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Opinion WERDEGAR, J. Plaintiffs, seasonal agricultural workers, brought this action under Labor Code section 1194 and other theories to recover unpaid minimum wages. Plaintiffs contend the Industrial Welfare Commission’s (IWC) wage order No. 14-2001, entitled “Order Regulating Wages, Hours, and Working Conditions in Agricultural Occupations” (Cal. Code Regs., tit. 8, § 11140), commonly known as Wage Order No. 14, defines defendants as their employers for purposes of section 1194. The lower courts rejected the argument. We affirm. I. Background This case arises out of the strawberry farming operations of Isidro Munoz, Sr., who did business as Munoz & Sons (Munoz). Plaintiffs are seasonal agricultural workers whom Munoz employed during the 2000 strawberry season: Antonio Perez Cortes, Catarino Cortez, Otilio Cortez, Asuncion Cruz, Hilda Martinez and Miguel Martinez. Munoz, originally named as a defendant, has been granted a discharge in bankruptcy. The remaining defendants are two of the produce merchants through whom Munoz sold strawberries: Apio, Inc. (Apio), and Combs Distribution Co., together with its principals, Corky N. Combs and Larry Combs, and its field representative Juan Ruiz (collectively Combs). Plaintiffs’ separate action against a third merchant, Frozsun, Inc. (Frozsun), has been stayed pending the outcome of this action. A fourth merchant, Ramirez Brothers, has petitioned for bankruptcy. During the 2000 season, Munoz grew and harvested strawberries in the Santa Maria Valley, which lies on the Central Coast along the border of San Luis Obispo and Santa Barbara Counties. Munoz farmed a total of 130 acres divided among four sites. He leased two 30-acre sites (the “Océano” and “Zenon” fields) from defendant Apio and a 40-acre site (the “El Campo” field) from an unidentified third party. Munoz had leased the Océano and El Campo fields in prior years. He rented an additional 30-acre site (the “Santa Maria” field) from Ramirez Brothers. Munoz operated his business as a single, integrated concern, using his employees and equipment in all four fields, as needed, and combining his revenues and expenses. During the peak of the harvest, Munoz employed approximately 180 agricultural workers, three foremen (including his brother, Armando Munoz) and two office workers (including his son, Isidro Munoz, Jr.). Munoz owned his equipment, including trucks, tools and strawberry carts, and paid his own business expenses, including plants, fertilizer, pesticide, irrigation, fuel, packaging, and rent for additional trucks, a large tractor and field toilets. On the occasions when Apio and Combs paid Munoz’s expenses in the first instance, they billed him. Both defendants, for example, charged Munoz for packaging that bore their companies’ labels, and for refrigeration, and Apio charged Munoz for his portion of the cost of a shared irrigation system. Munoz grew and harvested strawberries for two distinct markets: fresh sale to consumers in markets, and sale for processing (typically freezing). Fresh market and freezer berries are harvested differently. Fresh market berries cannot be too green or too ripe, and the calyx (sepals and stem) is left attached. Market berries are packed in the field, as they are picked, into the containers in which they will be sold to consumers, such as plastic baskets or clamshell boxes. Freezer berries, in contrast, are selected for advanced ripeness and packed in bulk into crates with the calyx removed. Munoz harvested strawberries for both markets from the same fields. He decided which fields to harvest on any given day, and whether to harvest for fresh market sale or the freezer, based largely on the need to pick fields every three days, informing the merchants of his schedule and taking into account their orders and the berries’ condition. The four produce merchants through which Munoz sold strawberries are not related to one another. Munoz had dealt profitably with defendant Apio for three years prior to 2000, and with defendant Combs for one. The principals of Ramirez Brothers were Munoz’s personal friends. Apio, Combs and Ramirez Brothers dealt only in fresh market berries, and Frozsun dealt only in freezer berries. Apio, Combs and Frozsun each accepted berries from many independent growers, not just Munoz. Combs also sold beans for Munoz after the strawberry season ended. Munoz had different contractual relationships with each merchant. Apio and Combs acted as produce brokers, selling Munoz’s strawberries for a commission and remitting to him the net proceeds. Munoz retained title until sale. Both defendants, following a common practice of produce merchants on the Central Coast, advanced money to Munoz before the season began, in exchange for exclusive rights to fresh produce from designated fields. These advances were retired over the season from sales revenues. Apio and Combs handled payment differently. Combs agreed to remit the actual net proceeds of sale to Munoz within 21 days, in weekly payments, minus a deduction for loan repayment (30 percent), expenses such as packaging materials and cooling, and an 8 percent commission. Apio operated similarly and charged the same commission but, rather than making weekly payments to Munoz of actual net proceeds, paid him estimated net proceeds in the form of a weekly “Pick-Pack” payment that was initially set at $2 per carton but actually varied with the price of strawberries. Frozsun, which purchased strawberries exclusively for processing, paid Munoz on delivery the official “field price” posted by the Processing Strawberry Advisory Board of California. Munoz and Ramirez Brothers, being personal friends, conducted business without a written contract. Their understanding was that Munoz would pay for plants and labor and Ramirez Brothers would pay all other expenses, remitting net profits to Munoz after recovering their costs. Munoz’s financial resources for the 2000 season came from many sources. Much of his cash during the season came from sales proceeds, including at least $378,392 in Pick-Pack payments (estimated net proceeds) from Apio, $476,955 in net proceeds from Frozsun, and an unspecified amount from Combs. Munoz also invested at least $500,000 of his own funds and an unspecified amount of loan proceeds. The record does not identify all of Munoz’s financing sources. Some financing, as noted, came from the produce merchants. Apio advanced Munoz $163,000, or $2,716 per acre for the Océano and Zenon fields, and Combs advanced $80,000, or $2,000 per acre for El Campo. These advances were not intended to cover Munoz’s actual costs for growing and harvesting strawberries, which were far higher. The vice-president of Apio described that company’s advances as covering rent for the Océano and Zenon fields. Frozsun agreed to make or facilitate a loan of up to $225,000 in exchange for the exclusive right to purchase freezer and cannery berries from all of Munoz’s acreage. Munoz also received loans from personal friends and financing for equipment from Ford Motor Company and John Deere. Munoz alone, with the assistance of his foremen, hired and fired his employees, trained them when necessary, told them when and where to report to work, when to start, stop and take breaks, provided their tools and equipment, set their wages, paid them, handled their payroll and taxes, and purchased their workers’ compensation insurance. Munoz and his foremen