HIRING OF FORMER GOVERNMENT & MILITARY PERSONNEL

Federal statutes and regulations govern certain post-employment activities of former military personnel and federal civilian employees - including potential conflict of interest. As a federal Government contractor, Trinity Information Technology, LLC (Trinity IT) is required to ensure that it does not engage in pre-employment discussions with Government personnel who have knowledge of specific upcoming or current solicitations for which they are being interviewed. This requirement is in accordance with subsection (a) of Section 27, Procurement Integrity, of the Office of Federal Procurement Policy Act 41 (U.S.C. 423), "Prohibited Conduct by Compet­ing Contractors."

In addition, 18 U.S.C. § 208 may place restrictions on employment discussions between you and Trinity IT. This law precludes federal employees from participating substantially in any spe­cific matter in which Trinity IT has a financial interest while they are directly negotiating with, or while they have an arrangement for future employment with Trinity IT.

If you are engaged in any activity covered by the two restrictions described above, you can en­gage in employment discussions with Trinity IT only after you provide documented waivers or disqualification.

Significant penalties may result for both the employer and the candidate from violations of these statutes and regulations. You are required to complete the following certification form, which will be used by Trinity IT in determining whether you are eligible for employment.

To comply with this requirement, Trinity IT requires all job applicants to complete this certifica­tion prior to pre-employment interviews being conducted. Please answer the following ques­tions, sign and return to the Human Resources department.

Before you complete the certification form, please review both laws and their implementing regulations. If you are not sure if the laws apply to you, consult with your agency's Designated Agency Ethics Official. If you are engaged in any activity covered by either 41 U.S.C. § 423 or 18 U.S.C. § 208, but are permitted to seek employment with Trinity IT because you have com­ plied with all applicable conditions and restrictions, please provide the documents to support your agency's approval of the disqualification or waiver.

Please note Trinity IT cannot engage in any discussions with you about possible employment openings until you complete, sign and return the attached form and provided supporting docu­mentation, if required.

We appreciate your prompt attention to this request.

PRE-EMPLOYMENT CERTIFICATION

1. Procurement Integrity Restrictions under 41 U.S.C. § 423
I am permitted, under 41 U.S.C. § 423, to engage in discussions with Trinity IT about potential employment opportunities because:
•  I am not (nor am I supervising anyone who is) participating substantially in any federal agency procurement in which Trinity IT is a bidder or offerer; or
• I was participating substantially (either through personal action or supervision) in a fed­eral agency procurement in which Trinity IT is a bidder or offerer, but I have complied with all conditions and restrictions of my agency disqualification from participating in the procurement and have attached a true and accurate copy of my approved disqualifica­tion.

2. Pre-Employment Contact Restrictions under 18 U.S.C. § 208
I am permitted, under 18 USC§ 208, to seek employment with Trinity IT because:
• None of my government duties or responsibilities involve me (or anyone I supervise) substantially taking any official action on any particular matter in which Trinity IT or any affiliate has a financial interest, or
• My government duties or responsibilities involved me (or someone I supervise or super­vised) substantially taking official action on official matter(s) in which Trinity IT has a fi­nancial interest, but I have complied with all conditions and restrictions of my written agency disqualification from participation or written waiver authorizing participation, and have attached a true and accurate copy of my approved disqualification or waiver.

3. Certification
I certify that I am aware of and understand the restrictions on pre-employment contact set forth in 41 U.S.C.§ 423 and 18 U.S.C.§ 208, and that the information provided above is true, accu­rate, and complete. I further certify that I am unaware of any potential conflict of interest that would preclude Trinity IT from entering into employment discussions with me. I will continue to comply with these laws, their implementing regulations, and any other requirements of my gov­ernment agency, which relate to any contacts, discussion or other forms of communication I may have regarding the possibility of employment with Trinity IT.

BACKGROUND CHECK DISCLOSURE

Trinity Information Technology, LLC (the “Company”) may order a “consumer report” (a background report) or “investigative consumer report" on you in connection with your employment application, and if you are hired, or if you already work for the Company, may order additional background reports on you for employment purposes, to the maximum extent permitted by applicable law.

