How-To-Guide: Establishing Your Company’s Internship Program Industrial Distribution’s Recruitment Program Helping your company

How-To-Guide:
Establishing Your Company’s Internship Program
®
Industrial Distribution’s Recruitment Program
Helping your company reach, engage, prepare and connect
with tomorrow’s industrial distribution workforce.
Alliance
Partners
FOUNDATION
Building the Industrial
Careers PathwaySM
As of June 2014
his guide is meant to be a starting point for those interested in establishing an
internship program in their organization. You may ask yourself, “Why should I
establish an internship in my company? How will I benefit from doing this?”
Establishing an internship in your organization will help you develop possible future
job candidates, raise your company’s profile in your community and among job seekers
and you’ll become a vital link in ICP’s mission to secure a skilled industrial distribution
workforce for today and tomorrow.
What Is an Internship?
How Long Do Internships Last?
Basically, an internship is a formal program that provides
practical experience to students in a specific occupation
or profession where they can learn more about what
is involved in that occupation through experiencing it
firsthand in an organization. Internships provide a benefit
to both the intern and the company hiring the intern.
Internships have a specified beginning and end date
agreed upon by both the intern and the employer.
Internships usually correspond with the educational
institution’s (high school, community/vocational college
or university) quarter or semester system. Internships
will often require a foundation of learning in order for
students to be able to perform credit-specific tasks or
functions, so interns are typically further along in their
studies.
Internships last for a specific period of time agreed to by
both the employer and the intern. Internships may lead
to permanent full-time employment, but do not have
to. They offer the ability to develop work experience
while still in school. Internships may be paid or unpaid:
however, unpaid internships are fading out. Internships
provide a workplace-based educational experience for the
student.
In most cases, internships are
Internships
offered through an educational
should
institution – community/technical/
benefit both
vocational college, university, jobthe company
training program or high school
and the
and provide a way to earn course
intern.
credit while developing work
experience. Internships provide a
way for students to “try on the profession” and determine
how well it “fits.”
>
An internship is a learning experience and, in many
cases, an intern may earn course credit for the time they
spend in your organization. You will need to provide
opportunities for the student to develop skills such
as preparing a budget, making a sales call, doing a
presentation, using a specific piece of equipment, etc.
The learning experiences should be agreed upon ahead
of time by the educational institution, the intern and your
organization.
Internships can be full-or part-time for the length of the
internship. Interns can work a certain number of hours
each day or come in only on specific days. All this needs
to be determined and specified before the intern starts.
Do I Need to Be a Large Company to
Hire an Intern?
Companies of all sizes can benefit from having an intern.
Small companies can perhaps benefit more than larger
organizations since interns bring the energy of youth and
knowledge of current technology as well as new ideas
that may not be present in current employees. Interns are
a great way to bring in a potential new hire to see how
they fit in the organization.
What Do Students Want from an
Internship?
A recent study conducted in early 2014 by Millennial
Branding (http://millennialbranding.com) and Internships.
com found the three things high school students
want from an internship are:
• D
evelop
new skills
experience
M
entoring/networking
• W
ork
Internships should benefit both the company and the
intern.
•
ICP Internship How-to | 2
For college students, the top three are:
• W
ork
experience
new skills
J ob offers
• D
evelop
•
Additionally, internships provide opportunities to gain a
realistic view of industrial distribution, how the workplace
functions and the operations of a particular organization.
If you are serious about establishing an internship at
your company, make sure you let students know that
your internship will provide these types of opportunities.
Then build in opportunities to develop new skills. Make
sure you provide them with a mentor. You should also
let them know that the internship could lead to full-time
employment, although not a guarantee.
Do I Need to Pay an Intern?
There has been some debate over whether or not
an intern is an employee. This has been found to be
dependent on the specific circumstances “surrounding
their activities” on the premises of the employer.
A U.S. government publication is available and provides
general information on whether an intern must be paid
under the Fair Labor Standards Act. It is Fact Sheet #71:
Internship Programs Under The Fair Labor Standards Act
and is available at. It can be found at the end of this guide.
