PSSI recently 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

We are 100 percent committed to doing everything we can to enforce our absolute prohibition against employing anyone under the age of 18. This includes the following recent steps (among others) since the DOL inquiry to bolster our already extensive procedures.

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.

4. PSSI is launching a charitable fund with an initial $10 million commitment dedicated to enhancing the well-being of children in the communities we serve and helping reduce the prevalence of the rising problem of unauthorized underage workers amid record levels of unaccompanied minors entering the United States

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 will require an acknowledgment of receipt and will be incorporated into the onboarding process for all managers and supervisors on a going-forward basis.

9. PSSI is launching 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. During the training, PSSI is recommunicating information to all team members on how they can anonymously report any concerns, including age-related concerns, to a toll-free hotline.

10. PSSI has 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. 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.

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