Yearly Archives: 2015

Effective Communication in the Workplace.

Employees and the people on the ground in general, are an invaluable source of information for employers. Whether it is positive or negative, employees can provide a whole host of important feedback for your business - if you take the time to listen to and interpret their comments they can be a real asset to you. Effective Communication Conducting regular meetings between employees and managers is a good way to keep lines of communication open. However, sometimes people are reluctant to speak out in an open forum, particularly where they have something negative to say or where they have an issue involving someone else who is included in the meeting. Employee surveys are an ideal way for employees to share their opinions about their job and work environment etc. Confidential surveys tend to encourage honesty and can prove to be of great assistance to employers. Employee participation should be encouraged. Employees will feel as though their input is valued if attention is paid to their suggestions/recommendations. If action is taken by the employer as a result of employee opinions, morale amongst workers can be increased and relationships between the employer and their employees can be drastically improved. This has a positive effect on productivity. Similarly, as employees leave the company; an exit interview should be carried out. This can be very beneficial for the employer as it can, for instance, give the employer an insight in to the reasons behind the employee’s departure. It can also highlight other issues that exist within the business – issues that management may not necessarily already be aware of. It can also reveal what is working well and where resources should be focused. People tend to be more open and honest about what they are feeling when they know that divulging the information will not have any negative bearing on them. Not asking the opinion of a departing employee is a wasted opportunity. It is important to give employees the opportunity to elaborate on their answers and to encourage them to give you as much information as possible – the more information that they impart the better. Leave an additional space for them to comment on issues that you may not have thought to include. Here are some examples of questions that should be included in an exit interview:

  • How long were you employed by the company?
  • Were you in a supervisory role?
  • Were you a full-time or part-time employee?
  • Did you resign or was your employment terminated? If other, please explain.
  • If you resigned, what were your reasons for leaving the company? Please list all reasons. (E.G: Geographical Location, Family Circumstances, Career Development etc.)
  • If you left for a new position, was the salary offered greater than your salary here? If so, please reveal the approximate percentage difference.
  • Can you explain why the new position (if relevant) was more desirable than your position here?
  • What might have motivated you to remain in your current position? (E.G: Improved Benefits, More Time-Off, Less/More Travel, Promotional Opportunities etc.)
Exit Survey
  • What impacted your decision to leave the company? (E.G: Lack of Equipment/Information, Work that did not Challenge, Too much/Too little work, Pressure, Remuneration/Benefits, Other Personnel, Relationship with Supervisor/Co-workers, Morale, Teamwork, Goals, Harassment, Organisational Structure, Physical Environment etc.)
  • Can you please tell us about your positive experiences with the company? (E.G: Benefits, Hours, Facilities, Your Supervisor, Co-Workers, Personnel Practices/Policies, Physical Environment/Work Area, Development Opportunities, Level of Support etc.)
  • Do you feel as though you received adequate consideration for positions that you applied for? Please explain your answer.
  • Do you feel as though your work was fairly evaluated through performance reviews during your employment? Please explain your answer.
  • Do you feel as though your monetary recognition was in line with your performance? Please explain your answer.
  • Was the frequency/level of your recognition appropriate? Please explain your answer.
  • Do you feel as though you received adequate training for your position and the duties you were required to carry out? Please explain your answer.
  • Did you have adequate resources, equipment, support and information to carry out your job well? Please explain your answer.
  • Was your work environment free of sexual, religious, age and/or racial discrimination? If no, please explain in detail.
  • Were you satisfied with the quality and quantity of feedback received from your supervisor about your performance? Please explain your answer.
  • Were you kept well informed on what was expected of you in the workplace? Please explain your answer.
  • Did you feel free to discuss your career development with your supervisor? Please explain your answer.
Idea Generation Arrange Consultation    
By |2017-01-02T11:00:08+00:00June 17th, 2015|Communication|0 Comments

Equality Officer Awards €40,000 in Gender Discrimination Case

Equality Officer Awards €40,000 to Anne Delaney in response to complaint made against the Irish Prison Service. Discrimination, Compensation Anne Delaney took a case against the Irish Prison Service because she was discriminated against by her employer on the grounds of gender in relation to promotion, training and conditions of employment. In 2011, Ms. Delaney referred a complaint against her employer under the Employment Equality Acts 1998 to 2008 to the Equality Tribunal. She alleged that the Irish Prison Service discriminated against her on grounds of gender when she applied for numerous posts over several years. Junior or less suitable/less experienced male candidates were appointed to the roles ahead of Ms. Delaney on all occasions.   Gender Discrimination, Equality Tribunal  

