I working as Cashier at

Columbus Ohio located above address on daily basis, Today’s date is

My employment commenced  I do not (circle one) accept, handle and/or process food stamp Coupons in the ordinary use of my work.

I understand that ALL employees of Store

Regardless of weather or not they accept handle, and/or process food stamp must periodically undergo training

Deli's expense, about the Federal government Stamp program. Upon completion of each such training session, I will sign and receive a certificate of completion. A copy of each signed certificate is kept in my personnel file.

I have received the copy of Food Stamp police statement & regulations for store employees who handle Food Stamps" (hereinafter, the" Statement"). I understand, or have had thoroughly explained to me, the full content of the ''Statement". I agree to abide by all of the Rules in the Statement.

I have also received copies of all the materials produced by the Federal Government's Food and Consumer Services: "Food Stamp & Ohio Direction Card Program:" "Tips for Cashiers" "Food Stamp & Ohio Direction Card Program: A Guide for Retailers". l have read, or have had explained lo me, all of these material, with a particular emphasis on the "do's and these, with a particular emphasis on the "do’s and don’ts.

In particular, I understand the importance of ensuring that Ohio Direction Card & Food Stamp coupons are not used by, customers to purchase INELIGIBLE items or NON­ FOOD items. I also understand that the µse of food stamps by customers for any purpose other than the purchase of ELIGIBLE food items is against Store Policy, is a crime and is, therefore, illegal. I understand that if I violate any regulation (s) of the Food Stamp or Ohio Direction Card Program, the store could lose the privilege of accepting Food Stamp coupons and Ohio Direction Card from our customers. I further understand that it is ALSO illegal and against Store Policy for employees to exchange food stamps for cash (commonly known as "trafficking in food stamps") or to trade food stamps for items of value outside the context of a normal store sale of ELIGIBLE food items. Furthermore, I more Ohio Direction Card Program access devices, firearms, ammunition, explosives, or controlled substances in a cash or barter transaction, whether on or off store property. I understand that the normal discipline for trafficking or attempted trafficking in food stamps, Ohio Direction Cards, ATP cards, other food stamp program access devises, firearms, ammunition, explosives, or controlled substances, shall be termination of employment for the first offense, without exception. The normal discipline for accepting Food Stamps & Ohio Direction Cards for ineligible items shall also be terminated. Allegations of employees and/or investigators employed by or for the Federal Government's Food and Consumer Service that Food Stamp coupons or Ohio Direction Card were improperly accepted for ineligible items are sufficient cause for termination.       '

An illustrative list of INELIGIBLE food items and NON-FOQD items, printed by the Food Stamp & Ohio Direction card Program, has been given to me and l understand that in EVERY food stamp transaction, it is the responsibility of the employee who accepts the Stamps or Ohio Direction Card to ensure that food Stamps or Ohio Direction Card are only accepted for ELIGIBLE FOOD items. In any particular transaction that I may be involved in, if I am in doubt as to whether a sale item is ELIGIBLE or not, I shall immediately procure the assistance of a knowledgeable fellow employee and/or the store manager. If at any time I am unable to determine that a sale item is ELIGIBLE or not, I MUST NOT consummate the sale, AND MUST return the customer's Food Stamp and/or Ohio Direction Card to the customer, and politely request payment for the item in cash.

If at ANY time, I observe or have knowledge of: (1) ANY act or activity whatsoever that is, or I believe may be, in violation of the Governments Food Stamp and Ohio Direction Card Program requirements; or (2) ANY act or activity whatsoever that is, or I believe may be, in violation of the above-stated Store Policy and Regula ions regarding Food Stamps and Ohio Direction Cards I will immediately (within 12 hours) report such observation or knowledge to my Supervisor and/or the Manager; or this store, listed below. I further understand that my failure to make a report, where one was required, shall be just cause for disciplinary action up to and including my dismissal.

FINALLY, I understand that the store is permitted by Law to utilize internal review to verify employee's compliance with Food Stamp and Ohio Direction Card Program regulations. Such internal review will not be announced before hand.

1) The store has implemented a comprehensive personnel training program to instruct employees about the various regulations governing the Food Stamp Program and the consequences of violating those regulations. All employees have been informed that violating any part of the regulations governing the Food Stamp program constitutes an illegal act and such behavior will not be tolerated. Specifically, employees have been informed, in writing, that once trained, any employee caught exchanging Food Stamp coupons, ATP cards or other program access devices for cash (all commonly known as trafficking), or selling firearms, ammunition, explosives, or controlled substances in exchange for Food Stamp coupons or accepting Food Stamp coupons for INELIGIBLE items will be terminated at once. There shall be exceptions.

