CWA, Local 6306

1098 DECISIONS OF NATIONAL LABOR RELATIONS BOARD Communications Workers of America, Local 6306, AFL-CIO, and Communications Workers of America, AFL-CIO (Southwestern Bell Telephone Company) and Adele M. Gotthardt and Marilyn Mason. Cases 14-CB-2325-1 and 14-CB-2325-2 August 28, 1972 DECISION AND ORDER BY MEMBERS JENKINS, KENNEDY, AND PENELLO On May 25, 1972, Trial Examiner Samuel M. Singer issued the attached Decision in this proceed- ing. Thereafter, the Respondents and the General Counsel filed exceptions and supporting briefs. Pursuant to the provisions of Section 3(b) of the National Labor Relations Act, as amended, the National Labor Relations Board has delegated its authority in this proceeding to a three-member panel. The Board has considered the record and the Trial Examiner's Decision in light of the exceptions and briefs and has decided to affirm the Trial Examiner's rulings, findings,' and conclusions2 and to adopt his recommended Order.3 ORDER Pursuant to Section 10(c) of the National Labor Relations Act, as amended, the National Labor Relations Board adopts as its Order the recommend- ed Order of the Trial Examiner and hereby orders that the Respondents , Communications Workers of America, Local 6306, AFL-CIO, and Communica- tions Workers of America, AFL-CIO, their officers, agents, and representatives, shall take the action set forth in the Trial Examiner's recommended Order. i The Respondents have excepted to certain credibility findings made by the Trial Examiner It is the Board's established policy not to overrule a Trial Examiner's resolutions with respect to credibility unless the clear preponderance of all of the relevant evidence convinces us that the resolutions were incorrect Standard Dry Wall Products, Inc, 91 NLRB 544, enfd 188 F 2d 362 (C A 3) We have carefully examined the record and find no basis for reversing his findings 2 We agree with the Trial Examiner that Local President Eagan's letter of October 12, 1971, to the Charging Parties is not an effective retraction of his September 22, 1971, letter in which he had told Gotthardt that her withdrawal of checkoff authorization was untimely, that the manner of her subsequent dues payments was violative of the CWA constitution, and that unless she signed a new checkoff authorization "I will be forced to initiate action which will lead to your dismissal by the Company " Although Eagan testified that he wrote the October letter because he had been mistaken about both the timeliness of Gotthardt's withdrawal and the manner of her dues payments, the letter merely states that in view of the existing facts no action would be taken, but it does not withdraw or correct the unlawful statement of the member's obligation Accordingly, we find that the letter is inadequate as a retraction of the earlier letter and does not nullify the unfair labor practices committed 3 General Counsel contends that the Trial Examiner erred in failing to recommend that Respondents be ordered to rescind the rule herein found unlawful In view of our Order directing Respondents to cease and desist from maintaining and enforcing the unlawful rule, we find it unnecessary to require rescission of the rule TRIAL EXAMINER'S DECISION SAMUEL M . SINGER, Trial Examiner : This proceeding was heard before me in St . Louis, Missouri, on April 11, 1972, pursuant to charges and amended charges filed on September 29 and October 26, 1971, and complaint issued on February 17, 1972. The complaint alleged that Respon- dent labor organizations violated Section 8(b)(1)(A) of the National Labor Relations Act by threatening Charging Parties Gotthardt and Mason with discharge or loss of employment if they refused to sign authorization cards for dues checkoffs and by maintaining and enforcing a rule requiring members to execute such checkoffs . All parties appeared and were afforded full opportunity to be heard and adduce evidence. Briefs were received from General Counsel and Respondents. Upon the entire record in the case' and from my observation of the testimonial demeanor of the witnesses, I make the following: FINDINGS AND CONCLUSIONS 1. BUSINESS OF THE EMPLOYER INVOLVED Southwestern Bell Telephone Company (the "Compa- ny"), the Charging Parties' employer, is a Missouri corporation with its principal office and place of business in St. Louis, Missouri, furnishing telephone communica- tion service. During the past 12 months, a representative period, it derived revenues in excess of $500,000, and purchased and received from sellers in other States products valued in excess of $50,000. I find that it is an employer engaged in commerce within the meaning of Section 2(6) and (7) of the Act. II. THE LABOR ORGANIZATIONS INVOLVED Respondents Communications Workers of America, AFL-CIO (the International) and Communications Work- ers of America, Local 6306, AFL-CIO (the local), are i Transcript as corrected