Policy articles – Page 2 – ARA University Success Center

Don’t make handbook promises you’re not prepared to keep

Handbooks are a necessary part of managing the workforce. But drafting handbook language can be tricky. You don’t want the whole handbook to become a binding contract, but you do want employees to understand they have to follow the rules.

But you may want some sections of the handbook to be binding—such as an agreement to arbitrate any employment disputes rather than take them to a state or federal court.

So what’s the best approach? Include language in your handbook that explains the rules, but leaves it up to the organization to make changes whenever necessary.

Page by page, turn your old handbook’s vulnerabilities into legal strengths. Protect your at-will status, write legally sound disclaimers, and avoid these 12 common handbook mistakes— Start Here…

Advice: Consider treating arbitration agreements as separate documents, so they do become contractually binding.

Recent case: Theresa Niebrugge sued her employer, King’s Medical Group, for allegedly unpaid overtime hours. The medical practice asked the federal court to dismiss the case because it claimed employees were bound by an arbitration agreement. The practice said arbitration was mandatory to resolve any employment disputes.

Niebrugge argued that there were several versions of the company handbook. The first said that arbitration was a voluntary option. That original handbook also said that it “may be amended at anytime.” Niebrugge said she understood that the company would inform her of any handbook changes. When the company electronically sent a new version of the handbook, it required employees to click through to show they had received the material. The instructions included the statement, “I understand that I will be told about any handbook changes.”

That was enough for the court to hang onto the case a bit longer. Niebrugge claims she was never told that the click-through handbook agreement included any changes from the earlier arbitration agreement. The employer will have to show she got that notice, since it was promised. (Niebrugge v. King’s Medical Group, No. 08-1018, CD IL, 2008)

Final note: Had the employer left out the promise to tell employees about any changes and simply informed them that it retained the right to make any changes it saw fit, the case probably would have been dismissed.

8 Reasons Your Organization Should Have an Employee Handbook

8 Reasons Your Organization Should Have an Employee Handbook

Introduces Employees to the Organization’s Culture, Mission, and Values
Perhaps the most important aspect of your Employee Handbook is the introduction of new employees to your corporate culture and how they will fit in. This helps to foster a sense of pride and belonging, which studies show will help employees become more productive in a shorter period of time. The introduction section of an Employee Handbook will answer these questions: “What do we do that sets us apart?” “How did the company get here?” “What are we passionate about?” “How can I, as a new hire, become a part of this culture?” The introduction section sets the standard for the employment relationship in general, and provides a guidepost for the remaining policies communicated in the handbook.

2) Communicates to Employees what is expected of them
A well-written handbook provides employees with a clear understanding of their responsibilities. The handbook also serves as a compass for the organization’s policies and procedures. For example, it advises employees what the procedures are for requesting time off or a vacation. It advises employees whom they should contact when they have an unscheduled absence (and what the timing should be). It tells employees whom to go to if they have questions about any of the specific policies in the handbook. The handbook also communicates an employee’s general responsibilities regarding safety, timekeeping, reporting, and so on. By providing this clear, accessible information, handbooks ensure companies continue moving in the right direction.

3) Educates Employees About What They Can Expect From Management and Leadership
An employee handbook clarifies company objectives and leadership styles, as well as management best practices, to foster healthy management-employee relationships. It also outlines logistics, such as timekeeping requirements, hours of work, pay periods, and so on. Further, a complete employee handbook advises employees of their various entitlements to federal and state leaves, such as FMLA or Jury Service Leave. These clearly communicated policies help to eliminate confusion and inconsistencies that result when handbooks are silent on these topics.

4) Helps Ensure Key Company Policies are Clearly and Consistently Communicated
No policy is effective if it is practiced inconsistently. A handbook will accurately communicate your organization’s policies regarding employment, conduct and behavior, compensation, and other policies and procedures your organization follows. Most importantly, managers can refer to the handbook when answering questions or making decisions regarding your policies, and ensure their answers and actions are consistent with your policies and best practices.

5) Showcases the Benefits the Organization Offers
Does your organization offer vacations, 401k, health insurance, paid parental leave, or other benefits to employees? Make sure they know about these policies and the eligibility requirements by communicating them in the handbook. A robust benefits package can help you retain your best and brightest employees, so be sure they know about your full suite of offerings by communicating these in the handbook.