2) Internal review will be an integral part of the store's plan to verify employees' compliance with all regulations of the Food Stamp program.

3) Internal review will consist of two components:

1. a) Ordinary day-to-day surveillance by the store manager of store transactions that involve Food Stamp coupons, including, where possible, observation and recording through closed circuit television,
2. b) Use of purchased Food Coupons by undercover store agents ("operatives") in "sham" transactions with employees who are reasonably suspected of violating any regulation of the Food Stamp Program.

4) The amount and timing of day-to-day surveillance shall be left to the discretion of the individual store manager, subject to the following requirements:

1. a) Any new employee, particularly cashiers, but also other categories of workers, shall be regularly supervised in his transactions with Food Stamp coupons until such time as he has successfully transacted at least $500 worth of retail food purchases.
2. b) Any employee who arouses the store manager's suspicions regarding that employee's compliance with the regulations of the Food stamp program shall be regularly observed and, if possible, recorded via closed circuit television during his transactions involving Food Stamp coupons. At the conclusion of a reasonable period of observation, if reasonable suspicion of wrongdoing still exists, the procedures outlined in below shall be employed without delay.

5) Use of Food Coupons for Internal Security Checks

1. a) If reasonable grounds exist, the store is authorized by Food Stamp regulations to purchase marked stamps from the Government and use them in "sham" transactions with any store employee, regardless of whether or not the employee is a suspect in any wrongdoing.

1. b) The store owner or manager shall write to:

Deputy Administrator for Family Nutrition Programs Food and Consumer Service U.S. Department of Agriculture 3101 Park Center Drive Alexandria, Virginia 22302

and request a specified dollar amount of stamps, for example, one-hundred dollars worth. (There is no limit on the amounts of stamps that may be requested.) A check or money order payable to the "Food and Consumer Service" must be enclosed with the request. These stamps are later redeemed in the ordinary course of business, so that there is essentially n cost to the store for Procuring these marked coupons.

1. c) A trustworthy and responsible individual (hereinafter, the "operative") selected by the store manager, and who is a stranger to the employee, shall attempt either a purchase of ineligible item(s), trafficking, or any other specified offense which 'the employee' is suspected of committing. The operative shall not entice or cajole the employee into committing an offense. The purpose of this means of internal verification is not to entrap innocent individuals and, hence, this procedure must be used with care and with due regard for the legal and civil rights of the individual employees’ the purpose is to see if the employee is predisposed toward committing the offense. Therefore, the operative should not behave in a suggestive way. If possible, the operative and store employee's actions should be taped via the store's security system for later disciplinary action, if that turns out to be warranted. If taping is not practical, the store manager might consider using a second operative as a witness.
2. d) Any and all such internal investigations conducted by the operative shall be immediately recorded in writing in a store

Curriculum to be Followed in Instructing Store Employees about the Rules and Regulations Governing the Food Stamp Program

1) Every employee, regardless of position or title, shall undergo training in the proper acceptance, handling, and redemption of food stamps.

2) Every employee shall sign a Disclosure Notice and receive a copy of the store's "Food Stamp Policy Statement & Regulations for Store Employees Who Handle Food Stamps". Such written employee training information shall include the following notification: "Any employee caught exchanging Food Stamp coupons, ATP cards, or other program access devices for cash (all commonly known as ’trafficking•), or selling firearms, ammunition, explosives, or controlled substances in exchange for Food Stamp coupons or accepting Food Stamp coupons for INELIGIBLE items will be terminated at once. There shall be no exceptions."

3) At least once during training every employee shall be orally warned that: "Any employee caught exchanging Food Stamp coupons, ATP cards, or other program access devices for cash (all commonly known as "trafficking"), or selling firearms, ammunition, explosives, or controlled substances in exchange for Food Stamp coupons or accepting Food Stamp coupons for INELIGIBLE items will be terminated at once. There shall be no exceptions."

4) For existing employees, training shall commence July 1, 1995. for maximum effect, training shall be limited to groups of no more than ten employees at one time. Training shall be conducted twice per year, at approximately six-month intervals.

5) Dated and written records of employees' attendance at training shall be kept in the Central Record Keeping depository.

