California Employer Gets Landmark Criminal Conviction For Wage Theft

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In a first-of-its-kind criminal conviction in California, a San Diego restaurant owner has been sentenced to two years in jail for promising wages to immigrant workers but paying them only in tips. San Diego County Superior Court also ordered the employer to repay $20,000 in stolen wages and tips to six of the restaurant workers.

California Labor Commissioner Julie A. Su, who led the wage theft investigation, said in a statement, “Our investigation uncovered egregious wage theft and worker abuse.” This included:

  • Collecting a portion of the tips from unpaid workers;
  • Charging the workers $5 a shift for “glass breakage” to offset the employer’s costs; and
  • Paying kitchen staff $4 an hour and forcing them to work during rest and meal breaks.

The restaurant owner was convicted of two felony counts of grand theft of labor for failing to pay workers as promised, one felony count of grand theft of tips and several misdemeanor charges, including four counts for failing to provide itemized wage statements.

Governor Jerry Brown signed California’s Fair Day’s Pay Act last year, which aimed to crack down on wage theft violations such as these by giving the Labor Commissioner increased enforcement rights against employers. The law took effect January 1, 2016. The Act provides that owners, directors, officers or managing agents can be held personally liable as the employer for certain wage and hour violations.

California is not the only state that has taken firm steps to deter wage theft. Effective January 1, 2017, a new Oregon law will require an employer to include additional information on employees’ pay statements to prevent wage theft.

Business Standard Mileage Rate Decreases for 2017

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Starting January 1, 2017. The Notice also provides the 2017 maximum standard automobile cost that may be used to compute the allowance under a fixed and variable rate (FAVR) plan.

Specifically, the standard mileage rates for the use of a car, van, pickup or panel truck will be:

  • 53.5 cents per mile for business miles driven (down from 54 cents per mile in 2016);
  • 17 cents per mile driven for medical or moving purposes (down from 19 cents in 2016); and
  • 14 cents per mile driven in a passenger car in performing charitable services (set by law and unchanged).

Cal/OSHA Amendment Significantly Expands its Definition of “Repeat” Violations

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Effective January 1, 2017, Cal/OSHA will be utilizing a broader definition of “Repeat” violation under California’s Health and Safety Code.  This is significant for California employers because if Cal/OSHA finds a Repeat violation, the employer could initially be subject to a penalty of up to $70,000, and up to $124,709 or more when Cal/OSHA updates its penalties as required by federal OSHA.  According to OSHA, the purpose of the greater penalty for Repeat violations is to encourage an employer’s ongoing compliance with safety and health standards at all of its locations without requiring OSHA to engage in separate compliance actions at each location.  Because Cal/OSHA has always previously limited Repeat violations to a single worksite reoccurrence, and because of the forthcoming increased penalty structure, California employers will need to develop a more strategic response to any citations they receive.

In its 2013 Federal Annual Monitoring and Evaluation (FAME) Report, federal OSHA found that California’s enforcement of Repeat violations was lower than the federal average and noted that the policy used by the state was different and less protective than that applied by federal law.  As a result, Cal/OSHA was directed to amend California Code of Regulations Title 8, Section 334(d), to be consistent with the definition of a Repeat violation as used by Federal OSHA.

Currently, a Repeat violation is defined in section 334(d), as a violation where an employer has corrected, or indicated correction of, an earlier violation for which a citation was issued and, upon a subsequent inspection within three years, Cal/OSHA finds that the employer has recommitted the same violation.  For employers with fixed establishments, section 334(d) currently limits Cal/OSHA’s authority to issue a repeat citation to the cited establishment, which means that both the underlying and the subsequent violation must have occurred at the same work site or address.

Now, however, California employers will be subject to a much broader definition of Repeat violation.  Specifically, Cal/OSHA amended section 334(d) by:

  1. Expanding the “look back” period of a Repeat violation from three years to five years.
  2. Defining a Repeat violation as a substantially similar violation.
  3. Increasing the geographic scope of a Repeat violation to any violation in the state.

Cal/OSHA Will Now Look Back Five Years

The current three-year look-back period of a Repeat violation begins to run on the date of the conduct giving rise to the violation.  But, if the employer appeals the citation, the appeal prevents the citation from becoming final, and a final citation is necessary for a Repeat violation to be found.  As the three-year clock runs from the date of the conduct, the employer could minimize its chance of a Repeat violation by appealing every citation issued.

