All members of a campus community deserve a healthy academic work environment where each member is valued, treated with dignity and respect, and encouraged to engage in lively debate, spirited discussion, and meaningful discourse free from discrimination, harassment, and intimidation. Healthy workplaces generate heightened levels of employee satisfaction, engagement, and morale. The American Psychological Association (APA, 2015) defines psychologically healthy workplaces according to five major categories, including employee involvement; work–life balance; employee growth and development; health and safety; and employee recognition. According to the APA, psychologically healthy work-places benefit from improved work quality and productivity, lower absenteeism, employee engagement, less turnover, and better customer service ratings.
Similarly, The Chronicle of Higher Education (2016) recognizes colleges and universities for workplace excellence in 12 categories, including collaborative governance; compensation and benefits; confidence in senior leadership; diversity; facilities, workspace, and security; job satisfaction; professional/career development; respect and appreciation; supervisor or department chair relationship; teaching environment; tenure clarity in process; and work–life balance. Each year, these criteria are used to identify colleges and universities determined by faculty, staff, and college administrators to be great places to work.
In 2006, the National League for Nursing (NLN, 2006) developed the Healthful Work Environment Tool Kit to provide a measurement for academic workplace assessment and a platform for discussion of how nursing faculty and administrators can work together to build healthy academic nursing workplaces. The tool kit included nine elements that constitute a healthy academic work environment, including salaries; benefits; workload; collegial environment; role preparation and professional development; scholarship; institutional support; marketing and recognition; and leadership. Clark (2017) suggested three additional elements, including establishing and committing to a shared vision, mission, values, and norms; engaging in effective communication and constructive conflict negotiation; and fostering individual, team, and organizational civility.
Although there are multiple dimensions to the establishment and sustainment of healthy work environments, this article focuses on the construct of civility that corresponds with the APA category of employee recognition; The Chronicle of Higher Education category of respect and appreciation; and the NLN category of collegial environment. The purpose of this article is threefold: (a) to discuss the importance of civility in the workplace; (b) to provide a legal framework for policy development; and (c) to present an exemplar policy to promote civility in the workplace and a guide to address work-place incivility.
Civility in the workplace involves expressing respect for others while honoring differences and treating one another with dignity and respect (Emry & Holmes, 2005; Guinness, 2008), which requires time, presence, engagement, and intention to seek common ground (Clark & Carnosso, 2008). Put more succinctly, Maxey (2011) defined civility as “those actions and behaviors that support the dignity of another” (p. 36). Some reasons for the perceived rise of incivility in higher education include doing more with less, economic uncertainty, increase in technology and online learning modalities, student and faculty diversity, unmanageable or unreasonable workloads, power and structural imbalances, and juggling competing demands related to work, family, and life responsibilities (Cipriano, 2011; Clark, 2013; Clark, Olender, Kenski, & Cardoni, 2013). It is important to note that being civil and collegial does not mean that we all agree, nor does it “imply mindless conformity or absence of dissent. Rather, operationalizing collegiality [civility] as either a noun or adjective enhances productive dissent, a basic tenet of the academy” (Cipriano, 2011, p. 15).
Because all members of the campus community have a responsibility to foster social discourse, questioning, and critical argument, each must commit to creating safe spaces for the free expression of diverse and differing points of view, opinions, and beliefs. This requires taking action not only to promote civility but to address incidents of incivility—defined by Clark (2017) as the display of a range of rude or disrespectful behaviors, failing to take action when action is warranted, or both. These behaviors and inactions may result in psychological or physiological distress for the people involved and, if left un-addressed, may worsen or progress into threatening situations. Acts of incivility in the academic workplace can take various forms, including actions that we do, such as using profanity and vulgar language, making demeaning or disparaging remarks, or engaging in threatening or intimidating behavior. Incivility also includes actions that we do not do, such as failing to share important information, refusing to assist a colleague or participate in the work of the department, or excluding and marginalizing others. These behaviors, especially when prolonged over time, can have lasting and harmful effects on individuals, teams, and the academic workplace.
