Decision

Bargaining Unit Decision

Updated 4 November 2024

Applies to England, Scotland and Wales

Case Number: TUR1/1384(2024)

3 June 2024

CENTRAL ARBITRATION COMMITTEE

TRADE UNION AND LABOUR RELATIONS (CONSOLIDATION) ACT 1992

SCHEDULE A1 - COLLECTIVE BARGAINING: RECOGNITION

DETERMINATION OF THE BARGAINING UNIT

The Parties:

Prospect

and

ECEBS

1. Introduction

1)         Prospect (the Union) submitted an application to the CAC dated 17 January 2024 that it should be recognised for collective bargaining purposes by ECEBS (the Employer) in respect of a bargaining unit comprising “all staff in grades of Manager and below (excluding senior management i.e., heads of departments and above) and in the following departments within, ECEBS. Admin, Technical (including Development and Engineering Operations), Sales Support, Product management, Risk management.” The location of the bargaining unit was given as “The Torus Building, Rankine Avenue, Scottish Enterprise Technology Park, East Kilbride, Glasgow, G75 0QF.” The application was received by the CAC on 17 January 2024 and the CAC gave both parties notice of receipt of the application by a letter of the same date. The Employer submitted a response to the CAC dated 24 January 2024 which was copied to the Union.

2)         In accordance with section 263 of the Trade Union and Labour Relations (Consolidation) Act 1992 (the Act), the CAC Chair established a Panel to deal with the case. The Panel consisted of Mrs Sarah Havlin, Panel Chair, and, as Members, Mr Alistair Paton and Mr Matt Smith. For the purposes of this decision Mr Alistair Paton was replaced by Mr Richard Fulham. The Case Manager appointed to support the Panel was Joanne Curtis.

3)         By a decision dated 12 February 2024 the Panel accepted the Union’s application. The parties then entered a period of negotiation in an attempt to reach agreement on the appropriate bargaining unit. As no agreement was reached, the parties were invited to supply the Panel with, and to exchange, written submissions relating to the question of the determination of the appropriate bargaining unit.

Hearing

4)         A hearing was held via zoom on 2 May 2024 and the names of those who attended the hearing are appended to this decision. Both parties provided written submissions prior to the hearing together with supporting documentation. The Panel would like to thank the parties for answering the questions raised by the Panel during the hearing. The information provided was very helpful to the Panel.

2. Background

5)         The Employer is a software company that specialises in smart electronic ticketing solutions for the public and transport sectors. On 4 August 2023 Unicard Limited acquired 100% of the share capital in ECEBS from Visa Europe Limited. Following the acquisition, the Employer said that urgent cost-saving exercises were necessary in order to safeguard the future of the ECEBS business, ensure the sustainability of its operations, protect jobs and avoid redundancies wherever possible. The Employer said it therefore carried out a consultation process for the purpose of making changes to employees’ contractual terms and conditions, including benefits, with a view to improving financial viability. The Employer said that the original organogram provided to the Union showed a relatively “flat” management structure with 27 workers in the ECEBS business. The Employer said that the structure contained in the original Organogram was in place at the time of the Union’s application to the CAC however since then, the business had been restructured. The Employer said that the acquisition had given rise to claims which were currently the subject of proceedings before the Glasgow Employment Tribunal. These matters are not within the jurisdiction of the CAC, and nor do they form any part of the Panel’s decision.

3. The 21-worker threshold

6)         The Original Organogram showed the structure of ECEBS at the date of the Union’s application to the CAC but also two impending changes at that date: the Principal Software Architect was leaving the business on 31 March 2024 and one of the Project Managers was retiring at the end of March 2024. The Employer said that on 18 March 2024 it had announced a proposed restructure and commenced a period of consultation. The Employer went on to say that the outcome of the process, which was communicated on 11 April 2024 was:

“a. Six roles were to be made redundant: Finance, Test Engineering Architect, Risk and Accreditations Manager, Test Engineer, Dev Ops Engineer, Senior Systems Administrator. The affected employees cannot be redeployed and were given notice of termination of employment on 17 April 2024. At the time of drafting these submissions the appeal process has not completed.

b. One employee resigned during the consultation process; the Senior App Support Engineer.

 c. One role which had been considered for redundancy, the Service Support Manager, was not selected for redundancy.”

