Cherylle C. Corpuz and Manuela M. Morais

The New ICE Age: The Government Cracks Down on Employer Immigration Violations U.S. Immigration & Customs Enforcement worksite enforcements incorporate multiple investigations and criminal charges that have resulted and will continue to result in serious felony charges for employees and their employers. Here s what to do to limit the risks. Cherylle C. Corpuz and Manuela M. Morais 6 Worksite enforcement actions target a key component of the illicit support structure that enables illegal immigration to flourish. No employer, regardless of industry or location, is immune from complying with the nation s laws. ICE and our law enforcement partners will continue to bring all of our authorities to bear in this fight using criminal charges, asset seizures, administrative arrests and deportations. (Julie L. Myers, Assistant Secretary for Homeland Security, U.S. Immigration & Customs Enforcement, Aug. 14, 2008.) This quote makes clear the agenda of the U.S. Immigration & Customs Enforcement (ICE), established in March 2003 as part of the Department of Homeland Security (DHS). Since its creation, the agency has expanded its operations notably with significant increased activity relating to raids, removal proceedings and criminal prosecution of both employees and employers for immigration violations. Given that it is the largest DHS investigative agency and has the largest force of investigators, it can further homeland security priorities by taking increasingly aggressive measures. The Immigration Reform & Control Act of 1986 (IRCA), among other things, requires employers to verify the identity and work eligibility of each employee hired after 1986, through the use of Form I-9, Employment Eligibility Verification. For enforcement of worksite compliance, employers that fail to comply with the statute are subject to civil (monetary) and criminal penalties, which, although discretionary, can be significant depending on the employer s offense. However, before 2003, for many employers the IRCA-imposed penalties were for the most part considered as part of the cost of doing business. Although criminal penalties were brought against employers for pattern and practice violations, these cases were far and few in between. However, due to multiple factors including the sharing of government information (principally between U.S. Citizenship and Immigration Services (USCIS) and the Social Security Administration (SSA)), technological advances and the call from President Bush for comprehensive immigration reform a new approach to worksite enforcement evolved within ICE. Cherylle C. Corpuz, of counsel in the Philadelphia office of Blank Rome LLP, has extensive experience in all aspects of immigration law and currently manages Blank Rome's immigration practice. She can be reached at Corpuz@BlankRome.com. Manuela M. Morais, senior associate with the firm, focuses her expertise on global immigration, as well as employer compliance and due diligence issues. She can be reached at Morais@BlankRome.com. Human Resources 2009 Winter Edition 39

ICE s enforcement actions are a far cry from the traditional IRCA penalties. These worksite enforcements incorporate multiple investigations and criminal charges that have resulted and will continue to result in serious felony charges for both employees and their employers. For this reason, employers must carefully monitor their hiring practices, from the highest level down to their work force, and implement a corporate policy that assists employees in addressing and properly resolving issues relating to unlawful employment. ICE Operations An Overview of Recent Activity and Cost to Employers According to ICE press releases, worksite enforcement in fiscal year 2007 resulted in $30 million in civil judgments, restitutions and criminal fines, more than 4,000 administrative arrests and 863 criminal arrests of employees and their employers. The latest available count for fiscal year 2008 includes more than 2,900 administrative arrests and approximately 1,035 criminal arrests involving 914 employees and 121 employers. The ICE has taken these actions in partnership with other federal agencies, including the USCIS, SSA, Department of Justice, Internal Revenue Service, Department of Labor (DOL) and Federal Trade Commission. The following are examples of law enforcement efforts over the last eight months (see box). DATE COMPANY INDUSTRY STATE February 2008 March 2008 April 2008 Universal Industrial Sales National Guard Air Base contractors Specialty Inc. Wood Products Guardrail, bridge rail, sign structures manufacturer Military installation Pallet manufacturing Utah 57 Tennessee 34 Idaho 13 April 2008 Lansdowne Resort Luxury hotel Virginia 59 April 2008 April 2008 April 2008 April 2008 April 2008 May 2008 June 2008 Azteca, Don Lorenzo, El Caporal (NY), Jalapeno Loco, La Herradura, El Caporal (W.Va), Nogales Pilgrim s Pride Shipley Do-Nut Flour and Supply Nash Gardens Naylor Concrete Agriprocessors Aerospace Manufacturing Technologies Seven Mexican restaurants Chicken processing Baking materials supplier Landscaping and nursery Little Rock National Airport contractor Kosher meatpacking plant Aircraft parts manufacturer New York, Ohio, Pennsylvania, West Virginia Arkansas, Florida, Tennessee, Texas, West Virginia NUMBER ARRESTED 56 311 Texas 27 Texas 28 Arkansas/ Oklahoma 25 Iowa 389 Washington 32 40 Winter Edition Thompson Publishing Group

