Landmark Worldwide: Difference between revisions

Content deleted Content added

Inline

Revision as of 23:20, 28 November 2005

The term Landmark Education refers to the company Landmark Education LLC and to its commercial operations, which primarily involve the delivery of a series of motivational and self-development courses. Landmark Education LLC refers to the most well-known of its offerings as The Landmark Forum.

Landmark Education and its supporters market the company's courses primarily to individuals, while the subsidiary Landmark Education Business Development provides training and consultancy to organisations.

The Landmark organisation and its methods evoke considerable controversy, with passionate opinions held both by supporters and by detractors.

Stated scope

Landmark Education states that "[a] fundamental principle of its work is that people and the communities, organizations, and institutions with which they are engaged have the possibility not only of success, but also of fulfillment and greatness. ... [i]n independent research, graduates of Landmark's programs report major positive results in the following areas:

The quality of their relationships.
The confidence with which they conduct their lives.
The level of their personal productivity.
The experience of the difference they make.
The degree to which they enjoy their lives."

Landmark Education states that it intends its courses for mentally healthy people and discourages potential participants who may have unresolved mental health issues which psychotherapy might more appropriately treat.

Landmark Education maintains both publicly and during the Forum that the Forum consists of an "inquiry", rather than providing a belief system or an ideology. While this can make course-content difficult to summarize, many who have attended the Forum enthusiastically cite the benefits as claimed above.

Operation

Landmark Education courses generally take place in large, carefully-prepared rooms and involve 100 to 200 attendees listening to lectures, engaging in dialogue, and participating in exercises. Volunteer workers keep the room clean and tidy, set out the chairs in neat rows, replenish the drinking water and hand out any required supplies and notes. (See Kopp's academic analysis of the Landmark Forum milieu for an analysis of the delivery-setup and of the importance of managing minutiae of the environment.)

The courses are investigations into the ways in which human beings make decisions in response to their experiences in the past; and how these decisions then place constraints on how they perceive the world and the people around them. In identifying and taking responsibility for these decisions (rather than blaming factors beyond their control - other people, circumstances etc) the majority of course participants discover a freedom to act in previously unimaginable ways. The results vary as much as the individuals who get them. They range from the trivial (such as tidiness, punctuality, and personal organisation) to the dramatic (for example: reconciliation with an estranged divorced partner, starting a business which goes on to make millions). Numerous specific examples can be found on many of the websites referenced below.

Prospective participants are encouraged to define in advance an area of their life in which they wish to experience a "breakthrough" result, and to define it with sufficient detail to leave no doubt as to whether this result has in fact been accomplished. Landmark Education claims that a large majority of customers report getting the result they specified, and in addition received further unexpected benefits.

Regarding philosophical aspects of the course content, supporters of Landmark Education have made comparisons with the ideas of historical and contemporary thinkers and schools such as Heidegger, Richard Rorty, Sartre, Fernando Flores and Westernized and popularized Zen. Others have suggested that Landmark Education has incorporated ideas from a wide range of philosophers from Socrates to Wittgenstein. Some suggest that Nothingness and meaninglessness form a key part of Landmark Education's existentialist foundation.

An eight-page article in the March 2001 edition of the journal Contemporary Philosophy hosted at the University of Colorado at Boulder and co-authored by Professor Steven McCarl and by Landmark Education Business Development CEO Steve Zaffron discusses philosophy and the Landmark Forum under the title "The Promise of Philosophy and the Landmark Forum". (Readers interested in a detailed discussion from Landmark Education's point of view can read this article - one of the few written articles discussing course content of Landmark Education (aside from the course syllabus - one of Landmark Education's marketing documents.)

Courses

Landmark Education offers four principal courses, collectively named "The Curriculum for Living ":

The Landmark Forum, three days and an evening, focused on "completing" participants' pasts.(The word "completing" is here used in a specialised sense of coming to terms with events or interactions in the past such that they no longer limit what the individual sees as possible for them now and in the future. Typically this may involve e.g. apologising to someone, telling them that you no longer blame them for something, owning up to something, or asking someone for forgiveness). Doing the Landmark Forum is a pre-requisite for registering into any other Landmark course.
The Landmark Forum in Action Seminar, a series of ten 3-hour seminars at weekly intervals (normally delivered free of charge to people who have completed the Forum within the previous year). The seminars review the material from the Landmark Forum and encourage participants to see how it may apply in practical terms to their own circumstances.
The Advanced Course, four days and an evening, focused on designing "a new future of freedom and self-expression" for participants' lives. In 2005, in some centers, a developmental three-day and an evening Advanced Course became available.
The Self Expression and Leadership Program (SELP) focused on giving practical exprssion to the "new future" that was "designed" in the Advanced Course. As one part of this course, each participant (including the program leader and the coaches) takes up a project in a community (not related to Landmark Education), such as a sports or social club, an extended family, a church group or a charitable undertaking.

