July 26, 2006

Best Hiring Practices as Defined by ICE under the Image Program

• Use the Basic Pilot Employment Verification Program for all hiring.

• Establish an internal training program, with annual updates, on how to manage completion of Form I-9 (Employee Eligibility Verification Form), how to detect fraudulent use of documents in the I-9 process, and how to use the Basic Pilot Employment Verification Program.

• Permit the I-9 and Basic Pilot Program process to be conducted only by individuals who have received this training—and include a secondary review as part of each employee’s verification to minimize the potential for a single individual to subvert the process.

• Arrange for annual I-9 audits by an external auditing firm or a trained employee not otherwise involved in the I-9 and electronic verification process.

• Establish a self-reporting procedure for reporting to ICE any violations or discovered deficiencies.

• Establish a protocol for responding to no-match letters received from the Social Security Administration.

• Establish a Tip Line for employees to report activity relating to the employment of unauthorized aliens, and a protocol for responding to employee tips.

• Establish and maintain safeguards against use of the verification process for unlawful discrimination.

• Establish a protocol for assessing the adherence to the “best practices” guidelines by the company’s contractors/subcontractors.

• Submit an annual report to ICE to track results and assess the effect of participation in the IMAGE program.