What constitutes the initial step in penalty accrual against a PPO?

The initial step in penalty accrual against a Private Patrol Operator (PPO) occurs when there is a failure to pay wages. This is critical because the payment of wages is a fundamental obligation that employers have towards their employees, especially in the private security industry regulated under the California Private Security Services Act. When a PPO does not meet this obligation, it triggers legal repercussions and subsequent penalties aimed at ensuring compliance with labor laws.

The focus on wage payment as the starting point for penalties emphasizes the importance of adhering to labor standards. Failure to pay wages reflects a violation of employee rights and can lead to claims filed against the employer, further escalating into fines and legal action. The other options, while related to operational compliance, do not directly initiate the penalty accrual process in the context of wage-related violations. For example, while filing a complaint may lead to investigation, it is the concrete act of failing to pay wages that directly signals non-compliance and potential penalties.