also supervised his employees. Plaintiffs contend defendants Apio and Combs participated in the supervision, characterizing as supervision the activities of defendants’ field representatives in the areas of quality control and contract compliance. We will return to this subject below. (See, post, at p. 75 et seq.) Summarizing for present purposes, picking and packing strawberries for fresh market sale necessitated communication in the field, during the harvest, between defendants and Munoz’s personnel. Both Apio and Combs regularly sent field representatives to ascertain the quality of available strawberries and to explain the manner in which they were to be packed. Apio sent their representatives Juan Toche and Manuel Cardenas. Combs sent defendant Juan Ruiz, who performed similar services for many entities and whom Combs eventually hired as an employee in June 2000. Munoz’s contract with Apio expressly provided for these quality control activities. The contract provided, under the headings “Performance Oversight and Coordination” and “Quality of Crops,” that Apio would “set the standards for, and be the sole judge of, the quality and maturity of the Crops and the pack,” and that Apio would “have the right to send its quality control personnel to the fields ... at any time to confirm that the Crops ... are the quality required for purchase by [Apio] and/or marketing and sale under [Apio’s] labels . . . Munoz operated the same way with Combs, apparently as a matter of standard practice, even though the parties’ terse, single-page contract did not address the subject. Munoz began delivering fresh market strawberries to Apio and Combs sometime in March 2000. He delivered the last fresh berries to Apio on May 16, 2000, and to Combs on May 18, 2000. The freezer berry harvest began at the end of April and thus overlapped the last few weeks of the fresh berry harvest. When the fresh berry harvest ended, the freezer berry harvest greatly increased. To illustrate, as of May 20 Munoz had sold to Frozsun a total of 175,400 pounds of freezer berries for $31,663. In the next week alone (ending May 27), Munoz sold 787,208 pounds for $149,340. Sales to Frozsun continued until August 12, eventually totaling 2,608,781 pounds and $476,955 in payments to Munoz. In the last few weeks of the fresh strawberry harvest, the market for fresh berries deteriorated. According to Munoz, more berries were grown and harvested in 2000 than the market could handle. Apio, Combs and Ramirez Brothers were receiving poor prices for berries and, in some cases, no price at all when customers took berries on consignment. Apio’s Pick-Pack payments of estimated net proceeds, initially set at $2 per carton, reached a high of $2.50 per carton from mid-March to April 23 and then dropped gradually to $1.33 in May as the price of strawberries fell. Apio paid Munoz $68,791 on May 12 for berries delivered the week ending May 7, in advance of the 21-day contractual due date for payment. The next Pick-Pack advance payments from Apio were due on June 2 for the week ending May 14, and on June 9 for the week ending May 21. Apio actually advanced Munoz $77,662 for both weeks sometime between June 8 and 10. Combs advanced Munoz $30,000 in the last five days of May. Munoz received no payments at all from Ramirez Brothers during the 2000 season. Munoz finished the season owing Apio about $80,000, Combs about $8,000, and Ramirez Brothers about $30,000. Despite advances from Apio and Combs, and despite increasing payments from Frozsun, Munoz at some point in May 2000 began to have problems paying his workers. This led to a work stoppage on the afternoon of Saturday, May 27, in the El Campo field, where over 100 of Munoz’s employees were harvesting freezer berries. Munoz’s employees, who had apparently not been paid for several weeks, had stopped work and were talking with Jose Popoca Serrano, who identified himself as a member of the “Organization for Human Rights.” Serrano was compiling a list, which he later gave to the Division of Labor Standards Enforcement (DLSE), of workers claiming unpaid wages. Munoz’s supervisor Arturo Leon, and Munoz himself by telephone, asked Serrano to help persuade the workers to return to work, telling Serrano that Munoz could not pay because Apio was withholding payment. Munoz promised Serrano he would pay his workers on Tuesday. At some point, Combs’s field representative Juan Ruiz arrived, telling Serrano he had a check payable to Munoz from Combs for $25,000 and that Munoz already had another $20,000. Ruiz then spoke directly to Munoz’s workers. According to plaintiff Asuncion Cruz, “Juan [Ruiz] . . . told us to keep working and help Munoz. Juan told us not to worry and said he guaranteed we would be paid as his boss had checks he was delivering to Isidro Munoz.” Cruz “heard workers tell Juan they were concerned that the amount of the check he brought with him would not be enough to pay everyone. Juan told us not to worry as he would deliver even larger amounts of money from his boss to Isidro Munoz the following week, and even more money the week after that, which would be enough to pay us all.” Munoz’s workers recognized Ruiz as the field representative for the company (Combs) to whom Munoz delivered fresh market berries from the El Campo field. According to Leon, Ruiz also spoke with individual workers, explaining that “if all of you stop right now, the strawberries are going to go to waste. And they won’t be able to pay you.” After Ruiz spoke, several workers crossed their names off Serrano’s list and returned to work, but 75 workers left for the day to return on Monday. On June 5, 2000, the DLSE began to investigate wage claims against Munoz, based on Serrano’s information. The next day, DLSE investigator Paul Rodriguez met with Tim Murphy, Apio’s vice-president, who said that a payment to Munoz of approximately $75,000 was pending. Rodriguez asked Murphy not to pay Munoz but, instead, to pay Munoz’s employees directly. Murphy declined because Apio owed the money to Munoz, not his employees, and did not want to breach its agreement with Munoz. Subsequently, however, Apio and Munoz agreed, at the DSLE’s suggestion, that Apio would pay Munoz, and that cashier’s checks would immediately be issued in the names of the employees who had filed wage claims. Implementing this agreement on June 8 or 9, Murphy and Munoz visited Mid-State Bank & Trust in Guadalupe, where Murphy did business. Munoz endorsed Apio’s check to the bank, and the bank issued checks to the workers named on a list Munoz provided. On June 10, Murphy delivered the checks to DLSE investigator Rodriguez at the Betteravia Government Center in Santa Maria. Rodriguez, a second DLSE investigator, and Munoz’s foreman Arturo Leon distributed the checks to Munoz’s employees. Murphy observed the distribution but did not participate. On November 21, 2000, plaintiffs filed the present action against defendants Apio, Combs and Ruiz, as well as the now bankrupt Munoz. Plaintiffs asserted a variety of claims. Specifically, plaintiffs alleged defendants were liable for unpaid minimum wages (§ 1194), liquidated damages for unpaid minimum wages (§ 1194.2), unpaid contract wages (§ 216), waiting time penalties (§ 203), penalties for failure to provide wage statements (§ 226), and breach of contract. On behalf of similarly situated employees, plaintiffs also alleged claims under the unfair competition law (Bus. & Prof. Code, § 17200 et