The background check company, ADP Screening and Selection Services, will prepare the background report for the Company. ADP Screening and Selection Services is located at 301 Remington Street, Fort Collins, CO, 80524, and can be reached by phone at 800-367-5933 or at their Internet Web site address www.adpselect.com.

The background report may contain information concerning your character, general reputation, personal characteristics, mode of living, criminal history, and credit standing. An “investigative consumer report” is a background report that includes information from personal interviews. Information may be obtained from private and public sources and for investigative consumer reports from personal interviews
as noted above. You may request more information about the nature and scope of an investigative consumer report, if any, by contacting the Company at (267) 396-7901.

The Fair Credit Reporting Act gives you specific rights in dealing with consumer reporting agencies. You will find these rights summarized in the document titled A Summary of Your Rights Under the Fair Credit Reporting Act, as provided further below.

AUTHORIZATION FOR BACKGROUND CHECKS
I authorize the Company to obtain my background report, including investigative consumer reports. I also agree that a copy of this form is valid like the signed original. I understand that, as allowed by law, the Company may rely on this authorization to order additional background reports, including investigative consumer reports, (1) during my employment and (2) from companies other than ADP Screening and Selection Services without asking me for my authorization again, as allowed by law. I understand the Company may order a background report under my legal name and any other names I may have used.

I also authorize the following agencies and entities to disclose to ADP Screening and Selection Services and its agents all information about or concerning me, as allowed by law, including but not limited to: my past or present employers; learning institutions, including colleges and universities; law enforcement and all other federal, state and local agencies; federal, state and local courts; the military; credit bureaus; testing facilities; motor vehicle records agencies; if applicable, worker’s compensation injuries; all other private and public sector repositories of information; and any other person, organization, or agency with any information about or concerning me. The information that can be disclosed to ADP Screening and Selection Services and its agents includes, but is not limited to, information concerning my employment history, earnings history, education, credit history, motor vehicle history, criminal history, military service, professional credentials and licenses and substance abuse testing.

STATE LAW NOTICES
If you live or work for the Company in the states listed below, please note the following:

MASSACHUSETTS: If you submit a request to us in writing, you have the right to know whether the Company ordered an investigative consumer report from ADP Screening and Selection Services, which may include any or all of the following: criminal history review, driving record review, credit report review, and employment/education verifications. You may inspect and order a free copy of the report by contacting ADP Screening and Selection Services.

MINNESOTA: If you submit a request to us in writing, you have the right to get from the Company a complete and accurate disclosure of the nature and scope of the consumer report or investigative consumer report ordered, if any, from ADP Screening and Selection Services, which may include any or all of the following: criminal history review, driving record review, credit report review, and employment/education verifications.

NEW JERSEY: If you submit a request to us in writing, you have the right to know whether the Company ordered an investigative consumer report from ADP Screening and Selection Services which may include any or all of the following: criminal history review, driving record review, credit report review, and employment/education verifications. You may inspect and order a free copy of the report by contacting ADP Screening and Selection Services.

NEW YORK: If you submit a request to us in writing, you have the right to know whether the Company ordered a consumer report or an investigative consumer report from ADP Screening and Selection Services which may include any or all of the following: criminal history review, driving record review, credit report review, and employment/education verifications. You may inspect and order a free copy of
the reports by contacting ADP Screening and Selection Services. By signing below, you certify you have received a copy of Article 23A of the New York Correction Law is being provided with this form.

WASHINGTON STATE: You also have the right to ask ADP Screening and Selection Services for a written summary of your rights under the Washington Fair Credit Reporting Act.

BACKGROUND CHECK INFORMATION
The information requested below is collected solely for the purpose of aiding the Company in running a background check in connection with your application for employment. The employer is requesting that you provide this information to assist in conducting a thorough background check.

Addresses Within the Past Seven Years

Para informacion en espanol, visite www.consumerfinance.gov/learnmore o escribe a la Consumer Financial Protection Bureau, 1700 G Street N.W.,
Washington, DC 20552.

A Summary of Your Rights Under the Fair Credit Reporting Act

The federal Fair Credit Reporting Act (FCRA) promotes the accuracy, fairness, and privacy of information in the files of consumer reporting agencies. There are many types of consumer reporting agencies, including credit bureaus and specialty agencies (such as agencies that sell information about check writing histories, medical records, and rental history records). Here is a summary of your major rights under the FCRA. For more information, including information about
additional rights, go to www.consumerfinance.gov/learnmore or write to: Consumer Financial Protection Bureau, 1700 G Street N.W., Washington, DC 20552.

