Division of Advice says Boeing’s code of conduct did not interfere with employees’ Section 7 rights
A code of conduct maintained by The Boeing Company as part of its business ethics policy did not unlawfully interfere with employees’ Section 7 rights, the General Counsel’s Division of Advice concluded in a recently released advice memorandum. The policy required employees to acknowledge that they would not “engage in conduct or activity that may raise questions as to the company’s honesty, impartiality, reputation, or otherwise cause embarrassment to the company.” Employees were also asked to refrain from engaging in any activity that might create a conflict of interest for the company; follow all company restrictions on the use and disclosure of information; use company assets only for company-approved activities; and report any illegal or unethical conduct to management, among other directives.
Agreeing with the regional office, the Division of Advice found employees would not reasonably construe the code’s “potentially overbroad language” to restrict protected concerted activities, and thus violate Sec. 8(a)(1), given the context of the almost 40 pages of explanations and examples that immediately followed the code provision.
Source: WKL&B Editorial Staff