Author: Stephen Paskoff

009 is proving to be a time of intense trial for organizations and for the people who work in them. The worst economic climate in decades is intersecting with a new administration in Washington, whose intent it is to bring about greater workplace and business regulation. Even though this combination of forces brings great challenges, I believe that leaders can actively build upon the progress that their organizations have made and keep the commitments they have pledged for the future without disrupting operations or even incurring great expense. In fact, those commitments are more important than ever if leaders intend to weather the economic and legislative changes of the upcoming year.

The complex issues we face require leaders to do their jobs in a consistent and professional way. Of course, this will not just happen by itself. Organizations must adopt a simple, clear leadership behavior strategy. This strategy is as important as the individual steps leaders will take to review policies and communicate new standards as they arise.

In truth, many organizations have sorely tested the trust of their workforces in recent years, and employees are not only anxious about their jobs, but doubt that they can rely on their employers for honest communication and professional treatment. Employers can best deal with these perceptions if they communicate truthfully, listen carefully to employees’ concerns, address problems promptly and act professionally. None of these standards require financial outlay. Leaders must just follow clear, specific behaviors to fulfill them. The challenge lies in ingraining these behaviors in the organization so they apply to all the actions, initiatives and workday responsibilities of leaders at all levels. Only then can organizations prevent problems that can arise across an increasing range of the issues that are being invoked by the debilitated economy and the political changes that are now taking place and beginning to affect businesses nationwide.

2008’s financial meltdown continues to exert economic pressures, causing further job cuts and business contraction. Some people, in the midst of such crises, will search for means to protect themselves. Some will just try to get even. Charges and lawsuits typically rise in recessions. In fact, EEOC discrimination claims in 2008 were already at their highest level since 1992. The economy’s downward spiral, marked by steep unemployment and tanking financial markets, increases the odds that these claims will surge even higher. Furthermore, as a reaction to remote and disengaged leadership, union organizing efforts this year will be an increasingly attractive option for disaffected employees.

The Obama administration has stated its commitment to not only turn around the economy but to act swiftly to regulate business more aggressively than the previous administration. Regulatory developments will give employees new avenues for administrative and judicial relief that we have not seen for many years. At this moment, provisions are either already in place (Title VII, FMLA and ADA) or contemplated (FLSA) to strengthen existing laws.

Next up is the Employee Free Choice Act, which was reintroduced in the House of Representatives on March 9 and which President Barack Obama has indicated he will support, in some form. At this writing, its chances of passage are not certain, given that 41 Senate Republicans have indicated they will filibuster to prohibit a final vote. The measure went down in 2007 on such a move. But if the act is passed in any of the forms that have been discussed so far, it will greatly facilitate union organizing and increase the risk to employers who try to combat union drives in their workplaces. In other areas of business, from occupational safety to securities, increased regulatory provisions are being planned.

How employers might respond
The resulting press of legislation, government oversight and risk will place on organizations an added burden of cost and a decreased focus on business, just at a time when most have already slashed budgets and resources for both operations and staff. Recognizing all that confronts them, many organizations will respond in the same way they have to lesser challenges that have arisen since the 1970s. Most organizations, understandably concerned about increases in litigation, charges, lawsuits and potential union organizing activity, will look at each area of new or enhanced risk and devise separate strategies to address and manage these concerns. They will send out e-mails regarding new statutes, put revised compliance processes in place and review each and every organizational policy to ensure it is legally accurate. Then, they will launch initiatives related to each of the new laws and assign them to subject-matter experts who will develop information sheets or fact-laden training sessions coupled with multiple processes to field complaints.

And that will be the end of it. While processes and briefings are important, organizations relying on these measures alone will not address the very root causes that are likely to trigger or inflame today’s workplace problems. Worse yet, they will hinder their ability to resolve these problems internally. Leaders who do not welcome complaints, who do not take decisive steps to fix problems, who do not communicate honestly and act professionally, will spawn new problems arising from what may appear to be disparate causes. In fact, though, common leadership misbehaviors are responsible for these problems.

These intensely trying times bring a heightened urgency for leadership strategies focused on daily behaviors. These strategies are as important as any organizational initiative that is meant to address processes and broad communications. In fact, now more than ever, organizations must insist on the highest standards of professional behavior if they intend to weather the economic and legislative changes we face.

