07/10/2002

3. Steps of what to do when the investigator arrives and begins their investigation or inspection.

When the Wage and Hour officer calls:

a.) Give them a suitable and comfortable place to work. There are many borderline questions that may arise. There is no point in creating any animosity because of discourtesies. In fact, it is advantageous to have records in such orderly condition that it will not be necessary for them to interview many of your employees.

b.) Select a competent person to help them get together the records they need.

c.) Don't be over-friendly. Investigators have strict instructions not to accept free lunches, cigars, etc. Expect them to be an honest and honorable person the same as you want them to feel that you are above cheap chicanery.

d.) Don't try to tell your employees what to say. It won't work. In the first place, it isn't fair to put your employees in that type of an embarrassing position. Your employee is not in the habit of making false or misleading statements and he certainly doesn't intend to do so when checked by an investigator.

e.) Don't hold back confidential information or records. If you are concerned about your method of computing time and a half because of an incentive plan, bonus, etc., check it in advance and don't wait until the Wage-Hour officer gets into your office.

f.) Before the investigator leaves, find out where you stand. Ask them frankly, upon what points they feel you might be on the borderline of a violation. Get all the information you can and then set up your system so that whether you are there or not, the system will carry through. Get the system correct...then see to it that it is followed.