Many provinces in Canada are putting together guidelines
for whether or not an intern must be paid. These
guidelines/regulations differ by province. There does not
appear to be a government document that covers all
of Canada and it is suggested that Canadians visit their
provincial website to obtain current information.
The U.S. Guide offers a “Six Prong Test” to determine
whether or not an employment relationship exists. If ALL
of the following six criteria are met, it is possible that the
intern would not have to be paid. These have been taken
directly from the Fact Sheet.
1. T
he internship, even though it includes actual operation
of the facilities of the employer, is similar to training
which would be given in an educational environment;
2. T
he internship experience is for the benefit of the
intern;
3. T
he intern does not displace regular employees, but
works under close supervision of existing staff;
4. T
he employer that provides the training derives no
immediate advantage from the activities of the intern;
and on occasion, its operations may actually be
impeded;
5. T
he intern is not necessarily entitled to a job at the
conclusion of the internship; and
3 | ICP Internship How-to
6. T
he employer and the intern understand that the
intern is not entitled to wages for the time spent in the
internship.
recommended that you consult
< Itwithis highly
your attorney regarding whether or not
you need to pay your intern. Laws vary by state
and province and you should consult with your
attorney to determine if your state or province
requires interns be paid.
Why Should I Start an Internship
Program?
There are many reasons your company might want
to start an internship program, but perhaps the most
compelling is to start building a pool of potential
job candidates for open positions as they become
available. Additionally:
• Y
ou
will get to know these young people and see how
they work.
• Y
ou
will eliminate much of the learning curve if you
decide to hire them as full time employees since these
candidates have already been trained.
• Y
ou
will know ahead of time if they are good workers or
a good fit in your organization since they already know
your company.
• I f
they have a good experience, even if they don’t
become a full-time employee, they can provide you with
names of other possible candidates.
• Y
ou
will support your community by providing learning
opportunities for students.
• Y
ou
will develop a relationship with a college,
community college or training program that builds your
organization’s visibility among potential job candidates.
• Y
our
involvement will bring you names of potential job
candidates that your competition won’t get.
• Y
ou
will have insight into the Millennial generation and
their attitudes, skills, etc.by seeing how they function in
the workplace.
• Y
ou
can shape attitudes about industrial distribution
and industrial careers. Interns will see firsthand that the
environment is not a dirty grimy place to work.
• Y
ou
can provide supervisory experience to current
employees you would like to observe by assigning them
to train your intern.
• P
roviding
new responsibilities to current employees
gives them new experiences and makes them more
valuable employees.
• Y
ou
can have an addition to your team that works on a
project, produces a report, prepares an analysis, preps
for a sales call, etc.
Where Do I Find Potential Interns?
Finding the right academic partner makes a great
difference. The best place to look is at a community/
vocational/technical college in your area. You can
search using community/vocational/technical college
and your location to find these types of educational
facilities in your area. There are also specific websites
you can search including: www.trade-schools.net; www.
tradeschooladvisor.com and the white pages for your area.
On the school’s website see where “job placement” or
“internship program” falls in the organization. It may
be under student services, career center, placement,
guidance, counseling or “other services.” Get the name
and contact information for the head of the department
and make an appointment to see them.
You should feel as if the school is supportive, helpful,
engaged and interested in working with you to make a
good match. A school with little experience in applied
technology may not have a good understanding of
industrial careers and industrial distribution.
They may also not have many students likely to be
interested in an internship with a distributor. On the other
hand, a good partner school can help you develop a good
student plan, understand issues of college credit and align
learning objectives with activities.
The best way to make sure you have a good base for
potential interns is to develop a relationship with someone
at your local high school or community/technical/
vocational college or job training program. It might be a
department head, specific course instructor or someone in
the placement office. Explain the kind of soft skills – good
listener, problem solver, team player – and any technical
skills such as “likes to know how things work or fix things”
etc. – that you are looking for in a candidate and ask
them to let you know when they come across someone
who might be a good fit. You can offer to speak to their
class on the field of industrial distribution or provide a tour
of your facility in return.
