Internships Policy

Each year in the spring and fall, the Company seeks interns from two local universities and one trade school for various paid and non-paid positions. Human Resources will communicate with University advisors to post openings within the range of the intern’s skill set.

Before any position is classified as non-paid, Human Resources must confirm the internship satisfies the U.S. Department of Labor's current seven-factor "primary beneficiary" test (DOL Fact Sheet #71), which looks at the economic reality of the relationship, including whether there is a clear understanding that no compensation is expected, whether the internship is tied to the intern's formal education, and whether the intern, not the Company, is the primary beneficiary of the arrangement. If these factors are not met, the intern must be classified as an employee and paid at least minimum wage and applicable overtime.

Interns are guests who are interested in obtaining work experience and are not intended to be “lunch wranglers” or serve as a dumping ground for miscellaneous non-essential duties. If any department manager is interested in designing a new position or in filling a current position with an intern, please contact Human Resources with the particulars.

General information, not legal advice. Treat this as a drafting starting point, not a finished policy — employment law varies by jurisdiction and changes often, so have a licensed attorney tailor it to your situation before you rely on it.

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