COLLECTIVE AGREEMENT
Between Carboline Company/AD Fire Scarborough and
Sheet Metal, Air, Rail and Transportation SMART Local #540 CONTENTS PARAGRAPH PURPOSE RECOGNITION MANAGEMENT RIGHTS STEWARDS AND COMMITIEES NO DISCRIMINATION
UNION SECURITY & CHECK-OFF CO-OPERATION
MANAGEMENT/LABOUR COMMITIEE BULLETIN BOARDS
LEAVE OF ABSENCE
PREGNANCY & PARENTAL LEAVE BEREAVEMENT LEAVE
HOURS OF WORK OVERTIME
VACATION PAY & HOLIDAYS CLASSIFICATIONS
SENIORITY PERSONAL DAYS PROGRESSIVE DISCIPLINE HEALTH & SAFETY JOB POSTING GRIEVANCE PROCEDURE ARBITRATION AMENDMENTS GROUP INSURANCE JURY DUTY TERMINATION SEVERANCE PAY
1. PURPOSE
The General purpose of this Agreement is to secure for the Company and the Union the full benefit of orderly and legal Collective bargaining in respect to hours, wages and working conditions and to ensure the utmost extent possible, the safety and physical welfare of the employees, economy of operation, quality of output and the protection of property. This agreement moreover, seeks to provide for fair and peaceful adjustments of all disputes that may 3ri~f: IJetween the parties hereto and of all employees of the Company covered by this Agreement to cooperate fully, individually and collectively for the advancement of the conditions as set forth herein.
2. RECOGNITION
The Company recognizes the Union as the sole and exclusive bargaining agent for all full time hourly paid factory Employees of the Company at its plant in Scarborough save and except Supervisors, those above the rank of Supervisor, office, clerical, sales staff. This Agreement is not intended to cover any person hired for repair or additions to the Company plant or property, while so employed.
3. MANAGEMENT RIGHTS
a. The union acknowledges that it is the exclusive function of the Company, subject to the provisions of this Agreement to manage, supervise and direct its property, operations and work force. The Union agrees that the Company has the right to hire, classify, promote, demote, transfer, suspend, discharge or otherwise discipline employees for just cause.
b. To maintain order, discipline and efficiency; to make, ··<c:b!ish, alter and enforce reasonable rules and
regulations, policies and practices, to be observed by its Employee; to discipline and discharge employees with just cause.
c. The Union also acknowledges that the Company has certain other rights, prominent among which, but by no means wholly inclusive are the rights
to
decide the number and locations of its plants, the increase and decrease of its work force, the use of temporary workers for short term and or peak periods, (subject to the conditions outlined regarding temporary workers) types and quantities of machines, tools and equipment, the products to be manufactured, the methods of manufacturing, scheduling of production, the assignment of employees to jobs and shifts, the establishment of work standards, the introduction of new product lines and the general control and direction of the business of the Company. 4. STEWARDS AND COMMITTEESa. The Union shall elect or otherwise select Stewards for each shift, one of which shall be the Chief Steward and the Company agrees to recognize said Steward as the representative of the Employees covered by this Agreement. In order for an employee to be eligible to be a Steward, the employee must have successfully completed his probationary period. b. The union shall notify the Company in writing of the
names of Stewards and the Company shall not be required to recognize any Steward until such notification.
Supervisor or Plant Manager grants such request the Steward shall attend to the matter expeditiously and return to work promptly. The Steward shall report back to the Supervisor when resuming work. It is understood that the Steward will not lose pay for regular, non-overtime working hours for time spent during working hours servicing grievances or in grievance meetings with the Company. In no case shall payment to the Steward be extended beyond Step 3 of the grievance procedure.
5. NO DISCRIMINATION
a. The Ontario Human Rights Code defines harassment as a "course of vexatious comment or conduct that is known or ought reasonably to be known to be unwelcome." All Human Rights Law prohibits harassment (or discrimination) in employment because of gender, race, ancestry, place of origin, colour, ethnic origin, sex, sexual orientation, citizenship, creed, handicap, age, marital status, 1eceipt of public assistance or record of offences. It .. bo prohibits unwelcome sexual solicitations or advances or a reprisal because a sexual advance has been refused.
b. The Company, Union and the Employees covered by this Agreement acknowledge and agree that disparaging comments with gender, race, ancestry, place of origin, colour, ethnic origin, sex, sexual orientation, citizenship, creed, handicap, age, marital status, receipt of public assistance or record of offences or any other form of discrimination prohibited by the Ontario Human Rights Code cannot be tolerated.
