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White Employee Accused of Racist Statement Loses Discrimination Claims

?Takeaway: Employers can have a zero-tolerance policy toward racist statements but should enforce it equally against members of different races. Had the plaintiff presented comparator evidence showing that members of other races made racist statements and were not fired, his claim might have survived.

?A white director of training development for a Chick-Fil-A franchise who was fired for commenting that a Black employee might be a “protester” shortly after George Floyd’s death did not assert a valid legal claim, a federal district court ruled.

After the plaintiff was hired as a team member, the franchise provided him with its Team Member Policy Handbook, which included a Civility, Equal Employment Opportunity & Non-Harassment Policy. The plaintiff later became the director of training development.

On June 3, 2020, the plaintiff saw a Black employee standing outside in the rain. In the presence of other non-white team members, the plaintiff said, “He looks like a protester.” This comment came just days after the death of George Floyd and subsequent protests. Employees who heard the comment filed a complaint with the franchise’s management. On July 6, 2020, the plaintiff was fired because the comment was deemed “insensitive, unprofessional and inappropriate.”

The plaintiff filed a complaint with the Equal Employment Opportunity Commission. He received a right-to-sue letter on May 11, 2021. On Sept. 3, 2021, the plaintiff filed his complaint in state court, alleging:

  • Race discrimination in violation of Title VII of the Civil Rights Act.
  • Retaliation in violation of Title VII.
  • Common-law wrongful termination.
  • A claim for attorney fees and punitive damages.

The franchise removed the case to federal court and filed a motion to dismiss the complaint in its entirety. It argued that the plaintiff was not fired because of his race, but because he made a racially insensitive remark about a Black employee. It also argued that the plaintiff failed to plead any facts to support an inference of discrimination. The plaintiff failed to offer any comparator evidence that other employees not in the plaintiff’s protected class were treated more favorably than him.

The defendant also argued that the plaintiff failed to allege any protected activity in support of his retaliation claim, and that Pennsylvania, where the case arose, does not recognize a wrongful termination claim when there is an at-will employment relationship. Because the plaintiff failed to allege other valid claims, the defendant argued that the attorney fees and punitive damages claim should also be dismissed.

In reviewing the pleadings, the court noted that both parties admit that the plaintiff made the comment that resulted in his firing. They disagreed, however, as to whether the remark was racially insensitive. The plaintiff claimed that his termination “was a knee-jerk reaction to the political climate of the summer [of] 2020” and thus, his claim should not be dismissed.

The court considered the standard for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). That standard requires that the complaint contain sufficient factual matter to state a claim to relief that is plausible on its face. The plaintiff had to plausibly state facts to show that the employer is treating some people less favorably than others based upon a trait that is protected under Title VII.

The court found that all that the plaintiff had alleged was that he was wrongly accused of being racist. The court cited a decision by the 8th U.S. Circuit Court of Appeals finding that accusations of racism do not equate to race discrimination under Title VII. Rather, such an assertion wrongly conflates the ideas of race and racism.

The court also rejected the plaintiff’s retaliation claim because he did not allege that he complained about an unlawful employment practice and was fired because he opposed the practice. Rather, he claimed he was fired because his comments were mischaracterized as racist. The plaintiff’s wrongful termination, attorney fees and punitive damages claims could not survive because they depended upon a violation of Title VII, which the plaintiff did not plausibly assert.

As a result, the court dismissed the plaintiff’s claims.

Lacontora v. Geno Enterprises LLC d/b/a Chick-Fil-A, E.D. Pa., No. 21-03948 (March 23, 2022).

Jeffrey Rhodes is an attorney with McInroy, Rigby & Rhodes LLP in Arlington, Va.

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High Court Strikes Down Narrowly Tailored Workers’ Compensation Law

?A Washington workers’ compensation law applying only to federal contract workers at one federal facility in the state made it unconstitutionally easier for federal contractors to obtain workers’ compensation than state or private employees, the U.S. Supreme Court unanimously ruled on June 21.

The U.S. Constitution’s Supremacy Clause generally shields the federal government from state laws that directly regulate or discriminate against it. In United States v. Washington, the Supreme Court concluded that the state law discriminated against the federal government.

The state law fell outside the scope of Congress’ waiver of immunity for state workers’ compensation laws that apply to projects belonging to the federal government in the same way as if the premises were under the exclusive jurisdiction of the state.

