"I don't get it! If I tell an employee how well he did a certain work task, did I not just praise the employee?" No, what you did was praise the work done by the employee.
"What's the difference?"
When you praise an employee and not the work you are communicating to the employee that you value him or her as a person, instead of saying that you value a particular skill he or she possesses or the amount of hard work it took to get a certain job done. For example, Debbie is a salesperson who just signed up a new customer for your company. Now you have a choice, you can either tell Debbie that she is a great and terrific person, or you can tell Debbie that you appreciate all the hard work she did in order to sign-up the new customer.
"I still don't get it!"
When you praise Debbie as a person, you tell Debbie that she is a great person in all aspects of her work. She is great in sales, she is great at how she gets along with coworkers, and she is great in how she completes all the detailed paperwork that you require etc...etc... However, when you praise the work Debbie just did to secure a new customer, you praise Debbie on only one of her job duties, i.e., sales.
"Okay, I get the difference, but what's the big deal?"
A supervisor's job duties include being able to motivate and discipline employees. Overall, it is much easier to motivate an employee than to successfully discipline an employee. For instance, lets go back to the example of Debbie. In reality Debbie is really a mediocre salesperson who not only has poor sales numbers each month, but also comes to work late and tends to take long lunch breaks. Debbie's coworkers constantly complain about her lateness and are starting to wonder if you are favoring her over them. You see potential in Debbie to become a successful salesperson, but you know that unless she disciplines herself more she will only become a company liability.
What do you think will be easier? To talk with Debbie about her performance problems after you just indicated that she is a great and terrific person or after you just praised her work in obtaining a new customer. Not sure? Let's review the two options you could take with Debbie.
Option #1
As Debbie's supervisor, you told Debbie that she was a great and terrific person on Monday, and on Thursday you tell her that she must start to take shorter lunch breaks and come to work on time. Now what do you think Debbie's reaction will be? Most likely she will be completely dismayed and confounded about why you told her on Monday that she was terrific, and in a matter of few days, she is now a terrible person for coming to work late and taking too long at lunch. "Don't great and terrific employees get a few perks," says Debbie? Debbie is also likely to think that you are just another crazy boss from hell. After your unsuccessful discussion with Debbie, she becomes unmotivated, does not bring in another new customer for weeks, and calls in sick three days in a row. Eventually, she takes a job with another company after she has used up all her sick leave and vacation time.
Option #2
As Debbie's supervisor, you told Debbie on Monday that you saw how her persistence and sales skills successfully created a new customer for the company. On Thursday, you tell Debbie that even though she demonstrated high quality skills on Monday, she still has much to learn about how to use those skills consistently to bring up her sales numbers. You inform her that on Monday you saw the salesperson that she has the potential to become. Next, you tell Debbie that in order for her to develop her potential, she will need to make it to work on time and also to take the same amount of time on her lunch breaks as her coworkers. You tell Debbie that a successful employee not only has good sales numbers, but a successful employee is also a good team player. Lastly, you indicate that you are only giving a verbal warning at this time, and hope that she can use the same skills that allowed her to bring in a new customer account, to help herself come to work and return from lunch on time. Debbie accepts your statements and decides that she will work harder to come to work on time, take shorter lunch breaks, and improve her sales numbers.
In sum, it is best to praise an employee for either their hard work or a particular skill that led to a successful work outcome. Praising the employee for hard work or a particular skill, allows you to later discipline or point out areas of needed improvement without having the employee think you dislike them, as happens when you praise the person.
Happy Working,
Gary Vikesland, MA LP CEAP
Employer-Employee.com
Monday, August 6, 2007
Team-Building in Secret
Corporations have been going about building teamwork in some of the strangest ways known to employer and employee. It all began when corporations started having employees hang from ropes, next came having employees shoot each other with paintballs, and now some corporations are trying to build teamwork by having employees participate in inflatable-sumo-wrestling. What will the future hold? Will corporations be asking their employees to swim with dolphins to build teamwork, or perhaps group parachuting will be the key to transforming your squabbling employees into a winning team.Conduct a search on the Internet, and you will quickly realize just how ridiculous team-building exercises are becoming for both employers and employees. Therefore, if I may take a moment to speak on your employees' behalf: "PLEASE…PLEASE…do not make your employees participate in human foosball, comedy karaoke, or sing in a music video with the company CEO in order to build teamwork." Now, if I may take a moment to speak to the HR manager(s) in the company. "Team sailing, employee Olympics, and having all your employees ride around on All-Terrain Vehicles may be fun, but ask yourself this question: does a fun team sport really add up to more teamwork back in the office?"If comedy karaoke and human foosball will not develop your employees into a well-oiled self-directed team, what will? It's simple, if you want to build employee teamwork, do it in the office and do not tell your employees you're doing it. Why keep it a secret? It is important to keep any teamwork activities that you do a secret for three reasons.First, employees are human, well most of them anyway, and humans are social animals that gravitate to work in groups versus individually if given the opportunity. Therefore, employees are already naturally geared to work in teams (groups), and making them swing from ropes will not add any more "group behavior" to their genetic makeup.Secondly, since employees are already geared to work in teams, your primary goal is to integrate teamwork practices into everyday work patterns. It is up to the leaders within the organization to integrate teamwork practices, not the employees.Lastly, if you announce that the company plans to build teamwork, most employees will respond by asking when the team building practices will be over, so they can get back to work. By announcing your team-building efforts, you will not create additional motivation in your employees to suddenly get them to develop team cohesion.Steps to Team-Building in the Office:1.) Define your teams. Most large organizations will have one main team with numerous sub teams. A sub team may be composed of just one employee and employees may be on several different sub teams.2.) Setup a meeting and ask each sub team to define their goals, and what would be helpful for them to have from the other sub teams within the department. You will need to prepare your employee for this meeting by letting them know ahead of time what they will be asked, so they can prepare proper responses. End the meeting after all participants have reported to each other their goals and needs. Do not mention the words teamwork or team building.3.) In future meetings, ask employees to report what assistance they are receiving from other sub teams. Focus only on the positives, and applaud those sub teams that have assisted other sub teams. It may take a few meetings for employees to pick-up on the trend of asking how other sub teams are assisting, so don't give up if your employees are slow to report. Remember, be mindful not to mention the words teamwork or team-building.4.) Incorporate sub team assistance as a performance review item during employees' performance reviews. Be direct by asking employees to report how they have assisted other sub teams while they met their own goals.These are the basic skills necessary to build teamwork within your organization's various sub teams. Remember that your employees are already geared to operate in groups; all you need to do is integrate teamwork practices into your organization's operations. Hence, please cancel the inflatable-sumo-wrestling team-building exercise you have planned for next week.Happy Working,Gary Vikesland, MA LP CEAP
Saturday, July 28, 2007
Make sure your health and safety policies are relevant
Eyres v Atkinsons Kitchens & Bedrooms Ltd
Michael Eyres was an employee of Atkinsons Kitchens and Bedrooms. Late one evening, he crashed his van while returning to Bradford on the M1, having worked a 19-hour day and driven hundreds of miles. Eyres, who was not wearing a seatbelt, suffered a serious spinal injury in the accident, which left him tetraplegic.
