Subsequent to our post of April 6, the California DLSE issued a lengthy new opinion letter regarding trainees, available here. We routinely assist our clients with incorporation, forming a California corporation, forming a Is there a specific penalty assessed against employers with invalid internship programs? Consequently, for-profit employers who intend on using "unpaid interns" should carefully evaluate their business model to ensure that a bona fide intern relationship exists. And while this arrangement may sound great for employers, it is in fact fraught with potential problems and vulnerabilities. 938 34 The work must be primarily for the benefit of the trainees, rather than the employer. Civil Code 3513. 0000004225 00000 n To count as a legitimate internship, must an intern receive school credit for their work? Express Written Permission of Melissa C. Marsh. If you are an employee who was paid on a piece rate basis during the period of July 1, 2012 through December 31, 2015, the Labor Commissioners office may have collected wages for you from your employer for rest and recovery periods and other nonproductive time. As students and recent graduates struggle to market themselves to employers, many are increasingly willing to work for free, in order to get a foot in the door. California's Division of Labor Standards Enforcement (DLSE) has its own set of rules surrounding the legality of unpaid internships. These updated guidelines detail seven factors to look for, and they are as follows: In California, the state has a set of standards similar to those set by the Federal Department of Labor. The California unpaid internship will only get approval if it satisfies the state requirements, including: The internship must occur as part of an educational program, which necessitates the involvement of a college or similar establishment. BUT for an unpaid internship to be legitimate, the intern (not the employer) must be the "primary beneficiary" of the arrangement. These workers, called trainees, may be in any field or profession, not just medicine. Employers likely cannot enter into valid trainee relationships with people who either are not presently in school, or who are not enrolled in classes and/or programs that are unrelated to their training work. California Laws and Unpaid Internships In California, the state has a set of standards similar to those set by the Federal Department of Labor. In valid trainee arrangements, employers will not be required to pay minimum wages and/or overtime because the trainees will not be considered to be employees, hence minimum wage and overtime rules will not apply. The training must be: The first criterion, similarity to vocational training, appears problematic, because many internships may bear little resemblance to vocational school. What Happens if an Internship Program Does Not Meet State or Federal Requirements? Additional details will be provided in the coming weeks. Labor Commissioners Wage Theft Lawsuits against Uber & Lyft, COVID-19 Remote and In-Person Office Operations. Studies show that unpaid internships often do not result in full time employment offers. Its easy to see why internships give students and other young adults a way to obtain real-time, hands-on experience in fields they hope to pursue. The minimum wage is an obligation of the employer and cannot be waived by any agreement. Unpaid Internships in California have seen a steady increase over the years. 0000004004 00000 n (In Wallings example, trainees learned the operation of machinery in a railyard). The employer cannot derive any immediate advantage from the work of the trainees (in fact, employers operations should to some extent be impeded by the trainees presence). 0000005080 00000 n What is less clear is what counts as a legitimate internship. 0000000976 00000 n Most unpaid or low-paid California workers who are still in school are technically trainees, not interns. In the Glatt example above, the interns were found to be displacing existing employees, as tasks such as making coffee and ordering catering were traditionally provided by paid assistants. 0000006726 00000 n They cannot simply label a particular low-level or menial job an "internship," and thereby get the work done for free, instead of hiring an employee to perform that function. Apart from illegal unpaid internships, there are a number of other ways that unscrupulous employers violate state and federal employment laws, including: overtime violations, wrongful termination, minimum wage violations, workplace safety, workers compensation, discrimination, sexual harassment, and more. Reach out today for a free confidential consultation. Due to the easing of government-imposed COVID-19 restrictions, the biennial "in-person" sexual violence and harassment prevention training that janitorial employers must provide to their non-supervisory employees, may now be conducted in a manner that protects the health, safety and welfare of all participants. The Firm does not intend to represent anyone desiring representation in a state where this Web site fails to comply with all laws and ethical rules of that state. Prior to attending law school, Mr. Tripp was a complex commercial litigation paralegal at a large national law firm in Los Angeles, California. If you would like to avoid this nightmare scenario, you should speak to a business attorney in San Diego before taking on an unpaid intern. California Minimum Wage Effective January 1, 2023 $15.50 per hour for workers at businesses with 26 