“We see a general trend that state legislatures continue to broaden their workers’ compensation programs, focusing on increasing access, expediting treatment and easing the ability of workers to secure benefits,” said Debra Doby, an attorney with Vaughan Baio & Partners in New York City. “This decision certainly serves as a reminder to state legislatures that any changes to workers’ compensation statutes must be applied fairly and equitably for all entities, including the federal government.”

Background

The state law, enacted in 2018, applied only to federal contractors—not federal employees—at a site once used to develop and produce nuclear weapons, generating a massive amount of chemical and radioactive waste. After the Cold War, the federal government began decommissioning and cleaning up the nuclear site. Most of the workers are federal contract workers. A smaller number of workers include federal employees, state workers and employees who work for private companies not under contract with the federal government.

Compared to the general state workers’ compensation regime, Washington’s law made it easier for federal contract workers at the site to establish their entitlement to workers’ compensation by creating a presumption that certain diseases are caused by the cleanup work. The presumption could be disproved only by clear and convincing evidence. The presumption also lasted for a worker’s entire life.

The United States sued Washington, arguing that the law violated the Supremacy Clause by discriminating against the federal government. The district court ruled that the state law fell within the scope of the federal waiver of immunity and was constitutional. The 9th U.S. Circuit Court of Appeals affirmed.

Court’s Holding

The Supreme Court reversed and held that the law violated the Supremacy Clause.

First, the Supreme Court found that the case was not moot even though Washington had enacted a new law applying the presumption more broadly to any worker at a radiological hazardous waste facility.
The U.S. maintained that if the Supreme Court ruled in its favor, it would recoup or avoid paying between $17 million and $37 million in workers’ compensation claims that lower courts have awarded under the earlier law. The Supreme Court determined that the U.S. might recover money if the court ruled in its favor.

The court then noted that it has said that a state law discriminated against the federal government or its contractors if it singled them out for less favorable treatment or regulated them unfavorably on some basis related to their governmental status.

“Washington’s law violates these principles by singling out the federal government for unfavorable treatment,” the Supreme Court said. The U.S. also had not clearly authorized a state to enact a discriminatory law that singles out the federal government for unfavorable treatment.

The court stated that waivers of intergovernmental immunity should be interpreted narrowly, “at least where a state claims that Congress has waived immunity from discriminatory state laws.”

Close Scrutiny of Similar Statutes

The Supreme Court’s ruling shows that “if there is any hint of discrimination that increases the costs for the federal government, those statutes will be subject to close scrutiny,” Doby said.

Under the intergovernmental immunity doctrine, state laws may not increase costs to the federal government of performing its functions unless the laws impose those costs in a nondiscriminatory way, said Crystal McElrath, an attorney with Swift Currie in Atlanta.

“As we enter another charged election cycle, this ruling may impact the kinds of campaign promises that would-be state legislators make,” she added. “State legislators may not target and penalize the federal government in order to right a perceived social wrong without the federal government’s consent.”

McElrath concluded, “States that wish to expand workers’ compensation coverage to include specific conditions must do so at the expense of both private and federal employers or be sure that any law targeting only federal workers falls within the narrowest reading of a congressional waiver of intergovernmental immunity.”

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Supreme Court Sides with Health Plan Over Dialysis Payments

In a 7-2 decision, the U.S. Supreme Court made it harder to prove that a health plan violates the Medicare secondary payer rules when the plan requires patients to pay high out-of-pocket costs to treat kidney failure with dialysis, when patients who switch exclusively to Medicare coverage, regardless of age, could have dialysis covered at less cost to themselves.

In the dispute over health insurance reimbursements for outpatient kidney dialysis, the Supreme Court agreed in Marietta Memorial Hospital Employee Health Benefit Plan v. DaVita Inc. with a self-insured health plan, rejecting a claim from dialysis provider DaVita Inc. that the health plan’s low reimbursement rates violated federal law.

Justice Brett Kavanaugh, author of the majority opinion, was joined by Chief Justice John Roberts and Justices Clarence Thomas, Stephen Breyer and Samuel Alito. In dissent, Justice Elana Kagan was joined by Justice Sonia Sotomayor.

Who Pays for Dialysis?