The Impact of Workplace Incivility
The impact of workplace incivility can be grave. Studies reveal (Pearson & Porath, 2009; Porath & Pearson, 2013) that workers on the receiving end of incivility reported a decrease in work effort, time spent working, and quality of work; time lost worrying about uncivil encounters; decline in performance and commitment to the organization; and taking frustration out on others. According to the Workplace Bullying Institute (2017), being the target of workplace bullying may also affect life outside the work setting, such as becoming physically ill leading up to the start of the work week; obsessing about work while at home or on vacation; suffering from physical and mental health problems; days off spent exhausted and lifeless; and favorite activities are no longer enjoyable. In some cases, employees do not report incidents of incivility and many leave the workplace without informing supervisors of their true reason for leaving. As a result, turnover costs accumulate quickly, and when compounded by direct and indirect costs of managing incivility, together they create a significant financial burden (Porath, 2016). Given the negative consequences and high costs of workplace incivility, it is imperative for academic institutions to develop, implement, and broadly disseminate polices to foster civility that support a healthy academic work environment.
Need for Policy Development and Implementation
Policy development must ensure strict confidentiality because employees are often reluctant to report acts of incivility due to worry over losing their job, fear of retaliation, and an overall lack of information and clarity about how to address the problem (Longo, 2010). In some cases, incivility has gone unaddressed for so long that these behaviors have become in-grained into the culture of an organization, and some employees believe that nothing can be done to effectively address the problem (Longo, 2010). Therefore, policy development and implementation are critical to the health of academic workplaces. To be effective, policies should be specific, extend beyond simply defining uncivil behavior, and include a clear plan for addressing incivility. Policies must ensure fairness, consistency, and confidentiality, and include an incremental disciplinary approach when applicable—except in cases of egregious misconduct. In addition, the policies must be comprehensive, be easily accessible, and include specific step-by-step procedures (Clark, 2017).
Current Protective Laws Fall Short
Common law and statutory remedies generally fail to address bullying situations in the workplace. Conduct disparate from sexual harassment or other forms of protected-class discrimination normally fail to rise to the level of actionable liability, such as intentional infliction of emotional distress (IIED). The tort of IIED has four elements: (a) the defendant must act intentionally or recklessly; (b) the defendant's conduct must be extreme and outrageous; and (c) the conduct must be the cause (d) of severe emotional distress (“Intentional infliction of emotional distress,” n.d.). In addition, in many states, workers' compensation statutes preempt claims for intentional infliction of emotional distress and other violations of laws that may result from bullying situations. As such, employees who are subject to abusive conduct would highly benefit from internal policies that proscribe procedures for reporting those who partake in such activities, as well as penalties to provide redress for the harm inflicted on them.
For example, in one western state, workers' compensation laws cover injuries “caused by an accident arising out of and in the course of any employment covered by the worker's compensation law” (Worker's Compensation and Related Laws, 2016). Accident means an unexpected, undesigned, and un-looked-for mishap, or untoward event, connected with the industry in which it occurs, and which can be reasonably located as to time when and place where it occurred, causing an injury (Worker's Compensation and Related Laws, 2016). Injury and personal injury include only an injury caused by an accident that results in violence to the physical structure of the body. These terms do not include an occupational disease (i.e., any chronic ailment that occurs as a result of work) and only include nonoccupational diseases that result directly from an injury (Worker's Compensation and Related Laws, 2016).
Emotional distress, such as the type of distress caused by workplace bullying, can be triggered by repetitive occurrences in the office, especially uncivil and intimidating incidents. When repeated incidents or the nature of the job cause emotional distress, a distinct accident has not occurred. “Instead, workers' compensation preemption will depend on whether the workplace experience constitutes a compensable occupational disease. The legal standard is whether the mental illness or injury was due to stresses or conditions different from those borne by the general public” (Pitillo v. NC Department of Environmental Health & Natural Resources, as cited in Copeley, 2015, p. 3).
Further, some states have rejected coverage of all psychological injuries when they lack a physical cause—so called mental-mental injuries; an injury or disease is not compensable if it was “solely caused by nonphysical means” and “did not result in any physical injury or disease” (Workers' Compensation W. Va. Code, as cited in Copeley, 2015, p. 4). Similarly, one eastern state's workers' compensation law excludes from the definition of personal injury a mention of emotional impairment “unless such impairment arises from a physical injury or occupational disease” (Bennett v. Beiersdorf, Inc., as cited in Copeley, 2015, p. 4).