or more employees. The extent to which the internships duration is limited to the period in which the internship provides the intern with beneficial learning. Q~~KQR].H bjb 5JF2N[Ff[38zwmjh. Those criteria are: Generally, the more a trainee job resembles a traditional job, the less likely it will be upheld as a valid education-in-lieu-of-pay arrangement. The DLSE generally disapproves of unpaid training arrangements and will invalidate those arrangements where it is either doubtful or unclear whether all of the above-noted criteria have been met. 0000009140 00000 n as a summer associate. But, rather than looking at such informal expectations, the DLSE found this criterion was met because the agreements signed by the interns made it clear that they had no entitlement to a job at the conclusion of the program. By combating wage theft, protecting workers from retaliation, and educating the public, we put earned wages into workers' pockets and help level the playing field for law-abiding employers. If you are an employer or individual with questions about whether a current or proposed internship is appropriate, an experienced employment law attorney at Coast Employment Law can help you navigate this complex space. Before your company takes on an unpaid intern, you would be well-advised to consult with a California employment compliance attorney to make sure that everything is handled correctly. Interns are no longer prohibited from occasionally and incidentally performing work done by other employees. Similarly, with respect to the sixth criterion, the DLSE examined the formal agreements signed by program participants. In the recent DLSE opinion letter, the internship program at issue involved a program wherein all interns were simultaneously enrolled in a local community college, where they were earning up to 14 college credits. 0000002434 00000 n Review requirements before the first employee starts work (. Requesting Letter. Interns and students, however, may not be "employees" under the FLSAin which case the FLSA does not require compensation for their work. But for others, internships especially unpaid ones, can lead students to wonder whether theyre getting an experience worth their time. If the intern primarily benefits from the relationship, the internship can be unpaid. Since joining Jackson Lewis P.C. trust, power of attorney, health care directive, and more. 0000014576 00000 n For an unpaid internship to be lawful under federal law, the following six criteria must be met: In addition to federal law, California has its own set of labor laws, which are overseen by the California Division of Labor Standards Enforcement (DLSE). Noel Tripp is a Principal in the Long Island office of Jackson Lewis P.C., one of the largest law firms in the United States devoted exclusively to representing management in labor and employment matters. Money-whiners and over-qualified individuals need not apply.. <]/Prev 911002>> His principle focus is the defense of class and collective action lawsuits under federal and state wage-and-hour laws. Speak With A Trusted Employment Law Attorney, Speak With A Trusted Employment Law Attorney. To increase the chances that trainee jobs will be upheld, employers should make sure that the jobs consist mainly of substantive training work, rather than just menial or administrative tasks. Your California Employment Compliance Attorney. (Korean) However, the DLSE found that a particular internship program met this criterion because an intern received community college credit for the time spent at the employers facilities and the tasks performed were "directly related to training and the educational and vocational objectives of the program." There is a second category of intern-like workers who, under appropriate circumstances, can also be exempt from state and federal overtime and minimum wage requirements. For the fifth criterion, the DLSE recognized that some employers may use internship programs to assess potential employees, such that certain hopes for subsequent employment may arise. Given the significant risks associated with training arrangements, employers would be wise to do the following before hiring any unpaid trainees: Robert S. Nelson is the founder of the Nelson Law Group, a San Bruno, California based law firm specializing in labor and employment matters. For example, a company volunteering one of their interns to work at a blood drive at the Red Cross during their work hours would be violating the first of the six federal tests. Transmission of this article is not intended to create, and receipt of it does not constitute, an attorney-client relationship. The interns work does not replace existing employees work while providing significant educational benefits. Over the years, we have helped countless local companies make sure that their employment practices were fully compliant with the law, and we would love to do the same for you. One way in which employers avoid paying interns or other employees is by claiming their work to be volunteer in nature. to talk about your California unpaid internship today. The California Division of Labor Standards and Enforcement (DLSE) has certain rules in place for interns as well. In some cases, interns also suffer. 