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5.9 Accuracy of Employment Related Documents

Purpose

To ensure every employment-related record and statement provided to or maintained by THE COMPANY is complete, accurate, and truthful. False, misleading, or incomplete information undermines legal compliance (payroll, taxes, immigration, background screening) and may result in discipline up to and including termination.

 

Scope

Applies to all applicants, candidates, and Team Members (hourly and salaried), at all SUBWAYÒ locations operated by THE COMPANY, as well as contractors or trainees where applicable law requires.

  • Definitions
    • Employment Records include, without limitation: job applications; onboarding questionnaires; I-9 and work authorization documents; tax and payroll forms (W-4, state forms); direct-deposit details; benefits forms; schedules; time and attendance entries; tip reports; training/acknowledgment forms; incident reports; background-check disclosures/authorizations; and any information submitted via Harri, Paradox (“Subrina”), SignNow, Cognito Forms or other THE COMPANY systems.
    • Electronic Signature/Record: Any electronic sound, symbol, or process attached to, or logically associated with, a record and executed with intent to sign. Under Georgia law, electronic records and signatures have the same legal effect as paper and wet signatures. 

 

Team Member Responsibilities

  • Truthful Submission: Provide complete, accurate, and truthful information during application, onboarding, and throughout employment.
  • Timely Updates: Promptly update changes to name, address, contact info, tax withholding, banking details, emergency contact, work authorization, and availability.
  • Accurate Time & Tips
    • Record all hours worked exactly as worked; no off-the-clock work; no rounding to “make it look right.”
    • Report all cash and charge tips accurately and by required deadlines on Company forms/systems. (Under federal tax rules, failing to report tips can trigger penalties and additional tax liabilities.) 
  • Document Integrity: Submit only authentic documents that belong to you; do not alter, forge, or allow others to use your identity or credentials. (Providing false identity or documents in the I-9 process can carry civil/criminal penalties under federal law.) 
  • Electronic Signatures: When e-signing via THE COMPANY systems (e.g., Harri, Subrina/Paradox, SignNow, Cognito Forms), review content before signing and sign only for yourself.
  • Company Responsibilities
  • Recordkeeping: THE COMPANY maintains required payroll and employment records per the Fair Labor Standards Act (29 C.F.R. Part 516) and other applicable laws. 
  • I-9 Compliance: THE COMPANY verifies work authorization using Form I-9 and corrects errors consistent with federal guidance. 
  • Background Checks: When using a third-party consumer reporting agency, THE COMPANY provides the FCRA-required standalone disclosure and obtains written authorization before procuring a report. If adverse action is contemplated, THE COMPANY provides pre-adverse and adverse action notices as required. 

 

Prohibited Conduct (Examples, not exhaustive)

  • Falsifying or omitting information on applications, onboarding forms, acknowledgments, or any THE COMPANY record.
  • Submitting forged, altered, or another person’s documents (IDs, Social Security cards, work authorization, medical notes). 
  • Inaccurate or deceptive time entries; clocking in/out for another person (“buddy punching”); editing time to conceal lateness or extend hours not worked.
  • Tip underreporting or manipulation of tip declarations. (IRS penalties may apply to underreported tips.)
  • E-signing on behalf of another person or pressuring others to sign.

Audits, Reviews, and Corrections

  • Audits: THE COMPANY may audit employment records at any time (including timekeeping, schedules, tip reports, and I-9 files) to ensure accuracy and compliance with wage-hour recordkeeping rules. 
  • Corrections: If errors are discovered (by you or the Company), promptly notify Management so they can be corrected (for example, an I-9 correction/addendum in accordance with USCIS guidance). 
  • Cooperation: Team Members must cooperate fully and truthfully during audits or investigations.

 

Reporting Procedure

Any suspected falsification, inaccuracy, or irregularity in employment records must be reported in writing using the Record Accuracy Concern Form. Verbal reports will not be accepted.

  • Step 1 – Complete the Form: Team Members must complete a Record Accuracy Concern Form within 24 hours of discovering an issue. The form is available on the Team Member Portal.
  • Step 2 – Submit Securely: Submit the form electronically through the designated portal.
  • Step 3 – Confirmation: The submitting Team Member will receive a digital confirmation receipt via email (date/time stamped).
  • Step 4 – THE COMPANY Review: THE COMPANY will review the submission within five (5) business days, conduct any necessary fact-finding, and document corrective action or follow-up results.
  • Step 5 – Record Retention: All forms and findings will be stored in the Team Member’s confidential file in compliance with federal and Georgia recordkeeping laws.

 

No Retention

Team Members who report concerns in good faith via the official Record Accuracy Concern Form are protected from retaliation. Any form of reprisal or intimidation related to such a report will result in disciplinary action.

 

Consequences

  • Discipline: Violations may result in corrective action up to and including termination. Factors considered include the seriousness of the conduct, whether it was intentional, repeated, or concealed, and any impact on legal compliance (for example, payroll, tax, or immigration rules).
  • Restitution: Overpayments or improper payouts resulting from falsified records may be recovered through lawful payroll deductions or other remedies, consistent with THE COMPANY policy and applicable law.
  • External Penalties: Certain misconduct (e.g., immigration document fraud or tax underreporting of tips) may expose individuals to government penalties separate from Company discipline. 

 

Electronic Records & Signatures

THE COMPANY uses secure electronic systems (e.g., Harri, Paradox/“Subrina,” SignNow, and Cognito Forms) for forms, acknowledgments, and signatures. Electronic records and signatures have the same force and effect as paper/wet signatures under Georgia’s Uniform Electronic Transactions Act. 

 

At-Will Employment

Nothing in this policy alters the at-will employment relationship. THE COMPANY may modify or discontinue this policy at any time, consistent with applicable law.

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