Actions based on workplace abuse will also avoid workers' compensation preemption if they are brought as intentional torts, such as IIED (Pleasant v. Johnson, as cited in Copeley, 2015, p. 4; i.e., intentional injuries are not preempted). Hogan v. Forsyth Country Club Co. (as cited in Copeley, 2015, p. 4) held that IIED claims are not preempted because the “essence of [IIED] is non-physical; the injuries alleged by plaintiffs do not involve physical injuries resulting in disability.”
Nonetheless, claims for intentional infliction of emotional distress have not been very successful when they are not related to claims for sexual harassment: “it is extremely rare to find conduct in the employment context that will rise to the level of outrageousness necessary to support a claim” of IIED (Thomas v. N. Telecom, Inc., as cited in Copeley, 2015, p. 4). Further, the Hogan v. Forsyth Country Club Co. court found conduct “not sufficiently outrageous where supervisors screamed and shouted at a plaintiff, called her names, interfered with her supervision of others, and refused to grant a plaintiff pregnancy leave.” Based on these cases and observations, clearly there is a need for policies and legal remedies that address workplace incivility, bullying, and harassment, without regard to protected class status.
Current Efforts for Redress: The Healthy Workplace Bill
In the early 2000s, Suffolk University Professor of Law David Yamada drafted the text of the Healthy Workplace Bill (HWB). The HWB has been presented in more than half of the United States, with more than 100 versions, and has been sponsored by more than 400 legislators. Although there have been partial victories in Utah, California, and Tennessee, no state has yet to pass the full version of the HWB that holds employers accountable for fostering an abusive work environment (Workplace Bullying Institute, 2014b).
According to the HWB (Workplace Bullying Institute, 2017), workplace bullying is defined as the “repeated, health-harming mistreatment of one or more persons (the targets) by one or more perpetrators: abusive conduct that takes one or more of the following forms: verbal abuse, or threatening, intimidating or humiliating behaviors (including nonverbal), or work interference—sabotage—which prevents work from getting done, or some combination of one or more” (para. 1). In a 2014 national survey, 27% of Americans have suffered abusive conduct at work, another 21% have witnessed it, and 72% are aware that workplace bullying happens (Workplace Bullying Institute, 2014a).
The HWB provides benefits to both employers and employees. For the former, the bill specifically defines an abusive work environment (which is a high standard for misconduct); requires proof of health harm by licensed health or mental health professionals; protects conscientious employers from vicarious liability risk when internal correction and prevention mechanisms are in effect; gives employers the reason to terminate or sanction offenders; requires plaintiffs to use private attorneys; and plugs the gaps in current state and federal civil rights protections (Workplace Bullying Institute, n.d.). For harmed employees, the HWB holds the employer accountable; allows an employee to sue the perpetrator as an individual; provides an avenue for legal remedies for health-harming cruelty at work; allows for restoration of lost wages and benefits; and compels employers to prevent and correct future instances (Workplace Bullying Institute, n.d.).
The HWB provides a framework for an internal policy and process to promote a healthy academic work environment. For a detailed description of the HWB, see Massachusetts Senate Bill 1013 petitioning for “An Act addressing work-place bullying, mobbing, and harassment, without regard to protected class status” that may be modified and translated to our proposed policy (S.B. 1013, 190th Gen. Court, Reg. Sess. [Mass. 2017]). Although the HWB text does set forth the need for such a law or policy, provide helpful definitions to be utilized, and indicate when actors are liable, it does not address the mechanics such as the need for confidentiality or a reward system. However, some states (California and Utah) have mandated training in abusive conduct, and Utah has implemented a complaint and investigative procedure that serves as a helpful example for policy development (Utah Admin. Code r. 477-16). A brief description of the state of Utah complaint procedure is outlined in the next section and provides a framework for the policy exemplar described later in this article.
Utah Complaint Procedure
Management shall permit employees who allege abusive conduct to file complaints and engage in a review process free from bias, collusion, intimidation, or retaliation.
Employees who feel they are being subjected to abusive conduct should do the following:
document the occurrence;
continue to report to work; and
identify a witness(es), if applicable.
An employee shall file a written complaint of abusive conduct with their immediate supervisor, any other supervisor in their direct chain of command, or the Department of Human Resource Management (DHRM), including the agency human resource field office.
Complaints may be submitted by any employee, witness, volunteer or other individual.
Any supervisor who has knowledge of abusive conduct shall take immediate, appropriate action in consultation with DHRM and document the action.
When warranted, investigations shall be conducted based on DHRM standards and business practices.
