Appellant (Sisco) was fired from her job when she refused to come to work one snowy day in December 1993. She sued for wrongful termination under what she contends was a contract between herself and appellee (hereafter the Credit Union) setting forth specific conditions for discipline and discharge. The trial court, concluding that the Credit Union’s Policy Manual created no such contractual relationship as a matter of law, granted summary judgment to the Credit Union. This appeal presents two questions. First, were the terms of the Policy Manual enough, for purposes of summary judgment, to overcome the traditional presumption of at-will employment in the case of an employee, like Sisco, who had no other contractual right to continued employment? And, if so, was the promise of job security contained in the Policy Manual supported by adequate consideration?
See Rinck v.
Association
of Reserve City Bankers,
I.
Sisco began working as a loan processor for the Credit Union in 1985, and was promoted to head teller two years later. Beyond a ninety-day probation period, there were no formal terms of her employment during this time. In March 1988, the Board of Directors of the Credit Union adopted a written Policy Manual intended to “act as a guide for everyone in the organization.” In her affidavit opposing summary judgment, Sisco asserted that at that time the Credit Union’s “manager gave us the manual at a staff meeting!,] ... told us that the manual is our ‘bible,’ ” and stated that it “would answer all questions about our job, [that] we should read it to answer anything we wanted to know, and that if we lost it we would have to pay a cost.”
The Policy Manual states at the beginning that “[i]t is clearly understood that the board [the Board of Directors] alone is responsible for setting policy,” and that the manual “becomes the policy of the new board” only after adoption annually by the newly constituted board. Sisco does not dispute that the Board adopted the Policy Manual unilaterally without input from the Credit Union’s employees, and that the Board could revise or discontinue use of it at any time without consent of the employees. 1
The record contains only portions of the Policy Manual, and our review is limited to those parts. Under the heading “Part III— Personnel,” the manual has a section entitled “Probation,” which states that “[b]oth management and staff are to be employed on a 90 *54 day management probationary period” and that “[t]he manager[ 2 ] serves at the pleasure of the board of directors.” During the probationary period “an employee may be dismissed without recourse, if that employee is a new employee.” Upon “successful completion of probation, an employee shall receive a step increase.”
At the center of this dispute is section 17, “Discharge or Discipline.” It contains a “guide to progressive discipline,” which is invoked only after a supervisor has made less formal efforts to resolve problems of unsatisfactory work or inefficient use of time by an employee. If “progressive discipline” is necessary, the manual provides that it “shall be handled as follows”:
1) 1st offense. Written reprimand with or without suspension, up to three work days.
2) 2nd offense. Written reprimand with or without suspension, up to five work days.
8) 3rd offense. Discharge (this applies if first two reprimands accumulate within a twelve-month period for similar offenses). Where third offense does not result in discharge, reprimand with or without five days suspension.
4) 4th offense. Discharge when four offenses of differing nature occur within a twelve-month period.
The Policy Manual goes on to enumerate twenty-nine “causes for progressive disciplinary action,” including unexcused absence and refusal to accept a job assignment, but adds that these reasons “shall not be deemed to exclude the credit union’s right to discipline or discharge employees for any other cause.” The manual also enumerates eleven acts of a more serious nature, including misappropriation of funds, falsifying records, and insubordination, and provides as to these:
An employee will be temporarily suspended without pay if there are reasonable grounds to believe that any of [these] acts have been committed. Conclusive proof shall result in immediate discharge effective from the time of suspension. If charges are not proven, the employee will be reinstated with full back pay.
In her affidavit, Sisco asserted that some time in 1993 she “was told by an official of [the Credit Union, a Mrs. Daisey Graham,] that I have a right to file a grievance based on the ‘policy book.’ ”
II.
This is not the first time the court has considered whether an employer personnel or policy manual, by its terms and the manner of its distribution, served to create a jury issue regarding whether an otherwise at-will employment relationship gave way to an implied contract limiting the right to discharge. Our first case dealing directly with the issue,
Washington Welfare Ass’n, Inc. v. Wheeler,
An employer’s personnel manual is evidence of the terms and conditions both employer and employee accept as part of the agreement.... Whether a personnel manual creates contractual rights for the employee is a question for the jury.... [T]he Manual [here] evidences intent of the parties that specific preconditions had to be met before employment could be terminated. ...
