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Labor Management Reporting and Disclosure Act

Issued: January 1, 1993

Latest Revision: May 15, 2017 

Policy Statement

This policy outlines the University's obligations under the ("LMRDA").

 

Reason(s) for the Policy

To ensure that members of the University community know that payments to unions, union officials, or employees that are intended to influence or interfere with an employee's choice of representative may be unlawful and are contrary to University policy. Nevertheless, certain financial transactions between the University, labor organizations and their representatives and employees and labor relations consultants must be reported to the United States Department of Labor pursuant to Section 203(a) of the Labor Management Reporting and Disclosure Act.

 

Responsible University Office & Officer

The Office of Labor and Employee Relations is responsible for collecting financial information and ensuring that appropriate transactions are reported.

 

Who is Governed by This Policy

All staff and faculty at the University - or anyone working on behalf of the University - who have financial dealings with a labor organization, its representatives or a labor consultant.

This policy applies to non-instructional officers and staff. Faculty should consult the Faculty Handbook or contact the Office of the Senior Vice Provost for Academic Administration. Officers of the Libraries should consult the Libraries Director of Human Resources regarding policy interpretation and application. Employees in collective bargaining units should consult the relevant provisions of their collective bargaining agreements or contact the Office of Labor and Employee Relations. 

 

Who Should Know This Policy

All staff and faculty at the University - or anyone working on behalf of the University - who have financial dealings with a labor organization, its representatives or a labor consultant.

 

Policy Text

The University must file Form LM-10 annual reports to disclose financial transactions and certain specified dealings, subject to a $250.00 de minimus exemption, with a union or officer, agent or other representative of a union. The primary focus of the LM-10 regulation is to disclose payments by employers to union officials and to employees for the purpose of influencing or interfering with the employee's choice of representative. There should be no expenditure of University funds for those purposes, as they may violate federal law, and would violate the University's conflict of interest policies and be contrary to the University's policies on employee choice of bargaining representative. Nevertheless, certain transactions must be reported; these include:

  • providing meeting/office space at no cost to unions or union officials;
  • providing food or beverages (subject to the $250.00 annual cap) to unions or union officials (unless food or beverages are provided for all meetings).

 

Responsibilities

For any reportable transaction, the University must record the following information:

  • The date and amount of each transaction;
  • The name, address and position of the person/entity with whom the agreement or transaction was made.
  • A full explanation of the circumstances of all payments made, including the terms of any agreement or understanding pursuant to which they were made.

This information along with support documentation must be submitted to the Office of Labor and Employee Relations.