English (Rev. 6/2017)

Summary

English (Rev. 6/2017)

Text

STATE OF CALIFORNIA Gavin Newsom, Governor  
DEPARTMENT OF INDUSTRIAL RELATIONS 
Labor Commissioner’s Office 
2031 Howe Avenue, Suite 100 
Sacramento, CA 95825 
Phone: 916-263-2991 
Email: [email protected] 
FILING A RETALIATION COMPLAINT 
Who may file? 
Any employee or applicant for employment who believes he or she was discharged or denied 
employme
nt or otherwise retaliated against in violation of any law under the jurisdiction of the 
Labor Commissioner may file a complaint with the Labor Commissioner by completing and mailing 
the complaint form (RCI-1) to the address below. Pay special attention to page 2 of the complaint; 
this page will be shared with your employer. It is important that you provide a summary of your 
complaint rather than a detailed document. 
What is the time limit for filing? 
A complaint alleging retaliation in violation of laws under the jurisdiction of the Labor 
Commissioner m
ust be filed within six (6) months after the occurrence of the alleged retaliatory 
action, except for complaints filed under Labor Code sections 230(c), (e) and (f), 230.1, 230.2(b), 
230.5, 1311.5, and Health and Safety Code section 1596.881 (see below). For a claim of disparate 
pay based on sex, race, or ethnicity under Labor Code section 1197.5, there is a two (2) or three (3) 
year statute of limitations; however, a retaliation claim based on this statute must be filed within six 
(6) months since it will be investigated as a violation of Labor Code section 98.6. 
Where do I file? 
For work performed in Monterey, Fresno, Kings, Tulare, Inyo counties and other counties that lie  
further 
north, mail the completed (signed and dated) complaint form to:  
Labor Commissioner’s Office   
Retaliation Comp
laint Investigation Unit  
2031 Howe Avenue, Suite 100  
Sacramento, CA 95825  
For work performed in Kern, San Luis Obispo, Santa Barbara, Ventura, San Bernardino counties and 
other counties that lie further south, m
ail the completed (signed and dated) complaint form to: 
Labor Commissioner’s Office   
Retaliation Comp
laint Investigation Unit  
320 W. Fourth Street, Room 450  
Los Angeles, CA  90013  
Laws enforced by the Labor Commissioner that specifically prohibit retaliation against employees 
and job applicants 
are listed on the following pages. 
June 2017 1

(1)   Labor Code section 96(k) 
Protects an employee from loss of wages as a result of a failure to hire, demotion, 
suspension, 
or discharge from employment because the employee engaged in lawful conduct 
asserting “recognized constitutional rights” occurring during nonworking hours away from 
the employer’s premises. 
(2)   Labor Code section 98.6 
Protects an employee filing or threatening to file 
a claim or complaint with the Labor 
Commissioner, instituting or causing to be instituted any proceeding relating to rights under 
the jurisdiction of the Labor Commissioner, or testifying in any such proceeding, 
complaining orally or in writing about unpaid wages, or for exercising (on behalf of oneself 
or other employees) any of the rights provided under the Labor Code or Orders of the 
Industrial Welfare Commission, including, but not limited to, the right to demand payment of 
wages due, the right to express opinions about, support or oppose an alternative workweek 
election, or the exercise of any other right protected by the Labor Code. In addition to other 
remedies that might be available, a civil penalty of up to $10,000 may be awarded to an 
employee for each violation of Labor Code section 98.6. Also, protects an employee who is a 
family member of a person who has or is perceived to have engaged in any protected 
conduct. 
(3)   Labor Code section 230(a) 
Prohibits an em
ployer from discharging or in any manner retaliating against an employee for 
taking time off to serve on a jury provided the employee gives reasonable notice that he or 
she is required to serve. 
(4)   Labor Code section 230(b) 
Protects an employee who is a victim of a crime, who takes tim
e off to appear in court to 
comply with a subpoena or other court order as a witness to a judicial proceeding. 
(5)   Labor Code section 230(c) 
Prohibits an em
ployer from discharging or in any manner discriminating or retaliating against 
an employee who is a victim of domestic violence, sexual assault, and/or stalking for taking 
time off from work to obtain or attempt to obtain relief to help ensure his or her health, 
safety, or welfare, or that of his or her child or children. (The complaint must be filed within 
one year from the date of occurrence of the violation.) 
(6)   Labor Code section 230(e) 
An em
ployer shall not discharge or in any manner discriminate or retaliate against an 
employee because of the employee’s status as a victim of domestic violence, sexual assault, 
and/or stalking, if the victim provides notice to the employer of the status or the employer 
has actual knowledge of the status. (The complaint must be filed within one year from the 
date of occurrence of the violation.) 
(7)   Labor Code section 230(f) 
An 
employer 
of any size shall provide reasonable accommodations for a victim of domestic 
violence, sexual assault, and/or stalking who requests an accommodation for the safety of the 
victim while at work. (The complaint must be filed within one year from the date of 
occurrence of the 
violation.) 
(8)   Labor Code section 230.1 
Protects an employee who is a victim of dome
stic violence, sexual assault, and/or stalking 
and works for an employer with 25 or more employees who takes time off to seek medical 
attention, to obtain services from a domestic violence program or psychological counseling, 
June 2017 2