7)        The Employer said that this meant (subject to an ongoing appeal process) that there was likely to be 15 roles in the business at the date of the CAC hearing (including those working notice periods). The Employer said this was below the 21 worker threshold for the statutory recognition regime and therefore there ought to be no statutory recognition of the Union. Further and alternatively, the Employer said that if the CAC was to determine the bargaining unit based on the structure of ECEBS at the date of the Union’s application, “whilst it may be that the application for recognition would fail at the validity stage (paras 20(2) and 43 to 50” of Schedule A1 to the Act (the Schedule)), “if it does not then ECEBS is likely to make an application under Part III regarding changes to the BU.” The Employer said that in doing this the parties would incur additional time and cost, and it would cause great uncertainty “on the ground” (including for the employees) and therefore was inconsistent with paragraph 171 of the Schedule.

8)         The Employer said that it must be correct for the CAC to take into account changes which were being implemented at a business when it was required to determine whether a bargaining unit was  appropriate because: “a. The CAC has to make its decision with regard to encouraging and promoting fair and efficient practices and arrangements in the workplace; this is to be applied (so far as possible) consistently with the provisions of [paragraph 171 of the Schedule]. b. It is not consistent with this for an employer, workers and a union to be dealing with consultation on and/or implementation of changes in a workplace, whilst at the same time attempting to work out together how a BU should be formulated and how collective bargaining should work. This increases the administrative burden for the employer, cuts across the consultation process and therefore increases uncertainty for all participants. This is particularly so in a small workplace such as ECEBS where changes are necessary to (1) ensure the financial viability of the business and safeguard jobs; and (2) ensure the business structure reflects ECEBS’ products and the needs and demands of the market in which it operates. c. This is also consistent with the primary matter the CAC is required to consider i.e., the need for the BU to be compatible with effective management [see paragraph 19B(2)(a) of the Schedule].”

9)         The Employer said that it was correct that the Schedule made provision for changes to be made to a bargaining unit once it has been determined (Part III of the Schedule). The Employer said where the structure of a business had changed between a Union’s application and the date when the CAC considered the bargaining unit if there were fewer than 21 employees remaining in the business the CAC ought not to determine a bargaining unit because it was outside the purpose of the regime in the Schedule; and if the CAC did make a determination of the bargaining unit based on the structure of the business at the date of the application by the Union then it was likely that one of the parties would apply under Part III of the Schedule to make changes to the bargaining unit. The Employer said that this was contrary to paragraph 171 of the Schedule given that it would require the parties to incur additional time and cost; “and/or to the extent that the BU is unstable, then determining a BU is likely to be contrary to paragraphs 19B(2) and 171 of [the Schedule].”

10)       The Panel further considered oral representations from the parties on this issue at the Bargaining Unit hearing on 02 May 2024.

11)       The Panel’s decision on the specific issue of the 21 worker threshold is set out at paragraphs 24-25 below.

4. Summary of the submissions made by the Union 

12)       The Union said that it was unsure of the Employer’s objections to the proposed bargaining unit, apart from one issue with the title of a role. The Union said that it was aware that the Employer had informed the CAC of redundancies and the likelihood of the business going below the threshold of 21 workers. The Union said that as far as it was aware the law stated that as long as the Employer had 21 workers at the time of the request this would not affect the outcome of a decision. The Union referred to the previous CAC acceptance decision in URTU v Industrial Chemicals Ltd, Acceptance Decision, TUR1/1385(2024) (15 February 2024).

13)       The Union said that there was no current arrangement in place between the Employer and the Union however the Union had undertaken research when selecting the bargaining unit and had considered TUR1/1356(2023) Prospect & Dock 10 Ltd where the bargaining unit was symmetrical to the one the Union had proposed to the Employer and TUR1/1374(2023) Prospect & Gloucestershire airport where the majority of workers were all based on one site in Scotland.

14)       The Union said that given the small size of the company it had proposed a bargaining unit consisting of “all staff in grades of Manager and below (excluding senior management i.e., heads of departments and above) and in the following departments within, ECEBS.

• Admin

• Technical (including Development and Engineering Operations)

• Sales

• Support

• Product management

• Risk management”

15)       The Union attached the “Unicard handbook” that all workers were required to adhere to. The Union said that this demonstrated the rationale for the Union’s bargaining unit. The Union said that workers within the proposed bargaining unit were based within the East Kilbride office in Scotland and at the time of voluntary recognition there were one or two who were not based at that office.