DaVita, part of UnitedHealth Group’s Optum division, argued that the employee health benefits plan at Marietta Memorial Hospital in Marietta, Ohio, violated the Medicare Secondary Payer Act (MSPA) by treating all dialysis providers as out-of-network and reimbursing them at the lowest-level rate. The MSPA requires private health plans that cover dialysis to be the primary payer of those treatments for at least 30 months after a patient is diagnosed with kidney failure, with Medicare as a secondary payer for Medicare-enrolled patients, to make up for what the employer’s plan won’t pay.

The lack of any in-network dialysis provider, DaVita argued, coupled with the fact that nearly all end-stage renal disease (ESRD) patients needing dialysis qualify for Medicare regardless of age, encouraged plan participants with ESRD to drop their employer-sponsored coverage and elect only to participate in Medicare to avoid high co-pays, co-insurance and deductibles for dialysis care.

According to Katherine Heptig, an attorney at Rivkin Radler in Uniondale, N.Y., the MSPA “requires that Medicare serve as the secondary payer for treatment of ESRD patients [and] prohibits plans from distinguishing between ESRD plan participants and other plan participants,” she wrote when the Supreme Court agreed to hear the case.

Secondary Payer Rules Not Violated

DaVita’s initial lawsuit was dismissed by a district court judge but then reinstated by the U.S. Court of Appeals for the Sixth Circuit, which ruled that the plan violated the MSPA by discriminating against ESRD patients.

The Supreme Court reversed the Sixth Circuit decision and remanded the case to be reheard consistent with the Supreme Court’s ruling.

Kavanaugh wrote, “Because the Marietta plan provides the same outpatient dialysis benefits to all plan participants, whether or not a participant is entitled to or eligible for Medicare, the plan cannot be said to ‘take into account’ whether its participants are entitled to or eligible for Medicare” in a way that the MSPA doesn’t allow.

In her dissent, Kagan wrote, “A reimbursement limit for outpatient dialysis is in reality a reimbursement limit for people with end stage renal disease. And so a plan singling out dialysis for disfavored coverage ‘differentiate[s] in the benefits it provides between individuals having end stage renal disease and other individuals’ ” in a way that is not permitted under the MSPA.

Permissible Discretion

As for other relevant federal statutes, Heptig said that differences in coverage specific to a disability such as ESRD are permissible under the Americans with Disability Act (ADA) if “based on risk factors determined by actuarial calculations or experience.” Allowing for plan discretion under the ADA also is consistent with the Employee Retirement Income Security Act, which precludes only “arbitrary and capricious” interpretations and enforcement of plans, she added.

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Employer Avoids State Law Liability for Alleged Conduct That Would Have Violated Federal Law

?Takeaway: While UtiliQuest’s legal counsel didn’t invent the pre-emption doctrine or pioneer its application in an employment case, it was definitely an outside-the-box strategy that paid off.

?An employee’s state law claims against his employer were so closely related to claims that could have been brought before the National Labor Relations Board (NLRB) that the state law claims were pre-empted, the 9th U.S. Circuit Court of Appeals held.

The plaintiff was a lead field technician for UtiliQuest. According to his suit, in 2017, UtiliQuest asked him to convince his fellow workers to “release their [union] rights” in exchange for a 10 percent raise. The plaintiff did that and received a 10 percent raise, but his co-workers did not. After he complained that the company hadn’t upheld its end of the bargain, he was terminated under what he alleged were false pretenses.

Two years later, the plaintiff sued UtiliQuest, contending his termination was a result of fraud, whistleblower retaliation and was a wrongful termination under California law. The appeals court affirmed the decision of the lower court that the plaintiff’s claims were all pre-empted by federal labor law. The general doctrine of federal pre-emption means that certain types of state action (whether a statute by a state legislature or a specific instance of litigation) are pre-empted by existing federal law that actually regulates the specific conduct at issue, or pre-emption can exist where it’s clear that Congress intended to leave a zone of activities unregulated. The plaintiff’s case concerned only the first type of pre-emption; specifically, that because the National Labor Relations Act (NLRA) prohibited the same conduct that was the basis of the plaintiff’s claims, he couldn’t bring a state action on that basis.

The court noted that while the focus of the plaintiff’s fraud claims would be an intent to deceive, the subject matter of the deception was an unlawful waiver of union rights, in violation of the NLRA by interfering with the union’s role. The whistleblower and wrongful termination claims were also pre-empted because these depended even more clearly on the plaintiff establishing that he’d engaged in protected concerted activity. It would be hard to imagine a scenario where he prevailed on these claims without also establishing an NLRA violation.