seq.) (UCL) for restitution (id., § 17203) and liquidated damages (Lab. Code, § 1194.2). Plaintiffs did not seek class certification. Defendants Apio, Combs and Ruiz moved for summary judgment on all claims. Plaintiffs’ opposition to the motions focused on three theories of liability. First, applying the definitions of “employ” and “employer” set out in Wage Order No. 14, plaintiffs contended defendants Apio and Combs, together with Munoz, jointly employed plaintiffs and were thus liable under sections 1194 and 1194.2 for their unpaid wages and liquidated damages. Second, plaintiffs argued they were third party beneficiaries of the contract between Munoz and Apio, in which, among other things, Munoz agreed to comply with all applicable laws, including the labor laws. Third, plaintiffs asserted they were parties to an oral employment agreement with Combs. The superior court rejected plaintiffs’ arguments and granted judgment for defendants. Plaintiffs appealed. The Court of Appeal affirmed in part and reversed in part. Finding no California case law interpreting the IWC’s definitions of “employ” and “employer” (e.g., Wage Order No. 14, Cal. Code Regs., tit. 8, § 11140, subd. 2(C), (F)), the court imported the “economic reality” test for employment developed in federal cases interpreting the Fair Labor Standards Act of 1938. (29 U.S.C. § 201 et seq.; see Goldberg v. Whitaker House Coop. (1961) 366 U.S. 28, 33 [6 L.Ed.2d 100, 81 S.Ct. 933].) Applying that test, the court concluded defendants “did not exercise sufficient control over [plaintiffs,] and [over Munoz’s] agricultural operation^] to be [plaintiffs’] joint employers,” and thus affirmed the summary judgment for defendants on plaintiffs’ claims under Labor Code sections 1194 and 1194.2. The court also affirmed the summary judgment for Apio on plaintiffs’ claim as purported third party beneficiaries of Apio’s contract with Munoz. Finally, the court found triable issues of fact on plaintiffs’ claim regarding the alleged oral agreement with Combs. The Court of Appeal reversed the judgment on this claim alone, and Combs did not seek review. In all other respects, the Court of Appeal affirmed. We granted plaintiffs’ petition for review and deferred further action pending consideration of a related issue in Reynolds v. Bement (2005) 36 Cal.4th 1075 [32 Cal.Rptr.3d 483, 116 P.3d 1162] (Reynolds). II. Discussion A. Introduction. The central question before us is whether defendants are subject to suit by plaintiffs under section 1194. The statute provides in relevant part as follows: “Notwithstanding any agreement to work for a lesser wage, any employee receiving less than the legal minimum wage or the legal overtime compensation applicable to the employee is entitled to recover in a civil action the unpaid balance of the full amount of this minimum wage or overtime compensation, including interest thereon, reasonable attorney’s fees, and costs of suit.” {Id., subd. (a).) The Legislature has thus given an employee a cause of action for unpaid minimum wages without specifying who is liable. That only an employer can be liable, however, seems logically inevitable as no generally applicable rule of law imposes on anyone other than an employer a duty to pay wages. Plaintiffs’ effort to recover unpaid wages from persons who contracted with their ostensible employer raises issues that have long avoided the attention of California’s courts. The statute currently designated as section 1194, with its specific operative language, was enacted in 1913 as part of the act that created the IWC and delegated to it the power to fix minimum wages, maximum hours of work, and standard conditions of labor. (Stats. 1913, ch. 324, § 13, p. 637.) In the ensuing 97 years, however, we have touched only once upon the question of how employment should be defined in actions brought under section 1194. (Reynolds, supra, 36 Cal.4th 1075, 1085-1089.) Similarly, the phrases the IWC presently uses to define the terms “employ” and “employer” in all 16 of its current industry and occupation wage orders (IWC wage orders Nos. 1-2001 to 16-2001, Cal. Code Regs., tit. 8, §§ 11010-11160) first appeared in orders dated 1916 and 1947, respectively, yet the courts of this state have never considered their meaning or scope. Likewise has the concept of joint employment avoided judicial scrutiny in the context of wage claims brought under state law. Although we have recognized that a person, by exercising significant control over the employees of another, may come to share the employer’s legal obligations, our decisions on this point have concerned statutory schemes other than the wage laws. How then do we define the employment relationship, and thus identify the persons who may be liable as employers, in actions under section 1194? The question is ultimately one of legislative intent, as “[o]ur fundamental task in construing a statute is to ascertain the intent of the lawmakers so as to effectuate the purpose of the statute.” (Day v. City of Fontana (2001) 25 Cal.4th 268, 272 [105 Cal.Rptr.2d 457, 19 P.3d 1196].) In this search for what the Legislature meant, “[t]he statutory language itself is the most reliable indicator, so we start with the statute’s words, assigning them their usual and ordinary meanings, and construing them in context. If the words themselves are not ambiguous, we presume the Legislature meant what it said, and the statute’s plain meaning governs. On the other hand, if the language allows more than one reasonable construction, we may look to such aids as the legislative history of the measure and maxims of statutory construction. In cases of uncertain meaning, we may also consider the consequences of a particular interpretation, including its impact on public policy.” (Wells v. One20ne Learning Foundation (2006) 39 Cal.4th 1164, 1190 [48 Cal.Rptr.3d 108, 141 P.3d 225].) B. The Parties’Arguments. The uncertainty surrounding the definition of the employment relationship in actions under section 1194 has led the parties to offer several diverse arguments. Those arguments, and our conclusions, may be summarized as follows: Plaintiffs contend the language and history of section 1194 show the Legislature intended generally to defer to the IWC’s regulatory definitions of the employment relationship in its wage orders. Plaintiffs would give those definitions sweeping breadth. Specifically, plaintiffs argue defendants “suffer [ed], or permitted plaintiffs] to work” (Wage Order No. 14, Cal. Code Regs., tit. 8, § 11140, subd. 2(C)), because defendants knew Munoz would need to hire workers to fulfill his contracts with defendants, and that defendants thus, in some sense, suffered or permitted plaintiffs to work for their benefit. Plaintiffs further argue defendants “exercise[d] control over [plaintiffs’] wages, hours, or working conditions” (Wage Order No. 14, Cal. Code Regs., tit. 8, § 11140, subd. 2(F)), because defendants, under the terms of their contracts with Munoz, controlled the remittance to him of his share of the proceeds of sale, and thus a portion of the income from which he paid his employees. Defendants, in opposition, cite our decision in Reynolds, supra, 36 Cal.4th 1075, where we looked to the common law to define employment in a suit under section 1194 seeking to hold the directors and officers of a corporation liable for its employees’ unpaid overtime compensation. (Reynolds, at pp. 1086-1087.) Alternatively, in the event Reynolds is