6) New employees shall be trained prior to their first day on the job. New employees who handle food stamps in retail transactions shall also be closely supervised, per the policy set forth in part 4(a) of the store document entitled, "Internal Review Procedures for Verifying Proper Acceptance, Handling, and Processing of Food Stamps"

7. The Food Stamp training curriculum shall consist of the following items:
8. a) Overview of the history and purpose of the Food Stamp Act, as amended.
9. b) Brief discussion of the procedure involved in the store's application for approval to accept Food Stamps.
10. c) Discussion of rationale for this eligible versus Ineligible items and the distinction.
11. d) Sanctions for accepting stamps for ineligible items.
12. e) Discussion of other prohibited activities, such as trafficking in Food Stamps and bartering goods or services for stamps.
13. f) Criminal sanctions that may be applied against an employee caught trafficking.
14. g) The relationship between the WIC Program and the Food Stamp Program (relevant to certain stores that have been approve for WIC).
15. h) The store motto shall be repeated throughout the training session, namely, "If in doubt about a particular transaction, procure the assistance of a more knowledgeable employee and/or the store manager. If this cannot be done or, if you are still in doubt, DO NOT consummate the sale for the particular item in doubt."
16. i) Appropriate humour and anecdotes should be employed during training as this often assists individuals in remembering key points that are being made.
17. j) At the conclusion of training, a 15-minute video shall be shown. The video should provide a visual demonstrate of attempted sale of INELIGIBLE items (along with an explanation of why the items were INELIGIBLE) and should also depict other "no no's", such as trafficking, with a clear explanation of the consequences of such acts.
18. k) At the conclusion of the videotape, the instructor should query employees about what they just heard and saw throughout the training session, so as to determine if all the material was fully understood.

Questions from employees should be fielded as well.

1) Employees should also be reminded that they have their own copies of materials published by the Food Stamp Program, copies of the store policy, and an employee disclosure statement that they have signed.

regarding that employee's compliance with the regulations of the Food Stamp program shall be regularly observed and, if possible, recorded via closed circuit television during his transactions involving Food Stamp coupons. At the conclusion of a reasonable period of observation, if reasonable suspicion of wrongdoing still exists, the procedures outlined in below shall be employed without delay.

5) Use of Food Coupons for Internal Security Checks

1. a) If reasonable grounds exist, the store is authorized by Food Stamp regulations to purchase marked stamps from the Government and use them in "sham" transactions with any store employee, regardless of whether or not the employee is a suspect in any wrongdoing.
2. b) The store owner or manager shall write to:

 Deputy Administrator for Family Nutrition Programs Food and Consumer Service U.S. Department of Agriculture 3101 Park Center Drive Alexandria, Virginia 22302

and request a specified dollar amount of stamps, for example, one-hundred dollars worth. (There is no limit on the number of stamps that may be requested.) A check or money order payable to the "Food and Consumer Service" must be enclosed with the request. These Stamps are later redeemed in the ordinary course of business, so that there is essentially no cost to the store for procuring these marked coupons.

1. c) A trustworthy and responsible individual (hereinafter, the "operative") selected by the store manager, and who is a stranger to the employee, shall attempt either a put base ineligible item(s), trafficking, or any other specified offense which the employee is suspected of committing. The operative shall not entice or cajole the employee into committing an offense. The purpose of this means of internal verification is not to entrap innocent individuals and, hence, this procedure must be used with care and with due regard for the legal and civil rights of the individual employee. The purpose is to see if the employee is predisposed toward committing the offense. Therefore, the operative should not behave in a suggestive way. If possible, the operative and store employee's actions should be taped via the store's security system for later disciplinary action, if that turns out to be warranted. If taping is not practical, the store manager might consider using a second operative as a witness.
2. d) Any and all such internal investigations conducted by the operative shall be immediately recorded in writing in a store log of internal review actions, one copy of which log shall be kept in the Centralized Record Keeping depository. The store log shall include, at a minimum, the name of the operative, the store employee who was investigated, identification of the Food Stamp regulation(s) that the employee was suspected of violating, the total dollar amount of Food Stamps used in the transaction with the operative, dates that the operative carried out his transactions, the results of such transactions (i.e., did the employee violate Food Stamp regulations in his transactions with the operative), whether or not the transaction was taped and the location of said tape, if violations occurred, a record of disciplinary action taken against the employee for the violations, and any other information that may be relevant for a subsequent investigation.

6) The above policy regarding internal review shall be periodically reviewed and updated to ensure that it is consistent with the regulations and requirements of the Food Stamp program.

7) Questions regarding interpretation and enforcement of the above internal review policy shall be directed to the owner of the store who has sole and final authority over actions undertaken in furtherance of employee compliance with the regulations governing the Food Stamp program.