Global Background Checking Policy Statement
North America Background Checking Policy
Background Checking Programs
Aon, its subsidiaries, and affiliates (“Aon”) is committed to bringing the highest quality services to our clients. To serve that effort, Aon hires talented, client-oriented, and ethical associates to serve our customer base. Aon believes that hiring qualified individuals contributes to our overall success as an organization.
Purpose of Background Checking
A background check is an important part of the selection process at Aon. It helps to promote a safe and secure work environment and affords additional protection for our clients. Background checks provide additional applicant-related information that helps determine an applicant’s eligibility for employment and a current associate’s eligibility for continued employment.
The purpose of a background check is twofold—to protect Aon, its associates, clients, and data from anything that may threaten the security and/or integrity of Aon’s work environment and to help assess the qualifications and suitability of an applicant for a position. Aon conducts background checks and pre-employment screenings in compliance with all legal and professional standards.
When Background Checking Is Used
Aon is committed to completing a comprehensive background check on every associate in North America, and aspires to do so globally in accordance with local laws and customs. This policy requires that all job applicants to whom an offer of employment has been made pass a background check screening as a condition of employment. Depending on requirements of the position, an applicant’s information will be reviewed and verified against set criteria to determine eligibility.
Current associates may be required to go through a background check and the same standards outlined in this policy must be met for continued employment with Aon. If a current associate does not meet the background checking standards set forth in the policy during the course of his or her employment with Aon, he or she will have the same ability to challenge any adverse finding. However, such finding may also result in separation from the firm. Circumstances that might necessitate a background check be completed on a current associate include, but are not limited to, new client requirements, transferring to a client team that requires background checks, assuming a role that requires driving an Aon-owned vehicle, or at the request of the business for other purposes.
Background Checking Policies
Aon has a general Global Background Checking Policy Statement that applies to all locations around the globe. In addition, a more specific North America Background Checking Policy is in place for the United States and Canada, and additional policies for other locations may be added in the future.
Global Background Checking Policy Statement
Aon’s policy, which is fully implemented in North America and in some locations outside of North America, is to conduct pre-employment background checks on all external job applicants as a condition of employment. Where this policy is operationalized, background checks will be administered within the laws and customs of the operating country.
Standards for All Aon Locations Globally
The laws and customs of countries vary considerably and, as a consequence, the checks conducted vary. However, Aon has set a global standard that we will strive to meet in all locations to the extent allowed by local law including:
- Verify the most recent educational credentials, employment for the prior 5 years, and criminal history.
- Use national ID numbers, such as SSNs in the US, to support the criminal check, where such numbers exist.
- Implement reporting capabilities allowing us to monitor results over time and confirm team member eligibility, if needed, to clients.
- Provide for a consistent means of validating eligibility across locations (e.g., falsification of educational credentials will be a disqualifying result in all locations, within any local legal limits).
Variable Elements
Our ability to complete some components of client-desired background checks varies by country. In addition to legal limitations, the infrastructure may not exist to complete some components (e.g., commercial credit checks are not available in all areas). To the extent that these checks can be done in each specific country, and are desired by the client, they will be performed at an additional cost. They are not part of our global standard.
Background Checks for Current Associates
At times, we may need to conduct or update background checks on current associates. Circumstances that might necessitate a background check include, but are not limited to, transferring to a client team that requires a more extensive background check, being on a team that implements expanded background checking, or assuming a role that requires driving an Aon Hewitt-owned vehicle. Aon reserves the right to conduct a background check on associates at anytime. Background checks may include any of the above mentioned components.
All inquiries are limited to information relevant to job performance and workplace safety and security. Inquiries are conducted by an outside agency in accordance with applicable laws. An associate who does not meet the background checking standards may be separated from the company. Adverse findings will be disclosed to the associate and s/he will have the opportunity to dispute any adverse findings.
Modifications
We reserve the right to modify this global policy statement and any location-specific policies. The effective date of these modifications will be communicated a minimum of 10 business days prior to the change.
North America Background Checking Policy
Aon’s North American background checking policy limits all background check inquiries to information that impacts job performance and the workplace. A consumer report and/or investigative report will be requested as part of the background checking process for all new hires and for current associates as outlined further below. Inquiries are conducted by an outside agency, as hired by Aon, in accordance with applicable federal and state/provincial laws, including the Fair Credit Reporting Act (FCRA) (n/a in Canada).
Consumer Reports
A Consumer Report is the most common report used and is run for all applicants to whom an offer of employment has been made. It may also be run on an existing associate if he or she is moving to a team which requires it to be run, or if the associate’s current team requirements have changed based on client needs.
A Consumer Report consists of information deemed to have a bearing on job performance, and may include information from public and private sources, public records, former employers, and references. The scope of the report may include information concerning the applicant’s civil and criminal court records, education, credentials, past addresses, Social Security Number/Social Insurance Number, previous employment, driving record, and personal references.
Investigative Consumer Reports
An Investigative Consumer Report may be run under special circumstances or to investigate inappropriate conduct.
An Investigative Consumer Report is a report based upon interviews that may contain information relating to the applicant’s character, general reputation, personal characteristics, or mode of living. Applicants have the right to request additional disclosures of the nature and scope of the investigation and statement of their rights. An Investigative Consumer Report may also include reference checks from former employers or references provided by the job applicant. Any reference check is strictly limited to job-related information of report.
Timing
Aon has a policy of conducting background screening reports on all job applicants as a condition of employment. All checks will be started after an employment offer has been made, prior to a new hire’s start date, and employment is contingent upon successful completion of the check. All checks must be successfully completed prior to applicant’s start date.
Confidentiality
The results of the background check are shared by the vendor with a limited number of associates and only when further action is needed based on the results of the check.
Clients may also request an audit of those associates who support their team and have access to their employee personal data. Aon’s position is to provide aggregate data only confirming that all associates assigned to their team have passed a background check in accordance with the contract requirements.
| Type of Check | Criteria |
|---|---|
Education Verification |
Verify High School or post-High School education. |
Employment Verification |
Verify previous seven years of employment, including current employer. |
Criminal History Check |
Based on seven-year residence history or the number of years allowed by the applicable state/provincial laws if less than seven to include:
|
Social Security Trace (not applicable in Canada) |
Uncovers names and addresses associated with the applicant’s Social Security number (SSN). Data is used to target counties of past/current residence for criminal check investigations. |
Global Sanctions and Enforcement Check (GSEC) |
Searches domestic and international data sources from major sanctioning bodies (e.g., U.S., UN, OFAC, European Union, Bank of England), law enforcement agencies (i.e. Interpol, FBI) and financial regulators (i.e. SEC, OCC, FINCEN, OFAC, Lloyds) around the world. |
| Drug Screening | Candidates who accept an offer of employment must successfully complete a 9-panel drug screen within 3 business days of notification. |
Other Impacted Groups
Mergers, Acquisitions, and Business-Process Outsourcing Workforce Additions
For any new hire resulting from a merger, acquisition, or new business-process outsourcing work, checks will be done in accordance of the agreement of the merger or acquisition or BPO contract.
Rehires/Interns/Temporaries
A background check will be required for all rehires, including those who have been separated from Aon for more than 30 calendar days, and had previously completed a background check. A background check is also required for all interns and temporaries (Aon and Aon Hewitt Alumni and external).
