Breach of an Implied ContractA small number of employees includi.docx

Breach of an Implied Contract
A small number of employees including professional athletes,
high-level managers like Dov Charney (see the “Clippings”
feature), and entertainers have “express” (i.e., explicit, mutually
acknowledged) contracts of employment that are negotiated,
executed in writing, signed, and specify a particular term of
employment (or specific grounds under which the contract can
be terminated). If an employee with an express contract is
terminated prior to the expiration of the contract, the employer
will be liable for damages for breach of contract unless the
employer can show that there was cause to terminate. Most
often, contractual disputes of this type are settled by
negotiations between the parties.
But the vast majority of employees do not have express
contracts of employment and are employed at will.
Nevertheless, under the implied contract exception to
employment at will, the right of employers to terminate at will
can be limited by promises of job security. Even in the absence
of an express contract of employment, written or oral statements
by employers—and their entire course of conduct in dealing
with employees—can give rise to enforceable contractual rights
to something other than employment at will. The “something
other” might be employment for a specified term, termination
only for certain reasons (e.g., “for cause”), or use of specified
procedures when making termination decisions (e.g.,
progressive discipline). If an implied contract exists, discharged
employees can sue for wrongful termination based on breach of
the implied contract.
Criteria for Determining the Existence of an Implied Contract
Most statements made by employers, whether orally or in
writing, are not contractually binding. However, the following
factors point to the existence of an implied contract:
· • A specific promise was made.
· • The promise was made frequently and consistently.

· • The source of the promise was someone with sufficient
authority to offer it.
· • The promise was communicated to the employee.
· • The promise was not highly conditional (i.e., dependent on
the employer’s own judgment).
· • The employer’s entire “course of conduct” (e.g., policies,
practices, statements, industry practices, employee tenure) was
consistent with the promise.
· • There was an exhaustive listing of dischargeable offenses in
a handbook (and the offense for which termination occurred was
not included in that list).
· • A change to a less protective policy was not communicated
to employees.
· • There was no effective disclaimer.
Vague, stray, or highly conditional promises do not evidence
intent to depart from employment at will. Statements such as
“you have a promising future with the company” (lack of
specificity) or “you will have a job here for as long as we are
pleased with you” (conditionality) are unlikely to be
enforceable. The statements relied on must be sufficiently
specific to constitute “offers,” rather than mere general
statements of policy. Thus, inclusion of a general
nondiscrimination provision in an employee handbook did not
create an implied contract because it “was not specific and did
not make any promises regarding disciplinary procedure or
termination decisions.11 In contrast, an employee handbook that
labeled its provisions as “binding” and that outlined specific
disciplinary procedures was sufficiently specific and
authoritative to form the basis for an implied
contract.12Listings of dischargeable offenses can limit
employment at will if they can fairly be read to restrict
terminations to those based on the stated set of reasons.
To understand whether a promise was made, some courts look
not only at statements spoken by managers or written in
documents but also to the entire course of an employer’s
conduct. The course of conduct relevant to determining the

existence of an implied contract includes the employer’s
informal policies, past practice (e.g., practice of not terminating
without cause), industry customs, and treatment of the
individual employee. However, although longevity, consistent
raises, promotions, and positive performance appraisals can
bolster an employee’s claim that employment is not strictly at
will, “they do not, in and of themselves, … constitute a
contractual guarantee of future employment security.”13
Practical Considerations
Should employers issue employee handbooks? If so, how should
handbooks be constructed? Disseminated to employees?
Specific promises made to employees regarding their term of
employment, permissible reasons for termination, or termination
procedures must be honored. Employers that do not want to
limit their prerogative to terminate at will should refrain from
making such promises. Because they are often cited by
plaintiffs as sources of implied contracts, handbooks,
application forms, and job offer letters should be carefully
written and vetted (reviewed) by people with legal expertise
before they are put into use.
If contractual rights limiting employment at will can stem from
employers’ statements in handbooks and other sources, what
happens if modifications are made that adversely affect those
rights? Many courts permit employers to unilaterally make such
changes, provided that employees are given reasonable
notice.14 However, other courts require more. The Arizona
Supreme Court, for example, has held that merely providing
employees with new handbooks is not legally adequate. Instead,
employees must be specifically informed of any new terms,
made aware of their effect on the preexisting contract, and
affirmatively consent to modifications. Modifications must be
supported by separate consideration—that is, some benefit to
employees beyond simply being allowed to continue their
employment. The court explained its reasoning as follows:
· To those who believe our conclusion will destroy an
employer’s ability to update and modernize its handbook, we