or to participate in safety planning. (The complaint must be filed within one year from the 
date of occurrence of the violation.) 
(9)   Labor Code section 230.2(b) 
Requires 
an em
ployer to allow an employee who is a victim of a crime, an immediate family 
member of a victim, a registered domestic partner of a victim, or the child of a registered 
domestic partner of a victim to take time off from work to attend judicial proceedings related 
to that crime. (The complaint must be filed within one year from the date of occurrence of the 
violation.) 
(10)   Labor Code section 230.3 
Protects an employee 
who takes time off to perform emergency duty as a volunteer 
firefighter, a reserve peace officer, or an officer, employee, or member of a disaster medical 
response entity sponsored or requested by the State. An employee who is a health care 
provider must notify his or her employer at the time the employee becomes designated as 
emergency response personnel and when the employee is notified that he or she will be 
deployed as a member of a disaster medical response team. 
(11)  Labor Code section 230.4 
Protects an employee who is a volunteer firefighter
, a reserve peace officer, or emergency 
rescue personnel, and works for an employer employing 50 or more employees, from being 
discriminated or retaliated against because he or she has taken time off to engage in fire or 
law enforcement training. The employee is permitted to take up to an aggregate of 14 days 
per calendar year for such training. 
(12)   Labor Code section 230.5 
Protects an employee who is a victim of an offens
e listed under Labor Code section 230.5 for 
taking time off from work, to appear in court to be heard at any proceeding, including any 
delinquency proceeding, involving a post-arrest release decision, plea, sentencing, post-
conviction release decision, or any proceeding in which a right of the victim is at issue. A 
victim is any person who suffers direct or threatened physical, psychological, or financial 
harm as a result of the commission or attempted commission of a crime or delinquent act. 
The term “victim” also includes the person’s spouse, parent, child, sibling, or guardian. (The 
complaint must be filed within one year from the date of occurrence of the violation.) 
(13)  Labor Code section 230.7 and Education Code section 48900.1 
Protects an employee who is the parent or guardian of 
a pupil for taking time off from work 
to appear in the pupil’s school at the request of the pupil’s teacher, if the employee, prior to 
taking the time off, gives reasonable notice to the employer that he or she is requested to 
appear at the school. 
(14)   Labor Code section 230.8 
Protects an employee 
who is a parent (including stepparent, foster parent, or person who 
stands in loco parentis to the child), guardian, or grandparent, and who is employed by an 
employer who employs 25 or more employees, for taking time off from work (up to 40 hours 
each year, not exceeding eight hours in any calendar month) to participate in activities of the 
child’s school, for school emergencies, or to locate or enroll the child in school or with a 
child care provider. 
(15)   Labor Code sections 232(a) and (b) 
Prohibits an em
ployer from requiring an employee, as a condition of employment, to refrain 
from disclosing or discussing the amount of his or her wages or requiring an employee to 
June 2017 3