distinguishable and the wage order’s definitions do apply, defendants argue we should construe the wage order as if it incorporated the federal “economic reality” definition of employment developed in cases arising under the Fair Labor Standards Act of 1938 (29 U.S.C. § 201 et seq.; FLSA; see Goldberg v. Whitaker House Coop., supra, 366 U.S. 28, 33) and articulated in federal regulations promulgated under the FLSA (see 29 C.F.R. § 791.2 (2009)) and the Migrant and Seasonal Agricultural Worker Protection Act (29 U.S.C. § 1801 et seq.; 29 C.F.R. § 500.20(h)(5) (2009)). We hold as follows: In actions under section 1194 to recover unpaid minimum wages, the IWC’s wage orders do generally define the employment relationship, and thus who may be liable. An examination of the wage orders’ language, history and place in the context of California wage law, moreover, makes clear that those orders do not incorporate the federal definition of employment. Applying these conclusions to the facts of the case, we affirm the Court of Appeal’s judgment. C. Labor Code Section 1194. As noted at the outset, the Legislature has not, within the four comers of section 1194, either defined the employment relationship or identified the persons who are liable under the statute for unpaid wages. We thus turn for guidance to the statute’s context and legislative history. Section 1194 is the direct successor of, and its operative language comes immediately from, section 13 of the uncodified 1913 act (Stats. 1913, ch. 324, § 13, p. 637) that created the IWC and delegated to it the power to fix minimum wages, maximum hours and standard conditions of labor for workers in California. An examination of section 1194 in its statutory and historical context shows unmistakably that the Legislature intended the IWC’s wage orders to define the employment relationship in actions under the statute. The act creating the IWC (the 1913 act) joined a wave of minimum wage legislation that swept the nation in the second decade of the 20th century. No state’s law provided for a minimum wage before 1912. By the end of 1913, however, nine states had enacted such laws, motivated by widespread public recognition of the low wages, long hours, and poor working conditions under which women and children often labored. By 1919, another five states, the District of Columbia and Puerto Rico had followed. (Brandéis, Labor Legislation: Minimum Wage Legislation in 3 History of Labor in the United States 1896-1932 (Commons edit. 1935) pp. 501, 507 (Brandéis).) These states took a variety of approaches to the problem. For example, two states (Mass, and Neb.) enacted voluntary minimum wage laws, and one state (Utah) set a minimum wage by statute. Other states, including California, went much further by directing commissions to study labor conditions and to set minimum wages based on the cost of living, and by making the failure to pay the minimum wage a crime. (Brandéis, supra, at p. 502; Note, Woman’s Work (1913) 3 Am. Lab. Legis. Rev. 433, 434-473.) These states did not follow a federal model, as Congress would not enact the FLSA (29 U.S.C. §201 et seq.) until 1938. In California specifically, calls to enact a minimum wage followed 1911 legislation prohibiting some child labor and regulating the hours women and children could be required to work (Stats. 1911, chs. 116, 258 & 456, pp. 282, 437, 910), and a comprehensive 1912 report by the State Bureau of Labor Statistics on wages, hours and labor conditions throughout the state. The report showed, among other things, that approximately 40 percent of working women earned less than $9 per week. (State Bur. of Lab. Statistics, 15th Biennial Rep., 1911-1912 (1912) pp. 100-101, 458.) “Although interpretations of this evidence varied widely, most experts thought that these wages were unreasonably low. The bureau itself considered them below a decent standard of living—‘many women were living below any normal standard, and . . . such subnormal living was having a most disastrous effect on the health and morals of the women workers.’ ” (Hundley, supra, 29 Pac. Hist. Rev. at pp. 272-273, fn. omitted, quoting IWC, What California Has Done to Protect the Women Workers (May 1927) p. 5.) Although the 1911 legislation had nearly eliminated unpermitted child labor, the bureau reported that minors from 12 to 16 years old working with permits still constituted just under 1 percent of the workforce. (State Bur. of Lab. Statistics, 15th Biennial Rep., supra, at pp. 21, 24.) The bureau did not report working minors’ wages. The 1913 Legislature addressed these continuing problems by creating the IWC and delegating to it broad authority to regulate the hours, wages and labor conditions of women and minors (Stats. 1913, ch. 324, p. 632), and by proposing to the voters a successful constitutional amendment confirming the Legislature’s authority to proceed in that manner. The argument in favor of the proposed constitutional amendment informed the voters that “[i]n 1911 bills were passed controlling the hours of women’s and children’s work, and it was obvious that the work was less than half done unless the other two minimum rules of industrial life were also made to protect this weakest and most helpless class: that is, that the safety and the sanitary conditions in which women worked should be controlled, and, what was more important, that they should be certain of a living wage—a wage that insures for them the necessary shelter, wholesome food and sufficient clothing.” (Ballot Pamp., Gen. Elec. (Nov. 3, 1914) argument in favor of Assem. Const. Amend. No. 90, p. 29.) On this point, the ballot pamphlet cited the findings of the State Bureau of Labor Statistics and expressed concern that substandard wages frequently led to ill health and moral degeneracy. (Ibid.) The IWC’s initial statutory duty under the 1913 act was to “ascertain the wages paid, the hours and conditions of labor and employment in the various occupations, trades, and industries in which women and minors are employed in the State of California, and to make investigations into the comfort, health, safety and welfare of such women and minors.” (Stats. 1913, ch. 324, § 3, subd. (a), p. 633.) To assist the IWC in this work, the Legislature gave the commission broad investigatory powers, including free access to places of business and employment (id., § 3, subd. (b), par. 2, p. 633), as well as the authority to demand reports and information under oath (id., § 3, subd. (b), par. 1, p. 633), to inspect records (id., § 3, subd. (b), par. 2, p. 633), and to issue subpoenas requiring the appearance and sworn testimony of witnesses (id., § 4, pp. 633-634). If, after investigation, the IWC determined that the wages paid to women and minors in any industry were “inadequate to supply the cost of proper living, or the hours or conditions of labor [were] prejudicial to the health, morals or welfare of the workers,” the IWC was to convene a “ ‘wage board’ ” of employers and employees. (Id,., § 5, p. 634.) Based on the wage board’s report and recommendations, and following a public hearing, the commission was to issue wage orders fixing for each industry “[a] minimum wage to be paid to women and minors . . . adequate to supply . . . the necessary cost of proper living and to maintain [their] health and welfare” (id., § 6, subd. (a), par. 1, p. 634), the maximum hours of work, and the standard conditions of labor (id., subd. (a), pars. 2-3, pp. 634-635). Today, the laws defining the IWC’s powers and duties remain essentially the same as in 1913, with a few important exceptions: First, the voters have amended the state Constitution to confirm the Legislature’s authority to confer on the IWC “legislative, executive, and judicial powers.” (Cal. Const., art. XIV, § 1, italics added [added by Assem. Const. Amend. No. 40 (1975-1976 Reg. Sess.), as approved by voters (Prop. 14), Primary Elec. (June 8, 1976)]; see Industrial Welfare Com. v. Superior Court (1980) 27 Cal.3d 690, 701 [166 Cal.Rptr. 331, 613 P.2d 579].) Second, the Legislature has expanded the IWC’s jurisdiction to include all employees, male and female, in response to federal legislation barring employment discrimination because of sex (tit. VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.). (See Stats. 