Adopt a behavioral leadership strategy
Implementing a day-to-day behavioral leadership strategy cannot be left to chance, nor can we give it secondary status. Instead, it must be the first step, rather than the last, of a workplace plan to deal with our current challenges. A comprehensive behavioral strategy must be the pivotal point around which organizations build all other processes.

Regrettably, without organizational direction, the same economic stresses that affect employees will bring out the worst behavior in some of the leaders who manage them. In industries from health care and banking to telecommunications, pharmaceuticals and electric utilities, some leaders will vent their fears and stress by reverting to disruptive behaviors that will lead to discrimination and harassment claims, inattention to safety and quality details, ethical shortcuts and outright lapses. They can also pave the way for unionization efforts.

This unchecked behavior is already prevalent in too many workplaces. In compiling the results of a workplace survey in which many of our clients participated last summer, my colleagues and I found signs of what such “leadership” can do in an organization, regardless of the industry.

Overall, we observed a glaring degree of frustration among employees over managers and leaders who could not communicate accurately and professionally and who would not listen to employees and address basic issues. We found these results particularly striking because we received them even before the torrent of bad economic news hit, beginning in September 2008.Here are representative comments from survey participants:

• Bullying continues to be a problem. There are, however, even more subtle behaviors. These are unconscious or unintentional behaviors resulting from a lack of awareness of the signals and nuances of cultures other than our own. This includes differences of age and geographic roots, even within the U.S. or within individual states in the U.S.

• I work in an organization where it appears to be OK and allowed for managers to make sexist comments and lie. And what makes it even more bizarre—these folks get promoted!

• Stifled complaints have caused several employees to up and leave without promise of gainful employment. They had to leave their job for “sanity” and to preserve their reputation.

• Unethical behavior jeopardizes our ability to execute and deliver service appropriately. When it has been long-accepted, it takes time to change.

• The manager is not approachable. The employee does not have a comfort level with their manager to discuss an issue. Many times the employee feels intimidated by their manager and will not say anything.

• They fail to respond to employee issues, tell the employee to “get over it” and essentially tell them they are troublemakers.

• In health care, a double standard exists for leaders and physicians versus the rank-and-file employees. Rank-and-file employees are held to higher standards and poor behaviors are tolerated less from them than the physicians and leaders.

Recommendations for a behavioral leadership strategy
If the kinds of behaviors described in the survey responses go unchecked, serious and damaging workplace issues will result. The drafting of policies and the communication of topical information about legislative, regulatory and other issues will prove futile unless organizations address bad behavior such as bullying, harassment, lying and condescension. Establishing a core behavioral leadership strategy will produce shared behaviors that encourage two-way communication on all issues and provide a foundation of consistently civil, inclusive and lawful treatment.

When issues do arise, whether those issues are wage-and-hour compliance, discrimination and harassment or unionization efforts, a consistent leadership strategy will assure that they will be detected and corrected sooner rather than later, which is when the damage is irreparable. The shared behavioral standards of leadership must become the foundation for every policy, communication, management initiative and training session. When an organization lays this behavioral foundation, it will prevent problems, uncover them if they do arise and ensure their prompt correction. These are the hallmarks of voluntary compliance: prevention, detection and correction. They must be the standard for conducting business.

Leadership behaviors defined
Of course, talking about leadership behaviors is all well and good, and many leaders intuitively adopt these behaviors in the workplace. But other leaders need detailed instruction and practice in order to incorporate these behaviors into their daily leadership strategies. Here are key leadership behaviors and ideas on how leaders should apply them:

Communicate honestly: A tough economic time is the time for truth. This means not only telling the truth when questioned, but also sharing news, whenever possible, before it leaks through the grapevine that filters through all organizations. Leaders may not be in a position to reveal all plans and confidential business information. But they must never mislead or lie; whatever they say and write must be factual. Dishonest communications can lead to perceptions of discrimination or other unlawful conduct. This behavior gives labor organizers an argument to use: You can’t believe what your employers say; you cannot trust them to do the right thing. Credibility is crucial and cannot be manufactured. Leaders must build credibility over time in the routine interactions that touch every aspect of the workplace.

