1. Purpose
The purpose of this policy is to ensure Tenex hires and retains individuals who demonstrate integrity, reliability, and legal eligibility to work in the United States. As a cybersecurity company handling sensitive data and infrastructure, we are committed to a thorough and compliant screening process.
2. Scope
This policy applies to:
– All new hires (full-time and part-time)
– Interns
– Contractors and consultants
– Temporary or agency workers
– Current employees
3. Policy Statement
Tenex requires all employment offers to be contingent upon the successful completion of background screening and work authorization checks, which must be finalized prior to onboarding. No employee may begin work until all required checks are completed and cleared.
4. Background Screening
Tenex utilizes Checkr.com to conduct the following background checks:
Check Type | Description |
SSN Trace | Verifies the candidate’s Social Security Number and retrieves associated names and addresses. |
Global Watchlist Search | Screens for matches on international and domestic watchlists (e.g., OFAC, Interpol, FBI, etc.). |
National Criminal Search | Identifies criminal history across national and state databases. |
Sex Offender Search | Flags candidates listed on federal and state sex offender registries. |
Education Verification | Confirm education and certification history to help ensure the candidate has required qualifications for a specific role. |
Employment Verification | Confirm the candidate’s employment history for a specific time period. |
FACIS (Fraud Abuse Control Information System) | Screens for records of sanctions, exclusions, disciplinary actions, or other compliance-related findings to help identify individuals who may be restricted from working in regulated industries. |
Drug Testing* | Screens for the presence of illegal drugs and controlled substances to ensure compliance with company policy and role requirements. |
*Additional Checks
Additional checks such as credit reports or drug testing may be required for specific roles, based on customer requirements, access level or fiduciary responsibilities.
5. Work Authorization
Tenex complies with U.S. employment eligibility requirements via:
Requirement | Description |
I-9 Verification | All employees must complete Form I-9 within the first three business days of employment. Tenex verifies the identity and work authorization documents submitted. |
E-Verify | Tenex participates in the E-Verify program to electronically confirm employment eligibility with the Department of Homeland Security (DHS) and Social Security Administration (SSA). |
6. FINRA and FCPA Attestation Requirement
In addition to the background checks and work authorization verifications described above, Tenex requires all employees to complete a formal attestation regarding their regulatory and ethical history.
Each employee must sign an Employee Attestation Letter, affirming the following:
Criminal and Regulatory History:
The employee has not been convicted of or pled guilty/no contest to any felony or certain misdemeanors, including those related to fraud, investments, bribery, or other misconduct. The employee has not been disciplined, barred, or suspended by any securities or financial regulatory body (e.g., FINRA, SEC, CFTC).Anti-Bribery and Foreign Corrupt Practices Act (FCPA) Compliance:
The employee has not and will not offer or provide any improper payments, gifts, or items of value to foreign officials or political parties in violation of the Foreign Corrupt Practices Act (FCPA) or similar anti-bribery laws.Duty of Accuracy:
Misstatements or omissions in the attestation may result in termination of employment and legal recourse. This attestation is binding and enforceable under state law.
7. Timing & Conditional Offers
All background checks must be completed prior to onboarding. Employment offers are conditional and may be rescinded based on the results of the background check or work authorization outcome.
Tenex will provide all legally required disclosures and obtain written consent before initiating any screening processes.
8. Disqualifying Criteria
Disqualification decisions are made based on job-relatedness, security posture, and legal obligations. Grounds may include, but are not limited to:
– Unresolved or disqualifying criminal history (fraud, violence, cybercrime, felony conviction)
– Ineligibility to work in the U.S.
– False identity or documentation
– Sex offender registration
– Material misrepresentations or omissions
– Failed drug test, evidence of specimen tampering, or refusal to test (required for specific roles)
Each case is subject to an individualized assessment in accordance with EEOC guidance and applicable laws.
9. Rechecks and Ongoing Screening
Tenex reserves the right to request a formal attestation and/or conduct periodic re-screening or additional checks during employment for:
– Elevated access privileges
– Executive or financial responsibilities
– Material changes in role or contract status
– To ensure compliance with customer requirements
10. Privacy & Data Retention
All collected data is handled with the strictest confidentiality and stored in secure systems. Tenex limits access to authorized HR and compliance personnel. Retention aligns with legal and regulatory standards.
11. Appeals Process
Candidates or employees may dispute inaccurate findings. Tenex will temporarily suspend hiring decisions while Checkr.com or other vendors investigate and resolve disputes.
12. Enforcement & Violations
Failure to comply with or pass required screenings will result in rescinded offers, denied onboarding, or disciplinary action up to and including termination for existing employees.