1973, ch. 1007, § 8, p. 2004; Stats. 1972, ch. 1122, § 13, p. 2156; see generally Industrial Welfare Com. v. Superior Court, supra, at pp. 700-701.) Third, “while retaining the authorizing language of [the 1913 act],” the Legislature has “restated the commission’s responsibility in even broader terms” (Industrial Welfare Com. v. Superior Court, supra, at pp. 701-702), charging the IWC with the “continuing duty” to ascertain the wages, hours and labor conditions of “all employees in this state,” to “investigate [their] health, safety, and welfare,” to “conduct a full review of the adequacy of the minimum wage at least once every two years” (Lab. Code, § 1173), and to convene wage boards and adopt new wage orders if the commission finds “that wages paid to employees may be inadequate to supply the cost of proper living” (id., § 1178.5, subd. (a); see also id., § 1182). Finally, while the amount of the minimum wage has in recent years been set by statute (e.g., id., §§ 1182.11, 1182.12), specific employers and employees still become subject to the minimum wage only through, and under the terms of, the IWC’s applicable wage orders (id., § 1197). To ensure the IWC’s wage orders would be obeyed, the Legislature included criminal, administrative and civil enforcement provisions in the original 1913 act. The criminal enforcement provision declared that employers who failed to pay the minimum wage, as well as officers, agents and other persons acting for such employers, would be guilty of misdemeanors. (Stats. 1913, ch. 324, § 11, p. 636.) The administrative provision authorized the IWC to “take all proceedings necessary to enforce” payment of the minimum wage based on complaints filed by underpaid employees. (Id., § 14, p. 637.) The civil provision—the immediate predecessor of Labor Code section 1194—gave employees a private right of action to recover unpaid minimum wages and invalidated agreements to work for less than the minimum wage. (Stats. 1913, ch. 324, § 13, p. 637, quoted, ante, p. 52, fn. 18.) More robust versions of these enforcement provisions appear in today’s Labor Code. (See §§ 1193.5 [administrative enforcement], 1193.6, 1194, 1194.2 [civil actions], 1199 [criminal liability].) The 1913 act did not give any employee the immediate right to receive a minimum wage. Instead, the Legislature provided that implementation and enforcement of the minimum wage would depend upon, and await, the IWC’s issuance of wage orders governing specific industries and occupations. This was the effect of section 11 of the 1913 act, which provided that “[t]he minimum wage for women and minors fixed by said commission as in this act provided, shall be the minimum wage to be paid to such employees, and the payment to such employees of a less wage than the minimum so fixed shall be unlawful. . . .” (Stats. 1913, ch. 324, § 11, p. 636.) Accordingly, the essential predicate of each employer’s obligation to pay a minimum wage was the IWC’s issuance of an applicable wage order fixing the minimum wage for a particular industry or occupation. The applicable wage order also provided the necessary legal basis for an action by an employee to recover unpaid minimum wages. Section 13 of the 1913 act, the original civil liability provision, permitted “[a]ny employee receiving less than the legal minimum wage applicable to such employee ... to recover in a civil action the unpaid balance of the full amount of such minimum wage . . . .” (Stats. 1913, ch. 324, § 13, p. 637, italics added.) The italicized phrase unambiguously referred to the wage mandated by the terms of the applicable wage order, because section 11 defined the wage “fixed by said commission” as “the minimum wage to be paid” and its nonpayment as “unlawful.” (Stats. 1913, ch. 324, § 11, p. 636.) Virtually the same statutory and regulatory structure remains in place today. Under section 1197, “[t]he minimum wage for employees fixed by the commission is the minimum wage to be paid to employees, and the payment of a less wage than the minimum so fixed is unlawful.” Under section 1194, “any employee receiving less than the legal minimum wage . . . applicable to the employee is entitled to recover in a civil action the unpaid balance of the full amount of this minimum wage . . (id., subd. (a)). Accordingly, today, as under the 1913 act, specific employers and employees become subject to the minimum wage only under the terms of an applicable wage order, and an employee who sues to recover unpaid minimum wages actually and necessarily sues to enforce the wage order. The newly created IWC moved diligently to exercise its broad delegated powers. After investigating labor conditions in the fruit and vegetable canning industry, the commission convened the first wage board in 1916 and later that year issued its first wage order (IWC former wage order No. 1; see p. 50, fn. 13, ante), making women and minors working in that industry the first employees in California to receive a legally established minimum wage. By the end of 1918, the commission had issued additional orders establishing minimum wages in the mercantile, laundry, fish canning, fruit and vegetable packing, and manufacturing industries, and in general and professional office occupations. (IWC, Third Biennial Rep. (1919) pp. 9-11.) Today 18 wage orders are in effect, 16 covering specific industries and occupations, one covering all employees not covered by an industry or occupation order, and a general minimum wage order amending all others to conform to the amount of the minimum wage currently set by statute. D. How the IWC Has Defined the Employment Relationship. The IWC’s first wage order, adopted in 1916, contained no separate definition of the term “employ,” but various substantive provisions imposing duties on employers began with language like that the IWC still uses today in all of its industry and occupation wage orders to define the term. For example: “No person, firm or corporation shall employ or suffer or permit any woman or minor to work in the fruit and vegetable canning industry in any occupation at time rates less than the following . . . .” (IWC former wage order No. 1, § 2, italics added; see, e.g., Wage Order No. 14, Cal. Code Regs., tit. 8, § 11140, subd. 2(C) [“ ‘Employ’ means to engage, suffer, or permit to worE' (italics added)].) The chosen language was especially apt in an order intended to regulate the employment of women and minors because it was already in use throughout the country in statutes regulating and prohibiting child labor (and occasionally that of women), having been recommended for that purpose in several model child labor laws published