Landmark Forums have taken place in at least 26 countries : Japan, Israel, India, the Philippines, Malaysia, Singapore, Thailand, Hong Kong, Romania, Belgium, Denmark, France, Germany, Ireland, Italy, Netherlands, Sweden, United Kingdom, South Africa, Kenya, Jamaica, United States, Canada, Mexico, Australia and New Zealand.

Beyond the Curriculum for Living, Landmark Education offers the following other curriculums to supplement the Landmark Forum:

The Communication Curriculum, consisting of Communication: Access to Power, and Communication: Power to Create. These two courses focus on creating a "new model" of communication focused on creation rather than on surviving and fixing. (Note: While not formally a part of the Communication Curriculum, the Team, Management, and Leadership Program has the two communications courses as its prerequesites and revolves heavily around the distinctions of the Communication Curriculum.)
The Wisdom Curriculum, consisting of various courses that take place over an extended period of time and which focus on the connection between childhood and adulthood.
Various seminar series which cover a large variety of topics, ranging from general topics such as excellence, integrity, and commitment, to specific subjects such as money, sex and intimacy, and fitness.
The Introduction Leader Program, six months duration, which prepares participants to lead Introductions to the Landmark Forum. This is also the foundation of the training for Progam Leaders of all of Landmark's courses. Many participants report breakthrough results in confidence and public speaking skills, regardless of whether they go on to lead Landmark events or not [1].

In addition to its regular courses, Landmark Education also presents free "Special Evening About the Landmark Forum" events. These offer an invitation for prospective customers to learn about the Landmark Forum, to experience an introduction to the Forum's work, and to register for the Landmark Forum.

Most courses include an evening session or guest evening that offers an intensification of the standard word-of-mouth marketing to guests, giving them an opportunity to participate in the technology their friend or family member has participated in. Landmark Education encourages the guests to participate in exercises from the course itself so they can get a sense of what the course offers.

Memberships, associations, affiliations

Landmark Education and its subsidiaries hold memberships in the following professional associations and organizations:

American Society for Training and Development
International Society for Performance Improvement
American Management Association
International Association for Continuing Education and Training Membership Details CEU Qualifications
Academy of Management

Some organizations use Landmark Education as a provider of continuing education offering course credit. One such organization, the Phoenix Police Sergeants and Lieutenants Association, states that the Landmark Forum (in the language of the reference) "has been determined to qualify for POST continuing 43.5 training credits." (POST means "Peace Officer Standards and Training".)

Structure and financials

Structurally, Landmark Education as an organization comprises an international employee-owned company with more than half its offices in North America. Landmark Education employees and, in some cases, graduates from Landmark Education's courses own all the stock, with no single individual holding more than 3%. The company does not distribute dividends, so any profits go either to expand the operation generally worldwide or to subsidise courses in countries such as Kenya, South Africa and India (thus rendering them affordable to local populations of those countries).

Currently between 70,000 and 80,000 people take the Landmark Forum annually, and around 50,000 take the various other courses offered.

Landmark Education reported revenues of $70 million for 2004.

History

Landmark Education Corporation ("LEC"), originally set up under that name in 1991, later became Landmark Education LLC in February 2003.

Landmark Education Corporation acquired certain rights to the form and content of the course previously known as "The Forum" from Werner Erhard and Associates (WEA -- the corporate successor of Erhard Seminars Training - better known as "est" ). The new owners, some of them former staff-members of WEA, renamed the course "The Landmark Forum" and developed its content, reducing the duration from two weekends to three days plus an evening. There was a further major re-design of the Landmark Forum in 1999, as well as continuous on-going adjustments in the light of experience.

