Unions Helped, But Now Hurt, Cannabis Industry

Yea yea … last week it was drug abuse and addiction. This week it’s marijuana. Trust me, I’ve taken my share of ribbing around the halls 173779091--cannabisof HRE for having seemed to take on the “drug beat.” (Though Mark McGraw’s post on Wednesday about the implications of the Colorado Supreme Court’s Coats v. Dish Network decision may have spared me a few ribs.)

For the record, I’m not obsessed. Nor am I high. (Or funny, I’m sure.) Just hugely intrigued by the growing problem of drugs at work, and the almost explosive ascension of marijuana as a legalized “mind-alterer” and legitimate business. (Here are two recent posts — one late last year, one early this year — and a news analysis in which I’ve examined this phenomenon.)

It’s the business side of marijuana I find most intriguing in this recent piece on the Marijuana Business Daily site. Seems the very union that has nudged this burgeoning cannabis industry along, “helping to pass legislation and regulations that benefit business owners and the movement as a whole,” as the story puts it, is now presenting “canna-business” owners with some challenges.

Actually, the story refers to unions, plural, but the leader of the charge to organize thousands of businesses — dispensaries, infused products companies, ancillary firms and cultivation sites in numerous states including California, Colorado and Minnesota — and to represent even more thousands of employees, from budtenders to growers, is the United Food and Commercial Workers Union, one of the largest labor organizations in the country. UFCW even has a marijuana division along with a parallel website dedicated to promoting unionized marijuana businesses.

Bear in mind, these businesses sprouting up faster than the plants themselves are being run — for the most part — by people who are new to business. Now they’re finding they have to negotiate collective-bargaining agreements, and “that can boost costs, increase red tape, lead to legal issues and create new headaches,” the story says.

Granted, there are positives, too.

As the MBD story notes, in addition to politically partnering with the industry and helping to muscle pro-marijuana legislation through in more than one state, the UFCW’s “experience in moderating employer-employee disputes is an asset, along with systems the union usually proposes to standardize employee reprimands and evaluations.”

Still, it will be interesting — “intriguing,” to quote this very post — to see just how these cannabis start-ups deal with the challenges of working with labor unions.

As industry consultant Todd Mitchem tells MBD:

“When someone’s pro-union in the industry, my question is, ‘What’s the motivation?’ [According to him, there’s not a lot of need in cannabis companies for the traditional watchdog role that unions have played in other industries, such as mining or automotive manufacturing.]

“By and large, this industry wants to play by the rules. You run into a massive divisiveness between the employer and the employee [once unions become part of the equation]. To overlay a union structure onto a fragile industry … is really short-sighted and, in my opinion, risky.”

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Are ‘Significant’ Changes to Comp Disclosures Coming?

If you believe the good folks over at Towers Watson, then the answer to that question in the headline is a yes. (A qualified yes, but, a yes nonetheless.)

One in three U.S. public companies expect to significantly change their approach to disclosing information on how they reward their executives in the wake of the Securities and Exchange Commission’s proposed pay-for-performance disclosure rules, according to a poll by global professional services company Towers Watson.

The poll also found that a majority of companies are likely to provide additional information and analysis that go beyond what the proposed rules will require.

In case you forgot, back in April, the SEC issued proposed rules to implement the Dodd-Frank provisions that require companies to disclose the relationship between executive compensation actually paid and the company’s financial performance.

The proposal would require company proxy statements to include a pay-versus-performance table and an explanation of the relationship between pay and performance. The Towers Watson poll of 453 corporate executives and compensation professionals was conducted June 4, during Towers Watson’s national webcast on the proposed rules.

According to the poll, 33 percent of respondents expect the pay-for-performance disclosure rule will fundamentally change their approach to executive pay disclosure. More than half of the respondents (55 percent) expect to do more than the minimum that would be required under the SEC proposal: 37 percent plan to disclose additional information and analyses to help tell their pay-for-performance story, while 18 percent will perform and may disclose additional pay-for-performance analyses.

“With the SEC rules on the table, companies can carefully evaluate how they tell their pay-for-performance story to shareholders,” said Steve Kline, a director in Towers Watson’s Executive Compensation consulting group and the practice’s pay-for-performance analytics team leader. “The fact that many companies expect to provide more information than the rules require is encouraging, although for many, the real challenge will be deciding the best way to present this information in their proxies.”