by my order on notice dated May 5, 1972 General Counsel's unopposed motion, dated April 27, 1972, to reopen the record to receive the amended charges and affidavit of service of said charges, and to renumber the index and description of formal documents, is hereby granted 198 NLRB No. 157 CWA, LOCAL 6306 1099 labor organizations within the meaning of Section 2(5) of the Act. III. THE ALLEGED UNFAIR LABOR PRACTICES A. The Facts 2 1. Background; contractual provisions regarding dues payments Respondent Local represents employees of Southwestern Bell, including Charging Parties, plant clerical employees, and local members. Insofar as here relevant, the collective agreement in effect through July 17, 1971, and a new 3- year agreement effective thereafter provided for dues checkoffs by the Company upon written authorization by employees. Each agreement also provided that members could "escape" their membership obligation within speci- fied time limits (10 days before the end of the contract term.) 3 A resolution adopted by Respondent International in July 1968 provided that "[w]here payroll deduction Union dues and fees is provided by a valid and subsisting contract with an employer, it shall be the only acceptable method" for collecting dues and fees. The adopted resolution also stated that it "is the policy of CWA that all contracts with employers contain check-off agreements"; that all dues and fees "must be remitted" by the employer to the International's secretary-treasurer; that the latter is to remit the proceeds to locals after deducting each member's per capita dues and fees; and that, where a collective agreement contained no checkoff clause, it was the locals' responsibility to collect all dues and fees. Minutes of the International executive board, dating back to February 1955, provide that membership dues are payable on the first day of each month and must be paid by the end of the last day of the month to avoid delinquency. 2. Charging Parties' cancellation of their dues- checkoff authorizations The Charging Parties have been long-time members of Local 6306. Gotthardt, a member for 26 years, had been "Group B" director "in charge" of female stewards and about 105 female employees for at least 12 years-until November 1968. Mason succeeded Gotthardt, as Group B director, holding that position until abolished in November 1969; she also served as steward "several times," last time from May to December 1971. 2 The material facts are based largely on documentary evidence and on uncontradicted, credited testimony of the Charging Parties (Gotthardt and Mason) To the extent that the testimony of Respondents' only witness Local President Eagan is inconsistent with that of Charging Parties, I credit the latter, who impressed me as honest and forthright On the other hand, Eagan, who was personally involved in the alleged unfair labor practices, often displayed studious attempts to conform his testimony to what he considered to be in the best interest of Respondents 3 Although there are variations in language in the two agreements (one of them containing a "Maintenance of Union Dues" and the other a "Modified Agency Shop" clause), Respondents' counsel stipulated that "as it pertains to these particular charging parties ' I don't believe there would really be any significant difference " Neither contract provided for the typical union-shop clause under which employees must become members after 30 days' employment, although under the latest agreement Dissatisfied with Local President Eagan's failure to rectify their repeated complaints about "underrepresenta- tion," 4 on July 8 (10 days before the termination of the then collective agreement; i.e., during the "escape period") Gotthardt and Mason formally notified the Company that they were canceling their dues-checkoff authorizations effective as of August.5 Charging Parties then wrote International President Beirne a letter voicing their complaints, which was received by Beirne on July 14. Gotthardt specifically complained that the Group B director position was abolished arbitrari- ly without regard to the fact that "105 girls is a large enough group to have our own representative"; indicated that the Group A director (who formerly handled only male workers) could not adequately represent all employ- ees; and advised Beirne that the two girls were stopping "our dues deduction from our paychecks" and would mail the dues directly to him each month. Mason specifically complained that "we are not satisfied" with the steward appointed by Local President Eagan; stated that they had tried "in vain to have her [the steward] replaced" and "hold an election for this job"; and pleaded, "Let's do something for the `Plant Clerical Group.' "6 On July 19, International President Beirne wrote Gotthardt that he was referring the matter to International Vice President McCowen. 