6) Ensures Compliance with Federal and State Laws
No matter what state you do business in, or how many employees you have, you will be subject to state and federal employment laws. Your handbook not only communicates these various entitlements and obligations to employees, but is useful in demonstrating that your organization strives to be compliant with these regulations. For example, if your employee is called away to active-duty military service, you will want to be sure they understand their rights and obligations when communicating their need for leave to you. Your Military Leave Policy should clearly define these parameters to the employee. Similar policies should communicate rights and obligations regarding state disability leaves, federal FMLA leave, and other government mandates.

7) Helps Defend Against Employee Claims
Unfortunately, employers should consider it a matter when, and not if, they will face a lawsuit or similar challenge from a current or former employee. When this happens, one of the most useful documents you can provide your attorney or third party investigator will be a copy of your handbook. A thorough and compliant employee handbook will help to show that the organization exercised “reasonable care” towards its employees. The employee’s signed acknowledgement page will show that the employee had an opportunity to familiarize themselves with the organization’s policies, a chance to ask related questions, knew whom they could turn to for help within the organization, and agreed to follow the terms and conditions of employment set forth by the organization.

8) Lets Employees Know Where to Turn for Help
Ultimately, you want employees to feel comfortable turning to a trusted member of management for help when they want to report workplace violations, get workplace-related assistance, and get answers to any other questions they may have. The alternative is for them to turn to an outside third party, like the EEOC or DOL, which could trigger a costly and time-consuming investigation. When a handbook not only outlines one or two management individuals for an employee to turn to in these situations, but also designates another individual to turn to in the event the employee disagrees with the first decision, they are more likely to keep their complaints in-house, and this is a good thing for employers

4 common mistakes lurking in your manual

Company policies lay the foundation on which employment expectations are formed. There’s no time like the present to audit your organization’s policy handbook. Start by checking that your organization’s policies don’t fall into these four policy writing traps.
Do-It-Yourself Employee Manual — Get the blueprint for your whole company manual…
Mistake #1
Disclaimers Too Few and Far Between

Some employers mistakenly believe that adding a single disclaimer to an employee policy handbook is all they need to do to give themselves the latitude to bypass, revise, or replace existing policy provisions. If, however, employees are left scratching their heads after reading the disclaimer or searching for it within the text of the handbook, chances are good that the disclaimer will carry little legal weight should any of your organization’s policies be legally challenged.

Here are 5 disclaimers and qualifiers you organization’s manual needs:
• Opening disclaimer, which, in no uncertain terms, states that the handbook is not a contract of employment and that the employment relationship is at-will.
• Benefits section qualifier, which explains that benefits or premium contributions may change at the company’s discretion and that if there is a conflict between language in the employee handbook and language in an official plan document (such as a group health insurance policy), the official plan document governs.
• At-will reminder. In any discipline policy or complaint resolution policy, restate the employer’s right to discipline or terminate an employee at-will, with or without cause.
• Misconduct qualifier. In any list of misconduct examples, state that the list is not all encompassing or not all inclusive.
• An acknowledgment, upon which an employee’s signature means that he/she acknowledges: receiving a copy of the handbook, reading it, understanding it, having had the opportunity to ask questions about it, having had it explained, that the handbook is not a contract of employment, and that the employment relationship is at-will.
Mistake #2
Provisions that are too open to interpretation
No matter how well-worded you think a policy appears, there’s a chance that some employees may be confused by it. Sometimes, that confusion is a result of the language used. Just because you’re familiar with certain terms, doesn’t mean rank-and-file employees are, too. Always read policies with an eye out for HR jargon or legalese.
Mistake #3
Requirements that are too stringent
Another mistake employers commonly make when drafting policies is including more stringent requirements than called for by federal and state law. In some instances, this is perfectly acceptable, as long as you don’t penalize employees for failing to meet these more stringent requirements.
Best bet: Keep policies in step with legal requirements. Before actually writing a policy, consider whether there are any applicable laws no matter what the topic is.
Mistake #4
Protections that are too one-sided
Don’t forget to equally address all potential parties in a policy.
Case in point: One company’s policy on union harassment stated: “This is a non-union organization. It always has been and it is certainly our desire that it will always be that way….You have a right to join and belong to a union and you have an equal right NOT to join and belong to a union. If any other employee should interfere or try to coerce you into signing an authorization card, please report it to your supervisor and we will see that the harassment is stopped immediately.”
While the policy might have been intended to protect union supporters and detractors alike, the 7th Circuit deemed it unlawful. Reason: The policy lacked an “equal protection guarantee” for union sympathizers

What is Not Harassment?

