The Employer’s Charter

The biggest mistake is calling it a charter. A charter is a grant of rights or at least a formal recognition that someone is entitled to exercise particular rights. The ‘Employer’s Charter’ does not do this. It just lists 11 things that an employer can do so long as it acts ‘fairly and reasonably’. Even this is subject to the qualification that ‘individual circumstances may vary and employers should act in accordance with their legal obligations’. In other words, you can’t rely on the rights set out in the charter because employment law is too complicated to be reduced to bullet points in this way.

This is a poor piece of work. Why were these 11 points chosen? Why does the charter go to the trouble of telling employers that they can withhold pay from strikers or ‘talk to employees about their performance’ but completely fail to mention that employers can sack employees for no good reason in the first year of their employment? The Government’s view may be that they are addressing particular myths that have arisen in relation to an employer’s rights. I’m in favour of myth-busting – but why call it a charter? That’s just inviting ridicule.

Badly Written

Even as an exercise in myth busting it’s a failure. It’s not well written – in fact it’s hardly a piece of writing at all. It’s just some bullet points that you can fit onto one side of A4. The only prose used actually qualifies and limits the content of the bullet points. If you are going to bust a myth, you have to explain things – give examples and illustrations. Use words to persuade and enlighten. This is just a seemingly random list of things employers can do, subject to unspecified qualifications and exceptions.

I make part of my living by writing about employment law and it’s a subject I take seriously. This charter shows all the signs of having been bashed out over somebody’s lunch break in time for a meeting. No thought is given as to how the charter is structured or phrased. Bullet points are listed in a seemingly random order and then topped and tailed with disclaimers to cover the back of whoever wrote it.

Actually, if that is how it was written I’d sort of sympathise. We’ve all had to rattle off something quickly when we’ve missed a deadline or been subjected to some random act of management. My fear is that that this charter actually represents the carefully considered fruits of the Government’s deliberations. Perhaps a team of senior civil servants spent many long hours honing the prose and carefully selecting the issues to cover. Maybe ministers considered several drafts before selecting the one that struck just the right tone. Maybe key stakeholders were carefully consulted and their views distilled into the 11 bullet points that make up the charter. Now that is a seriously scary thought. If this is a document that the Government come up with after trying their very hardest then we are all in deep trouble.

And then we come to the small matter of accuracy. Now of course you can’t really reduce complicated employment law issues to bullet point form without glossing over some of the details or leaving out important exceptions and qualifications (a good argument for not putting employment law into bullet points, I would say!). However, even making allowances for considerable simplification there are some problems with the bullet points themselves.

Asking employees to take a pay cut

I could pick apart most of the bullet points on the list, but I think the biggest single problem lies with the statement ‘you are entitled to… ask an employee to take a pay cut’. I know it only says you are entitled to ‘ask’ but in the way it is phrased it gives the impression that by ‘ask’ it means ‘require’. If you say that you are entitled to ask someone to do something – for example you are entitled to ask a police officer to show you his or her identification – then that implies some obligation on the person you ask to comply with your request. As all reading this will know, however, you are entitled to ask an employee to take a pay cut in the same way as you are entitled to ask them to come to your birthday party. You can ask them, but they are entitled to say ‘no’.

Of course if the employer needs to force through a pay cut, there are ways of doing it. But it has to be done right and if it isn’t, then legal consequences will follow. It is just irresponsible for a charter to introduce the idea of asking employees to take a pay cut and then leave the issue hanging there, with no guidance on what to do if the employee doesn’t seem keen.

The Government and Acas publish plenty of information that is well thought out and which gives useful advice to employers and employees. This ‘charter’ adds nothing useful. It is pointless, badly written and misleading. It should be withdrawn

Default Retirement Age or the Right to sack 65 year olds?

