The count should be done at the employer level (firm- or corporate-wide), not the individual location level.
So, if I work at a small place with around 20 employees, because it is part of a larger company that has over 100 employees at different locations, the mandate still stands, right? This is downright harassment. The regime has decided to use the stick.
Wait. It says “should” be done not must be done. What kind of garbage is this?