A union-run organization called Rebound has sent several ABC members letters requesting wage information.

Who is Rebound?

Rebound is an organization funded by construction unions. They state that their mission is to “promote voluntary compliance with prevailing wage laws.” Rebound routinely sends letters

to open shop contractors working on public works projects requesting wage information. Rebound representatives may claim they are associated with a governing agency, but they do not have any authority to request records be sent directly to them, come onto a jobsite or interview employees during working hours.

What is the goal of Rebound?

Rebound typically sends open shop contractors that are working on a public works projects a letter requesting wage and other personal information about your employees. Despite their insistence that they are trying to simply get wage information, the real goal of Rebound is to attain the name, home address and other personal information from an open shop contractor’s workforce in an effort to organize them.

How should I react to Rebound?

Despite not having any state-sanctioned authority, contractors cannot simply ignore the wage requests from Rebound. According to RCW 39.12.010(4), Rebound is classified as an “interested party,” like all other unions. Any “interested party” may request a certified payroll form. According to WAC 296-127-320 (2), “A contractor shall, within ten days after it receives a written request, from the department or from any interested party as defined by RCW 39.12.010(4), file a certified copy of the payroll records with the agency that awarded the contract and with the department.” The following actions should be taken immediately after you receive a letter from Rebound:

1) Do not respond directly to Rebound, or send them any sensitive materials related to your workforce.

2) Contact Vice President of Government and Labor Affairs Aran Buchanat ABC, (800) 640-7789 or (425) 646-8000.

3) Go to the Department of L&I’s website to download a certified payroll form: www.lni.wa.gov/FormPub/.

4) Fill out the certified payroll form and submit it to the public agency that awarded your contract and the Department of Labor and Industries within 10 days.

What happens next?

Rebound will then have to go through a Public Disclosure Commission request to get a copy of the certified payroll form. At that point, L&I will redact your employee social security numbers, but other personal information, such as their home address, will remain. Rebound typically uses this information to try to organize your employees by contacting them at their homes in an effort to unionize your shop.

After you have submitted a certified payroll form, it’s a good idea to speak to your employees about the benefits of working for your company, and reiterate the added costs and downside of working for the union and/or organizing. If you have a strong workforce and employment structure, Rebound typically moves on to a contractor with weaker management.