Prior to the accident, while his managing director Craig Atkinson was asleep as a passenger, Eyres read and sent a number of text messages on his mobile phone while driving at high speed. The accident was caused by Eyres having to brake suddenly and losing control of the vehicle.
Eyres had claimed that his employer was liable in negligence and/or breach of statutory duty because it had caused or permitted him to drive when he was too tired having worked excessively long hours without a proper break.
Decision
The High Court found that it was Eyres' not paying attention through using his mobile phone that caused the accident, rather than his tiredness, and entered judgment in the defendant's favour. Eyres appealed.
The Court of Appeal overturned the High Court ruling, concluding that on a balance of probabilities the accident was caused by Eyres falling asleep, rather than using his mobile phone.
The Court of Appeal found that his employer, which encouraged a long-hours culture, had been negligent by requiring him to drive in such circumstances and doing nothing to guard against the risk of injury.
It was also directed that Eyres' damages should be reduced by 33% due to his contributory negligence in not wearing a seat belt and in driving while tired and liable to fall asleep.
Key implications
All employers should be alert to health and safety and working time requirements. However, employers of staff who engage in higher-risk activities (such as long-distance driving, working at height, or operating heavy or dangerous machinery) must take care to ensure they comply at all times with their duty of care to their employees. Casually asking an employee who has worked long hours, and is clearly suffering from fatigue, if they are "OK to carry on" with the relevant activity will not usually be sufficient.
The Eyres case is also a reminder that while risks taken by the employee may reduce damages through contributory negligence, they may not be enough to ensure that the employer escapes liability. Having exemptions or obtaining employee opt-outs from working time legislation will not prevent liability for health and safety or negligence claims.
The Corporate Manslaughter and Homicide Bill will bring such risks into even sharper focus.
Employers should ensure their health and safety policies adequately address risks that are relevant to their workforce, and that they:
Comply with all relevant health and safety and working time legislation for the industry in question.
Make it clear that a long working hours culture that puts employees' health and safety at risk is positively discouraged.
Ensure that working schedules and, where relevant, journey times are realistic and safe, with provision for rest breaks.
Put checks in place to ensure these schedules are adhered to.
Provide practical measures to ensure that employee health and safety is not placed at risk - for example, ensuring an overnight stay rather than requiring completion of a long road journey at the end of a working day.
By Adam Fuge, partner, Matthew Arnold & Baldwin
HR : http://www.personneltoday.com
Michael Eyres was an employee of Atkinsons Kitchens and Bedrooms. Late one evening, he crashed his van while returning to Bradford on the M1, having worked a 19-hour day and driven hundreds of miles. Eyres, who was not wearing a seatbelt, suffered a serious spinal injury in the accident, which left him tetraplegic.
Prior to the accident, while his managing director Craig Atkinson was asleep as a passenger, Eyres read and sent a number of text messages on his mobile phone while driving at high speed. The accident was caused by Eyres having to brake suddenly and losing control of the vehicle.
Eyres had claimed that his employer was liable in negligence and/or breach of statutory duty because it had caused or permitted him to drive when he was too tired having worked excessively long hours without a proper break.
Decision
The High Court found that it was Eyres' not paying attention through using his mobile phone that caused the accident, rather than his tiredness, and entered judgment in the defendant's favour. Eyres appealed.
The Court of Appeal overturned the High Court ruling, concluding that on a balance of probabilities the accident was caused by Eyres falling asleep, rather than using his mobile phone.
The Court of Appeal found that his employer, which encouraged a long-hours culture, had been negligent by requiring him to drive in such circumstances and doing nothing to guard against the risk of injury.
It was also directed that Eyres' damages should be reduced by 33% due to his contributory negligence in not wearing a seat belt and in driving while tired and liable to fall asleep.
Key implications
All employers should be alert to health and safety and working time requirements. However, employers of staff who engage in higher-risk activities (such as long-distance driving, working at height, or operating heavy or dangerous machinery) must take care to ensure they comply at all times with their duty of care to their employees. Casually asking an employee who has worked long hours, and is clearly suffering from fatigue, if they are "OK to carry on" with the relevant activity will not usually be sufficient.
The Eyres case is also a reminder that while risks taken by the employee may reduce damages through contributory negligence, they may not be enough to ensure that the employer escapes liability. Having exemptions or obtaining employee opt-outs from working time legislation will not prevent liability for health and safety or negligence claims.
The Corporate Manslaughter and Homicide Bill will bring such risks into even sharper focus.
Employers should ensure their health and safety policies adequately address risks that are relevant to their workforce, and that they:
Comply with all relevant health and safety and working time legislation for the industry in question.
Make it clear that a long working hours culture that puts employees' health and safety at risk is positively discouraged.
Ensure that working schedules and, where relevant, journey times are realistic and safe, with provision for rest breaks.
Put checks in place to ensure these schedules are adhered to.
Provide practical measures to ensure that employee health and safety is not placed at risk - for example, ensuring an overnight stay rather than requiring completion of a long road journey at the end of a working day.
By Adam Fuge, partner, Matthew Arnold & Baldwin
HR : http://www.personneltoday.com
What is the 'same job' following maternity leave?
Blundell v St Andrews Catholic Primary School
When is a job not the same job? That was the question considered in Blundell v St Andrews Catholic Primary School, where for the first time the Employment Appeal Tribunal (EAT) considered the criteria to be used when assessing what exactly amounts to the 'same job' under the Maternity and Parental Leave Regulations 1999.
In the regulations, a woman returning from ordinary maternity leave has the right to "return to the same job, in which she was employed before her absence".
Background
Mrs Blundell was a primary school teacher. The practice in her school was for teachers to teach a particular class every two years and then rotate - to give them a breadth of experience.
