IN THE EMPLOYMENT AND DISCRIMINATION TRIBUNAL

 

 

IN THE MATTER:

 

 

BETWEEN

FIRE AND RESCUE SERVICE ASSOCIATION

CLAIMANT

 

AND

 

 

STATES EMPLOYMENT BOARD

RESPONDENT

 


 

TRIBUNAL JUDGMENT


 

 

Reference:                  [2018] TRE 133

 

Hearing Date:                14 November 2018                            

 

 

Before:                         Mrs H G Griffin, Chairman

                                    Mr S Cross and Mrs E Harper, Panel Members

 

Appearance:

For the Claimant:           Mr B King, Prospect

For the Respondent:     Mr J Goudie QC, 11 Kings Bench Walk

 

 

THE DECISION

 

The Respondent failed to observe the terms and conditions of a collective agreement which was relevant to a dispute between the Claimant and the Respondent.

 

 

THE REASONS

 

The Complaint

 

1.       By a claim form presented on 4 September 2018, the Claimant made an application to the Tribunal (“Application”) under the provisions of the Employment Relations (Jersey) Law 2007 (“ERJL”).

 

2.       The Application was brought by the President of the Fire and Rescue Service Association (“FRSA”) on behalf of those members of the FRSA who were employed by the Respondent (“SEB”) before 1 January 2016 (“Members”).

 

3.       The FRSA seeks a declaration from the Tribunal that the SEB has acted (and continues to act) “unreasonably” by failing to comply with an agreed procedure for the resolution of disputes which is contained in a collective agreement between the FRSA and the SEB dated 2010 (“Collective Agreement”).

 

4.       The SEB contests the Application.

 

The Issues

 

5.       On the basis of the claim and response forms presented by the parties, the Chairman issued case management orders on 18 October 2018 (“Orders”) [p31-37].  The Orders identified the following issues to be determined by the Tribunal (“Issues”):

 

a)       Is the dispute between the parties a “collective employment dispute” under the provisions of Article 5 ERJL (“Article 5 Test”)?  In this regard, the Tribunal will consider:

 

                     i.            whether the employees concerned are represented by a trade union;

                   ii.            if so, whether a collective agreement exists between the trade union and the SEB; and if so,

                  iii.            whether this dispute relates to the terms of employment of one or more employees.

 

b)      If this is a “collective employment dispute”, does the Tribunal have jurisdiction to hear the case under the provisions of Article 22 ERJL (“Article 22 Test”)?  In this regard, the Tribunal will consider:

 

                     i.            whether there is an “available procedure”; and if so,

                   ii.            whether the SEB “unreasonably” refused to comply with such “available procedure” by refusing to proceed to binding arbitration.

 

Background

 

Pension changes

6.       Under the provisions of their individual contracts of employment [p114-119], Members are currently entitled to participate in the existing public sector pension scheme known as the “Public Employees Contributory Retirement Scheme” (“PECRS”). 

 

7.       Following a lengthy consultation period, the States Assembly passed legislation to replace PECRS with a new public sector pension scheme known as the “Career Average Revalued Earnings Pension Scheme” (“CARE”). 

 

8.       CARE came into effect from 1 January 2016 for those public sector employees (including fire-fighters) who commenced employment with the SEB from that date (“New Employees”).   For those public sector employees (including fire-fighters) who were employed before 1 January 2016 (“Old Employees”), CARE will come into effect on 1 January 2019.  Members’ pension provisions will therefore transfer from PECRS to CARE on 1 January 2019.

 

The underlying dispute

 

9.       The FRSA claims that CARE will result in a detriment to Members as they will be required to pay increased contributions and will receive reduced benefits.  The FRSA therefore seeks monetary recompense from the SEB (as the Members’ employer) to offset the reduction in income which it claims Members will suffer when their pension provisions change from PECRS to CARE (“Dispute”).

 

10.   The FRSA made it clear (both at the Hearing and in correspondence with the SEB between April and October 2018) that it:

 

a)       accepts that CARE will come into effect for Members from 1 January 2019;

b)      does not seek to delay the implementation of CARE;

c)       does not seek to change the CARE legislation; and

d)      does not seek any recompense from the CARE pension scheme. 

 

11.   The Tribunal did not hear submissions on the extent to which the change from PECRS to CARE may or may not impact Members and it makes no finding in this regard.  Nor did the Tribunal consider the merits of the Dispute.