DATE COMPANY INDUSTRY STATE July 2008 August 2008 August 2008 September 2008 Colorado Precast Concrete Dulles International Airport contractors Howard Industries SunValley Group Industrial construction Critical Infrastructure facility Electric transformer manufacturer Wholesale flower grower Colorado 18 Washington, D.C. 42 Mississippi 595 California 24 NUMBER ARRESTED The public perception may be that only certain types of employers in particular industries and states regularly hire unauthorized workers, and therefore the ICE targets only those stereotypically identified as violators. A review of these examples shows, however, that law enforcement efforts are country-wide and not targeted to just one specific industry sector or geographical area. It is interesting to note that the employer s size which in the past may have been important in terms of enforcement priorities has not been as much of a factor in determining which employers to target. In conjunction with this, it is also interesting to note that the number of arrests varies significantly among the ICE raids. These facts highlight two very important points of interest for all employers: 1) the ICE is not discriminating against any employer, big or small, in its efforts to curtail unlawful employment practices through the use of raids; and 2) the ICE has the resources to commit to large- and small-scale operations that result in only a handful of apprehensions and removals. The ICE s use of worksite raids as an enforcement tool is controversial (see box). Criticism and Aftermath of Large ICE Workplace Raid The U.S. Conference of Catholic Bishops called a press conference on Sept. 10, 2008 in response to the largest single-workplace ICE raid that has ever occurred a raid at Howard Industries in Mississippi on Aug. 25, 2008 that resulted in the arrests of approximately 600 workers. Consistent with other ICE operations, ICE agents, heavily armed and wearing flak vests, stormed the facility, sealed all entrances and surrounded the facility. Workers were segregated and interrogated without having legal counsel present before being arrested, handcuffed and loaded onto waiting buses to be taken to detention facilities. Records were removed from the premises and management was questioned about their hiring processes. All this activity took place in an atmosphere of sudden chaos, an environment the ICE purposefully created, the Conference charged. It denounced such raids as unacceptable in a civilized society. During a raid, the element of surprise coupled with chaos leaves the employer and its employees vulnerable and disoriented. Although how to respond during a raid is outside the scope of this chapter, it suffices to say that every employer should have a plan in place if a raid does occur, including designating individuals to review the search warrant and immediately contact legal counsel. Additionally, individuals should be assigned to ICE officers to monitor closely and record their specific actions and lines of questioning. This information will be of crucial importance if the employer is officially charged. Individuals should also be assigned to make a list of any items ICE agents seize and confiscate during a raid. Human Resources 2009 Winter Edition 41

Putting aside the emotional human trauma associated with the aggressive methods used during a raid, it is important to understand the various costs to both the employee and the employer of such enforcement actions. In addition to the civil penalties and criminal prosecutions of executives, managers and employees, there is the potential cost to the employer s reputation with business partners and clients, as well as the obvious cost incurred due to a sudden reduction in work force. For example, due to the number of employees arrested at Howard Industries, the company was forced to completely shut down due to a lack of sufficient work force. How Are Operations Triggered? Although the list is not all-inclusive, these are some triggers known to have resulted in the ICE investigating an employer: the number of SSA-issued no-match letters to a single employer; the number of employer correction requests from a single employer to SSA to correct employee records; immigration related complaints filed with USCIS, DOL/Wage and Hour; Department of State; Equal Employment Opportunity Commission (EEOC); or any other local, state or federal agency relating to employer immigration violations or noncompliance; and tips from current or past employees, disgruntled employees, unions and competitors. The ICE encourages employers to monitor trends in the work force. An example of such a trend is an atypically large number of Form I-9 claims to U.S. citizenship in companies doing business in industries that historically employ a large percentage of non-u.s. citizens. Immigration-related Criminal Charges and Penalties The cost to employers of disobeying the nation s immigration laws is heavy. The penalties for immigration-related violations are severe and follow a lengthy list of potential criminal charges against noncompliant employers (see box). For this reason, employers shouldn t turn a blind eye to what may be going on with their work force. The good news, however, is that an employer can mitigate this impact by taking proactive compliance measures, such as voluntarily participating in government programs. IRCA Liabilities and Penalties Under IRCA: Generally speaking, there are three categories of employer liability: 1) hiring violations, which involve knowingly hiring or continuing to employ unauthorized workers; 2) paperwork violations, which include failure to verify employment eligibility on the Form I-9, properly complete or retain the Form I-9 or to present I-9 forms when a government agency requests them; and 3) document fraud, which includes knowing use or acceptance of fraudulent documentation to satisfy the Form I-9 requirements. The penalties for these violations include: Penalties for Hiring Violations: Knowingly hiring unauthorized workers 1st offense: $275 - $2,200 (per worker) 2nd offense: $2,200 - $5,500 (per worker) 42 Winter Edition Thompson Publishing Group

