Guidelines for Level 1 Suppliers
External Staff Vetting Level 1 Overview
Level 1 Suppliers are approved to either conduct the vetting themselves and/or by engaging a vetting vendor in line with the UBS global vetting specifications.
Independent of any delegation of vetting execution, Level 1 suppliers remains accountable for retention of vetting evidence and the result of the vetting checks for all their staff inclusive of subcontractors / 4th party staff.
Level 1 Approval process
Level 1 Approval process
For information about the Level 1 approval process (including changes to vetting process and addition of new countries) see information in the link below:
Guidance notes - Execution of vetting
Guidance notes - Execution of vetting
- Provision of Vetting Declaration Form: The supplier representative will be provided with a Vetting Declaration Form for each candidate. The supplier is responsible for gaining consent of the candidate to do the vetting and inform their staff about additional background checks by UBS (e.g. Global Background Checks, fingerprinting in the USA).
- Submission of Vetting Declaration Form: The Vetting Declaration Form and any other necessary documents (e.g. ID document) must be completed and returned to the UBS Business Contact once all of the vetting checks are completed. The supplier must inform UBS (via the SVD) about the completion date of each check.
- Starting vetting checks: Vetting on the UBS side cannot commence before the supplier has signed a staff vetting annex with UBS and the UBS Business Contact confirmed the assignment/engagement of the candidate.
- Findings in vetting checks:
There are two types of finding and the action that should be taken by the supplier is different dependent on the type of finding:
- Declaration by supplier staff of relatives and relationships or an external directorship:
Action for supplier is report the information to the relevant Regional Staff Vetting Operations Team by sending an email and attaching a copy of the staff vetting Declaration form as soon as possible (See "contact" for email addresses).
- A finding in a check e.g. unsatisfactory vetting results in a credit report, failure to have a valid ID document:
Action for supplier: Perform an Individualized assessment in accordance with applicable law. The supplier should refer to the 'Vetting Finding Guidelines' (available in the “Document Library” tab) which outlines the thresholds for each finding and in accordance with the applicable law determine if the finding constitutes a vetting fail. Please always consider that the decision made should not expose UBS to any reputational or non-financial risk. If the outcome is that there is a vetting fail, the employee needs to be withdrawn from providing services to UBS, please inform the relevant Regional Staff Vetting Operations Team (see 'Contact') and your business contact.
5. Retention of candidate vetting files: Vetting evidences and documents gathered in the vetting process will be stored with the vetting vendors or Level 1 supplier for 12 months (or longer/shorter if required by applicable local law) after vetting execution.
6. Audit: UBS will request an annual audit of the vetting evidence, through a 3rd party auditor or to be reviewed by UBS.
Documents required to be evidenced in audit:
Level 1 suppliers who conduct vetting checks through a vetting vendor; only the vetting vendor report is required (No underlying evidence is required to be presented to the auditors. At your discretion you can present underlying evidence you have been provided from your vetting vendor to the auditors, if you feel that the vetting vendor report does not provide sufficient details about the check. Whilst the vetting vendor report should provide all of the required information about the check, it maybe that the report structure that your vetting vendor uses does not include all of the criteria outlined in the UBS country specifications. If this is the case, you may want them to ask them to change their report structure so that it includes all of the required information from the UBS specification for your vetting cases undertaken for UBS Level 1 vetting).
Level 1 suppliers who do not have a vetting vendor report, this is typically Level 1 suppliers to conduct vetting through their own in house vetting team – the evidence to the check e.g. PDF, certificate, email, print screen, transcript should presented to the auditors.
For suppliers who do not have checks via a vetting vendor and encounter that they have restrictions to retaining the original document which shows the vetting check for 12 months (we have encountered retention issues with criminal record checks) you should ask the 3rd party who conducted the check to provide the information about the check (as outlined in the country specification) in another form of communication e.g. letter, email, which you can present to the auditors as an alternative. You should also show the auditors the evidence from the 3rd party that you have a time restriction to retaining the original document.
Further details of the audit process and schedule will be communicated separately.
7. Exceptions to start without vetting completed
In exceptional circumstances, Regional Staff Vetting Operations Team may allow the candidates to start without vetting being completed. It is the UBS Business Contact’s responsibility to submit the complete exception request to Regional Staff Vetting Operations Team when raising an onboarding request. Every exception request will be reviewed on case-by-case basis. If the exception request does not meet the exception criteria, the exception will be rejected. Regional Staff Vetting Operations Team will inform the UBS business contact about a rejected exception and a requirement to complete all mandatory pre-start check by the Supplier prior to start date. In case of an approved exception, supplier is obliged to send an email to the Regional Staff Vetting Operations Team confirming approved post-start checks completion 4 week after the start date at the latest*.
In case of delays, UBS expects suppliers to report delays of approved post-start vetting checks in a standardized format according to the following mandatory requirements:
- Delays of vetting checks must be reported for each staff member individually by using a standardized email template (available in the “Document Library” tab of this webpage)
- The email must be sent to relevant Regional Staff Vetting Operations Team (see 'Contact')
- Delays must be reported at least 3 days prior to the actual deadline
