Read the following excerpt from a US court opinion:
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1997) (unpublished disposition). The Court does not find those factual findings to be clearly erroneous. Therefore, the Court concludes that even if the letter had created a binding contract, Telelect was free to withdraw from the agreement given Baker’s inadequate performance. The Bankruptcy Court also considered whether the statements of policy published by Telelect and sent to Baker created a valid and binding contract under Virginia law. The trial court held that Telelect’s decision to send a copy of its statement of policy to Baker could imply a promise to abide by the terms of the statement as consideration for the distributor’s services. See In re JGB Industries, Adv. Proc. No. 96-3046 at 12-13 (citing Thompson v. American Motor Inns, Inc., 623 F.Supp. 409, 416-17 (W.D.Va.1985) ; Michael v. Sentara Health System, 939 F.Supp.
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What is the most suitable continuation to the opinion? Your options are:
A. holding that policies set out in employee handbook formed implied contractual obligations
B. holding that an arbitration agreement in an employee handbook was illusory where the employer expressly reserved a right to unilaterally rescind any provisions of the handbook
C. holding that employee handbook did not give rise to implied contract where it stated that it was not a contract and that employment was terminable at will
D. holding that an employee handbook did not constitute a valid unilateral contract between the employee and employer in the absence of adequate independent consideration
E. holding employee handbook or employers printed statement of policy are promises in implied offer of unilateral contract which an employee can accept by beginning or continuing to work for employer
Reply with [A, B, C, D, E] only.