 

The FRSA’s Application to the Tribunal

 

12.   The FRSA submits that the Dispute is one which falls within the scope of a ‘fast track resolution procedure’ (or “FTRP”) which is contained in the Collective Agreement.  The SEB has refused to comply with the FTRP (for reasons which are set out below). 

 

13.   In the Application, the FRSA seeks a declaration from the Tribunal that the SEB has failed to comply with the FTRP.

 

14.   The SEB does not dispute that it has failed to comply with the FTRP but submits that it is not required to do so in the particular circumstances of the Dispute.

 

Collective Agreement

 

15.   The FRSA and the SEB entered into the Collective Agreement in 2010 [p106-113] and the parties remain subject to its terms.  The Collective Agreement includes a ‘no impairment of service’ clause (or “NISA”) [p109] which precludes Members from taking strike action in disputes with their employer.  The NISA is considered by the SEB to be necessary because fire-fighters are deemed to provide an essential public service.

 

16.   In return for fire-fighters’ agreement to waive their right to strike under the NISA, the SEB agreed to the FTRP [p111-112], the aim of which was to provide a procedure which both parties would follow to resolve disputes which, in the absence of the NISA, could lead strike action by fire-fighters.

 

17.   The relevant paragraphs of Section 3 of the Collective Agreement [p109] provide as follows:

 

“Section 3 - Collective Procedure

2.         The purpose of this agreement is to set down a framework for the discussion of issues, whether proposed by Management or by the FRSA/ACTSS[1] which involve those aspects of pay, [sic] terms and conditions of service of Fire and Rescue Service's staff represented by the FRSA/ACTSS that are subject to negotiated outcomes as covered by Section 1 of the Terms & Conditions Agreement.

 

3.         It is the aim of this agreement to allow for discussions between the two parties on the exploration of proposals and any differences that may exist. It provides the opportunity for each party to modify the views of the other. Both parties are committed to engaging in open discussions with the aim of establishing common ground. For negotiations (items under Section 1 of the Terms and Conditions Agreement), the parties are committed to operating the procedures described in Section 4 – Fast Track Procedure for the Resolution of Disputes. However, this does not apply in the case of issues of consultation (items under Section 2 of the Terms and Conditions Agreement), over which management are required to seek and consider the views of staff and the FRSA/ACTSS but are not required to negotiate them.

 

No Impairment of Service

4.         The FRSA and its members will not at any time take any industrial action/actions which impairs or may impair the service provided by the [Fire and Rescue Service].  This includes emergency response to incidents, community fire safety activities, fire prevention work and all preparatory activities such as training and equipment maintenance. In return a fast track procedure for the settlement of collective differences has been developed and is set out in Section 4."

 

18.   The relevant paragraphs of Section 4 of the Collective Agreement [p110-112] provide as follows:

 

“Section 4 - Fast Track Procedure for the Resolution of Disputes

General Principles

The following general principles are accepted as paramount:

a)         Where disagreements involve pay, and items covered by Section 1 of the Terms & Conditions Agreement that are subject to negotiated outcomes, the resolution of disputes procedure set out in sections 4, 5 & 6 of this agreement must be followed. The Chief Fire Officer (or his nominee), a representative of the Employment Relations Section, States Human Resources Department, Staff Side Secretary, Fire Service Association, ACTSS (or his nominee) and the President of the FRSA must be involved at all stages of the procedure. [emphasis not added]

b)        

Formal Procedure

1          Stage One – Service Management Level.

The matter will be referred to the Chief Fire Officer (or Nominee Principal Officer) for resolution

2          Stage Two – Department Management Level.

Failing agreement at Stage I, the parties will, within one further week, identify precisely the issue(s) of disagreement by way of a written statement and formally register this disagreement with the Chief Officer of Home Affairs (or his nominee), the Chief Fire Officer (or Nominee), the Head of Employment Relations (or Nominee) the Staff Side Secretary, Fire Service Association, ACTSS, and the President of the FRSA who will meet within one further week with the intention of resolving the dispute. At this meeting, it will be expected that officers from each side of the dispute will attend in order to verbally supplement their respective written cases.

In the event that this meeting fails to resolve the dispute, the matter will be referred to Stage 3 of the procedure.