Results of investigation
If an investigation finds the allegations of abusive conduct to be sustained, agency management shall take appropriate administrative action.
If an investigation reveals evidence of criminal conduct in abusive conduct allegations, the agency head or Executive Director, DHRM, may refer the matter to the appropriate law enforcement agency.
At the conclusion of the investigation, the appropriate parties shall be notified.
Participants in any abusive conduct investigation shall treat all information pertaining to the case as confidential.
Based on current research and the clear need to develop and implement a healthy workplace policy and procedure, an exemplar is offered by the authors.
Exemplar Policy Purpose. To (1) provide a formal process for fostering a civil, productive work environment, (2) outline a fair, consistent, confidential procedure for defining and addressing workplace incivility, including behaviors that pose a threat to the safety and/or well-being of self, others, or the academic environment, (3) provide a mechanism for reporting and subsequent investigation of uncivil acts if indicated), and (4) reward civility and respectful workplace behavior. This exemplar policy establishes the academic institution's commitment to the sustainment of a civil workplace and applies to all members of the campus community.
Exemplar Policy Statement. This academic institution is committed to fostering and sustaining a civil, respectful work environment free from uncivil, harmful, abusive, or threatening behaviors. The institution strives to provide an atmosphere of collegiality, transparency, collaboration, and safety—a campus community whereby all members are treated with dignity and respect. Consequently, all reports of uncivil, harmful, and/or abusive behaviors occurring in the workplace will be addressed, investigated, and followed through to resolution. Anyone filing legitimate complaints will not be reprimanded or admonished for reporting uncivil, harmful, and/or intimidating behaviors.
Commitment to Civility and a Healthy Work Environment. The academic institution is dedicated to creating and maintaining a civil, healthy work environment that supports respectful behavior and interactions, openness to opposing points of view, and an unequivocal commitment to inclusion and diversity. As a member of the campus community, each individual pledges to abide by the institutional vision, mission, shared values, and corresponding norms of desired behavior. Members further vow to communicate and interact with civility, professionalism, and respect. When disagreement occurs, differences will be restricted to the issue itself while continuing to respect the individual with whom we disagree. Each member of the institution is responsible and accountable for conducting themselves in a professional manner and treating others with dignity, respect and fairness regardless of their position or span of authority. Any form of uncivil, harmful, and/or abusive behaviors is prohibited and will be fully and swiftly addressed according to the procedures outlined in the healthy work environment policy.
Statement of Shared Values. Shared values include the following:
- Professionalism and academic citizenship.
- Inclusion and respect for diversity.
- Integrity and accountability.
- Respect and civility.
- Social justice.
- Collegiality and collaboration.
Statement on Uncivil, Harmful, and Abusive Behaviors. Uncivil, harmful, and abusive behavior is described as a style of interaction with any individual that interferes with work performance; causes distress; affects morale; negatively impacts working relationships; undermines a safe and productive work-place; and/or creates a hostile work environment.
Examples of Uncivil, Harmful, and Abusive Behaviors. The following are considered by the authors to represent uncivil behaviors:
- Using profane, disrespectful, or threatening language or other forms of verbal abuse.
- Making demeaning or degrading remarks, such as name-calling, insults, abusive comments.
- Harshly criticizing others in the presence of others or making comments that negatively affect work performance.
- Engaging in intimidating behavior that suppresses input and diminishes psychological safety, such as withholding important information, refusing to answer questions, or failing to assist when needed.
- Making unreasonable or unfavorable work assignments on a routine basis.
- Retaliating against an individual who has reported an instance of incivility or abusive behavior.
- Abusing position or authority (berating or talking down to others).
- Purposefully excluding individuals from work-related meetings when they ought to be invited.
- Excluding, marginalizing, using the silent treatment or shunning others.
- Making personal attacks or threatening comments (verbal, e-mail, telephone, online).
- Setting a coworker up to fail.
- Withholding important information to perform a work assignment.
- Making racial, ethnic, sexual, gender, or religious slurs.
- Circulating private e-mails, without knowledge or permission.
- Making rude nonverbal behaviors or gestures (eye-rolling, arm-crossing, finger-pointing).
- Taking credit for work or contributions of others.
- Gossiping or spreading rumors.
