Due Diligence and Ongoing Monitoring

 View Only

  • 1.  Janitorial Vendors

    This message was posted by a user wishing to remain anonymous
    Posted 12-04-2024 09:05 AM
    This message was posted by a user wishing to remain anonymous

    What practice do most use for vendors performing janitorial services for a bank? Cleaning is performed after business hours so as not to interfere with business operations. Some of our services are in-house and have the standard background checks etc. performed but most of our locations are contracted.

    This raises questions that if a bank employee leaves documents out overnight - could the vendor view them and steal identity, vault not properly secured - could money be stolen? 

    So to counter any of the security lapses above:

    Is a background check required for each employee of the vendor who has access (background check performed by the bank or the vendor)?

    Does the vendor and their employees sign an NDA?

    Is alarm training required?



  • 2.  RE: Janitorial Vendors

    Posted 12-04-2024 09:18 AM

    This came up in an audit for us several years ago.   

     

    We require a background check from the vendor on the employee.   We also require updates on their background checks as well.  If anything changes such as arrests then we are to be notified immediately and the person is not allowed back on the premises.   

     

    We also require that the vendor has a signed NDA on file and their employees also sign an NDA their first day onsite.

     

    I do believe there is alarm training as well as I know they clean after hours when staff is not available.

     

    Thanks,

    This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute as attorney work product. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, notify us immediately by telephone and (i) destroy this message if a facsimile or (ii) delete this message immediately if this is an electronic communication. Thank you.




    Original Message


  • 3.  RE: Janitorial Vendors

    Posted 12-04-2024 10:07 AM

    This is a good question. We obtain a Certificate of Insurance and W9. My trainer also said we should do the following:

     

    You should also do a background check on the company principals of the Janitorial services unless it's a national company. You need to be sure that all employees are legal and are receiving proper wages.

     

    Unfortunately, I haven't found out how to do one of these background checks. I asked on this group awhile back, and didn't get any responses. Maybe someone in the group now knows? I actually have a new janitor to vet and would love if anyone knows.

     

    Thanks so much!

     

    Cheryl Turner

    Farmers Insurance FCU

     

     

     




    Original Message


  • 4.  RE: Janitorial Vendors

    This message was posted by a user wishing to remain anonymous
    Posted 12-04-2024 10:48 AM
    This message was posted by a user wishing to remain anonymous

    To ensure that the janitorial services you hire are operating ethically and legally, including verifying the background of the company principals and the status of their employees, you can follow these steps:

    1. Research the Company

    • Company Name and Address: Start by finding the official name, address, and contact information of the company. This can often be found on their website or in business directories.
    • Check for National or Local Operations: If the company is a national service provider, it might be more regulated, and background checks on principals may not be necessary if they are part of a well-established network. However, for local or smaller operations, a more detailed investigation is needed.
    • Business Registration: Ensure the company is properly registered. In the U.S., you can check with the Secretary of State's office in the state where the business is based to verify its legal status and if it is in good standing.

    2. Background Check on Company Principals

    • Search for Public Records: Check the company principals through online databases or public records. Sites like LinkedIn, and sometimes the company's own site, can provide information on the leadership team. You can also use business background check services such as:
      • PACER (Public Access to Court Electronic Records): A service for accessing federal legal records.
      • LexisNexis: Offers detailed reports on individuals and businesses.
      • State Business Lookup: States often have public records databases where you can search for business owners and any legal or financial issues associated with them.
    • Credit Report/Financial Check: Some services offer business credit checks that can give you insights into the financial stability of the company and any red flags regarding its management or financial practices.
    • Research Past Violations: Check for any previous violations, lawsuits, or complaints. Websites like the Better Business Bureau (BBB) or Yelp can help determine if there are any customer complaints.

    3. Verify Employment Practices

    • Employee Background Checks: Confirm that the company performs background checks on its employees. Reputable janitorial services should ensure all employees have legal work authorization and clean criminal backgrounds (especially given that many janitors work in sensitive areas like offices, healthcare, and schools).
      • E-Verify: Ensure that the company uses E-Verify, a government system to confirm that their workers are legally authorized to work in the U.S. If the company does not mention E-Verify or any similar programs, ask them directly about their employee screening process.
    • Wage Verification: Check if the company is adhering to local labor laws regarding wages. Inquire about the compensation and benefits their workers receive.
      • Fair Labor Standards Act (FLSA): You can verify if the company follows the U.S. Department of Labor's standards for minimum wage, overtime, and other worker protections.
      • State Labor Departments: Contact the state labor department to ensure the company complies with wage laws and regulations in the state where they operate.

    4. Assess the Company's Reputation

    • Online Reviews: Research online reviews about the company on platforms like Google, Yelp, and Trustpilot to gauge customer satisfaction.
    • References: Ask the janitorial service for references from previous or current clients. This will give you insight into their reliability and professionalism.
    • Compliance Certifications: Verify whether the company holds any certifications related to employment law or the cleaning industry, such as certifications for labor compliance or environmental standards.

    5. Ask Specific Questions

    • Legal Employment Status: Ask them directly how they ensure all their employees are legal to work and how they handle wage and benefits compliance.
    • Training and Benefits: Inquire about employee training programs, including safety and legal requirements (e.g., OSHA training) and the benefits offered to staff.
    • Insurance: Confirm that the company carries necessary insurance (e.g., workers' compensation) for its employees. This protects you in case of accidents or claims involving their workers.

    6. Audit Practices Regularly

    • If you are hiring a local company for a long-term contract, consider implementing regular audits or checking in on employment practices, including verifying employee status and wages periodically.

    By following these steps, you can ensure that the janitorial service you hire operates legally and ethically, protecting both your business and their employees.


    Original Message