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The bill went through more than five hundred amendments before being passed by majority vote in the House (307-116) on July 27 and in the Senate on July 28 (70-24). The legislation made two amendments to the Social Security Act of 1935. ... On July 30, 1965, President Johnson signed the bill, making it Public Law 89-97.
Your 28 days holiday is free holidays (assuming you have not including predetermined holidays - i.e public holidays)
28 days divide by 12 months = 2.333 days
Your holiday year cannot be April to April as this is 13 months - so I have assumed it is April to March, or it could be May to April - This will affect how many holidays you have earnt upto August.
Multliply the 2.33 days per month by the number of months until your holiday in August. The calculation your employer is using may take into account you have to earn full days by the end of the month before you take a holiday.
2.33 days X 4 months to end of July = 9 days 2.33 days X 5 months to end of August - 11 days.
You may have to exclude the public holidays if this is included in your annual allowance