Examples of Desired Behaviors (Management Responsibility). Leaders and other key personnel have a unique responsibility to model and ensure a healthy work environment where appropriate behaviors are consistently exhibited by everyone and where reports of uncivil, harmful, or abusive behaviors are swiftly and fairly addressed. Leaders and managers are expected to:
- Model civility and respectful interactions with all members of the campus community.
- Provide ongoing, multifaceted civility training.
- Be accountable and take responsibility for actions.
- Practice prevention strategies to promote civility.
- Celebrate and reward civil encounters and initiatives.
- Implement policies for reporting and addressing incivility.
- Take reports of uncivil behavior seriously and implement policies.
- Be observant for signs of incivility and prevent low risk uncivil behaviors from worsening.
- Maintain confidentiality when seeking to resolve incivility reports.
- Develop and implement a performance improvement plan, if indicated.
- Provide resources and issue sanctions for the offender, if indicated.
- Ensure that an individual filing a report is not victimized or admonished for doing so.
- Monitor and follow up regarding the situation, and evaluate the effectiveness of the process.
Examples of Desired Behaviors (Employee Responsibility). Employees are expected to:
- Model civility and respectful interactions with all members of the campus community.
- Participate in and encourage ongoing, multifaceted civility training.
- Be accountable and take responsibility for actions.
- Practice prevention strategies to promote civility.
- Recognize and report acts of civility.
- Celebrate and reward civil encounters and initiatives.
- Address and/or report uncivil (and civil) behaviors using organizational policies and procedures.
- Participate in the reporting and follow-up process as indicated.
Exemplar Policy Procedure. Clearly written, comprehensive, easily accessible, and specific step-by-step procedures are needed to proactively promote a healthy work environment and to reinforce that uncivil, harmful, or abusive behaviors will not be tolerated by the institution. All individuals (regardless of position or authority) who have knowledge of uncivil, harmful, or abusive behaviors are encouraged to immediately report the behavior to a member of the management team or to a Human Resources representative.
Reporting. All members and visitors of the organization who witness uncivil, harmful, or abusive behaviors are encouraged to complete a report. The completed form is reviewed by a neutral third party and examined for validity and follow-up. The individual identified in the report will be given an opportunity to address and respond to the complaint. A SMART policy will be used as a framework to report and address incivility, to reward civility, and to evaluate progress (Clark, 2017):
- System for confidential reporting.
- Managing report information.
- Addressing incivility.
- Rewarding civility.
- Tracking and evaluating progress.
System for Confidential Reporting. All employees have an obligation to report any alleged uncivil, harmful, or abusive behaviors and should report these allegations to their immediate supervisor, another member of the management team, or a Human Resources representative. Reports are filed using a confidential, web-based reporting system by which members of the academic workplace can report incidents of incivility. This reporting system ensures confidentiality and may be accessed from anywhere, including home or a private network. The reporting form should include relative contact information for follow-up purposes only and should not be released to any parties. Specific fields include time, date, and location of occurrence; description of the incident; impact of the uncivil, harmful, or abusive behaviors; the reporter's perception of and response to the issues; and suggestions for follow-up. The storage and retrieval structures must also be secure and confidential. If the alleged behavior is particularly egregious or violent, it must be reported immediately to the security department, with a follow-up report to the immediate supervisor. In the event of immediate threat or danger, employees and others are instructed to call 911.
Managing Report Information. Issues and complaints concerning alleged uncivil, harmful, or abusive behaviors will be held in confidence and with as limited disclosure to the extent necessary to conduct a thorough investigation. If the alleged complaint involves an employee, the investigation will be conducted by the Human Resources department; if the alleged complaint is against a nonemployee, a member of the management team will evaluate the merit of the alleged complaint to determine the appropriate action. The individual named in the report will be notified in writing that an allegation has been made, assured of the presumption of innocence at this juncture, and given an opportunity to meet with the individual filing the report and member(s) of the neutral party or parties to address and resolve the problem. The intent is to resolve the alleged problem at the local level if possible and to find an interest-based resolution, with clear expectations, and a mutual agreement on who is going to do what by when. The investigation process includes reviewing the incivility report, meeting with all involved parties—reporter and alleged offender—and seeking resolution in a fair and timely manner. If one or more of the parties decline to meet, the report will be forwarded to and investigated by a supervisor (or designee such as a Human Resources representative). If the report is found to be valid, a supervisor or Human Resources representative will continue the investigative process and impose necessary remedies or sanctions.
