Who should have access to an Investigation Report and can ‘Legal Privilege’ protect the confidentiality of an investigation report?

It is important to be mindful during a workplace investigation of who has access to the investigation report. We have been asked by many clients over the years for advice in relation to the extent to which a report should be shared within the business.

Should the Complainant and Respondent be provided with a copy of the report?

We strongly advocate that a report is shared only with those who have a responsibility to make decisions arising from the report. Why?

Firstly, to maintain confidentiality as far as possible for all parties to the investigation. Secondly, to protect the integrity of your organisations complaint/grievance process.

If reports are more broadly shared, it could have negative consequences for future investigations. Perception that confidentiality is not maintained could see complainants being reluctant to raise a complaint via your internal complaint/grievance process. Witnesses may refuse to participate or severely limit their evidence, having an adverse impact on the investigation process and outcome.

It is essential that complainants and respondents are provided with feedback regarding the findings of an investigation and it is confirmed to them in writing, however they are not required to be provided with a copy of the report unless your organisations policy or procedure specify this requirement.

A recent case heard in the Fair Work Commission highlights an example of where an employee terminated for bullying requested access to an investigation report as part of an unfair dismissal claim. The employer refused on the grounds of Legal Professional Privilege.

What is Legal Privilege?

Legal professional privilege is a rule protecting the disclosure of communications between a lawyer and their client when in the process of providing legal advice.

The case of Kirkman v DP World Melbourne Limited [2016] FWC 605 highlights that when legal privilege is effectively established and maintained the confidentiality of internal documents and advice can be protected from disclosure.

The employer received a complaint of bullying and instructed their lawyers to engage an independent investigator who investigated the complaint and prepared a report on the findings. The claim of bullying was substantiated.

Six months later the employee was dismissed. He filed an unfair dismissal claim requesting a copy of the investigation report and several associated documents to assist his claim. The employer refused, stating the report was legally privileged and the employee disputed the decision.

In this case legal privilege was upheld and the employer was entitled to refuse to provide access to the investigation report on the basis that;

• the investigator was engaged by the employer’s lawyers to assist in preparing advice for the employer;
• the investigators communications were only directed to the lawyers, not the business;
• document control was strictly established and maintained;
• the report was marked private and confidential; and
• the employer had not expressly or impliedly waived privilege over the document, partial disclosure for use in disciplinary discussions in relation to the allegations was permitted.

Interestingly, it was also noted that this was not a case in which the documents were required to be disclosed so that the employee could understand the nature of the allegations of misconduct put against him.The allegations were clearly put to the respondent in writing in the course of the investigation.

Wow – casuals being eligible for redundancy entitlements, being able to bring claims of unfair dismissal…where to next?

Historically casual employment has been described as employment which is intermittent or irregular in nature. We know that this is no longer the case, casual employment has evolved but many organisations often engage casuals because of the presumed ease of this arrangement. However, the pervious 12 months saw some interesting decisions with respect to casual employment that you might want to consider.

Redundancy entitlements have commonly been calculated on the basis of an employee’s part-time or full-time service, casual service did not count. The case of AMWU v Donau Pty Ltd [2016], FWCFC 3075, now changes this paradigm. In a contentious decision, splitting the Full bench 2-1, the FWC  made a ruling that casual service which has been regular and systematic prior to an employee transitioning, without a break in time, to a part-time or full-time role and whose role is subsequently made redundant will have their period of casual service counted for the purposes of redundancy pay. The issue in question for the Full bench was the concept of “continuous service”. Section 22 of the Fair Work Act defines a period of service as a period during which the employee is employed by the employer, but does not include:

• Any period of unauthorised absence; or

• Any period of unpaid leave or unpaid authorised absence (except community service leave or stand down).

The Full bench determined therefore, that a period of service by a regular and systematic casual employee is not identified as one of the exclusions from a period of service in the Act and as such, where this is established, it should count as services for the purposes of calculating redundancy pay.

It should be noted, where the role of a genuine casual is being made redundant, S.123 of the Fair Work Act continues to provide that redundancy provisions do not apply. This decision only relates to situation in which a permanent employee’s role is made redundant and they have transitioned from a casual engagement which can be demonstrated to be regular and systematic in nature.