can only reply that the great majority of handbook terms are
certainly non-contractual and can be revised, that the existence
of contractual terms can be disclaimed in the handbook in effect
at the time of hiring and, if not, permission to modify can
always be obtained by mutual agreement and for consideration.
In all other instances, the contract rule is and has always been
that one should keep one’s promises.15
If changes are made that lessen employees’ rights not to be
terminated at will, employees should be clearly informed of
those specific changes. Employers should not try to just “slip
them by.” Some states require employers to obtain a clear
indication of employees’ assent to those changes and to provide
some benefit in exchange.
In Dillon v. Champion Jogbra, the court must decide whether an
implied contract to use specified termination procedures exists,
despite the presence of a “disclaimer.”
Dillon v. Champion Jogbra
819 A. 2d 703 (Vt. 2002)
OPINION BY JUSTICE MORSE:
Plaintiff Linda Dillon appeals an order of the superior court
granting summary judgment to defendant Champion Jogbra, Inc.
in her action for wrongful termination. Dillon contends that the
trial court erroneously concluded as a matter of law that
Dillon’s at-will employment status had not been modified by
Jogbra’s employment manual and employment practices, and
that the undisputed material facts failed to give rise to a claim
for promissory estoppel supporting a claim for wrongful
discharge. We affirm with respect to Dillon’s claim for
promissory estoppel, but reverse and remand on her breach of
contract claim. * * *
Jogbra has an employee manual that it distributes to all
employees at the time of their employment. The first page of the
manual states the following in capitalized print:
· The policies and procedures contained in this manual
constitute guidelines only. They do not constitute part of an
employment contract, nor are they intended to make any

commitment to any employee concerning how individual
employment action can, should, or will be handled.
Champion Jogbra offers no employment contracts nor does it
guarantee any minimum length of employment. Champion
Jogbra reserves the right to terminate any employee at any time
“at will,” with or without cause. During the period from 1996 to
1997, however, Jogbra developed what it termed a “Corrective
Action Procedure.” This procedure established a progressive
discipline system for employees and different categories of
disciplinary infractions. It states that it applies to all employees
and will be carried out in “a fair and consistent manner.” Much
of the language in the section is mandatory in tone.
Linda Dillon … was hired on as a full-time employee in August
1997 in the position of “chargeback analyst.” In the summer of
1998, the position of “sales administrator” was going to become
vacant. Dillon was approached by Jogbra management about
applying for the position. * * * In the course of interviewing for
the position, Dillon recalls that she was told that she would
receive “extensive training.” More specifically, she was told by
the human resources manager that she would overlap with her
predecessor who would train her during those days. Originally,
her predecessor was scheduled to leave August 15. In the course
of Dillon’s interview with the vice president of sales, who
would be her immediate supervisor, he informed her that her
predecessor was actually leaving earlier and would be available
for only two days of training before Dillon started the job. He
reassured her, though, that the predecessor would be brought
back sometime thereafter for more training. Dillon also recalls
that he told her that “it will take you four to six months to feel
comfortable with [the] position,” and not to be concerned about
it. Dillon was offered and accepted the position. She spent most
of her predecessor’s remaining two days with her. Her
predecessor then returned in early September for an additional
two days of training. Dillon stated that she felt that, after the
supplemental training, she had received sufficient training for
the job.

