Background Check

LPGA Background Screening Program
August 7, 2008

Purpose. To foster a safe and secure environment for LPGA players, their families, and all LPGA tournament volunteers, workers and spectators. The LPGA is expanding its background screening program to encompass all persons who have inside the ropes access on a weekly basis and caddies seeking to work for LPGA Tour players. This group will include at a minimum, agents, instructors, and caddies. Beginning in 2009, the LPGA will only issue caddie credentials to those individuals with “Approved” caddie status. Such status shall be conditioned upon the successful passage of a criminal background screen. A list of approved caddies will be posted on the player extranet in a document entitled “LPGA Approved Caddies List.”

Unless otherwise indicated in paragraph 12 all players must hire an approved and credentialed person as her caddie. There are no exceptions.

2. Background Screener. National Center for Safety Initiatives (“NCSI”) shall be the authorized background screening organization that performs background screens for the LPGA. NCS1 is a full service screening organization that works with other high profile sports organizations. NCSI shall be responsible for interpreting the search results, communicating result information to the caddie applicant, and reporting all results to the LPGA. NCSI operates in accordance with the Fair Credit Reporting Act and confidentially maintains all information obtained throughout the background screen process, except where such information is requested by the LPGA.

3. Background Screen Registration. NCSI will develop a background screen authorization and disclosure form for caddie applicants, a registration web site, and an electronic payment authorization system. Information related to the background screen registration shall be available at \\ N\    C0111. Prior to the 2009 LPGA tournament season, each caddie applicant must:

I . Complete the online background screen authorization and disclosure form(s);

2. Enter personal information on the secured online web site; and

3. Submit payment online directly to NCSI (costs for US. resident background screen ($25) average cost of international background screen ($195).

4. A fax in form option will be made available for those who do not have on line access.

4. Background Screen Description. All applicants shall undergo a comprehensive background screen, including:

1 Social security number (or foreign country equivalent) and address verification;

2 Two independent national database searches;

3 Non database (county courthouse runner) searches of county criminal records of all jurisdictions of residence;

4 Sex offender registry search of all available states/countries; and

5 Federal terrorist database search.

5. Turnaround Time. The background screen result is guaranteed within ten (10) business days; provided,
however, that the caddie applicant may submit a “rush order” request to NCSI for an additional fee.

6. Findings. Based on the criteria stated in Sections 7 and 8 below, NCSI shall issue results on a “Red Light/Green Light” basis. A “Green Light” finding indicates that a caddie applicant passed the background screen, and is eligible for listing on the LPGA Approved Caddie List. A “Red Light” finding means that, upon initial    review, information obtained about the caddie applicant does not satisfy the LPGA’s screening criteria.
Prior to issuing a Red Light result, NCSI will contact the caddie applicant and provide him/her with an opportunity to seek an appeal of the record with NCSI, pursuant to the Fair Credit Reporting Act. During such appeal, the caddie applicant may correct potential errors in the caddie applicant’s record or provide additional
relevant information related to the screening results. Following the appeal process, NCSI shall issue its final result    to both the caddie applicant and the LPGA  Thereafter, as a last resort, the caddie applicant may appeal a Red Light finding to the LPGA.

7. Red Light Criteria. A conviction (or the entry of any plea of guilty or no contest) or disclosure from a caddie applicant that contains the following information will trigger a Red Light designation:

1 . Any felony (crime punishable by confinement of greater than one year);

2. Any lesser crime involving force or threat of force against a person;

3. Any lesser crime in which sexual relations is an element, including “victimless” crimes of a sexual nature (including pornography);

4. Any lesser crime involving controlled substances (not paraphernalia or alcohol);

5. Any lesser crime involving cruelty to animals; or

6. Any sex offender registrant.

8. Further Investigation of Non Red Light Offenses. As part of NCSI’s comprehensive approach, the following information will result in further investigation involving the caddie applicant and/or the appropriate courts and/or relevant third party sources:

1. An arrest under Section 7 with no disposition noted;

2. An expunction, restoration of rights, or pardon relating to an offense under Section 7;

3. Any charge involving a minor resulting in a disposition favorable to the caddie applicant; or

4. An arrest Or conviction where it is not readily apparent if drugs or alcohol were involved.

9. Appeal of Last Resort. Upon request, the caddie applicant may appeal a Red Light finding before the
LPGA background investigation review panel (“Panel”). Such request shall be made in writing and be deemed to have been duly given and effective: (i) on the date of delivery, if delivered personally to the LPGA Senior Vice President and Chief Operations Officer; (ii) upon receipt if sent by an overnight delivery service or
certified mail (return receipt requested) to 100 Intentional Golf Drive, Daytona Beach, FL 3 2124, ATTN: LPGA Senior Vice President and Chief Operations Officer; or (iii) upon confirmation of receipt, if sent by electronic mail to the LPGA Senior Vice President and Chief Operations Officer (Chris.Higgs@lpga.com). Any such appeal shall state specifically the nature of the appeal and shall include all supporting documents and/or explanations related to any convictions or arrests. Within forty eight (48) hours after receipt of such written request, the Panel shall convene, review the caddie applicant’s appeal, and deliver a final decision; provided, that,    all relevant documentation has been received by the Panel. Such final decision shall be either delivered personally to the caddie applicant, or sent to the caddie applicant via e mail or certified mail within seventy two (72) hours of the LPGA’s receipt of such appeal request.

The Panel shall consist of three members, selected from a pool of seven (7) persons represented by LPGA senior staff and/or security personnel. The pool shall consist of the LPGA Deputy Commissioner, Senior Vice President and Chief Operations Officer, LPGA General Counsel, the LPGA security team president, and tournament site senior staff (if applicable and where necessary), or their respective designees. The members of the pool shall be approved in advance by the LPGA Player Executive Committee. The Panel shall be fair, impartial and free of any conflicts of interest with respect to the parties involved. If a caddie applicant alleges that a Panel member has a conflict of interest, the Panel shall request additional information, as necessary, in order to render a decision on whether or not a conflict exists. If the Panel determines a conflict actually exists or could be imputed to a Panel member, such Panel member shall immediately recuse herself or himself from appointment and appoint a designee.

At its sole discretion, the Panel may examine written documents submitted by the caddie applicant and/or documents related to the background screen findings conducted by NCSI and/or hear an oral explanation (time limit restricted to five (5) minutes) and/or hear a maximum of two (2) character witnesses. The Panel shall make a final decision on a case by case basis, utilizing the following criteria:

1. Nature/seriousness of the crime;

2. Whether the caddie applicant is likely to have committed the report conduct;

3. The nexus between reported criminal conduct and caddie duties;

4. Number of reported arrests/convictions and the surrounding circumstances;

5. The date and age of the caddie applicant at the time of arrest/conviction;

6. Mitigating or aggravating factors;

7. Rehabilitation record, if any; and

8. An assessment of the potential risk that the caddie applicant may pose to persons in the LPGA tournament environment.

9. International Tournaments. For each LPGA co,,sanctioned international tournament, the tournament organizer will aspire to perform background screens on available local caddies and or provide character references on their behalf The criteria used for the background screen should be the same as or similar to that utilized by NCSI. If available, LPGA players that do not have a caddie at international tournaments may select from a pre-approved list of local caddies.

11. Timeline For Completion of Background Screens – 2009 Season. In order to receive results and pursue any related appeals prior to the start of the 2009 LPGA season, caddie applicants are encouraged to submit their application to NCSI online by November 1, 2008.

12. Exemptions from screening. All persons wishing to be issued a LPGA “Inside the Ropes” will be required to complete background screening including all spouses and family members. Temporary exceptions will be made in the instance that a player’s caddy is absent, injured, dismissed or not able to perform, his or her duties on a given day. A player may substitute her caddy with a temporary caddy for the remainder of that tournament but she must engage a properly credentialed caddy for the next tournament that she plays. Persons who caddy in the pro-am for amateurs are not required to be screened. Persons under the age of 15 are not required to be screened.

13. Local Caddies for Domestic Events. Persons wishing to be hired as a local caddie at a LPGA tournament will be required to complete background screening. The tournament caddie committee should provide all potential local caddies with the relevant information at least two or three weeks prior to the tournament so that these persons will have sufficient time to be screened in advance of the tournament. They will pay the same fee as regular LPGA caddies. Local caddies who have been screened and approved are permitted to be in the local caddie pool available to players. If they fail to be approved they will not be permitted to caddie.

14. Length of Credential Status and “Approved Caddies”. An applicant who receives Green Light status will receive Approved Caddie status for a three (3) year term, and the LPGA shall post the caddie’s name on the LPGA player extranet. Caddies will be required to re-apply for Approved Caddie status on a three (3) year term basis

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