The ramifications of this are yet to be seen. Given we know the right to request flexible working arrangements or take unpaid parental leave is driven by a service pre-requisite and entitlements to annual leave and paid personal /carer’s leave are also calculated with reference to continuous service, could these be challenged too? We will wait to see. For employers who are seeking to transition casuals who have been utilised in less than an adhoc manner to permanent staff, the Donau decision is something to keep in mind.

Most employers are aware that permanent employees, are entitled to access unfair dismissal provisions under the Fair Work Act when their employment is terminated in circumstances that they believe to be harsh, unjust or unreasonable provided they completed the minimum qualifying period of 6 or 12 months, depending on the size of the organisation. Employers beware, The Fair Work Commission in the matter of Cole, determined that in relation to the minimum qualifying period, a period of service as a casual employee does count towards the employee's period of employment if the employment was on a regular and systematic basis; and the employee had a reasonable expectation of continuing employment by the employer on a regular and systematic basis.

The case of Skene v Workpac Pty Ltd [206] FCCA 3035 highlights a further anomaly with respect to casuals. In this case it was established that an employee can be a casual employee under the terms of an enterprise agreement (and therefore have no entitlement to annual leave under that agreement) yet not be a casual under the Fair Work Act 2009 (FW Act) and therefore entitled to annual leave under the FW Act. In this case, although both the employer and employee believed the employee was a casual and although the employee was paid a casual loading, the Federal Circuit Court ruled that the employee was not in fact a casual. This meant that the employee was entitled to annual leave in addition to his casual loading.

This case sits uneasily with the Fair Work Commission decision in Telum Civil (Qld) Pty Ltd v CFMEU [2013] FWCFB 2434, where a Full bench of the Fair Work Commission held that, where employees are engaged under an industrial instrument, the industrial instrument determines the status of the employee’s engagement. 

In the case of Skene, the employee on commencement of employment signed a “Casual or Fixed Term Employee – Terms and Conditions of Employment” document which set out the casual nature of his employment and that he would be paid a casual loading as such. However, the nature of his engagement saw him working a regular work schedule with regular hours which were all determined in advance. In his determination His Honour Judge Jarrett found that Mr Skene’s employment did not have “the essence” of casual employment but instead had the hallmarks of a permanent employee.

What this case is saying is simply labelling and paying an employee as a casual, in an attempt to deem them a “casual” under a relevant industrial instrument may not be enough. It is evident the courts in to determining whether an employee is truly a casual for the purposes of the Fair Work Act will consider factors including:

• The permanence and regularity of the employee’s roster patterns;
• What an employee is told and what documents they have signed on commencement of their employment, as well as;
• The terms of any relevant EA or Award.

These cases really highlight that organisations need to be certain that their employment arrangements reflect the true nature of an employee’s engagement, or else they may face exposure to a variety of claims they previously sought were exempted by engaging a casual employee.

The Fair Work Commission recently released its first quarterly report on its anti-bullying powers. The report reveals that there were 151 applications to stop alleged bullying at work between January and March this year. All matters were dealt with in the mandatory 14-day period, and the vast majority were resolved without proceeding to a formal decision. Only one application was granted, and you can read the details of that decision in a previous PEEL News.

What is of most interest in the report is the demographic information. It revealed that most applicants were employees (133), most complaints came from those working in large organisations (67), and the greatest number of allegations (109) were against managers.

While 151 seems like a lot of applications, it is heartening to see that very few have progressed to a hearing.  It is also evident from the statistics that where the FWC have become more involved, it has been by way of mediation.

The Report is a good reminder to ensure you:

Here is a link to the FWC Quarterly Report.

Since the introduction of anti-bullying amendments to the Fair Work Act (2009) in January 2014, many have wondered what these changes will mean in practice. What will anti-bullying orders involve? How detailed with they be? We now have our first glimpse of these amendments at work.

