INTRODUCTION
 

This is a settlement agreement between (EMPLOYER’S NAME) and (UNION’S NAME) concerning the grievance of (GRIEVANT’S).
 

BACKGROUND
 

The grievance in this case was filed on (DATE). The Grievant claimed:
 

(AN OBJECTIVE STATEMENT OF THE GRIEVANT’S CLAIM, PERHAPS TAKEN VERBATIM FROM THE ORIGINAL GRIEVANCE).

(AN OBJECTIVE STATEMENT OF THE EMPLOYER’S CLAIM, PERHAPS TAKE FROM THE REPLIES TO THE GRIEVANCE AT EACH STEP).

SETTLEMENT

The Parties now find that settle of this grievance is in their mutual best interests as follows:

 
1. (A BRIEF STATEMENT OF WHAT THE EMPLOYER WILL DO TO SETTLE THE CASE; THE "RELIEF" THE PARTIES HAVE AGREED WILL SATISFY THE GRIEVANT AND THE UNION).

2. (A BRIEF STATEMENT OF WHAT THE GRIEVANT WILL DO IN RETURN FOR THE EMPLOYER’S RELIEF. FOR EXAMPLE: IN LAST CHANCE AGREEMENTS, IF THE GRIEVANT MUST SEEK TREATMENT FOR THE PERSONAL PROBLEM WHICH BROUGHT ON THE DISPUTE, THEN DESCRIBE THE TREATMENT).

3. (A BRIEF STATEMENT OF WHAT THE UNION WILL DO TO SETTLE THE CASE. REMEMBER, IN SOME INSTANCES THE UNION WILL BE GIVING RELIEF TO THE EMPLOYER).

4. The Union and the Grievant agree to withdraw the grievance and arbitration in this case with prejudice. (CAN YOU SETTLE OTHER CASES HERE? SEE: INTEGRATION CLAUSE BELOW).

This Settlement Agreement is non-precedential. (OPTIONAL).

 

This Settlement Agreement is confidential. (OPTIONAL).

 

This Settlement Agreement may not be used by either party to advance a claim in any forum. (OPTIONAL).

 

This Settlement Agreement may not be used by either party or copied without the express 

written permission of all parties. (OPTIONAL).
 

This is the full and complete agreement between the parties concerning this grievance and arbitration. (NARROW INTEGRATION CLAUSE).

 

This is the full and complete agreement between the parties concerning any and all claims by the Union and the Grievant as to any and all issues raised by the Union and the Grievant in any forum. (BROAD INTEGRATION CLAUSE).

For the Employer: 
 
 

___________________________________________________
NAME                                               TITLE
 
 
 

For the Union:
 
 

_____________________________________________________
NAME                                                TITLE 
 
 

______________________________
GRIEVANT
 
 
 

DATE:______________________ DATE:_____________________
 
 

PRESENTED BY:
Sean J. Rogers, Esq.
Senior Hearing Officer
National Mediation Board