At the time of commencing maternity leave in January 2004, she was in her second year of teaching the class 'reception yellow'. On her return to work, at the start of the following academic year, she was offered the choice of a floating role or teaching year two. She chose the latter. However, she claimed that this was a more stressful role, and not the same job that she had left prior to her maternity leave.
Decision
The EAT disagreed, and found her role to be that of a primary school teacher, and not specifically defined as a teacher of the reception yellow class.
An employer has to consider three things when deciding upon the 'same job': the 'nature' of the job, as provided by the contract of employment the 'capacity' in which the employee is employed, which is a factual label to describe the employee's function more than merely their status and the 'place' at which the employee works.
The issues of capacity and place are not dictated solely by the contract, but are to be decided by a tribunal on the particular facts. For example, where a mobility clause allowing for an alternative location exists in the contract of employment, this would not necessarily entitle an employer to move an employee on her return from maternity leave.
The EAT ruled that where there is variation to the role in practice, the employer is not obliged to "freeze time at the precise moment that maternity leave is taken, but may have regard to the normal range within which variation has previously occurred". It concluded that teaching year two was not outside the normal range of variability that she could reasonably have expected, and was therefore the 'same job'.
As her role was regularly rotated, the EAT found that the nature of her job was to teach at a primary school, her capacity was as a class teacher rather than a reception yellow teacher, and her place of work was at the school.
Key implications
Although of little comfort to Blundell, the EAT was keen to stress the purpose of the regulations, which is to ensure that women who return from maternity leave experience as little disruption as reasonably possible at an already stressful time for them.
While the EAT was sympathetic to the intentions of the regulations, the positive message for employers is that in practice, as in this case, it is likely that a generic job description and less rigid working practices will go a long way in affording them the flexibility that they may require.
The guidelines set out by the EAT are useful. However, nothing can be taken for granted and, where there is uncertainty, each case will still rest on its own facts.
Stefan Green is a lawyer in the employment and benefits team at Allen & Overy
HR LINK : http://www.personneltoday.com/
When is a job not the same job? That was the question considered in Blundell v St Andrews Catholic Primary School, where for the first time the Employment Appeal Tribunal (EAT) considered the criteria to be used when assessing what exactly amounts to the 'same job' under the Maternity and Parental Leave Regulations 1999.
In the regulations, a woman returning from ordinary maternity leave has the right to "return to the same job, in which she was employed before her absence".
Background
Mrs Blundell was a primary school teacher. The practice in her school was for teachers to teach a particular class every two years and then rotate - to give them a breadth of experience.
At the time of commencing maternity leave in January 2004, she was in her second year of teaching the class 'reception yellow'. On her return to work, at the start of the following academic year, she was offered the choice of a floating role or teaching year two. She chose the latter. However, she claimed that this was a more stressful role, and not the same job that she had left prior to her maternity leave.
Decision
The EAT disagreed, and found her role to be that of a primary school teacher, and not specifically defined as a teacher of the reception yellow class.
An employer has to consider three things when deciding upon the 'same job': the 'nature' of the job, as provided by the contract of employment the 'capacity' in which the employee is employed, which is a factual label to describe the employee's function more than merely their status and the 'place' at which the employee works.
The issues of capacity and place are not dictated solely by the contract, but are to be decided by a tribunal on the particular facts. For example, where a mobility clause allowing for an alternative location exists in the contract of employment, this would not necessarily entitle an employer to move an employee on her return from maternity leave.
The EAT ruled that where there is variation to the role in practice, the employer is not obliged to "freeze time at the precise moment that maternity leave is taken, but may have regard to the normal range within which variation has previously occurred". It concluded that teaching year two was not outside the normal range of variability that she could reasonably have expected, and was therefore the 'same job'.
As her role was regularly rotated, the EAT found that the nature of her job was to teach at a primary school, her capacity was as a class teacher rather than a reception yellow teacher, and her place of work was at the school.
Key implications
Although of little comfort to Blundell, the EAT was keen to stress the purpose of the regulations, which is to ensure that women who return from maternity leave experience as little disruption as reasonably possible at an already stressful time for them.
While the EAT was sympathetic to the intentions of the regulations, the positive message for employers is that in practice, as in this case, it is likely that a generic job description and less rigid working practices will go a long way in affording them the flexibility that they may require.
The guidelines set out by the EAT are useful. However, nothing can be taken for granted and, where there is uncertainty, each case will still rest on its own facts.
Stefan Green is a lawyer in the employment and benefits team at Allen & Overy
HR LINK : http://www.personneltoday.com/
Case of the week: When can the 'without prejudice' rule be set aside?
In Brunel University & Schwartz v Webster & Vaseghi, the Court of Appeal analysed the 'without prejudice' rule and circumstances in which the rule can be set aside.
The without prejudice privilege attaches to evidence of settlement negotiations aimed at resolving disputes, and prevents such evidence being referred to in proceedings. However, privilege will fall away where both parties waive it, and can also be withdrawn where it would otherwise conceal unlawful behaviour.
Facts
Vaseghi and Webster brought claims of race discrimination against Brunel University. The without prejudice discussions to settle the disputes were unsuccessful and tribunal hearings went ahead. Subsequently, in a university newsletter, the vice-chancellor complained about the cost of defending the claims, and alluded to the fact that the claims had been accompanied by "unwarranted demands for money". Vaseghi and Webster brought victimisation grievances and tribunal claims on the basis of these comments. An independent panel set up by the university heard the grievances, including evidence about the without prejudice discussions.
The tribunal pleadings and bundle also contained various references to the settlement discussions. However, when Vaseghi and Webster disclosed a statement by a solicitor about these discussions, the university's lawyers objected on the basis that the evidence was without prejudice.
Decision
The Court of Appeal said that privilege had been waived on the basis that both parties:
Gave or called evidence of the without prejudice discussions at the independent panel review (an unusual forum as it was adversarial in nature and a formal trial)
Referred to the without prejudice discussions in their respective pleadings.
However, the court said that, in normal cases where without prejudice discussions are mentioned at internal grievance meetings, privilege would not be waived.
While the court declined to comment on whether there was an exception to the without prejudice rule in cases of discrimination to prevent the rule from concealing the "evil" of discrimination, it did say that it could understand that it may be difficult to prove discrimination if the general without prejudice rule applies fully in every case.
Key implications
Be aware that without prejudice protection will not apply in all cases and is not absolute. To protect the without prejudice status of communications:
Consider whether there is a dispute before speaking on a without prejudice basis. The rule only applies where there is a dispute between the parties and the discussions are a genuine attempt to end the dispute.
