Volkswagen has a new policy governing labor-management relations at its Chattanooga, TN facility.  The “Community Organization Engagement” policy, available here, establishes that VW will “allow eligible organizations the opportunity to engage in constructive dialogue with Volkswagen and its employees.”  Under the policy, “organizations” are those that “exist for the primary purpose of representing employees and their interests to employers consistent with the National Labor Relations Act.”  Substantively, the policy establishes three tiers of representational rights.  For organizations that represent more than 15% of the workforce, the policy grants the right to use company space for meetings and the right to “[m]eet monthly with Volkswagen Human Resources to present topics that are of general interest to their membership.”  When an organization garners support from more than 30% of the workforce, it gains the right to meet quarterly with “a member of the Volkswagen Chattanooga Executive Committee.”  At representational levels of more than 45%, the organization meets bi-weekly with Human Resources and monthly with the Executive Committee.

The policy thus commits VW to some regular interactions with employee representatives and it grants these employee groups some potentially important rights to use company property for organizational activity.  This strikes me as an important development.  In the NLRB election held this spring, the UAW got 46% of the vote and, assuming that support level has stayed stable, the new policy would put the UAW in the top tier of representational rights.

But note that the policy does not commit VW to bargain with any organizational representatives, even at the 45% level.  The only obligation on VW is to “meet” with organizations and allow them to “present topics.”  In this sense, the new policy – at least by its terms – does not establish true minority unionism at Volkswagen.  In a true minority union setting, management has actual bargaining obligations to employee representatives. Of course, it is entirely possible that, in practice, the right to “meet” with VW management will translate into something quite meaningful and closer to actual bargaining.  That will be an important development to watch.