6. UNION SECURITY AND CHECK-OFF
a. The Company agrees with the Union that, as a condition of employment all Employees covered by this agreement shall become members of the union
once the probationary period (90days) has been completed.
b. It is also agreed that the Company will deduct Union dues in the amount advised by the Financial Secretary of the Union from the wages of all Employees covered by this agreement. The Company will remit the dues to the Union by the 1 O'h of the following month.
7. CO-OPERATION
a. The Union agrees that it will not cause, authorize or sanction, nor permit its member to cause or take part in any strike, sit down, stay in, slow down in productivity within any department of the Company's operation or curtailment of work or restrictions of or any interference with production.
b. The Company agrees that it will not cause or sanction a lockout during the life of this agreement.
8. MANAGEMENT/LABOUR COMMITTEE
The parties (the Company and the Union) agree to meet two times each year, or more often if mutually agreed to managemenVIabour concerns. Problems arising will be addressed within a reasonable time frame. Both parties agree that discussions will be pursued on issues raised with the objective of mutual agreement. Agreed solutions will be implemented within a reasonable time frame.
9. BULLETIN BOARDS
President for approval prior to posting. Such permission
shall not be unreasonable withheld.
10. LE.;' •!-: :JF ABSENCE
a. Provided that two weeks written notice and the
Company approval is granted members of the Union not exceeding one (1) in number shall be granted
reasonable leave of absence without pay for
transaction of business for the Union. If less than two weeks notice is given, such leave of absence may be granted only if it will not interfere with the efficient operations of the plant.
b. The Company agrees to recognize a Union
negotiating Committee consisting of two Employees
with at least one-year seniority, elected or appointed
by the Bargaining unit. Such employee will not be
paid for time lost from work in negotiations. Such
committee, including representatives from the staff of
the Union will meet the Company for the purpose of negotiating renewal of the Collective Agreement.
c. Personal leave of absence shall mean an absence
from work requested by an employee in writing. The
Employee concerned shall make all requests for
personal leaves of absence to the Plant Manager in writing, and such letter shall indicate the reason for
requesting the leave of absence. Any leave granted
shall be in writing covering a specific period of time
but in any case not to exceed three (3) months. Such
l:>::we shall be granted and shall be without pay or any ntner forrn of compensation and the employee shall not work in any other position during such leave of
absence unless agreed to by the Company in writing.
If an employee overstays a permitted leave of absence without securing an extension of such leave of absence from the Company or without a reason satisfactory to the Company, such employee shall be removed from the seniority list shall lose his seniority
standing and employment.
d. Refer to chart below for length of noticed required.
Class Weeks Notice
Material Handler 2weeks
Forklift Operator "Main" 4weeks
Shipper/Receiver 4weeks
Machine Operator 6weeks
e. Comments: Time to train replacement worker to level
3 (requires no supervision to do the job) from our ISO system
11. PREGNANCY AND PARENTAL LEAVE
Pregnancy and parental leave will be granted in accordance with the terms of the Employment Standards Act 2001
12. BEREAVEMENT LEAVE
a. Employees covered by this Agreement who have
completed their probationary period (90days) will be granted four (4) days with pay due to the absence from work to mourn the death of any of the following relatives; parents (includes in-laws and step parents), spouse (includes common-law), child, sister, brother and grandchild.
b. Two (2) day with pay will be granted due to the
absence from work to mourn the death of any of the
following: grandparents, grandparents of spouse,
sister-in-law, brother-in-law ,aunts, uncles and
cousins, nieces and nephews.
c. Company will allow an employee to take up to five (5)
13. HOURS OF WORK
a. The daily hours of work shall be eight (8) hours Monday through Friday inclusive, with two paid 15minute coffee breaks. This will not constitute a
guarantee by the Company of hours of work per shift.
b. Depending on the work load the plant production can be scheduled to operate one (1 ), two (2) or three (3)
shifts and shall be eight (8) hours Monday through
Friday inclusive, with two paid 15minute coffee breaks. This will not constitute a guarantee by the •:>:-!npany of hours of work per shift.
c. Any employee who reports for work at his/her regular
<
starting time and has not been instructed by theCompany in advance not to do so shall be guaranteed
e--at straight time, as a minimum payment, four (4) hours of payment, unless work is not available for reasons
beyond the control of the Company.
d. The Employee is responsible to give to his immediate Supervisor his current mailing address and phone
number.