Label settlement documents 'without prejudice', although remember that a document will not become privileged merely because of its label.
Only refer to without prejudice communications during internal grievance proceedings where absolutely necessary, and make it clear that privilege is not being waived. Where independent panels are set up to determine grievances, beware that adducing evidence of without prejudice communications is likely to waive privilege.
Do not refer to without prejudice documents or discussions in pleadings, witness statements or any other tribunal documents.
The privilege may not cover communications that disclose evidence of discrimination. There remains a risk that the without prejudice rule will be set aside to allow a claimant to prove discrimination.
By Judith Harris, professional support lawyer, Addleshaw Goddard
HR LINK : http://www.personneltoday.com/
The without prejudice privilege attaches to evidence of settlement negotiations aimed at resolving disputes, and prevents such evidence being referred to in proceedings. However, privilege will fall away where both parties waive it, and can also be withdrawn where it would otherwise conceal unlawful behaviour.
Facts
Vaseghi and Webster brought claims of race discrimination against Brunel University. The without prejudice discussions to settle the disputes were unsuccessful and tribunal hearings went ahead. Subsequently, in a university newsletter, the vice-chancellor complained about the cost of defending the claims, and alluded to the fact that the claims had been accompanied by "unwarranted demands for money". Vaseghi and Webster brought victimisation grievances and tribunal claims on the basis of these comments. An independent panel set up by the university heard the grievances, including evidence about the without prejudice discussions.
The tribunal pleadings and bundle also contained various references to the settlement discussions. However, when Vaseghi and Webster disclosed a statement by a solicitor about these discussions, the university's lawyers objected on the basis that the evidence was without prejudice.
Decision
The Court of Appeal said that privilege had been waived on the basis that both parties:
Gave or called evidence of the without prejudice discussions at the independent panel review (an unusual forum as it was adversarial in nature and a formal trial)
Referred to the without prejudice discussions in their respective pleadings.
However, the court said that, in normal cases where without prejudice discussions are mentioned at internal grievance meetings, privilege would not be waived.
While the court declined to comment on whether there was an exception to the without prejudice rule in cases of discrimination to prevent the rule from concealing the "evil" of discrimination, it did say that it could understand that it may be difficult to prove discrimination if the general without prejudice rule applies fully in every case.
Key implications
Be aware that without prejudice protection will not apply in all cases and is not absolute. To protect the without prejudice status of communications:
Consider whether there is a dispute before speaking on a without prejudice basis. The rule only applies where there is a dispute between the parties and the discussions are a genuine attempt to end the dispute.
Label settlement documents 'without prejudice', although remember that a document will not become privileged merely because of its label.
Only refer to without prejudice communications during internal grievance proceedings where absolutely necessary, and make it clear that privilege is not being waived. Where independent panels are set up to determine grievances, beware that adducing evidence of without prejudice communications is likely to waive privilege.
Do not refer to without prejudice documents or discussions in pleadings, witness statements or any other tribunal documents.
The privilege may not cover communications that disclose evidence of discrimination. There remains a risk that the without prejudice rule will be set aside to allow a claimant to prove discrimination.
By Judith Harris, professional support lawyer, Addleshaw Goddard
HR LINK : http://www.personneltoday.com/
Case of the week: 'Without prejudice' discussions
Framlington Group Ltd and Axa Framlington Group Ltd v Barnetson (Court of Appeal)
Hot on the heels of Brunel University & Schwartz v Webster & Vaseghi (see case of the week, Personnel Today, 12 June), which dealt with the circumstances in which the 'without prejudice' rule can be set aside, comes a second Court of Appeal case - Framlington Group Ltd and Axa Framlington Group Ltd v Barnetson.
Written or oral communications made in a genuine attempt to resolve a dispute will generally be protected by the without prejudice rule. This means that those communications cannot be used as evidence in court proceedings in relation to that dispute.
It is well established that where settlement negotiations occur in the context of litigation, or threatened litigation, those negotiations will be covered by the without prejudice rule. However, in the 2004 case of BNP Paribas v Ms A Mezzotero the EAT restricted the operation of the rule and said that it would only apply where litigation was likely and not before that point.
Framlington follows on from Mezzotero, and considers, for the first time, whether discussions that took place months before litigation started, or was even likely, will be covered by the rule.
Facts
In early 2005, Mr Barnetson started employment as chief operating officer at Framlington Group Ltd. He was told that his orally agreed terms and conditions would be confirmed in writing at a later date. However, when Barnetson pursued this written confirmation, a difference of opinion arose as to the terms that had been agreed. Discussions around his terms took place until the end of October 2005, at which point Framlington told Barnetson it intended to dismiss him at the end of the year.
Further negotiations ensued, during which a compromise agreement was produced and Barnetson set out the terms on which he would be prepared to settle. These discussions broke down and on 20 December 2005, Barnetson was given notice that his employment would terminate.
Barnetson brought proceedings for damages for wrongful dismissal in April 2006. Framlington alleged that certain parts of Barnetson's witness statement in support of his claim should not be allowed because they related to without prejudice discussions that had taken place between the end of October and 20 December 2005. The High Court judge rejected this argument. Framlington appealed.
Decision
The Court of Appeal held that, once Framlington had told Barnetson it intended to dismiss him, the discussions that followed were without prejudice and could not, therefore, be used as evidence in the court proceedings.
There was a public policy consideration underlying the without prejudice rule namely, to encourage people to settle their disputes without resorting to litigation. In light of this aim, it was not appropriate to set a time limit prior to litigation before which any discussions would not be protected. Rather, courts should determine the point at which, during the course of negotiations, the parties contemplated, or might reasonably have contemplated, litigation if they could not reach agreement.
Key implications
This case clarifies the circumstances in which discussions with staff will be covered by the without prejudice rule:
There is no need for litigation to be threatened or underway for negotiations to be protected. If it is clear that the parties understood that litigation might result if the negotiations failed, then such discussions are likely to be protected.
The discussions in this case were only protected from the point at which Barnetson was told of his employer's intention to dismiss him. Discussions during internal grievances are unlikely to be protected.
By Laura Green, assistant solicitor, Lovells' Employment Group
HR Link : http://www.personneltoday.com
Hot on the heels of Brunel University & Schwartz v Webster & Vaseghi (see case of the week, Personnel Today, 12 June), which dealt with the circumstances in which the 'without prejudice' rule can be set aside, comes a second Court of Appeal case - Framlington Group Ltd and Axa Framlington Group Ltd v Barnetson.