Although the educational institutions you are working
with may have posting requirements, it is a rule of thumb
that posting a position early will increase your chances
of getting the best candidates. There are online posting
opportunities that may attract students from anywhere
(www.internships.com), not just from specific schools, but
you should be sure to post the internship at the colleges,
community colleges and technical colleges in your area
that have applied technology programs. In addition, some
schools will have internship fairs, often in conjunction with
job fairs.
In addition to working with the appropriate personnel at
the educational facility, you can also place ads on bulletin
boards at schools and local retail establishments or pass
out flyers at career or job fairs. You can also ask your
current employees if they know of anyone that might be
interested. And, once you’ve had an intern on board, you
can always contact them for referrals.
ICP Internship How-to | 4
Make sure to include the basics on your posting:
• C
ompany
name, address, contact person with email
AND how to apply (phone, in-person, online, etc.)
• B
rief
background on your company and what you do
• W
hat
the intern will be doing (placing orders,
researching products, executing a marketing campaign,
etc.)
• W
hat
are the hours, pay, dress code
• W
hat
are the requirements – do they need to be
enrolled in a specific course; do they have to know a
specific computer application; do they have to be able
to work on their own, etc.
Put the same kind of information in your posting for an
intern as you would for any job opening you have. People
want to know what they will be doing, what skills they
need and something about you as an employer.
What Makes a Successful Internship
Program?
Management buy-in is crucial.
Without support from management and supervisors,
an intern program will not be successful. If the leaders
in a company don’t accept the investment of time and
energy necessary to fully involve interns in a meaningful
way, interns can be perceived as a burden or kept on the
sidelines without meaningful projects.
what they need to do better. They can’t wait until the end
of the internship to find out they have not been meeting
your expectations. Make sure their supervisor schedules
feedback sessions throughout the term of the internship.
Remember that in many cases this internship will
be the first real job your intern has had.
Make sure you provide your intern with a good Employee
Orientation. In many cases the intern won’t have a good
knowledge of exactly what is involved in the workplace.
They may need to have specifics reviewed such as:
•
Being late is not okay.
• I f
you are going to be late then you need to call your
supervisor.
• Y
ou
are expected to keep company information
confidential.
• T
he
appropriate dress code for the office does not
include flip-flops.
They may need help understanding the reporting structure
and how the parts of the organization work together.
Although you may have them sign that they have read the
organization “rules,” you might want to have a face-toface meeting to make sure they “get it.”
Be clear about what your requirements are.
Interns can range from high school students to postgraduates. Remember your intention is to provide a
meaningful workplace-based educational opportunity. An
internship appropriate for a high school student will be
very different from one of value to a college engineering
student.
There is someone in the organization that can
serve as a mentor or coach.
If there is no one in your organization who is willing to
take the time to mentor or coach your intern, the chances
of the program being a success greatly decrease. Your
intern needs someone they can ask questions of, get
information on the company culture, understand the
politics of the organization, and learn from. The intern’s
direct supervisor is not always able to fill this role. The
person who fills this role must want to do so. You cannot
simply pick someone and expect them to fill the role.
Make sure there is a feedback mechanism in place.
One thing the younger generation requires is feedback.
Your intern will want to know how they are doing and
5 | ICP Internship How-to
How Do I Prepare for Hiring an
Intern?
Your intern should be treated just like any other employee
and, like any new employee, an intern will want to know
in advance what he/she will be doing. You will want to
make sure that you tell everyone involved who the intern
is and when they will start.
Some things that your intern will need include:
• A
brief description/profile of the company that includes
company name, address, website, phone, and contact
person
• L
ist
of responsibilities including title, working hours and
hours per week, skills required
• O
rganizational
chart so they can see where things fit in
with adequate lighting, computer,
telephone and office supplies
The intern agreement should include:
• S
tudent
information including graduation date, title of
the internship, contact information
• D
esk/workstation
• C
ompany
• T
heir
• S
chedule
own computer log-on and email address
for establishing voice mail, including what is
an appropriate greeting
information including the contact information
for the direct supervisor
of hours/days to be worked
• I nstructions
• R
esponsibilities
• Office
• Job
codes for accessing the copier, entering the
building/office, parking permit, etc.
