Position requires i Ten 10 years of experience in a director or managerlevel role for a global security and logistics company; ii five 5 years of concurrent experience developing global security and risk operational standards, conducting and reviewing internal audits, and leading loss investigations and implementing risk mitigation strategies, operational standards and operational efficiencies, and experience with security logistics in Latin America and Africa. Position requires 30 domestic and international travel.br br Although the requirements for this position exceed the SVP of the OES occupational classification, such requirements are supported by business necessity and are common within the industry. In support of business necessity, at this time, BGSi is proactively providing the DOL with evidence of the Business Necessity for the Application in an effort to avoid an audit. The delays associated with an audit would have significant negative consequences on both Mr. Watson and BGSi as time is of the essence.br br The Brinks Company is the oldest and largest security transportation company in the world with 160 branch operations in the US, 40 in Canada, and wholly or partially owned subsidiaries in more than 50 countries around the globe. BGSi is a subsidiary and a division of The Brinks Company, a publicly traded company. The most recent Form 10K Annual Report for The Brinks Company evidences that the company had revenue of over 3 billion dollars.br br All listed job requirements are justified by business necessity. As an initial matter, it should be noted that this position is not an entry level position, but rather, a directorlevel position for a multinational, multibilliondollar, publicly traded company. To be qualified for the position of Global Operations Director, a candidate must possess ten 10 years of experience in a director or managerlevel role for a global security and logistics company.br br This is a key directorlevel position that requires managerial experience within the industry since this position is responsible for managing this essential business unit. Thus, ten 10 years of experience in a director or managerlevel role for a global security and logistics company is directly related to the duties of our Global Operations Director position. A minimum of five 5 years of experience developing global security and operational standards are essential because of the high value commodities moved by BGSi and is a key component of this position. Security protocols are of paramount importance and the Global Operations Director position is critical for sharing best security practice whilst implementing the various operational standards and initiatives. Thus, the five 5 years of concurrent experience is directly related to performing the duties of our Global Operations Director position.br br Furthermore, ONet states that to become a General and Operations Manager under 111021, Most of these occupations require a fouryear bachelors degree, BUT SOME DO NOT. Additionally, there are current job postings for similar positions in the industry that do not require a degree, but rather, require extensive relevant experience. Therefore, BGSis job requirements are consistent with industry standard and reasonably related to the occupation and essential to perform the job in a reasonable manner. We submit that, in totality, the above evidence demonstrates that the requirements as listed on the Form ETA 9089 for the job opportunity of Global Operations Director are supported by business necessity. Please see Declaration of James Hennessy, VP Operations, uploaded to the DOL portal in support of business necessity along with evidence of BGSis compliance with 20 CFR 656.10d, 20 CFR 656.17 e, 20 CFR 656.17 g1, and 20 CFR 656.24b2i. We respectfully request that DOL process and certify the application without an audit.

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