Listen to concerns: Employees are concerned about their jobs and their personal circumstances. They have questions and need to know that their leaders are willing to take time to hear their concerns. Whatever those issues are, the manner in which one concern is handled—just one—will determine whether employees raise the next concern internally or through external sources. Finding out about employees’ concerns allows leaders to find out about potentially problematic issues. They can then address the issues within the organization, rather than through expensive external avenues. What managers say and how they say it—content, body language, and tone—are all vital indicators of their sincerity. We have learned that listening is a behavioral skill; these and other components can be taught and must be regularly applied.

Address problems promptly: With the uncertainty prevalent in today’s workplace, employees will likely have many concerns. Employees must know that their concerns will not only get attention, but also responses. That does not mean the responses will be what they want to hear, and it does not mean that leaders will give out information that cannot be released. However, the responses should fulfill these criteria:

• Leaders must answer questions accurately. If they cannot divulge the information, they should honestly say that to employees.

• Explanations must be timely. A tardy response is virtually no response at all. At the very least, if leaders need time to investigate a situation, they should let employees know when they can provide the response and follow up accordingly.

Act professionally: A few simple rules can help leaders accomplish this goal. A key principle that my colleagues and I recommend is that managers make certain that they guard their words and actions. Yelling and condescension in tone of voice, body language or written communications have no place in professional conduct.

Apologize readily: Like anyone else, leaders make mistakes and sometimes fail to act in line with the organization’s leadership strategy. If this happens, they should apologize and then change their behavior.

Learning that makes a difference
Organizations that implement these behaviors as comprehensive cultural standards will prevent problems that might otherwise lead to significant damage. Conversely, organizations that launch a barrage of policies and systems without addressing the vital role that leadership behavior plays simply ignore what is essential to building a legal workplace. And that, ultimately, is what every new law, regulation and initiative which addresses individual or collective conduct is meant to foster. Organizations must clearly define what constitutes leadership behavior. Leaders must then understand that this behavior is a non-negotiable requirement. In addition, organizations must hold leaders accountable for implementing these behavioral standards and managing in accordance with them.

There is nothing complex about the behaviors described here. They are brief but concrete guidelines that every leader can learn quickly and apply immediately. When they do so, their organizations will see leadership that makes a difference. They will minimize risk and increase productivity. This is a common-sense necessity for any organization that hopes to survive and thrive in the days ahead.

The information contained in this article is intended to provide useful information on the topic covered, but should not be construed as legal advice or a legal opinion. Also remember that state laws may differ from the federal law.

A colleague recently told me about a problem with an employee at her company. Change a few of the facts about the industry or job position, and it’s a story that’s familiar to many human resources executives. The employee worked at night managing a network for a midsize wireless provider in the telecommunications industry. He knew about security and system protocols. He’d been taught not to duplicate software and other copyrighted content and had signed off on the company policies prohibiting such behavior. Despite all he had been told and everything he had read, he downloaded a bootlegged copy of a popular movie one night for his own use. He probably wasn’t thinking about the policies, or maybe he thought he could escape detection. But he was caught. He was fired and could have been subjected to civil and criminal prosecution. And his company faced a lawsuit from the producer of the movie.

    The incident didn’t make the news, and the technician’s actions didn’t destroy his company’s reputation or stock value. But his lack of respect for the company’s values and code of conduct, and for the law, is increasingly common, as reflected not only in highly publicized corporate scandals involving corrupt executives but also in day-to-day ethical lapses among rank-and-file employees. The bottom line is that no matter what companies or governments do, some people are going to commit ethical violations, whether in the executive suite or in remote cubicles. Reissuing codes of conduct and requiring compulsory “check-the-box” training on subjects ranging from antitrust to workplace health and safety may be well-intentioned, but it won’t do much to combat these kinds of issues. As this example shows, the problem isn’t just a lack of policies or communication about what constitutes a violation. The issue is translating lofty vision statements and policies into simple forms of day-to-day behavior that are communicated, understood and applied as clearly as other corporate commitments.

    The U.S. Sentencing Commission recognizes the problem and is developing solutions. The commission has proposed amendments to the Federal Sentencing Guidelines that will limit liability for civil or criminal violations if an organization can demonstrate that it has implemented effective compliance programs. Until now, the definition of “effective” was open to interpretation. Now the government’s message will be very direct: Don’t think that filling out forms, drafting carefully crafted policies or producing printouts of the names of employees who sat through training courses will reduce your penalty. The government expects a company to “build a culture that encourages commitment to the law” and to have workplaces that will actively prevent and detect violations. For many, this will mean addressing that disconnect between the policies and training and the way employees actually behave on the job.