Additional offenses: $3,300 - $5,500 (per worker) IRCA Liabilities and Penalties (continued) Pattern or practice of knowingly hiring unauthorized workers: Civil penalties, plus criminal penalty of $3,000 (maximum), plus six months imprisonment (maximum) Penalties for Paperwork Violations Civil fine of $110 to $1,100 (per worker) Penalties for Document Fraud First-time violations: $275 - $2,200 (per document) Subsequent violations: $2,200 to $5,500 (per document) Whether the company is small, medium or large, the civil penalties listed above are not insignificant when considered in the aggregate. More than one kind of liability could be found and when assessed in the aggregate quickly adds up. Furthermore, the possibility of criminal sanctions is a real one, given the more aggressive stance being taken by the relevant law enforcement authorities. ICE: Below is a list of some of the criminal charges being brought against employers: unlawful employment of aliens; harboring of illegal aliens; inducing, aiding or encouraging illegal aliens to reside or remain in the United States for the purpose of commercial advantage or private financial gain; fraud and misuse of immigration documents; aggravated identity theft; Social Security fraud; mail and wire fraud; evasion of federal taxes; money laundering; forgery; and conspiracy to or aiding and abetting any of the above. Case in point: On Feb. 28, 2008, a grand jury returned a six-count felony indictment against five current managers of the Pallet Management Division of IFCO Systems North America. The charges include: conspiracy to harbor illegal aliens; aiding and abetting the harboring of illegal aliens; conspiracy to encourage and induce illegal aliens to reside in the United States; aiding and abetting the encouragement and inducement of illegal aliens to reside in the United States; and conspiracy to transport, and the transportation of, illegal aliens for the purpose of commercial advantage and financial gain. The charges carry a five- to 10-year maximum prison term and a maximum fine of $250,000. The indictment came after an employee tipped off ICE with a report about workers ripping up their W-2 forms and a manager who responded to that employee s inquiry with a statement that these workers were illegal aliens with fake Social Security cards who had no intention of filing income tax returns. As a result of the ensuing investigation, nine IFCO worksites were searched, including the headquarters; 40 worksites were subject to raids; and approximately 1,200 unauthorized workers and seven current and former managers were arrested. Human Resources 2009 Winter Edition 43