3. Respondents' demands that Charging Parties execute new dues-checkoff authorizations; the threats of loss of employment if they failed to do so On July 29, International Vice President McCowen wrote a memorandum to CWA Representative Kelly, with copies to Gotthardt, Mason, and Local President Eagan, requesting Kelly to "check into" the Charging Parties' complaints "and see what can be done to rectify the problem which apparently exists." McCowen explained that "Our International rules do not permit payment of Union dues" directly to the International "particularly when payroll deduction for union dues is available." On September 3, McCowen wrote another memorandum to International Area Director Lovett, with copies again to Charging Parties and Eagan, referring to his prior memorandum to Kelly, noting that the International received two more money orders from Charging Parties, and calling attention to Lovett "and others receiving copy of this letter" the established dues-payment procedures, including the July 1968 "established rule" of the Interna- containing the "Modified Agency Shop" provision, nonmembers were required to pay the equivalent of "periodic dues applicable to members" 4 Gotthardt objected to abolition of the Group B director position and Mason to the inadequacy or inefficiency of stewards 5 Unless otherwise indicated, dates are 1971 6 The letter is divided in two parts, one signed by Gotthardt and the other by Mason Although, Gotthardt's portion ends with the words "2 former members of Local 6306 and Local 6306 Executive Board," it is clear, as they testified, that they continued to regard themselves and remained dues-paying members I so find Gotthardt's letter expressly states, "We must always be union members," and Mason admittedly continued to act as a steward after sending the letter-until October 1971 As Mason later told Local President Eagan, they wrote the letter to the International "to draw attention to our problems," and that it was her intention to resume checkoff deductions once "the trouble" was "straightened out " 1100 DECISIONS OF NATIONAL LABOR RELATIONS BOARD tional executive board (referred to supra, sec. A, 1), that "where payroll deduction of Union dues and fees is provided . . . it shall be the only acceptable method." McCowen also wrote that "Since payroll deduction of Union dues is available [to Gotthardt and Mason] they are in violation of this established rule by remitting their membership dues through the use of postal money orders." Finally, he expressed the hope that "this situation can be rectified" by Charging Parties' "signing new payroll deduction cards and without the need of taking further action." On September 22, Local President Eagan wrote Gott- hardt reminding her that she had already received International Vice President McCowen's September 3 letter outlining "the only acceptable method of paying your dues"; telling her she was "in violation of the CWA Constitution"; indicating that in accordance with his information she had "cancelled [her] dues deduction authorization during the month of August 1971" when "there was no escape period"; and admonishing her that unless she signed a new dues checkoff authorization card by October 2, he "will be forced to initiate action that will lead to your dismissal." At the hearing Eagan reiterated that he wrote the letter to Gotthardt to "get her back on the dues checkoff system," indicating that as a member of the Union she should "fulfill" her membership obligation by executing a payroll deduction card. He testified that he did not write a like letter to Mason at that time because "I thought I had an understanding with her as to when she would sign a dues deduction card." Mason testified credibly that she had several telephone conversations with Eagan-the first shortly after she and Gotthardt sent their July letter to International President Beirne, when Eagan stated he was "shocked at [her] part in it" and disputed some of the complaints mentioned in the letter. Mason assured him that she "had not withdrawn from the Union," that she only wanted "to draw his attention to our problems" (in her case the steward situation, supra, fn. 4), and that she "would sign another payroll deduction card . . . when he got the trouble .. . straightened out." In early September, when Eagan again telephoned to inquire when she "was going to sign" the dues-deduction authorization, Mason reiterated that she would do so when her complaints were rectified; Mason also urged him to attend to Gotthardt's grievance concern- ing abolition of the Director B position. On September 29, Mason telephoned Eagan and asked why he had sent Gotthardt the letter "threatening her with dismissal from her job." When Eagan answered that Gotthardt "dropped out of the union" when she could not do so, Mason disputed the statement and urged Eagan to attend to Gotthardt's complaints. Eagan replied that Gotthardt