Cal/OSHA’s amendment eliminated an employer’s incentive to appeal solely to shorten or exhaust the look-back period.  Now, the starting time for calculating the period begins at either:

  • the date of the final order affirming the existence of a previous violation cited in the underlying citation;
  • the date on which the underlying citation becomes final by operation of law; or
  • the date of final abatement of the violation cited in the underlying citation.

Cal/OSHA also expanded the window of time for a Repeat violation from three years to five years, which is a policy change that federal OSHA made in 2010.1

Cal/OSHA Will Now Consider Substantially Similar Violations

Cal/OSHA currently defines a Repeat violation as occurring when the employer has corrected, or indicated correction of an earlier violation, for which a citation was issued, and upon a later inspection is found to have committed the same violation again.

Cal/OSHA amended the rule to broadly allow it to find a Repeat violation for a violation of a “substantially similar” regulatory requirement. This change places Cal/OSHA directly in line with federal OSHA.  The “substantially similar” standard is the language used by federal OSHA but is not officially defined by Cal/OSHA.  Federal OSHA also does not have a regulatory definition of “substantially similar” but the term has been interpreted in policy documentation and numerous citation appeal decisions.  As the term is undefined, employers will have some opportunity to influence the interpretation of what constitutes substantially similar violations supporting a Repeat violation in California, but this may be one area where the state adopts the federal interpretation.  The greater scope naturally increases the frequency at which a Repeat violation could be issued.

Cal/OSHA Will Now Consider Statewide Violations

The current rule defining the geographic scope of Repeat violations is that the later citation must involve the same factory, store, or other fixed establishment that was previously cited.  But, for field sanitation standards, a Repeat violation is any subsequent violation state-wide, on the theory that farm labor contractors work up and down the state during a short span of time and, thus, violations at different sites in California are akin to Repeat violations.

Cal/OSHA eliminated the difference between field sanitation and other industries and removed the geographical restrictions that currently limit a Repeat violation to a specific facility or store.  In other words, in determining whether to cite the employer for a Repeat violation, Cal/OSHA will consider any violation in the state as opposed to violations at a specific location.  Thus, for example, if Cal/OSHA finds a violation at a facility in Los Angeles, and if the employer has facilities in Sacramento and San Francisco, the agency will determine whether citations for substantially similar violations were issued at the facilities in those two cities.

Implications for Employers

Starting in 2017, California employers can no longer focus solely on the financial implications of settling a citation or contesting it.  Employers will have to be more strategic in their response.  Because the Repeat classification and increased penalties are not directly limited to Serious violations, employers will even have to consider their acceptance or appeal of General and Regulatory citations.

Employers can initially focus even more attention on preventing workplace safety violations through comprehensive programs.  However, if an employer receives a citation, it should carefully evaluate whether simply paying the citation is the best strategy and also should immediately determine whether it is in compliance with other standards that are “substantially similar” to the one for which it was cited at all of its California facilities.  This increased focus will raise the cost of abatement for employers that do decide to accept a citation because they will need to ensure abatement at all of their locations to avoid future Repeat violations with their substantial penalties.  Overall, this change will undoubtedly lead to more litigation over Cal/OSHA citations as employers will need to manage their citation history to avoid future Repeat violations occurring over a five-year period.

Cal/OSHA Adopts First in the Nation Standard on Workplace Violence Prevention for Healthcare Employers

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National research indicates that health care workers are at a substantially higher risk of workplace violence than the average worker in another industry.  According to the federal Occupational Safety and Health Administration (OSHA), from 2002 to 2013, the rate of serious workplace violence incidents (those requiring days off for an injured worker to recuperate) was more than four times greater in healthcare than in private industry on average.1  Patients are the largest source of violence in healthcare settings, followed by visitors or co-workers, and surveys show that many incidents go unreported.

On October 21, 2016, the California Occupational Safety and Health Standards Board (Standards Board) unanimously passed a new General Industry Safety Order entitled “Workplace Violence Prevention in Health Care” (Standard).2  The Office of Administrative Law approved the Standard on December 8, 2016.  The Standard is codified at Section 3342 of Title 8 of the California Code of Regulations.