• P
rocedure
manual for the responsibilities they have
• E
mployee
manual with rules, regulations, expectations,
dress code, etc.
• I nformation
• H
ow
of all parties – intern (student),
educational facility, employer
responsibilities
• G
oals
and objectives
• I f
there is a final project required, a description of this
should be included
• D
ated
and signed by all parties
on your company goals and objectives
they will be evaluated
If you would provide something to a new employee,
you should provide that same item to your intern. There
should be a person assigned as the intern supervisor
with a plan for supervision that includes regular contact
and progress assessment. There should also be informal
contact and opportunities to meet with other employees.
The supervisor should be given adequate time to work
with the intern.
The intern’s goals should be aligned with the company
goals. Of course, the intern goals should follow the same
rules that apply to all goals of being specific, measurable,
realistic and few. In addition, remember that the intern
can and should have specific educational and skill-building
goals. Goals laid out for the intern should include both the
goals that are important to the intern (e.g. prepare a sales
call training manual) and to the company (e.g. assist in
warehouse reconfiguration).
A basic format for an internship goal could be:
Don’t assume that, after a few days or weeks, the intern
can work on his or her own. Structure regular (at least
weekly) contact to monitor progress, continue to educate,
troubleshoot and see if assignments need to be modified.
Connect the intern with other employees, answer
questions, get feedback and ideas from the intern and
assure that the intern is feeling he/she is benefiting from
the experience. The Millennial generation is known for
wanting lots of interaction, liking teamwork and looking
for gold stars and pats on the back.
• S
pecific
goal – Prepare a sales call training manual.
In many cases, the agreement you have with the
educational institution the intern attends will require
specific learning experiences for the intern to receive
course credit for the internship. These items will need
to evaluated and feedback provided to both the intern
and the instructor. These should be worked out ahead
of time with the instructor and become part of the intern
agreement.
• E
valuation
• T
asks
to accomplish the goal (how the goal will be
achieved).
–D
etermine the key pieces of information needed
when calling on a prospect
–D
evelop questions to ask the customer that will
determine customer needs
–T
alk with company sales reps and find out what they
think makes them successful
method (how it will be determined if the
goal has been met).
• D
eadline
for goal completion.
Many internships have failed because goals were not clear and understood by everyone
< CAUTION:
involved including the intern, the school, the company leaders, supervisors and employees who will be
working with the intern. Make sure the goals you set are simply stated and clear.
What Are Some Things We Should
Consider?
• D
o an Internship Program Assessment: Fill out the
Internship Program Assessment Form on pages 8-10
to make sure you cover everything and to determine if
your company is ready to start an internship program.
• K
eep
focus: It is easy to allow your intern to become
a “gopher” called on to do copying, run errands or
set up a meeting room. Stick to the responsibilities in
the job description as much as possible so that both
your organization and your intern find the experience
educational and valuable.
• Provide
context for the intern: Sometimes it is hard
for the intern to see why he or she is spending hours
putting together packets of materials. But if it is part of
meeting a defined goal or learning objective, it makes
sense. Millennials need to know how what they are
doing fits into the big picture. Make sure you tell them.
• A
ssign
a mentor to your intern: Give your intern
one person they can go to with questions about
the company, the job, the politics of the workplace,
people issues, etc. This individual MUST want the role
of mentor/coach and does not need to be the direct
supervisor. Having someone to go to when the need
arises could mean the difference between a great and a
bad experience.
• E
valuate
the total internship experience: Because
internships do take company resources, you will want to
have a company goal for your internship program that
you can use in assessing the value of the program and
considering how to increase company benefit for a good
return on company investment.
• P
rovide
opportunities for soft-skill development.
In many cases, this will be the first real workforce
experience for your intern. To help them as they move
forward into the world of work, give them opportunities
to talk about their assignments, give presentations to
you and your team, interact directly with customers and
suppliers and attend meetings.
