Footnote 173

I do not, however, suggest that parties should have to mediate complaints if a more informal process, like conversation with a supervisor or a human resources officer, solves the problem to the satisfaction of the participants--that is the point of "stepped" programs. See supra text accompanying note 154. Ms. Morse-Shamosh, PaineWebber's Program Facilitator, indicates that the majority of workplace complaints in her company are resolved before mediation, the third step in the ADR program. The earlier two involve handling through either the Open Door policy or the Issue Resolution Office; unlike mediation, these are both internal processes. See Early Dispute Resolution, supra note 169, at 2; Meade, supra note 138; see also CPR Institute, supra note 111, app. G at 457-61.