?.
e. The Company agrees that employees are not required to punch or swipe prior to changing for work so long as they arrive prior to the start of the shift.
f. The Company agrees to a 15 minute deduction in pay
for those employees arriving late for work. The
employees, at their option, can agree to work. 14. OVERTIME
b. An Employee shall be paid at a rate of time and one half (1 %) for all work performed on a Saturday,
Sunday and any statutory holidays.
c. The Employer agrees to first assign daily overtime to
the person performing such work. The employer
agrees to assign weekend overtime to those
employees that normally perform the job, then by
senior qualified volunteers from within the plant requiring the overtime. An employee offered Saturday or Sunday work must notify the employer no later than
4:30 pm Thursday of his desire for the offered
overtime work. The employer must notify all
employees asked to volunteer for overtime work no
later than 10:00 am Friday if the overtime work is to be
canceled.
d. Employees who are requested to work overtime for a
minimum of two hours will be given a ten (1 0) minute
coffee break prior to commencing overtime.
15. VACATION PAY AND HOLIDAYS
a. An Employee with less than one year seniority at his
anniversary date has not accumulated vacation but
has earned vacation pay at the rate of 4% of his
earnings.
b. Employees with less than five (5) years seniority shall
receive two weeks vacation, which is paid at the rate
of 4% of earnings.
c. Employees with less than ten (1 0) years seniority shall
receive three weeks vacation, which is paid at the
rate of 6% of earnings.
d. Employees with more than ten (10) years seniority
shall receive four weeks vacation, which is paid at the
rate of 8% of earnings.
e. Employees with more than twenty (20) years seniority shall receive four (4) weeks vacation, which is paid at the rate of 1 0% of earnings
f. Vacation and or vacation pay will not be carried from one year to the next. If vacation pay has not been requested during the year it will be paid out in the middle of December.
g. Vacation and vacation pay will be determined by the Employees anniversary date.
h. The Company shall have the right to declare a general vacation period of up to two (2) weeks.
The Company further agrees that an employee may take vacation on an individual day basis, not to exceed ten (10) consecutive work days. j. An employee may request up to 3 weeks of
consecutive vacation work days during the months of December and January. Such request is subject to
'l'.r;agement approval, business needs and other
~cheduled vacations.
An Employee shall be paid at his/her straight time rate on the basis of his/her regularly scheduled normal daily hours of work in the ten holidays as defined below without being required to perform services.
These statutory holidays are:
- New Years Day - Good Friday
- Victoria Day - Canada Day - Labour Day
- Ontario Civic Holiday
- Thanksgiving Day - Christmas Day
- Boxing Day
- Family Day
k. An Employee shall not be entitled to be paid Statutory Holiday:
If the Employee is employed for less than his probationary period,
If the Employee does not work on their regular day of work preceding and following the holiday,
If the Employee, having agreed to work on the Statutory Holiday, does not report for and
perform the work, unless the employee is on
leave with permission or presents a doctor's note for said absence.
If the Employee is receiving benefits under the Workers' Compensation Act.
Any further Statutory Holidays declared by the Federal
or Provincial Governments would be added to the paid holidays.
m. The Statutory Holiday must occur or be observed
between Monday and Friday inclusive.
n. The Company agrees to post a notice no later than
December 1st and remain posted until December 31
to allow the employees to select vacation. Said
vacation shall be awarded and the employee shall be notified no later than the end of the second week in
January. Vacations shall be awarded on the basis of
seniority. 16. CLASSIFICATIONS
Material Handler Machine Operator Forklift Operator "Main" Shipper/Receiver
17. SENIORITY
a. 1'1 1111 cases of lay off and recall after lay off, the 1r.:!owing factors shall apply:
Factor 1 -Seniority
Factor 2- Skill and Ability (to perform the work required or available)
b. Where factor 2 is relatively equal, seniority shall be the governing factor.
c. The Company further agrees that senior employees shall be allotted a reasonable familiarization period.