Measures Employers Should Take No employer is entirely immune from an ICE action. As indicated above, various triggers could subject the employer to investigation. Nonetheless, an employer can and should take affirmative steps to minimize the likelihood that it will be investigated and to mitigate any penalties that could be imposed. The most important step an employer can take in its defense against the ICE is to have and enforce a written, established corporate compliance program. To this end, an employer would be prudent to discuss two voluntary governmental programs that can serve as frameworks for developing corporate best practices. The SSA and ICE administer these programs; their purposes are different, but both address issues that trigger ICE investigations namely, No-Match Letters and I-9 records. Participation in Voluntary Government Programs An employer s voluntary participation in government programs may lessen the likelihood of an ICE action against it or if an action ensues, the severity of the sanction. SSNVS To ensure accuracy of an employee s Social Security number (SSN) and thus reduce or avoid the possibility of receiving No-Match Letters from the SSA, an employer may voluntarily register to use the Social Security Number Verification Service (SSNVS). This service allows companies to match their employees names to their Social Security records. For new hires, the system allows a company to verify up to 10 names and SSNs (per screen), and the results are instantaneous. For more extensive searches, including the verification of an entire company payroll database, the information can be uploaded and results can be obtained the next business day. This service is available to any employer. The only caveat is that the service can only be used to verify current and former employees and only for wage reporting (W-2) purposes. Thus, employers should not rely on this service as a means to verify an individual s immigration status or work eligibility. Additionally, if this service is used, employers should use this consistently and not target selected populations within the work force. A final note regarding the SSNVS system: It may not be used for prospective hires. An employee s offer and acceptance must have occurred at the time that the SSN is verified through this service for W-2 purposes. Registration to use SSNVS can be made through the following link: http://www.ssa.gov/bso/bsowelcome.htm. IMAGE ICE has endorsed the use of a joint government initiative known as the ICE Mutual Agreement between Government and Employers (IMAGE) program. This voluntary program offers employers education and training on proper hiring procures, detection of fraudulent documents, proper use of E-Verify and anti-discriminatory procedures. In exchange for this tutoring and training, the employer agrees to take specific action, including: completing a self-assessment questionnaire; enrolling the company in E-Verify; enrolling in the SSNVS; 44 Winter Edition Thompson Publishing Group

adhering to IMAGE Best Employment Practices; undergoing an I-9 audit that ICE officers conduct; and signing an official IMAGE partnership agreement with the ICE. ICE Best Practices require the employer to take on several responsibilities relating to policy implementation, audits and reporting. Following are ICE-endorsed IMAGE Best Practices (http://www.ice.gov/partners/opaimage) (see box). IMAGE Best Practices 1) use the DHS employment eligibility verification program (E-Verify, currently) to verify the employment eligibility of all new hires; 2) establish an internal training program on the hiring process, with annual updates, that is, on how to manage completion of Form I-9 and on how to detect the fraudulent use of documents in the I-9 process, and cooperate with the ICE to make employees available for ICE training sessions as deemed appropriate; 3) limit the I-9 and E-Verify process to 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; 4) arrange for an external auditing firm or a trained employee not otherwise involved in the I-9 process to conduct annual I-9 audits; 5) establish a self-reporting procedure for the reporting to the ICE of any violations or discovered deficiencies; 6) ensure and document the definitive resolution of no-match letters from the SSA, per SSA and DHS guidance; 7) establish a tip line mechanism (inbox, e-mail, etc.) for employees to report activity relating to the employment of unauthorized aliens, and a protocol for responding to employee tips; 8) establish and maintain appropriate policies, practices and safeguards against use of the verification process for unlawful discrimination, and to ensure that U.S. citizens and authorized workers do not face discrimination for hiring, firing or recruitment or referral for a fee because of citizenship status or national origin; 9) communicate IMAGE guidelines to other companies in the hiring network (such as employment services/agencies) and contractors/subcontractors. Work toward incorporating IMAGE guidelines into relationships and agreements with these companies and establish a protocol for assessing the company s contractors and subcontractors adherence to the best practices guidelines; 10) submit an annual report to the ICE to track results and assess the effect of participation in the IMAGE program that should include: identification of individuals removed from employment in accordance with participation with the IMAGE program; instances and resolution of SSA No-Match Letters; major organizational changes; and identification of any vulnerabilities that unscrupulous employees and unauthorized aliens are exploiting when appropriate, ICE encourages timely disclosure in advance of the annual report. Discovery or allegations of substantive criminal violations will be immediately reported to ICE (in accordance with best practice #5), whereas technical violations may be documented in the annual report. Human Resources 2009 Winter Edition 45