The anti-discrimination statutes are not a general civility code. Thus, federal law does not prohibit simple teasing, offhand comments, or isolated incidents that are not extremely serious. Rather, the conduct must be so objectively offensive as to alter the conditions of the individual’s employment. The conditions of employment are altered only if the harassment culminates in a tangible employment action or is sufficiently severe or pervasive to create a hostile work environment.

Hostile Work Environment Laws

There are no Federal “hostile work environment laws” or “hostile workplace laws” named as such. Creating a hostile workplace is prohibited under certain Federal discrimination laws (listed below).

Subsequently, to be illegal under one of the laws in the eyes of the courts, a hostile work environment typically must be caused by discriminatory workplace harassment based on race, color, religion, national origin, disability, age or sex. Additionally, the harassment typically must be severe, recurring and pervasive.

Lastly, the victim or witnesses typically must reasonably believe that tolerating the hostile work environment is a condition of continued employment. In other words, the victim or witnesses typically must reasonably believe that they have no choice, but to endure a hostile workplace in order to keep their jobs.

Defining the hostile work environment
According to the law, there are two forms of sexual harassment:

Quid pro quo harassment, which means “this for that,” is where a supervisor threatens to fire or not promote an employee if he or she doesn’t have sex with that supervisor.
Hostile work environment harassment is where speech or conduct is “severe or pervasive” enough to create a hostile or abusive work environment. Examples of inappropriate conduct of a sexual nature include sexually oriented jokes, sexually explicit e-mail, screen savers, posters, cartoons, and graffiti, and unwanted verbal and physical contact. The standard used by civil rights agencies and courts in determining whether a hostile work environment exists is whether a reasonable person, in the same or similar circumstances, would find the conduct offensive.

Put it in writing
Chrys Martin focuses on employment law from the management perspective in the Portland, OR, office of Bullivant Houser Bailey. She said that managers have “the legal responsibility to make sure the workplace is free from harassment or discrimination.”

“Managers should ensure that their employees do not feel uncomfortable because of behavior in the workplace, such as teasing, taunting, jokes, and inappropriate gestures,” said Martin.

To help create this environment, every employer needs a comprehensive policy that prohibits all types of harassment. “The policy needs to include a definition of what could constitute harassment or create a hostile work environment, information on who to report to, and a nonretaliation provision,” said Martin.

Employees must also be provided with a copy of the company’s policy and trained on what constitutes harassment and discrimination. In addition, employees need to know what steps to take if they become victims of such behavior.

Carol Merchasin, a partner at the Chicago office of Seyfarth Shaw, also works in the area of employment law. She designs and develops training sessions for clients on a wide range of employment law topics, including the Internet and dating relationships between managers and subordinates.

According to Merchasin, when courts rule against a plaintiff in a sexual harassment suit, many times it’s because a company can prove that it had a detailed harassment policy in place and that it took appropriate action when a report was made. Such measures can reduce a company’s and a manager’s liability.

Be professional and follow procedure
Managers need to know what is going on in the workplace at all times and be aware if inappropriate behavior exists, according to Martin. They also need to set an example by not engaging in harassment themselves and by stopping it immediately if they hear it or see it.

Merchasin said that it is important for a manager to use caution in the “danger zones, such as comments on personal appearance, jokes, cartoons, and nicknames that demean others on the basis of their race, gender, ethnic origin, religion, age, disability, and sexual orientation.”

“Remember, harassment can be created even if you did not intend to harass anyone. Even if no one complains to you, you need to be alert to conduct that is inappropriate and make sure that you put an end to it,” Merchasin said.

All violations must be reported immediately to the human resource department. Martin said, “The employer must take prompt remedial action to stop the harassment and make sure it does not recur, including discipline or termination of the offenders if need be.

“Employers have an obligation to maintain a workplace free from harassment and discrimination. They must stop behavior when they first learn of it rather than waiting until someone complains,” said Martin. “It is critical that employers train all managers and supervisors on what constitutes harassment and discrimination and how to deal with it if it occurs.”