    Organizations building legal, ethical cultures communicate their vision through their leaders and then continue the process through communication and education. Training often includes learning about specific behaviors that are part of successful business performance. Employees know, for example, that no matter what the issue is and who is involved, lying, fabricating records or covering up problems is unacceptable. The standard is stated, repeated, applied and understood by everyone in the organization, regardless of job title or tenure.

    Years ago I defended an employer in the chemical industry that had a manager who engaged in improper sexual conduct at work and appeared to have taken bribes from a key supplier. The company had a code of conduct in place and all the right policies. But as we investigated the case, it turned out that this wasn’t the only manager in the organization who had engaged in such conduct. The behavior hadn’t been reported because it was part of the real culture, not the “paper culture” designed by lawyers and human resources professionals. Building a culture to eliminate such long-standing practices is a continuous process, not an annual set of steps handled outside the senior executive office, like filling out EEO-1 reports or tax forms. It is not the sole responsibility of lawyers and risk managers; it’s the responsibility of the entire organization. While employees should know the laws governing their jobs, it’s more important for them to know that there is an internal commitment to lawful operations, a value that is fundamental to an organization.

    The most visible recent offenses in corporate America have involved senior leaders. In my experience, company executives often exempt themselves from legal and ethical training that is compulsory for other employees. This sends a signal to employees that the company is delivering the training because it is required to, not because it is a fundamental, respected corporate value. The new guidelines will require decision-makers to fully participate if they hope to argue that their programs are effective. Their participation will communicate to others that respecting the law and acting ethically as defined by the organization in terms of clear behaviors are vital responsibilities.

    In addition to attending training, top leaders must be aware of the steps the company is taking to prevent legal misdeeds and be readily able to discuss them credibly. I recently met with a group of senior executives who run a well-known consumer-products company. They told me that their CEO speaks passionately about sales, industry position and safety. But they also said that when he speaks about employees and ethical issues, his comments have been written by the communications department, whose script he reads word for word. And it shows. Employees say that his packaged delivery blunts the impact of the message.

    Contrast this company with a prominent medical institution where I am working with a group of physicians to develop training to address behavior that can create legal risk and undermine productivity. The hospital is requiring its own physician leaders to conduct the training and is relating the professional treatment of colleagues to the organization’s commitment to excellence. This is the kind of program that is in line with the government’s message that executives can’t be superficial about how their companies prevent legal or ethical disasters, or profess that they are too far removed to know what’s going on and to take responsibility. In designing a compliance program, a company must determine what it has to accomplish in order to operate legally and to detect problems. Often the very first consideration is how much money and time the company is willing to devote to the effort. Then those arguing that their programs are “effective” will have to prove that the resources they allocated were reasonably adequate to prevent problems.

    Combined with other governance reforms that increase institutional and leadership responsibilities, these proposed guidelines will force organizations to decide whether they are really serious about having effective compliance programs. If they are, they’ll need to invest and plan as they would for any other business initiative. And they’ll have to involve human resources strategists in an ongoing process to make sure a clear vision and continuing commitment are understood and regularly communicated to everyone in the organization.

Workforce Management, May 2004, p. 18 —Subscribe Now!

Big shots make headlines. Whether they’re top-ranked executives, brilliant surgeons, powerful law firm partners or visionary entrepreneurs, when they act, news follows. And lately, the news has not been good. In the past year, ImClone’s Samuel Waksal was imprisoned for insider trading and fraud. Former Salomon Smith Barney telecom analyst Jack Grubman was fined $15 million and banned from the business for life for improper dealings.

    High-profile scandal extends beyond the office of the CEO. In workplaces across the country, a small but recognizable group of top performers are often known as much for their extreme conduct as for the business results they deliver. Their behavior, if not technically illegal, clearly crosses the boundaries of civility and business prudence set for the rest of the workplace. Yet their very prominence means they will come under greater scrutiny when their behavior crosses the line. When top execs are out of control, whoever they are, it can create not only devastating career and personal damage but also catastrophic loss to the organization itself.

    Why this conduct occurs and how it can be prevented, or at the very least stopped, are critical risk-management issues. What is needed are credible organizational structures, effective communication and a commitment to take action against offenders–no matter who they are.