would not talk to him and, in any event, that the Group B director position was "unnecessary" so that it was useless to talk about it. To Mason's inquiry why she "hadn't gotten a letter" like Gotthardt, Eagan said that Mason had promised to execute a dues-checkoff card when her complaint was "straightened out" and he "had no reason to doubt [Mason's] word, but if [Mason] didn't [she] would probably receive [such] a letter, too." When Mason insisted that she and Gotthardt had canceled their checkoff authorization "during the legal escape period," Eagan said "that might be true but he was still going to do it," stating that if he did not receive Gotthardt's new checkoff authorization card by the October 2 deadline he "was going to spend the entire weekend" getting the Company to fire her. On October 5, International Vice President McCowen again wrote a memorandum to Area Director Lovett (with copies to Charging Parties, Eagan and others), stating that on October 4 he once more received dues payments from Gotthardt and Mason and expressing amazement about their unwillingness "to pay their membership dues in the manner as determined by the Executive Board" as he had outlined in his September 3 memorandum; "copy of which letter was furnished" to both employees. 4. Alleged "retraction" of the threats In the meantime, on September 29, Gotthardt and Mason filed the original charges in this proceeding alleging violation by Respondent Local of Section 8(b)(1)(A) of the Act.7 On October 12, Local President Eagan wrote Gotthardt that his September 22 letter admonishing her that he "would be forced to initiate action" leading to her dismissal from employment was written "under a miscon- ception and misunderstanding of the facts" and he now assured her that no such action "has been or will be initiated." On the same day, Eagan also wrote Mason, enclosing a copy of his letter of "retraction" to Gotthardt and also assuring her that "such action was never contemplated with regard to you nor was it my intention to infer that it would in any conversations we have had on this subject." Thereafter, beginning with November, Charging Parties sent their dues directly to the local; and insofar as appears, neither one had yet executed new dues-checkoff cards. At the hearing, Eagan testified that he wrote his letter of "retraction" to Gotthardt after learning that she canceled her dues-checkoff authorization during the proper "escape period." However, when asked if it was "the time at which [he ] thought she had revoked her dues . . . rather than the fact she had revoked her dues checkoff" that prompted his letter, he answered, "I was in error as to what I thought her obligations were, I guess you could say that." At another point, he indicated that he was still of the view that "the dues checkoff system was the only acceptable method" for membership dues payments On March 21, 1972, the International's executive board amended its July 1968 resolution to state that payroll dues deductions, when provided by a collective agreement, "shall be the only acceptable method, except when provided otherwise by law." B. Conclusions 1. In International Union of Electrical, Radio and Machine Workers, Local 601, AFL-CIO (Westinghouse Electric Corporation), 180 NLRB 1062, the Board laid 7 Amended charges, filed on October 26, also named the International `.originated" with a Board agent who "suggested" that such letter "may help 8 Eagan also testified that "the idea" of writing a letter of retraction resolve the issue." CWA, LOCAL 6306 1101 down the general principle , dispositive of the basic issue in this case: The Board has repeatedly held that dues checkoff authorizations must be made "voluntarily" and that an employee has a "right under Section 7 of the Act to refuse to sign checkoff authorization cards." Any conduct, express or implied, which coerces an employ- ee in his attempt to exercise this right clearly violates Section 8(b)(1)(A). [Citations omitted]. Also in Westinghouse, the Board held that the proviso to Section 8(b)(1)(A), according a labor organization "the right" to prescribe its own rules regarding retention of membership "does not extend to interference with the relationship between employee and employer." 180 NLRB 1066. The union may not "deprive[s ] the employee of his right to select or reject the checkoff system as the method by which to pay his periodic dues to the Union " whether the collective agreement provides for a union-security clause, or a lesser form of security such as a "maintenance- of-dues" clause . Id., at 1062. See also Local 4012, Communications Workers of America, AFL-CIO (Michigan Bell Telephone Co.), 184 NLRB No. 20. 