Last Friday, the Fair Work Commission handed down its first order to stop bullying in response to an application from an employee (Matter AB2014/1052). While the order does not provide specifics about the situation, it does go into great detail about required behaviours. For example, the respondent is directed to ‘have no contact with the applicant alone’, ‘make no comment about the applicant’s clothes or appearance’, and ‘not send any emails or texts to the applicant except in emergency circumstances’, ‘complete any exercise at the employers premises before 8:00am’, and the applicant is directed to ‘not arrive at work prior to 8.15am’. Such a response indicates that anti-bullying orders are likely to get into the detail and impose operational requirements.  Breaching any such order may lead to penalties of up to $10,200 for individuals and $51,000 for corporations.

Further orders will provide more insight into how the FWC intends to use the anti-bullying amendments, but there are already some important lessons here for organisations, including:

On the 27^th June 2013, the Fair Work Act 2009 was amended to give the Fair Work Commission anti-bullying powers.  They will come into effect on the 1^st January 2014.

What does this mean?

The amendments to the Fair Work Act:

1. Allow workers to apply directly to the Fair Work Commission for an order to stop the bullying. The worker must reasonably believe they are being bullied. There is no income cap restricting those who can apply.
2. Define “bullying at work” to be “repeated unreasonable behaviour by an individual or group of individuals towards a worker (or group of workers of which the worker is a member), where the behaviour creates a risk to health and safety whilst at work”.
3. Require the Fair Work Commission to deal with an application for an order to stop bullying within 14 days of an application being made. In the process, employers and co-workers may be summonsed to attend a hearing or conference, or to produce documents.
4. Give the Fair Work Commission the power to make any order it considers appropriate, other than financial penalties, reinstatement or compensation.

There is no time limit for an employee to make of an application to the Fair Work Commission. The worker needs only to remain in the workplace and still be exposed to circumstances that pose a risk.  Additionally, the worker will not be precluded from commencing other actions under the Fair Work Act such as unfair dismissal or general protection applications.

The first step for the Fair Work Commission before making an order will be to satisfy itself the worker was bullied and there is an obvious risk the bullying will continue. They will consider:

1. The outcome of any prior investigations into the matter.
2. Whether there are any other procedures available to the individual to resolve the grievance and/or dispute.

What could this mean for Employers?

1. There is no requirement for a worker to first raise a bullying concern internally.
2. There will be greater scrutiny and expectation around performance management processes.
3. It will be an imperative to thoroughly document all workplace investigations and ensure they are procedurally fair.
4. The lack of clarity around what constitutes “bullied at work will possibly expose employers to claims arising from social media interactions or as a result of flexible work arrangements that are not clearly defined.
5. This amounts to a new workplace right triggering general protection provisions and increasing exposure to adverse action claims.
6. A order from the Commission may increase the success of workers compensation claims for psychological injury.

What do you have to do to be ready for 1 Jan 2014?

Peel has developed an Action Plan to assist with your preparation for 1st January 2014. Check it out here.

The bottom line is to ensure that all complaints made are responded to quickly and in sufficient detail.

To assist you in the implementation of your action plan you will find a copy of the following document on our website www.peelhr.com.au

·  Draft Code of Practice Preventing and Responding to Workplace Bullying

·  Safe Work Australia Workplace Bullying – Draft -  A Workers Guide

·  A sample investigation file note template

Keep ahead of the change and start implementing steps now. If you require any assistance in relation to workplace investigations or training in Respectful Workplaces feel free to contact us at email@peelhr.com.au or call (02) 4963 7373.

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Debate over the most acceptable method for drug testing has been hot in the industrial environment.  It is a debate that employers, employees and unions alike would like a closing address too.  The advocates of urine testing argue that it is a more cost-effective and accurate method, while those against it say it’s an intrusive method and that oral drug testing has fewer privacy issues.

The recent ruling by Fair Work Australia (FWA) in the ‘Endeavour Energy Case’ has provided some conclusions. This is a landmark case in the context of WHS obligations as the full bench decision may now set a precedent for employers across the country.

To assist you in increasing awareness on these key issues among the leaders within your business, PEEL has developed a LEADERS BRIEF, for distribution by you with details on the ‘background, the decision and the bottom line’.