Where Can I Learn More?
The ICP website is a great place to send your intern to
learn about the field of industrial distribution. The section
designed for the younger generation is www.idcareers.
org. There they can learn about possible career paths,
what OEM and MRO mean, what skill sets are needed for
full-time employment in the field.
ICP also has a course on the basics of the field called
Elements of Industrial Distribution. It is available online
or in print and has four modules that cover the field
of industrial distribution including an organizational
and functional overview as well as customer service
and marketing and profitability. Learn more at www.
industrialcareerspathway.org/elementsintro.
Two websites with additional materials are: www.
InternBridge.com that has many templates and
employer specific information and www.internships.
com which hosts many employer resources.
Additionally, you can contact us at [email protected] or
call 312.516.2100. We will be happy to work with you
to assist you in putting together an internship program at
your organization.
Industrial Careers Pathway is a program of the PTDA Foundation
230 West Monroe St., Suite 1410, Chicago, IL 60606.
©2014 Power Transmission Distributors Association Foundation.
Industrial Careers Pathway® is a registered trademark of the Power Transmission Distributors Association Foundation.
ICP Internship How-to | 7
Internship Program Assessment
The internship assessment is designed to answer the following questions in preparation for implementing an internship
program at your organization: Is your organization prepared to manage an internship program? What value can an
internship program bring to your organization?
Answers to the following questions will provide the basis of the internship job description.
1. W
ould your company benefit from the work of interns to write, research, identify business leads and provide overall
organization support?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
2. W
ould a formal internship program help your organization reduce staffing costs, including part-time and temporary
employee needs?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
3. W
ould having interns benefit current staff members by providing managerial and supervisory experience?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
4. D
o you have the support of senior management?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
5. What are the goals of your organization’s internship program?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
8 | ICP Internship How-to
Internship Program Assessment (cont.)
6. What type of project work (research, writing, marketing support, sales support, etc.) needs to be completed?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
7. Are specific skills required for the project work?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
8. Is there a preference for the intern’s area of study?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
9. Can your organization offer opportunities for unique industry experiences during the internship?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
10. What type of student are you willing to host? q College q High School q College or High School
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
11. What type of work environment can you offer to an intern?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
ICP Internship How-to | 9
Internship Program Assessment (cont.)
12. Do you have a mentor committed to supervise an intern?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
13. Is this a paid or unpaid internship? If unpaid, are there alternative forms of compensation that could be offered?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
14. What are the dates for this internship?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
15. Is this a part-time or full-time internship opportunity?
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
This Internship Program Assessment was developed by Robert Shindell, Ph.D., Intern Bridge, Inc. and is being used with
permission. For additional tools and templates, visit www.internbridge.com.
10 | ICP Internship How-to
U.S. Department of Labor
Wage and Hour Division
(April 2010)
Fact Sheet #71: Internship Programs Under The Fair Labor Standards Act
This fact sheet provides general information to help determine whether interns must be paid the minimum wage
and overtime under the Fair Labor Standards Act for the services that they provide to “for-profit” private sector
employers.
Background
The Fair Labor Standards Act (FLSA) defines the term “employ” very broadly as including to “suffer or permit
to work.” Covered and non-exempt individuals who are “suffered or permitted” to work must be compensated
under the law for the services they perform for an employer. Internships in the “for-profit” private sector will
most often be viewed as employment, unless the test described below relating to trainees is met. Interns in the
“for-profit” private sector who qualify as employees rather than trainees typically must be paid at least the
minimum wage and overtime compensation for hours worked over forty in a workweek. 
The Test For Unpaid Interns
There are some circumstances under which individuals who participate in “for-profit” private sector internships
or training programs may do so without compensation. The Supreme Court has held that the term "suffer or
permit to work" cannot be interpreted so as to make a person whose work serves only his or her own interest an
employee of another who provides aid or instruction. This may apply to interns who receive training for their
own educational benefit if the training meets certain criteria. The determination of whether an internship or
training program meets this exclusion depends upon all of the facts and circumstances of each such program.
