Earlier this year, the New Jersey Division on Civil Rights (DCR) issued proposed regulations to allow employers to satisfy the state’s Law Against Discrimination (LAD) and Family Leave Act (NJFLA) poster requirements via an internet or intranet site rather than a conventional bulletin board in the workplace. The proposed regulations also imposed a new annual LAD and NJFLA notice distribution requirement. Those regulations became final on August 1, 2022. Among the key new requirements for New Jersey employers are the following.
“In the event that an employer has an internet site or intranet site for use by its employees to which all employees have access and the employer customarily posts notices to affected employees or other affected individuals electronically on the site, posting of the official [LAD and NJFLA] poster[s]” on the employer’s internet site or intranet site will satisfy the laws’ posting requirements.
Employers must not only post, but also distribute, copies of the posters to each employee (1) annually, on or before December 31 of each year, and (2) upon the first request of an employee. An employer can satisfy these distribution requirements (1) by email delivery; (2) through printed material, including, but not limited to, paycheck inserts, a brochure or similar informational packet provided to new hires, an attachment to an employee manual or policy book, or a flyer distributed at an employee meeting; or (3) through an internet or...
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