16)       During the hearing on 2 May 2024 the Union added to its written submissions and said that there was a clear continuing desire for collective bargaining on the part of the workers concerned. The Union said that the bargaining unit was appropriate in that it did not cause fragmentation. The Union said that it was compatible with effective management, and that this was a modest test which meant that the bargaining unit needed only to be able to coexist with effective management and did not need to be the optimal unit. The Union said that any redundancies in the workplace did not change the fact that at the material time the business met the minimum worker threshold. At a very late point in the hearing and also in response to the 21 worker threshold the Union said that the size of the Employer must be looked at by the CAC in the context of its associated companies.

5. Summary of the submissions made by the Employer

17)       The Employer rejected the Union’s proposed bargaining unit as described as “all staff in grades of Manager and below (excluding senior management i.e, heads of departments and above) and in the following departments within, ECEBS. Admin, Technical (including Development and Engineering Operations), Sales, Support, Product management, Risk management.” The Employer said that the Union’s application stated that the reason for selecting the proposed bargaining unit was “the small nature of the company and that all roles are specialised the rationale is to have one bargaining unit for all staff.” The Employer said that in the Employer’s response document it had said it did not agree that there were 27 roles in the proposed bargaining unit and that it disagreed because there had been significant changes to the workforce which had not been reflected in the Union’s calculations and there was no Risk Management function within the business. The Employer went on to say that the Union’s proposed bargaining unit was incompatible with effective management because: (a) it included all roles across all functions of the business save for the general manager and (b) it would give rise to internal conflicts of interest. The Employer said “it is unstable. A finding that it is in fact appropriate would be inconsistent with the CAC’s object of encouraging and promoting fair and efficient practices and arrangements in the workplace (paragraph 171 of the Schedule).” The Employer said that the interaction between the Employer and the Union was “currently cordial.” The Employer said that the Union had failed to explain its rationale for the proposed bargaining unit “so as to enable ECEBS to engage with the substantive issues of who should be in any BU and why.” The Employer went on to say that “without prejudice to its position” there ought to be no statutory recognition due to the 21 workers threshold.

18)       The Employer said that the Union’s proposed bargaining unit based on the original organogram included all roles except for the General Manager. This included the Technical Team (under the Principal Software Architect) and the Operations Team (under the General Manager) and very senior roles for example the Senior Systems Administrator alongside very junior roles for example Graduate Software Engineer. The Employer said that it would be inconsistent with effective management for the Technical Team to be in a bargaining unit with the Operations Team because the former focused on IT development, whilst the latter focused on customer-facing and outwards business development. The Employer said that this meant that the objectives of both sides of the business were unlikely to be aligned when it came to matters which would be collectively bargained, “for example: a. The Accreditations and Risk Manager is responsible for International Organization for Standardization (‘ISO’) audit and accreditation (see job description on p76). It is imperative that this role (and the person performing it) be independent and objective. Being part of a BU has the potential to seriously undermine this. b. “Developers” (i.e. Software Engineers, Senior Software Engineer) write code and “Testers” (i.e. Test Engineers) test it to ensure that it does what it is designed to do. Including both of these functions in one BU could either cause a conflict of interest between both groups, or create potential for testers to be less robust in their testing. The latter could lead to code being deployed by ECEBS which contains security vulnerabilities and would undermine the product being sold to customers. c. Including Project Management (i.e. Project Manager Roles) and Customer Service (i.e. Service Managers, Senior App Support Engineer, App Support Engineer, Support Engineers) roles along with Developers and Testers within the BU has the potential to create a conflict of interest. Also, Developers need good quality information in order to carry out their work; Project Managers extract and share information about customer requirements. If a defective product is delivered, complaints about this will be made to the Customer Service team who are also responsible for debugging. In short, these roles need to work independently in order to ensure robust business practices are in place and that a high quality product is delivered. d. There is potential for a conflict of interest between a Database Administrator (who deals with particularly complex product development issues) and Developers and Testers because if poor quality code is utilised then the Database Administrator has to debug it. e. There is potential for a conflict of interest between IT and technical (Development and Testers) and Project Management roles. These functions need to work together to co-ordinate the scope of work being carried out and to ensure that the necessary infrastructure is in place.”

