PSSI’s ZERO TOLERANCE POLICY AGAINST EMPLOYING ANYONE UNDER THE AGE OF 18

Oct 18, 2023

PSSI continues to uphold its zero-tolerance policy against employing anyone under the age of 18.

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PSSI’s ZERO TOLERANCE POLICY AGAINST EMPLOYING ANYONE UNDER THE AGE OF 18

It’s been one year since a U.S. Department of Labor (DOL) inquiry began regarding allegations that some of PSSI’s locations employed underage workers. During and after the subsequent DOL settlement, PSSI continues to uphold its zero-tolerance policy against employing anyone under the age of 18.

On this 18th Day of October, PSSI would like to take this opportunity to reshare its remediation plan – which has grown to 18 points meant to enhance our safety and compliance efforts. Our latest steps include the recent announcement of the company’s first Chief Compliance Officer Diego Alvarez, as well as a company-wide employee pledge against child labor. We continue to honor the PSSI’s guiding principles of compliant, safe, clean and on-time.

  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 hired a new world-class CEO, Tim Mulhere, to continue driving these remediation steps forward. Furthermore, Tim emphasizes compliance as a chief tenet of PSSI’s corporate culture, joining safety amongst its workforce and nation’s food supply; as well as cleanliness and timeliness to its customer service.
  4. PSSI launched 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 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 provides 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. It includes never allowing anyone under 18 to enter or work in a PSSI-serviced facility; actively looking for anyone who might be underage and reporting all concerns promptly to the We Care hotline (844-880-0009); taking appropriate action to warn others; and teaching team members of the company’s prohibition of PSSI’s no-minors policy.

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