Jared Kushner, President Trump’s son-in-law, has presented all kinds of headaches for his White House. Forget the multiple federal investigations into the Kushner family businesses; his manifold financial interests have presented scores of potential conflicts of interest, impairing both men’s reputations and damaging the public view of Kushner’s family brand.
This all would have been avoided if Trump had followed the rules governing his Las Vegas hotel, which largely bar giving top jobs to family members.
We know about those rules because Property of the People, an advocacy group specializing in Freedom of Information Act (FOIA) litigation, obtained the Trump International Hotel Las Vegas employee handbook as part of a FOIA request of the National Labor Relations Board. The NLRB heard a case related to allegations of union-busting at the Trump Hotel in Las Vegas, and Property of the People FOIA’d the hearing transcripts as well as all the exhibits that were entered.
One of those exhibits—entered on Nov. 18, 2015—was the hotel’s Associate Handbook, which includes all the rules employees at the hotel had to follow. The handbook as it was entered in court is published in full below.
The handbook has strong words about hiring family members.
“While TIHLV [Trump International Hotel Las Vegas] does not wish to deprive itself of the services of potentially valuable Associates by establishing a policy excluding the employment of relatives, it must be acknowledged, that such employment can result in the appearance of a conflict of interest, collusion, favoritism, and other undesirable work environment conditions,” the handbook says. “Therefore, management reserves the right to limit the employment of relatives in situations within the company if a conflict of interest is deemed to exist.”
The handbook bars relatives from working “under the direct or indirect supervision of a relative.” It also bars relatives from working “in situations that create the possibility of conflicts of interest,” without the written approval of senior management officials.
This rule, however, clearly didn’t apply to the Trump family. The handbook includes photos of Trump himself, as well as his daughter Ivanka and his sons, Don Jr. and Eric. Don Jr. was hired by his father in 2001. Ivanka and Eric followed in 2005 and 2006, respectively.
“The Freedom of Information Act exists to hold government accountable,” said Gunita Singh, a staff attorney at Property of the People. “As his hotel manual demonstrates, Donald Trump doesn’t even hold himself accountable to his own standards.”
The White House directed The Daily Beast to the Trump Organization for comment on this story. Amanda Miller, a spokesperson for the Trump Organization, defended the handbook.
“The policies set forth in our employment manual are both lawful and standard in the hospitality industry,” she told The Daily Beast.
The handbook includes two provisions that employment attorneys said could run afoul of federal law. First, the handbook bars male employees from having visible tattoos, but with some exceptions for seasonal workers. Female employees, however, are totally barred from having visible tattoos—no exceptions.
“The tattoo rule appears to burden women seasonal workers more than male seasonal workers,” said Eve Hill, an attorney with Brown, Goldstein & Levy and a former official in the Justice Department’s Civil Rights Division. “So that seems to violate the sex discrimination rules on its face.”
Another issue: The handbook bans male employees (but not female employees) from having braided hair. Hill said this provision could raise concerns about racial discrimination.
“Braids and dreads for African-American men are very common and not generally considered disruptive or distracting or a poor grooming habit,” Hill said. “In fact, they can be beautiful. I think if this were applied to African-American men, you could easily get a race discrimination challenge on that basis, and the Equal Employment Opportunity Commission would seem to recognize that as potential race discrimination.”
The manual also strictly prohibits harassment. It bars “epithets, slurs, quips, or negative stereotyping” related to people’s race, religion, gender, and other factors. And it bars “‘jokes,’ ‘pranks’ or other forms of ‘humor’ that are demeaning or hostile.”
It includes a section specifically regarding sexual harassment that bars a host of inappropriate activity. Prohibited activity includes “[u]nwelcome or offensive sexual jokes, sexual language, sexual epithets, sexual gossip, sexual comments or sexual inquiries” and unwelcome flirting. It also bars “[s]exually suggestive or obscene comments or gestures” as well as “[n]egative statements or disparaging remarks targeted at one sex (either men or women), even if the content of the verbal abuse is not sexual in nature.”
Trump’s notorious “grab ’em by the pussy” remark would have run afoul of this policy. By ABC News’ count, at least 16 women have accused the president of sexual harassment or misconduct. The allegations run the gamut: Multiple women allege the president reached his hands under women’s skirts between their legs, and one, Cathy Heller, alleges that he forcibly kissed her on the lips at his Mar-a-Lago club on Mother’s Day.
Summer Zervos, a former contestant on The Apprentice who says Trump pushed his genitals against her without her consent, is suing the president for defamation because he called her a liar over that allegation.
During the campaign, Trump categorically denied all allegations of sexual misconduct and threatened to sue all the women who came forward. He has yet to follow through on his lawsuit threats.
The Trump hotel’s employee manual specifically bars “[c]oerced sexual acts,” as well as “[t]ouching or assaulting an individual’s body, or staring, in a sexual manner.”
“Beyond allowing his private corporations to unconstitutionally profit from taxpayer dollars, Donald Trump can’t even manage to follow his own company’s guidelines on sexual harassment,” Singh said. “In the White House sits a con artist and Womanizer in Chief.”
Hill noted the discrepancy between Trump’s personal behavior and his company’s requirements of its employees.
“It appears, as is often the case, that those rules are applied to the workers but not the leadership,” she said.