3 and times for the election,
., § 3(b), and on who was eligible to vote,
., § 5. In consideration
for Volkswagen’s assistance with
organizing its employees, the UAW agreed to be subservient to Volkswagen when acting as an employee representative. First, the UAW agreed to delegate many of its duties and functions to a company
whose leadership will be separate from the UAW and trained and funded by Volkswagen.
., Ex. B, §§ 1.1, 2.3, & 3. Second, the union
agreed that, “while the parties negotiate for an initial collective bargaining
agreement, (a) the UAW will not engage in picketing, strikes, boycotts, or work
., § 7. Third, the UAW agreed to negotiate collective bargaining agreements that
maintain[ ] and where possible enhance[ ] the cost advantages and other competitive advantages that [Volkswagen] enjoys relative to its competitors in the United States and North America, including but not limited to legacy automobile manufactur
., § 6(b). In other words, the UAW agreed not to bargain for wages and benefits for employees at the Chattanooga Plant that are equal or superior to those at General Motors, Ford, Chrysler, or other automakers. In addition, the UAW also agreed to limits on its organizing activities in
consideration for Volkswagen’s assistance.
This includes not making any
“negative comments” about the company,
., § 9,
see also id
. at § 5(c); and not conducting organizing or other activities in connection with the Chattanooga Plant or any other Volkswagen facility for one year if the union loses the election,
., § 6(c).
Case 1:14-cv-00076-CLC-SKL Document 5 Filed 03/18/14 Page 3 of 25 PageID #: 148