The poll also found that nearly half of the companies (46%) have been waiting for the rules to be issued and now expect to make some changes to their Compensation Discussion and Analysis (CD&A), while one in 10 view this as an opportunity to revamp their CD&A significantly. Additionally, roughly half of respondents (51%) anticipate using the same peer group for their pay-versus-performance disclosure that they use for benchmarking their total compensation.

“While not surprising given the language of the Dodd-Frank requirement, the fact that the SEC proposal defines performance in this disclosure as total shareholder return will put even more shareholder focus on this measure,” Kline said. “However, TSR is only a part of the pay-for-performance story. Companies will want to think carefully about the broader performance picture and how best to help shareholders understand how the pay programs support long-term value creation.”

Indeed, HR leaders will need to be a big part of that thought process around the “broader performance picture” in order to set the right framework to ensure compliance with these proposed changes.

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H-1B: Disney Retreats; DOL Investigates

The Walt Disney Co.’s Disney ABC Television Group appears to be backing off from a layoff announcement two weeks ago, in which it had told a group of approximately 35 of its IT workers that their jobs were being outsourced to Cognizant Technology Solutions, a New Jersey-based company with large overseas operations. But now, reports Computerworld, those IT workers have been told that the layoff has been canceled.

Some of the IT workers who were to be laid off were told by Disney/ABC managers they would have to train their replacements before leaving, Computerworld reports. This is, of course, reminiscent of the move by Disney’s Parks and Resorts division to outsource 250 IT jobs to workers allegedly brought in under the H-1B visa program and have many of those employees train their replacements in order to receive severance. The furor this created when it was reported recently by mainstream publications such as the New York Times may have led Disney to cancel the latest layoffs, a source told Computerworld.

“They [Disney officials] want this to go away — right now,” said the source, a Disney/ABC IT employee who asked not to be named.

A source at Disney confirmed to Computerworld that the layoff had been rescinded. Although Cognizant is a major user of H-1B visas, it is unclear whether any of the workers in the Disney/ABC project had been brought in under the program.

Other companies besides Disney have come under fire for replacing their IT workers with H-1B visa holders, including Southern California Edison. The Department of Labor has announced it will investigate two outsourcing companies, Infosys and Tata Consultancy Services, for possible violations of rules for H-1B visa holders in conjunction with work they did for Southern California Edison. Those two companies, along with several others, are the biggest recipients of H-1B visa allotments each year. Sen. Bill Nelson, D.-Fla., has also called for an investigation of the H-1B program.

The fracas continues to focus more negative attention on the H-1B program. In a post on his blog, longtime tech observer and consultant Robert X. Cringely labels the  H-1B program “a scam” and says the argument that it’s necessary due to a shortage of technical talent here in the United States is false. He quotes an anonymous source, identified as a former chief technology officer at several companies, who said that — throughout his career — H-1B visa holders were routinely brought in by companies as a cheaper alternative to hiring more-expensive American tech workers: “The reason of course was $$$.  The H1B’s cost approx. 1/3rd or 1/4th the cost of the comparable American in the same job.”

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Clearing the Haze Around Medical Marijuana

smokeEarlier this week, the Colorado Supreme Court handed down a ruling that one attorney says “may serve as a roadmap” for other courts—and employers—navigating the gray areas surrounding medical marijuana laws.

On Monday, the state high court’s 6-0 decision in Coats v. Dish Network determined that an organization can terminate an employee for using medical marijuana, even if said marijuana use occurs while off-duty.

Court documents indicate that former Dish Network employee Brandon Coats has been confined to a wheelchair since he was a teenager, as a result of injuries sustained in a car accident. Court records indicate that Coats registered for and obtained a state-issued license to use medical marijuana in 2009, as a way to treat leg spasms brought on by his quadriplegia.

On June 7, 2010, however, Coats was fired from his job as a telephone customer service representative with the Dish Network, after testing positive for tetrahydrocannabinol—a component of medical marijuana—the previous month.

At the time, Coats informed the company that he was a registered medical marijuana patient, and planned to continue using medical marijuana, according to court records. After being fired for violating the organization’s drug policy, Coats filed a wrongful termination claim against Dish, alleging the company was prohibited from firing an employee based on his or her engagement in “lawful activities” off the employer’s premises during non-working hours. Coats argued that his off-the-clock and away-from-work medical marijuana use was lawful under the Medical Marijuana Amendment and its implementing legislation.

