<Li> Tangible Employment Action: A tangible employment action must take place as a result of the employee's submission or refusal of supervisor's advances . In Burlington Industries, Inc. v. Ellerth, the Court stated that tangible employment action amounted to "a significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits ." It is important to note that only supervisors can make tangible employment actions, since they have the company's authority to do so . The Court also held that unfulfilled threats by a supervisor of an adverse employment decision are not sufficient to establish a "Quid pro quo," but were relevant for the purposes of a Hostile work environment claim . Additionally, The Supreme Court has held that Constructive dismissal can count as a tangible employment action (thus allowing a quid pro quo sexual harassment claim) if the actions taken by a supervisor created a situation where a "reasonable person...would have felt compelled to resign ." </Li> <P> Difference Between hostile work environment claims and Quid pro quo harassment claims: Although these terms are popular among lawyers and scholars, neither hostile work environment nor "Quid pro quo" are found in Title VII of the Human Rights of 1964, which prohibits employers from discriminating on the basis of race, sex, color, national origin, and religion . The Supreme Court noted in Burlington Industries, Inc. v. Ellerth that these terms are useful in differentiating between cases where threats of harassment are "carried out and those where they are not or absent altogether," but otherwise these terms serve a limited purpose . Therefore, it is important to remember that sexual harassment can take place by a supervisor, and an employer can be potentially liable, even if that supervisor's behavior does not fall within the criteria of a "Quid pro quo" harassment claim . </P> <P> In the United Kingdom, the one - sidedness of a contract is covered by the Unfair Contract Terms Act 1977 and various revisions and amendments to it; a clause can be held void or the entire contract void if it is deemed unfair (that is to say, one - sided and not a quid pro quo); however this is a civil law and not a common law matter . </P> <P> Political donors must be resident in the UK . There are fixed limits to how much they may donate (£ 5000 in any single donation), and it must be recorded in the House of Commons Register of Members' Interests or at the House of Commons Library; the quid pro quo is strictly not allowed, that a donor can by his donation have some personal gain . This is overseen by the Parliamentary Commissioner for Standards . There are also prohibitions on donations being given in the six weeks before the election for which it is being campaigned . It is also illegal for donors to support party political broadcasts, which are tightly regulated, free to air, and scheduled and allotted to the various parties according to a formula agreed by Parliament and enacted with the Communications Act 2003 . </P>

Which of the following can be classified as quid pro quo