Criminal Check (Article 2.1. paragraph 5). Refusal to provide information or disclosure of conviction may lead to offer withdrawal (Article 5.1) and employment termination (Article 5.2).

Effective from 1st of January 2020, UBS decided to conduct criminal check of defined categories of staff in Poland in order to meet Global Vetting Policy requirements and to meet GDPR restrictions. Criminal check will be applicable to following categories of staff (based on Hiring/Line manager’s nomination):

  1. senior management roles (rank ED+ and board members) including personal assistants, and board administrators with access to confidential information.
  2. functions which involve the handling of sensitive/confidential financial information, including financial systems (e.g. highly privileged users, regulated persons);
  3. staff of control functions per Policy 1-C-007976 (e.g. Group Risk Control, Group Compliance, Regulatory & Governance, Group Finance, Group Legal and Group Human Resources). This is limited to those having an access to confidential / legally protected information.

As a Level 1 suppliers you will be contacted in case that a Criminal Check is required (On-boarding).

For all risk-sensitive staff subject to periodic vetting, as determined by UBS, Criminal Check is mandatory in Poland (please see attached vetting check specifications).

Updates, including the amendments to both the Vetting Country Specifications and the Vetting Finding Guidelines, will be available on the Level 1 Supplier Webpage as of 3 January 2020 (the effective date of the changes).

Communication Date: 29 July 2019

On a regular basis, UBS takes the opportunity to review our vetting processes and documentation with an eye towards improvements, simplification, global alignment and compliance with new laws or regulations. With this in mind, we would like to inform you about some vetting changes that will come into effect as of 1st September 2019.

What's changing for you?

For Re-Engagement (if the time between the UBS termination date and new start date of your staff is less than 6 months [less than 90 days in the Americas], and vetting evidence is less than 12 months old and available) the additional two checks need to be performed and escalated to UBS in case of any finding:

  • External Directorship Self Declaration
  • Family Relationship Self Declaration

This change will also be reflected in the updated Staff Vetting Declaration Form, in addition to a question, where we ask you to provide us with the preferred name of your candidate which will help us to perform the UBS background checks.

Updates, including the Staff Declaration Form and the related amendments to the Vetting Finding Guidelines, will be available on the Level 1 Supplier Webpage as of 1 September 2019 (the effective date of the changes).