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Certain claims may be asserted before the Kansas Department of Labor and Industrial Relations, the Kansas Human Rights Commission, and in some instances, local agencies. Most claims may be asserted in courts of general jurisdiction, although certain claims must first be presented to the appropriate administrative agency.


The Main Sources Of Employment Law

Common law, state statutes, and state regulations are the main sources of employment law in Kansas. Major state employment statutes include the Kansas Act Against Discrimination (Kan. Stat. Ann. §44-1001 et seq.), Kansas Age Discrimination in Employment Act (Kan. Stat. Ann. §44-1111 et seq.), the Kansas Wage Payment Law (Kan. Stat. Ann. §44-313 et seq.), and the Kansas Workers’ Compensation Law (Kan. Stat. Ann. §44-501 et seq.). Individual contracts (whether written or oral) and collective bargaining agreements may also govern the employment relationship.


National Law And Employees Working For Foreign Companies

State law applies to all individuals physically working in the state. Federal law and, in some instances, a national treaty with a foreign government may also apply. The parties may contractually agree to apply a different state’s law in some circumstances.


National Law And Employees Of National Companies Working In Another Jurisdiction

State law applies only when the employee is physically working in the state or when both parties have agreed in writing to the application of Kansas law.


Data privacy

An employer that monitors employees’ personal phone calls without notifying them could be found liable for intrusion on seclusion under Kansas law. (Ali v. Douglas Cable Communications, 929 F. Supp. 1362 (D. Kan. 1996). Kansas does not have a general privacy act pertaining to employees.

Legal Requirements As To The Form Of Agreement

There are no legal requirements regarding the form of an employment agreement, and employment agreements are not required.


Mandatory Requirements
  • Trial Period
  • There is no legal requirement to provide trial periods (also referred to as “probationary periods” or “introductory periods”). The terms of a collective bargaining agreement may apply.

  • Hours Of Work
  • There is no restriction on the number of hours employees may be required to work, except for children. However, employees who are non-exempt under federal wage and hour laws are entitled to overtime pay at a rate of one and one-half times the regular rate of pay for all hours worked over 40 in a workweek. Under Kansas law, non-exempt employees are entitled to overtime pay for all hours over 46 in a workweek (Kan. Stat. Ann. §44-1204). The terms of a collective bargaining agreement may also apply.

  • Special Rules For Part-time Work
  • Any employee working less than 40 hours per week is considered an employee on an occasional or part-time basis. (Kan. Stat. Ann. §44-1202 et. seq.). Students 18 years of age and under working between academic terms shall be considered part-time employees regardless of the number of hours worked.

  • Earnings
  • All non-exempt employees must be paid the federal or state minimum wage, whichever is higher, for all hours worked (Kan. Stat. Ann. §44-1203). Exempt employees must be paid certain minimum weekly salaries or fees in accordance with federal law. The terms of a collective bargaining agreement may also apply.

  • Holidays/Rest Periods
  • There are no statutory provisions regarding holidays and rest periods. The terms of a collective bargaining agreement may apply.

  • Minimum/Maximum Age
  • The minimum age for most jobs is 14 years old. Children under the age of 14 are allowed to work only in certain industries. Certain federal and state rules apply to the employment of children under the age of 16 (Kan. Stat. Ann. §38-601 et seq.). There are no maximum age limits. The Kansas Age Discrimination in Employment Act prohibits discrimination on the basis of age for individuals age 40 or older (Kan. Stat. Ann. §44-1111 et seq.). The terms of a collective bargaining agreement may also apply.

  • Illness/Disability
  • There are no statutory provisions regarding illness or disability, such as paid leave. However, federal and state law impose specific anti-discrimination and leave requirements for employees with a disability or serious medical condition. The terms of a collective bargaining agreement may also apply.

  • Location Of Work/Mobility
  • There are no statutory provisions regarding location of work or mobility.

  • Pension Plans
  • There are no statutory provisions regarding pension plans. Federal law may apply.

  • Parental Rights (Pregnancy/ Maternity/ Paternity/ Adoption)
  • There are no statutory provisions regarding pregnancy, maternity or adoption benefits; however, state non-discrimination requirements apply. Federal leave requirements and the terms of a collective bargaining agreement may also apply.