Note:    If, for any reason, either party refuses to participate in Stage 1 or Stage 2 of the procedure, the other party may refer its statement and supporting case unilaterally to Stage 3 below.

3          Stage Three – States Employment Board

Within two weeks following the failure to agree, the matter will be referred to the States Employment Board who will consider the matter at its next meeting (or at a specially generated meeting if necessary). At this meeting, the President of the Fire & Rescue Service Association (or Nominee) will be provided with an opportunity to present their case with a view to seeking a resolution.

In the event that reference to the States Employment Board fails to produce a negotiated resolution, the procedure will move on to Stage Four below.

4          Stage Four – Conciliation/Mediation – Arbitration

The matter may be referred to conciliation/mediation held under the auspices of the Jersey Advisory & Conciliation Service (JACS). In the event that after conciliation/mediation the dispute remains unresolved, the matter may be unilaterally referred to arbitration organised by, and under the auspices of, JACS. The result of the arbitration will be binding on both parties.

5          Status Quo

During all stages of the procedure, normal service levels will remain in place.…”

 

Terms and Conditions of Service Agreement

 

19.   The Tribunal was only provided with Section 1 of the Terms and Conditions of Service Agreement (“Terms and Conditions Agreement”) [p121-131] (to which the Collective Agreement refers in Section 3 and Section 4).  The issue of ‘pay’ falls within Section 1 of the Terms and Conditions Agreement [p122].  Consequently, disputes which relate to ‘pay’ are considered to be the ‘subject of negotiated outcomes’ under Section 3 of the Collective Agreement.  The parties did not provide a copy of Section 2 of the Terms and Conditions Agreement.  According to Section 3(3) of the Collective Agreement, Section 2 of the Terms and Conditions Agreement relates to issues of consultation (in contrast to Section 1 which relates to issues which are the “subject of negotiated outcomes”).

 

SEB’s alleged breaches of the FTRP

 

20.   The FRSA asserts that the SEB breached the following provisions of the FTRP:

 

a)       that, in breach of Stage 3 of the FTRP, the SEB failed to provide the President of the FRSA with the opportunity to present the FRSA’s case at the relevant SEB meeting.  The SEB did not invite the FRSA President to attend that meeting; and

b)      that, in breach of Stage 4 of the FTRP, the SEB refused to agree to the dispute being referred to binding arbitration.

 

The Law

 

21.   The ERJL sets out the process which a tribunal must follow if asked to issue a declaration (or an order) relating to a “collective employment dispute”.

 

22.   A “collective employment dispute” is defined under Article 5 ERJL (“Article 5 Test”) [p38-39].  For the purposes of the Application, the following sections of Article 5 are relevant:

 

5    “Collective employment dispute”

(1)  In this Law, "collective employment dispute" means a dispute between one or more employers and one or more employees, where –

      (a)        the employee or employees concerned are represented by a trade union;

(b)  a collective agreement exists between the employer or employers and the trade unions; and

(c)  the dispute relates wholly or mainly to one or more of the matter is described in paragraph (2).

       (2) The matters to which this paragraph refers are –

(a)   the terms of employment of one or more employees;

       ….”           

           

23.   Once it has been established that the issue in question relates to a "collective employment dispute, a tribunal must then consider the provisions of Part 4 Article 22 ERJL (“Article 22 Test”) to determine whether it has jurisdiction to determine the issues in question.

 

24.   Article 22 ERJL provides as follows:

 

22   Jurisdiction in respect of collective employment disputes

(1)  Proceedings may be brought before the Jersey Employment Tribunal in respect of a collective        employment dispute –

      (a)        with the consent of each party to the dispute; or

      (b)        at the request of any party to the dispute, in the circumstances described in paragraph (2).

(2)  The circumstances to which this paragraph refers are –

      (a)        that the body or person making the request considers that as far as is practicable all          other available procedures have been applied unsuccessfully to seek to resolve the          dispute; and

      (b)        that a party to the dispute is acting unreasonably in the way in which that party is or is       not complying with an available procedure.

(3)  For the purposes of paragraph (2), a procedure is an available procedure if –

      (a)        it is a procedure for the resolution of the dispute that is contained in a collective     agreement, relevant contract of employment or a relevant handbook for employees;

      (b)        it is a procedure for the resolution of the dispute in accordance with an approved code        of practice; or

      (c)        it is a procedure for the resolution of the dispute that is otherwise established within the      trade or industry concerned by this Law or any other Law.

