CORI Policy

1. Purpose

This policy describes how Blooming Brands Inc. ("the Company") requests, uses, stores, and disposes of Criminal Offender Record Information ("CORI") when making employment-related decisions. It is intended to ensure that the Company screens applicants fairly and in a manner consistent with the City of Boston's CORI-related standards under City of Boston Code, Chapter 4, Section 7 ("CORI Screening by Vendors of the City of Boston"), the Massachusetts CORI law (M.G.L. c. 6, §§ 167–178), and the regulations of the Massachusetts Department of Criminal Justice Information Services ("DCJIS") at 803 CMR 2.00.

2. Scope

This policy applies to all applicants, meaning any current or prospective employee, independent contractor, intern, or volunteer of the Company, and to every person at the Company who requests, receives, or reviews CORI.

3. When the Company Requests CORI

The Company does not conduct a CORI check on an applicant unless a CORI check is required by law, or the Company has made a good-faith determination that the position is of such sensitivity that a CORI report is warranted. Positions that may warrant a CORI check include roles that involve work on or around school buses or other vehicles serving children, access to student-occupied areas, access to law-enforcement evidence or personal data, or access to client systems and facilities.

4. Applicant Must Be Otherwise Qualified First

The Company reviews each applicant's qualifications and determines that the applicant is otherwise qualified for the position before conducting a CORI check. The Company does not conduct a CORI check on an applicant who is not otherwise qualified for the position.

Consistent with Massachusetts law, the Company does not ask about criminal history on its initial written application form.

5. How CORI Is Obtained

• CORI is requested only through channels authorized by DCJIS (including iCORI) and only at the level of access the Company is authorized to receive.
• Before requesting CORI, the Company obtains a signed CORI Acknowledgement Form from the applicant and verifies the applicant's identity with a government-issued photo ID.
• Only individuals authorized by the Company may request, receive, or review CORI.

6. Information the Company Is Not Authorized to Receive

If the Company is authorized to receive CORI reports consisting solely of conviction and case-pending information, and a report received by the Company contains other information (for example, cases disposed of favorably for the applicant, such as not guilty or dismissed), the Company will inform the applicant and provide the applicant with a copy of that information so the applicant may pursue correction.

7. Before Any Adverse Decision

When the Company receives a proper CORI report and is inclined to refuse, rescind, or revoke an offer of a position based in whole or in part on that report, the Company will, before making a final decision:

• notify the applicant of the potential adverse decision;
• provide the applicant with a copy of the CORI report received by the Company;
• inform the applicant of the specific parts of the CORI report that concern the Company;
• provide the applicant an opportunity to discuss the report with the Company, including an opportunity to present information rebutting the accuracy and/or relevance of the report;
• provide the applicant with a copy of this policy and information on how to correct a CORI record through DCJIS;
• review any information and documentation received from the applicant; and
• document all steps taken.

8. Final Decisions

The Company makes final employment-related decisions based on all of the information available to it, including the seriousness of the offense(s), the relevance of the offense(s) to the position, the number of offense(s), the age of the offense(s), and the occurrences in the life of the applicant since the offense(s).

If the final decision is adverse to the applicant and results in the refusal, rescission, or revocation of a position, the Company promptly notifies the applicant in writing of the decision and the specific reason(s) for it.

9. Confidentiality, Storage, and Disposal

• CORI is confidential. It is shared only with individuals who have a legitimate need to know, and is never disseminated except as permitted by law. Any permitted secondary dissemination is recorded in a dissemination log.
• Paper CORI is kept in a locked, separate file; electronic CORI is kept encrypted with access limited to authorized individuals.
• CORI is retained no longer than required by law and is destroyed securely (shredding or secure deletion) when no longer needed.

10. Records

The Company keeps a record of each CORI check: date, position, the authorized requester, the decision, and copies of all notices given to the applicant. These records are available to the City of Boston and other contracting agencies on request, as required by contract.

11. Non-Discrimination

The Company does not discriminate against any applicant or employee on the basis of sex, race, color, sexual orientation, gender identity or expression, marital status, parental status, ex-offender status, prior psychiatric treatment, military status, religious creed, disability, national origin, ancestry, source of income, or age, except where based on a legally permissible and bona fide occupational qualification.

12. Questions and Concerns

Applicants may direct questions about this policy, or request a copy of it, by emailing [email protected]. Concerns about the CORI practices of City of Boston vendors may also be reported to the City of Boston Office of Civil Rights.

13. Review and Approval

This policy is reviewed at least annually and whenever applicable law or City of Boston standards change.

Adopted November 7, 2026 by Mohamed Hafez, Founder, Blooming Brands Inc.