After reviewing all of the submitted evidence, the Equality Officer was satisfied that the complainant, Ms. Delaney, had established a link between the incidents that she complained about. The Equality Officer considered the incidents as separate manifestations of the same disposition to discriminate. The Equality Officer criticised the lack of transparency stating that she was unsure of the fairness of the selection procedures that were followed. There were no marking schemes available for review and no records to help her to assess what grounds the hiring decisions were based on. It also became apparent that the same senior personnel were involved in the selection process for all posts.

Gender Discrimination, Compensation

The Equality Officer’s investigation of the complaint concluded that the Irish Prison Service discriminated against Ms. Delaney on gender grounds when she applied for a gym instructor course in 2001, when she applied for an Operational Support Group post in 2009, when she was asked to step down from the post of Acting ACO in August 2010 and again in September 2010 when she applied for an allowance carrying post in the Detail Office.

As a result of her findings the Equality Officer tasked with making the decision on the case ordered that Ms. Delaney be appointed to the position of Acting ACO, and placed on the permanent roster for that position. The Equality Officer backdated this appointment to the 5th of August 2010 and ensured that all consequential employment rights and entitlements, including remuneration and recognition of service, were upheld.

Gender Discrimination resized 600The Equality Officer found that Ms. Delaney had been subjected to discrimination on the grounds of her gender on numerous occasions during her career with the Irish Prison Service. The Equality Officer considered a compensatory award of €40,000 to be just and equitable in response to the distress suffered by Ms. Delaney as a result of the discrimination that she suffered. The Equality Officer felt as though €40,000 was a proportionate, effective and dissuasive sum to award. That component of the award was not in the form of remuneration and, consequently, was not subject to the PAYE/PRSI Code.

The Equality Officer found that the Irish Prison Service’s selection process for the allowance carrying post in the Detail Office (a post applied for by Ms. Delaney in September 2010) was deficient and non-compliant with Equality Legislation. The Equality Officer ordered that the Irish Prison Service ensure that a fair selection process be adopted in all future selections. She also ordered that the selection panel must be trained in the process and that it must set down the criteria in writing before embarking on the selection process. The Equality Officer also ordered that a marking scheme must be adopted and that the weighting should be given under each element. She also directed that notes must be retained for future reference.

DEC-E2013-155

DECISION NO: DEC-E/2013/155

Anne Delaney Vs Irish Prison Service

FILE NO: EE/2011/292

DATE OF ISSUE: 19th of November, 2013 Letu0026#39u003Bs Chat

By |2017-01-02T11:00:14+00:00June 17th, 2015|Compensation|0 Comments

Pension Obligations of Irish Employers

No matter how big or how small your company may be – or whether your employees are part-time, seasonal or fixed-term - every Irish employer is obliged to enter into a contract with a PRSA provider and to provide access to at least one standard PRSA for all ‘excluded employees’.

What are ‘excluded employees’? Employees are considered to be ‘excluded employees’ if:
  • their employer does not offer a pension scheme, or
  • they are included in a pension scheme for death-in-service benefits only, or
  • they are not eligible to join the company’s pension scheme or will not become eligible to join the pension scheme within six months from the date they began working there, or
  • they are included in a pension scheme that does not permit the payment of additional voluntary contributions (AVCs).
  Pensions, Employer Responsibilities   Even if there is only one ‘excluded employee’, an employer must:
  • enter into a contract with a PRSA provider (there is no charge for doing this)
  • provide employees with access to a Standard PRSA
  • allow reasonable paid leave of absence, subject to work requirements, so that excluded employees can set up a  Standard PRSA
  • make deductions from payroll if required
  • advise employees in writing (normally on their payslip) at least once a month of their total contribution, including employer’s contribution, if any.
What an Employer is NOT responsible for:
  • You’re not obliged to give any advice to employees in relation to PRSAs, but you must allow your PRSA provider or intermediary reasonable access to your employees to brief them on PRSAs.
  • You don’t have to contribute to PRSAs on behalf of your employees, but if you decide to do so, your contributions must be paid to the PRSA provider within 21 days of the end of the month in which the employer contributions are due. And please note that you cannot make any deductions from this payment.
  • You are not responsible for the investment performance of PRSAs
What are the consequences of non-compliance? Be aware that there are significant penalties for failing to discharge your obligations.  The Pensions Board will issue on-the-spot fines and prosecute any employers found in breach of theobligations, so it pays to get it right. As an Employer you may be subject to an on-the-spot fine if: (a)     You fail to respond to a request by The Pensions Board to furnish information about their provision of access to a Standard PRSA for ‘excluded employees’ and (b)     You do not provide at least a monthly statement to employees showing contributions deducted and employer contributions paid in the previous month. The bottom line is that this is not an issue that you can afford to get wrong. To find out more about your obligations, there’s a very helpful booklet on the Pension Board’s website.