2. The record establishes that as far back as July 1968, the International promulgated a rule that "where payroll deduction [of] Union dues and fees is provided" by a collective agreement with an employer, "it shall be the only acceptable method" for dues and fees collections. The record further shows that during the statutory 6-month limitation period both the International and Local 6306 sought to enforce this rule. Thus, on learning that the Charging Parties (members of Local 6306) had canceled their dues-checkoff authorizations in July (admittedly during the appropriate "escape" period before expiration of the existing collective agreement ), International Vice President McCowen on September 3 informed the Charg- ing Parties as well as Local President Eagan of the existence of this rule, and of the Charging Parties' "violation of this established rule." McCowen at the same time expressed the hope that the Charging Parties would sign "new payroll deduction cards . . . without the need of taking further action." Implementing McCowen 's instruc- tions, Local President Eagan on September 22 wrote one of the Charging Parties (Gotthardt) specifically referring her to McCowen's letter and to the International's rule regarding "the only acceptable method of paying your dues" and threatening "to initiate action" to terminate her employment unless she signed a new payroll deduction card within 10 days (October 2). The other Charging Party (Mason), who was spared such letter because Eagan expected her ultimately to execute an authorization, was on September 29 verbally warned of a similar fate if Eagan's 9 The promulgation of the rule in 1968, beyond the 10(b) limitation period, does not bar a finding that invoking and enforcing the rule within the 6-month period was unlawful Cf, e g, Cone Mills Corporation, 174 NLRB 1015, 1021, 1 LA Local No 1694 (James T Moock), 137 NLRB 1178, 1186-87, enfd 331 F 2d 712 (C A 3) Respondents' contention (br pp 22-23) that if either Respondent is liable for any violations, it is the local and not the International since Local President Eagan's threats are not attributable to the International is without ment Respondents ignore the fact that Eagan was implementing an avowed International policy Indeed, it was International Vice President McCowen who directed Eagan (and Charging Parties) to the International's "estab- lished rule" and thereby "instigated the course of events" that followed. Cf expectations were not realized. Several days later (October 5), International Vice President McCowen reiterated to the Charging Parties and Eagan the viability of the Interna- tional rule regarding the method of paying membership dues. I conclude, based on applicable Board law, that by maintaining, enforcing, and implementing (through threats of reprisal) a rule requiring union members to execute dues-checkoff authorizations, Respondents International and Local 6306 restrained and coerced employees in violation of Section 7, thereby violating Section 8(b)(1)(A) of the Act .9 3. Contrary to Respondents' contention (br. pp. 20-21), the instant case does not fall within the exception to the general rule enunciated in Westinghouse Electric, supra, exemplified by General Motors Corporation, Packard Electric Division, 134 NLRB 1107. In General Motors, the Board affirmed the Trial Examiner's conclusion that the dues-checkoff requirement imposed upon five employees was proper and lawful, noting that the employees involved "were part of an organized dissident group whose practice it was to willfully delay payment of union dues in order ... to harass the statutory bargaining representative"; that the employees involved, members of a rival organiza- tion, had previously been "in default" under the union- shop agreement; and that the union's action was in no way motivated by a desire to "penalize" members of the rival organization. (134 NLRB at 116.) The Trial Examiner concluded that "considering the background of delayed payments and default, the [union] had reasonable grounds to believe that the only assured way to prevent recurrence of default by the five men was to require a checkoff authorization"; and that under "the circumstances" in- volved which measure was both reasonable and necessary to a fair administration of the contract." (Id. at 1117). Here, on the other hand, there is no credible evidence that the Charging Parties had deliberately defaulted on dues payments and certainly no claim by Respondents that they had imposed the checkoff requirements on that ground.io Nor is there any evidence of any attempt to "harass" Respondents, the Charging Parties' sole objective in canceling their checkoff authorizations and remitting their dues to the International having been "to draw attention" to responsible International officials the problems in the administration of the local. Furthermore, even Local President Eagan ultimately conceded at the hearing that Charging Parties had properly withdrawn their authonza- tions during the legal "escape" period, contending only that they should have sent their dues directly to the local instead of