PSSI ENHANCES COMPLIANCE ACTIONS AGAINST UNDERAGE LABOR
PSSI REMEDIATION STEPS TO ENFORCE ZERO TOLERANCE POLICY AGAINST EMPLOYING ANYONE UNDER AGE 18
PSSI resolved a U.S. Department of Labor (DOL) inquiry which emerged in October 2022 regarding allegations that some of its locations employed underage workers. We have been crystal clear from the start: PSSI has a zero-tolerance policy against employing anyone under the age of 18, and fully shares the DOL’s objective of ensuring full compliance at all locations.
For nearly two decades, we have run every single new hire through the Federal Government’s own recommended E-Verify system to confirm their employment authorization – alongside DHS IMAGE best practices and a $10 million investment in biometric identity verification – so the only way these procedures could be circumvented is through deliberate identity theft or fraud at a local plant. Regardless of the reason they occurred, however, it is our responsibility to address the problem
1. PSSI retained one of the most highly decorated former officers in the history of U.S. Customs and Border Patrol, to provide additional identity theft training to PSSI’s Compliance and Human Resources team on how to detect and identify fraudulent documents to minimize the risk of identity theft circumventing its compliance program.
2. PSSI conducted extensive additional internal reviews of its workforce to help ensure that no one under the age of 18 is working for the company today.
3. PSSI has hired a new world-class CEO, Ecolab’s Tim Mulhere, as it continues driving these remediation steps moving forward.
5. As part of the DOL settlement, PSSI engaged an independent third-party consultant – who is a 26-year DOL veteran and former District-head responsible for enforcing child labor and wage/hour laws – to conduct monthly, unannounced Facility visits, at facilities chosen by the consultant, to monitor PSSI’s ongoing compliance with the child labor laws.
6. PSSI’s Board engaged an independent third-party law firm, ArentFox Schiff, to review and make recommendations to bolster PSSI’s compliance policies and procedures.
7. PSSI hired an external compliance consultant to help strengthen its compliance department, and to assist the Company in hiring substantial additional new compliance personnel.
8. PSSI conducted company-wide training for all managers on its prohibition of minor employment and has made clear that managers or supervisors who hire, or who are aware of instances of minor employment but do not take immediate action, will be terminated on a zero-tolerance basis. The training required an acknowledgment of receipt and will be incorporated into the onboarding process for all managers and supervisors on a going-forward basis.
9. PSSI launched its “See Something, Say Something” campaign with its hourly workforce, outlining the Company’s absolute prohibition against child labor, and the team members’ duty to speak up if they see anything suspicious relating to a team member’s age warranting further investigation. PSSI recommunicated information to all team members on how they can anonymously report any concerns, including age-related concerns, to a toll-free hotline.
10. PSSI sent communications to school districts in every single community we serve asking that they contact us immediately if they know or have reason to believe that one of their students is working for PSSI so we can swiftly remove them from employment. We firmly believe that anyone under the age of 18 should be in school and not in work in environments such as ours.
11. PSSI reiterated its policy to conduct ongoing age verification audits at 100% of its worksites, utilizing both on-site management’s face-to-face visual inspection, and PSSI’s Corporate Compliance team’s review of biometric photos.
12. PSSI is enhancing Standard Operating Procedures (SOP’s) and workflows to assist the on-the-ground team with identity verification and investigations.
13. To further our commitment to our zero-tolerance policy against employing anyone under the age of 18, a “No Minors” poster has been created and posted in every plant we serve.
14. PSSI is undertaking a review to identify additional technologies it can leverage as part of its background screening of new hires prior to their first day in the facilities they serve.
15. PSSI has implemented a new Anti-Human Trafficking policy and required training for all team members leveraging the government’s Blue Campaign which is a national public awareness campaign designed to educate on the indicators of human trafficking and how to appropriately respond to possible cases. Posters and handouts were also created and shared out to all locations we serve.
16. PSSI introduced a required training for all hiring managers called “Child Labor in Sanitation and Meat Processing Industry.” This training will provide information around Child Labor and the Fair Labor Standard Act (FSLA); Information and Understanding of PSSI’s Zero tolerance policy as well as Hazardous Occupations within the Sanitation and Meat Processing Industry.
17. PSSI hired an experienced Chief Compliance Officer, Diego Alvarez, to strengthen our culture and drive our commitment to compliance.
18. Helping enforce the Company’s prohibition of the employment of minors, PSSI launched its “No Minors Pledge” for its team members.
19. We have established our first Code of Conduct and Ethics, which outlines the principles driving our business practices and provides a framework for ethical decision-making. It aligns with our mission, vision, and commitment to doing the right thing, serving as a key resource for navigating ethical considerations in all aspects of our work.
20. To reinforce our commitment to prohibiting the employment of minors, each PSSI sanitation plant has received and signed a banner stating “18+ DOING THE RIGHT THING: No Underage Workers Allowed at PSSI.” This banner activity also encourages team members to speak up they have concerns.
