UNITED STATES OF AMERICA — DO NGF WATE WWE BRACE renee NATIONAL LA3OR RELATIONS BOARD. ——= ‘CHARGE AGAINST EMPLOYER ime perrne wstRucTions: ——— RSTRUCTIONS crs grESTDEREIS oie WNEE WA LGGRI TIO GBS IER SC CUTET TT BTR 1 Type of Erablstmere fockn, ine, whales, °*) Hospital Health Care Services fe narecteromer | 413-794-7870 [Baystate Franklin Medical Center went | | [5 Aaaions (abw0r oly, Sat, ZIP Coe) ik Enpiayer Resreswniatve——=~S*| «Ct FaxNow | lea High Steet Iketry Damon, Senior Diector| gen | |Gresnfield, MA.01901 jof Labor & Employee Relations “carry damon@baystatehealth. l ea T ieently principal produd or manic fy Number of workers employed Unknown a pracces whine meaning of Seton a}, suboactons i J sit seston) tbee pracioes ave uni pacts afccing Gonmarce wie the maring ta Act | seas a Chip ales 6 Der ance Bao i arg wpe wi” HOP. SEE ATTACHMENT A INotas | Oana Simon, by any ss ‘counsel: Alan J. McDonald, McDonal [Ramp Road Suis 210" Soumoorouh MA | |S Futnene of party fling Charge [fader crpganzaton, gre ful meme, inauding local nar ard num: iMassachusetts Nurses Association ‘4c, Call No. |i nas ero ao Si TPCT Wi Fesho fee Canton Corporate Center, 340 Turnpike Street, 2d Floor Canton, MA 02021 fa Farner araeeansror errata GORI O WHER HTS a GTS oF ERT OT |. The nbove-names emeloyer hes ergaged in anc s engaging in wnt abot (3) (5)_ ‘!tna Novonal aber Relauons Act and hese untae nature at the bottom of this ULP request and authorize you to send all notices peri I$ Lamond Canzoneri 352 ims ULP directly tothe atenuon of MNA'S 1177251 756 Telephone (608) 485-8800; Facsimile (508) 485-4477, ap Tot No. 781-821-4625 ve Feveneaton Nia 7 5 GECLARATION = 1 ‘declare tha{Pnave red the apove charge and thatthe statement ere tue tothe best of my knowledge and bell, | LAL Mi Director of Strategic Campaigns | ean preiaroe Beran Tanne PROTEAD Tre, Ta | Dana Simon Tek No 781-821-4625 Massachusetts Nurses Association Office, # any, Como. Canton Corporate Center Feet 340 Tumplke Street, 26 Floor ; | Canton, MA 02021-2711 ensi —_dsimon@mnar org - peg March ,2017. = 4 — a eeATTACHMENT A 1, ‘Since on or about September 1, 2016, the Employer has bargained in bad faith by engaging in surface bargaining for 8 successor to its collective bargaining agreement with the Charging Party that expired on January 1, 2017, 2, Since on or about September 1, 2016, the Employer has bargained in bad faith by refusing to meet at reasonable times and reasonable places for the purpose of negotiating a successor to its collective bargaining agreement with the Charging Party that expired on January 1, 2017, 3, Since on or about November 21, 2016, the Employer has bargained in bad faith by refusing to bargain with the Charging Party over mandatory subjects for bargaining, to wil: health and safety measures, work load, and staffing for bargaining unt employees, and insisting that it would only discuss health Insurance off the record, ail in the course of negotiations for a successor collective bargaining agreement. 4, Since on or about February 21, 2017 the Employer has bargained in bad faith by falling and refusing to provide information requested by the Charging Party that is necessary and relevant to successor negotiations, to wit: terms and conditions of health by the Employer that would allow the Charging Party insurance programs to be offered to evaluate those programs and to fashion proposals for health insurance coverage in the successor negotiations, 5. Since on of about February 21, 2017, the Employer has engaged in bad faith bargaining, and independently sought to interfere with, restrain, or coerce employees in the exercise of rights guaranteed by the Act, by making an unlawful proposal, to wit: @ uniform policy prohibiting the wearing of insignia promoting the Charging Party or promoting terms and conditions of employment favored by the Charging Party. 6. Since on or about November 21, 2016, the Employer has bargained in bad faith during successor negotiations, and independently discriminated against bargaining unit ‘employees in terms and conditions of employment to discourage union activity, by making proposals and counter proposals designed to diminish the status of Charging Party a3 the exclusive representative of bargaining unit nurses and/or designed to diminish the terms and conditions of employment of the members of the Charging Party's bargaining unit.