18. PERSONAL DAYS
a. The Company agrees that in a calendar year, the Company shall pay for personal days as follows:
PAID PERSONAL DAYS (inserted new graph below) Personal Days 0-5 years 6 6-lOyears 7 11-20years 8 20+years 9
b. ~·1·::· Company agrees to pay out by the last pay period
i11 the month of the New Year any unused sick days.
c. Company provides employees up to 10 Personal Emergency Leave occurrences per calendar year,
which the Company provides a minimum of 6 paid personal days.
19. PROGRESSIVE DISCIPLINE
a. The Company agrees that it shall apply the following
progressive discipline process for most infractions: (1)
verbal warning, (2) written warning, (3) one day
suspension, (4) three day suspension, (5) termination.
The Company reserves the right to skip steps based on the severity of the event.
b. The company agrees that discipline shall remain in the
employee's file indefinitely but will be removed from consideration for disciplinary purposes after 12 months.
20. HEALTH AND SAFETY
a. The Company will continue to make reasonable
provisions for the health and safety of its entire staff during the hours of their employment as set out in the
Occupational Health & Safety Act and Regulations for
Industrial Establishments.
b. The Company will reimburse employee shortly after
submittal of a receipt, for the purchase of CSA approved safety shoes or boots once per year based on the following schedule:
a. January 2019- up to a maximum of $175
b. January 2020 - up to a maximum of $200
c. January 2021 -up to a maximum of $200
The shoe purchasing will be done through Mr. Safety Shoe corporate account.
c. The Company will issue all Employees
non-prescription safety glasses, upon the return of the
worn non-prescription glasses. The Employee will do
his utmost to achieve the maximum life span of these items.
d. For those Employees requiring prescription eye
face respirator the company will reimburse to a maximum of $400.00 once every two years. Glasses must meet the Companies definition for safety glasses. Copy of prescription and receipt is required. e. The Company will supply aprons, gloves and
respirators free of charge to all Employees, upon return of old apron, gloves, respirators. The Employee will do his utmost to achieve the maximum life span of these items.
f. The Company will educate and maintain a reasonable :.t..n,ber of first-aid attendants.
g. As per the Occupational Health & Safety Act and Regulations for Industrial Establishments, the Company will maintain an active Joint Heath and Safety Committee.
h. Company agrees to make every effort to ensure employees are reimbursed in a timely manner.
21. JOB POSTING
a. Prior to hiring a new Employee for any vacancy in the classification schedule , the Company shall post for five (5) days on all bulletin boards a notice of such vacancy stating the classification, department and applicable hourly rate along with the qualifications for the job. Job postings will be worded exactly as per the job description listed in the Collective Agreement and the Chief Steward will be given a copy of all job postings. Successful job applicants will be awarded the job within ten (1 0) days. Letters will be issued to all those applying for any postings stating why they did or did not get the job.
Company can exercise its right to hire outside. The Company will provide a Steward with the opportunity
to notify absent Employees about any job postings.
b. In the event that more than one application is received
for a lead hand vacancy, the Company will select the
applicant that has the best ability to do the job.
c. The Company shall have the right to temporarily fill
vacancies as outlined in 19.1 during the posting
procedure.
d. This may be extended by mutual agreement between
the Company and the Union.
22. GRIEVANCE PROCEDURE
a. It is the mutual desire of the parties hereto that
justified complaints of Employees shall be addressed
as quickly as possible and it is mutually understood that an Employee has no grievance until the
immediate Supervisor concerned has been given an
opportunity to address the complaint or answer the question. On this basis, it is understood that a grievance shall only consist of a dispute respecting the interpretation or alleged violation of this agreement, provided that it is raised with the Employee's immediate Supervisor within two (2) days
of the date of the occurrence. After the Employee has
taken the matter up with his immediate Supervisor and
is not satisfactory, he shall then process the grievance
through the following steps: Step 1
The employee within two (2) working days of receiving the reply of his immediate Supervisor discuss the
matter with the Steward who may accompany him in
taking the matter up with the Supervisor. A decision
shall be rendered by the
supervisor within two (2) working days. Step 2
Failing settlement under step 1, and within two (2) working days of receiving the decision of the Supervisor the matter shall be reduced to writing and ~hall identify the facts giving rise to the grievance, the
·p.;ific section or sections of the
collective agreement allegedly violated and shall be signed, dated by the griever and Steward. The Steward presenting the written grievance to the Plant Manager or his designate shall request a meeting with Plant Manager or his designate and the griever. The Plant Manager or his designate shall render his written decision within two (2) working days of the meeting. Step 3
Failing settlement under step 2 and within two (2) working days of receiving the written decision of the Plant Manager and or his designate, a meeting shall be requested with the Business Union Representative and the Company Vice-President or his designate. A written decision shall be rendered by the Company Vice-President or his designate within five (5) working days of the meeting.