The following six criteria must be applied when making this determination:
1. The internship, even though it includes actual operation of the facilities of the employer, is similar to
training which would be given in an educational environment;
2. The internship experience is for the benefit of the intern;
3. The intern does not displace regular employees, but works under close supervision of existing staff;
4. The employer that provides the training derives no immediate advantage from the activities of the intern;
and on occasion its operations may actually be impeded;
5. The intern is not necessarily entitled to a job at the conclusion of the internship; and
6. The employer and the intern understand that the intern is not entitled to wages for the time spent in the
internship.
If all of the factors listed above are met, an employment relationship does not exist under the FLSA, and the
Act’s minimum wage and overtime provisions do not apply to the intern. This exclusion from the definition of
employment is necessarily quite narrow because the FLSA’s definition of “employ” is very broad. Some of the
most commonly discussed factors for “for-profit” private sector internship programs are considered below.
FS 71
Similar To An Education Environment And The Primary Beneficiary Of The Activity
In general, the more an internship program is structured around a classroom or academic experience as opposed
to the employer’s actual operations, the more likely the internship will be viewed as an extension of the
individual’s educational experience (this often occurs where a college or university exercises oversight over the
internship program and provides educational credit). The more the internship provides the individual with skills
that can be used in multiple employment settings, as opposed to skills particular to one employer’s operation,
the more likely the intern would be viewed as receiving training. Under these circumstances the intern does not
perform the routine work of the business on a regular and recurring basis, and the business is not dependent
upon the work of the intern. On the other hand, if the interns are engaged in the operations of the employer or
are performing productive work (for example, filing, performing other clerical work, or assisting customers),
then the fact that they may be receiving some benefits in the form of a new skill or improved work habits will
not exclude them from the FLSA’s minimum wage and overtime requirements because the employer benefits
from the interns’ work.
Displacement And Supervision Issues
If an employer uses interns as substitutes for regular workers or to augment its existing workforce during
specific time periods, these interns should be paid at least the minimum wage and overtime compensation for
hours worked over forty in a workweek. If the employer would have hired additional employees or required
existing staff to work additional hours had the interns not performed the work, then the interns will be viewed as
employees and entitled compensation under the FLSA. Conversely, if the employer is providing job shadowing
opportunities that allow an intern to learn certain functions under the close and constant supervision of regular
employees, but the intern performs no or minimal work, the activity is more likely to be viewed as a bona fide
education experience. On the other hand, if the intern receives the same level of supervision as the employer’s
regular workforce, this would suggest an employment relationship, rather than training.
Job Entitlement
The internship should be of a fixed duration, established prior to the outset of the internship. Further, unpaid
internships generally should not be used by the employer as a trial period for individuals seeking employment at
the conclusion of the internship period. If an intern is placed with the employer for a trial period with the
expectation that he or she will then be hired on a permanent basis, that individual generally would be considered
an employee under the FLSA.
Where to Obtain Additional Information
This publication is for general information and is not to be considered in the same light as official statements of
position contained in the regulations.
For additional information, visit our Wage and Hour Division Website: http://www.wagehour.dol.gov
and/or call our toll-free information and helpline, available 8 a.m. to 5 p.m. in your time zone, 1-8664USWAGE (1-866-487-9243).
U.S. Department of Labor
Frances Perkins Building
200 Constitution Avenue, NW
Washington, DC 20210

1-866-4-USWAGE
TTY: 1-866-487-9243
Contact Us
The FLSA makes a special exception under certain circumstances for individuals who volunteer to perform services for a state or
local government agency and for individuals who volunteer for humanitarian purposes for private non-profit food banks. WHD also
recognizes an exception for individuals who volunteer their time, freely and without anticipation of compensation for religious,
charitable, civic, or humanitarian purposes to non-profit organizations. Unpaid internships in the public sector and for non-profit
charitable organizations, where the intern volunteers without expectation of compensation, are generally permissible. WHD is
reviewing the need for additional guidance on internships in the public and non-profit sectors.