between 1904 and 1912 (see Rutherford Food Corp. v. McComb (1947) 331 U.S. 722, 728, fn. 7 [91 L.Ed. 1772, 67 S.Ct. 1473]). The language had been interpreted to impose criminal liability for employing children, or civil liability for their industrial injuries, even when no common law employment relationship existed between the minor and the defendant, based on the defendant’s failure to exercise reasonable care to prevent child labor from occurring. Not requiring a common law master and servant relationship, the widely used “employ, suffer or permit” standard reached irregular working arrangements the proprietor of a business might otherwise disavow with impunity. Courts applying such statutes before 1916 had imposed liability, for example, on a manufacturer for industrial injuries suffered by a boy hired by his father to oil machinery (Curtis & Gartside Co. v. Pigg, supra, 134 P. 1125, 1127), and on a mining company for injuries to a boy paid by coal miners to carry water (Purtell v. Philadelphia & Reading Coal & Iron Co., supra, 99 N.E. 899, 900-901). Results such as these, while foreign to the common law, were generally understood as appropriate under child labor statutes that included the “employ, suffer or permit” standard. As one state supreme court explained, “[i]f the statute went no farther than to prohibit employment, then it could be easily evaded by the claim that the child was not employed to do the work which caused the injury, but that he did it of his own choice and at his own risk; and if it prohibited only the employment and permitting a child to do such things, then it might still be evaded by the claim that he was not employed to do such work, nor was permission given him to do so. But the statute goes farther, and makes use of a term even stronger than the term ‘permitted.’’ It says that he shall be neither employed, permitted, nor suffered to engage in certain works.” (Curtis & Gartside Co. v. Pigg, supra, 134 P. 1125, 1129.) The standard thus meant that the employer “shall not employ by contract, nor shall he permit by acquiescence, nor suffer by a failure to hinder.” (Ibid.) Similarly, another state supreme court rejected the employer’s argument that the standard could “only apply when the relation of master and servant actually exists.” (Purtell v. Philadelphia & Reading Coal & Iron Co., supra, 99 N.E. 899, 902.) “To put [such a] construction on this statute . . . would leave the words ‘permitted or suffered to work’ practically without meaning. It is the child’s working that is forbidden by the statute, and not his hiring, and, while the statute does not require employers to police their premises in order to prevent chance violations of the act, they owe the duty of using reasonable care to see that boys under the forbidden age are not suffered or permitted to work there contrary to the statute.” (Ibid.) The IWC’s separate definition of “employer” (i.e., a person who “employs or exercises control over the wages, hours, or working conditions of any person”) is only relatively recent, having first appeared in a 1947 order regulating the manufacturing industry. The same language appears today in all 16 of the IWC’s industry and occupation orders. Beginning with the word “employs,” the definition logically incorporates the separate definition of “employ” (i.e., “to engage, suffer, or permit to work”) as one alternative. The remainder of the definition—“exercises control over . . . wages, hours, or working conditions”—has no clearly identified, precisely literal statutory or common law antecedent. About this language, however, one may safely make three observations: First, the scope of the IWC’s delegated authority is, and has always been, over wages, hours and working conditions. (§§ 1173, 1178.5; see Stats. 1913, ch. 324, §§ 3, 5 & 6, pp. 633-635.) For the IWC to adopt a definition of “employer” that brings within its regulatory jurisdiction an entity that controls any one of these aspects of the employment relationship makes eminently good sense. Second, phrased as it is in the alternative (i.e., “wages, hours, or working conditions”), the language of the IWC’s “employer” definition has the obvious utility of reaching situations in which multiple entities control different aspects of the employment relationship, as when one entity, which hires and pays workers, places them with other entities that supervise the work. Consistently with this observation, the IWC has explained its decision to include the language in one modem wage order as “specifically intended to include both temporary employment agencies and employers who contract with such agencies to obtain employees within the definition of ‘employer.’ ” Third, and finally, the IWC’s “employer” definition belongs to a set of revisions intended to distinguish state wage law from its federal analogue, the FLSA. We touched upon this point in Morillion v. Royal Packing Co., supra, 22 Cal.4th 575. In 1947, Congress limited the FLSA by enacting the Portal-to-Portal Act of 1947 (29 U.S.C. § 252 et seq.), which relieved employers of the obligation to compensate employees for time spent travel-ling to the worksite, even in an employer’s vehicle, and for time spent in activities “preliminary to or postliminary” to work (id., § 254(a)(2)). In response, the IWC, exercising its authority to provide employees with greater protection than federal law affords (Morillion v. Royal Packing Co., supra, at p. 592; see also Ramirez v. Yosemite Water Co. (1999) 20 Cal.4th 785, 795 [85 Cal.Rptr.2d 844, 978 P.2d 2]), revised its wage orders from 1947 forward to define the term “hours worked” as meaning “the time during which an employee is subject to the control of an employer, . . . including] all the time the employee is suffered or permitted to work, whether or not required to do so.” At the same time, the IWC defined “employer” as meaning “any person .. . who directly or indirectly, or through an agent or any other person, employs or exercises control over the wages, hours, or working conditions of [an employee].” Noting this history, defendant Combs argues the IWC’s 1947 changes were intended solely to expand the definition of “hours worked” and not also to affect the definition of “employer.” This is plainly wrong, as the IWC could have redefined “hours worked” without also redefining “employer.” One change did not logically compel the other. E. Judicial Deference to the IWC’s Orders. The Legislature and the voters have repeatedly demanded the courts’ deference to the IWC’s authority and orders. In the original 1913 act, the Legislature narrowly confined the scope of judicial review of the commission’s orders, making its findings of fact conclusive in the absence of fraud and declaring that the minimum wage fixed by the commission was “presumed to be reasonable and lawful.” (Stats. 1913, ch. 324, § 12, p. 636; see now Lab. Code, §§ 1185 [IWC’s orders “shall be valid and operative”], 1187 [IWC’s findings of fact are conclusive in the absence of fraud].) At the same time, as noted, the Legislature enacted and successfully proposed to the voters a constitutional amendment approving the IWC’s creation and providing that no part of the state Constitution would be construed as limiting the Legislature’s authority in the matter. (Cal. Const., former article XX, section 17 1/2; see, ante, at p. 54, fn. 20.) The ballot argument in favor of the measure explained the Assembly had proposed the amendment “to make sure that after the commission’s work is done, its findings and rulings can not be assailed and made useless by the state courts declaring this [the 1913] act unconstitutional.” (Ballot Pamp., supra, argument in favor of Assem. Const. Amend. No. 90, p. 29.) In 1949, the Legislature provided that the IWC’s orders “shall be valid and operative” and exempt from the Administrative Procedure Act (Gov. Code, § 11340 et seq.). (Lab. Code, § 1185; Stats. 