to the International. To begin with, Eagan at no time told the employees that they could satisfy their Shelby-Baitersby and Company v N LR B, 259 F 2d 151, 157 (C A 4) and cases cited therein iO There is evidence that, in March 1972 (long after the events here involved), Mason had made an extra dues payment on discovering that the Company had erroneously failed to deduct I month's dues (for July 1971) when Mason was still under the checkoff system However , it is clear that the Union (either because it was itself unaware of the error or for other undisclosed reasons) never made an issue of this On the contrary, at the hearing Respondents conceded that "the record is clear that we have never paid attention [to the purported month's dues delinquency ] or discharge of [her] for this " 1102 DECISIONS OF NATIONAL LABOR RELATIONS BOARD membership obligations through such procedure; he admitted at the hearing that the purpose of his September 22 letter to Gotthardt, threatening her with loss of employment, was "to get her back on the dues checkoff system." In any event, beginning with November Gott- hardt and Mason did send their dues directly to the Local. 4. Respondents' final contention (br. pp. 21-22, 24) that even if they committed the alleged unfair labor practices, this complaint should be dismissed because they had taken "corrective" action to undue their wrongs presents a closer question. Respondents' rely particularly on Local President Eagan's October 12 "apologetic letters" to the Charging Parties withdrawing his previous threats and on the International's March 1972 resolution modify- ing its prior rule (promulgated in July 1968) to provide that payroll dues deductions shall be the only acceptable method, "except when provided otherwise by law." While it may be that these actions have nullified immediate threats to Charging Parties who are now being permitted to pay their dues directly to the local without interference, I am not satisfied that Respondents' past violations can be considered mere "technical" transgressions, justifying the withholding of a remedial order. In the first place, Eagan's October 12 letter did not reassure the Charging Parties (nor other members who, it is reasonable to assume, have learned of their plight) that the policy previously enunciated repeatedly by the Internation- al (i.e., that a dues checkoff is "the only acceptable method" for collecting membership dues and fees) was no longer operative. Eagan's letter said nothing more than that he had "acted under a misconception and misunder- standing of the facts" without assuring the Charging Parties of their legal right to refuse to sign checkoff authorizations in the future. Nor does Eagan's testimony at the hearing demonstrate that he "retracted" his threats in recognition of the law that employees had the statutory right not to pay membership dues through payroll deductions. Instead, he emphasized only the time factor; i.e,, that he had failed to appreciate the fact that the Charging Parties had canceled their authorizations during the contractual "escape period." Indeed, at one point he indicated that he still clung to the rule that "the dues checkoff system was the only acceptable method" for dues payments. The International's March 1972 amendment of the 1968 rule is no more enlightening than Eagan's interpretations. The addition of the vague phrase "except when provided by law" to the rule requiring dues payments through checkoffs places an unfair burden of deciding the law upon employees-a factor inconsistent with statutory policy of affording employees a free choice in selecting or rejecting checkoffs as the means for paying membership dues. Under all the circumstances, it appears reasonable and appropriate to require Respondents to post a notice clearly informing their members of their rights in regard to execution of dues checkoffs, and to issue a cease-and-desist 11 In the event no exceptions are filed as provided by Sec. 102.46 of the Rules and Regulations of the National Labor Relations Board, the findings, conclusions, recommendations, and recommended Order herein shall, as provided in Sec 102 48 of the Rules and Regulations , be adopted by the Board and become its findings, conclusions, and order, and all objections thereto shall be deemed waived for all purposes order insuring that Respondents will hereafter abide by a lawful dues-collection policy and refrain from threatening employees with job loss if they refused to execute checkoff authorizations. CONCLUSIONS OF LAW 1. Respondents restrained and coerced employees in the exercise of their Section 7 rights, and thereby engaged in unfair labor practices within the meaning of Section 8(b)(1)(A) of the Act, by (a) maintaining and enforcing a rule requiring members to pay dues and fees only by means of checkoff authorization, where checkoffs are permitted in an applicable collective agreement ; and (b) by threatening members with discharge or loss of employment unless they executed checkoff authorization cards. 