    The Family Medical Leave Act (“FMLA”), 29 U.S.C. § 2601, et seq., a federal statute, provides eligible employees who work for a covered employer with up to 12 weeks of leave in a one year period for one or more of the following reasons: birth or care of new-born child of employee, placement with employee of an adopted child or child in foster care, care of an immediate family member (spouse, child, or parent) with a serious health condition, medical leave when employee is unable to work because of his or her own serious health condition or for certain qualifying military exigencies. An employee who actually has day-to-day responsibility for caring a child may be entitled to leave regardless of biological relationship with the child, this includes a person standing in loco parentis. In addition, the FMLA provides eligible employees with up 26 weeks of leave during a single 12-month period to care for a spouse, son, daughter, parent or next of kin who is a member of the Armed Forces.

    A “covered employer” employs 50 or more employees during the current or proceeding calendar year within a 75-mile radius. An “eligible employee” is an employee who has worked for a covered employer for a total of 12 months, has provided at least 1,250 hours of service during the 12-month period immediately preceding the commencement of leave,and works at a location where the employer has at least 50 employees within 75 miles.

  • Compulsory Terms
  • There are no compulsory terms that must be included in an employment agreement.

  • Non-Compulsory Terms
  • The employer and employee may agree to any terms, provided that the terms do not abrogate statutory rights (e.g., employees may not agree to compensation less than the minimum wage or waive their right to overtime compensation).


Types Of Agreement

Employers and employees may enter into a variety of agreements related to the employment relationship including standard employment agreements (regarding hours, wages, benefits, etc.), confidentiality and non-disclosure agreements, arbitration agreements, non-competition agreements, non-solicitation agreements, etc. Common law and state statutes will determine the enforceability of such agreements.


Secrecy/Confidentiality

There are rules relating to secrecy and confidentiality that are implied in the employment relationship. During the employment relationship, an employee is under a duty of loyalty and must not act contrary to the employer’s interest by, for example, misappropriating trade secrets. The Kansas Uniform Trade Secrets Act regulates the misappropriation of trade secrets both during and after employment (Kan. Stat. Ann. §60-3320 et seq.). Employers and employees may also enter into confidentiality and non-disclosure agreements.


Ownership of Inventions/Other Intellectual Property (IP) Rights

A provision in an employment agreement requiring an employee to assign any of the employee’s rights in an invention may not apply to any invention for which no equipment, supplies, facilities or trade secret information of the employer was used and that was developed entirely on the employee’s own time unless (a) the invention relates to the employer’s business or actual or demonstrably anticipated research or development; or (b) the invention results from any work performed by the employee for the employer (Kan. Stat. Ann. §44-130(a)). Any provision in an employment agreement purporting to apply to such excluded inventions is void and unenforceable (Kan. Stat. Ann. §44-130(b)). An employer may not require such a prohibited provision as a condition of employment (Kan. Stat. Ann. §44-130(b). Federal law may also apply.


Pre-Employment Considerations

Kansas law generally prohibits discrimination in hiring practices. The following are prohibited in preemployment inquiries and practices: inquiries about the birthplace of an applicant or close relative; requiring an applicant to submit a birth certificate, naturalization record, or baptismal record; any requirement or suggestion that an applicant submit a photograph; any inquiry into name and address of any relative of an adult applicant other than spouse or child; any inquiry into an organizational membership that could indicate race, religion, colour, national origin, or ancestry of applicant. (Kan. Admin. Regs. §21-30-17.).

An employer may require a job applicant to sign a release allowing access to that individual’s criminal history record information for purposes of determining the applicant’s fitness for employment. An employer will not be liable for a decision based on such information, provided that the information reasonably bears on the employee’s or applicant’s trustworthiness or the safety or well-being of the employer’s employees or customers. (Kan. Stat. Ann. §22-4710.).


Hiring Non-Nationals

Kansas has no specific law relating to hiring of non-nationals. All employers must ensure, however, that they are in compliance with federal law and that all employees are eligible to work in the United States.

 

Hiring Specified Categories Of Individuals

There are restrictions on the types of work that children may be hired to perform. For example, children under age 14 may not work in any occupation except as provided by the child labor laws, and children under age 18 may not be employed in any occupation declared to be hazardous by the U.S. Secretary of Labor (Kan. Stat. Ann. §38-601 et seq.).