19)       The Employer said that the fact that there was a relatively “flat” structure to the Organogram should not obscure the fact that the relatively small team of employees at ECEBS included those performing very senior and very junior roles. “For example: a. The Senior Systems Administrator is the second most highly remunerated role in the business. It is clear from the job description (p68) that this role has a high level of responsibility i.e. for designing, installing, operating, and troubleshooting computer, storage, and network systems (including wireless) to meet business objectives. b. The Senior Software Engineer role is also a very senior role with considerable responsibility (p70) and is required to design, develop, test and deliver … Ticketing products and services to meet requirements to agreed standard timescale. c. The System Administrator role is comparably junior and involves providing support for IT within the business (p72).” The Employer said that it was unrealistic to expect all of these roles to be contained within one bargaining unit. The Employer went on to say “senior roles have significant responsibility for running the business as a whole and supervising and mentoring junior employees. In a small business where the people performing these roles are expected to work closely together, which will involve constructive feedback being delivered by senior roles, this has the very real potential to create conflicts within the BU.”

20)       The Employer emphasised that including managers with line management responsibilities in the same bargaining unit as their direct reports effectively put them on both sides of the table. The Employer said that this would undermine the line management structure which depended on senior roles being able to actively manage their direct reports (which involved setting objectives, monitoring performance, managing quality of output and preparing timetables). The Employer said “the salary details of the relevant roles are contained in the Anonymised Salary Details spreadsheet (p81). This shows a significant disparity between renumeration packages across the roles. It is incompatible with effective management and inappropriate for senior employees on higher salaries to collectively bargain their pay with more junior employees on more modest salaries; an employer may be more inclined to make larger 15 percentage increases for employees on lower salaries than higher salaries. Likewise, it is incompatible with effective management and inappropriate for employees with benefits to collectively bargain their salary with those who do not. Employees with benefits may be content to take a lower increase to their salary (knowing they have a benefit “on top”) than employees without benefits. There is clearly potential for tension within the BU in these scenarios.”

21)       In an email dated 14 March 2024 the Employer suggested a bargaining unit which would consist of the two Senior Application Support Engineer roles, one Application Support Engineer and one Finance role because “a. These roles are all in the Operations Team and therefore this proposed BU does not cut across both halves of the business. b. None of these roles have direct reports.” The Employer concluded its written submissions by saying that the bargaining unit as suggested by the Employer was compatible with effective management based on the “original Organogram.”

22)       In the oral submissions the Employer re iterated that the 21-worker threshold was no longer met after significant business restructuring and the resulting loss of 6 roles. The Employer set out an updated organogram to illustrate the significant staff changes and changes to business functions and said that the CAC should therefore interpret the Schedule in the context of the overall provisions of paragraph 171 to encourage and promote fair and efficient practices and arrangements in the workplace. The Employer went on to say that even if the Panel did not accept the 21 worker threshold argument did not apply at this stage the bargaining unit was not compatible with effective management as it merged wholly different functions and did not align with the structure of staff teams. The Employer said that the seniority of some of the managers included would mean that some workers would have to ‘sit on both sides of the table’ on pay negotiations which would be a conflict of interest. The Employer explained that Managers received a salary plus a package of benefits which was different from more junior staff in terms of remuneration and reward. In response to questions from the Panel the Employer confirmed that decision making power on pay rested with the Chairman/CEO.

23)       To assist the Panel the Employer then went on to detail the roles that had now been entirely removed from the business and reiterated that it was not merely a matter of people leaving but that the functions of those roles no longer existed. The Employer said that the business now had a ‘more lean structure’ with fewer functions. The Employer proposed a small bargaining unit limited to the operations team which, unlike that proposed by the Union, the Employer said would not cut across business operations.

6. Considerations

The 21-worker threshold

24)       Before turning to the statutory considerations which are used to determine whether the proposed bargaining unit is appropriate and, if found not to be appropriate, to decide in accordance with paragraph 19(3) a bargaining unit which is appropriate the Panel has considered the issue of the 21-worker threshold and the Employer’s submission that the application is no longer valid due to the recent changes to the workforce.  The Employer explained that this meant that the total workforce had reduced in size and it now employed less than 21 workers. The Panel has considered the provisions under paragraph 7(1) of the Schedule which states that the request is not valid unless the Employer taken with any associated employer or employers, employs –

(a) at least 21 workers on the day the employer receives the request, or

(b) an average of at least 21 workers in the 13 weeks ending with that day.

