NATIONAL LABOR RELATIONS BOARD

VII. PRINCIPLES ESTABLISHED 53
him constantly and make reports to the company concerning his
union activities; other detectives were sent to attend union meetings
and conventions; still others were given union leaflets and circulars
for investigational purposes.°
Espionage, is not, however, limited to the activities of professional
spies employed for such purposes. At times regular employees have
been directed or encouragtd by the employer to report upon the union
membership or activities of their fellow workers. Such action by the
employer also is violative of section 8 (1). In some cases the evidence
establishes quite a comprehensive and efficient system maintained
by the employer for keeping himself informed of the progress
of the union and of its officers. Thus in Matter of Agwilines, Iiw.,7
detailed reports on union activities in the various branch offices of
the company were regularly made and transmitted to the general
office which determined the company's labor policy.° In other cases,
while no such system existed, individual employees were utilized on
occasion for spying purposes.°
Perhaps the most common type of espionage which appears in the
cases is that engaged in by company supervisory or managerial employees,
and officials. Such employees and officials have been found
to post themselves at points of vantage near union meetings in order
to note the identity of employees who attended. 1° In Matter of Boss
Manufacturing Company a foreman repeatedly importuned an employee
to give him information about the union's activities, but the
employee refused. The Board found that the attempted procurement
of such information, though unsuccessful, was a violation of section
8 (1).
2. BRIBERY
Bribery or attempted bribery of employees, as an antiunion weapon,
has been found in a number of cases. The Board has condemned
such practice as a violation of section 8 (1). In some instances company
officials have openly offered bribes to union leaders in an
attempt to induce them to cease their union activities. In Matter
6 Matter of Consolidated Edison Company of New York, mo., and United Electrical and
Radio Workers of America, 4 N. L. R. B. 71, order enforced in Consolidated Edison Co. V.
National Labor Relations Board, 95 F. (2d) 390 (C. C. A. 2d, 1938), certiorari granted.
304 U. S. 555. See also Matter of Fashion Piece Dye Works, Inc., and Federation of sirk,
and Rayon Dyers and Finishers of America, 6 N. L. R. B. 274, order enforced in National
Labor Relations Board V. Fashion Piece Dye Works, Inc., 3 Cir., decided November 28, 1938,
where the president of the company told an employee that he had a Pinkerton detective
trailing him the previous night when the employee had met with officers of the union.
'Matter of Agtoilines, Inc., and International Longshoremen's Association, 2 N. L. R. B. 1,
order enforced in Agwilines, Inc., v. National Labor Relations Board, 87 F. (2d) 146
(C. C. A. 5th, 1937).
° See also Matter of William Randolph Hearst, Hearst Publications, Inc., and American
Newspaper Guild, Seattle Chapter, 2 N. L. R. B. 530, where the employer's city editor
told a union member that the employer had "an espionage system that reaches everywhere,"
and averred that the publishers knew of every member of the Guild in Seattle.
9 See for example, Matter of Metropolitan Engineering and Metropolitan Device Corporation
and United Electrical and Radio Workers of America, 4 N. L. R. B. 542; Matter of
Friedman-Harry Marks Clothing Company Inc., and Amalgamated Clothing Workers of
America, 1 N. L. R. B. 411, order enforced in National Labor Relations Board v. Friedman-
Harry Marks Clothing CO., 301 U. S. 58, enforcement denied in 85 F. (2d) 1 (C. C. A. 2d,
1936 .
See, for example, Matter of Mansfield Mills, Inc., and Textile Workers Organizing Committee,
3 N. L. R. B. 901; Matter of C. A. Lund Company and Northland Ski Manufacturing
Company, and Woodenware Workers Union, Local 20481, 6 N. L. R. B. 423. In some cases
supervisory officials drove past the union meeting place in an automobile; in others they
stood outside watching the employees enter and leave. A somewhat similar practice was
revealed in Matter of Tiny Town Togs, mo., and International Ladies' Garment Workers
Union, 7 N. L. R. B. 54, where supervisory officials of the company stationed themselves
outside the plant to observe which employees accepted the union pamphlets then being
passed out by organizers.
11 Matter of Boas Manufacturing Company and International Glove Workers of America,
3 N. L. It. B. 400.