Coverage

Although Senate Bill 1299 only required a standard for hospitals, the Standards Board went further and the standard applies to any “health facility,” which is defined very broadly to mean “any facility, place, or building that is organized, maintained, and operated for the diagnosis, care, prevention, or treatment of human illness, physical or mental, including convalescence and rehabilitation and including care during and after pregnancy, or for any one or more of these purposes, for one or more persons, to which the persons are admitted for a 24-hour stay or longer.”3

The Standard also applies to home health care and home-based hospices, emergency medical services and medical transports, drug treatment programs and outpatient medical services to those incarcerated in correctional and detention settings.  The Standard will not apply to certain state-run health facilities.

The Standard Broadly Defines “Workplace Violence”

“Workplace violence” means any act of violence or threat of violence that occurs at the work site.  The term workplace violence shall not include lawful acts of self-defense or defense of others.  Workplace violence includes the following:

1.         The threat or use of physical force against an employee that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury;

2.         An incident involving the threat or use of a firearm or other dangerous weapon, including the use of common objects as weapons, regardless of whether the employee sustains an injury;

3.         Four workplace violence types:

  • “Type 1 violence” means workplace violence committed by a person who has no legitimate business at the work site, and includes violent acts by anyone who enters the workplace with the intent to commit a crime.
  • “Type 2 violence” means workplace violence directed at employees by customers, clients, patients, students, inmates, or visitors or other individuals accompanying a patient.
  • “Type 3 violence” means workplace violence against an employee by a present or former employee, supervisor, or manager.
  • “Type 4 violence” means workplace violence committed in the workplace by someone who does not work there, but has or is known to have had a personal relationship with an employee.

Workplace Violence Prevention Plan

Healthcare employers covered by the Standard are now required to establish, implement and maintain an effective workplace violence prevention plan (Plan), which must be in effect at all times and in every unit, service or operation.  The Plan must be in writing, be specific to the hazards and corrective measures for the unit, service, or operation, and be available to employees at all times.  The written Plan may be incorporated into the employer’s written IIPP or maintained as a separate document.

The Plan must include the following:

  • Names or job titles of the persons responsible for implementing the Plan;
  • Effective procedures to obtain the active involvement of employees and their representatives in developing, implementing, and reviewing the Plan, including their participation in identifying, evaluating, and correcting workplace violence hazards, designing and implementing training, and reporting and investigating workplace violence incidents;
  • Methods the employer will use to coordinate implementation of the Plan with other employers whose employees work in the same health care facility, service, or operation, to ensure that those employers and employees understand their respective roles as provided in the Plan;
  • Effective procedures for obtaining assistance from the appropriate law enforcement agency during all work shifts;
  • Effective procedures for the employer to accept and respond to reports of workplace violence and to prohibit retaliation against an employee who makes such a report;
  • Procedures to ensure that supervisory and non-supervisory employees comply with the Plan;
  • Procedures to communicate with employees regarding workplace violence matters;
  • Procedures to develop and provide training to employees that addresses workplace violence risks employees are reasonably anticipated to encounter on the job;
  • Assessment procedures to identify and evaluate environmental and community-based risk factors for each facility, unit, service, or operation, which shall include a review of all workplace violence incidents that occurred in the facility, service, or operation within the previous year, whether or not an injury occurred;
  • Procedures to identify and evaluate patient-specific risk factors and assess visitors or other persons who are not employees;
  • Procedures to correct workplace violence hazards in a timely manner; and
  • Procedures for post-incident response and investigation.

The Standard describes in great detail the procedures that must be addressed within each of these topics.

At least annually, the employer is required to review the effectiveness of the Plan and correct any problems.  The annual review must include employees and their representatives and address the employees’ respective work areas, services and operations.  The Standard sets out numerous additional items the employer must consider when reviewing the Plan, including, among other things, staffing, sufficiency of security systems and job design and equipment.

Violent Incident Log

Healthcare employers will be required to record in a “violent incident log” every incident, post-incident response, and workplace violence injury investigation with descriptive details.  The employer must review the log as part of its annual review of the Plan.

The log must contain, at a minimum, the following items:

  • The date, time, specific location, and department of the incident;
  • A detailed description of the incident;
  • A classification of who committed the violence;
  • A classification of circumstances at the time of the incident;
  • A classification of where the incident occurred;
  • The type of incident;
  • The consequences of the incident; and
  • Contact and other information about the person completing the log.

