CASE PROCESSING PROCEDURES; COMPLAINT – Issuance of Complaint

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A complaint alleging surface bargaining typically states that, by the totality of its conduct, including but not limited to the conduct described in the complaint, the respondent failed and refused to meet and confer in good faith. In contrast, a complaint alleging a unilateral change—a per se violation—typically states that the respondent changed policy without affording the exclusive representative prior notice or an opportunity to meet and confer over the change or its effects. (p. 12.)