On September 29, Dillon was called into her supervisor’s office.
The human resources manager was also present. They informed
Dillon that things were not working out and that she was going
to be reassigned to a temporary position, at the same pay and
benefit level, that ended in December. She was told that she
should apply for other jobs within the company, but if nothing
suitable became available, she would be terminated at the end of
December. According to Dillon, her supervisor stated that he
had concluded within ten days of her starting that “it wasn’t
going to work out.” Prior to the meeting, Dillon was never told
her job was in jeopardy, nor did Jogbra follow the procedures
laid out in its employee manual when terminating her. Dillon
applied for one job that became available in the ensuing months,
but was not selected for it. She left Jogbra in December when
her temporary position terminated. * * *
In the implied contract context, we have noted … that … when
an employer takes steps to give employees the impression of job
security and enjoys the attendant benefits that such an
atmosphere confers, it should not then be able to disregard its
commitments at random. * * * [W]e have noted repeatedly that
the presumption that employment for an indefinite term is an
“at-will” agreement … “imposes no substantive limitation on
the right of contracting parties to modify terms of their
arrangement or to specify other terms that supersede the
terminable-at-will [arrangement].” Additionally, an employer
may modify an at-will employment agreement unilaterally.
When determining whether an employer has done so, we look to
both the employer’s written policies and its practices. An
employer not only may implicitly bind itself to terminating only
for cause through its manual and practices, but may also be
bound by a commitment to use only certain procedures in doing
so. * * *
When the terms of a manual are ambiguous … or send mixed
messages regarding an employee’s status, the question of
whether the presumptive at-will status has been modified is
properly left to the jury. This may be the case even if there is a

disclaimer stating employment is at-will, as the presence of
such a disclaimer is not dispositive in the determination. “The
mere inclusion of boilerplate language providing that the
employee relationship is at will cannot negate any implied
contract and procedural protections created by an employee
handbook.” Furthermore, an employer’s practices can provide
context for and help inform the determination. * * *
In this case, we cannot agree with the trial court that the terms
of Jogbra’s manual are unambiguous such that, as a matter of
law, Dillon’s status was not modified, especially considered in
light of the conflicting record before the court regarding
Jogbra’s employment practices. Notwithstanding the disclaimer
contained on the first page of the manual quoted above, the
manual goes on to establish in Policy No. 720 an elaborate
system governing employee discipline and discharge. It states as
its purpose: “To establish Champion Jogbra policy for all
employees.” It states that actions will be carried out “in a fair
and consistent manner.” It provides that “the Corrective Action
Policy requires management to use training and employee
counseling to achieve the desired actions of employees.” It
establishes three categories of violations of company policy and
corresponding actions to be generally taken in each case. It
delineates progressive steps to be taken for certain types of
cases, including “unsatisfactory quality of work,” and time
periods governing things such as how long a reprimand is
considered “active.” All of these terms are inconsistent with the
disclaimer at the beginning of the manual, in effect sending
mixed messages to employees. Furthermore, these terms appear
to be inconsistent with an at-will employment relationship, its
classic formulation being that an employer can fire an employee
“for good cause or for no cause, or even for bad cause.”
With respect to the record before the court on Jogbra’s
employment practices, Dillon herself was aware of at least one
employee whose termination was carried out pursuant to the
terms set forth in the manual. She also testified in her
deposition to conversations with the human resources manager,

with whom she was friendly, in which the manager had
described certain procedures used for firing employees. She
stated that the manager had told her that Jogbra could not “just
get rid of ” people, but instead had to follow procedures. The
human resources manager herself testified that, although the
progressive discipline system was not generally applied to
salaried employees, it was “historically” used for nonsalaried
employees. She could only recall two instances in which the
portion of the manual providing for documentation of
progressive action was not followed, one of which resulted in a
legal claim against the company and the other of which involved
an employee stealing from the company. In fact, the manual
specifically provides that stealing “will normally result in
discharge on the first offense.” Thus, it is not clear how that
discharge deviated from the provisions of the manual.
In conclusion, the manual itself is at the very least ambiguous
regarding employees’ status, and Jogbra’s employment practices
appear from the record to be both consistent with the manual
and inconsistent with an at-will employment arrangement.
Therefore, summary judgment was not proper on Dillon’s
breach of implied contract claim.
Dillon also argues that the trial court’s grant of summary
judgment on her claim of promissory estoppel was erroneous.
Dillon based her claim on two separate statements: the
assurance that she would receive training and the assurance that
it would take her four to six months to become comfortable with
the sales administrator position. We have held that, even if an
employee otherwise enjoys only at-will employment status, that
employee may still be able to establish a claim for wrongful
termination under a theory of promissory estoppel if that
employee can demonstrate that the termination was in breach of
a specific promise made by the employer that the employer
should have reasonably expected to induce detrimental reliance
on the part of the employee, and that the employee did in fact
detrimentally rely on the promise. We agree with the trial court
in this case, however, that essential elements of promissory