sign a waiver or other document that purports to deny the employee the right to disclose or 
discuss hi
s or her wages. 
(16)   Labor Code section 232.5 
Prohibits an em
ployer from requiring that an employee refrain from disclosing or discussing 
information about the employer’s working conditions, and from requiring an employee to 
sign a waiver or other document that restricts or denies the employee the right to disclose or 
discuss information about the employer’s working conditions. 
(17)   Labor Code section 233 and 234 
Prohibits retaliation for 
using or attempting to use sick leave that accrued during six months 
for a reason allowed under section 246.5. Section 234 provides that an employer’s “absence 
control” policies that punish sick leave taken pursuant to section 233 are a violation of 
section 233. 
(18)   Labor Code section 244 
Reporting or threatening 
to report an employee’s, former employee’s, or prospective 
employee’s citizenship or immigration status, or the suspected citizenship or immigration 
status of a family member of the employee, former employee, or prospective employee, to a 
federal, state, or local agency because the employee, former employee, or prospective 
employee exercises a right under the Labor Code, the Government Code, or the Civil Code 
constitutes an adverse action for purposes of establishing a violation of an employee’s, 
former employee’s, or prospective employee’s rights. Claims of immigration-related 
retaliation may be processed by the Labor Commissioner under this section, in conjunction 
with section 98.6, which prohibits retaliation against employees, former employees, and 
prospective employees for exercising their rights under the Labor Code. 
(19)   Labor Code sections 245-249 
Protects an employee who uses accrued paid sick leave, 
files a complaint with the Labor 
Commissioner claiming paid sick leave, alleges a violation of paid sick leave rights, 
cooperates in an investigation or prosecution under this statute, or opposes a policy or 
practice prohibited by this statute. Employers are prohibited from denying an employee the 
right to use paid sick leave, or discharging, threatening to discharge, demoting, suspending or 
in any manner discriminating against an employee who exercises these rights. There is a 
REBUTTABLE presumption of unlawful retaliation if the employer acts in a manner 
described above within 30 days of the employee’s request for leave or other protected 
activity. In addition to other remedies that might be available, an administrative penalty of up 
to $4,000 may be awarded. 
(20)   Labor Code section 432.7 
Protects the right 
of an applicant for employment not to disclose information concerning an 
arrest or detention that did not result in conviction, or any information regarding referral to, 
and participation in, any pretrial or post-trial diversion program. Protects the right of an 
applicant for employment not to disclose information about his or her criminal history that 
occurred while the applicant was subject to juvenile court law. Prohibits an employer from 
seeking or using as a factor in an employment decision, any record of an arrest or detention 
that did not result in a conviction. Provides exceptions for law enforcement employment, 
health facilities, concessionaires and other specific employment situations. 
(21)   Labor Code section 432.8 
Protects the rights 
of an applicant for employment or employee from disclosing information 
regarding a conviction related to the possession of marijuana where the conviction is more 
than two years old. 
June 2017 4

(22)   Labor Code section 432.9 
A state o
r local agency shall not ask an applicant for employment to disclose information 
concerning the conviction history of the applicant until the agency has determined the 
applicant meets the minimum qualifications for the position as stated in any notice for the 
position. 
(23)   Labor Code section 752 
Ensures that employees in non-unionized smelters
 or underground mines have a right to a fair 
and impartial election to establish a workday greater than eight hours. In addition to other 
remedies that might be available, a civil penalty of up to $200 for each violation for each 
affected employee may be awarded. 
(24)   Labor Code section 1019 
Prohibits certain unfair immigration-related practices 
in retaliation for engaging in activities 
protected by the Labor Code and local ordinances. Unfair immigration-related practices 
include: requesting more or different documen ts than are required by federal immigration 
laws; refusing to accept such documents when they reasonably appear on their face to be 
genuine; using the federal E-Verify system to check the employment authorization of a 
person at a time or in a manner not required under federal law; filing or threatening to file a 
false police report or a false report or complaint with any State or federal agency, including 
the Federal Immigration and Customs Enforcement Agency (“ICE”); or contacting or 
threatening to contact immigration authorities. Labor Code section 1019 creates a private 
right of action in court for victims of unfair immigration-related practices that are retaliatory. 
The Labor Commissioner will process such complaints under Labor Code section 98.6, 
which prohibits retaliation for engaging in rights protected under the Labor Code.  
(25)   Labor Code section 1019.1 
Makes it an 
unlawful practice for an employer to request more or different documents than 
those required by federal immigration law, refuse to honor documents that appear to be 
genuine, or attempt to reinvestigate or re-verify any incumbent employee’s authorization to 
work using an unfair immigration-related practice. In addition to other remedies that might 
be available, a penalty of up to $10,000 may be awarded for each violation. 
(26)   Labor Code section 1024.6 
An employer m
ay not discharge an employee or in any manner discriminate, retaliate, or take 
any adverse action against an employee because the employee updates or attempts to update 
his or her personal information based on a lawful change of name, social security number, or 
federal employment authorization document. 
(27)   Labor Code sections 1025-1028 
Every private employer regularly employing 25 or mo
re employees shall provide reasonable 
accommodations for an employee to participate in an alcohol or drug rehabilitation program. 
If the employee believes that he or she has been denied such reasonable accommodation, he 
or she may file a retaliation complaint with the Labor Commissioner’s office. 
(28)   Labor Code sections 1030-1033 
Prohibits retaliation against an employee who 
requests a lactation accommodation or who 
attempts to express breast milk. Every employee desiring to express breast milk for the 
employee’s infant child shall be provided a reasonable amount of break time to do so. The 
break time shall, if possible, run concurrently with any break time already provided to the 
employee. Break time for an employee that does not run concurrently with the rest time 
authorized for the employee by the applicable wage order of the Industrial Welfare 
Commission need not be paid. The employer shall make reasonable efforts to provide the 
June 2017 5

