Assessment Of Legal Astuteness - Target

Dear Bob,

You have asked me audit our company and develop a plan to improve or sustain the legal astuteness level of our company, and to make sure it is a part of everyday business. Astute is defined as having or showing shrewdness and perspicacity, or otherwise a strong knowledge of. The law establishes guidelines, which function as an ethical floor, a line that if crossed will, and should, result in consequences. Therefore legal astuteness requires having a strong knowledge of the laws that govern our business and practices in place to comply with those laws. I will be exploring the legal astuteness of our company from the store level operations, which is the largest portion of our business, to provide you with the most accurate information I have.

As way of background let me establish that we are, as discussed in my memo dated November 27, 2007, a very ethical corporation. With many practices in place that go above and beyond the legal minimums that are required. For example, we give to our communities more than three million dollars a week. We care for our employee with the very best benefits in our industry. We strive to be the best for our shareholders, by always being honest and forthcoming in financial information. We thrive and prosper by our guests that shop in our stores, and we train our team to be friendly and courteous to them.

To begin the analysis we need to establish criteria for evaluating and exploring our current level of astuteness. I will then explain a few barriers, that make it difficult to expand our understanding, and practice of legal astuteness. Then we can take a closer look at different areas of the law that Target deals with almost daily and that should be included in a training program. Finally I will attempt to make suggestions on improving and maintaining our legal astuteness.

Questions To Ask:

What are our current policies that are in place that help us be legally astute? How often are the policies updated? How do we communicate legal issues and changes to our teams? What training programs are in place to reach our goal of legal astuteness? These are a few of the question we must ask during our audit.

Current Policies

The amount of statutes and regulations that effect Target are complex and often overlapping. It is not imperative that our teams understand all the laws that impact Target, but they must be aware of the statutes and regulations that affect them regularly and that there are policies in place to facilitate compliance.

For example, Target has in place a six hour policy; it is required at all Target locations that team members must clock out and take a lunch before their sixth hour of work. This policy exists to guarantee that Target complies with federal regulations, which requires business' to offer unpaid breaks of thirty minutes or more for person working more than six hours. Team members who violate this policy are subject to corrective action. This policy serves multiple purposes such as, responding to the needs of Team members and shielding Target from liability. Additionally, Target allows team members' to clock out of work and clock back into work without a minimum of eight hours between the shifts. This policy, much like the previous one is in place for the protection of our team members, but it also protects the company from labor laws that govern our industry and many others.

The interviewing process is governed by a separate policy at Target for a number of reasons. Target uses standardized interview forms for all candidates. Each candidate is interviewed by at least two people, and more as the job title increases, using the form that is filled out. Interviewers are given a set of uniform questions and are not allowed to vary from the questions. Furthermore, they are required to only write down candidate's exact responses. Target uses this strategy to give everyone a level ground to start from and to comply with the anti-discrimination laws. It is imperative that hiring decisions are not based on race, gender, religious orientation, age, or any other form of discrimination. Target has multiple people partake in hiring decisions to ward off any impermissible discrimination and to ensure we hire the most talented applicant.

In the era of google and fast information, Target strives to protect team members' privacy. Target does not publish any team member's first and last name anywhere at work where other team members have access to it. Target has a legal obligation to make sure that our team member's private information remains private. Our policy of not publishing or using more than the first three letters of anyone's last name assists in our efforts to keep team members information confidential.

Frequency of Updating Policies

How often do Target's policies change? From what I have been able to learn and observe during my time with Target, our policies are fairly fluid. Our policies change when change is needed or required.

Target uses our intranet to quickly communicate any policy changes, and managers are required to read all intranet communication on a daily basis, in order to make sure they are following all new policies that influence their areas of business. After a policy changes and it has been sent out over our intranet, hard copies will then be sent to all company managers in a monthly store communication packages. Hard copies of new policies are distributed to managers on the first Tuesday of every month, putting in place any new changes for good.

For example, six months ago we did not have a policy about where cat litter could be stored. Cat litter could be stored anywhere in our back rooms. This policy was changed to respond quickly to a change in health department laws and policies. Now cat litter cannot be stored above any foods, including dog and cat foods.

Communicating Legal Issues

How are legal issues communicated to our employees? Legal issues are broken down and communicated as policies to our employees. The first form of communication is our store orientation for new team members. The second form of communication is our weekly updated communication boards. We have eight different communication boards, all of which cover different information. The boards are not just used to communicate policies and legal information, but also to inform our teams and vendor of our store's performance. The third form of communication is daily huddles. Teams are required to attend huddles at every scheduled shift. Store hold three huddles throughout the day: morning, evening, and over night.