Recruitment of Ex-Offenders Policy
This policy outlines Lloyds Wealth Management Limited approach to the recruitment of individuals with criminal records. It applies across all UK jurisdictions, including England, Wales, Scotland, and Northern Ireland, and is designed to ensure compliance with relevant legislation and promote fair and inclusive recruitment practices.
We comply with the Rehabilitation of Offenders Act 1974 (as amended) and the Rehabilitation of Offenders (Northern Ireland) Order 1978. We also adhere to the Exceptions Orders applicable in each jurisdiction, which outline roles where spent convictions must be disclosed. Where criminal record checks are required, we follow the relevant Code of Practice issued by the Disclosure and Barring Service (DBS) or AccessNI.
This policy is made available to all applicants at the outset of the recruitment process.
We are committed to equality of opportunity and to providing a recruitment process free from unfair discrimination. No applicant or employee will be treated less favourably on the grounds of gender, race, age, disability, sexual orientation, political opinion, or offending background, unless it is demonstrably relevant to the role.
As a regulated organisation, we ask all applicants to disclose any criminal convictions or cautions. This requirement reflects the nature of our work and the legal and regulatory obligations associated with our roles. All information disclosed during the recruitment process, including criminal record details, will be treated with the utmost confidentiality and will only be shared with those directly involved in the recruitment decision-making process.
All candidates with a conditional offer will be subject to criminal record checks. The majority of roles will be subject to a Basic level check, revealing any unspent convictions. We will only request a Standard or Enhanced check where it is proportionate and legally justified (for example a Senior Management Function as per the FCA definition) based on a risk assessment of the role. Standard and Enhanced checks include both spent and unspent convictions, cautions, reprimands, and final warnings.
In line with the Rehabilitation of Offenders (Exceptions) (Northern Ireland) Order 1979 (as amended), we will only consider convictions that are not protected under current filtering rules.
Where a disclosure is made, we will conduct a fair and confidential risk assessment, considering:
- The relevance of the offence to the role
- The time elapsed since the offence
- The circumstances and evidence of rehabilitation
Failure to disclose relevant information may result in withdrawal of a conditional offer.
All recruitment staff are trained in fair recruitment practices, including how to assess and handle disclosure information appropriately and in line with the Rehabilitation of Offenders (NI) Order 1978. If applicants require assistance in understanding the implications of their criminal record and how it may affect their application, we encourage them to contact the hiring manager for the role.
We adhere to the Access NÍ Code of Practice which candidates can view on this webpage.
We keep this policy under regular review and will reflect any updates within this page. This was last updated in May 2026.