Although the IMAGE program s purpose is to develop a more secure and stable work force and to educate and enhance awareness of document fraud, employers should proceed with caution with program enrollment and participation. It should be noted that becoming IMAGE Certified, a distinction that the ICE believes will become an industry standard, in no way shields the employer from liability. While the ICE has indicated that participation in the IMAGE program could lessen the likelihood that the employer is found in violation and may be considered a mitigating factor in determining civil penalty (fine) amounts if they are levied the language is very speculative. Additionally the agency has said nothing on the impact that program registration and participation have on criminal charges. The lack of a guarantee of safe harbor, coupled with some of the program s unduly burdensome requirements (including enrollment in E-Verify and the reporting obligations), render this program unfeasible for most employers. Four Goals for Every Employer For employers that are prepared to implement a policy outlining procedures the company can and will take to reasonably reduce the hiring of unlawful aliens, but that do not want for various reasons to participate fully in the IMAGE program, an option is to create a solid corporate compliance program that mirrors the ICE s 10 best practices. A written policy will also serve as evidence of good-faith compliance if there is an audit or raid. Four goals should be considered in developing a corporate compliance program: 1) establishing and implementing a comprehensive policy; 2) conducting internal audits with a system of check and balances to ensure reliability; 3) education and training of employees; and 4) changing the corporate culture. In general, a comprehensive policy should incorporate a system of checks and balances to ensure reliability. It should provide for mandatory auditing of I-9 records, as well as hiring practices. The obligation to enforce the corporate compliance program should be vested at the most senior level, and there should be prompt investigation and resolution of all alleged violations. Lastly, in accordance with ICE best practices there should be a mechanism in place for reporting complaints or violations. This mechanism should permit employees of the company to report allegations to the company without fear of employer retaliation. For companies with several offices, each should be made aware of the policy s existence and the company s commitment to enforcing such policy uniformly within the company. Establish and Implement a Comprehensive Policy A comprehensive immigration policy will differ based on the company s immigration make-up, its business and the policies that are already in place. At a minimum, however, a solid policy will consist of the following: 1) Statement. The policy should first consist of an overall statement of the company s goal and mission regarding the implementation and enforcement of its immigration policies. It should have upper management s endorsement and should indicate the company s willingness to comply with all relevant immigration laws. 2) Completion and re-verification of I-9 records. The policy should indicate the time for completion of the I-9 record. As a reminder, employers are required to complete 46 Winter Edition Thompson Publishing Group

Form I-9 for each new or rehired employee on or before the first day of employment. Within three business days, employers must review the employee s original document(s) to verify the employee s identity and employment authorization. This part of the policy should also address updating the I-9 record and retaining copies of documents, and also deal with situations when the I-9 cannot be completed within the three days of hire. 3) Retention. The policy should address the retention of the records, specifically the length of time for which certain documents must be retained and their physical location. For Forms I-9, the company should maintain records throughout the period of employment. For employees who have been terminated, the I-9 should be discarded after either three years after the date of hire, or one year after the date employment terminated, whichever is later. For practical purposes, the I-9 records should generally be kept apart from personnel and payroll records. This section should also address other mandatory immigration related documents in the event of an audit, namely the public access file (for employers that have H-1B nonimmigrant workers) and the PERM recruitment reports (for foreign nationals whom employers have sponsored for labor certification). For the DOL records that must be maintained in the event of an audit, the company should maintain payroll records for the alien and any other individuals with experience and qualifications similar to those of the alien who are in the same position at the place of employment, for a period of three years from the date of the records creation. 4) Authenticity of Documents. Detail guidance on steps and procedures to be taken in the event of document issues. The policy should specifically identify what steps should be taken and who within the company should be notified when there are questions related to authenticity of documents presented for identity and/or employment eligibility. It should also summarize issues relating to steps the company will take when an employee is found to have committed fraud. It should address steps that the company will take before and after the termination, including the re-hiring of the individual. It should also provide a reporting structure to ensure that management be immediately notified of any situations that arise. 5) Fraud. The policy should provide protocol in dealing with situations when there is constructive knowledge of fraud. The company s policy should clearly note that any employee with knowledge of any employee s unauthorized employment should report that knowledge to management. It should also address situations when an employee knowingly accepts a fraudulent document. There should be a clear message in the policy handbook (and it should be applied) that engaging in fraud is not tolerated and will serve as immediate grounds for termination. 6) Tracking of expired documents. The policy should develop a tracking system to monitor expiration dates of employees I-9 documents. A tickler should be set for follow-up at the six- and three-month interval before the document s expiration date. To prevent interrupting employment once the work authorizing document expires it is prudent to send correspondence to the employee at the six-month mark advising him or her that I-9 re-verification is necessary. 7) SSN No-Match Letters. The policy should detail steps to take in resolving issues relating to SSA No-Match Letters. The policy should not only indicate how to correct an internal error in the event the employer s records are inaccurate, but should also deal Human Resources 2009 Winter Edition 47