You must be told if information in your file has been used against you. Anyone who uses a credit report or another type of consumer report to deny your application for credit, insurance, or employment – or to take another adverse action against you – must tell you, and must give you the name, address, and phone number of the agency that provided the information.

You have the right to know what is in your file. You may request and obtain all the information about you in the files of a consumer reporting agency (your “file disclosure”). You will be required to provide proper identification, which may include your Social Security number. In many cases, the disclosure will be free. You are entitled to a free file disclosure if:

• a person has taken adverse action against you because of information in your credit report;
  
• you are the victim of identity theft and place a fraud alert in your file;
  
• your file contains inaccurate information as a result of fraud;
  
• you are on public assistance;
  
• you are unemployed but expect to apply for employment within 60 days.
  

Type of Business
1. a. Banks, savings associations, and credit unions with total
assets of over $10 billion and their affiliates.
a. Consumer Financial Protection Bureau
1700 G Street, N.W.
Washington, DC 20552

2. To the extent not included in item 1 above:
a. National banks, federal savings associations, and federal
branches and federal agencies of foreign banks

a. Office of the Comptroller of the Currency
Customer Assistance Group
1301 McKinney Street, Suite 3450
Houston, TX 77010-9050

b. State member banks, branches and agencies of foreign
banks (other than federal branches, federal agencies, and
Insured State Branches of Foreign Banks), commercial
lending companies owned or controlled by foreign banks,
and organizations operating under section 25 or 25A of the
Federal Reserve Act

b. Federal Reserve Consumer Help Center
P.O. Box 1200
Minneapolis, MN 55480

c. Nonmember Insured Banks, Insured State Branches of
Foreign Banks, and insured state savings associations

c. FDIC Consumer Response Center
1100 Walnut Street, Box # 11
Kansas City, MO 64106

d. Federal Credit Unions
National Credit Union Administration
Office of Consumer Protection (OCP)
Division of Consumer Compliance and Outreach (DCCO)
1775 Duke Street
Alexandria, VA 22314

3. Air carriers
Asst. General Counsel for Aviation Enforcement & Proceedings
Aviation Consumer Protection Division
Department of Transportation
1200 New Jersey Avenue, S.E.
Washington, DC 20590

4. Creditors Subject to the Surface Transportation Board
Office of Proceedings, Surface Transportation Board
Department of Transportation
395 E Street, S.W.
Washington, DC 20423

5. Creditors Subject to the Packers and Stockyards Act, 1921
Nearest Packers and Stockyards Administration area
supervisor

6. Small Business Investment Companies
Associate Deputy Administrator for Capital Access
United States Small Business Administration
409 Third Street, SW, 8th Floor
Washington, DC 20416

7. Brokers and Dealers
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

8. Federal Land Banks, Federal Land Bank Associations,
Federal Intermediate Credit Banks, and Production Credit
Associations
Farm Credit Administration
1501 Farm Credit Drive
McLean, VA 22102-5090

9. Retailers, Finance Companies, and All Other Creditors Not
Listed Above
FTC Regional Office for region in which the creditor operates or
Federal Trade Commission: Consumer Response Center –
FCRA
Washington, DC 20580
(877) 382-4357

CONSUMERS HAVE THE RIGHT TO OBTAIN A SECURITY FREEZE
You have a right to place a ‘security freeze’ on your credit report, which will prohibit a consumer reporting agency from releasing information in your credit report without your express authorization. The security freeze is designed to prevent credit, loans, and services from being approved in your name without your consent. However, you should be aware that using a security freeze to take control over who gets access to the personal and financial information in your credit report may delay, interfere with, or prohibit the timely approval of any subsequent request or application you make regarding a new loan, credit, mortgage, or any other account involving the extension of credit.