Harassment Investigations

Recent court decisions emphasize that it is not enough just to have a

written harassment policy. You also must make sure that it is

implemented in an “effective” manner. This standard means you must

be proactive and take steps to apply your policy properly. In particular,

you must be prepared to conduct an investigation to determine the

nature and extent of any alleged harassment.

* Basic Principles of Harassment Investigations *

As a general rule, all harassment complaints should be investigated,

even when the complaining employee requests that nothing be done or

when the complaint is anonymous. The investigation should be

undertaken promptly and completed as expeditiously as possible, for

several reasons.

First, the disruption caused by actual harassment or rumors can be

substantial. In addition, as time passes, evidence can be lost and

witnesses’ memories often become less accurate. Furthermore, the

longer a resolution is delayed, the more stressful the situation becomes

for the complaining employee or for an unjustly accused defendant,

which can lead to subsequent legal claims for emotional distress. And,

case law has established that employers are liable for failing to take

prompt and effective action to eliminate known hostile work

environments. Therefore, investigations typically should be completed

within a few days.

* Who Should Conduct the Investigation *

Ideally, the investigator should be a human resources professional who

is specially trained to conduct harassment investigations. This training

helps assure that all important aspects of the situation are considered,

including whether multiple complaints have been received about the

same individual. The investigator also should understand what

constitutes harassment under both your organization’s policy and the

law, in order to evaluate the complaint properly.

Whenever possible, it can be helpful to have a person from management

outside the human resources department assist in the investigation. In

addition, when the allegations involve sexual or gender harassment, it is

a good idea to have both a man and a woman investigate the complaint

together. Some employers use an outside investigator or the Board of

Directors if the complaint indicates that harassment is pervasive or

involves top management employees.

* The Investigation Process *

The process should provide a fair method for both sides to be heard and

to receive information. Most experts recommend interviewing the

complaining party first to ensure that all important details and witnesses

are identified promptly. Investigators should be sensitive to the

emotional nature of this type of investigation and should be prepared to

deal with employee embarrassment and anger and be patient, but firm,

in explaining that details are needed for an accurate investigation.

The interview of the alleged harasser may be even more difficult

because of the natural instinct of the accused to be defensive.

Therefore, interviewers must be objective and nonjudgmental and allow

the accused to respond to each allegation. The investigator also should

explain the disciplinary action possible if the allegations are found to be

true. However, investigators should not use threats to obtain

information, but should explain matter-of-factly the consequences of not

cooperating. Both parties should be told to avoid contact with one

another, and you should implement measures to minimize this contact.

Witnesses also should be interviewed as soon as possible. All

responses should be documented and, if possible, statements should be

reduced to writing and signed by the persons providing the information.

In addition, all participants in the investigation should be reminded that

their cooperation and confidentiality are required, that your policy

prohibits retaliation, and that any retaliation must be reported

immediately, should it occur.

* Focus on Fairness *

Harassment investigations can be difficult and time-consuming. But,

they are a vital component of your harassment policy. If you conduct

them properly, they can help ensure that your decisions are based on

facts and perceived as fair. And, in situations where you determine that

your harassment policy was not violated, a thorough investigation will

provide strong support if you are challenged in court or by a government

agency.

Alcohol, Holiday Parties, and Liability (Part 2 of 2)

Unfortunately, it is true that if you permit employees to consume alcohol
at business events, you have an increased risk of legal liability. Most
claims of liability involve employees who become intoxicated at an
employer-sponsored function and then injure coworkers or others.
These cases are brought under a variety of legal theories and focus on
the employer’s responsibility for its employees’ actions. (These legal
theories were introduced in last week’s E-Tips. If you missed that issue,
click here for a copy: http://www.ppspublishers.com/ez/html/120604txt.html

As discussed last week, though, you are shielded from liability in most
states under “dram shop” (seller liability) and social host theories.
Still, no one wants to be in the position of defending an unpleasant case
involving injuries or death. A better approach is to prevent these
accidents and problems altogether by taking some common sense steps
to limit alcohol consumption and its effects.

* To Serve or Not to Serve *

So what’s an employer to do? Your most conservative policy option is to
ban alcohol consumption in all business settings, including holiday
parties. However, many may view this prohibition as unduly protective or
unwelcome, especially for essentially social or team-building functions.

Therefore, a more practical solution is to have a clear policy statement
requiring employees to exercise moderation and good judgment when
drinking at a business function. Obviously, for such a policy to be
effective, top management must support it and set a good example.