    Improper conduct often is habitual. Some top performers even consider bad behavior a perk of the job. The conduct occurs and is tolerated because the offenders believe that the rules don’t apply to them. They conclude that by virtue of their contributions to the organization–the money they bring in, the power they have, the prestige they command in the industry–they’re immune to the rules that everyone else has to follow.

    The other part of the problem is that in many organizations, virtually all of the other employees, including peers, direct reports, superiors and even board members, believe it, too. Those who could and should rein in the behavior stay silent for fear of rocking the boat. They worry that the big shot will leave or won’t perform as well, or that his or her morale will deteriorate. Lower-level employees may think their complaints won’t be valued because of the leader’s power, contributions and professional status. Bad conduct is tolerated and excused for the supposed good of the business.

    But all of this is changing. A perfect example is the case of the brilliant physician who throws instruments, yells at nurses and humiliates nearly everyone in his path. Faced with numerous lawsuits, nursing shortages, staff dissatisfaction and a general lack of trust by a well-informed patient base, many hospitals and physician practices will no longer tolerate such behavior. They’re taking positive steps to change the workplace culture, measures that can be applied in virtually any business or industry.

    Changing behavior isn’t easy. It requires the right messenger, who must deliver the right message in the right way. Big shots often have big intellects to match. The irony is that what they need to learn is simple compared to the complexities involved in their jobs. What is the right message? It’s simple and direct: Don’t make sexual comments. Don’t give company secrets to friends for financial gain. Don’t use shady accounting to inflate earnings. It tells those who misbehave that their conduct is unacceptable, it jeopardizes the organization and it must change or they will be fired. It counters all challenges to the concept with this simple fact: Your career is on the line. The choice is yours.

    Getting these points across in a way that changes behavior, however, requires the right messenger. Almost invariably, big shots who misbehave have egos that may be even bigger than their intellects. Some will listen only to those with equal clout and professional standing. Frequently, that messenger is a respected peer, a superior, an individual who is viewed as credible in a different profession, or another key figure such as a corporate board member.

    I was at a meeting recently where a prominent surgeon questioned why he needed to spend his time on a discussion about behavior in the workplace. The chief of surgery, an internationally known physician, replied, “Because I’m requiring it and your career depends on it.” Not surprisingly, the surgeon’s level of interest increased dramatically.

    By their very nature, hugely successful people often assume that what happened to someone else can’t happen to them. For this reason, even though big shots may not like to listen to lawyers, it often is an attorney who is the most effective at communicating the very real personal and professional risks they could face. Sometimes court-room simulations can take the place of going to court. I’ve seen flashes of insight appear on top executives’ faces after they were asked a few direct and unrelenting questions about their conduct “under oath.” That can be far more effective than simply lecturing them about the law and its consequences.

    Ultimately, the most important way to change misbehavior is for everyone to know that the conduct won’t be tolerated no matter who is involved. Organizational leaders and sometimes even board members must be committed to taking action if necessary to protect their institutions from big shots who don’t or won’t get the message. The actions can range from blunt discussions to corrective discipline, therapeutic interventions and, if proper, a resignation or firing. Because of the seriousness of the behavior and the attendant risks, business, professional, legal and human resources representatives should be involved.

    I’ll bet if we asked some of the business hotshots we’ve heard about recently in the news if they would rather have been reined in internally than face the public consequences of their conduct, each would reply, “Why didn’t someone set me straight before all this happened?”

The information contained in this article is intended to provide useful information on the topic covered, but should not be construed as legal advice or a legal opinion. Also remember that state laws may differ from the federal law.

Workforce Management, October 2003, pp. 16-18 —Subscribe Now!

The current spate of business scandals–Arthur Andersen, Enron, WorldCom, HealthSouth and others–brings up an interesting question: How can companies enforce certain business protocols so effectively that they become an integral part of the operations and yet fail to rein in blatant legal and ethical lapses that might be the stepping stones to corporate ruin? It’s unlikely that you would have ever seen an Arthur Andersen employee wearing a golf shirt from another Big Five firm at a client social event. Employees knew that such behavior was inappropriate and that they would surely face some sort of punitive action for it. Yet violations of ethical and legal codes–which led to the firm’s downfall–were seemingly routinely ignored. Regardless of their policies and grand mission statements, these companies seemed unable to communicate the message about ethical business practices and how to handle potential problems in a manner that positively influenced the behavior of their employees.