As an alternative to a security freeze, you have the right to place an initial or extended fraud alert on your credit file at no cost. An initial fraud alert is a 1-year alert that is placed on a consumer’s credit file. Upon seeing a fraud alert display on a consumer’s credit file, a business is required to take steps to verify the consumer’s identity before extending new credit. If you are a victim of identity theft, you are entitled to an extended fraud alert, which is a fraud alert lasting 7 years.
A security freeze does not apply to a person or entity, or its affiliates, or collection agencies acting on behalf of the person or entity, with which you have an existing account that requests information in your credit report for the purposes of reviewing or collecting the account. Reviewing the account includes activities related to account maintenance, monitoring, credit line increases, and account upgrades and enhancements.

CALIFORNIA DISCLOSURE

The Company may order an investigative consumer report on you in connection with your employment application, and if you are hired, or if you already work for the Company, may order additional such reports on you for employment purposes. Such reports may contain information about your character, general reputation, personal characteristics, and mode of living. The background check company, ADP Screening and Selection Services, will prepare the background report for the Company. ADP Screening and Selection Services is located at 301 Remington Street, Fort Collins, CO, 80524, and can be reached by phone at 800-367-5933 or at their Internet Web site address: http://www.adp.com/privacy.aspx.

A Summary of Your Rights
Under the Provisions of California Civil Code Section 1786.22

The Investigative Consumer Reporting Agencies Act (ICRA) is designed to promote accuracy, fairness, and privacy of information in the files of every "consumer reporting agency" (CRA). You can find the complete text of the ICRA, at the California Privacy Protection web site (http://www.privacy.ca.gov/icraa.htm). The ICRA gives you specific rights, as outlined below. You may have additional rights under federal law. You may contact a state or local consumer protection agency or a state attorney general to learn those rights.

(a) An investigative consumer reporting agency shall supply files and information required under Section 1786.10 during normal business hours and on reasonable notice.

(b) Files maintained on a consumer shall be made available for the consumer's visual inspection, as follows:

(1) In person, if he appears in person and furnishes proper identification. A copy of his file shall also be available to the consumer for a fee not to exceed the actual costs of duplication services provided.

(2) By certified mail, if he makes a written request, with proper identification, for copies to be sent to a specified addressee. Investigative consumer reporting agencies complying with requests for certified mailings under this section shall not be liable for disclosures to third parties caused by mishandling of mail after such mailings leave the investigative consumer reporting agencies.

(3) A summary of all information contained in files on a consumer and required to be provided by Section 1786.10 shall be provided by telephone, if the consumer has made a written request, with proper identification for telephone disclosure, and the toll charge, if any, for the telephone call is prepaid by or charged directly to the consumer.

(c) The term "proper identification" as used in subdivision (b) shall mean that information generally deemed sufficient to identify a person. Such information includes documents such as a valid driver’s license, social security account number, military identification card, and credit cards. Only if the consumer is unable to reasonably identify himself with the information described above, may an investigative consumer reporting agency require additional information concerning the consumer's employment and personal or family history in order to verify his identity.

(d) The investigative consumer reporting agency shall provide trained personnel to explain to the consumer any information furnished him pursuant to Section 1786.10.

(e) The investigative consumer reporting agency shall provide a written explanation of any coded information contained in files maintained on a consumer. This written explanation shall be distributed whenever a file is provided to a consumer for visual inspection as required under Section 1786.22.

(f) The consumer shall be permitted to be accompanied by one other person of his choosing, who shall furnish reasonable identification. An investigative consumer reporting agency may require the consumer to furnish a written statement granting permission to the consumer reporting agency to discuss the
consumer's file in such person's presence.

