We find reports of inappropriate conduct as appalling as anyone. The 45,000 guests who visit our more than 1,000 franchised locations every day expect to enjoy a wellness experience in a safe and comfortable environment. Our stringent hiring requirements, along with the industry’s most comprehensive therapist training program, and our industry-leading policies and procedures (including our zero tolerance policy against inappropriate conduct) ensure that’s exactly what is delivered.
Over the last several years, we have invested millions of dollars in personnel, programs, policies and procedures that are aimed at getting to zero incidents of inappropriate conduct. We have also terminated 15 franchise agreements in the last two years for violation of our policies surrounding inappropriate conduct. We will not rest until we get to zero. To that end, we are in various stages of development on some exciting and innovative programs that we believe can change the landscape for the entire industry.
Incident Reporting and Handling. We have continually evolved our reporting system for inappropriate conduct incidents, and our system now allows for real-time, automated reporting of incidents by franchisees to our Franchise Support Center. We require reporting by franchisees of every incident, including those that may appear to be false accusations, or incidents of inappropriate conduct by member/guests towards therapists. We require franchisees to report incidents to law enforcement and state boards, as required, and franchisees regularly cooperate with law enforcement and state board investigations of incidents.
Enforcement and Accountability around Zero Tolerance. When an incident of inappropriate conduct does occur despite our best prevention efforts, we strictly enforce our zero tolerance policy through serious consequences, including termination of therapists by franchisees and/or termination of franchise rights. We do not tolerate any franchisee that is uninformed or fails to follow our policies surrounding inappropriate conduct, and we have filed claims against our own franchisees when they violate these policies. Our franchisees have provided testimony leading to criminal convictions and license revocations of therapists that violated these policies. To ensure compliance, we have increased our field staff three-fold and our franchise compliance department six-fold. We have terminated x franchisees in the last two years for violation of our zero tolerance policy. We conduct presentations and workshops on inappropriate conduct at every annual and regional meeting, and we regularly remind franchisees of the consequences for violating these policies.
Industry’s Most Comprehensive Therapist Training Program. Therapists employed by Massage Envy Spa franchisees are required to complete four mandatory training courses each year, along with a practical evaluation. Our Behind Closed Doors training is a ground-breaking course, which has been approved by the National Certification Board for Therapeutic Massage & Bodywork (NCBTMB) and addresses the boundaries and perceptions of appropriate touch and focuses on therapists’ communication, approach and conduct to ensure their work is provided within each individual client’s comfort zone. Another required training course focuses on the Massage Envy Spa draping policy, which is the most stringent in the industry. Our Code of Conduct training ensures that all therapists and managers employed by franchisees understand the Code of Conduct, which specifically enumerates “zero tolerance offenses,” and also understand how to handle, report and resolve an incident of inappropriate conduct. Finally, our Wellness Chart training helps therapists consult with clients and obtain consent as to specific body parts that will be addressed during a therapeutic massage session. Each of these four required courses are required to be completed annually.
Stringent Therapist Hiring Requirements. Each franchisee is required to perform a criminal background check on their massage therapists prior to employment. Background checks must be completed by Universal Background Screening, one of a select few background screening companies accredited by the National Association of Professional Background Screeners. Franchisees are also required to complete a thorough reference check and to validate each massage therapist’s license or certification (in states where licensure or certification exists, currently only in 45 states and DC). In states where no licensure or certification exists, we conceptually serve as the licensing authority by requiring completion of no less than 500 hours of massage therapy education from an educational institute. Franchisees are required to keep an employee file on each massage therapist, which includes a copy of their licensure, certification, or completed education, their background and reference check, their certificate of completed annual training, and their sign Standards of Practice, which is written acknowledgment from the massage therapist that they understand the Code of Conduct and the stringent requirements that must be met to be employed as a massage therapist by a Massage Envy Spa franchisee.
Innovative/Disruptive Programs. We are working with a world-class vendor to develop a state-of-the-art therapist screening and monitoring tool, so we can have continual, real-time access to any therapist’s confirmed identity, background, certification and disciplinary history. We are working with and supporting associations like the Federation of State Massage Therapy Boards (FSMTB), whose purpose is to improve the safety and create a more uniform regulatory structure for the massage therapy industry. We are also working with educators to encourage more thorough and substantive training around inappropriate conduct.