Between WEA and Landmark Education (in 1991), the organization was temporarily incorporated as "Transnational Education" and as "The Centers Network," and as "Rancord Company, Ltd." in Japan [2]. Once the organizations became part of Landmark Education, the naming standardised and stabilised. For example, all of the centers (offices) in the United States have used the name "Landmark Education" since 1991 ("Landmark Education Corporation" to 2003 and "Landmark Education, LLC" since 2003).

Results

Some critics dispute whether the Forum is actually responsible for producing the reported results, or whether participants have an improvement in their life and wrongly attribute it to being caused by the Forum.

Post hoc?

Michael Langone, "Large Group Awareness Training Programs," Cult Observer, v. 15, n. 1, 1998, states his opinion that people who are having problems are the kind of people who sign up for seminars. Many people then have upswings and experience fewer problems, and many of these participants will attribute their sense of improvement to the program they've taken, but, Langone speculates, much of their reason may be post hoc: that the improvement happened during or after participation, but that participation was not the actual cause of the improvement, only the perceived cause of improvement. [3]

Supporters point to the scale and consistency of the results reported in the following surveys, and in the numerous personal accounts, and suggest that it is implausible for such widespread benefits to be entirely coincidental, or accountable by selection bias. Also many reported outcomes are linked to a specific topic in the published syllabus.

Academic study

An academic study commissioned by Werner Erhard and Associates concluded that attending a (pre-Landmark) Forum had minimal lasting effects, positive or negative, on participants' self-perception. (J.D. Fisher, R. C. Silver, J. M. Chinsky, B. Goff and Y. Klar Evaluating a Large Group Awareness Training: A Longitudinal Study of Psychosocial Effects Springer-Verlag, 1990, ISBN 0387973206). (This study won a 1989 American Psychological Association award.)

Charles Wayne Denison's Ph.D. research involved interviewing Landmark Forum participants and reported (as suggested above) predominantly positive outcomes.

DYG study

An analysis done for Landmark Education by Daniel Yankelovich, chairman of DYG, Inc., (Analysis of The Landmark Forum and Its Benefits) ) of a survey (carried out by questioning 1300 respondents about six months after they had participated in the Landmark Forum) concluded that:

95% of respondents report "practical value for many aspects" of life
94% of respondents saw the Forum as "likely to have enduring value"
93% of respondents saw the Forum as "well worth ... time and effort"
90% of respondents adjudged the Forum "well worth the cost"
More than 90% of respondents who self-reportedly attended the Forum in order to gain "a better understanding of relationships and how they work" expressed satisfaction.
Nearly every participant in the survey reported receiving unexpected benefits - ranging from 'ability to control weight' to 'achieving a specific educational or business goal'

Yankelovich conducted this study over a period of three months.

Harris Interactive

A survey (whose date and methodology Landmark Education has not reported in detail) carried out by Harris Interactive for Landmark Education Corporation) concluded that:

One-third experienced a significant increase (of 25% or more) in their incomes after completing The Landmark Forum. Of that group, 94% said The Landmark Forum directly contributed to the increase.
Seven out of 10 people said they worried less about money and became more effective in managing their finances after completing Landmark's programs.
Participants found they were working fewer hours, suggesting they achieved greater balance in their lives.

It remains unclear over what time duration Harris Interactive conducted this study.

University of Southern California

The University of Southern California Marshall Business School carried out a case study into the work of Landmark Education Business Development (LEBD) at BHP New Zealand Steel. Landmark Education summarized: "The set of interventions in the organization produced impressive measurable results:

Safety performance improved 50%
Key benchmark costs were reduced 15-20%
Return on capital increased by 50%
Raw steel produced per employee rose 20%"

(Full report available from USC at a cost of $3 plus shipping and taxes)

International Society for Performance Improvement

The International Society for Performance Improvement (ISPI) site contains a report of Landmark Education's involvement with improving safety at Minera Escondida Ltda, which ran the largest copper mine in the world and a workforce of 5,000 people. The ISPI report notes that the when Landmark started working with Minera Escondida, the total injury frequency rate was 23.7 accidents per million man hours worked. Five months later, when Landmark finished its program with Minera Escondida, the injury rate had been reduced by over 50% to 11.5 accidents per million man hours worked. ISPI reports that Landmark created this environment of improved safety. The ISPI awarded Landmark Education a "Got Results" award for its actions. [4]

Controversies

Critics of Landmark Education make accusations which generally fall into one or more of these areas:

Questioning whether the courses do really produce worthwhile benefits (discussed in the section above)
Suggesting that participating in the programs may have harmful consequences
Speculating that customers may be exploited, financially or otherwise, by the proprietors of Landmark Education.

