Does Employer Statements Of Policy Give Rise To Contractual Rights of Employees Even though It Can Be Amended By Employer Without Notice To Employees ? In Harless v. Willis Day Warehousing Co. (1978), the Court quoted remarks made by a Michigan Supreme Court: "Employer statements of policy...can give rise to contractual rights in employees...although the statement of policy...can be unilaterally amended by the employer without notice to the employee... While an employer need not establish personnel policies or practices, where an employer chooses to establish such policies and practices and makes them known to its employees, the employment relationship is presumably enhanced. The employer secures an orderly, cooperative and loyal work force, and the employee the peace of mind associated with job security and the conviction that he will be treated fairly. No pre-employment negotiations need take place and the parties' minds need not meet on the subject; nor does it matter that the employee knows nothing of the particulars of the employer's policies and practices or that the employer may change them unilaterally. It is enough that the 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. The employer has then created a situation 'instinct with an obligation.'" Day v. Good Samaritan Hosp. & Health Ctr., Ohio App. (1983), Montgomery App. No. 8062, unreported, quoting Toussaint v. Blue Cross & Blue Shield of Michigan (1980), 408 Mich. 579, 613, 292 N.W.2d 880, 892.