It may seem strange to invite a court to imagine a violation of one law as a defense to suit under another law. However, it made sense in this case because an employee has only six months to file an unfair labor practice charge with the NLRB. Since the plaintiff waited until two years after his termination to file suit, pleading this defense didn’t subject the company to any additional risks.

Moreno v. UtiliQuest LLC, 9th Cir., No. 21-55313 (March 18, 2022).

Whitney R. Brown is an attorney with Lehr Middlebrooks Vreeland & Thompson PC, the Worklaw® Network member firm in Birmingham, Ala.

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One of Apple’s U.S. Stores Unionized—A First

?One of Apple’s U.S. stores, located near Baltimore, voted to unionize, a first within the country, the National Labor Relations Board (NLRB) announced June 18. We’ve gathered articles on this news from SHRM Online and other media outlets.

Main Issues

The major issue driving the organizing vote was workers wanting to have a say in the way the store is run, said Christie Pridgen, a technical expert at the store and one of the organizers. “Compensation is important, considering the cost of living in general and inflation, but the bigger thing is having a say,” she stated. “That was the most important thing to me.” Workers having a say in hours and scheduling and being involved in establishing safety protocols during the pandemic were the big issues, Pridgen said. Apple declined to comment on the vote.

(CNN Business)

Growing Trend

The Towson, Md., store joins a growing trend in labor organizing among retailers, restaurants and tech companies. At Apple, employees of more than two dozen stores have recently voiced interest in unionizing, according to union leaders. However, earlier this month employees at an Apple store in Atlanta abandoned a planned election after union support lost steam following Apple’s moves to increase wages and highlight company benefits.

(The New York Times)

Apple Statement

After workers in Atlanta filed a petition for a union election and before they abandoned the election, an Apple spokesman said the company offered strong benefits, including health care coverage, tuition reimbursement and paid family leave, and a minimum pay rate of $20 per hour for retail workers.

(The New York Times) and (SHRM Online)

Amazon Opposes Union Win

In other labor relations news, much attention has been given this year to a union election win at an Amazon warehouse in Staten Island, N.Y. However, Amazon has filed 25 objections to the election. The company claimed that the NLRB’s regional office in Brooklyn, N.Y., an office that oversaw the election, favored the union and helped it win. Amazon also maintained that union organizers threatened employees who did not support unionization. Amazon is seeking a new election at the facility.

(NPR)

Unionization Drive at Starbucks

At least 150 of Starbucks’ 9,000 company-run U.S. stores have voted to unionize since a store in December became the first Starbucks in the nation to organize, according to the NLRB. At least 10 Starbucks stores have rejected unionization. Former Starbucks CEO Howard Schultz returned to the company in April amid the unionization wave.

(The Hill) and (The Wall Street Journal)

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Fine-Tune Compensation Strategies to Keep Workers On Board

Compensation structures are not something you set and forget, said Tina Marie Wohlfield, SHRM-SCP, founder and chief people strategist at HR consultancy TIMAWO LLC in Fraser, Mich., near Detroit.

Wohlfield offered tips to keep pay strategies up-to-date on June 14 at the SHRM Annual Conference & Expo 2022 in New Orleans, in her concurrent session “When Pay Strategies Fail—Why HR Needs to Act Now.”

Avoiding Ad Hoc, Reactive Practices

When pay ranges haven’t kept up with job market rates, “employees leave because they are offered life-changing money by another organization,” Wohlfield said. The problem worsens when employers rely on ad hoc approaches to setting employees’ pay.

Managers or executives “shouldn’t just say, ‘I met this guy on the golf course, let’s give him X dollars,’ ” yet they often do, she noted.

When job categories haven’t been synced with market-based pay rates for years, “you can’t blame rising turnover solely on pay inflation,” she said.

Keep in mind, Wohlfield advised, that:

  • Just being reactive to pay issues gets HR into trouble.
  • Pay systems will break down without preventive maintenance.
  • Don’t let the finance department dictate pay budgets without HR’s input. Make friends and work with finance.

“Counteroffers are reactionary and often too late,” Wohlfield noted. But if made, they should be based on market data, with competitive pay rates.

Penalizing Loyal Employees

Pay compression is a common result of an ad hoc approach to pay and out-of-date salary ranges, Wohlfield said. Long-tenured employees earning less than new hires in the same position are paying a “loyalty tax,” she noted, a term used by organizational psychologist Adam Grant.