employee with the use of a room or other location, other than a toilet stall, in close proximity 
to the em
ployee’s work area, for the employee to express milk in private. The room or 
location may include the place where the employee normally works if it otherwise meets the 
requirements of this section. An employer is not required to provide an employee break time 
for purposes of lactating if to do so would seriously disrupt the operations of the employer. 
Retaliation for requesting or using this accommodation is prohibited and will be investigated 
under Labor Code section 98.6. In addition to other remedies that might be available, a civil 
penalty of up to $100 for each violation may be awarded. 
(29)   Labor Code section 1041-1044 
Every private em
ployer regularly employing 25 or more employees shall reasonably 
accommodate and assist any employee who reveals a problem of illiteracy and requests the 
employer’s assistance in enrolling in an adult literacy education program. An employee who 
believes she or he has been denied reasonable accommodation to enroll and participate in an 
adult literacy education program may file a retaliation complaint with the Labor 
Commissioner’s office. 
(30)   Labor Code section 1101 
Protects employees who engage or participate in 
politics or who become candidates for 
public office. An employer may not make, adopt, or enforce any rule, regulation or policy 
that forbids, controls, directs or tends to direct the political activities or affiliations of 
employees. 
(31)   Labor Code section 1102 
Prohibits an em
ployer from coercing, influencing or attempting to coerce or influence 
employees’ political action or political activity. 
(32)   Labor Code section 1102.5 
Protects against retaliation for disclosing information, or because an em
ployer believes an 
employee has disclosed information, to a government or law enforcement agency, to a person 
with authority over the employee, or to another employee who has the authority to 
investigate, discover, or correct a violation where employee reasonably believes that the 
information discloses a violation of a state or federal statute, or a violation of or 
noncompliance with a local, state, or federal rule or regulation. Protects an employee who 
refuses to participate in an activity that would result in a violation of a state or federal statute, 
or a violation of or noncompliance with a local, state, or federal rule or regulation. Protects 
an employee who exercised his or her rights under Labor Code section 1102.5 in any former 
employment. Protects an employee who is a family member of a person who has or is 
perceived to have engaged in any protected conduct. In addition to other remedies that might 
be available, a civil penalty of up to $10,000 may be awarded for each violation. 
(33)   Labor Code section 1171 
Protects individuals participating in a national service program (e.g., AmeriCorps), for 
refusing to work overtim
e for any legitimate reason. 
(34)   Labor Code section 1197.5 
Allows an employee 
who is paid at a wage rate less than the rate paid to an employee of the 
opposite sex, or another race or ethnicity for substantially similar work, when viewed as a 
composite of skill, effort, and responsibility, and which is performed under similar working 
conditions, except where the payment is made pursuant to a seniority system, a merit system, 
a system which measures earnings by quantity or quality of production, or a differential 
based on a bona fide factor other than sex, race, or ethnicity, to file a claim for unequal pay 
June 2017 6

