To our valued employees and fellow community members:
While our work is often behind the scenes, our values are always front and center: We speak with candor, act in good faith, and are committed to continuous improvement.
You may have read that PSSI recently resolved a U.S. Department of Labor (DOL) inquiry which emerged in October 2022 regarding allegations that some of its locations employed minors. 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.
These violations were entirely contrary to our values, shocking to our company, and completely unacceptable. 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 – among multiple other compliance measures – 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 fix the problem.
While this DOL matter has ended and we have conducted an extensive internal review of our workforce to help ensure that no minors are working for the company today, PSSI will do everything we can going forward continue to further strengthen and enhance our hiring procedures. As parents ourselves and members of our local communities, we do not ever want to see anyone under 18 years of age working for our company. Period.
To that end, we have been taking several measures to bolster our compliance program. We’ve engaged a former high-ranking DOL official to conduct monthly inspections to track compliance. We’ve also retained one of the U.S. Customs and Border Patrol’s most highly decorated former officers to provide additional identity theft training to PSSI’s Compliance and Human Resources teams. Additionally, we’re strengthening our Standard Operating Procedures and workflows to assist our on-the-ground teams with identity verification and investigations.
But that’s just the start: Because we’re committed to continuous improvement at every level, we’re deploying a host of other measures as part of our background screening of new hires before their first day in the facilities that we serve.
We’re conducting company-wide training with our managers and supervisors to reiterate our zero-tolerance policy on the employment of minors. We are also doubling down on our policy to conduct age verification audits at 100% of our worksites, utilizing both on-site management’s face-to-face visual inspection and reviewing biometric photos to identify any potential violations for further investigation.
Another critical initiative is our “See Something, Say Something” campaign and associated training. This program underscores PSSI’s zero-tolerance policy for violating our company-wide prohibition against the employment of anyone under 18. We strongly encourage our team members to speak up if they see anything suspicious that warrants further investigation – without any fear of repercussions. As an organization, we want to promptly know about potential issues at the local level so we can swiftly correct them. All team members can safely and anonymously report any concerns, including age-related ones, to a toll-free hotline.
We also know America’s previously under-recognized child labor crisis has broader root causes. While those are beyond the power of any one company to address, we also want to contribute to helping combat those issues in our local communities.
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. This fund will identify and provide aid for direct community services in legal aid, education, poverty reduction, and health services – the lack of access to which contribute to families seeking unauthorized employment for minors – and support national efforts to help address this issue.
PSSI is committed to working with government agencies, outside experts, local communities, other companies, and other stakeholders to help address this problem holistically – since we recognize no one business will be able to solve it alone given the broad-based nature of this emerging challenge. As part of that, we are committed to sharing the difficult lessons our company has learned and remedial measures we have taken.
We may not have all the answers. But we’ll do our best to speak candidly, act in good faith, and follow our values. It’s what you deserve and what we always have and will consistently seek to deliver.