“When a new hire makes $8,000 to $10,000 more than long-tenured workers, existing workers will learn about it because employees talk, and then they leave—or they stay and are unhappy,” she said. “We need to stop penalizing employees loyal to us.”

Warning Signals

HR compensation managers need to “show company leaders that the ‘check engine’ light is on and flashing red,” using data on market-based pay rates and turnover, Wohlfield said. “Employees know what they’re worth and are demanding it.”

Signs that compensation maintenance is needed, she said, include:

  • Increasing turnover.
  • Exit interview data, such as an employee telling you they are leaving to make $5 more per hour.
  • Struggles to find candidates for vacancies, including offers being extended and declined.
  • Competitors poaching talent.

In this situation, employers need to put in place a preventive maintenance plan, reviewing current salaries to identify which positions aren’t keeping up with competitive rates.

Wohlfield also favors sharing pay ranges in job descriptions. “Many states require it, and it’s a good practice—why waste your time and a job candidate’s time if the money isn’t appropriate?”

Preparing 2023 Pay Budgets

Now is the time to prepare to have 2023 pay budgets sufficiently funded to address these issues, Wohlfield said, leaving a cushion of funds to fix unanticipated future developments—such as a spike of 8 percent or more in what the market is paying for a position that’s highly valued by your organization.

HR’s job is to “convince leadership to provide the funds” because a major loss of key talent, and the intellectual capital they hold, can be devasting to an organization.

Consider midyear pay increases but not across the board, she suggested, instead focusing on critical talent whose pay has fallen out of sync with the market.

“Turnover is high enough,” Wohlfield said.

Related SHRM Articles:

Creating a Motivational Cash Compensation Program, SHRM Online, June 2022

U.S. Inflation Rate Reaches 8.6% in May, a 40-Year High, Pushing Wages Up, SHRM Online, June 2022

High Inflation Means Resetting Pay Strategies, All Things Work, June 2022

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Culture Amp Launches a New Employee Development Solution

Learn more about HR Technology and Product Reviews from Workology. See our FTC disclosure at the end of this review.  Culture Amp Launches a New Employee Development Solution   In our current talent marketplace, employers are focused heavily on employee retention and engagement. Learning and development programs can be one benefit that supports both, as […]

The post Culture Amp Launches a New Employee Development Solution appeared first on Workology.

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Court Addresses the Duty to Accommodate Employee’s Religion

Takeaway: An employer is generally advised to try to make an accommodation that would wholly eliminate the conflict between its requirement and an employee’s religious belief. If there are no reasonable means to do so, the employer should document why. If there are reasonable means to eliminate the conflict, but the accommodation would impose an undue hardship on the employer, the employer should document what the actual burden is.

The undue hardship standard is easier to meet with regard to religion under Title VII of the Civil Rights Act of 1964 than with regard to disabilities under the Americans with Disabilities Act. Check state law, too, as some states impose a heavier burden than under Title VII for an employer to establish an undue hardship with regard to religious reasonable accommodation claims. 

?An employer provides a reasonable accommodation only if it wholly eliminates the conflicts between the employee’s religious belief and the employer requirement, according to the 3rd U.S. Circuit Court of Appeals.

The plaintiff requested every Sunday off as an accommodation for his religious beliefs. While the U.S. Postal Service (USPS) accommodated him by assigning other employees to cover most Sundays, it concluded it could not relieve him entirely of work on any Sunday. Faced with progressive discipline for failing to work on some Sundays when there was no coverage for him, the plaintiff resigned and later sued USPS for allegedly not going far enough in accommodating him.

The federal district held that, in order for an employer to offer a reasonable accommodation, the accommodation does not need to eliminate wholly a conflict between the employee’s religious belief and the employer’s requirement. More specifically, the district court held the voluntary swap program offered by USPS was a reasonable accommodation, even though the plaintiff still had to work some, albeit fewer, Sundays.

Acknowledging a split among the circuit courts, the 3rd Circuit overturned the district court, holding that an accommodation is reasonable only if it eliminates wholly the conflict between the religious belief and the employer requirement. This interpretation comports with Equal Employment Opportunity Commission guidance on the issue.