"Cult-like", "brainwashing" or "hypnotism"?

The Australian psychologist Louise Samways included a section on Landmark Education in her book Dangerous Persuaders: An exposé of gurus, personal development courses and cults, and how they operate (Penguin, 1994; currently out of print) ISBN 0-14-023553-1. Samways seems to have a very broad conception of what can be classified as a "cult", and includes may organizations that would not generally be so-described, such as multi level marketing company Amway.

Apologetics Index (an online Christian ministry providing research resources on what it considers cults, sects, other religious movements, doctrines, and practices) quotes one critic of the Landmark Forum as saying the Forum

"Might lead to personality disorders. You might become a zealot for the Forum or addicted to it by registering for more".[5]

This critic admits he has never participated in the Landmark Forum and his area of expertise is not stated. [6]

After taking the Landmark Forum, one customer, Martin Lell, wrote a book titled Das Forum: Protokoll einer Gehirnwäsche: Der Psycho-Konzern Landmark Education [The Forum: Account of a Brainwashing: The Psycho-Outfit Landmark Education], Deutscher Taschenbuch Verlag, Munich, 1997, ISBN 3423360216. Landmark sued to have the word "brainwashing" removed from the sub-title.

During the hearing, Lell stated that following completion of The Landmark Forum, he did not see a doctor, was not hospitalized, did not seek or obtain medication, and was not diagnosed by a medical professional as being brainwashed or having any mental problem. The court decided that "brainwashing" was a matter of opinion and allowed the sub-title to remain.

Traci Hukill, a reporter for Metroactive, participated in the Landmark Forum and wrote [7]

For me, it's almost impossible to observe The Forum's methods without the word "brainwashing" flashing across my intellectual radar screen every 15 seconds or so.

Landmark refers inquiries in this department to a letter by Forum graduate Edward Lowell, a New Jersey psychiatrist who states in no uncertain terms that Landmark does not use brainwashing techniques.

Edward H.Lowell MD PA, an eminent psychiatrist with expertise in the areas of cults and brainwashing stated [8]

Brainwashing involves (1) intensive, forcible indoctrination aimed at destroying a person's basic convictions and attitudes and replacing them with an alternative set of fixed beliefs and (2) the application of a concentrated means of persuasion, such as repeated suggestion, in order to develop a specific belief or motivation. Necessarily involved are a kind of physical entrapment, power to inflict harm or detrimental effects, and secluding one from contact with friends and family. Not one of these exists in Landmark or any of its programs.

Raymond Fowler, a psychologist and past President of the American Psychological Association (speaking on his own behalf and not that of the APA), was requested by Landmark Education to evaluate the effectiveness, safety, and appropriateness of the procedures in the Landmark Forum in 1999. Fowler reported [9]

I saw nothing in the Landmark Forum I attended to suggest that it would be harmful to any participant. ... the Landmark Forum is nothing like psychotherapy ... has none of the characteristics typical of a cult ... does not place individuals at risk of any form of “mind control” “brainwashing” or “thought control.”

Classification by various governmental agencies

In France, Landmark Education 'assistants' have the apparent legal status of volunteer unpaid workers -- the French Labour Ministry has judged this practice illegal.

Also in France, an agency of the French government, the Interministerial Mission for Awareness against Sectarian Risks (MILS) has classified Landmark Education as a secte (cult). It is not clear what criteria the MILS uses to make this classification, and many of the organisations which it has so classified strenuously dispute the validity. Defamation lawsuits in the US and the Netherlands refute this classification, and, regarding France, the US State Department noted in a 2002 report that the French legislation creating the MILS did not define the term "cult" and that the president of MILS had resigned in mid-2002 and that no replacement had emerged by the time of the US State Department's reporting deadline.)

The Berlin State Senate report on Sects - their risks and consequences originally listed Landmark Education as espousing "a religious world view". The Berlin Senate subsequently retracted that, and re-classified Landmark Education as a "provider of life-assistance" (Anbieter von Lebenshilfe). (The literal translation of Lebenshilfe, "life help", does not accurately reflect the contexts in which speakers of German use Lebenshilfe.)