There are specific labor provisions for agricultural employees designed to protect agricultural workers. These provisions permit freedom of association, self-organization, and designation of representatives of their own choosing (Kan. Stat. Ann. §44-818 et seq.).


Outsourcing And/Or Sub-Contracting/Temporary Agency Work

There are provisions within the Kansas Workers’ Compensation Laws regarding responsibility for workers’ compensation when an employer has subcontracted for work (Kan. Ann. Stat. §44-503). The terms of a collective bargaining agreement may also apply.

Changes To The Contract

Changes to an employment contract are generally governed by the contractual terms and common law.


Change In Ownership Of The Business

There are no statutory provisions regarding change in ownership of the business. Contractual provisions and federal law may apply.


Social Security Contributions

Employers and employees are both required by federal law to make social security contributions. Employing units doing business in Kansas are subject to the provisions of the Employment Security Law. However, not all employing units are subject to the taxing provisions of the law. Coverage is determined by the type and nature of the business, the number of workers employed, and the amount of wages paid for services in employment. Employers may also be required to pay for workers’ compensation insurance (Kan. Stat. Ann. §§44-703 et seq., 44-501 et seq.).


Accidents At Work

Employee injuries occurring at work are governed by the Kansas Workers’ Compensation Law (Kan. Stat. Ann. §44-501 et seq.). Employers may also be responsible under common law for accidents caused by the acts of their employees where the employees were acting within the scope of their employment. Federal law may also apply.


Discipline And Grievance

A memorandum of agreement between public employers and employees may contain a grievance procedure and may provide for the impartial arbitration of any disputes that arise on the interpretation of the memorandum agreement. Such arbitration shall be advisory or final and binding, as determined by the agreement, and may provide for the use of a fact-finding board. The public employee relations board is authorized to establish rules for procedure of arbitration in the event the agreement has not established such rules. In the absence of arbitrary and capricious rulings by the fact-finding board during arbitration, the decision of that board shall be final. Judicial review shall be in accordance with the act for judicial review and civil enforcement of agency actions (Kan. Stat. Ann. §75-4330).

Class action waivers in arbitration agreements between employers and employees are enforceable. An employer can rescind an employment offer if a prospective employee refuses to sign an arbitration agreement. An employer can fire an at-will employee who refuses to sign an arbitration agreement.

There are no statutory provisions regarding discipline and grievances for private employers. A collective bargaining agreement or other contract may apply.


Harassment/Discrimination/Equal pay

The Kansas Act Against Discrimination prohibits job discrimination on the basis of race, religion, color, sex, disability, national origin, or ancestry (Kan. Stat. Ann. §44-1001 et seq.). The law also bars discrimination based on an employee’s or a prospective employee’s genetic screening or testing information. The law applies to employers of four or more workers and to those acting for an employer or employment agency, labor organization, and the state and its political subdivisions. Non-profit fraternal or social organizations are exempt. Kansas also prohibits job discrimination on the basis of HIV infection (Kan. Stat. Ann. §65-6001 et seq.). The Age Discrimination in Employment Act protects individuals aged 40 or older from discrimination on the basis of their age (Kan. Stat. Ann. §44-1111 et seq.). The Kansas Equal Pay Law prohibits employers from paying females a wage rate less than the wage rate paid to male employees who perform the same quantity and quality of the same classification of work (Kan. Stat. Ann. §44-1205).


Compulsory Training Obligations

There are no statutory provisions regarding compulsory training obligations.


Offsetting Earnings

Employers may deduct from an employee’s wages if (1) the employer is permitted by state or federal law; (2) the deductions are for medical, surgical, or hospital care, do not financially benefit the employer, and are clearly recorded in the employer’s books; (3) the employer has signed authorization from the employee for deductions accruing to the benefit of the employee; or (4) deductions are for contributions to a retirement plan.