Written or oral communications made in a genuine attempt to resolve a dispute will generally be protected by the without prejudice rule. This means that those communications cannot be used as evidence in court proceedings in relation to that dispute.
It is well established that where settlement negotiations occur in the context of litigation, or threatened litigation, those negotiations will be covered by the without prejudice rule. However, in the 2004 case of BNP Paribas v Ms A Mezzotero the EAT restricted the operation of the rule and said that it would only apply where litigation was likely and not before that point.
Framlington follows on from Mezzotero, and considers, for the first time, whether discussions that took place months before litigation started, or was even likely, will be covered by the rule.
Facts
In early 2005, Mr Barnetson started employment as chief operating officer at Framlington Group Ltd. He was told that his orally agreed terms and conditions would be confirmed in writing at a later date. However, when Barnetson pursued this written confirmation, a difference of opinion arose as to the terms that had been agreed. Discussions around his terms took place until the end of October 2005, at which point Framlington told Barnetson it intended to dismiss him at the end of the year.
Further negotiations ensued, during which a compromise agreement was produced and Barnetson set out the terms on which he would be prepared to settle. These discussions broke down and on 20 December 2005, Barnetson was given notice that his employment would terminate.
Barnetson brought proceedings for damages for wrongful dismissal in April 2006. Framlington alleged that certain parts of Barnetson's witness statement in support of his claim should not be allowed because they related to without prejudice discussions that had taken place between the end of October and 20 December 2005. The High Court judge rejected this argument. Framlington appealed.
Decision
The Court of Appeal held that, once Framlington had told Barnetson it intended to dismiss him, the discussions that followed were without prejudice and could not, therefore, be used as evidence in the court proceedings.
There was a public policy consideration underlying the without prejudice rule namely, to encourage people to settle their disputes without resorting to litigation. In light of this aim, it was not appropriate to set a time limit prior to litigation before which any discussions would not be protected. Rather, courts should determine the point at which, during the course of negotiations, the parties contemplated, or might reasonably have contemplated, litigation if they could not reach agreement.
Key implications
This case clarifies the circumstances in which discussions with staff will be covered by the without prejudice rule:
There is no need for litigation to be threatened or underway for negotiations to be protected. If it is clear that the parties understood that litigation might result if the negotiations failed, then such discussions are likely to be protected.
The discussions in this case were only protected from the point at which Barnetson was told of his employer's intention to dismiss him. Discussions during internal grievances are unlikely to be protected.
By Laura Green, assistant solicitor, Lovells' Employment Group
HR Link : http://www.personneltoday.com
Case of the week: Banking on the bonus doesn't pay
Ridgway v JP Morgan Chase Bank National Association, High Court
What is the extent of an employer's discretion when making bonus decisions? We already know that discretion is not completely unfettered, and that employers must not act in a way that is irrational or perverse when making bonus decisions. But does that authorise an employer to award no bonus whatsoever?
Background
In Ridgway v JP Morgan, the High Court decided that the bank was entitled to award a 'nil' bonus to a trader who had spent most of the bonus year on sabbatical.
Mr Ridgway, who headed up the bank's options desk, took an unpaid sabbatical starting in April 2003. One of the terms of the sabbatical agreement was that Ridgway would continue to be eligible for a discretionary bonus for the year ending December 2003. At the end of the bonus year, the bank awarded Ridgway a nil bonus.
On his return from sabbatical, Ridgway's previous job was unavailable, and he and the bank failed to agree on an alternative role for him. Ridgway resigned and claimed constructive dismissal. He claimed compensation for his bonus on the basis that the bonus decision was irrational and perverse, as well as compensation for stock awards that he lost as a result of resigning.
Decision
The High Court dismissed all of Ridgway's claims. In relation to the bonus claim, it followed the guidelines for the award of discretionary bonuses set out in the recent Court of Appeal decision of Commerzbank v Keen. In Commerzbank, the Court of Appeal said the hurdle is set very high for an employee to show that a bonus decision is irrational or perverse. However, the Court of Appeal also said an employer must identify the reason for a bonus award and the decision maker.
The High Court said the bank had been entitled to award Ridgway a nil bonus after taking into account the fact that he had been on sabbatical for most of the bonus year. The bank had also taken into account the fact that Ridgway had been making a loss when he went on sabbatical, that his 'add-on' contribution was very limited, and that there were no other factors to justify awarding a bonus.
The court endorsed Commerzbank and said the task of proving irrationality or perversity in the exercise of the bank's discretion to award a bonus is a "daunting one".
Key implications
Following the Commerzbank and JP Morgan decisions, courts will be reluctant to intervene in bonus decisions except in exceptional cases. However, bonus decisions are subject to challenge where the decision appears irrational and/or where the decision-making process is not transparent. Employers should be mindful of the following when making discretionary bonus decisions:
Properly and fully consider whether to award a discretionary bonus and, if so, the amount of the award.
Ensure the decision-making process is transparent and provide reasons why the bonus was assessed at the level it was so that the employee has an understanding as to how the figure was reached.
Tell the employee who made the bonus decision.
Review bonus wording to ensure it provides the level of discretion required (subject, of course, to the legal limitations set out above).
By Judith Harris, professional support lawyer, Addleshaw Goddard
Employers' Law
Each month, Employers' Law magazine outlines the latest legal rulings and what these mean for you. Click here to subscribe, or call 01444 445566.
Article by : http://www.personneltoday.com
What is the extent of an employer's discretion when making bonus decisions? We already know that discretion is not completely unfettered, and that employers must not act in a way that is irrational or perverse when making bonus decisions. But does that authorise an employer to award no bonus whatsoever?
Background
In Ridgway v JP Morgan, the High Court decided that the bank was entitled to award a 'nil' bonus to a trader who had spent most of the bonus year on sabbatical.
Mr Ridgway, who headed up the bank's options desk, took an unpaid sabbatical starting in April 2003. One of the terms of the sabbatical agreement was that Ridgway would continue to be eligible for a discretionary bonus for the year ending December 2003. At the end of the bonus year, the bank awarded Ridgway a nil bonus.
On his return from sabbatical, Ridgway's previous job was unavailable, and he and the bank failed to agree on an alternative role for him. Ridgway resigned and claimed constructive dismissal. He claimed compensation for his bonus on the basis that the bonus decision was irrational and perverse, as well as compensation for stock awards that he lost as a result of resigning.
