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In a June 8 split decision, the National Labor Relations Board held that an arbitration policy contained in the employee handbook of a non-unionized employer, requiring employees to arbitrate “all disputes relating to or arising out of an employee’s employment [with the Company] or the termination of that employment,” was unlawful under the National Labor Relations Act because the policy might reasonably be read by employees to prohibit the filing of unfair labor practice charges with the board. U-Haul Co. of California, 347 NLRB No. 34 (2006).

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