As with the Plan, the Standard describes in the detail the specific information that must be included for each item.

Training

The Standard requires healthcare employers to provide training to employees designed to address the workplace violence risks that employees are reasonably anticipated to encounter in their jobs.  The employer must have an effective procedure for obtaining the active involvement of employees and their representatives in developing training curricula and training materials, participating in training sessions, and reviewing and revising the training program.

The Standard requires that training be conducted at various times, including:

  • when the Plan is first established and when an employee is newly hired or newly assigned to perform duties for which the training was not previously provided;
  • when new equipment or work practices are introduced; and
  • when a new or previously unrecognized workplace violence hazard has been identified.

The Standard requires the initial training to address the workplace violence hazards identified in the facility, unit, service or operation, and the corrective measures the employer has implemented.  The initial training also must include:

  • An explanation of the employer’s Plan, including the employer’s hazard identification and evaluation procedures, general and personal safety measures the employer has implemented, how the employee may communicate concerns about workplace violence without fear of reprisal, how the employer will address workplace violence incidents, and how the employee can participate in reviewing and revising the Plan;
  • How to recognize the potential for violence, factors contributing to the escalation of violence and how to counteract them, and when and how to seek assistance to prevent or respond to violence;
  • Strategies to avoid physical harm;
  • How to recognize alerts, alarms, or other warnings about emergency conditions such as mass casualty threats and how to use identified escape routes or locations for sheltering, as applicable;
  • The role of private security personnel, if any;
  • How to report violent incidents to law enforcement;
  • Any resources available to employees for coping with incidents of violence, including, but not limited to, critical incident stress debriefing or employee assistance programs; and
  • An opportunity for interactive questions and answers with a person knowledgeable about the employer’s workplace violence prevention plan.

Annual refresher training also is required for employees performing patient contact activities as well as their supervisors.

In addition, employees assigned to respond to alarms or other notifications of violent incidents or whose assignments involve confronting or controlling persons exhibiting aggressive or violent behavior must be provided training on numerous topics prior to initial assignment and at least annually thereafter, including strategies to prevent physical harm, aggression violence predicting factors and characteristics of aggressive and violent patients and victims.

Reporting Requirements for Certain Hospitals

In addition to the above requirements, the Standard requires general acute care hospitals, acute psychiatric hospitals, and special hospitals to report to Cal/OSHA any incident involving either of the following:

  • The use of physical force against an employee by a patient or a person accompanying a patient that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury (as that term is defined in Cal/OSHA’s regulations requiring the reporting of other types of injuries or illnesses).
  • An incident involving the use of a firearm or other dangerous weapon, regardless of whether an employee sustains an injury.

All reports must be made within 72 hours, except that the report must be made within 24 hours if the incident:

  • results in a fatality or an injury that requires inpatient hospitalization for at least 24 hours for other than medial observation or in which an employee suffers a loss of a limb or suffers any serious degree of permanent disfigurement;
  • involves the use of a firearm or other dangerous weapon; or
  • presents an urgent or emergent threat to the welfare, health, or safety of hospital personnel, which means that hospital personnel are exposed to a realistic possibility of death or serious physical harm.

The Standard describes the information that must be included in the report.  Cal/OSHA will implement an online system for employers to report the information.  These reports do not relieve the healthcare employer from making reports that may be required by other Cal/OSHA regulations.  Employers can expect that these reports will result in a significant number of new non-formal and on-site inspections.

Recordkeeping

The Standard will require healthcare employers to maintain various records, including records of workplace violence hazard identification, evaluation, and correction, training records, and records of violent incidents.  Records must be made available to employees and their representatives, as well as Cal/OSHA, upon request.

Next Steps for Employers

The Standard is effective on April 1, 2017, which means that California healthcare employers have less than four months to get in full compliance with these onerous requirements.  Cal/OSHA’s Standard is a first of its kind at the federal and state level, although Federal OSHA is proceeding with a rulemaking and will hold a public hearing on January 10, 2017.