Decision
The High Court dismissed all of Ridgway's claims. In relation to the bonus claim, it followed the guidelines for the award of discretionary bonuses set out in the recent Court of Appeal decision of Commerzbank v Keen. In Commerzbank, the Court of Appeal said the hurdle is set very high for an employee to show that a bonus decision is irrational or perverse. However, the Court of Appeal also said an employer must identify the reason for a bonus award and the decision maker.
The High Court said the bank had been entitled to award Ridgway a nil bonus after taking into account the fact that he had been on sabbatical for most of the bonus year. The bank had also taken into account the fact that Ridgway had been making a loss when he went on sabbatical, that his 'add-on' contribution was very limited, and that there were no other factors to justify awarding a bonus.
The court endorsed Commerzbank and said the task of proving irrationality or perversity in the exercise of the bank's discretion to award a bonus is a "daunting one".
Key implications
Following the Commerzbank and JP Morgan decisions, courts will be reluctant to intervene in bonus decisions except in exceptional cases. However, bonus decisions are subject to challenge where the decision appears irrational and/or where the decision-making process is not transparent. Employers should be mindful of the following when making discretionary bonus decisions:
Properly and fully consider whether to award a discretionary bonus and, if so, the amount of the award.
Ensure the decision-making process is transparent and provide reasons why the bonus was assessed at the level it was so that the employee has an understanding as to how the figure was reached.
Tell the employee who made the bonus decision.
Review bonus wording to ensure it provides the level of discretion required (subject, of course, to the legal limitations set out above).
By Judith Harris, professional support lawyer, Addleshaw Goddard
Employers' Law
Each month, Employers' Law magazine outlines the latest legal rulings and what these mean for you. Click here to subscribe, or call 01444 445566.
Article by : http://www.personneltoday.com
Ownership of contacts lists after employment has ended
PennWell Publishing (UK) Limited v Isles
Who owns a contacts list maintained by an employee in Outlook on the employer's computer system? In PennWell Publishing (UK) Limited v Isles, the High Court decided that the list belonged to the employer, despite the fact that it contained personal contacts and contacts that the employee had made before his employment had started.
Background
Mr Isles, a journalist, was employed as a publisher and conference chairman for PennWell. During his employment, he created and maintained a contacts list on PennWell's Outlook system, which included personal contacts, journalistic contacts and contacts that he had made before his employment started, as well as business contacts that he developed in his role with PennWell.
After Isles left PennWell to set up a competing business, it discovered that he had downloaded the entire Outlook contacts list from his work laptop.
Isles's contract stated that all documents used during employment belonged to the company and had to be returned before he left.
PennWell applied for an injunction for the return of the contacts list. Isles argued that most of the contacts on the list were personal to him.
Decision
The High Court had to decide whether the contacts list belonged exclusively to either PennWell or Isles or whether it was jointly owned by both.
The High Court said that where an address list is contained in Outlook or a similar software that is part of the employer's e-mail system and backed-up by the employer, the database or list belongs to the employer and may not be copied or removed in its entirety by employees for use outside or after employment. The High Court said that it would be "highly desirable" for employers to publish e-mail policies to communicate this to employees. While PennWell had an appropriate e-mail policy, the policy had not been effectively communicated to Isles and, therefore, PennWell was not entitled to rely on it.
Had Isles maintained his list of contacts as a separate, private address book, he would most likely have been entitled to that list. The court distinguished between contacts developed for the purposes of employment, where removal of contact information would be detrimental to the employer, and other contacts that an employee might keep for career purposes.
The court concluded that the list belonged to PennWell, but that Isles could copy from it his journalistic contacts and those made before his employment started.
Key implications
The confusion over ownership of the contacts lists that led to this case coming to court highlights the need for clear policies on ownership of contacts information. Employers should as a minimum:
Review e-mail policies to ensure they clearly identify what information is considered to belong to the employer, and confirm that it may not be removed or copied.
Communicate e-mail policies to all existing staff and bring these to the attention of new employees.
Ensure that confidentiality and return of property provisions in contracts cover contacts information and state what information will be protected/must be returned after employment.
Consider giving employees the option of a personal contacts folder to maintain contacts that are personal and/or those that pre-date employment.
Judith Harris, professional support lawyer, Addleshaw Goddard
HR : http://www.personneltoday.com
Who owns a contacts list maintained by an employee in Outlook on the employer's computer system? In PennWell Publishing (UK) Limited v Isles, the High Court decided that the list belonged to the employer, despite the fact that it contained personal contacts and contacts that the employee had made before his employment had started.
Background
Mr Isles, a journalist, was employed as a publisher and conference chairman for PennWell. During his employment, he created and maintained a contacts list on PennWell's Outlook system, which included personal contacts, journalistic contacts and contacts that he had made before his employment started, as well as business contacts that he developed in his role with PennWell.
After Isles left PennWell to set up a competing business, it discovered that he had downloaded the entire Outlook contacts list from his work laptop.
Isles's contract stated that all documents used during employment belonged to the company and had to be returned before he left.
PennWell applied for an injunction for the return of the contacts list. Isles argued that most of the contacts on the list were personal to him.
Decision
The High Court had to decide whether the contacts list belonged exclusively to either PennWell or Isles or whether it was jointly owned by both.
The High Court said that where an address list is contained in Outlook or a similar software that is part of the employer's e-mail system and backed-up by the employer, the database or list belongs to the employer and may not be copied or removed in its entirety by employees for use outside or after employment. The High Court said that it would be "highly desirable" for employers to publish e-mail policies to communicate this to employees. While PennWell had an appropriate e-mail policy, the policy had not been effectively communicated to Isles and, therefore, PennWell was not entitled to rely on it.
Had Isles maintained his list of contacts as a separate, private address book, he would most likely have been entitled to that list. The court distinguished between contacts developed for the purposes of employment, where removal of contact information would be detrimental to the employer, and other contacts that an employee might keep for career purposes.
The court concluded that the list belonged to PennWell, but that Isles could copy from it his journalistic contacts and those made before his employment started.
Key implications
The confusion over ownership of the contacts lists that led to this case coming to court highlights the need for clear policies on ownership of contacts information. Employers should as a minimum:
Review e-mail policies to ensure they clearly identify what information is considered to belong to the employer, and confirm that it may not be removed or copied.
Communicate e-mail policies to all existing staff and bring these to the attention of new employees.
Ensure that confidentiality and return of property provisions in contracts cover contacts information and state what information will be protected/must be returned after employment.