estoppel are absent with regard to both statements.
With respect to Jogbra’s promise to Dillon that she would
receive training, Dillon specifically conceded that, upon her
predecessor’s return in September, she had received adequate
training to perform the job. In other words, Jogbra had
delivered on its promise. Furthermore, even assuming that
Jogbra failed to provide the full extent of promised training,
Dillon has failed to explain how, as a matter of law, the promise
of training modified her at-will status. * * * With respect to the
assurance that it would take four to six months to become
comfortable with the position, the statement cannot be
reasonably relied upon as a promise of employment in the sales
administrator position for a set period of time. Courts have
generally required a promise of a specific and definite nature
before holding an employer bound by it. An estimate of how
long it would take a person to adjust to a job cannot be
converted into a definite promise of employment for that period
of time. Thus, the vague assurance given to Dillon is not
sufficient to support her claim of promissory estoppel. * * *
CASE QUESTIONS
1.
What were the legal issues in this case? What did the court
decide?
2.
What was the implied contract in this case? How did the
employer breach it?
3.
Why does the disclaimer in the employee manual not have the
effect desired by the employer?
4.
Why does Dillon’s promissory estoppel claim fail?
Effect of Disclaimers
Employment at will is a harsh arrangement. It is difficult to put
a positive “spin” on the message that “We can fire you at any
time for any reason not specifically prohibited by law and
without even the most elementary procedural safeguards.” Most

employers prefer to gain the motivational and employee
relations benefits that come from communicating the desire to
treat employees fairly. Most employers probably also intend to
treat employees fairly. But employers do not want to be bound
by promises of fair treatment and liable for breaches. In short,
most employers would like to have it both ways: basking in the
warm glow of assurances of fair treatment and remaining
entirely free to depart from any self-imposed limitations on the
right to terminate at will.
Disclaimers are used to this end. Disclaimers are written
statements incorporated into employee handbooks, employment
applications, or other important documents that “disclaim” or
deny that any statements in those documents create contractual
rights binding on the employer. Language disclaiming the
existence of a contract is typically combined with notification
to employees in clear terms that their employment is at will.
The statement (capitalized) on the first page of the employee
manual in Dillon informing employees that the manual’s
provisions constituted guidelines only and that no commitment
was being made to employees about how terminations and other
decisions would be handled is a good example of a disclaimer.
As another example, a bank included the following in its
employee handbook:
· [T]he contents of this handbook DO NOT CONSTITUTE THE
TERMS OF A CONTRACT OF EMPLOYMENT. Nothing
contained in this handbook should be construed as a guarantee
of continued employment, but rather, employment with the bank
is on an “at will” basis. This means that the employment
relationship may be terminated at any time by either the
employee or the Bank for any reason not expressly prohibited
by law.16
Disclaimers also frequently include language denying the
contractual effect of any conflicting statements made elsewhere,
reserving the right of the employer to modify policies, and
placing that authority solely with designated individuals. For
example:

· [M]y employment and compensation can be terminated, with
or without cause, and with or without notice, at any time, at the
option of either the company or myself. I understand that no
store manager or representative of Sears, Roebuck and Co.,
other than thepresident or vice-president of the Company, has
any authority to enter into any agreement for employment for
any specified period of time, or to make any agreement contrary
to the foregoing.17
But do disclaimers, inserted in the midst of statements and other
facts suggesting a departure from employment at will, actually
shield employers from wrongful discharge suits based on
implied contract? In many cases, the answer is yes.
Thus, employers that desire to maintain employment at will
should incorporate disclaimers into employee handbooks and
other important documents defining the employment
relationship. As the New Jersey Supreme Court put it in a
leading implied contract case:
· [I]f the employer, for whatever reason, does not want the
manual to be capable of being construed by the court as a
binding contract, there are simple ways to attain that goal. All
that need be done is the inclusion in a very prominent position
of an appropriate statement that there is no promise of any kind
by the employer contained in the manual; that regardless of
what the manual says or provides, … the employer continues to
have the absolute power to fire anyone with or without good
cause.18
Disclaimers often defeat contractual rights flowing from
handbooks and other sources if the disclaimers themselves are
clear and unequivocal and if they are presented to employees in
a prominent and conspicuous manner. Fine print buried in
lengthy documents is not sufficient. A disclaimer placed on the
first page of an employee manual, capitalized, and printed in
bold is both prominent and conspicuous.19 An employee’s
implied contract claim was defeated despite having been
terminated in violation of specific company policies prohibiting
retaliation against employees raising ethics concerns because