In addition, if your organization decides to serve alcohol at its business
functions, your best bet is to manage the situation carefully and enforce
certain limits, while also requiring employee moderation and good
judgment. The following eight steps can help you do that.

1. Have a clear policy prohibiting the use of alcohol (and illegal
drugs) while working. The policy should include any exceptions for
business social functions and entertaining.

2. Make it clear that employees who become intoxicated at
employer-sponsored events will be subject to discipline.

3. Remind employees that work rules regarding appropriate
behavior and prohibiting harassment apply to employer-sponsored
events.

4. Limit the availability and consumption of alcohol by stipulating
that it may be served only for a set period of time.

5. Do not allow supervisors to purchase alcoholic drinks for
employees.

6. Serve substantial food that can offset the effects of alcohol.

7. When possible, hold events at restaurants or other sites not
operated or staffed by the employer.

8. Have a designated monitor to make sure that intoxicated or
impaired employees do not drive themselves home.

Alcohol, business entertaining, and employee functions are a volatile
mix. You need to understand your organization’s needs and
responsibilities before setting policy. If you don’t want to prohibit
alcohol consumption totally and thus be viewed as the “holiday grinch,”
then take the above steps to control consumption, require accountability,
and limit your exposure.

Alcohol, Holiday Parties, and Liability (Part 1 of 2)

Does your organization serve alcohol at the annual holiday party? Or, do
you sponsor department “happy hours” on Friday afternoons to
encourage teamwork and interaction? Unfortunately, if you do, you
increase your risk of legal liability if a drunken employee harms himself
or others.

Employers can be sued for their intoxicated employees’ misdeeds under
a number of different legal claims and theories, ranging from workers’
compensation to sexual harassment to negligence. Fortunately, despite
overall increased litigation, employers generally are still shielded from
liability in most states.

Even with this shield, and regardless of actual negligence, the employer
remains a tempting legal target and is considered the “deep pockets”
when damages are sought. In this week’s E-Tips, you get a look at the
legal issues and some cases addressing employer liability for alcohol-
related incidents.

However, if you still want to serve alcohol at this year’s party, don’t
totally despair. In next week’s E-Tips, you also will find steps to help
prevent alcohol-related problems, or at least to limit your liability
exposure if they do occur.

* Respondeat Superior *

One of the biggest concerns for employers, when alcohol is involved, is
the potential for liability for injuries to nonemployees. Most often,
third parties injured by an organization’s intoxicated employee will claim
employer liability on the theory of “respondeat superior.” Under this legal
doctrine, the employer may be liable for its employee’s acts if they were
committed within the scope or course of employment.

For example, in Carroll Air Systems, Inc. v. Greenbaum, 629 So.2d 914
(Fl. App. 1993), the employer was liable for third party injuries caused
by an intoxicated employee. In that case, the employer paid the mileage
and automobile expenses for the employee to drive to and from the
meeting where alcohol was served and at which the employee became
intoxicated.

In contrast, in Mosko v. Ratheon Co., 622 N.E.2d 1066 (Mass. 1993), the
court found that the employer was not liable under respondeat superior
theory to a third party injured in a car accident involving an employee
who became intoxicated at a Christmas party partially sponsored by the
employer. The party was not on the employer’s premises or during
working hours, it provided no tangible benefit to the employer, and
alcoholic beverages were purchased from a cash bar staffed by the
restaurant.

* Workers’ Compensation Laws *

While respondeat superior legal theory deals with liability to third
parties, workers’ compensation laws deal with employer liability to its
own employees or their survivors. In general, these laws cover all work-
related injuries regardless of fault. However, they typically exclude
injuries that are incurred at employer recreational events where
attendance is not required or that are the result of the employee’s
intoxication on the job.

* Wrongful Death and Survivorship Statutes *

Employers may also be sued for alcohol-related incidents under state
wrongful death or survival acts. Under these laws, the personal
representative of a deceased person may file suit, on behalf of the
surviving spouse or next of kin, against any party whose actions caused
the death. The purpose of these laws is to compensate survivors by
providing the financial benefits that would have been received had the
person lived.