with the Labor Commissioner’s office. A civil action to recover wages under section 
1197.5(a) may be commenced no later than two years after the cause of action occurs, except 
that a civil 
action arising out of a willful violation may be commenced no later than three 
years after the cause of action occurs. The same filing period will be used for a claim filed 
with the Labor 
Commissioner for equal pay as the filing period for a civil action. Also 
protects an employee who invokes or assists with the enforcement of the equal pay law, 
discloses his or her own wages, discusses the wages of others, inquires about another 
employee’s wages, or aids or encourages any other employee to exercise his or her rights 
under this section and is retaliated against. A complaint with the Labor Commissioner 
alleging retaliation must be filed within six (6) months of the adverse action. 
(35)   Labor Code section 1198.3 
Prohibits retaliation against an employee who refuses to work hours in excess of those 
permitted 
by the Industrial Welfare Commission (IWC) Orders. 
(36)   Labor Code section 1311.5 
Provides for triple damages for individuals who 
are retaliated against for having filed a claim 
or civil action alleging a Labor Code violation occurring while the individual was a minor, 
even if the claim was filed after the individual reached 18. Extends the time limit for claims 
under the Labor Code, including claims for unpaid wages and retaliation claims, such that the 
time limit does not begin to run until the individual turns 18. 
(37)   Labor Code section 1512 
Prohibits retaliation against an employee who exer
cises the right to take a paid leave of 
absence for the purpose of donating his or her organ or bone marrow to another person. 
(38)   Labor Code section 2814 
Makes it unlawful 
to use E-Verify to check the employment authorization status of an 
existing employee or applicant who has not been offered employment at a time or in a 
manner not required by federal law, authorized by a federal agency, or as a condition of 
receiving federal funds. An employer who has offered employment to an applicant can 
lawfully utilize the federal E-Verify system to check the employment authorization status of a 
person who has been offered employment. Requires that the employer furnish to the 
employee any no-match notification issued by the Social Security Administration or the 
United States Department of Homeland Security containing information specific to the 
employee’s E-Verify case. In addition to other remedies that might be available, each 
unlawful use of the E-Verify system carries a civil penalty not to exceed $10,000. 
(39)   Labor Code section 2929(b) and (c) 
Prohibits discrim
ination because the garnishment of an employee’s wages has been 
threatened, or because his or her wages have been subjected to garnishment for the payment 
of one judgment. The employee shall give notice to his or her employer of his or her 
intention to m
ake a wage claim within 30 days after being discharged, and file a wage claim 
with the Labor Commissioner within 60 days after being discharged. 
(40)   Labor Code section 2930 
Protects an employee who is disciplined or discharged based on a shopping investigator
’s 
report of the employee’s conduct, performance, or honesty when the employee was not 
provided with of copy of the report before the discipline or discharge. The shopping 
investigator must be licensed under the Business and Professions Code for this section to 
apply. 
June 2017 7

(41)   Labor Code section 6310 
Protects an employee 
who: (1) complains about safety or health conditions or practices, (2) 
institutes or causes to be instituted any proceeding relating to the employee’s rights to safe 
and healthful working conditions, or testifies in any such proceeding, (3) exercises any rights 
under the California Occupational Safety and Health Act, or (4) participates in an 
occupational health and safety committee established pursuant to Labor Code section 6401.7. 
Protects an employee who is a family member of a person who has or is perceived to have 
engaged in any protected conduct. 
(42)   Labor Code section 6311 
Protects an employee 
who refuses to perform work in the performance of which the Labor 
Code, any occupational safety or health standard, or any safety order would be violated 
where the violation would create a real and apparent hazard to the employee or her or his co-
workers. 
(43)   Labor Code section 6399.7 
Protects an employee who complains or testifies regarding non-compliance with the 
Hazardous Substances Information and Training Act. 
(44)   Labor Code section 6403.5 
Protects an employee who refuses to lift, 
reposition, or transfer a patient due to the health 
care worker’s concerns about patient or worker safety or because of the lack of trained lift 
team personnel or equipment. 
(45)   Health and Safety Code section 1596.881 and 1596.882 
Protects an employee 
who: (1) complains about the violation of any licensing or other laws 
relating to child day care facilities (e.g., staff-child ratios, transportation of children, or child 
abuse), (2) institutes or causes to be instituted any proceeding against the employer relating 
to the violation of any licensing or other laws, (3) appears as a witness or testifies in a 
proceeding relating to the violation of any licensing or other laws, or (4) refuses to perform 
work in violation of a licensing or other law or regulation after notifying the employer of the 
violation. A claim by the employee alleging the violation by the employer of section 
1596.881 shall be presented to the employer within 45 days after the action as to which 
complaint is ma
de, and presented to DLSE not later than 90 days after the action as to which 
complaint is made. 
(46)   Unemployment Insurance Code section 1237 
Protects an employee 
who seeks information from the Employment Development 
Department (EDD) concerning rights under the Unemployment Insurance Code or Labor 
Code, cooperates with any investigation undertaken by EDD, or testifies in any proceeding 
brought pursuant to the Unemployment Insurance Code or the Labor Code. 
(47)   IWC Orders 1 through 13, section 3(C)(8); IWC Order 16, section 3(C)(7); and IWC 
Order 17, section 5 “Election Procedur
es” (H) 
Protects an employee who expresses an opinion concerning an alternative workweek election 
or for opposing or supporting its adoption or repeal. 
Please note: Except for the Labor Commissioner’s enforcement of the California Equal Pay Act 
(Labor Code section 1197.5 noted above), the Departme
nt of Fair Employment and Housing (DFEH) 
maintains the authority to investigate complaints of discrimination (based on race, religion, sexual 
orientation, gender, national origin, etc.) in the areas of employment, housing, public 
accommodations and hate violence. The National Labor Relations Board (NLRB) investigates 
complaints of unfair labor practices by employers and unions. 
June 2017 8