the employer clearly alerted its employees to their “at will”
status (on their application forms and elsewhere) and had a
disclaimer stating that “none of the Company’s policies,
procedures, or practices should be viewed as creating promises
or any contractual rights to employment for a specific duration
of time or to any specific benefits of employment.”20 It did not
matter that the disclaimer appeared in a different document than
the promises of nonretaliation. Disclaimers should be
communicated to employees, and employees should be asked to
acknowledge receipt in writing. Disclaimers that are included
on applications for employment, so that employees know the
terms of the relationship up front, appear to be especially
effective.
However, disclaimers—even those carefully crafted and
prominently displayed—are not foolproof. Some courts have
taken the position that the interspersing of disclaimers and
statements that appear to confer rights is inherently ambiguous.
Rather than simply allow a disclaimer to override everything
else, the case is given to a jury to decide what the contract, as a
whole, means.21 This is precisely the approach that the court
took in Dillon. The “mixed messages” sent by the disclaimer,
the specific “Corrective Action Policy,” and the employer’s
practices created ambiguity as to whether an implied contract
existed.
If it is determined that contractual rights limiting an employer’s
ability to terminate at will do not exist, an implied contract
wrongful discharge claim will fail. However, if contractual
rights exist, it still remains to be proven that the employer
violated those rights in terminating an employee. In a case
involving an employee who was hired under an
implied contractual agreement to terminate only for “good
cause” and who was subsequently fired for sexual harassment,
the California Supreme Court held:
· [T]he question critical to defendant’s liability is not whether
plaintiff in fact sexually harassed other employees, but whether
at the time the decision to terminate his employment was made,

defendants, acting in good faith and following an investigation
that was appropriate under the circumstances, had reasonable
grounds for believing plaintiff had done so.22
Thus, under this view—shared by most other courts—the role of
the courts in implied contract cases is not to start with a blank
slate and decide whether the employer’s judgment was correct,
but instead to determine whether the employer’s decision was
reasonable under the circumstances. In one relevant implied
contract case,23 the court upheld a jury’s verdict that the
employee was not discharged for good cause, as company policy
prescribed. The employee had been terminated for violating a
strict policy against taking “anything, large or small.” His
offense was retrieving expired meat that had been disposed of in
a barrel for pickup by a salvage company, cooking the meat on a
grill, and (along with coworkers) eating it for lunch. The jury
determined that the employer violated the implied contract by
terminating the employee without a “fair and honest” reason.
Other Contract-Related Claims
Courts have long read into contracts an implied covenant of
good faith and fair dealing. As a type of wrongful discharge
claim, the covenant of good faith and fair dealing pertains to
terminations that are undertaken in bad faith and that have the
effect of denying employees the benefits of their contractual
employment relationship. The term is potentially misleading. It
does not amount to a general requirement that employers
operate with good faith or terminate employees only for cause.
Instead, in most of the states where it is recognized, the
covenant applies only where there is an express or implied
contract and the employer has used a termination to deprive an
employee of an already-earned benefit. For example, a wrongful
discharge in violation of the covenant of good faith and fair
dealing was recognized where a long-term employee was fired
immediately after obtaining a large order, for the purpose of
depriving him of his commission.24 Some uncertainty remains
about the reach of the covenant of good faith and fair dealing
and a few states, particularly Alaska, have given it a broader

