If it was my company would bet on my lawyers being better than whoever wrote this statute.
There will be loopholes. And my people will exploit them faster than the drones who work for the city can find and close them.
I could just tell them that we aren't providing free meals and make them prove that we are and make it into a huge legal battle for every little document or access to the facility. Draw the whole thing out and get them to make legal errors that I could exploit later.
I could institute a credits program where you get company scrip for doing things unrelated to your job or pay. Like making a phone call on behalf of a charity or sending an e-mail to someone or some other small thing and with this scrip you can buy company merch and/or use it in the cafeteria. It would be set up so that only 10 minutes a week will get you enough scrip for a month of cafeteria visits. And of course the legal battle will be just as intense as in the first example.
If the statute only says "employees" then I could possibly subsidize non-employees. If so then I can invite friends and relatives of my workers to come enjoy the food and if they want to be served much more food than they can eat and then give that extra food to their friend or relative I don't see how that can be an issue.
Or perhaps finagle using tour groups to do the same thing. Say everyday you have multiple groups come in for "eat with an engineer day" they do their tour and then retire to the cafeteria where they are assigned to one or more employees and then the tourist gets to place an order for as much food as they want, taking input from the employees of course, and then it's off to the tables to talk about things.
I could charge for the food up front but when it's yearly bonus time the money makes it way back to the workers.