Consider giving employees the option of a personal contacts folder to maintain contacts that are personal and/or those that pre-date employment.
Judith Harris, professional support lawyer, Addleshaw Goddard
HR : http://www.personneltoday.com
Thursday, July 26, 2007
10 Tips For Planning A Corporate Incentive Travel Program
Corporate incentive travel is a great way to motivate and reward your valuable employees. Incentive travel can be group or individual, and the destination can be local or international. But every successful incentive travel program begins with careful planning.
The following are tips to help you plan a corporate travel program that fits your company’s culture, size and available budget:
Determine your corporate incentive program goals. In specific terms, establish what the incentive program should accomplish. This could be an increase in sales, increase in production output or profits, or a reduction in defective products, sales returns or lost contracts. Be sure to assign a value to the improvement or reduction - a percentage, absolute number of units or contracts, or a dollar figure.
Select the target group for the program. This could be management, employees, salespeople, or even customers.
Discover what the target’s values, interests and preferences through paper surveys or interviews. Then browse our corporate incentives guide to match up preferences with available packages in your budget range.
Considering past performance and employee behavior, establish reasonable tasks for your target group.
Make sure you have a performance tracking system in place with a clear way to measure incentive program results.
Brainstorm what obstacles may exist to the success of the incentive program. This could be current employee morale, organizational structure or market conditions.
Determine whether the program will be managed internally or outsourced to an agency.
Understand applicable tax implications. Travel can be taxable to recipients under certain conditions, and special tax forms may be required.
When selecting a corporate incentive travel company, make sure it agrees to fulfill what is promised for your budgeted cost, and that you understand its cancellation policies.
At the end of your program, survey winners and non-winners to determine whether the program was successful in meeting the objective.
Corporate Travel on a Smaller Budget
Even if you can’t afford to whisk your top performers away to Europe on a private jet, you can still reward your employees with incentive travel that they can enjoy.
If you can afford to send your team away on a teambuilding retreat, it doesn’t have to be far away. Campsites and resorts, even a day on a chartered boat can create a memorable experience. For individuals, it’s a better idea to send your recipient somewhere exotic enough to be memorable. If possible, allowing a spouse or children to accompany your employee is also a good idea.
An employee incentive getaway generally lasts from three nights to a full week, but weekend getaways can also work for smaller budgets. Accommodation could be in a bed and breakfast. Check travel and hotel websites often to catch their “travel best bets.”
Conclusion
For any corporate incentive travel program to accomplish its goal, you must determine how much you can spend, what options are available and what people want. And you must anticipate potential problems both within and without your organization. A clear system for measuring results will help you with future planning. Even on a smaller budget, corporate incentive travel can benefit your organization.
Linda Bustos is the Director of Marketing for Image X Media, a full service web design firm in Vancouver.
Back to HR Article Directory
The following are tips to help you plan a corporate travel program that fits your company’s culture, size and available budget:
Determine your corporate incentive program goals. In specific terms, establish what the incentive program should accomplish. This could be an increase in sales, increase in production output or profits, or a reduction in defective products, sales returns or lost contracts. Be sure to assign a value to the improvement or reduction - a percentage, absolute number of units or contracts, or a dollar figure.
Select the target group for the program. This could be management, employees, salespeople, or even customers.
Discover what the target’s values, interests and preferences through paper surveys or interviews. Then browse our corporate incentives guide to match up preferences with available packages in your budget range.
Considering past performance and employee behavior, establish reasonable tasks for your target group.
Make sure you have a performance tracking system in place with a clear way to measure incentive program results.
Brainstorm what obstacles may exist to the success of the incentive program. This could be current employee morale, organizational structure or market conditions.
Determine whether the program will be managed internally or outsourced to an agency.
Understand applicable tax implications. Travel can be taxable to recipients under certain conditions, and special tax forms may be required.
When selecting a corporate incentive travel company, make sure it agrees to fulfill what is promised for your budgeted cost, and that you understand its cancellation policies.
At the end of your program, survey winners and non-winners to determine whether the program was successful in meeting the objective.
Corporate Travel on a Smaller Budget
Even if you can’t afford to whisk your top performers away to Europe on a private jet, you can still reward your employees with incentive travel that they can enjoy.
If you can afford to send your team away on a teambuilding retreat, it doesn’t have to be far away. Campsites and resorts, even a day on a chartered boat can create a memorable experience. For individuals, it’s a better idea to send your recipient somewhere exotic enough to be memorable. If possible, allowing a spouse or children to accompany your employee is also a good idea.
An employee incentive getaway generally lasts from three nights to a full week, but weekend getaways can also work for smaller budgets. Accommodation could be in a bed and breakfast. Check travel and hotel websites often to catch their “travel best bets.”
Conclusion
For any corporate incentive travel program to accomplish its goal, you must determine how much you can spend, what options are available and what people want. And you must anticipate potential problems both within and without your organization. A clear system for measuring results will help you with future planning. Even on a smaller budget, corporate incentive travel can benefit your organization.
Linda Bustos is the Director of Marketing for Image X Media, a full service web design firm in Vancouver.
Back to HR Article Directory
How To Create Lasting Change & Achieve Greater Success At Work
“This year, I’m going to get that raise.”
“I will get my desk organized once and for all.”
“I’ll have better work/life balance.”
“I’ll start that business I’ve always dreamed about.”
At some point we’ve all vowed to make some big change – similar to the resolutions above. But by the time the rosy blush of good intentions wears off, the resolution gets pushed aside. Not because we don’t still long to have what we want, but because we just don’t know how to change.
Changing your behavior takes work.
Our brains have enormous “plasticity,” meaning they can create new cells and pathways. But our brains create strong tendencies to do the same thing over and over.
Here’s why:
The brain cells that fire together wire together. Meaning, they have a strong tendency to run the same program the next time. That’s why lasting change takes lots of practice; you’ve got to create a pathway to the new options.
According to many brain scientists it can take six to nine months to change your behavior. Yet people continue to waste so much money on those seven-day miracle programs and then wonder why they have not experienced lasting change and greater success at work.
Here’s The Top 3 Reasons Why Many Business Entrepreneurs and Executives Fail To Change Their Behavior & Achieve Greater Business Success:
1. They’ve not yet realized that the change process is not about getting rid of bad habits. The pathway to your current behavior is there for life. Instead you want to focus on creating new, more positive habits that will positively affect your business. Even stopping doing something, like procrastinating, is really about creating a good new habit, starting sooner.
