ARTICLE 37. MANAGEMENT EMPLOYEE RELATIONS Section 1. (a) The parties agree that the principle of a fair day’s work for a fair day’s pay shall be observed at all times and employees shall perform their duties in a manner that best represents the Employer’s interest. The Employer shall not in any way intimidate, harass, coerce or overly supervise any employee in the performance of his or her duties. The Employer shall not retaliate against employees for exercising rights under this Agreement.