b. A claim by a seniority Employee that he has been unjustly discharged shall be treated as a grievance and commence at step 3 provided a written grievance signed by the employee and his Steward is presented to the Company within two (2) working days after the discharge.
23. ARBITRATION
a. r:r:1!ling settlement under the previous steps of the l:liievance Procedure, and within (30) thirty days of the date of Step 3 answer, either the Company or the Union may give written notice of referral of the grievance to arbitration by a sole Arbitrator who shall be bound by the rules of this Agreement. The
Company and the Union shall endeavor to agree on a mutually acceptable Arbitrator within (10) ten days of the giving of the notice of referral to arbitration. In the event of a failure to agree upon an Arbitrator, the Ministry of Labour will be requested to make an appointment.
b. The decision of the arbitrator shall be binding and accepted by both parties to this agreement, and all Employees covered by this Agreement.
c. The Arbitrator shall not have any power to add to, delete from, or otherwise alter or vary a term of this Agreement.
d. The Company and the Union will jointly bear the expenses, if any or the Arbitrator.
Notwithstanding the foregoing, either party may require that the grievance be referred to a Board of Arbitration, one member being named by the Company, one member being named by the Union, and the chair being selected by agreement if the two parties within ( 1 0) ten working days if the referral, failing which the chair will be appointed by the Ministry of Labour. All of the foregoing terms and conditions of this will apply to the Board of Arbitrators, with necessary modifications.
24. AMENDMENTS
By mutual agreement between the parties to this Agreement, any clause herein may be deleted, amended, or a new clause added to during the life of this Agreement.
25. GROUP INSURANCE
a. The Company will make available to employees and
their dependents Group Health Insurance on the same
terms as it makes available to employees not in the bargaining unit. Some items covered under the group insurance plan are as follows: dental, prescription
drugs, life insurance, long term disability. Refer to group benefit booklet for more details and limitations.
During the life of this agreement the Employer will pay the premiums.
b. The Company agrees that it shall reimburse employees for the cost of doctor's notes and insurance forms etc. for which the Company has made a request.
26. JURY DUTY
The Company agrees to pay to an employee who has been selected for Jury Duty or who is subpoenaed as a crown witness the difference between what he/she received from the Court and what he/she otherwise would have received for a regular day at his/her regular rate. To qualify for such make up pay, the employee must furnish proof of Service and the amount received for jury duty or crown witness and must return to work at every opportunity during the period of such service.
27. TERMINATION
All provisions of this agreement shall continue in force and effect beginning the 1st day of May 2018 and shall cor.ti···ue in force for a period ending April 301h, 2020, and shett' .;,Jntinue in for and effect from year to year thereafter un;ess written notice of change is given not less than (90) days prior to the expiration date.
28. SEVERANCE PAY
The Company agrees that if any employee is to lose his employment with the Company, said employee shall be entitled to a severance pay of two (2) weeks for each year of service prorated, up to a maximum of 52 weeks
29. SHIFT PREMIUM AND WAGE INCREASES
a. Those working the afternoon and midnight shifts will be paid one extra hour at regular pay rate. You must work your whole regular shift in order to benefit. If you are late for the afternoon and night shifts you will forfeit the shift premium pay.
b. WAGE AND CLASSIFICATION SCHEDULE WAGE INCREASE:
May 1, 2018 $0.65 evaluation May 1, 2019 $0.75 evaluation May 1, 2020 $0.75 evaluation
Starting rate May 2018- $ 15.50/hour Starting rate May 2019- $17.00/hour Starting rate May 2010- $18.50/hour c. WAGE FREEZE
While it is not the Company's intent to implement a wage freeze, events may occur that will warrant such a drastic step. Examples of such events may include but are not limited to: an unforeseen drop in sales or profitability, a mandate by either parent company (RPM International or StonCor), and significant material cost increases. Should a wage freeze be implemented, it will be company-wide which will include ALL Carboline and AD Fire employees in the U.S and Canada. The Company is committed to providing the highest quality products and services to its customers and realizes this cannot be done without the support and dedication of its workforce, therefore,
significant measures will take place to assure the duration of any wage freeze is as short as possible.