IFG have many years of experience of providing Pension Scheme Design & Risk Advisory services to Irish companies. They would be delighted to answer any and all of your pension queries if you would like to find out more www.ifg.ie .

Annual Leave Tracker
By |2017-01-02T11:00:13+00:00June 17th, 2015|Policies & Procedures|0 Comments

Christmas Parties – Advice for Employers

With the Christmas season upon us again many employers will arrange a work-related social event (Christmas party) in order to thank employees for their efforts and hard work over the past year.

Christmas Season, Christmas Parties, Work-Related Social Events

Despite Christmas parties occurring mostly outside of the work place, responsibility still lies with the employer for the protection and safety of their employees.   Each year cases concerning bullying and harassment are brought before the Rights Commissioner and the Equality Tribunal. These incidents can be perpetrated at work-related social events like the Christmas party and the employer is often held liable for such action.  
For the protection of the organisation and to avoid any such issues, below is a list of preventative steps which can be taken:
  • Re-circulate the company’s Dignity at Work policy, which should include reference to bullying, harassment and sexual harassment in the workplace.  This policy should clearly state that work-related social events fall under the terms of this policy.
  • Ensure that it is clearly outlined to employees that they may be subject to disciplinary action leading up to and including dismissal should they be found in breach of the company’s Dignity at Work policy at a work-related social event.
  • Ensure that employees are aware of the company’s Disciplinary and Grievance procedures.
  • Re-circulate the company’s Social Media policy to ensure employees are aware of the rules surrounding publishing photographs online in order to prevent any privacy infringements arising or damage being caused to the company’s reputation.
  • If the event is scheduled on an evening where employees are required to work the following day, ensure employees are aware of the company’s Absence policy.
  • Brief members of Management on the above policies and ensure that they know how to deal with behaviour that could be deemed inappropriate at the event should it arise.
  • Advise Management not to discuss issues relating to salaries, performance or career prospects at the event.
By |2017-01-02T11:00:12+00:00June 17th, 2015|Christmas|0 Comments

Force Majeure Leave in the Irish Workplace

There are several types of leave that an employee may be entitled to. Some forms of leave are statutory entitlements and some other forms are not. Maternity Leave, for instance, must be given to employees when they are pregnant. Some forms of leave are paid and others are not. This can depend on statutory obligations and on the terms and conditions set out in the Contract of Employment. Annual Leave is a statutory entitlement and it must be paid by the employer. Sick Leave, however, is not always paid by the employer (this depends on individual company policies). Force Majeure Force Majeure Leave is less commonly discussed. The purpose of Force Majeure Leave is to provide limited, paid leave to enable an employee to deal with family emergencies resulting from injury or illness of a close family member. Force Majeure Leave applies where the immediate presence of the employee is urgent and indispensable (essential). A close family member is defined as one of the following:

  • A child or adopted child of the employee
  • The husband/wife/partner (same or opposite sex) of the employee
  • A parent/grandparent of the employee
  • A brother/sister of the employee
  • A person to whom the employee has a duty of care (where he or she is acting in loco parentis)
  • A person in a relationship of domestic dependency with the employee
  • Persons of any other class (if any) as may be prescribed
Force Majeure Leave By its nature, an employee will not usually be able to give notice of the need to take Force Majeure Leave. The employee should, however, inform the employer (in writing) of reasons for taking the leave as soon as is reasonable practicable. The employee should provide details regarding the need for the leave and should confirm who the leave was taken in respect of. Employers are obliged to keep a record of Force Majeure Leave taken by employees. Employees will be entitled to: -   up to 3 days paid Force Majeure Leave in any consecutive 12 month period; or -   up to 5 days in a 36 consecutive month period. Absence for part of a day is usually counted as a full day of Force Majeure Leave. Employees are entitled to receive pay for this type of leave. Employers can grant employees more than the number of days outlined above; however, they are not obliged to do so. Employees are protected against Unfair Dismissal for taking Force Majeure Leave or for proposing to take it. Death is not covered under Force Majeure Leave – Leave taken when a death occurs falls under Compassionate Leave and this tends to depend on employee contracts as well as custom and practice within the workplace.
By |2017-01-02T11:00:09+00:00June 17th, 2015|Policies & Procedures|0 Comments

Worker dismissed at probationary period meeting awarded €10k

Labour Court, Unfair Dismissal, ProbationOn 17th September 2013 a former employee of a coach hire company referred his case under Section 20 (1) of the Industrial Relations Act, 1969 to the Labour Court and agreed to be bound by the Recommendations of the Court.

  The case revolved around the alleged Unfair Dismissal of the claimant at his probationary meeting. An employee with less than 12 months’ service cannot avail of the protections offered by the Unfair Dismissals Acts, however, as this particular employee did, employees with less than 12 months’ service can refer a claim under the Industrial Relations Act as the amount of service is irrelevant in these instances. The employee claimed that he was made aware that he was being dismissed at the meeting but stated that no issues about his performance were raised at that time. The employee described how he was denied his right to appeal the decision as his employer either claimed to be “unavailable” or simply “failed to respond” to any correspondence relating to an appeal process. A Labour Court hearing was scheduled for, and took place on, January 10th 2014. The employer, who was notified of the hearing, did not attend and did not appoint any representation to attend on his/her behalf. Given his opportunity to speak, the worker claimed that throughout the course of his probation, he was never told of any issues with his performance. He went on to describe how he was not afforded his right to query why he was dismissed and was not given any opportunity to appeal the decision made by his employers to terminate his employment at that time. As there was no representation on the part of the employer the employee’s claims went uncontested. With the evidence presented to it, the Court decided that the process used in deciding to dismiss the claimant fell short of the standards of fairness that a reasonable employer should exhibit. The Court, satisfied with the evidence of the claimant, ruled that he be compensated in the amount of €10,000. This figure was in full and final settlement of all claims arising from this dismissal. Award, Unfair Dismissal The determination in this case should encourage all employers to ensure that they follow Labour Court approved procedures with extreme care when dismissing an employee - even when doing so during a probationary period. Employers should note from this case that all employees, including those who are dismissed during probation, are entitled to be afforded details of the reasons why they are being let go and should also be offered the right to appeal the decision to terminate. As should be the case all employees, even employees on probation, are entitled to natural justice. Probation Performance Assessment Form
By |2017-01-02T11:00:15+00:00June 17th, 2015|Compensation|0 Comments

How to avoid an unfair dismissal claim when making someone redundant

Redundancy is a minefield if you take chances. You must remember that employees now know their rights better than ever before. They have lived through a time when friends, family and work colleagues have been laid off - there is also a lot of information readily available for them online. Redundancy, Avoiding Unfair Dismissal Employees have picked up a great deal of information about their rights. We say to Employers "your employees know their rights - do you?" Some businesses are now facing into a second phase of redundancies. In that instance, you can be guaranteed that staff know their entitlements even better than they did for the first phase. If you don't follow process, or if you make a false move, it could cost you - you could quite easily end up in the Labour Courts with an Unfair Dismissal case on your hands. Unfair Dismissal cases are very common these days and they are very difficult for employers to win as the onus is on the employer to prove that he or she made the correct choices when letting someone go. Proving that a redundancy, for instance, was necessary is essential - making the position, not the person, redundant is crucial - an employer cannot make an employee redundant and then hire a new staff member to carry out the same tasks the following week. Commissioners will scrutinize every detail and decision and will want to see that the employer has dotted every "I" and crossed every "T". Employers have a 50/50 chance of leaving Labour Court hearings with a large figure to pay out - it is important to remember that a huge number of cases are also settled prior to court proceedings so the odds are heavily stacked against the employer coming away from the Court with no fine on their hands. Unfair Dismissal, Labour Court, Redundancy Without a doubt redundancies can be required to keep a business viable. Employers need to ensure that they make their decisions based on what's best for the business - not because they want to get rid of Danny the storeman who you feel hasn't done a tap for years. Before making people redundant, look at the business overall and see what areas are suffering a downturn, what areas are picking up, and how best you should react to changed circumstances. A Selection Matrix will help to clarify your thoughts and take the personalities out of the decision - and also ensure that no-one can accuse you of using redundancy simply to remove people you don't like from your company. As a business owner or manager, you are entitled to make decisions that make business sense. So establish the logic of any decision before you make it.