1949, ch. 1454, § 12, p. 2538, as amended.) In 1976, as noted, the voters again amended the Constitution to confirm in even stronger terms that “[t]he Legislature may provide for minimum wages and for the general welfare of employees and for those purposes may confer on a commission legislative, executive, and judicial powers.” (Cal. Const., art. XTV, § 1, italics added; see, ante, p. 54, fn. 20; see generally Industrial Welfare Com. v. Superior Court, supra, 27 Cal.3d 690, 701.) Obeying these formal expressions of legislative and voter intent, the courts have shown the IWC’s wage orders extraordinary deference, both in upholding their validity and in enforcing their specific terms. Concerning the wage orders’ validity, “[judicial authorities have repeatedly emphasized that in fulfilling its broad statutory mandate, the IWC engages in a quasi-legislative endeavor, a task which necessarily and properly requires the commission’s exercise of a considerable degree of policy-making judgment and discretion.” (Industrial Welfare Com. v. Superior Court, supra, 27 Cal.3d 690, 702.) “Because of the quasi-legislative nature of the IWC’s authority, the judiciary has recognized that its review of the commission’s wage orders is properly circumscribed. ... ‘A reviewing court does not superimpose its own policy judgment upon a quasi-legislative agency in the absence of an arbitrary decision ....’” (Ibid., quoting Rivera v. Division of Industrial Welfare (1968) 265 Cal.App.2d 576, 594 [71 Cal.Rptr. 739]) “Moreover, past decisions . . . teach that in light of the remedial nature of the legislative enactments authorizing the regulation of wages, hours and working conditions for the protection and benefit of employees, the statutory provisions are to be liberally construed with an eye to promoting such protection.” (Industrial Welfare Com. v. Superior Court, supra, at p. 702.) Concerning the specific terms of wage orders, we have explained that “[t]he power to fix [the minimum\ wage does not confine the [IWC\ to that single act. It may adopt rules to make it effective.” (Cal. Drive-in Restaurant Assn. v. Clark (1943) 22 Cal.2d 287, 303 [140 P.2d 657], italics added.) “The power to provide safeguards to insure the receipt of the minimum wage and to prevent evasion and subterfuge, is necessarily an implied power flowing from the power to fix a minimum wage delegated to the commission. [][] It is true that an administrative agency may not, under the guise of its rule making power, abridge or enlarge its authority or exceed the powers given to it by the statute, the source of its power. [Citations.] However, ‘the authority of an administrative board or officer ... to adopt reasonable rules and regulations which are deemed necessary to the due and efficient exercise of the powers expressly granted cannot be questioned. This authority is implied from the power granted.’ ” (Id., at pp. 302-303, quoting Bank of Italy v. Johnson (1926) 200 Cal. 1, 20 [251 P. 784].) Consistently with these deferential principles of review, we have repeatedly enforced definitional provisions the IWC has deemed necessary, in the exercise of its statutory and constitutional authority (§ 1173; Cal. Const., art. XIV, § 1), to make its wage orders effective, to ensure that wages are actually received, and to prevent evasion and subterfuge. (Cal. Drive-in Restaurant Assn. v. Clark, supra, 22 Cal.2d 287, 302-303.) Such provisions have, for example, excluded restaurant servers’ tips from the legal minimum wage (id., at p. 290); defined “ ‘[h]ours worked’ ” as including “the time during which an employee is subject to the control of an employer,” even if travelling on the employer’s bus and not actually working (e.g., Wage Order No. 14, Cal. Code Regs., tit. 8, § 11140, subd. 2(G); see Morillion v. Royal Packing Co., supra, 22 Cal.4th 575, 581-595); and required that an “ ‘[o]utside salesperson,’ ” to be exempt from overtime compensation, must “regularly work[] more than half the working time away from the employer’s place of business” in sales activities (IWC wage order No. 7-2001, Cal. Code Regs., tit. 8, § 11070, subd. (2)(J); see Ramirez v. Yosemite Water Co., supra, 20 Cal.4th 785, 794-803). Such provisions constitute valid exercises of the IWC’s authority because, and to the extent, they have “a direct relation to minimum wages” (Cal. Drive-in Restaurant Assn. v. Clark, supra, at p. 302) and are reasonably necessary to effectuate the purposes of the statute (see Ramirez v. Yosemite Water Co., supra, 20 Cal.4th 785, 800; see also Cal. Drive-in Restaurant Assn. v. Clark, supra, at p. 302). Courts must enforce such provisions in wage actions because, as we have explained, an employee who sues to recover unpaid minimum wages under section 1194 actually sues to enforce the applicable wage order. Only by deferring to wage orders’ definitional provisions do we truly apply section 1194 according to its terms by enforcing the “legal minimum wage” (id., subd. (a)). F. The Significance of Reynolds, supra, 36 Cal.4th 1075 Against this background we consider the significance of Reynolds, supra, 36 Cal.4th 1075, and whether that decision governs this case. In Reynolds we looked to the common law rather than the applicable wage order to define employment in an action under section 1194 seeking to hold a corporation’s directors and officers personally liable for its employees’ unpaid overtime compensation. (Reynolds, at pp. 1086-1088.) We conclude Reynolds does not govern this case. Wage Order No. 14, and not the common law, properly defines the employment relationship in this action under section 1194. The plaintiff in Reynolds, supra, 36 Cal.4th 1075, worked for a corporation that owned and operated automobile painting shops. He sued under section 1194 to recover unpaid overtime compensation allegedly due him under the IWC’s applicable wage order. The plaintiff named as the defendants, in addition to the corporation, eight of its officers and directors in their individual capacities. The question before us on demurrer was whether the plaintiff had stated a cause of action against the individual defendants. We held he had not. (Reynolds, supra, 36 Cal.4th 1075, 1083, 1087-1088.) We properly began our analysis in Reynolds, supra, 36 Cal.4th 1075, 1086, by looking “to the IWC’s intent in promulgating the employer definition.” The applicable wage order defined “employer” in precisely the same language as all of the commission’s other industry and occupation orders. Thus, “employer” meant “any person . . . who directly or indirectly, or through an agent or any other person, employs or exercises control over the wages, hours, or working conditions of any person.” (IWC wage order No. 9-2001, Cal. Code Regs., tit. 8, § 11090, subd. 2(F).) Reasoning that “[t]he best indicator of [the commission’s] intent is the language of the provision itself’ (Reynolds, at p. 1086), we accepted the plaintiffs’ concession that “the plain language of Wage Order No. 9 defining employer does not expressly impose