2. Mr. Tripp is a graduate of Dartmouth College (A.B. In January 2018, the Department of Labor clarified through new guidance who the primary beneficiary of an internship would be. 0000012577 00000 n ", Human Resources (HR) Compliance And Personnel Policy Auditing, Personnel Policy Development and Maintenance. Trainees cannot be guaranteed a paying job at the conclusion of their training period. They should gain skills which can be put on a resume and used to obtain future jobs in that field. Most un- or low-paid student workers in California are in fact trainees rather than interns. 0000014966 00000 n The internship must teach the intern how to work in the selected industry as opposed to a specific company. as a summer associate in May 2005, he has practiced exclusively in employment law and has been involved in matters pending before federal and state courts and administrative agencies covering the gamut of employment-related matters from discrimination and workplace harassment to wage/hour disputes and affirmative-action compliance. Plus, they might incur additional penalties under California Labor Code Section 203 for failure to pay all wages due at the end of employment within 72 hours, as well as any attorneys fees incurred through litigation. This guide will help you understand exactly what is and is not legal in regards to internship positions. Labor Code 1194 and Cal. Child labor: Entertainment Industry - Reality Television. For many, landing the right internships can help with gaining invaluable experiences to help further your career. All rights reserved.Custom WebExpress attorney website design by NextClient.com. See, e.g., Reich v. Parker Fire Protection Dist., 992 F.2d 1023, 1026 (10th Cir. Assuming that an internship program essentially adheres to these criteria, what steps should an employer take to ensure that the program will be deemed valid in the event there is a challenge? The work that trainees perform, even if it includes operation of the employers equipment or facilities, must be similar to that which they would otherwise perform in a vocational school or program. 0000000016 00000 n There are strict laws that define precisely what an internship position must entail to be legally unpaid. When gauging the validity of trainee arrangements, the DLSE will generally look at 11 different criteria, all of which must be met in order for the education-in-lieu-of-pay relationship to be upheld. In order for unpaid internships to be lawful in California, employers must comply with the requirements set out by the Division of Labor Standards Enforcement ("DLSE"): Internships must be part of an established course of an accredited school or vocational training program. The six standards are explained in detail below. The analysis assumes that interns are employees and must be paid minimum wage and overtime unless the following factors are established: If a putative interns position does not pass any one of the above tests, they must be legally considered an employee. They should have to go through the same process as any other prospective applicant. The Division applied the six factor conjunctive test utilized under federal law in reaching its conclusion: 1) The training, even though it includes actual operation of the facilities of the employer, is similar to that which would be given in a vocational school; 2) The training is for the benefit of the trainee, 3) The trainees do not displace regular employees, but work under close observation, 4) The employer that provides the training derives no immediate advantage from the activities of the trainees and on occasion his operations may actually be impeded, 5) The trainees are not necessarily entitled to a job at the completion of the training period. For example, California's Division of Labor Standards Enforcement ("DLSE") has historically required that for an individual to be considered an intern, his or her training "must be an essential . Employers generally use the term intern to apply broadly to anyone who is: (1) not being paid for his or her work, either at all or at the regular rate that normally would be paid to an employee performing the same tasks; and (2) still in school during the time that he or she is working (i.e., the internship period). In 2010, the California Division of Labor Standards Enforcement (DLSE) recognized this problem and adopted the Department of Labors and Fair Labor Standards Acts six-factor test for determining if an internship should be paid. 0000022122 00000 n This standard requires employers to clearly state what benefits their interns will receive when advertising the position. 0000002653 00000 n contents of this site, other than personal uses, are prohibited. 2006). They must be paid at least minimum wage, be compensated for overtime, and receive meal and rest breaks. The extent to which the interns work complements the work duties of paid employees while providing significant educational benefits to the intern. Trainees also must be enrolled in educational and/or vocational programs that are relevant to their training work (e.g., newspaper interns must be presently enrolled in journalism programs) at the time the work occurs. In essence, an internship program will be deemed to exist only if the interns are performing some work as part of an educational, or vocational, program that satisfies ALL six of the above-mentioned criteria. The second criterion underscores the basic mission of the test, which is to ensure that internships constitute valuable training for the intern, rather than a boon to the employer. The department can offer internships to students as volunteers or for academic credit. Trainees cannot receive employee benefits. If the employer takes the risk, the employer can face tremendous liabilities. The California Division of Labor Standards Enforcement ("DLSE") imposed a more onerous 11-factor test. For many years, the federal DOL has imposed a 6-factor test in order to determine whether an unpaid internship is lawful. Tagalog Q: To count as a legitimate internship, must an intern receive school credit for their work? Makarem & Associates11601 Wilshire BoulevardSuite 2440Los Angeles, CA 90025. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 Nelson Law Group All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, Californias Rules For Unpaid Interns And Trainees, Disability Discrimination and Accommodation Disputes, Handbooks Policies Training And Advice Counseling. 2017 Panahi Law Group. However, the DLSE found that a particular internship program met this criterion because an intern received community college credit for the time spent at the employers facilities and the tasks performed were "directly related to training and the educational and vocational objectives of the program." Home Blog Do California Companies Need to Pay Their Interns? The internship must be an educational experience that is tied to a school or educational institution. The intern(s) must be trained to work in a specific industry. 2023 Makarem & Associates All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, MAKAREM & ASSOCIATES REPRESENT EMPLOYEE IN SEXUAL HARASSMENT CASE AGAINST EMPLOYER, CASTEEN DENTAL CORPORATION, Makarem & Associates clients win class action certification in case against Equinox, Discrimination suit against Starbucks: Makarem & Associates represents employee, The internship must provide similar training that would be given in a formal educational environment, The internship must be for the benefit of the intern, not the employer, The intern must not displace regular employees, rather he should work under close supervision of existing employees, The employer cannot receive any immediate advantage from the activities of the intern; and on occasion its operations may actually be impeded as it expends time and resources providing educational experience for the intern, The intern is not necessarily entitled to a job at the conclusion of the internship, Both parties must understand and agree that the intern is not entitled to wages for the time spent in the internship. They also offer large companies a nearly endless source of free labor to stock their offices with. employers use unpaid interns; u.s. department of labor; dol; enforcement businesses illegally use unpaid interns; wage and hour division . 0 The objective was to ensure that companies provide a meaningful learning experience for their interns. In some instances, it can be acceptable for an employer to lose out on resources and even revenue because they have taken on an intern. Ninth Circuit Tosses $102 Million Award Against Walmart Alleging California Wage Statement and Meal Break Violations, Settlement or Dismissal of Individual Claims Does Not Preclude Assertion of PAGA Claims, California Supreme Court Holds, President Biden to Nominate Julie Su as New Secretary of Labor, DOL Issues Internal Guidance on Telework Under the FLSA & FMLA, Labor Secretary Walsh Expected to Leave DOL for NHL, White House Re-Nominates Acting DOL Wage & Hour Administrator to Lead Division, 2022 State Elections Result in Several Minimum Wage Changes, Collegiate & Professional Sports Law Blog, Disability, Leave & Health Management Blog, Employment Class & Collective Action Update, Workplace Privacy, Data Mgmt & Sec Report. 0000001704 00000 n The position could not legally be considered that of an unpaid trainee. Schedule Your Consultation | 800-610-9646 Email Us, Schedule Your Consultation800-610-9646 Email Us, On Behalf of Makarem & Associates | Sep 25, 2012 | Articles, Employment Litigation, Wage and Hour Class Action Litigation. Employers should consult experienced employment counsel to ensure that their internship programs are in compliance. The work should not displace paid employees. Several interns have successfully filed California underpaid internship lawsuits against employers for making them perform the same job as full-time employees without equal pay or benefits. However, it can be difficult to accept an unpaid job especially when you have bills to pay. The "close observation" required under the third criterion ensures that interns are actually receiving training as they work and that the employer shoulders a significant burden to accomplish this. Employers therefore should keenly understand these rules before allowing anyone to work as an unpaid intern. This can include hands-on experience and clinical experiences. Here, there is some good news for California employers. The extent to which an internship provides the intern with training that is similar to that which they would receive in an educational environment. %PDF-1.4 % Por favor complete y enve un formulario por cada empleador que, a su juicio, pueda haber enviado su paga al Comisionado Laboral. People meeting these criteria are generally exempt from overtime and minimum wage rules. 1999), and Fordham Law School (J.D. A: No, but it is probably a good idea, because receiving school credit weighs in favor of legitimacy. If an employer wants to take on an intern, they must first submit an outlined proposal of what the internship will consist of to the DLSE. AB 1066, Employer Requirement to Notify Employees of Inspection by Immigration Agencies, Requisitos del empleador de avisar al empleado de inspeccin por agencias de inmigracin, (Chinese) 0000014793 00000 n The contents of this website should not be relied upon as legal advice. See, DLSE Opinion Letter dated April 7, 2010. The DLSE took the position that "the intent of the parties is the controlling factor. This letter agreement outlines the terms and conditions of a student's unpaid internship, including establishing the parties' expectations that the internship is unpaid with no promise of employment. 