reading. According to the Alaska Supreme Court, the covenant
of good faith and fair dealing applies to at-will employment
contracts in the following manner:
· The covenant … generally requires employers to treat like
employees alike and act in a manner that a reasonable person
would regard as fair. The covenant has both a subjective and an
objective component: the subjective component “prohibits an
employer from terminating an employee for the purpose of
depriving the employee of the contract’s benefits,” and the
objective component “prohibits the employer from dealing with
the employee in a manner that a reasonable person would regard
as unfair.”25
Although this formulation of the covenant of good faith and fair
dealing stops little short of establishing a just cause
requirement for terminations, it is the exception to the rule. In
most states where this type of wrongful termination claim is
recognized, it adds little protection beyond that already
available under the implied contract theory.
Another contract-related claim occasionally raised in discharge
cases is promissory estoppel. We previously considered this
legal claim in the context of a job applicant accepting
employment and then having the offer withdrawn prior to
commencing work (see Chapter 7). The key elements are
reasonable and detrimental reliance on a clear promise. If, for
example, an employee remains on the job because of reasonably
relying on an employer’s promises of job security, turns down
lucrative alternative employment offers or incurs expenses
relocating to a new assignment, and is then terminated,
promissory estoppel might be invoked by the courts to redress
the harm to the terminated employee—even in the absence of an
express or implied contract. An employer who reneged on an
offer to reinstate an employee if he was found innocent of
criminal charges was liable for damages based on this
theory.26 In Dillon, the employer’s statement that it would
probably take four to six months for an employee to become
comfortable in her new position was not a sufficiently clear

promise of job security to support a promissory estoppel claim
when Dillon was terminated for unsatisfactory performance
shortly following acceptance of the job.
A third contract-related claim (but one for which tort damages
are available) is intentional interference with a contractual
relationship. This occurs when intentional, improper
interference causes a third party to breach or not enter into a
contractual relationship (the latter is sometimes referred to as
“interference with prospective business advantage”) with the
plaintiff. In this context, “contractual” means any type of
employment relationship, including at-will employment. The
interference must be improper or without justification.
Additionally, there must be a third party that is induced to
breach or not enter into a contractual relationship. Cases where
a former employee is blacklisted to prevent him from obtaining
other employment clearly fit this requirement. The application
of this claim to terminations in which agents of an employer
(e.g., supervisors) use improper means to get employees fired is
less clear. Is the employer a third party in such cases? The
answer depends on whether the supervisor was acting within the
scope of employment when the interference occurred. An
intentional interference claim was allowed to proceed to trial in
the case of a manager who took actions that led to the
constructive discharge of an employee who opposed his
romantic relationship with a married female subordinate.
Evidence that the manager was acting from the purely personal
motive of maintaining his affair made it plausible to argue that
he was a separate party from the employer.27 Likewise,
allegations that the chief of schools for a school district
terminated a school principal for the purpose of installing one
of his girlfriends in the position were sufficient to avoid
summary judgment in an intentional interference with a
contractual relationship claim.28 If the allegations are proven,
the chief of schools was acting as a third party when he injured
the plaintiff in the pursuit of personal goals that were contrary
to the employer’s best interests.

Discussion Questions 1
Choose two (2) factors from those discussed in the attachment
“Breach of an Implied Contract” that may cause a possible
breach of an implied contract. Suggest two (2) strategies that an
employer may use to avoid these possible breaches from
occurring. Justify your response.
Choose two (2) factors from those discussed in the textbook that
may cause a possible breach of an implied contract.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX
XXXXXXXXXX
Suggest first strategy that an employer may use to avoid these
possible breaches from occurring.
XXXXXXXX
XXXXXXXXXX
XXXXXXXXXXXXXXXX
Suggest second strategy that an employer may use to avoid
these possible breaches from occurring.

XXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX
Discussion Questions 2
From the following two (2) acts: National Labor Relations Act
(NLRA), and Age Discrimination in Employment Act (ADEA).
Determine two (2) major challenges that each of the selected
acts may cause within an organization, and then outline a plan
to prevent the challenges from adversely affecting the
organization or employees. Justify your response.
National Labor Relations Act (NLRA): Determine two (2)
major challenges, of the selected act, may cause within an
organization.
XXXXX
XXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX
Outline a plan to prevent the challenges from adversely
affecting the organization or employees.
XXXXXXXXX
XXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXX
Age Discrimination in Employment Act (ADEA): Determine
two (2) major challenges, of the selected act, may cause within
an organization.
XX
XXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX
Outline a plan to prevent the challenges from adversely
affecting the organization or employees.
XXXXXXXXX
XXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX

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