In so holding, the 3rd Circuit focused on the meaning of the word “reasonable” in relation to the word “accommodate.” The 3rd Circuit rejected the argument that “reasonable” limits the scope of what must be achieved for an accommodation to be reasonable. Instead, the word “reasonable” informs or limits only the means that an employer must consider in order to eliminate wholly the conflict between the employee’s religious belief and the employer’s requirement.

The 3rd Circuit said offering the employee a less desirable shift or even an alternative but lower-paying position could be a reasonable means to eliminate the conflict. However, offering the employee unpaid time off when other employees were offered paid time off to accommodate personal purposes likely would not be reasonable. Indeed, it likely would be discriminatory.

If there is a reasonable accommodation that would wholly eliminate the conflict, the employer still has available to it the argument that it does not have to make such accommodation because it would impose an undue hardship on the employer. In this case, the 3rd Circuit held that while USPS had failed to make a reasonable accommodation, it had established that it would be an undue hardship to excuse the plaintiff from any work on Sundays.

By way of background, the Supreme Court held in Trans World Airlines Inc. v. Hardison that a reasonable accommodation imposes an undue hardship if it requires the employer to “bear more than a de minimis cost” to provide a religious accommodation. In this case, the 3rd Circuit held USPS met the undue hardship standard, relying on, among other factors, the negative impact on workers who had to cover for the plaintiff without volunteering and the negative impact on morale. The court also noted the accommodation disrupted the workflow, but focused mostly on the impact on the employees in the workplace.

Dissenting in part, Judge Thomas Hardiman agreed with the majority that an employer provides a reasonable accommodation only if it eliminates wholly the conflict between the employee’s religious beliefs and the employer’s requirement. However, the dissenting judge disagreed that undue hardship could be based on the impact of the accommodation on co-workers. Rather, per Judge Hardiman, an undue hardship could be met only by establishing more than a de minimis cost on the business, a burden Judge Hardiman concluded USPS did not meet.

Groff v. DeJoy, Postmaster General of the United States Postal Service, 3rd Cir., No. 21-1900 (May 25, 2022).

Jonathan A. Segal is a partner at Duane Morris in Philadelphia and a SHRM columnist. Follow him on Twitter @Jonathan_HR_Law.

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Pearls of Wisdom from SHRM22

?Former employment attorney and author Jathan Janove writes for SHRM Online on how to inject greater humanity into HR compliance. He welcomes your questions and suggestions for future columns. Contact him at the e-mail address at the end of this column.

From employee turnover to mental health, HR professionals face massive challenges—and massive opportunities to Cause the Effect in their workplaces and the world.

Last week at the SHRM Annual Conference & Expo 2022 (SHRM22) in New Orleans, thousands of HR professionals received numerous nuggets of valuable advice. Here’s an overview of several of them—one pearl per program.