liability under section 1194 on individual corporate agents” (Reynolds, at p. 1086). This reasoning sufficed to dispose of the Reynolds plaintiffs claim because, as we have explained, a claim under section 1194 is in reality a claim under the applicable wage order and thus subject to the order’s definitional provisions. Nevertheless, we went on in Reynolds, supra, 36 Cal.4th 1075, 1086-1087, to state that the common law rather than the applicable wage order defined the employment relationship for purposes of the plaintiff’s action under section 1194. We reached this conclusion in two steps: First, we rejected the suggestion that the Legislature had intended “to incorporate” the IWC’s definitions into section 1194. {Reynolds, at p. 1086.) Second, we applied the maxim of interpretation that “[a] statute will be construed in light of the common law unless the Legislature ‘ “ ‘clearly and unequivocally’ ” ’ indicates otherwise.” (Ibid., quoting California Assn, of Health Facilities v. Department of Health Services (1997) 16 Cal.4th 284, 297 [65 Cal.Rptr.2d 872, 940 P.2d 323].) Elaborating on the latter point, we explained that when “ ‘a statute refer[s] to employees without defining the term . . . courts have generally applied the common law test of employment.’ ” (Reynolds, at p. 1087, quoting Metropolitan Water Dist. v. Superior Court, supra, 32 Cal.4th 491, 500.) In a footnote, we added that the “plaintiff . . . ha[d] not persuaded us that one may infer from the history and purposes of section 1194 a clear legislative intent to depart, in the application of that statute, from the common law understanding of who qualifies as an employer.” (Reynolds, at p. 1087, fn. 8.) As we have now shown, an examination of section 1194 in its full historical and statutory context shows unmistakably that the Legislature intended to defer to the IWC’s definition of the employment relationship in actions under the statute. The Legislature has delegated to the IWC broad authority over wages, hours and working conditions (§ 1173 et seq.), the voters have repeatedly ratified that delegation (Cal. Const., art. XIV, § 1; see id., former art. XX, § 17 1/2), and we have confirmed that “[t]he power to fix [the minimum] wage does not confine the [IWC] to that single act. It may adopt rules to make it effective” (Cal. Drive-in Restaurant Assn. v. Clark, supra, 22 Cal.2d 287, 303). The power to adopt rules to make the minimum wage effective includes the power to define the employment relationship as necessary “to insure the receipt of the minimum wage and to prevent evasion and subterfuge . . . .” (Id., at p. 302.) Finally, as we have explained, a worker who sues under section 1194 for unpaid minimum wages actually sues to enforce the applicable wage order. This is because the “legal minimum wage” recoverable under section 1194 is “[t]he minimum wage . . . fixed by the commission” (§ 1197) in the applicable wage order, even if that order merely incorporates the amount currently set by statute, and because employers and employees become subject to the minimum wage only through the applicable wage order and according to its terms (§ 1197; see, ante, at pp. 55-57 & fn. 22). This is not to say the common law plays no role in the IWC’s definition of the employment relationship. In fact, the IWC’s definition of employment incorporates the common law definition as one alternative. As defined in the wage orders, “ ‘[e]mployer’ means any person . . . who . . . employs or exercises control over the wages, hours, or working conditions of any person,” and “ ‘[e]mploy’ means to engage, suffer, or permit to work.” (Wage Order No. 14, Cal. Code Regs., tit. 8, § 11140, subd. 2(C), (F), italics added.) The verbs “to suffer” and “to permit,” as we have seen, are terms of art in employment law. (See, ante, at p. 57 et seq.) In contrast, the verb “to engage” has no other apparent meaning in the present context than its plain, ordinary sense of “to employ,” that is, to create a common law employment relationship. This conclusion makes sense because the IWC, even while extending its regulatory protection to workers whose employment status the common law did not recognize, could not have intended to withhold protection from the regularly hired employees who undoubtedly comprise the vast majority of the state’s workforce. To employ, then, under the IWC’s definition, has three alternative definitions. It means: (a) to exercise control over the wages, hours or working conditions, or (b) to suffer or permit to work, or (c) to engage, thereby creating a common law employment relationship. While the common law definition of employment plays an important role in the wage orders’ definition, and thus also in actions under section 1194, to apply only the common law definition while ignoring the rest of the IWC’s broad regulatory definition would substantially impair the commission’s authority and the effectiveness of its wage orders. The commission, as noted, has the power to adopt rules to make the minimum wage “effective” by “preventing] evasion and subterfuge . . . .” (Cal. Drive-in Restaurant Assn. v. Clark, supra, 22 Cal.2d 287, 303, 302.) We have repeatedly upheld the commission’s exercise of this authority. (See, ante, at p. 61 et seq.) Furthermore, language consistently used by the IWC to define the employment relationship, beginning with its first wage order in 1916 (“suffer, or permit”), was commonly understood to reach irregular working arrangements that fell outside the common law, having been drawn from statutes governing child labor and occasionally that of women. (See, ante, at p. 57 et seq.) For the IWC, created as it was to regulate the employment of women and minors, to use this language to define the employment relationship was thus uniquely appropriate. To adopt such a definitional provision also lay squarely within the IWC’s power, as the provision has “a direct relation to minimum wages” (Cal. Drive-in Restaurant Assn. v. Clark, supra, at p. 302) and is reasonably necessary to effectuate the purposes of the statute (see Ramirez v. Yosemite Water Co., supra, 20 Cal.4th 785, 800; see also Cal. Drive-in Restaurant Assn. v. Clark, supra, at p. 302). For a court to refuse to enforce such a provision in a presumptively valid wage order (§ 1185) simply because it differs from the common law would thus endanger the commission’s ability to achieve its statutory purposes. One cannot overstate the impact of such a holding on the IWC’s powers. Were we to define employment exclusively according to the common law in civil actions for unpaid wages we would render the commission’s definitions effectively meaningless. Concerned about such a result, we suggested in Reynolds, supra, 36 Cal.4th 1075, 1088-1089, that the IWC’s definitions might still play a role in administrative proceedings to recover unpaid minimum wages (i.e., “Berman” hearings). (See § 98 et seq.; Cal. Code Regs., tit. 8, § 13501 et seq.) Since Reynolds, however, the Court of Appeal has correctly observed that “[t]he distinction [between judicial and administrative proceedings] may be an empty one, since Berman hearings are reviewed de novo in superior court at [the] request of either party.” (Jones v. Gregory, supra, 137 Cal.App.4th 798, 806.) The statutory trial de novo (see § 98.2) “is neither a conventional appeal nor review of the Labor Commissioner’s decision, but is rather a de novo trial of the wage dispute” (Murphy v. Kenneth Cole Productions, In