In affirming lower court rulings, the Colorado Supreme Court found the term “lawful” applies only to those activities that are legal under both state and federal law. Ergo, employees engaging in activities such as medical marijuana use that are permitted by state law but forbidden by federal law are not protected by the statute.

While not binding in other states, this Colorado ruling could hold lessons for employers elsewhere, John DiNome, a Philadelphia-based labor and employment attorney and partner at Reed Smith, told HRE this week.

“The short takeaway,” says DiNome, “is that Federal law trumps state law. The Federal Controlled Substance Act lists marijuana as an illegal substance. As such, use of marijuana is not a lawful activity in Colorado.”

For employers, “this seems to confirm that, if they choose to have a ‘zero-tolerance’ policy with respect to drug use, they are on fairly solid ground in doing so.”

As such, “even if an employer is operating in a state where marijuana is either legal for medical or recreational use, the employer may ban use of illegal drugs and take the position that marijuana is not legal at the federal level,” he says.

DiNome notes that, while the Justice Department has said it will not prosecute certain marijuana use offenses, “the fact remains that Congress has not addressed the topic, and marijuana is still an illegal substance under federal law.”

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A Sampling of What to Expect at HR Tech

In case you didn’t notice, this year’s full HR Technology Conference and Exposition® agenda was posted online about a week or so ago and was officially announced yesterday by HRE, via a press release. 200213603-001As you’ll see, the program continues to build on many of the general and concurrent sessions that have resonated with HR and HR IT leaders and professionals at past events. It also features a number of new and exciting additions. Here are just a few of the highlights mentioned in the release …

  • The return of the “Awesome New Startups” session, showcasing  HR technology innovators that are pushing the envelope.
  • Live demonstrations of “Awesome New Technologies for HR,” featuring new solutions from industry leaders.
  • Recognition of HRE’s “Top HR Products of 2015.”
  • HR Tech’s first-ever Hackathon, providing attendees with an exclusive peek into how today’s technology vendors develop solutions that address real-world HR and business challenges.
  • HR transformation and employee-driven organizational-culture shifts at companies such as Cisco, Delta Air Lines and MGM Resorts International.
  • The latest developments in mobile HR technology, as told through the experiences of companies such as Ovation Brands, PwC, Texas Mutual Insurance Co. and Marriott International.
  • Examples of successful HR technology strategies and implementations that have gotten it right in areas such as HCM, talent acquisition, employee engagement and change management.
  • Results from the 18th Annual Sierra-Cedar HR Systems Survey.
  • A closing general session featuring some of the most innovative thinkers in HR, who will share cutting-edge ideas about HR, technology and the workplace in a fast-moving “Ignite”-style format.

There also will be keynotes by two industry luminaries, Marcus Buckingham and James Whitehurst. New York Times best-selling author Buckingham will discuss a radically new approach to equipping team leaders with the tools they need to enhance employee engagement and improve performance management. Red Hat President and CEO Whitehurst, meanwhile, will share how unleashing the power of openness within an organization can transform corporate culture and drive higher levels of engagement and business performance.

And, of course, HR Tech will again feature the world’s largest expo of HR technology products and services.

Be sure to check out the full program at the conference’s website, linked above, if you haven’t already. Hope to see you there.

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Drug Use, Addiction at Work Continues to Rise

The use and abuse of drugs in the workplace isn’t slowing down at all. Latest reports indicate the percentage of American workers 73267092 -- drugs at worktesting positive for illicit drugs such as marijuana, cocaine and methamphetamines has increased for the second consecutive year in the general U.S. workforce — putting an end to the decades-long decline.

Indeed, this article references a government report that finds nearly one in 10 full-time workers now has a substance-abuse problem. And the latest Quest Diagnostics Drug Testing Index shows an upsurge in the positivity rate of drug tests by 9.3 percent — from 4.3 percent in 2013 to 4.7 percent in 2014. (Here is an additional link to the actual tables/stats within the index.)

“American workers are increasingly testing positive for workforce drug use across almost all workforce categories and drug-test-specimen types,” says Dr. Barry Sample, director of science and technology for Quest Diagnostics Employer Solutions. “In the past, we have noted increases in prescription-drug-positivity rates, but now, it seems, illicit drug use may be on the rise, according to our data.