(4)  In deciding whether or not a party to the dispute is acting unreasonably in the way in which that party is or is not complying with an available procedure in a relevant handbook for employees, regard shall be had to whether or not the handbook has been agreed by or on behalf of the parties to the dispute, but this paragraph does not limit the generality of paragraph (2)(b).

25.   If the Tribunal determines that it has jurisdiction under the Article 22 Test, it may then either issue an order or a declaration in accordance with the provisions of Article 23 ERJL.  In this instance, under the provisions of Article 23 ERJL, the Tribunal may only issue a declaration (and not an order) because the Application has been made without the SEB’s consent.

 

Codes of Practice

26.   In accordance with Article 25 ERJL, the Social Security Minister issued Codes of Practice (“Codes”) to supplement the ERJL [p60-73]. The Tribunal may take the Codes into account in determining any question arising in proceedings before it [p60].

 

27.   Code 3 [p71-73] relates to the resolving of collective employment disputes.

 

28.   The parties did not refer the Tribunal to the Codes during their oral submissions, but the Tribunal considers the following paragraphs to be instructive in relation to what constitutes ‘unreasonable conduct’:

 

Code 3 – Resolving Collective Disputes

3.         Many recognition agreements provide specific procedures to be followed in the case of a ‘failure to agree’ or in the event of some other disputes arising.  Where such agreement exists both sides must take all reasonable steps to complete that procedure before taking any action in respect of the dispute.  Failure to follow an agreed procedure will be regarded as unreasonable conduct.”

Conclusion

Article 5 Test

Is this a ‘collective employment dispute’?

29.   In response to specific questions by the Tribunal, Mr Goudie acknowledged that the first two limbs of the Article 5 Test are satisfied in that:

 

a)       the Members are represented by a trade union; and

b)      a collective agreement exists between the SEB and the FRSA.

 

30.   However, the SEB asserts that the Dispute is not a ‘collective employment dispute’ because the third limb of the Article 5 Test (ie. whether or not the Dispute relates “wholly or mainly” to the terms of employment) is not satisfied.

 

31.   The Tribunal noted that the SEB’s written submissions (filed before the Hearing) suggested that the FRSA was not a party to the FTRP.  In the absence of any detailed submissions on this point, the Tribunal rejects this argument, not least because the drafting of the Collective Agreement (including the FTRP) is clear in its intention that the FRSA be a party to its provisions. 

 

Is the Dispute with the SEB or with the States Assembly?

 

32.   The SEB asserted that the Dispute cannot be a ‘collective employment dispute’ because Article 5 provides that a collective employment dispute must be “between one or more employers and one or more employees”.

 

33.   The SEB asserted that the Dispute is not with the SEB but with the States Assembly because:

 

a)       the root cause of the Dispute is the FRSA’s objection to CARE;

b)      it was the States Assembly and not the SEB which imposed the CARE scheme;

c)       the FRSA is seeking redress for perceived losses caused by the implementation of legislation; and

d)      the States Assembly and the SEB are separate legal entities which cannot be ‘lumped together’.

 

34.   The FRSA asserted that the Dispute is with the SEB and not with the States Assembly because (as set out in paragraph 10 above) the FRSA does not seek to delay the implementation of CARE and accepts that it will come into force on 1 January 2019.  The FRSA asserted that it is “within the gift” of the SEB to resolve the Dispute.

 

35.   Having considered both parties’ submissions, the Tribunal rejected the SEB’s assertion that the Dispute is with the States Assembly rather than with the SEB.  To fall within the perimeter of the Article 5 Test, a dispute simply has to exist between employer and employee.  In this case, the Dispute relates only to the attempt by the FRSA to secure monetary recompense from the Members’ employer (the SEB).  Thus, as soon as:

 

a)       the FRSA made a claim for monetary recompense from the SEB; and

b)      the SEB rejected that demand,

 

a ‘dispute’ existed between the parties.  The root cause of the Dispute (ie. implementation of CARE by the States Assembly) is not relevant for the purposes of the Article 5 Test.

 

Does the recompense sought by the FRSA constitute ‘pay’ for the purposes of the FTRP and/or does it constitute an issue which is the ‘subject of negotiated outcomes’?