with steps employees must take to rectify an SSN error and the steps an employer will take if left unresolved. 8) Conduct internal audits with a system of checks and balances to ensure reliability. The employer should conduct an audit of its I-9 records, preferably by counsel, an external firm or an experienced employee who otherwise does not regularly complete the I-9 forms. After the initial audit, subsequent self-audits at regular intervals (at one year or six months) based on the size of the work force should be part of the employer s normal practice. The internal audit should access the current state of I-9 forms; in particular, note errors and discrepancies on I-9 records. Written guidance on how to correct technical errors should be outlined, as well as steps to be taken in the event of failures to complete the I-9 record properly. Audits to confirm that wage and hour issues are in order should be undertaken as well. For H-1B employers, audits to confirm proper maintenance of labor certification applications, and that the prevailing wage or actual wage is being paid to the H-1B nonimmigrant, should be done. Additionally, for labor certifications, an audit should be completed to confirm that the company has the required documentation to establish all the necessary PERM recruitment steps, and that there are no issues with the payment of the prevailing wage. 9) Education and training of employees. Employers should conduct regular I-9 training for all employees involved in the hiring process and for upper management. Training should also address pre-hire inquiries and the completion of the I-9 form to assist the employer in avoiding national origin and citizenship discrimination. A written policy should identify what questions can be asked of prospective hires on the employment application and at the time of interview. For I-9 purposes, the policy should also be clear on this point the choice of documentation in support of the I-9 is at the employee s sole discretion. The employer cannot, and should not, request to see specific document, or refuse to accept a document, unless there is a question about its authenticity. Employers should also call upon immigration counsel to provide updates regarding changes in immigration law that may have an impact on the I-9, and generally if possible, have counsel or an externally or internally trained individual provide an overview of the acceptable documents for I-9 purposes. Given that many individuals completing the I-9 are not completely familiar with the appearance of genuine immigration documents and may not necessarily know enough about immigration law to understand how a document is procured this training can be of enormous benefit. 10) Change the corporate culture. Through criminally prosecuting employers and employees for unlawful employment practices, the ICE has essentially created a deterrence that previously used enforcement actions under IRCA did not. And, thus it is important for employers to change their mindset about immigration, and in some cases how they operate their business. Once a comprehensive immigration compliance policy has been put into place, it should become part of the corporate culture. Employers, at all levels, should reinforce the policies set out as part of their normal course of business. Conclusion The ICE worksite enforcement program is a key component to the DHS overall mission and strategy, and is a critical part of DHS Secure Border Initiative. As daily media and ICE press releases make clear, it is evident that worksite enforcement of immigration 48 Winter Edition Thompson Publishing Group

laws is a top priority of the ICE, and worksite raids and audits are likely to continue and escalate in numbers in the future. Those employers that institute best hiring practices, including IMAGE best hiring practices, will be in the best position to deal with the chaos and aftermath of a raid or audit. At the other end of the spectrum will be those employers that blatantly abuse the system and encourage and foster illegal immigration for private gain. In light of current ICE objectives, these employers are the target of future ICE investigation as it is clear that the ICE is dedicated at all costs in identifying and prosecuting employers who knowingly undermine immigration law. In the middle of the spectrum are most employers. Those who in good faith can and should rely on their company s completed I-9 records, but that may have some room for improving their policies and processes with respect to their hiring practices. To these employers this chapter should provide some key issues to contemplate and discuss internally, and should provide guidance on implementing a solid immigration compliance program that should satisfy the ICE of good faith compliance in the event of a raid or audit. Each employer should remember that their primary role in the hiring process is not to discriminate against applicants, or to take on the position of an immigration specialist when confirming eligibility to work. Still an employer can implement positive changes to assist with worksite compliance, including: 1) implementing a written comprehensive policy; 2) providing continued education about the I-9 process; 3) conducting regular internal audits with a check and balance system; and 4) changing the corporate culture to understand the importance, and accept, best hiring practices. Human Resources 2009 Winter Edition 49

For More Information This article is one of 25 chapters on the most recent HR developments published in Human Resources 2009: Answers to Your 25 Top Questions, Winter Edition. Copyright Thompson Publishing Group. To obtain a discount on the purchase of the book, go to http://www.thompson.com/hr2009 and click on Add to Cart. On the Shopping Cart Page, enter friends1 in the Enter Web Offer Code field. Then click on Checkout to get your 25 percent discount.