By |2017-01-02T11:00:15+00:00June 17th, 2015|Redundancy|0 Comments

Searching Employee Belongings Appropriately

employee searches Many employers have experienced theft by an employee in the workplace and, consequently, need to put certain measures in place in order to protect the profits of the company. It is the policy of some companies to search employees’ personal belongings when they are leaving the work premises. Employers can also reserve the right to search employee lockers and vehicles if this is agreed with the employee in advance.   If the employer wishes to have the option to carry out personal searches then it is crucial that all details surrounding these searches are clearly communicated to the employees in the contract of employment. Employees sign this contract and by doing so agree to the policies and procedures contained therein.  If an employer reserves the right to search an employee’s belongings then he or she must do so in a dignified manner – giving the employee appropriate levels of privacy. There are several significant procedures to observe when performing a personal search. The individual carrying out the search should be in a management position and, in the interest of clarity; the employees should be made aware in advance who it will be. The location of the search is also something that should be considered very carefully – it is important to maintain consistency and to carry out searches in an area that offers privacy to the employee involved. Employees should be notified of the location of the search and, ideally, it should be out of the view of customers and other employees. The shop floor is not appropriate search setting – the canteen is not suitable either. Ideally the area should be covered by CCTV in order to prevent a “he said she said” situation from arising. If this is not possible then a witness should be present so that this scenario is avoided. Either way discretion is of cardinal importance. theft in the workplace As is procedure with airline security screening a male should search a male and a female should search a female, although, as the searches should not involve body contact this is less of a priority. It is essential that the employee is asked to open his or her bag, for instance, and that the person performing the search doesn’t breach privacy by putting their hands into the employee’s bag or on the employee’s person. Employees should be asked politely to remove any suspicious items from their bag for further inspection – the item/items should be placed on a clear surface in order to ensure that there is no confusion over what was actually in the bag. The searching employee (management/security where possible) should never assume that an item has not been paid for. If the item in question was from the store then the employee should be asked to produce a receipt for same. Further action can be taken if the employee cannot furnish proof of purchase. When an employee purchases an item in the store during the working day it is good practice for companies to put in place a policy where the bag is sealed and the receipt is attached to the bag. This removes any ambiguity. Some companies will carry out spot checks on employee belongings rather than checking them on a daily basis – it is vital to be fair and to ensure that the same employees are not targeted all the time. Not following appropriate procedures can lead to employees being awarded large sums of money. 

By |2017-01-02T11:00:20+00:00June 17th, 2015|Policies & Procedures|0 Comments

Average Award in Unfair Dismissal Cases on the Rise

According to the Employment Appeals Tribunal Annual Report 2011 the number of cases annually referred to the Tribunal increased three fold during the Irish economic recession (to a high of 9,458 cases in 2009). The average number of annual referrals before the recession had plateaued at approximately 3,500. Statistics for Unfair Dismissals cases: The average compensation awarded by the Tribunal in Unfair Dismissal cases has risen dramatically in recent years. For the year ended 31st December 2009 the average compensation in Unfair Dismissals cases was €11,476. In 2010 it was €16,064.05 and in 2011 it was €18,047.85. This is a trend that employers really need to pay attention to as large sums of money like this can seriously damage a company. It is crucial to stay up-to-date with employment legislation and to follow appropriate procedures when dealing with employee matters. Employment Appeals Tribunal, EAT, Compensation