“These findings,” says Sample, “are especially concerning because they suggest that the recent focus on illicit marijuana use may be too narrow, and that other dangerous drugs are potentially making a comeback.”

Dr. Robert DuPont, former director of the National Institute on Drug Abuse, says this latest analysis by Quest not only “suggests that illicit drug use among workers is increasing broadly for the first time in years in the United States [but that] public and private employers might want to consider revisiting existing substance-abuse policies to ensure that they are taking the necessary precautions to protect their workplace, employees and businesses.”

Equally concerning is the fact that abuse of legal drugs is also going up, as this news analysis by Andrew McIlvaine addresses. Drugs taken for attention-deficit-hyperactivity disorder — such as Ritalin, Adderall and Focalin — are now being abused by employees looking to add some sparks to concentration and alertness.

Will Wesch, Novus Medical Detox Center director of admissions, says many organizations are now updating their language in drug-free workplace policies to include potential impairment from a prescription drug. He urges HR practitioners to coach managers in how to engage employees suspected of such abuse and offer reasonable accommodations, up to or including modifying job responsibilities should an employee inform him or her that the medication he or she is on may impair job performance.

As for specific policies, concerns and approaches HR leaders should be considering right now when it comes to all workplace drug use, DuPont has this to offer:

“First, look at the big picture in workplace drug testing. There is much more to workplace drug testing than just testing for marijuana. An effective drug-free program includes testing for many widely used drugs [including prescription]. Second, consider the legal complications of workplace marijuana testing.  For example, several states allowing medical use of marijuana are now requiring an employer to show impairment before taking action against an applicant or employee who tests positive for marijuana. These provisions pose a significant limitation to workplace drug-testing programs for marijuana.

“I also recommend you provide clarity in your drug-free policies. … Every employee must be informed of the company’s substance-use policy and the reasons for the policy. Drug testing needs to be described in a written statement of the employer’s substance-use policy. This policy statement must clearly lay out the elements of the drug-testing program, including who is subject to testing, how testing is administered, how positive results are confirmed and what the consequences are for positive drug-test results. Supervisors and human resource staff should be trained in the employers’ substance-use policies and procedures, and be able to explain them to all employees and job applicants.”

And, again, when it comes to marijuana, DuPont says, “pay close attention to the specifics of state and local law,” obviously and especially in those states where it’s medically or recreationally legal. And make sure your drug-testing policies are being reviewed by attorneys “who are familiar with federal, state and local laws … particularly related to marijuana.”

Yes, folks, it’s a whole new world when it comes to drugs at work. DuPont says it’s time to consider “going beyond the urine cup and … the typical five-drug tests” and embrace the bigger picture now upon us.

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Do HR Leaders Have What It Takes?

This past Tuesday, I had a chance to hear Bill Conaty, HRE’s 2004 HR Executive of the Year, share his insights on how chief HR officers can be more effective leaders during the National Academy of Human Resources’ 13th CHRO Academy, held at the Yale Club in New York.

Bill Conaty, speaking in New York on Tuesday. (Photo by Robert Knowles)

Bill Conaty, speaking in New York on Tuesday. (Photo by Robert Knowles)

Conaty addressed his remarks to about 30 CHROs attending a dinner at the two-day, invitation-only event, which is held annually and specifically focuses on the needs of CHROs who are new to the job, have moved to a new employer or have a new CEO. As far as I know, there’s nothing comparable in the field today. (The faculty for CHRO Academy primarily consists of NAHR Fellows.)

A Distinguished Fellow in the NAHR, Conaty retired as senior vice president of HR at General Electric in 2007, but still remains quite active in the field and advises business leaders on a wide range of HR issues through his firm Conaty Consulting LLC.

In his talk, he touched on a number of important topics—but for purposes of this post, I’d like to specifically focus on his comments about what it takes to be a strong HR leader today. His list was based on the specs he had for his own job while at GE and reflected many of the qualities he was looking for in his own successor, though he was quick to point out that he didn’t necessarily fulfill each and every one of the items himself. Whether you’re new to the CHRO role or not, perhaps they might prove helpful in elevating your own game.