It is clear that the requirement to ensure that the Employer employs a minimum of 21 workers applies on the day the Employer receives the request from the Union.  The requirement of the 21-worker threshold only applies at that stage and it is only considered by the CAC when the application is first received. There is no provision for this issue to be revisited at any other stage in Part I of the Schedule. The 21 worker threshold argument is therefore not a relevant consideration for the Panel and the fact of a change to the 21 worker threshold cannot invalidate an application after it has been accepted by the CAC.

25)       Finally on this issue, it should be noted that at the end of the hearing the Union raised an additional point on the issue of the 21 worker threshold which related to the issue of ‘associated employer/employers’ under paragraph 7 of the Schedule. The Union argued that the Employer’s undertaking was part of a wider group of companies that was larger than 21 workers which should be considered in response to the Employer’s argument that the Employer’s undertaking no longer met the 21 worker threshold. This was an argument not previously raised which was pointed out by the Employer. However, in light of the findings of the Panel that the 21 worker threshold is not a permissible consideration for the Panel and cannot be revisited under Part 1 of the Schedule, this late argument advanced by the Union was not a relevant consideration and did not influence the Panel’s conclusion on the issue.

7. The Bargaining Unit

26)       The Panel’s task as required, by paragraph 19(2) of the Schedule, is to decide whether the proposed bargaining unit is appropriate and, if found not to be appropriate, to decide in accordance with paragraph 19(3) a bargaining unit which is appropriate. Paragraph 19B (1) and (2) state that, in making those decisions, the Panel must take into account the need for the unit to be compatible with effective management and the matters listed in paragraph 19B(3) of the Schedule so far as they do not conflict with that need. The matters listed in paragraph 19B (3) are:

(1) the views of the employer and the union;

(2) existing national and local bargaining arrangements;

(3) the desirability of avoiding small, fragmented bargaining units within an undertaking;

(4)   the characteristics of workers falling within the bargaining unit under consideration and of any other employees of the employer whom the CAC considers relevant; and

(5)   the location of workers.

27)       Paragraph 19B(4) states that in taking an Employer’s views into account for the purpose of deciding whether the proposed bargaining unit is appropriate, the CAC must consider any view the Employer has about any other bargaining unit that it considers would be appropriate.  The Panel must also have regard to paragraph 171 of the Schedule which provides that “in exercising functions under this Schedule in any particular case the CAC must have regard to the object of encouraging and promoting fair and efficient practices and arrangements in the workplace, so far as having regard to that object is consistent with applying other provisions of this Schedule in the case concerned.”

28)       In reaching its decision the Panel has taken account of the views of the Union and the Employer as expressed in their written submissions, responses to questions and oral submissions during the hearing.

29)         The Panel’s first responsibility is to decide, in accordance with paragraph 19(2) of the Schedule, whether the Union’s proposed bargaining unit is appropriate. That does not require the Panel to determine whether it is the most appropriate bargaining unit; only whether it is appropriate. This is the overriding requirement under paragraph 19B(2) and relates principally to the matters to be collectively bargained for under the statutory regime, namely pay, hours and holidays. The requirement is that the proposed bargaining unit would be compatible with effective management, not that it be compatible with the most effective management. Against the background of that overall responsibility the Panel has to consider the matters listed in paragraph 19B(3) of the Schedule, reminding itself that these matters must not conflict with the need for the unit to be compatible with effective management.

30)       The Panel finds in the current circumstances that the bargaining unit proposed by the Union is not appropriate. The Panel’s reasons are as follows:

The Union’s proposed bargaining unit is stated as:

“all staff in grades of Manager and below (excluding senior management i.e., heads of departments and above) and in the following departments within, ECEB:

•           Admin

•           Technical (including Development and Engineering Operations)

•           Sales

•           Support

•           Product management

•           Risk management

It is conceded by the Union that certain workers and categories of workers, which are explicitly set out in the description of the bargaining unit, can no longer be included in the bargaining unit as originally framed because they are roles which no longer exist within the workforce. The roles no longer existing were set out in detail by the Employer at the hearing. It was noted that the loss of one person in a function resulted in the removal of that entire business function/department. It is therefore the conclusion of the Panel that the Union’s description of the bargaining unit can no longer be said to be appropriate as it contains specific references to roles or categories of jobs which do not exist or have been entirely removed from the business.

