Frequently Asked Question – For CS onboardings as per 1st Dec 2023

Please note the below FAQ relate to a letter to UBS Level 1 vendors from October 2023 about required changes in vetting requirements “Application of UBS Vetting Standards across UBS Group AG (inc. Credit Suisse)– Level 1”. The purpose of the FAQ is to provide further detail regarding the requirements set out in the letter.

a. What vetting checks do I need to complete as a CS/UBS Level 1 supplier for a new CS onboarding as of the 1 December 2023?

As of 1 Dec 2023, you are required to complete the vetting checks per the country specifications found on the UBS Level 1 webpage of the country where you will onboard staff. Plus, we expect you to retain the vetting evidence for 12 months. Therefore, please also fill in the Staff Vetting Declaration Form as far as required and keep the record on file (no requirement to hand in to UBS/CS). This will simplify your coordination of checks when UBS performs the compliance check requirements via the level 1 audit.

b. When do the vetting check need to be completed by?

As of 1 Dec 2023, you are required to complete all the vetting checks prior to the CS start date for each candidate being onboarded at CS. Compliance with the requirements will be audited. Please note this important requirement. For urgent starts there is no longer an allowance of 2 months post CS start date for completion of the checks.

c. Can my staff start without all vetting checks being completed? Is there an exception to start without vetting completed?

No. All vetting checks must be completed prior to CS start date. There is no exception process. Vendor must coordinate with CS business to hold back and to ensure no one starts and gets system access prior to successful completion of all vetting checks.

d. Where do I raise the request to onboard my external staff at CS?

You continue to raise the onboarding request in Beeline and follow the required CS compliance requirements in Beeline.

e. Where and how do I raise a request to onboard an individual at CS with only building access (no IT system access)?

You continue to raise the access to CS buildings via your CS internal partner, who enters the request in the MyBuilding Access tool for non-IT external staff. As a Level 1 supplier, you must complete UBS vetting requirements prior to requesting access at CS for Cat III staff (building access only). Compliance with the requirements will be audited.

f. Will the vetting performed for CS staff become subject to a UBS compliance review?

Yes, all onboardings at CS as of 1 December 2023 (Cat I and Cat III staff), will become subject to UBS compliance reviews to be performed in 2024 and as per the same frequency i.e., quarterly.

g. Are there any further updates we can expect early next year?

UBS/CS will communicate any further updates post 1 December 2023 once teams and systems are operationalized.

h. There is a finding in a vetting check, what action is required?

Generally, as a Level 1 supplier, you are expected to assess the findings yourself in consideration of the ‘Vetting Finding Guidelines’. Any vetting questions can be addressed to the UBS Vetting Operations team and Supplier Vetting Advisory Team. (see "Contact" for email addresses).

i. Do we require the UBS/CS business contact to provide us with a completed UBS supplementary form to distinguish between basic and enhanced vetting?

No supplementary form is required. Please apply country specifications and use the ‘Vetting Finding Guidelines’, both found on the UBS Level 1 webpage. On this basis, please take a reasonable decision and document your approach. The documentation may be required when compliance with the requirements will be audited.

j. What vetting checks do I need to complete as a CS/UBS Level 1 supplier for any existing staff at CS onboarded per the requirements of CS Annex G?

As of 1 Dec 2023 (or earlier if possible), you are expected to start reviewing the vetting evidence you have for staff already onboarded to CS to ensure you can evidence compliance with UBS standards with regards to criminal and credit checks. If compliance cannot be demonstrated, you have until 31 January 2024 to obtain current evidence to ensure compliance (please note you will not be penalized if the evidence for legacy CS staff is current and not prior to start date). Suppliers are expected to evidence compliance with UBS standards in order to pass the 2024 UBS compliance reviews. You have until 31 January 2024 to ensure the evidence is complete unless a time extension is approved by UBS HR prior to year-end 2023.