First on Conaty’s list: Ensuring that there’s a good fit between the CHRO, CEO and CFO posts. Conaty shared how CEO Jeff Immelt, one year, did something at GE that hadn’t been done before: He asked to take a close look at the CEO, CFO and HR leader in each GE business. “What he was looking for was styles and fits,” he said, “If you had a CEO who was a hammer, a CFO who was a hammer and an HR leader who was a hammer, employees had no chance.”

Stressing the importance of having the “right balance,” Conaty said the exercise resulted in “changing a couple people out.”

Also on Conaty’s list is being able to earn the trust and confidence of the entire senior leadership team. “I’ve heard a lot HR folks say ‘I have a phenomenal relationship with my CEO—I’m in,’ ” he said. “I’ll tell you how long you’re in for: about 18 months. And then you’re going to get sucker punched and you’ll never know where it came from. The CEO is going to say, ‘Bill, I love you but no one else does—so we’re going to need to wrap this game up.’”

As the CHRO, Conaty said, “you have to work the whole 360.”

Other qualities Conaty cited included being a “talent magnet,” a great assessor of talent, someone who is able to operate in a global marketplace, a clear thinker and a change leader.

CHROs, he said, also need to have the ability to think through business issues and a capacity for complex problem solving. “You’ll still get some of the easy treadmill ones,” he said, “but you’re probably also going to confront things you haven’t confronted before … .”

His list also includes attributes such as operational savvy, decisiveness and the courage to make the tough calls, along with the need to be a continuous learner. You don’t want a person in the role who says he or she’s “ ‘been there, done that. I’ve seen it all,’ ” he said. “I never saw it all in my 40 years at GE. It was always a new day.”

At the end of the day, Conaty said, your job is to take [issues] off the CEO’s desk, not add to the pile. Conaty said he made it a point to never add to CEO Jack Welch’s pile. (I’m assuming the same was true when Immelt took the reigns.) If an issue arose that he felt Welch needed to be aware of, he said, he would bring it to his attention, but then tell him that he would take care of it and, if he couldn’t, would then get back to him. If you follow this approach, Conaty said, you’ll be “a welcomed face when you stick your head through that door.”

And who wouldn’t want to be a welcomed face when he or she entered the CEO’s office, right?

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A Great Present for (Some) Employees

Sir Richard Branson (photo by Chatham House)

Sir Richard Branson (photo by Chatham House)

The U.K.’s Sir Richard Branson is quite a generous guy. For example, employees at the management and licensing division of his Virgin Group company are entitled to an unlimited number of vacation days each year (I should note that unlimited-leave policies such as this are not without controversy).

Now, the blonde-maned Englishman has introduced an expansive leave policy for new parents at his 140-employee management offices in London and Geneva, Switzerland: 12 months of paid leave, for both parents, for the birth or adoption of a child. What’s more, the company may expand this policy to its office in the U.S. — the only industrialized nation that does not mandate paid leave for new parents.

“We are in the process of working hard on making this happen in the U.S. and hope to have an update in the coming months,” a Virgin spokesperson told ABC News.

Virgin Group’s paid paternity leave policy lets parents who’ve worked for the company at least four years to receive their full salary over 52 weeks of shared parental leave, regardless of gender. Employees with fewer than two years of service will receive 25 percent of their pay.

Generous, indeed — but then again, this benefit is available only to a small percentage of Virgin’s 50,000 or so employees (.2 percent, according to Bloomberg). Companies such as Google, Facebook, Bank of America and PricewaterhouseCoopers all offer from seven to 17 weeks of paid parental leave to their employees — far less than Virgin Group, but to a much greater share of their employee population.

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HR’s Not Dead, It’s Just Changing Names

name tagA quick Google search of the phrase “human resources is dead” brings back approximately 27,800,000 results.

On the first page of results alone, you’ll find articles declaring HR’s downfall—or calling for the human resource function to be dismantled—dating from 2002 all the way up to just a few hours ago.

In other words, reports of the HR department’s demise are in no short supply, and are nothing new.

One of the latest missives comes from the Huffington Post and Jacob Morgan, who earlier this week penned an online piece entitled “Why Human Resources Is Dead.”

Now, some articles of this ilk have written off HR as a largely useless, bureaucratic function that has no real potential as a “strategic partner” and needs to just go away. Others—think Fast Company’s 2005 “Why We Hate HR” feature—describe human resources as a “necessary evil” within the organization; a department that could really contribute to business performance but ultimately underwhelms.