Addressing Incivility. The objective of the investigation is to determine the merits of the report by interviewing the individual identified in the report, the reporter, witnesses, and any other relevant parties. All interviews are documented in writing to maintain clarity throughout the investigation. The identity of the investigator and other relevant parties should remain confidential because the goal is to conduct a fair and impartial investigation. If the report is validated, the first violation of the Healthy Work Environment Policy will result in the employee receiving a verbal warning, with no written documentation placed in the employee file. If a subsequent infraction occurs, the Human Resources director will conduct another thorough, fair, and confidential investigation. If the report is substantiated, the Human Resources director or supervisor will initiate a performance improvement plan, which includes education regarding the financial, human, and organizational costs that result from incivility, specific behavioral requirements (e.g., conflict negotiation or stress management classes), and associated time frames for compliance. After the investigation process is completed, a full report (including recommendations) is submitted to the individual's supervisor, who will follow up and implement actions. A plan for a follow-up meeting to evaluate progress on efforts to resolve the issue will be established.
If the individual makes minimal or no improvement or repetitive incidents are reported against that individual, disciplinary actions such as suspension, temporary leave, or termination may be warranted. The individual named in the report will be given an opportunity to respond in writing and allowed to appeal the decision. Appeals should include a detailed written outline of the reason for the appeal and should be submitted to and heard by another party that did not participate in the initial report or investigation. If the report is upheld, the supervisor will follow through with appropriate actions.
Rewarding Civility. It is important to develop and implement a confidential reporting system similar to one that involves alleged acts of uncivil, harmful, or abusive behaviors to collect reports of civility and benevolence occurring in the academic workplace. Like the uncivil, harmful, or abusive behaviors report, the civility report can be accessible online from home or from a private network. Specific fields include time, date, description of the civil or benevolent act, the reporter's perception of and response to the behavior, and suggestions for follow-up. These data are valuable in determining the success of the Healthy Work Environment Policy and used to dispense a civility reward (selected from a wish list of rewards and incentives) that the individual desires and holds in high regard.
Tracking and Evaluating Progress. The Human Resources department (or designee) will institute a method to evaluate the SMART policy, monitor progress, and use evaluation data to modify or improve processes to reach the desired results. Thus, the department needs to keep a record of each action or strategy to evaluate processes and to generate a formal report (or reports) to communicate progress on the SMART policy. The reports will be disseminated in aggregate to key members throughout the institution.
Discussion and Conclusion
Incivility in academic workplaces can have detrimental effects on individuals, teams, departments, and the campus community at large. On the other hand, healthy academic work-places generate heightened levels of employee satisfaction, engagement, and morale. Therefore, implementing comprehensive, confidential, and legally defensible policies related to workplace civility is critical to fostering and sustaining healthy academic work environments. To be effective, policies must include specific step-by-step procedures, an incremental disciplinary approach when applicable, and a reward system for policy adherence.
To further accomplish this goal, the authors recommend the inclusion of civility and collegiality as essential domains within annual employee performance evaluations. This action may require changes at the institutional level to revise faculty evaluations to include interpersonal effectiveness criteria beyond the traditional triumvirate of teaching, scholarship, and service. A faculty member may be proficient or even excel in all three areas, yet fail to get along with colleagues and add value to the department and campus culture overall. Including civility criteria in faculty evaluations and expanding them to include a 360-degree process may be a sensitive matter, but it may also help to create a more functional campus community (Clark et al., 2013). Although the American Association of University Professors (2016) discouraged creating a separate category for collegiality, it does not deny that collegiality, collaboration, and constructive cooperation are important aspects of a faculty member's overall performance. They suggest that instead of isolating collegiality as a separate criterion for faculty evaluation, institutions of higher education should focus on developing clear definitions of teaching, scholarship, and service in which collegiality is reflected. In any case, collegiality and civility are closely related, and leaders are challenged to consider effective ways to evaluate both.
The information set forth in this document is for informational purposes only and not for the purpose of providing legal advice. Contact an attorney to obtain advice with respect to any particular issue or problem. Use of this document or any of the citations does not create an attorney–client relationship between the authors and the reader. The opinions expressed throughout this document are the opinions of the individual authors. The information contained in the policy exemplar that follows is not fully inclusive, exclusive, or exhaustive of all reasonable methods or approaches, nor does it address the unique circumstances of each situation.
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