  • “Become an InfluenceHR: Six Principles Guaranteed to Increase Your Persuasiveness,” presented by Brad Karsh. Get people to agree to one small thing first; it increases the likelihood they’ll agree to a second, larger request. “Would it be OK if I research some options that allow us to achieve more of that (the positive)?” This tees you up to achieve your larger objective.
  • “Feedback Fears? Facilitate a Feedforward Frenzy!” presented by Tina Schust Robinson. We can’t change the past, but the future is limitless. Help your people unleash what is possible. “Feedforward” is a concept pioneered by New York Times bestselling author Marshall Goldsmith. Instead of telling employees what they did wrong, suggest future improvement.
  • “What Does Your Organization Trade On: Building Stronger Female Diversity into Your Organization’s Leadership Pipeline,” presented by Francine Parham. Diversity is not a grassroots initiative or program, it’s a leadership imperative. Assess the pipeline. That means see the progression of the individual. Ask to whom they report. See if those jobs are trending toward a specific leadership opportunity or other desired objective. If not, rework the pipeline.
  • “Now Is the Time for Quiet Men: Tapping Male Introverts’ Superpowers for Inclusion and Success,” presented by Jennifer B. Kahnweiler and Ed Frauenheim. In our fast-paced focus on fairness, now is the time to unleash the potential of the quiet introverted men in your workplace to showcase their talents and contributions.
  • “SHIFT: A Framework for Transformational Cultural Change in Diversity, Equity, Inclusion and Belonging,” presented by Nicole Yeldell Butts. The primary issue is setting a North Star. You must have a North Star for yourself as a diversity, equity and inclusion professional and help your organization develop one as well. Without that, you have nothing to navigate toward. Know where you want to go first, then everything else follows.
  • “Post-Traumatic (Stress) Growth: Emerging Stronger from Challenging Times,” presented by Dennis Alan Davis. Positivity, like negativity, is emotionally contagious. The overwhelming majority of our employees will follow our lead toward growth when we show them how.
  • “Mastering Ethical Leadership and Sustaining a Moral Workplace,” presented by Paul Falcone. Making ethics personal and building your ethical leadership brand is more important than ever. Working for transparent, ethical leaders tops Millennials’ list of priorities. And when it comes to real-life applications of ethics in the workplace, remember that you have a lot more discretion to act and escalate on conduct-based infractions than on performance or attendance transgressions. Know your rights as an employer in creating a fair, ethical and just culture by holding employees accountable for both their performance and conduct.
  • “Cutting Turnover 20% and More During ‘The Great Resignation,’ ” presented by Richard Finnegan. Cutting turnover with one-size-fits-all solutions like pay, benefits and survey-driven fixes is OUT. Cutting turnover with the following components is IN: converting turnover to dollars; developing retention goals; training managers to conduct stay interviews; asking managers to forecast how long each employee will stay; and holding leaders at all levels accountable for achieving retention goals and developing retention forecasts.
  • “Seven Steps for Creating Bulletproof Documentation,” presented by Allison West, Esq., SHRM-SCP. Create your documentation knowing that a third party might read and critique it. Is the message clear? Concise? Nonambiguous? Fair?
  • “Employment Law Compliance Made Easy,” presented by Jathan Janove. When engaging with a manager on a problem-employee situation, do not begin by asking for “documentation.” (Ban the word.) Instead, capture the business case first. What are the challenges the manager has been facing and what needs to happen from the manager’s perspective to correct the situation? Thereafter, you can move into compliance/claim prevention mode. More on this topic here.
  • “Excellence Is Earned: Best Practices in Developing Yourself and Your Teams into Winners,” presented by Walter Bond. It’s all about mindset! HR professionals sometimes make human resources way too complicated. Our job is to find talented individuals, help them develop and get them to work together as a team with a focus on winning.
  • ” ‘Don’t Take My Stuff!’ – Protecting Your Business With Restrictive Covenants, Even Though States Are Making It Harder,” presented by Gregory J. Hare. Prudent companies historically have implemented legally binding agreements to protect their business goodwill, including: nondisclosure clauses to protect trade secrets and confidential information; nonsolicitation clauses to protect their customers from raiding; nonrecruitment clauses to protect their employees from unfair poaching; and sometimes noncompete agreements to prevent ex-employees from joining competitors in limited situations. The sands are shifting, with many states limiting or prohibiting such clauses, so be sure to update your agreements to ensure your goals are met.
  • “Mental Health, Alcoholism and Substance Abuse – Issues Employers Cannot Ignore,” presented by Lara de Leon. HR is on the front line when it comes to working with employees and managers on these issues. To handle them defensibly and with empathy, we need to act with objectivity and a solution mindset—and not fall prey to myths, stereotypes and misperceptions.
  • “Shifting Mental Health Awareness into Action in the Workplace,” presented by Arianna Huffington and Melissa Anderson, SHRM-SCP. What we do about accumulated stress can lead to depression and other mental health issues. Just getting stuff done is no longer enough! When employees enjoy what they are doing, that’s important. Sleeping, eating healthy, moving, feeling connected and monitoring time on your cell phone are interconnected steps that allow you to more than just perform but to THRIVE.

I wish to thank the following SHRM22 speakers for their contributions to this column: Melissa Anderson, Walter Bond, Nicole Yeldell Butts, Dennis Alan Davis, Lara de Leon, Paul Falcone, Richard Finnegan, Ed Frauenheim, Gregory J. Hare, Arianna Huffington, Jennifer B. Kahnweiler, Brad Karsh, Francine Parham, Tina Schust Robinson and Allison West.

I’d also like to thank my colleagues Kimberly Gonsalves and Aaron Wheeler for helping me collect pearls.

Jathan Janove, J.D., is the author of Hard-Won Wisdom: True Stories from the Management Trenches (HarperCollins/Amacom, 2017). He is president of the Oregon Organization Development Network and was named in Inc. magazine as one of the Top 100 Leadership Speakers for 2018. If you have questions or suggestions for topics for future columns, write to jathan@jathanjanove.com.

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