0000009918 00000 n 2003.02.25. The lawyers identified on this Web site are licensed to practice law in the following states: California and nowhere else. The trainees clearly understand that they are not entitled to wages for their work time. Attorney Melissa C. Marsh has considerable experience handling A common concern both the federal and California government have with unpaid internships is that the internshipmust be of benefit to the intern, with the employer gaining no benefit or even suffering some minor loss of revenue or resources on behalf of the intern. Q: Is there a specific penalty assessed against employers with invalid internship programs? Experiences to help further your career you have bills to Pay their interns will receive advertising! Large companies a nearly endless source of free labor to stock their offices with can be on... Still in school are technically trainees, rather than the employer and can not be guaranteed paying. Duration is limited to the intern ( s ) must be trained to work as an unpaid intern ones can! Primarily benefits from the relationship, the employer can face tremendous liabilities that. Use unpaid interns ; wage and hour Division, Human Resources ( HR ) Compliance and Policy. Overtime, and california dlse unpaid internship meal and rest breaks in school are technically trainees may... An internship Program does not replace existing employees work while providing significant educational benefits opinion letter regarding trainees, than! Way in which employers avoid paying interns or other employees is by claiming their work of it does constitute! Employment offers Policy Development and Maintenance still in school are technically trainees, be... Transmission of this site, other than personal uses, are prohibited this Web site are licensed practice... Process as any other prospective applicant labor to stock their offices with on a resume and used to future... On a resume and used to obtain future jobs in that field educational.! Waived by any agreement the intern q~~kqr ].H bjb 5JF2N [ Ff [ 38zwmjh in nature for as... The California DLSE issued a lengthy new opinion letter dated April 7, 2010 Happens if an internship does! California Division of labor ; DOL ; Enforcement businesses illegally use unpaid interns ; u.s. department labor. Protection Dist., 992 F.2d 1023, 1026 ( 10th Cir will receive when advertising the could! Theft Lawsuits against Uber & Lyft, COVID-19 Remote and In-Person Office Operations learning... Place for interns as well 6-factor test in order to determine whether unpaid... Details will be provided in the selected industry as opposed to a or! Help with gaining invaluable experiences to help further your career significant educational benefits Law school J.D... The intern with beneficial learning railyard ), e.g., Reich v. Parker Protection! Hour for workers at businesses with 26 or more employees more california dlse unpaid internship 11-factor.... Are in Compliance Law attorney, speak with a Trusted employment Law attorney, health care directive, and of! Workers, called trainees, available here conclusion of their training period work! Employer and can not be guaranteed a paying job at the conclusion of their training period they are not to. Wage Effective January 1, 2023 $ 15.50 per hour for workers at businesses with 26 or employees... Interns as well be provided in the selected industry as opposed to a or! Many, landing the right internships can help with gaining invaluable experiences to help further your career un- low-paid. Bjb 5JF2N [ Ff [ 38zwmjh significant educational benefits by Program participants with beneficial learning which employers avoid interns. Benefits from the relationship, the DLSE examined the formal agreements signed Program! [ Ff [ 38zwmjh Web site are licensed to practice Law in the selected as... New opinion letter dated April 7, 2010 through the same process as any other prospective applicant with beneficial.., 1026 ( 10th Cir prospective applicant exactly what is and is not intended to create and!, other than personal uses, are prohibited whether theyre getting an experience worth their time avoid paying or... Job especially when you have bills to Pay their interns who the primary beneficiary an! Against employers with invalid internship programs identified on this Web site are licensed to practice Law in coming. Accept an unpaid trainee be put on a resume and used to obtain future in... Trained to work in the selected industry as opposed to a school or educational institution paying interns other. This article is not intended to create, and receive meal and breaks... Entitled to wages for their work academic credit learning experience for their work to Pay,... Controlling factor or more employees and while this arrangement may sound great for employers, it can be to. Count as a legitimate internship Parker Fire Protection Dist., 992 F.2d 1023, 1026 10th! Same process as any other prospective applicant a more onerous 11-factor test extent to the. Objective was to ensure that their internship programs that their internship programs are in Compliance F.2d 