2. The aforesaid unfair labor practices affect commerce within the meaning of Section 2(6) and (7) of the Act. THE REMEDY Having found that Respondents engaged in certain unfair labor practices, I shall recommend that they cease and desist therefrom and take certain affirmative action (posting of a notice) which, for reasons stated supra (sec. B, 4), I find necessary to remedy in order to effectuate the policies of the Act. Upon the basis of the foregoing findings of fact and conclusions of law and upon the entire record, and pursuant to Section 10(c) of the Act, I hereby make the following recommended: ii ORDER Respondents Communications Workers of America, Local 6306, AFL-CIO and Communications Workers of America, AFL-CIO, and their respective officers, agents, and representatives, shall: 1. Cease and desist from: (a) Maintaining and enforcing a rule requiring members to pay dues and initiation fees only by means of checkoff authorization, where checkoffs are permitted in a collective agreement with an employer. (b) Threatening employee-members of employers, in- cluding of Southwestern Bell Telephone Company with whom Respondents have executed collective agreements providing for payroll deductions, with discharge or loss of employment unless they signed checkoff authorization cards for collection of membership fees and periodic dues. (c) In any like or related manner restraining or coercing employees in the exercise of their rights guaranteed by Section 7 of the Act; 2. Take the following affirmative action designed to effectuate the policies of the Act: (a) Post at their offices and meeting halls copies of the attached notice marked "Appendix." 12 Copies of said notice, on forms provided by the Regional Director for 12 In the event that the Board's Order is enforced by a Judgment of a United States Court of Appeals, the words in the notice reading "Posted by Order of the National Labor Relations Board" shall read "Posted Pursuant to a Judgment of the United States Court of Appeals enforcing an Order of the National Labor Relations Board " CWA, LOCAL 6306 1103 Region 14, after being duly signed by their authorized representatives, shall be posted by Respondents immedi- ately upon receipt thereof, and be maintained by them for 60 consecutive days thereafter, in conspicuous places, including all places where notices to members are customarily posted. Reasonable steps shall be taken by Respondents to insure that said notices are not altered, defaced, or covered by any other material. (b) Furnish the Regional Director for Region 14 signed copies of said notices for posting by Southwestern Bell Telephone Company, if willing, in places where notices to employees are customarily posted. Copies of said notices, on forms provided by said Regional Director, shall, after being signed by Respondents, be forthwith returned to the Regional Director for disposition by him. (c) Notify said Regional Director, in writing, within 20 days from the receipt of this Decision, what steps have been taken to comply herewith.13 13 In the event that this recommended Order is adopted by the Board, this provision shall he modified to read "Notify said Regional Director, in writing, within 10 days from the date of this Order, what steps Respondents have taken to comply herewith " only acceptable method for collecting such fees and dues. WE WILL NOT threaten any of our members who are employees of Southwestern Bell Telephone Company, or of any other employer with whom we have collective-bargaining agreements, with discharge or loss of employment unless they sign dues or fees checkoff authorizations for us. WE WILL NOT in any like or related manner restrain or coerce employees in the exercise of their rights guaranteed by Section 7 of the National Labor Relations Act. Dated By APPENDIX NOTICE TO MEMBERS POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government To all members of Communications Workers of America, Local 6306, AFL-CIO, and Communications Workers of America, AFL-CIO. WE WILL NOT maintain or enforce any rule providing that payroll deductions or checkoffs of our membership fees and periodic dues from our members shall be the Dated By COMMUNICATIONS WORKERS OF AMERICA, LocAL 6306, AFL-CIO (Labor Organization) (Representative) (Title) COMMUNICATIONS WORKERS OF AMERICA, AFL-CIO (LABOR ORGAIZATION) (Representative) (Title) This is an official notice and must not be defaced by anyone. This notice must remain posted for 60 consecutive days from the date of posting and must not be altered , defaced, or covered by any other material. Any questions concerning this notice or compliance with its provisions may be directed to the Board's Office, 210 North 12th Boulevard, Room 448, St . Louis, Missouri 63101, Telephone 314-622-4167.