Religious worldviews

Paul Derengowski, formerly of the Christian cult-watch group Watchman.org, states that Landmark "has theological implications." [10] The Apologetics Index (an online Christian ministry providing research resources on what it considers cults, sects, other religious movements, doctrines, and practices) maintains a page on Landmark Education. [11]

Landmark Education states that many clergy have attended the Forum and find no conflict between the Forum and their faith. Clergy who have made statements supportive of Landmark Education include Father Gregg Banaga [12], Father Eamonn O'Conner [13], Sister Iris Clarke [14], Father Gerry O'Rourke [15], Father Basil Pennington [16], Bishop Otis Charles, Episcopal Church [17], Rabbi Arnold Mark Belzer [18], and Sister Miriam Quinn, O.P. [19].

Large Group Awareness Training?

Some commentators have described the Landmark Forum as a large group awareness training (LGAT) program, a view also espoused in a University of Denver Ph.D. dissertation by Charles Wayne Denison: "The Children of est: A study of the Experience and Perceived Effects of a Large Group Awareness Training (The Forum)" (which reported largely positive outcomes from participation). Others question the usefulness of this categorisation. In a sense the LGAT label appears clearly accurate, as Landmark courses do take place in large groups, and aim to increase awareness. On the other hand the term does have pejorative overtones for some, and it does encompass a wide range of different organisations which may have little in common in their actual activities.

Lawsuits against Landmark Education

There are a small number of allegations of mental disturbance following participation in Landmark events. The majority of these are posted anonymously on various discussion forums and cannot be verified. However, there are three instances over the fourteen years of Landmark operations which were examined in court hearings (plus the case of Martin Lell, reported above):

1) In September 1989, Stephanie Ney attended the Forum, conducted by Werner Erhard (doing business as Werner Erhardt & Associates (WE&A)). In 1992, Ney sued Landmark Education Corporation (LEC) for $2,000,000, saying that three days after attending the Forum she "suffered a breakdown and was committed to a psychiatric institute in Montgomery County." [20] The jury in the Ney case held Landmark Education not to be the cause of Stephanie Ney's emotional problems, and the appeals court also affirmed this decision [21]

The courts also ruled that LEC could not be liable in any case since the Forum that she attended had been conducted by Werner Erhard & Associates, the company whose assets LEC had purchased in 1991, and that Ney had failed to prove that LEC was a liable successor to WE&A. [22]

In 1996, Art Schreiber, legal counsel for Landmark Education stated "Out of more than 350,000 people who have participated in The Landmark Forum around the world, there has been only 1 person who filed a lawsuit. ... the United States District Court rejected Mrs. Ney's claims and ruled that The Forum did not cause her emotional problems." [23]

2) Tracy Neff sued Landmark Education,not over the content or effects of the courses, but alleging sexual harrassment and assault by a Landmark employee. Landmark lacked a sexual harrassment policy at the time, but introduced comprehensive anti-harrassment and anti-discrimination policies following this case, as well as detailed complaint and aribtarion procedures.

3) Been versus Weed with LE as a cross-defendent. Weed had had a psychotic episode shortly after his participation in the Landmark Forum, and the court ruled that there was no evidence that the Forum had been a cause of that.

Lawsuits by Landmark Education

Many media organizations have published items about Landmark Education, including Time Magazine (Landmark had no objections to the Time article, which it regards as fair and balanced) ("The Best of Est") article, and Elle. (Landmark Education sued Elle for libel for this article, then dropped the case without receiving the apology it sought. See the press release for the lawsuit from August 31, 1998.)

In September 2004, Landmark Education filed a one million USD suit against the Rick A. Ross Institute, claiming that the Institute's online archives did damage to its (Landmark Education's) product (legal term: product disparagement). In 2005, Landmark Education filed to dismiss its own lawsuit with prejudice.

Landmark Education sued Margaret Singer, a UC Berkeley professor and author of Cults in Our Midst (published in 1995) for defamation. Singer mentioned Landmark Education in her book but wasn't clear if she was calling Landmark Education a cult or not. Singer posted a retraction stating that she did not intend to call Landmark a cult nor did she consider it a cult. [24]

Hard sell?

