Got it. Feels like this will be a lengthy process and require a lot of work, i.e. collecting evidence and documenting over multiple quarters, having people manage the process, all for 12k people. And my understanding is when you get PIP’d, you get offered a package of some kind to leave. I would be surprised if this approach is cheaper than just laying people off.
It will be pushed to line level managers, who will be overworked and stressed about it. But if you just make your managers do more, it doesn't cost the company anything.