I really don’t like the phrase ‘default retirement age’. It sounds as though it covers something that happens automatically without any need for an employer to actually make a decision or do anything proactive. And did you know that the legislation simply doesn’t use that phrase at all?  In legal terms there is simply no such thing as a default retirement age. What we have instead is an exception in Schedule 9, Para 8 of the Equality Act which says that it is not discrimination to dismiss someone over the age of 65 if the reason for dismissal is retirement. This is backed up by some fiendishly complicated provisions in the Employment Rights Act describing the procedure that an employer must follow in order to dismiss someone for retirement – including giving them the right to ask for their job to be extended.

This isn’t a default retirement age – it’s a right to sack 65 year olds. The employer does not have to show that the decision is a fair one or that there is any business justification at all. As long as the procedure is followed the dismissal can’t be challenged on grounds of fairness or age discrimination.

I can understand why employers value the right to sack 65 year olds and why some would not want to see it abolished. But I struggle to see any justification for the demand made by the CBI today for businesses to be given an extra year to prepare. Prepare for what? There is no void created by the removal of the right to sack 65 year olds, just the extension of well established principles to the whole workforce regardless of age.

I’d also take issue with two other specific concerns raised by the CBI. The first is that the Government must legislate to protect conversations about retirement with employees because otherwise asking an employee what his or her plans are could amount to discrimination.

I don’t think so.

There is nothing wrong with an employer discussing an employee’s plans – provided it is not part of a campaign to force the employee out. In many employers where employees qualify for a pension before 65, these conversations go on already and they have never caused a problem. Indeed accompanied by help with financial planning they can be very positive and helpful. There should be no basis for a discrimination claim if the employer simply asks a 64 year old whether they plan to retire or not, unless the employer fails to hide its disappointment when the employee says no. Legislation to that effect is simply unnecessary.

My second issue is more general. In its press release, the CBI says:

For an employer, performance-related dismissals are already the hardest kind of dismissal to get right. Many dismissals take over a year and cause undue stress and cost to both parties. This is not a good way to end an employment relationship

I don’t dispute that many employers fail to get performance related dismissals right – but that is not the fault of employment law, it is the fault of bad performance management. If dismissals take more than a year that is absolutely not the result of some legal requirement. All employment law requires is that employees are communicated with effectively, given a reasonable opportunity to improve and a clear warning that in the absence of such improvement they face dismissal. Sprinkle in a general level of consistent treatment and you have the recipe for a fair dismissal. It goes wrong because managers fail to give effective feedback, don’t act consistently and only start ‘performance management’ when they are already at their wits’ end with the problem employee in question. It is certainly true that many employers have dealt with poor performance by waiting patiently until the employee is 65 and then ‘retiring’ them – but I don’t think it’s right for that to continue to be an option for another year.

The CBI also suggests that the Government should

Use the employment law review to streamline and rebalance the law on performance management and unfair dismissal. Introduce simpler performance and capability procedures for employers and develop better guidance for line managers to deal with declining performance among older workers. The Government should also make compromise agreements more straightforward to use.

But all the law currently requires is for employers to behave ‘reasonably’. How could the legislation possibly be simpler than that? Is the CBI suggesting that there should be something specific in unfair dismissal law requiring a procedure to be followed in capability cases? That would just make the law more complicated and give us employment lawyers more to argue about. This is just the sort of reasoning that led to the statutory dispute resolution procedures and you’ll remember what chaos ensued from that bright idea.

One thing I do agree with the CBI on though, is that the removal of the right to sack 65 year olds will lead to increased tribunal claims. That is inevitable. If you give the right not to be unfairly dismissed to people who did not previously have it then some of them will sue when they get dismissed. It is worth noting that this pretty obvious fact was completely missing from the Government’s Regulatory Impact Assessment when the consultation on sacking 65 year olds was published (check out pages 44/45). As a result the abolition of the exception was actually presented as a deregulatory measure which is simply absurd.