However, survivors have had little success suing employers for wrongful
death based on the intoxication of employees. For example, in DeRuyter
v. Wisconsin Elec. Power Co., 546 N.W.2d 534 (Wis. App. 1996), aff’d
565 N.W.2d 118 (Wis. 1997), the court determined that survivors of a
person killed in a car accident involving an intoxicated employee could
not bring a wrongful death claim against the employer. The court found
that, since the employee was driving to work, he was not within the
scope of his employment or under his employer’s control.

* Negligence *

Persons injured by intoxicated employees sometimes claim employer
negligence. These claims often arise in the context of the office party
where an employee becomes intoxicated, leaves the party, and injures
another person on the way home. The theory behind this claim is that
the employer owed a duty to the injured party to exercise reasonable
care and breached or violated that duty thereby causing harm to the
injured third party.

Courts have been hesitant to find that employers have a duty of care to
third parties except in situations where, for instance, the employer
continues to serve drinks to an obviously intoxicated employee. In these
situations, the deciding factor may be the employer’s authority to deny
alcohol to the inebriated employee.

In another interesting development in negligence theories, a few courts
have found that an employer may be held liable to third parties if it has
taken action to exercise control over the employee after the employee
becomes intoxicated.

* Harassment *

Besides personal injury claims, employers are also vulnerable to
harassment claims when inebriated employees make inappropriate
advances toward coworkers. In fact, the Seventh Circuit Court of
Appeals, in Place v. Abbott Laboratories, 215 F.3d 803 (7th Cir. 2001),
specifically noted, “office Christmas parties also seem to be fertile
ground for unwanted sexual overtures that lead to Title VII complaints.”

The court went on to cite approximately 20 cases where employees
complained of harassment occurring at employer-sponsored parties.
These cases underscore the potential problems associated with alcohol
consumption at any employer-sponsored event.

* Social Host Under “Dram Shop” Laws *

“Dram shop” laws, enacted in many states, may actually protect
employers from liability. These laws allow persons injured as a result of
their own or another person’s intoxication to sue the serving individuals
or entities if they are licensed by the state to sell or serve alcoholic
beverages.

In general, courts have not extended liability under state dram shop laws
to social hosts, and an employer usually is considered a social host
when it sponsors an event at which alcohol is served. But, note that the
employer may lose the protection of “social host” if it serves alcohol to
a minor.

Employee Personnel File Review / Audit Company Name

Name of Employee Date Reviewed

Type of File		YES	NO	NA	Comments
	*New Hire Recruitment and Employment*
· Application for employment
· Resume (if applicable)
· Signed offer letter
· Signed job description
· Applicable certificates and licenses
· Receipt of company property forms
· Applicable background investigations
· References
· Interview notes
· Applicable pre-employment tests
· Applicable state and local tax withholding forms
· W-4 withholding forms
· Emergency Information forms.
· Direct Deposit
· Certificate of Insurance
· Prescription Pad Order
·
·
	*Benefits*
· Election form – choice of benefits
· Other benefit related forms
o
o
	*On-going Maintenance*
· Obtained certificates and licenses
· Company property check-out forms
· Training records
· Safety training
· Promotions and transfers.
· Performance appraisals
· Compensation adjustments
· Changes in status
· Disciplinary notes
· Awards and commendations
· Timecards
· Wage garnishments.
· Leave Requests – Time Off Requests
· Business Expense Reimbursement submissions
· Updated tax forms changing status or withholding
· General Correspondence.

Type of File	YES	NO	NA	Comments
*Separation*
· Applicable resignation letter
· Signed receipt of property forms
· COBRA
· Exit interview
· Unemployment Claims

*Other*
· OSHA
· State or EEOC claims.
· Affirmative Action.
·
·
·
Type of File	YES	NO	NA	Comments
RESTRICTED FILES … MEDICAL … RESTRICTED FILES
· Emergency Medical Information
· Medical history information.
· Medical evaluations and related documents.
· Notes from doctors.
· Applicable Family Medical Leave Act (FMLA) Forms
· Requests for Americans with Disabilities Act (ADA) accommodations and related documents
· Workers’ compensation history, claims and related documents.
· Results of drug/alcohol tests and related documents.
· Any documents about past or present health, medical condition, or disabilities
·
·
RESTRICTED FILES … I-9 —- RESTRICTED FILES
· Note that I-9 forms are required to be completed within 3 days of hire; however it is advised that they are kept separately from the regular filing system
· Driver’s License
· Social Security Card
· Resident Alien Card
· Permanent Resident Card
· Passport
·

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Category: Policy articles