By |2017-01-02T11:00:20+00:00June 17th, 2015|Compensation|0 Comments

Why Companies are choosing to Outsource their HR

The number of cases annually referred to the Employment Appeals Tribunal increased three fold during the Irish economic recession and the average compensation awarded by the Tribunal in Unfair Dismissal cases rose from €11,476.00 to €18,047.85 between 2009 and 2011. During this time of economic hardship Employers must pay even closer attention than ever before to their expenditure. Many organisations are forced to downsize and - in this era of increased Employee Litigation - making sure you follow appropriate procedures in redundancy or disciplinary scenarios, for example, is growing in importance. Outsourcing CompaniesIt is at times like these that Companies need to concentrate on their Human Resource functions even more. Some elements of HR, however, can be both complicated and time consuming – an enormous burden on Employers. In recent years the focus has moved towards legal compliance (which can be a minefield with all of the pieces of Employment Legislation currently in operation) and administrative processes that can slow down the productivity of the firm.   For SMEs in particular, it makes a lot of business sense to outsource HR tasks as firms specialising in the field can improve efficiency dramatically. Outsourcing allows Companies to offload work that isn’t part of their core business. It also saves money. At a Company that doesn’t have the funds to hire specialists outsourcing can allow it to gain access to a vendor’s services when required as well as the expertise and wealth of experience that they have accumulated – all at an affordable price. While SMEs don’t have the same number of Employees as larger corporations and multinationals they still require the same HR elements on a smaller scale. For instance, they still need to recruit staff, they still need to abide by the vast array of Employment Laws and still require Employment Documentation (Contracts of Employment etc.).

Although some Companies do it, most SMEs cannot justify spending a large portion of their annual budget setting up a HR department comprehensive enough to incorporate the abundance of skills required to achieve a smooth-functioning, compliant working environment. Consequently, more and more Companies are choosing to outsource operations like HR and are directing vital, scarce, finances and resources towards other core/revenue-generating areas of the business.
On the other hand, some Employers end up trying to balance HR duties in addition to their other responsibilities which can leave opportunities for threats and vulnerabilities to creep in. As time goes by many Employers are realising that assigning a large percentage of their time to one area is not just inconvenient but impractical, too. Juggling all elements of a business without assistance can be extremely difficult and for this reason many Employers are opting for the cost-effective third party route which involves the use of an external HR Company. This gives them enhanced peace of mind and confidence that they are working within the confines of all Employment Legislation. Outsourcing Companies can deal with HR successfully and as a priority so that Employers do not have to concern themselves with the associated time constraints and conflicts. Companies can eliminate exposures they did not even know existed quickly and in a cost-effective manner by availing of the services of a HR Company. HR Outsourcing HR Companies deal with all features of Human Resources comprehensively. They have a base of specialist Employees who are trained and experienced in all areas of Employment Law – meaning they are fully equipped to deal with any Employee Relations issues that arise in the workplace. Engaging the services of HR professionals gives Employers access to a bank of relevant knowledge and experience. HR Companies are well prepared to support or advise SMEs without costing an arm and a leg. They keep up-to-date with all changes in Irish Employment Legislation and are able to offer better support and guidance than the client can attain in-house. Navigating Government regulations can be a draining activity for Employers, - it can be a time consuming and complicated process, however, it is what HR advisors are trained to do. HR firms can do a lot more than you might think – not alone do they have a top-class portfolio of skills, knowledge and experience concentrated in this specific area, they can offer a range of services and support at an extremely affordable price. Some HR Companies provide comprehensive services for as little as €100 per month – Hiring a HR Employee, even on a part-time basis, would cost far in excess of this. Similarly, many Employers currently engage the services of Solicitors to prepare Contracts of Employment and other Employment Documentation – this can also be an extremely costly process. The HR Company Business Photo HR Companies prepare Employment Documentation for their clients and on top of that are there to advise on all individual Employee related issues – discrimination claims, rest and annual leave entitlements, disciplinary and redundancy procedures, dismissals, grievances and much more. Lots of Companies operate outside of office hours and so some HR Companies even provide 24/7 advice lines for their clients meaning a client will never have an anxious wait for an answer. HR firms also provide support to existing HR departments within Companies - the level of service and associated costs are completely dependent on the needs of the individual Company. HR firms are growing in popularity. In the past outsourcing was often a difficult process because of the issues distance can sometimes create. Thanks to the advances in technology, however, dedicated HR experts are only a couple of clicks or a phone call away – so Human Resource emergencies can be dealt with on the spot.
By |2017-01-02T11:00:21+00:00June 17th, 2015|Adoptive Leave|0 Comments
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