The Government should press ahead with the abolition of the right to sack 65 year olds and accept that this does place an additional burden on business. Under their own rules this requires them to repeal an item of regulation to the redress the balance – any suggestions?

The Equality Act and Duncan Bannatyne

I want to make one thing perfectly clear. I do not spend my time monitoring Duncan Bannyne’s activities with a view to correcting him every time he gets something wrong. I’ve never watched ‘Dragon’s Den’, which I’m sure is a splendid programme, and I know very little about Duncan Bannatyne himself. I have no doubt that he is a fine upstanding member of society, fun to be with and kind to animals. I’m sure his business skills are second to none and I will happily defer to his expertise on anything to do with running a business.

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The Problem with Positive Action

I think that there is a serious problem with the positive action provisions in the Equality Act.

The problem lies not in the principle of positive action (or positive discrimination if you prefer, I don’t care what you call it) but in how the provisions are drafted and what the coalition government is going to do about implementing them. Remember, the Equality Act does not come into force automatically, each provision needs to be brought in to force by Ministerial order. The Ministers responsible for this are the dream team of Theresa May of the Conservatives and Lynne Featherstone of the Liberal Democrats. In Parliament the Conservatives strongly opposed the positive action measures while the Liberal Democrats supported them – but that’s not the problem.

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Why BA got that injunction

You can see why Unite the Union would be cross. To have had the long and winding process of organizing large scale industrial action end in an injunction granted over 11 spoilt ballot papers out of the thousands returned seems downright bizarre. Welcome to the world of industrial action law.

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The Equality Act 2010 – when will it come into force?

The Equality Act 2010 received Royal Assent at about 5.30 on Thursday 8th April in a rather archaic ceremony in the House of Lords.

However the substantive provisions of the Act will not come into force automatically. They have to be brought into force by a Ministerial Order and that can now only happen after Parliament returns on 18th May. If a Labour Government is returned then everything will be quite straightforward and the bulk of the Act is likely to come into force this October.

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Update on an Employment Law Update

Employment law moves more quickly than any other legal area I know. Last week I presented three separate employment law updates and by the end of the week one of the cases I mentioned had been overturned by the Court of Appeal.

The case is Sarkar v West London Mental Health NHS Trust and if you were on one of the courses you may remember that that was the case where the employer originally dealt with bullying allegations by invoking their informal ‘fair blame procedure’ but then decided that following further allegations and the employee refusing to accept the outcome of the  procedure they moved to the formal procedure and dismissed him. The EAT reversed the tribunal’s finding of unfair dismissal and held that the employer was entitled to act in the way that it did.

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Trade unions funding the labour party

The trade union Unite has been in the news over the last few days in the context of the forthcoming strike at British Airways which has in turn led to a lot of noise being made about the way in which the union funds the Labour party.

While slightly off my usual beaten track of employment law, the rules governing union funds were something I wrote about quite a lot when I was a writer on IDS Brief and so I thought it might be worth summarizing the rules on political donations from trade unions. It turns out that union funding is about the most well regulated and democratic kind of political donation you could wish for.

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The thing about workplace bullying

Workplace bullying seems to be in the news this week – can’t think why.

As an employment lawyer I have a problem with bullying. Let me rephrase that. I find it difficult to talk about bullying because there is no legal concept of bullying as such. An employee can’t put ‘workplace bullying’ on an employment tribunal claim form and expect to get anywhere.Proving that you have been bullied at work – whatever that means – does not in itself mean that you have any legal claims at all.

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Political Correctness Gone Mad!

I think I first remember hearing the phrase ‘its political correctness gone mad’ in a spitting image sketch in the 1980s. I can’t remember what the sketch was about – but the Daily Mail was mentioned.

As an employment lawyer who spends a lot of time training managers on discrimination issues, I know that ‘PCGM’ features strongly in many of their initial concerns about getting to grips with discrimination law and I hope that the training I give helps to dispel some of the myths that have grown up around what, I insist, is a very common sense area of the law.

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