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Four Quick Takes – Get ‘Em While It’s Hot

by D. Gregory Valenza | | July 5, 2019

  • EEO-1 “Component 2” – Remember, EEO-1 Filers, and you know who you are – you have to file compensation data this year.  The EEOC has set up online filing and has provided some helpful information here.  Do not wait until the cooler winds of autumn to deal with this.



  •  California enacted SB 188, (here) which amends the Fair Employment and Housing Act’s definition of race discrimination.  Effective January 1, 2020, employers cannot impose dress and grooming standards that discriminate against hairstyles. The point of the law is to prohibit grooming standards that would exclude hairstyles such as “braids, locks, and twists.”


  • The National Labor Relations Board change the rules on employers’ right to bar non-employees from soliciting employees in employers’ public spaces. This can affect non-union employers too, so don’t glaze over so quick.  The new decision, UPMC (opinion here) will affect how employers draft and enforce solicitation and distribution policies in their handbooks and the like. Under the new rule, “absent discrimination between nonemployee union representatives and other nonemployees—i.e., “disparate treatment where by rule or practice a property owner” bars access by nonemployee union representatives seeking to engage in certain activity while “permit[ting] similar activity in similar relevant circumstances” by other nonemployees—the employer may decide what types of activities, if any, it will allow by nonemployees on its property.”  That means employers must treat non-employees’ activities equally. 
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