Retrieval chunks

• #1

  STATE OF CALIFORNIA Gavin Newsom, Governor DEPARTMENT OF INDUSTRIAL RELATIONS Labor Commissioner’s Office 2031 Howe Avenue, Suite 100 Sacramento, CA 95825 Phone: 916-263-2991 Email: [email protected] FILING A RETALIATION COMPLAINT Who may file? Any employee or applicant for employment who believes he or …

• #2

  or discharge from employment because the employee engaged in lawful conduct asserting “recognized constitutional rights” occurring during nonworking hours away from the employer’s premises. (2) Labor Code section 98.6 Protects an employee filing or threatening to file a claim or complaint with the Labor Commis…

• #3

  has actual knowledge of the status. (The complaint must be filed within one year from the date of occurrence of the violation.) (7) Labor Code section 230(f) An employer of any size shall provide reasonable accommodations for a victim of domestic violence, sexual assault, and/or stalking who requests an accomm…

• #4

  taking time off from work, to appear in court to be heard at any proceeding, including any delinquency proceeding, involving a post-arrest release decision, plea, sentencing, post- conviction release decision, or any proceeding in which a right of the victim is at issue. A victim is any person who suffers direct or…

• #5

  control” policies that punish sick leave taken pursuant to section 233 are a violation of section 233. (18) Labor Code section 244 Reporting or threatening to report an employee’s, former employee’s, or prospective employee’s citizenship or immigration status, or the suspected citizenship or immigration status…

• #6

  that did not result in a conviction. Provides exceptions for law enforcement employment, health facilities, concessionaires and other specific employment situations. (21) Labor Code section 432.8 Protects the rights of an applicant for employment or employee from disclosing information regarding a conviction re…

• #7

  genuine, or attempt to reinvestigate or re-verify any incumbent employee’s authorization to work using an unfair immigration-related practice. In addition to other remedies that might be available, a penalty of up to $10,000 may be awarded for each violation. (26) Labor Code section 1024.6 An employer m ay not …

• #8

  ployer regularly employing 25 or more employees shall reasonably accommodate and assist any employee who reveals a problem of illiteracy and requests the employer’s assistance in enrolling in an adult literacy education program. An employee who believes she or he has been denied reasonable accommodation to enroll a…

• #9

  composite of skill, effort, and responsibility, and which is performed under similar working conditions, except where the payment is made pursuant to a seniority system, a merit system, a system which measures earnings by quantity or quality of production, or a differential based on a bona fide factor other than se…

• #10

  receiving federal funds. An employer who has offered employment to an applicant can lawfully utilize the federal E-Verify system to check the employment authorization status of a person who has been offered employment. Requires that the employer furnish to the employee any no-match notification issued by the Social…

• #11

  Protects an employee who complains or testifies regarding non-compliance with the Hazardous Substances Information and Training Act. (44) Labor Code section 6403.5 Protects an employee who refuses to lift, reposition, or transfer a patient due to the health care worker’s concerns about patient or worker safety …

• #12

  complaints of unfair labor practices by employers and unions. June 2017 8