External Staff Vetting Definitions
Vetting
Vetting, also known as background screening or pre-engagement screening, defines a set of checks investigating the background of an individual.
External staff
In this context, external staff are individuals who have no employment contract with a UBS Group AG (inc. Credit Suisse) company. They provide a service or a predefined good to a UBS Group AG (inc. Credit Suisse) company under a contract between a UBS Group AG (inc. Credit Suisse) company and a supplier by whom they are assigned or as a self-employed worker who has a contractual relationship with a UBS Group AG (inc. Credit Suisse) company.
Supplier
Suppliers provide services or resources to UBS under a contractual agreement with individuals who are not part of the UBS staff population.
Vetting vendor
A vetting vendor is a service provider who offers background screenings as his core service offering to other organizations.
Country Specifications
- The country specifications lay out exactly what vetting checks must be performed for candidates who are on assignment with UBS in that country.
- Criteria and thresholds in the country specifications may change based on regulatory, organizational or legal requirement and will be shared with suppliers via this site.
UBS Business Contact
This is the person who raises the external staff request in the UBS HR ticketing system. It is typically the hiring manager, but it could be delegated internally. Takes precautionary measures concerning restricting access to systems, buildings and confidential/strictly confidential information and/or exercises enhanced supervision in case of an approved exception.
Level 1 Suppliers
Level 1 Suppliers can either conduct the vetting themselves or engage a vetting vendor in line with the UBS global vetting specifications. In any case, the Level 1 supplier remains fully accountable for the external staff, retention of vetting evidence and the result of the vetting checks.
Level 2 Process
The vetting is executed by UBS and/or a UBS-certified vetting vendor in line with the UBS global vetting specifications. This process applies to cases where a Level 1 supplier raises an onboarding request for a country where they do not have prior approval. The supplier is accountable for adhering to local data privacy law, which may require the external staff's consent prior to vetting execution.
Regional Staff Vetting Operations Team
Administers vetting cases when there is an onboarding request for external staff. They should receive information from suppliers regarding delays and will inform suppliers and UBS Business Contacts of the vetting case completion. They are the point of contact for supplier representatives responsible for candidate vetting cases.
Vetting Service Management Team
Responsible for the implementation of the firm's external staff vetting policy and processes. The representatives are the point of contact for account managers, legal counsel,- and HR/vetting managers from the Level 1 Supplier.
ChainIQ
Support suppliers with execution of the Staff Vetting Annex.
Sub-contracting
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 subcontractor staff, to record the subcontractor company name.
Please note - Staff augmentation (e.g. staffing agencies) for UBS third party suppliers are not considered subcontractors. If staff augmentation applies to 4th party, they would be considered a subcontractor because they work directly for the subcontracted (e.g. 4th party) company.
Vetting Advisory Lead
The Vetting Advisory Lead is responsible for monitoring the Level 1 supplier compliance in accordance with the Global Staff Vetting Policy.