2. They fail to put external reminders in place, at least in the beginning. Unless you have a trigger from the outside like an email reminder, or a buddy it’s very likely you’ll keep defaulting to the old behavior because it’s automatic. That’s also why it’s so important to be willing to start over no matter how often you blow it or get discouraged.
3. They’re not concrete enough about what they want and are unrealistic about what they can reasonably ask themselves to change. Here’s what an executive client of mine said he wanted to change in three months: “to be more positive with co-workers, staff and colleagues, to be more creative and productive and to take better care of myself.” “How about create world peace while you’re at it?” I replied. “And what does `more’ mean anyway? As this client demonstrated, we expect too much of ourselves and we expect to change overnight. When that doesn’t happen, we resign ourselves to staying the same, convinced that we are hopeless, weak, or unmotivated. Which makes us even more stuck in a rut.
To truly change your behavior and achiever greater business success requires three things: desire, intent, and persistence. You have to identify what you desire enough to be willing to stick to. You have to make SMART goals (Specific, Measurable, Achievable, Relevant and Time-bound) like “leave the computer at the office and don’t look at the Blackberry after 9” rather than “having more balance”. You need determination and persistence to try again no matter how many times you blow it. Most importantly you need to avoid my top 10 common resolution pitfalls.
My Top 10 List of Resolution Pitfalls
1. Being vague about what you want
2. Not making a serious commitment
3. Excuse-making—no time, wrong time, dog ate homework 4. Unwilling to go through the awkward phase 5. Not setting up a tracking and reminder system 6. Expecting perfection and falling into guilt, shame, and regret 7. Trying to change by yourself 8. Telling yourself self-limiting rut stories 9. Not having backup plans 10. Turning slip-ups to give-ups
Armed with a new attitude and behavior, you can create lasting change and achieve greater success at work. When you have this invaluable tool in your arsenal, you’ll be empowered to bring anything you want into reality. You’ll become the master of your fate rather than the victim of old choices.
bio: M.J. Ryan is an executive coach and the author of THIS YEAR I WILL…How to Finally Change a Habit, Keep a Resolution or Make a Dream Come True. To receive a ton of free resources including free daily “I Will Power” emails that will help you make and actually keep your promises and achieve greater business success this year, go to http://www.mj-ryan.com
bio: M.J. Ryan is an executive coach and the author of THIS YEAR I WILL…How to Finally Change a Habit, Keep a Resolution or Make a Dream Come True. To receive a ton of free resources including free daily “I Will Power” emails that will help you make and actually keep your promises and achieve greater business success this year, go to http://www.mj-ryan.com
Back to HR Article Directory
“I will get my desk organized once and for all.”
“I’ll have better work/life balance.”
“I’ll start that business I’ve always dreamed about.”
At some point we’ve all vowed to make some big change – similar to the resolutions above. But by the time the rosy blush of good intentions wears off, the resolution gets pushed aside. Not because we don’t still long to have what we want, but because we just don’t know how to change.
Changing your behavior takes work.
Our brains have enormous “plasticity,” meaning they can create new cells and pathways. But our brains create strong tendencies to do the same thing over and over.
Here’s why:
The brain cells that fire together wire together. Meaning, they have a strong tendency to run the same program the next time. That’s why lasting change takes lots of practice; you’ve got to create a pathway to the new options.
According to many brain scientists it can take six to nine months to change your behavior. Yet people continue to waste so much money on those seven-day miracle programs and then wonder why they have not experienced lasting change and greater success at work.
Here’s The Top 3 Reasons Why Many Business Entrepreneurs and Executives Fail To Change Their Behavior & Achieve Greater Business Success:
1. They’ve not yet realized that the change process is not about getting rid of bad habits. The pathway to your current behavior is there for life. Instead you want to focus on creating new, more positive habits that will positively affect your business. Even stopping doing something, like procrastinating, is really about creating a good new habit, starting sooner.
2. They fail to put external reminders in place, at least in the beginning. Unless you have a trigger from the outside like an email reminder, or a buddy it’s very likely you’ll keep defaulting to the old behavior because it’s automatic. That’s also why it’s so important to be willing to start over no matter how often you blow it or get discouraged.
3. They’re not concrete enough about what they want and are unrealistic about what they can reasonably ask themselves to change. Here’s what an executive client of mine said he wanted to change in three months: “to be more positive with co-workers, staff and colleagues, to be more creative and productive and to take better care of myself.” “How about create world peace while you’re at it?” I replied. “And what does `more’ mean anyway? As this client demonstrated, we expect too much of ourselves and we expect to change overnight. When that doesn’t happen, we resign ourselves to staying the same, convinced that we are hopeless, weak, or unmotivated. Which makes us even more stuck in a rut.
To truly change your behavior and achiever greater business success requires three things: desire, intent, and persistence. You have to identify what you desire enough to be willing to stick to. You have to make SMART goals (Specific, Measurable, Achievable, Relevant and Time-bound) like “leave the computer at the office and don’t look at the Blackberry after 9” rather than “having more balance”. You need determination and persistence to try again no matter how many times you blow it. Most importantly you need to avoid my top 10 common resolution pitfalls.
My Top 10 List of Resolution Pitfalls
1. Being vague about what you want
2. Not making a serious commitment
3. Excuse-making—no time, wrong time, dog ate homework 4. Unwilling to go through the awkward phase 5. Not setting up a tracking and reminder system 6. Expecting perfection and falling into guilt, shame, and regret 7. Trying to change by yourself 8. Telling yourself self-limiting rut stories 9. Not having backup plans 10. Turning slip-ups to give-ups
Armed with a new attitude and behavior, you can create lasting change and achieve greater success at work. When you have this invaluable tool in your arsenal, you’ll be empowered to bring anything you want into reality. You’ll become the master of your fate rather than the victim of old choices.
bio: M.J. Ryan is an executive coach and the author of THIS YEAR I WILL…How to Finally Change a Habit, Keep a Resolution or Make a Dream Come True. To receive a ton of free resources including free daily “I Will Power” emails that will help you make and actually keep your promises and achieve greater business success this year, go to http://www.mj-ryan.com
bio: M.J. Ryan is an executive coach and the author of THIS YEAR I WILL…How to Finally Change a Habit, Keep a Resolution or Make a Dream Come True. To receive a ton of free resources including free daily “I Will Power” emails that will help you make and actually keep your promises and achieve greater business success this year, go to http://www.mj-ryan.com
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