At a minimum, employers covered by the Standard should immediately consider:

  • Gathering records of all incidents of workplace violence (with or without injury) from the previous year;
  • Reviewing all existing policies, programs, and training addressing elements of workplace violence prevention;
  • Conducting the required assessments for each workplace;
  • Drafting and implementing a new written Workplace Violence Prevention Plan, which addresses the numerous topics enumerated in the Standard;
  • Creating training programs for all employees that effectively advise of any workplace violence risks that may arise in a healthcare environment and in the employees’ particular work area; and
  • Establishing a record retention program for training and any incident that could be viewed as an incident of workplace violence, even if no injury resulted.

Employers should also review the significant privacy issues raised by the Standard, and with the advice of privacy attorneys, develop an appropriate policy addressing concerns which may arise in keeping records, reporting incidents to Cal-OSHA, and handling inspections of this Standard.

Should you have any questions, please contact your representative at HR Ideas.

California Employers Issuing W-2 or 1099 Must Revise Earned Income Tax Credit Notice

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For several years, California employers have been required to notify employees regarding the federal Earned Income Tax Credit. Beginning January 1, 2017, new California law (AB 1847) requires those same employers to also notify employees that they may be eligible for the California Earned Income Tax Credit (“EITC”).

The new law states that an employer must notify all employees that they may be eligible for the federal and the California EITC within one week (before or after) or at the same time that the employer provides an annual wage summary, including, but not limited to, a Form W-2 or a Form 1099, to any employee.

California employers should consider using the language on the availability of the federal and the California EITC specified in the new law in their notice to employees.

If you have any questions about this other workplace developments, please contact Hr Ideas.

2017 Tax Filing Season Begins Jan. 23 for Nation’s Taxpayers, Tax Returns due April 18

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The Internal Revenue Service announced today that the nation’s tax season will begin Monday, Jan. 23, 2017 and reminded taxpayers claiming certain tax credits to expect a longer wait for refunds.

The IRS will begin accepting electronic tax returns that day, with more than 153 million individual tax returns expected to be filed in 2017. The IRS again expects more than four out of five tax returns will be prepared electronically using tax return preparation software.

Many software companies and tax professionals will be accepting tax returns before Jan. 23 and then will submit the returns when IRS systems open. The IRS will begin processing paper tax returns at the same time. There is no advantage to filing tax returns on paper in early January instead of waiting for the IRS to begin accepting e-filed returns.

The IRS reminds taxpayers that a new law requires the IRS to hold refunds claiming the Earned Income Tax Credit (EITC) and the Additional Child Tax Credit (ACTC) until Feb. 15. In addition, the IRS wants taxpayers to be aware it will take several days for these refunds to be released and processed through financial institutions. Factoring in weekends and the President’s Day holiday, the IRS cautions that many affected taxpayers may not have actual access to their refunds until the week of Feb. 27.

“For this tax season, it’s more important than ever for taxpayers to plan ahead,” IRS Commissioner John Koskinen said. “People should make sure they have their year-end tax statements in hand, and we encourage people to file as they normally would, including those claiming the credits affected by the refund delay. Even with these significant changes, IRS employees and the entire tax community will be working hard to make this a smooth filing season for taxpayers.”

The IRS also reminds taxpayers that they should keep copies of their prior-year tax returns for at least three years. Taxpayers who are changing tax software products this filing season will need their adjusted gross income from their 2015 tax return in order to file electronically. The Electronic Filing Pin is no longer an option. Taxpayers can visit IRS.Gov/GetReady for more tips on preparing to file their 2016 tax return.

April 18 Filing Deadline

The filing deadline to submit 2016 tax returns is Tuesday, April 18, 2017, rather than the traditional April 15 date. In 2017, April 15 falls on a Saturday, and this would usually move the filing deadline to the following Monday – April 17. However, Emancipation Day – a legal holiday in the District of Columbia – will be observed on that Monday, which pushes the nation’s filing deadline to Tuesday, April 18, 2017. Under the tax law, legal holidays in the District of Columbia affect the filing deadline across the nation.

Los Angeles Poised to Ban the Box For Most Private Employers

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The Los Angeles City Council has overwhelmingly approved a “ban the box” ordinance prohibiting any employer in the city with 10 or more employees from asking about a prospective employee’s criminal history until a conditional employment offer has been made. The ordinance also would apply to city contractors and employment agencies.

While the measure still requires the signature of Mayor Eric Garcetti, this is seen as a formality. Garcetti has previously voiced strong support of the ordinance in saying, “Prejudging applicants for jobs makes the playing field unequal and doesn’t allow people to ‘run their race’ and succeed.” Los Angeles reportedly has the highest per-capita number of parolees of any city in the country.