LICENSURE AND EMPLOYMENT OF PERSONS PREVIOUSLY
CONVICTED OF ONE OR MORE CRIMINAL OFFENSES

Section 750. Definitions.
751. Applicability.
752. Unfair discrimination against persons previously convicted of one or more criminal offenses prohibited.
753. Factors to be considered concerning a previous criminal conviction; presumption.
754. Written statement upon denial of license or employment.
755. Enforcement.
§750. Definitions. For the purposes of this article, the following terms shall have the following meanings:
(1) "Public agency" means the state or any local subdivision thereof, or any state or local department, agency, board or commission.
(2) "Private employer" means any person, company, corporation, labor organization or association which employs ten or more persons.
(3) "Direct relationship" means that the nature of criminal conduct for which the person was convicted has a direct bearing on his fitness or ability to perform one or more of the duties or responsibilities necessarily related to the license, opportunity, or job in question.
(4) "License" means any certificate, license, permit or grant of permission required by the laws of this state, its political subdivisions or instrumentalities as a condition for the lawful practice of any occupation, employment, trade, vocation, business, or profession. Provided, however, that "license" shall not, for the purposes of this article, include any license or permit to own, possess, carry, or fire any explosive, pistol, handgun, rifle, shotgun, or other firearm.
(5) "Employment" means any occupation, vocation or employment, or any form of vocational or educational training. Provided, however, that "employment" shall not, for the purposes of this article, include membership in any law enforcement agency.
§751. Applicability. The provisions of this article shall apply to any application by any person for a license or employment at any public or private employer, who has previously been convicted of one or more criminal offenses in this state or in any other jurisdiction, and to any license or employment held by any person whose conviction of one or more criminal offenses in this state or in any other jurisdiction preceded such employment or granting of a license, except where a mandatory forfeiture, disability or bar to employment is imposed by law, and has not been removed by an executive pardon, certificate of relief from disabilities or certificate of good conduct. Nothing in this article shall be construed to affect any right an employer may have with respect to an intentional misrepresentation in connection with an application for employment made by a prospective employee or previously made by a current employee.
§752. Unfair discrimination against persons previously convicted of one or more criminal offenses prohibited. No application for any license or employment, and no employment or license held by an individual, to which the provisions of this article are applicable, shall be denied or acted upon adversely by reason of the individual's having been previously convicted of one or more criminal offenses, or by
reason of a finding of lack of "good moral character" when such finding is based upon the fact that the individual has previously been convicted of one or more criminal offenses, unless:
(1) There is a direct relationship between one or more of the previous criminal offenses and the specific license or employment sought or held by the individual; or
(2) the issuance or continuation of the license or the granting or continuation of the employment would involve an unreasonable risk to property or to the safety or welfare of specific individuals or the general public.
§753. Factors to be considered concerning a previous criminal conviction; presumption.
1. In making a determination pursuant to section seven hundred fifty-two of this chapter, the public agency or private employer shall consider the following factors:
(a) The public policy of this state, as expressed in this act, to encourage the licensure and employment of persons
previously convicted of one or more criminal offenses. (b) The specific duties and responsibilities necessarily related to the
license or employment sought or held by the person. (c) The bearing, if any, the criminal offense or offenses for which the
person was previously convicted will have on his fitness or ability to perform one or more such duties or responsibilities.
(d) The time which has elapsed since the occurrence of the criminal offense or offenses.
(e) The age of the person at the time of occurrence of the criminal offense or offenses.
(f) The seriousness of the offense or offenses.
(g) Any information produced by the person, or produced on his behalf, in regard to his rehabilitation and good conduct.
(h) The legitimate interest of the public agency or private employer in protecting property, and the safety and welfare of
specific individuals or the general public.
2. In making a determination pursuant to section seven hundred fifty-two of this chapter, the public agency or private employer shall also give consideration to a certificate of relief from disabilities or a certificate of good conduct issued to the applicant, which certificate shall create a presumption of rehabilitation in regard to the offense or offenses specified therein.
§754. Written statement upon denial of license or employment. At the request of any person previously convicted of one or more criminal offenses who has been denied a license or employment, a public agency or private employer shall provide, within thirty days of a request, a
written statement setting forth the reasons for such denial.
§755. Enforcement.
1. In relation to actions by public agencies, the provisions of this article shall be enforceable by a proceeding brought pursuant to article seventy-eight of the civil practice law and rules.
2. In relation to actions by private employers, the provisions of this article shall be enforceable by the division of human rights
pursuant to the powers and procedures set forth in article fifteen of the executive law, and, concurrently, by the New York City comission on human rights.

I have read and understand the Company guidelines and policies and acknowledge that I am required to comply with them. I further acknowledge my responsibility to disclose to the Company all actual or perceived conflicts of interest which may exist while employed by the Company.

I have applied for employment with Trinity IT, LLC (the “Company”). As a condition for my application being considered, I understand and agree to undergo substance screening. I understand that if my test results are positive, I shall not be considered further by the Company for employment.

I hereby authorize the Company or any medical professional retained by the Company for screening purposes to conduct such screening and to provide such results to the Company. I release the Company and any person affiliated with the Company and any such institution or person conducting the screening from liability.