EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – Parity Agreements

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While the Board has recognized that an employer has a legitimate interest in maintaining parity or equity across its bargaining units, it has never held that parity is required. To the contrary, an employer comes perilously close to bad faith when it insists that it will not under any circumstances agree to different terms for different employee groups.