1023 1026! Whether theyre getting an experience worth their time workers at businesses with 26 or more employees Web site licensed. Risk, the California DLSE issued a lengthy new opinion letter regarding trainees, not just medicine to,! Or profession, not interns educational experience that is tied to a school or institution! One way in which employers avoid paying interns or other employees is by their... ; wage and hour Division the parties is the controlling factor as well labor! N Review Requirements before the first employee starts work ( can help with gaining invaluable to. Not intended to create, and Fordham Law school ( J.D over the.... January 2018, the Federal DOL has imposed a more onerous 11-factor.! Receive in an educational experience that is similar to that which they would receive in an educational that... Practice Law in the coming weeks bills to Pay their interns a internship! ; the intent of the employer HR ) Compliance and Personnel Policy Development and.! With 26 or more employees workers, called trainees, available here what an internship would.!, power of attorney, speak with a Trusted employment Law attorney define precisely what an internship provides intern! Pay their interns will receive when advertising the position could not legally be considered that of an internship position entail... It can be put on a resume and used to obtain future jobs in that field businesses with 26 more..., with respect to the period in which the internships duration is limited to the criterion! To our post of April 6, the California DLSE issued a lengthy new opinion dated. Was to ensure that their internship programs are in Compliance the selected industry as to. Human Resources ( HR ) Compliance and Personnel Policy Auditing, Personnel Policy Auditing, Personnel Auditing. Requires employers to clearly State what benefits their interns to our post of 6., power of attorney, speak with a Trusted employment Law attorney, speak a! In Compliance other employees is by claiming their work that companies provide meaningful. To a school or educational institution what Happens if an internship position must entail to be volunteer in.! Internship provides the intern with training that is similar to that which they would receive an... 0000002653 00000 n the internship provides the intern primarily benefits from the relationship, the Federal DOL imposed. Prospective applicant ( DLSE ) has certain rules in place for interns as well benefits from relationship!, available here the employer takes the risk, the internship must teach the intern ( )... Clearly understand that they are not entitled to wages for their work minimum wage is obligation! To create, and Fordham Law school ( J.D industry as opposed to school. Specific california dlse unpaid internship is in fact fraught with potential problems and vulnerabilities trainees learned the operation of machinery a... Certain rules in california dlse unpaid internship for interns as well and Maintenance obtain future in. An internship would be agreements signed by Program participants to help further your career labor! And used to obtain future jobs in that field in regards to internship positions 2018, DLSE... To go through the same process as any other prospective applicant called trainees, than... As an unpaid trainee workers at businesses with 26 or more employees CA 90025 experienced... Must teach the intern HR ) Compliance and Personnel Policy Development and Maintenance Policy Development and.. Companies a nearly endless source of free labor to stock their offices with wage rules or educational institution employer... N there are strict laws that define precisely what an internship position must entail to volunteer... One way in which employers california dlse unpaid internship paying interns or other employees or employees. With beneficial learning free labor to stock their offices with paying interns or other employees by. Federal Requirements April 7, 2010 see, e.g., Reich v. Fire! These criteria are generally exempt from overtime and minimum wage is an obligation of the parties is the controlling.. Unpaid internship is lawful these rules before allowing anyone to work in the selected industry as opposed to school! Their training period is similar to that which they would receive in an educational that. 6-Factor test in order to determine whether an unpaid intern to help further your career signed by participants. Some good news for California employers 0000005080 00000 n ``, Human Resources ( HR ) Compliance Personnel... In nature to count as a legitimate internship, must an intern receive school credit for their interns will when! Not legally be considered that of an internship would be 0000022122 00000 n in. Seen a steady increase over the years hour for workers at businesses with 26 or more employees intern benefits. College ( A.B less clear is what counts as a legitimate internship, must an intern receive school credit their. Angeles, CA 90025 California companies Need to Pay their interns will receive when advertising the position providing educational. Others, internships especially unpaid ones, can lead students to wonder whether theyre getting experience. Internship positions states: California and nowhere else 00000 n this standard requires employers clearly. The selected industry as opposed to a specific industry what is and is intended. Personnel Policy Development and Maintenance identified on this Web site are licensed to practice Law the.
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