    In the aftermath of these very public collapses, organizations are scrambling to demonstrate their own compliance. They are making sure they have developed or updated codes of conduct and have taken steps to prove that everyone has been exposed to the code. The regulators’ response has been to call for more laws and penalties to prevent corporate misdeeds. In fact, most high-profile scandals are not caused because codes aren’t in place or because individuals faced with ethical dilemmas have no clear standards to follow. After all, Enron had a well-publicized code of conduct. Nor do these issues arise in a vacuum of legal regulations. The prosecutions and lawsuits already under way indicate that improper conduct occurred not in the absence of protections but in spite of them.

    In most cases, corporate catastrophes start with questionable, illegal or unethical acts such as “cooking the books,” falsifying records or defrauding investors. Next, individuals attempt to conceal these “bad acts” in a variety of ways. When people do eventually try to raise concerns, they are either ignored or retaliated against, and the cover-up escalates. Gradually, this kind of behavior becomes the standard of business practice in the eyes of the company’s employees–it’s “how we do things here.” When the company culture ignores, promotes or even rewards improper conduct, training everyone on the intricacies of numerous compliance laws won’t be enough to prevent a business disaster. Stock prices don’t plummet, a brand name isn’t seriously harmed and the government doesn’t launch massive investigations because individuals failed to recognize the applicability of an obscure regulation or misjudged an ethical gray area. Instead, companies should look at how people behave at work. They may find that they have to change “how we do things here.”

    Scores of state and federal laws regulate financial transactions, employment practices, environmental safety, antitrust, and a number of other compliance areas. In addition to prohibiting certain kinds of conduct and business methods, they forbid retaliation against individuals who try to complain of unlawful practices internally. In the current climate, all of these laws are seen as vital to maintaining an ethical, legally compliant workplace. Therefore, providing education is a necessary part of the process.

    However, if the idea is to affect the way people behave at work, inundating everyone with the details of these laws and regulations is not the answer. It’s nearly impossible to communicate every form of improper business conduct–no one could remember such a list. Even if they could, new forms of misconduct always seem to be around the corner. The U.S. Department of Labor’s Web site currently lists nine different provisions prohibiting retaliation against individuals for complaining of potentially illegal practices, and there are other statutes that prohibit retaliation for raising other kinds of concerns. Many states also have regulations.

    Beyond the complexity, regulatory statutes are also often ambiguous. A recent example of this is the Sarbanes-Oxley law, which contains provisions whose meaning is unclear even to those who supported the legislation. Additionally, workplace regulations are often, by their very nature, extremely complex, rife with exceptions and counterintuitive. For these reasons, it’s simply unrealistic to think that individual managers can be taught to recognize the nuances of not one but many applicable laws to avoid legal and business pitfalls.

    On the other hand, we know that instruction on legal issues is important. It communicates the significance of legal conduct, is required under some laws and can sometimes help reduce damages and penalties. So how can organizations most effectively use their training time and dollars to educate their workforce about these issues?

    Recently I worked with an international corporation to help them communicate standards of behavior to managers throughout the world. We realized that attempting to address all of the laws governing individual countries would not only be difficult but also would diminish the effectiveness of the message. Instead, we developed a program based on shared policies, skill building and a business rationale that all participants can understand and apply, regardless of where they are located. Similarly, when training nuclear-industry professionals, we don’t focus on the intricacies of the Nuclear Regulatory Commission’s statutes and regulations. We focus on behaviors that managers should follow, and give them skills to effectively handle employee concerns.

    We can’t expect businesspeople to become legal experts, but the good news is that they don’t have to. Rather than focusing on complex and often confusing legal regulations, organizations should communicate clear responsibilities and behaviors that reflect their values, codes and policies. Tying behaviors to responsibilities can help organizations instill messages about ethical practices in the same way they do other important business initiatives. The training should have a legal foundation, but by applying a clear set of behavioral guidelines to all workplace situations, managers will be able to minimize risk without having to know every detail of the laws. When managers understand the business consequences of improper conduct and have the skills to recognize and respond to such behavior, they can begin to change “how we do things here.”

The information contained in this article is intended to provide useful information on the topic covered, but should not be construed as legal advice or a legal opinion. Also remember that state laws may differ from the federal law.

Workforce, July 2003, p. 14 — Subscribe Now!