Pursuant to a signed, written agreement, an employer may deduct from an employee’s wages to (1) allow the employee to repay a loan or advance from the employer, made to the employee within the scope of employment; (2) recover payroll overpayment; and (3) compensate the employer for the replacement or unpaid cost balance of the employer’s merchandise or uniforms purchased by the employee. Upon written notice and explanation, an employer may deduct from an employee’s final wages to (1) recover the employer’s property provided to the employee in the course of business; (2) allow the employee to repay a loan or advance from the employer, made to the employee within the scope of employment; (3) recover payroll overpayment; and (4) compensate the employer for the replacement or unpaid cost balance of merchandise, uniforms, property, equipment, or other materials the employee intentionally purchased from the employer (Kan. Ann. Stat. §44-319). These deductions cannot reduce an employee’s wages to below the minimum wage required by federal or state law. Deductions from wages for garnishments must also comply with state and federal requirements (Kan. Stat. Ann. §§60-730, 60-734, 60-2310, 60-2310).


Payments For Maternity And Disability Leave

There are no statutory provisions regarding payments for maternity and disability leave.


Compulsory Insurance

Kansas employers with gross annual payroll for the preceding calendar year of more than $20,000 must carry workers’ compensation insurance. The Kansas Workers’ Compensation Act does not cover private employers engaged in agricultural pursuits and employments incident thereto (Kan. Stat. Ann. §44-505).


Absence For Military Or Public Service Duties

Employees returning from leave must be restored to a position and must have the same status in employment as they would have enjoyed if they had remained in their employment continuously from the time they were called to state duty until the time of restoration to such employment. Any person called to active duty by the state, whether by the Kansas National Guard, Kansas Air National Guard, Kansas State Guard, or other state military force, who gave notice to the employer of the call-up, is entitled to reinstatement upon satisfactory performance of military duty and release from such duty. The individual must report to the place of employment within 72 hours of release from duty or recovery from disease or injury resulting from the duty. If the person is no longer qualified to perform the duties of the position because of disability sustained during the period of state duty but is qualified to perform another job offered by the employer, the person shall be reemployed in a position that will provide like seniority status and pay, or the nearest approximation thereof consistent with the circumstances.

A person restored to employment following state duty is considered to have been on temporary leave of absence and shall be restored without loss of seniority. The person also shall be entitled to participate in any benefits offered by the employer pursuant to established rules and practices relating to employees on leave of absence. An individual restored to employment cannot be discharged without cause within one year after restoration to the position. It is a misdemeanour for an employer to refuse permission to a guard member to attend drill or annual muster or to perform active service when ordered. An employer that refuses leave or discharges or disciplines an employee for being absent in order to perform military duty is subject to a fine of $5 to $50 for each offense (Kan. Stat. Ann. §§48–222 and 48–517). Federal law may also apply.

Employers may not discharge, threaten to discharge, intimidate, or coerce any permanent employee because of an employee’s attendance or scheduled attendance on jury duty. An employee reinstated after jury duty is treated as having been on furlough or leave of absence during the period of jury service. The employee is to be reinstated without loss of seniority and is entitled to participate in insurance or other benefits offered by the employer. An employer who violates the jury leave provisions is liable for damages from any loss of wages and actual damages suffered by the employee. The employer shall be ordered to reinstate the employee and may be enjoined from further violations and ordered to provide appropriate relief (Kan Stat. Ann. §43–173).

Any eligible voter is allowed 2 consecutive hours to vote in all elections while the polls are open. The employer may specify the particular time during the day for voting, but not during any lunch period.


Works Councils or Trade Unions

Kansas employees shall have the right to self-organization, to form, join, or assist labor organizations, to bargain collectively through representatives of their own choosing, and to engage in concerted activities, for the purpose of collective bargaining or other mutual aid or protection, and such employees shall also have the right to refrain from any or all such activities (Kan. Stat. Ann. §44-803).

Public employees shall have the right to form, join and participate in the activities of employee organizations of their own choosing, for the purpose of meeting and conferring with public employers or their designated representatives with respect to grievances and conditions of employment. Public employees also shall have the right to refuse to join or participate in the activities of employee organizations (Kan. Stat. Ann. §75-4324).

Agricultural employees shall have the right to form, join and participate in the activities of employee organizations of their own choosing, for the purpose of meeting and conferring with agricultural employers or their designated representatives with respect to grievances and conditions of employment.

No agricultural employee may be required to join an employee organization as a condition of his employment, and every agricultural employee shall have the right to refuse to join or participate in the activities of employee organizations (Kan. Stat. Ann. §44-821). Federal law may also apply.