 

36.   The Tribunal considered both parties’ submissions (both written and oral) on the question of whether the FRSA’s claim for monetary recompense constitutes ‘pay’ under the Terms and Conditions Agreement. 

 

37.   The FRSA asserted that the claim for monetary recompense amounts to a claim for an increase in “pay”.  By contrast, the SEB asserted that the Dispute does not fall within the scope of the FTRP on the following grounds:

 

a)       the claim for recompense is ‘misconceived’ because the Dispute is an on-going pension dispute (with the States Assembly) rather than a pay dispute (with the SEB).  The recompense sought by the FRSA therefore cannot constitute ‘pay’ under Section 1 of the Terms and Conditions Agreement;

b)      in correspondence, the FRSA identifies the Dispute as relating to “compensation for loss” arising from the introduction of CARE and not relating to “pay” [p141-142].  The SEB asserts that “compensation” is not the same as “pay”; and

c)       the implementation of CARE (and consequently any alleged losses suffered by Members) was the product of a consultation process and was not therefore the “subject of negotiated outcomes” as required under the FTRP.

 

38.   The Tribunal carefully considered all written and oral submissions and carefully considered the Article 5 Test. It was clear to the Tribunal from the submissions that the FRSA is seeking monetary recompense (either by way of an increase in hourly rate of pay or by way of a lump sum payment) from the Members’ employer (the SEB).  The cause of the Dispute was the implementation of the CARE legislation.  However, (and as stated previously), for the purposes of the Application the Tribunal does not accept that the cause of the Dispute is a relevant consideration when applying the Article 5 Test.

 

39.   During the Hearing, the parties used various words to describe the FRSA’s claim, including “compensation”, “pay” and “recompense”.  The parties may seek to attach any label they want to the FRSA’s claim, but the Tribunal makes a finding of fact that the Dispute relates to Members seeking monetary recompense from their employer.  It appears to the Tribunal that once it has been established that the Dispute is:

 

a)       against the SEB (as the employer): and

b)      is for monetary recompense,

 

the Dispute can only be a “pay” dispute and it cannot be a dispute of any other nature when the Dispute exists because employees (the Members) are seeking more money from their employer (the SEB).              

 

40.   Furthermore, the SEB’s assertion (that the Dispute is not the “subject of negotiated outcomes” because there was a consultation) cannot succeed if the Dispute is with the SEB rather than with the States Assembly.  The FTRP is a procedure which the FRSA and the SEB agreed between themselves.  Consequently, references in the Collective Agreement to “consultation” and “negotiated outcomes” relate only to the resolution of disputes between the FRSA and the SEB; they do not relate to disputes which fall outside that relationship.  Therefore, the fact that there was a consultation before the implementation of CARE is not relevant to the question of ‘negotiated outcomes’ because of the Tribunal’s finding of fact that the Dispute is with the SEB and not with the States Assembly. 

 

41.   Accordingly, the Tribunal is satisfied that this is a “pay” dispute which is the subject of “negotiated outcomes” under the provisions of Section 1 of the Terms and Conditions Agreement. 

Is the Tribunal stepping outside its jurisdiction?

42.   The Tribunal does not accept Mr Goudie’s assertions that:

 

a)       the Application “trespasses into the providence of the legislature”; and

b)      for the Tribunal to make a declaration would amount to a “constitutional outrage” because it would “thwart and frustrate the will of the legislature”. 

 

This is a dispute between employees and their employer and the original cause of that dispute (ie. the States Assembly’s implementation of CARE) is not relevant to the Application.  It is not for the Tribunal to consider anything beyond that which is provided by the Article 5 Test.  The Tribunal’s jurisdiction is to consider the Application within the confines of the ERJL.

 

43.   On this basis the Tribunal is satisfied that the Dispute falls within the provisions of Article 5 ERJL and that, consequently, the Dispute is a “collective employment dispute”.

 

Article 22 Test

 

44.   Having established that the Dispute is a ‘collective employment dispute’, the Tribunal must then apply the Article 22 Test (ie. is there an “available procedure” and, if so, was the SEB unreasonable in failing to comply with it?)

 

Is the FTRP an “available procedure”?

 

45.   The Tribunal considered whether the FTRP is an “available procedure” as required under Article 22.  The Tribunal was satisfied that there is an “available procedure” on the following grounds:

 

a)       as addressed above, the Dispute is one which  relates to “pay” and is the “subject of negotiated outcomes”.  It therefore falls within the scope of the FTRP; and

b)      the FTRP is clear and unambiguous (Maindonald v States Employment Board 147/2010).