Id.
at 615-16. In
Nickens v. Labor Agency of Metro. Wash.,
In two other decisions, by contrast, we have found language present in the personnel manual negating the inference of an implied contract. In
Elliott v. Healthcare Corp.,
Finally, in
Rinck,
All told, we think the teaching of these decisions is that assurances by an employer in a personnel or policy manual distributed to all employees that are clear enough in limiting the right to terminate to specific causes or events will overcome the presumption of at-will employment. Such a promise, if supported by adequate consideration,
Rinck,
The Credit Union relies chiefly on the fact that the Policy Manual announces itself “as a
guide
for everyone in the organization” and describes the discharge or discipline provisions as a
“guide
to progressive discipline” (emphases added). It further points to the manual’s reservation of “the credit union’s right to discipline or discharge employees for
any other cause”
(emphasis added) than the twenty-nine enumerated. These provisions, we hold, are insufficient to overcome the assurance conveyed by an objective reading of the entire document that termination will be governed by its terms. First of all, the Policy Manual identifies specifically those who “may be dismissed without recourse”: new probationary employees, of which Sisco was not one. At another point it states that, while both management and staff are to be employed on a ninety-day probationary period, “[t]he
manager
serves at the pleasure of the board of directors” (emphasis added). Section 17, while described as “the guide to progressive discipline,” uses mandatory language in stating that informal steps “shall” be taken to correct a situation before instituting the guide, and that, once invoked, “[progressive discipline shall be handled” in a carefully calibrated manner depending on which “offense” has been committed up to the fourth. While the then-enumerated offenses or “causes for progressive discipline” are “simply meant to be samples,” the most natural reading of the reserved right to discipline or discharge “for any other cause” is that it means other causes for, or acts warranting,
disciplinary
action in accordance with the manual — not discharge for any or no reason at all.
See, e.g., Witkowski v. Thomas J. Lipton, Inc.,
The definiteness of these job-security provisions perhaps makes it unnecessary to consider the circumstances of the manual’s distribution, but they do not weaken Sisco’s case. Although the procedures for its delivery to employees are not formally prescribed as they were in
Nickens,
We conclude that a jury reasonably could find in the Policy Manual a promise of continued employment to nonprobationary employees, terminable only for cause in accordance with its provisions.
III.
There is another step to the analysis, however. The Credit Union adopted (and periodically revised) the Policy Manual without any negotiation with the employees over its terms. Sisco concedes that the only consideration the employees provided in return for the promise of job security it contained was the loyal continuation of their services. The question we must answer is whether this was enough.
“Generally, consideration is necessary to make a promise enforceable.”
Rinck,
The court in Rinck, however, expressly declined to decide whether that rule applied in the different setting where “an employer issues employee handbooks to those who had previously commenced employment.” Id. Noting a division of authority elsewhere on the point, it nonetheless opined:
Special factors are present in general personnel policy situations such as those involving employee handbooks. An employer, for example, may reasonably expect to benefit from better morale and a generally more cooperative attitude on the part of its entire workforce as a result of the promulgation of such a handbook. Moreover, enforcement of a handbook’s provisions does not depend upon resolution of a fact issue created by an employee’s recollection of a verbal exchange concerning such matters as the employer’s right to terminate.
Id. at 17 n. 5 (dictum). We today decide the issue left open in Rinck, and hold that remaining with an employer after receipt of a personnel manual promising job security supplies the necessary consideration to make the promise legally enforceable.
First, as the final sentence of the quotation from Rinck implies, the need for additional *57 consideration beyond work continuation in order to confirm the employer’s intent to be bound is diminished when that intent is expressed in a written manual given to all employees which expressly treats matters of termination and discipline. 4 Moreover, also in keeping with the Rinck language, we do not agree that the consideration of remaining with the employer in return for job security assurances is insubstantial: by instituting a company-wide policy concerning discipline and discharge,
[t]he employer secures an orderly, cooperative and loyal work force_ [T]he employer chooses, presumably in its own interest, to create an environment in which the employee believes that, whatever the personnel policies and practices, they are established and official at any given time, purport to be fair, and are applied consistently and uniformly to each employee.
Toussaint v. Blue Cross & Blue Shield of Mich., 408
Mich. 579,
The Credit Union argues, and it has been suggested, that the employer’s reserved right to modify the manual’s terms unilaterally “tends to show that any ‘offer’ made by the [employer] in distributing the manual was illusory.”
Jackson v. Action for Boston Community Dev. Inc.,
The order granting summary judgment is, accordingly,
Reversed.
Notes
. The parties agree that there is a factual dispute, not resolvable by summary judgment, as to whether the Policy Manual was still in effect at the time of Sisco's firing.
. Elsewhere the “manager” is defined as "the principal operating officer of the credit union.” Sisco, although the head teller, was not the manager.
. This case concerns only a discharge for reasons of discipline. We have no occasion to consider the bearing of the Policy Manual on terminations occasioned, for example, by job reclassification or reduction in workforce.
.
See Littell,
. The Credit Union, citing
Schoen v. Consumers United Group, Inc.,