Aggregating union members' claims based on their "common and undivided interest" in the union's contract negotiations, in conformance "with the fundamental premise of collective bargaining that a union is to represent its members in all aspects of the labor management relationship" which is "part of national labor policy"
In Delchamps, however, the NLRB attempted to impute knowledge from the supervisors at a satellite grocery store to an area supervisor who ordered the suspension of an employee based on a customer compliant.