Employees’ Right To Strike
    1. Private Sector Labor Relations.
    2. Kansas recognizes the right of employees to strike; however, certain strikes, including recognitional strikes, are illegal. Employers are prohibited from interfering with or impeding or diminishing in any way the right to strike or the right of individuals to work. Further, employers shall not invade unlawfully the right to freedom of speech (Kan. Stat. Ann. §44-813). Federal law may also apply.

    3. Public Sector Labor Relations.
    4. It shall be a prohibited practice for public employees or employee organizations wilfully to engage in a strike (Kan. Stat. Ann. §75-4333).

    5. Agriculture Labor Relations.

Employees On Strike

Employers are prohibited from interfering with or impeding or diminishing in any way the right to strike or the right of individuals to work. Further, employers shall not invade unlawfully the right to freedom of speech (Kan. Stat. Ann. §44-813).


Employers’ Responsibility For Actions Of Their Employees

Under the doctrine of respondeat superior, an employer may be liable for the negligent acts or omissions by an employee that are committed within the course and scope of employment. Employers may also be liable for negligent hiring and/or retention where the following elements are met: (1) the employer knew or should have known of an employee’s dangerous proclivities; (2) the employee was hired (or retained in employment); (3) the employer’s negligent act or omission was the proximate cause of an injury sustained by the plaintiff at the hands of the employee; and (4) the employee’s misconduct was consistent with the employee’s dangerous proclivity. For this claim, it is not necessary that the offending conduct occur within the course and scope of employment.

Procedures For Terminating the Agreement

There are no statutory provisions regarding procedures for terminating an employment agreement. Unless an employment contract with a specific term applies, the employment relationship is at-will and may be terminated at any time. An employment contract or collective bargaining agreement may specify termination procedures.


Instant Dismissal

There are no statutory provisions regarding procedures regarding instant dismissal of an employee. Unless an employment contract with a specific term applies, the employment relationship is at-will and may be terminated at any time. An employment contract or collective bargaining agreement may contain notice requirements.


Employee's Resignation

There are no statutory provisions regarding employee resignation. An employment contract or collective bargaining agreement may specify resignation procedures.


Termination On Notice

There are no statutory provisions regarding termination on notice. An employment contract or collective bargaining agreement may contain notice requirements.


Termination By Reason Of The Employee's Age

The Kansas Age Discrimination in Employment Act prohibits discrimination in employment on the basis of age (40 or more years of age). This provision applies to employers with four or more employees (Kan. Stat. Ann. §44-1111 et seq.). Federal law may also apply.


Automatic Termination In Cases Of Force Majeure

Kansas has no statutory provisions regarding termination in cases of force majeure.


Collective Dismissals

There are no statutory provisions regarding collective dismissals. Terms of a collective bargaining agreement may apply.

However, when two (2) or more employees are terminated on the same day or within a short period of time for the same reason, such as with a reduction in force, the OWBPA requires employers to include specific language in any severance agreement offered to employees if at least one of them is aged 40 years or older, and a waiver of rights is included. Specifically, the employees that are 40 or older must be given up to 45 days to consider the severance agreement (instead of 21 days), and the employer must provide specific information related to the “decisional unit” of the company affected by the terminations (including ages and positions).


Termination By Parties’ Agreement

The parties are free to terminate the employment relationship on any grounds they desire, except for unlawful reasons proscribed by federal, state or local law.


Directors Or Other Senior Officers

There are no statutory provisions regarding termination of directors and officers. An employment contract may apply and contain termination procedures. The termination of employment does not automatically terminate board membership. Separate steps, generally set forth in the bylaws or articles of incorporation/organization, are required to terminate board membership.


Special Rules For Categories Of Employee

There are no statutory provisions regarding the termination of certain categories of employees; however, termination decisions must comply with the anti-discrimination provisions of the Kansas Act Against Discrimination and the Kansas Age Discrimination in Employment Act.


Whistleblower Laws

A public employer cannot prohibit an employee from discussing the agency’s operation with member of legislature, reporting violation of state or federal law, rules or regulations or require prior notice to making a report. (Kan. Stat. Ann. §75-2973).

There are no statutory provisions applying to private employees. The False Claims Act, Sarbanes-Oxley Act, and other federal laws may apply.