31)       In terms of considering  whether the changes to the constituency of the bargaining unit would result in a bargaining unit which is ‘different’ the Panel has considered the case of ISTC and Eminox Ltd (TUR1/152/02, 25 October 2002), per the CAC at para 23 and is persuaded by the reasoning therein: The question whether a final bargaining unit differs from the original proposal is a question of definition, not content. The question is whether the boundaries are the same. It is ‘not a question . . . to be determined by degrees of difference but is a matter for a common sense decision on whether the two bargaining units . . . are the same’ or not (ISTC and Eminox Ltd (TUR1/152/02, 25 October 2002), per the CAC at para 23). The Panel also noted previous CAC decisions on this issue which decided that a bargaining unit which includes controllers is a different unit from one which excludes controllers, even if in fact the employer employs but one controller (GMB and Volvo Truck and Bus (South) Ltd (TUR1/223/02, 18 February 2003), CAC); a unit which includes the caretaker is a different unit from one which excludes the caretaker (NATFHE and LEAP Services (TUR1/470/05, 21 December 2005), CAC); a unit which excludes maintenance workers is a different unit from one which includes maintenance workers, even if there are only two maintenance workers

32)       The Panel has therefore determined that a bargaining unit consisting of ‘all staff in grades of General Manager and below (excluding senior management i.e., heads of departments and above).’ is an appropriate bargaining unit. The Panel considers that this bargaining unit is compatible with effective management based on the roles and responsibilities currently in place.

33)       A final point to address is that the Panel notes that the Employer’s submission argued that the inclusion of Mangers within the bargaining unit would create a conflict of interest owing to their managerial roles. However, the Panel does not regard the inclusion of roles such as ‘General Manager’ as being incompatible with effective management. The purpose of the bargaining unit is for the bargaining of pay hours and holidays. The Panel understands from the Employer’s evidence given at the hearing that the decision making power on pay hours and holidays sits above all of those workers included within the appropriate bargaining unit as set out above, including the role of General Manager. The Panel therefore finds that there is no evidence that there would be any unmanageable conflict of interest for the purpose of pay bargaining and a bargaining unit which includes workers with management functions cannot reasonably be said to be unable to coexist with effective management, particularly given that the Employer confirmed, in response to the Panels direct question, that the ultimate decision making power on pay in the Employer’s undertaking sits outside the remit and influence of any of the workers included.  

34)       The Panel has considered the matters listed in paragraph 19B(3) of the Schedule, so far as they do not conflict with the need for the unit to be compatible with effective management:

(1)       The views of the Employer and the Union, as described earlier in this decision, have been fully considered.

(2)       The Panel does not consider that there are any existing national or local bargaining arrangements in this case.

(3)       The bargaining unit does not present any risk of small fragmented bargaining units within the undertaking given the overall size of the undertaking.

(4)       In terms of the characteristics of workers, the Panel notes that the bargaining unit includes different roles and responsibilities but the shared characteristics of the workers, such as employment terms and conditions and the fact that all of the workers are subject to the same company handbook, are sufficiently unifying for the purpose of collective bargaining for all of the workers included in the bargaining unit. Any differences between individual terms and conditions of the workers are not of such a level and scale which would prevent their co-existence with effective management of a single bargaining unit, which, in the judgment of the Panel, is a sufficiently cohesive group of workers for the purpose of negotiating pay hours and holidays for the workers concerned.

(5)       Finally, the Panel notes that all the workers in the bargaining unit are located in one business location.

The Panel is therefore satisfied that its decision is consistent with the object set out in paragraph 171 of the Schedule.

8. Decision

35)       The Panel’s decision is that the appropriate bargaining unit is ‘all staff in grades of General Manager and below (excluding senior management i.e., heads of departments and above).’

36)       For the reasons outlined in paragraph 30, the appropriate bargaining unit differs from the proposed bargaining unit, therefore the Panel will now proceed under paragraph 20(2) of the Schedule to decide if the application is valid within the terms of paragraphs 43 to 50 of the Schedule.

Panel

Mrs Sarah Havlin, Panel Chair.

Mr Richard Fulham.

Mr Matt Smith.

3 June 2024

9. Appendix

Employer:

Counsel Alice Carse of 4 Pump Court Chambers

Sean Dickinson of ECEBS

Ginette Ramsell of ECEBS

Union:

Robbie Young

Steven Hall