 

46.   For the reasons stated in paragraph 31 above, the Tribunal rejected the SEB’s assertion that the FRSA is not a party to the FTRP.

 

Is the SEB’s behaviour “unreasonable”?

 

47.   The SEB did not challenge the FRSA’s assertion that, in accordance with Article 22(2)(a), the FRSA had exhausted all other procedures before making the Application

 

48.   Therefore, having established that there is an “available procedure”, the Tribunal is only required to consider whether the SEB acted ‘unreasonably’ in the way in which it failed to comply with the FTRP by (as set out in paragraph 20 above):

 

a)       failing to provide the President with the opportunity to present the FRSA’s case to the SEB meeting; and

b)      refusing to agree to the dispute being referred to binding arbitration.

 

49.   The SEB made written submissions as to why its conduct was not unreasonable [p6-7] and augmented those submissions at the Hearing.  The SEB submitted that Article 22(4) [p55] supports the assertion that the Tribunal should interpret Article 22(2) widely.

 

50.   In summary, the SEB’s submissions as to why the SEB did not act unreasonably are:

 

a)       the content and implementation of CARE is a legislative matter for the States Assembly;

b)      the States Assembly cannot be bound by arbitration and the SEB cannot be liable to compensate or indemnify Members for a legislative decision;

c)       it would be constitutionally inappropriate for the SEB to agree to binding arbitration;

d)      the SEB has no power to delegate policy relating to pensions to an arbitrator;

e)      there are possible wider consequences if a small group of public sector workers “receive a pay rise” when others do not.  This could lead to a ‘tsunami’ of claims and could place CARE in jeopardy;

f)         CARE was the subject of extensive consultation and the proposals were agreed by all unions other than FRSA;

g)    the Members constitute approximately 1% of the entire workforce, being only 33 fire-fighters out of a total membership of the relevant pension scheme which is approximately 9000. A successful claim would “raise the very real spectre of unravelling CARE”

 

h)       CARE already has legislative force, having come into force for New Employees on 1 January 2016; and

i)         SEB is not in breach of the Collective Agreement.

 

51.   The Tribunal considers it relevant that the General Principles under Section 4(a) of the FTRP specify that disagreements which involve pay “must” be resolved through the FTRP.  The Tribunal considers the drafting of Section 4(a) to be clear and unambiguous.

 

52.   As required under Article 26 ERJL, the Tribunal also considered whether the relevant Code of Practice [p60-73] is relevant in determining whether the SEB’s behaviour was unreasonable.  In this regard, the Tribunal noted that the Code of Practice states as follows:

 

“Failure to follow an agreed procedure will be regarded as unreasonable conduct.”

 

53.   Having considered both parties’ submissions, the Tribunal concluded that it was not the intention of the States Assembly that the Tribunal should make expansive decisions as to the potential consequences of a successful application under the FTRP.  The Tribunal therefore rejected all of the submissions which the SEB made (which are summarised in paragraph 50 above) with regards to whether or not its behaviour was “unreasonable”.

 

54.   The Tribunal is satisfied that a party to an “available procedure” behaves “unreasonably” under Article 22(b) ERJL simply by failing to comply with that available procedure unless there are procedural reasons for that failure (eg. the other party has not exhausted earlier stages of the “available procedure”).  The SEB’s fears that by following the FTRP:

 

a)       there may be unpalatable consequences; or

b)      a small percentage of the workforce may be treated differently,

 

are not acceptable grounds to refuse to engage in the agreed procedure.  

 

55.   Consequently, the Tribunal concludes that the SEB acted unreasonably by failing to comply with the FTRP (as outlined in paragraph 20 above).

 

Declaration

In accordance with Article 23(1)(b) ERJL, the Tribunal HEREBY DECLARES that the SEB has failed to observe the provisions of the FTRP, which is an “available procedure” under Article 22 ERJL and which forms part of the terms and conditions of the Collective Agreement. 

 

 

Mrs H G Griffin, Chairman                                                    Date:           4 December 2018

 

 



[1] The Association of Clerical, Technical and Supervisory Staff.  The ‘ACTSS’ is also a party to the Collective Agreement, but this is not relevant to the Application.


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