In the event of a mandatory, company-wide, wage freeze the employee's next scheduled raise would be delayed until the wage freeze is lifted. The wage
freeze duration will be no longer or shorter than the
remainder of the company.
For example: If the freeze is effective April 1, an
increase is due on May 1 and the freeze is lifted on
July 1 (three months later), the increase will occur on
August 1 and the next increase will occur when
regularly scheduled unless another freeze is instituted.
Any wage freeze will be announced by a Corporate Officer detailing the scope, reason, and steps or plans to eliminate the need of the freeze.
d. Students or temporary help may be employed as per
the letter of understanding regarding the same.
e. ~ '<> understood that employees working modified
shifts shall receive shift premium from the official start
time of the second shift. 30. PAY PERIOD
Pay will be deposited utilizing a third party payroll service by 12:01am Friday.
31. LEAD HAND
a. Delegates the work and instructs how the work is to
be done. Stages materials and equipment in order to
make-work flow as smoothly as possible. Does
physical work alongside co-workers. Reports to a
Supervisor at all times any incident that prevents the
smooth flow of work. (It is agreed that lead hand
positions shall be posted as per the job vacancy).
b. After selection, lead hands will receive a premium as
follows; year one (1) of the agreement fifty-cents per
hour ($0.50), year two (2) of the agreement
seventy-five cents per hour ($0.75) per hour, year three (3) of
the agreement one dollar per hour ($1.00)
WITNESS
IN WITNESS AND TESTIMONY of the provisions and terms mutually agreed upon and specified herein the duly authorized Offices and/or Representatives of both parties affix their signature this
<fJ.-_
18:_
day ofJ-{,.,&
,
2018.Signed on behalf of Carboline Company
AD Fire Protection Systems Inc
~.4~~·
David MarlenLETTER OF UNDERSTANDING Re: Students and Temporary help
The Company and the Union agree that students may be employed between the period of May 1 and September 1 and may
perform direct labour as directed.
it i::. undert.•::-ad that said students may only be employed to perform duties that do not displace seniority or probationary
employees.
It is further understood that said students may not work overtime unless all seniority and probationary employees have been given an opportunity to work said overtime.
The Company and Union agree that the company may only
employ temporary help under the following circumstances:
1) Temporary employees may perform direct labour as
directed on short-term bases where the uncertainty of full
time employment exists.
2) Temporary employees may not displace seniority
employees.
3) Temporary employees may be employed for a maximum of
forty-five (45) consecutive working days (The Union may
agree to extend this period by mutual agreement for valid production requirements). If hired, the total of all days worked as a temporary employee will be counted toward the union probationary period (this does not count toward
company probationary period for benefit, PIP, and RRSP
eligibility).
4) Temrorary employees may not work overtime unless all
ser,,. .. ·;cy and probationary employees have been given an op!-JJ• :unity to work said overtime.
5) Temporary employees may not be employed while
seniority employees and probationary employees are on
layoff who are willing to perform said work.
INDEX
A Arbitration: 16, 17 Amendments: 17 B Bereavement Leave: 7, 8 Bulletin Board: 5, 6
c
Classi ficarions: II Co-operation: 5 G Grievance Procedure: 15, 16 Group Insurance: 17 HHealth & Safety: 13, 14 Hours of Work: 8 Job Posting: 14 Jury Duty: 17, 18 L Lead Hand: 20 Leave of Absence: 6, 7 Lener of Understanding: 22 M Management/Labour Committee: Management Rights: 2, 3 i~
No Discrimt•tntion Clause:
0
Overtime: p
Pay Period: 20 Personal Days: 12 Pregnancy & Parental Leave: Progressive Discipline: 12, 13 Purpose: 2 R Recognition Clause: 2
s
Seniority: 12 Severance Pay: 18Shift Premium & Wage Increases: 18, 19,20
Stewards & Committees: 3, 4
T
Tennination: 18
u
Union Security & Check-off: 4, S
v
Vacation Pay & Holidays: 9, 10, II w
Witness: 21