Specific Rules For Companies in Financial Difficulties

There are no statutory provisions regarding companies in financial difficulty. Federal bankruptcy law, the Employee Retirement Income Security Act, the Worker Adjustment and Retraining Notification Act, and other federal laws may apply.


Special Rules For Garden Leave

There are no statutory provisions regarding garden leaves.


Restricting Future Activities

Contracts preventing a former employee from engaging in ordinary competition are unlawful in Kansas. However, reasonable non-competition and non-solicitation agreements are permitted between employers and employees in order to protect a legitimate business interest. “Legitimate business interests” include: (1) customer contacts, (2) customer relationships, and (3) trade secrets. The agreement must be reasonable in both duration and geographic scope and must be supported by consideration (at-will employment or a change in conditions or terms of employment that amounts to additional consideration for the agreement constitutes sufficient consideration under Kansas law). The agreement must not create an undue burden on the employee and must not be injurious to the public welfare. Enforceability of restrictive covenants is determined on a case-by-case basis. Agreements that prohibit disclosure of confidential information are generally enforceable. If a court finds that an agreement is too broad, the court has the power to modify the agreement to the extent necessary to make it reasonable.


Severance Payments

There are no statutory provisions regarding or requiring severance payments. Severance payments are not required unless the employer and the employee have a contract providing for severance. There are specific rules governing the validity of a release provided in exchange for severance payments.


Special Tax Provisions And Severance Payments

Severance payments are taxed in the same way as other wages.

Federal law may also apply.


Allowances Payable To Employees After Termination

Employees may be entitled to unemployment benefits after termination of employment so long as they meet certain requirements (Kan. Stat. Ann. §§44-701 et seq.).


Time Limits For Claims Following Termination

Statutes of limitation vary depending upon the nature of the claim.

For example, any claim for employment discrimination or harassment filed under the Kansas Act Against Discrimination (KAAD) must be filed with the Kansas Human Rights Commission (KHRC) within 180 days of the alleged violation (i.e. 180 days from the date of the adverse employment action that provides the basis for a claim). (Kan. Stat. Ann. § 44-1005(h)(1)). Claims stemming from violations of federal law, such as Title VII claim, must be filed with the Equal Employment Opportunity Commission (EEOC) within 300 days from the alleged violation 42 U.S.C.A. § 2000e-5.

Specific Matters Which Are Important Or Unique To This Jurisdiction

Job Reference

Employers cannot be held civilly liable for disclosing a former employee’s dates of employment, pay level, job description and duties, and wage history to a prospective employer. An employer that responds in writing to a prospective employer’s written request for information about a former or current employee also has immunity from civil liability for disclosing: (1) written evaluations conducted before the employee left the company (the employee is entitled to receive a copy of such evaluations upon request); (2) whether the employee was voluntarily or involuntarily released from service; and (3) the reasons for the separation (Kan. Stat. Ann. §44–119(a)).

If the polls are open before or after the employee’s scheduled work time, the employee is entitled to be absent from his or her employment only for such a period of time that when added to the time the polls are open, provided the time period does not exceed 2 hours. Deduction from wages or salary or other penalty against any eligible voter who participates in a general, primary and special election, whether federal, state, or local, is prohibited. Obstruction of voting privilege is a class A misdemeanour (Kan. Stat. Ann. §25–418).

Service Letter

An employer must provide a service letter stating the employee’s length of employment, occupational classification, and wage rate upon a terminated employee’s request. (Kan. Stat. Ann. §44-808).

Blacklisting

An employer cannot take any actions to prevent a discharged employee from obtaining employment elsewhere. The employer may, however, on request, supply a written statement giving the reason for discharge (Kan. Stat. Ann. §44-117).

Health Insurance Continuation

Kansas law requires employers with fewer than 20 employees to offer health insurance continuation upon a qualifying event for 18 months so long as the employee and eligible dependents have been covered by such health insurance for at least 3 continuous months (Kan. Stat. Ann. 44-2209).



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Mary Kathryn Curry
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© 2021, Polsinelli PC. All rights reserved by Polsinelli PC as author and the owner of the copyright in this chapter. Polsinelli PC has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this Guide.

The information in the How to Hire and Fire Guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: June 2021