Even after an employer is permitted to seek criminal history information, the ordinance requires the employer to provide a justification for why a job offer is being rescinded if it denies employment after learning about an applicant’s criminal record.

The Los Angeles “ban the box” ordinance goes well beyond California law, which only prohibits state and local government employers from asking criminal history questions on initial job applications. It also would mean that four of the nation’s five largest cities will have broad laws limiting criminal history inquiries in the hiring process, as Los Angeles will join New York City, Chicago and Philadelphia with “ban the box” laws that apply to all or most private employers.

In all, more than 100 municipalities have passed “ban the box” ordinances. States that have passed ban the box laws affecting private employers include:

  • Connecticut;
  • Hawaii;
  • Illinois;
  • Massachusetts;
  • Minnesota;
  • New Jersey;
  • Oregon;
  • Rhode Island; and
  • Vermont.

The Equal Employment Opportunity Commission (EEOC) has stated in an Enforcement Guidance that before an employer rejects an applicant with a criminal record, it should give the applicant a chance to explain the circumstances and why he or she should not be excluded from consideration.

Employers Required to E-File Paperwork with Employment Development Department

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Beginning January 1, 2017, employers with 10 or more employees will be required to electronically submit employment tax return, wage reports, and payroll tax deposits to the Employment Development Department (EDD).
 
Employers are encouraged to enroll now in e-Services for Business.  This will allow you to start reporting online before this mandate starts.
 
For additional information about the e-file and e-pay mandate, please visit: www.edd.ca.gov/efilemandate .

2017 Minimum Wage Increases Effective January 1st

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New Minimum Wage Mandatory Poster Updates

The California minimum wage will increase to $10.50 per hour on January 1, 2017 for businesses with 26 or more employees.
Also effective January 1, 2017, new wage postings will be required for the cities listed below:

· Oakland:             $12.86
· Palo Alto:            $12.00
· Richmond:          $12.30
· San Mateo:         $12.00

As an employer, you will need to take the following action:
1.      Post new minimum wage (based on your requirements);
2.      Update Notice to Employee Form for each hourly employee.

Attached please find the new updated postings reflecting the changes as well as the Notice to Employee Form for your use.  Should you have any questions, please contact your HR Representative at 925.556.4404.

Recommendations to Make the Corporate Holiday Party Fun, Festive, and Harassment-Free

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Around the holiday season,  a lot of employers want to celebrate in some form and fashion with their employees. Most employers don’t realize their potential liability. Potential liability is almost always there, but some simple recommendations can go along with in limiting their liability including:

  • Employers should consider hosting a holiday event outside of the traditional holiday party. A growing trend among many companies is to host corporate luncheons or volunteer events that benefit non-profit organizations. These alternatives can reduce the employer’s potential liability with regard to alcohol-related incidents and harassment complaints.
  • Likewise, instead of an employee holiday gift exchange, employers can sponsor a fundraising event for a local charity. Doing so decreases the potential for sexual harassment complaints associated with office gift exchanges. In addition, employers should avoid games, decorations, or other sexually charged traditions that could expose the company to liability.
  • As another option to help avoid incidents of sexual harassment, employers may want to consider hosting a holiday party that allows employees to invite their significant other, a plus one, or even children.
  • When planning holiday gatherings, employers should select a name for the event that is non-religious to avoid complaints of religious discrimination. Employers should also inform employees that participation in holiday gatherings, be it a corporate party or volunteer event, is voluntary.
  • When planning holiday soirees, employers should ensure that employees and guests do not consume excessive amounts of alcohol. Thus, it is strongly recommended that employers supply guests with drink tickets (generally two tickets are standard) or have a cash bar. Likewise, employers are strongly recommended to do the following: (1) close the bar one hour prior to the end of the event, (2) designate supervisors who will not drink at the event to monitor alcohol consumption of employees and guests, (3) and have a system in place to get intoxicated employees and guest(s) home safely, i.e., Uber, Lyft, or other local transportation options.
  • Prior to the corporate holiday event, employers should review their policies and procedures regarding discrimination and harassment and remind employees, through a memorandum, that all company policies will be in effect during the holiday party.

    If you need any assistance or have any questions, please contact you HR Ideas Representative.