In 1996, Jill P. Capuzzo from The Philadelphia Inquirer, Weekend took the Forum and reported "I made some eye-opening discoveries about myself and how I function in the world." She also stated that "One of the most irritating aspects of The Forum is the hard sell to sign up future participants.". [25]

Other participants have had different impressions, for instance Dr Raymond Fowler has said: "I was, along with everyone else in the group, encouraged to sign up for additional Forum sessions, but there was no coercion or high pressure sales. Participants were simply informed of the opportunities and told how to take advantage of them. In the months following the forum experience, I received, as I recall, two or three notices of forum opportunities and one telephone call which was cordial and non-coercive. I declined, because of time pressures, to attend any additional sessions and received no pressure to do so." [26]

Werner Erhard

Some critics state that Werner Erhard is still "pulling the strings" at Landmark Education [27]. Werner's younger brother is Landmark Education's current CEO. Landmark Education states that its programs are based on ideas originally developed by Erhard, but that Erhard has no financial interest, ownership, or management role in Landmark Education. [28] And in Stephanie Ney v. Landmark Education Corporation (1994) [29], the courts determined that Landmark Education Corporation did not have successor liability to Werner Erhard & Associates, the corporation whose assets Landmark Education purchased.

Management

Harry Rosenberg, CEO of Landmark Education (brother of Werner Erhard).

Mike Leavitt, President of Landmark Education

Joan Rosenberg, Vice President of Centers Division (sister of Werner Erhard).

Steve Zaffron, CEO of Landmark Education Business Development (LEBD)
Art Schreiber, general counsel. The importance of Art Schreiber's role relates to the numerous legal actions and threats of legal actions undertaken by Landmark Education, when, in Landmark Education's interpretation, media or individuals have crossed the line from free speech (including valid criticism) into the civil torts of defamation/libel [30] and false light.

Brian Regnier, prominent course designer and Landmark Forum Leader

Nancy Zapolski, PhD., VP of Course Development

Mark Kamin, Director of Media Relations

For those currently trained to lead the Landmark Forum (Landmark Forum Leaders), see these photographs.

External links

Generally critical opinions on Landmark Education

Landmark Forum: Human Potential Groups - What Potential Indeed? - anonymous personal speculation
Skeptic's Dictionary - amusing commentary
Berlin Senate report - official State government analysis and references (in German), more descriptive and not very critical at all
Swiss InfoSekta anti-cult movement (in German) (One line about the Martin Lell book, see above.)
Apologetics - a website of the Christian countercult movement offering zero evidence of personal experience with the Landmark Forum
Heidegger for Fun and Profit - some antecedents of Landmark Education philosophy
What's this Landmark Thing? - anonymous personal comment
Landmark Forum: Rants and Raves - links to various negative sites and discussion forums
Usenet group: alt.fan.landmark - unmoderated long-running discussions from multiple points-of-view
Steven Hassan's Freedom of Mind Center - part of the anti-cult movement (Author has financial self-interest in critical opinions.)
Stripping the Gurus - excerpt from book repeating generally discredited allegations against Werner Erhard
http://www.prevensectes.com/landmark.htm (in French) - site of the French anti-cult movement
Link to ELLE Magazine article posted on Google - see the libel case above.
How Orson Welles Saved the Siren - anonymous personal account

@@ Line 176: / Line 176: @@
 The courts also ruled that LEC could not be liable in any case since the Forum that she attended had been conducted by Werner Erhard & Associates, the company whose assets LEC had purchased in 1991, and that Ney had failed to prove that LEC was a liable successor to WE&A. [http://www.rickross.com/reference/landmark/landmark49.html#Appendix%20A:%20%20Text%20of%20Court%20Ruling%20in%20Ney%20Case]
+In 1996, Art Schreiber, legal counsel for Landmark Education stated "Out of more than 350,000 people who have participated in The Landmark Forum around the world, there has been only 1 person who filed a lawsuit. ... the United States District Court rejected Mrs. Ney's claims and ruled that The Forum did not cause her emotional problems." [http://www.stelling.nl/landmark/schreib2.htm]
 ) Tracy Neff sued Landmark Education,not over the content or effects of the courses, but alleging sexual harrassment and assault by a Landmark employee. Landmark lacked a sexual harrassment policy at the time, but introduced comprehensive anti-harrassment and anti-discrimination policies following this case, as well as detailed complaint and aribtarion procedures.