Familiar headline aside, however, Morgan’s piece doesn’t follow either of those well-worn narratives.

In fact, human resources isn’t even really dead, he says. Rather, the profession is just undergoing an identity makeover of sorts, or a rebranding.

“Companies are dropping the term ‘human resources’ altogether and are shifting towards more ‘people-centric’ terms,” writes Morgan, a futurist, consultant and author of The Future of Work.

Titles such as chief people officer, vice president of people operations and chief talent officer are becoming the norm, he says, replacing your oh-so-old-school monikers like chief human resource officer, for example.

Morgan acknowledges that this isn’t a new phenomenon, noting that some companies “have had these titles and departments for several years already.”

Lately, however, he says he has seen this transition “accelerate dramatically.”

Morgan cites a number of companies as examples of this evolution in action. Cisco’s Francine Katsouda, for instance, recently saw her title change from CHRO to chief people officer. Anne Byerlein at Yum! Brands shares the same designation. There’s Laszlo Bock, of course, the senior vice president of people operations at Google, and the list goes on.

But does bestowing these “nontraditional” titles upon HR leaders portend real changes in what the function actually does, at these organizations or elsewhere?

Morgan seems to thinks so.

“Most of the companies I have been speaking with or researching,” which include Cisco, Google, Glassdoor and LinkedIn, have all made “considerable strides in rethinking what the purpose of traditional ‘HR’ is, and all of these companies have moved on from looking at employees as capital assets,” he says.

I agree with Morgan in thinking the notion of employees as capital assets is antiquated. And, frankly, using such terms to describe thinking, feeling human beings has always seemed a bit cold and callous.

So, if employees have truly come to be seen as something more than “capital assets” or “human capital,” then that’s a positive. But, beyond that, Morgan’s short piece doesn’t get into detail as to how the aforementioned organizations are transforming their HR functions. So we’ll see whether we’re really on the cusp of what turns out to be a drastic reimagining of how HR works and what it does.

In the meantime, though, if the actual term “human resources” is truly on its way to extinction, then I suppose we here at HRE should probably start brainstorming new names for our publication.

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Staples Settles After FMLA Fail

Let’s put this next story in the “Why It’s Important to Make Sure Your Employees Know Their Family and Medical Leave Act Rights” file:

Late last week, the U.S. Department of Labor announced a settlement that was reached in a consent decree and approved by a federal court with Staples Inc., with the company agreeing to pay fired employee Jeffrey Angstadt $275,000 in wages, benefits and damages after failing to inform him of job protections to care for his ailing wife.

(A request for comment from Staples has yet to be returned.)

According to the DOL’s investigation, the furniture sales executive told his employer, Staples Contract and Commercial, Inc., a South Carolina-based subsidiary of Staples, Inc., that he needed to take leave to care for his critically ill wife in September 2010. But, the DOL notes:

While Angstadt was eligible for federal workplace protections for those coping with the illness of a family member, no one at Staples notified him as the law requires.

So, for the next two years, Angstadt used his personal, sick and vacation days, and worked remotely as needed to balance his work obligations and to care for his wife.

In January 2012, the DOL says, his supervisors decided Angstadt wasn’t meeting his job responsibilities, and the company fired him. Two months later, an investigation began by the U.S. Department of Labor’s Wage and Hour Division district office in Columbia, South Carolina. Following the investigation, the department then sued Staples in June 2013 for violating the Family and Medical Leave Act.

Said Wage and Hour Division Administrator Dr. David Weil in announcing the settlement:

“For more than 20 years, the Family and Medical Leave Act has been a critical safety net for working families. It ensures that no one should have to choose between the job they need and the family they love.”

As a part of the settlement, the company will also promote an enterprise-wide policy for compliance with the FMLA by providing training for human resources and other managerial personnel with respect to FMLA notice and eligibility requirements; post FMLA enforcement posters in the workplace; and investigate and respond to complaints of potential FMLA violations concerning an employee’s notice of FMLA rights, including correcting violations when discovered.

Unfortunately, Angstadt’s wife died in 2014 and did not live long enough to see justice served in her husband’s case.

Indeed, “when an employee must be away from work to care for a loved one, there are no second chances to get it right,” said Wage and Hour Division Administrator Dr. David Weil.

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