Is defending an unfair dismissal claim becoming too difficult? A recent research study conducted by Professor Oslington, of the Australian Catholic University and Assistant Professor of Economics, Benoit Freyens, of the University of Canberra, gives weight to this claim. The study conducted by the pair, compared unfair dismissal data under the last three major versions of workplace law. The research highlighted that 17,000 unfair dismissal claims are now being processed each year compared to around 6,000 under Work Choices and 7,000 under the previous Workplace Relations Act. Not only did the research show that unfair dismissal claims are on the rise, but the number of successful claims has also increased.

Specifically the study identified the following:

• Workplace Relations Act (1993 – 2006) 48 per cent of claims were successful, 35 per cent of cases won compensation and 13 per cent of claimants were reinstated in the company
• WorkChoices (2006-2009) Only 33 per cent of cases were successful with 21 per cent of claimants receiving compensation and 12 per cent were reinstated in the workplace
• Fair Work Act (2009 – present) 51 per cent of cases were successful, 42 per cent won compensation with only 8 per cent of claimants returning to their position.

This rise has principally been attributed to two things. Firstly the inclusion of small businesses in the system and secondly, claims being pursued under adverse action, thereby increasing the total number of claims. In considering this research, we need to ask: What does an employer need to do if they only have a 50:50 chance of success? What can be done to mitigate the risk in the first place?

In the majority of cases that come before the tribunals, employers have a valid reason for the dismissal of an employee but time and time again we see employers failing to give reasonable and due consideration to the broader issues. These are issues that can impact on the dismissal being seen by the tribunal as ‘harsh, unjust or unreasonable’. The case of Lambley v DP World Sydney Ltd FWA March 2012 clearly demonstrates this. Mr. Lambley was involved in a physical altercation which took place in the car park of his employer’s premises and he was subsequently dismissed for serious misconduct, resulting in him bringing a claim for unfair dismissal. At the hearing Mr. Lambley claimed he was set up; that in his 30 years of employment with the company he had never had so much as a warning or been involved in any type of altercation. An investigation was conducted by the employer and witnesses gave evidence Mr. Lambley was taunted by the other employee to meet him in the carpark. CCTV was also viewed but appeared to have been tampered with. Whilst the employer agreed the actions of the employee were “out of character”, it stuck to its position of zero tolerance in relation to the behaviour, not wanting to send a message that this type of behaviour was acceptable. FWA however agreed with the employee that the dismissal was “manifestly unjust”. In coming to this decision they gave consideration to broader issues in relation to the case:

• The employees remorse;
• His clean employment record;
• The employee being taunted by the other employee;
• That the behaviour of the employee to react like this was out of character; and
• The fact that the other employee involved no longer worked for the company.

FWA acknowledged that Mr. Lambley had breached policy yet he was reinstated.

As employers we need to be mindful of our broader obligations when making decisions in respect to terminations. Not only to be procedurally fair but to give consideration when there are potentially mitigating circumstances because if they are played out in a tribunal we need to ask, does it have the potential to make the decision appear unfair.

For advice on challenging performance management or potential termination situations, please feel free to contact us or on 02 4963 7373

It's not easy knowing when to mediate and, once you are in there, achieving a successful and sustainable mediation outcome.  Like any other craft there are some tricks and techniques to help you along the way.  Here are some key lessons learnt through our mediation practice that you may find valueable when tackling your next workplace mediation.

• Ensure your mediation outcomes are clear, measurable and achievable.  Vague agreement must be avoided.  Agreements between the parties should be concrete and pinned down with detail so there is a clear understanding about what changes are necessary to restore a productive working relationship.  Dont allow the 'I'm going to be nicer' commitment to wash - it is not a real and sustainable mediation outcome.  Your Mediation Action Plan might look similar to a performance plan - what is the action, who else needs to know about it, how do we measure it, what could impact it and when do we know we have succeeded.
• In a mediation, identify any environmental or systemic change required to re-adjust the workplace in order to prevent the conflict from re-occurring.  Take the opportunity to go beyond the human cause and consider process, system or organisational factors.  Actions to eliminate them will most likely belong to someone outside the immediate mediation, so refer them on.
• Harness the frontline leader in the mediation process.  Gaining an understanding of the conflict or relationship from the frontline leader allows the mediator to have a fuller picture of the conflict prior to commencing the mediation.  Also, click-in again before the end of the process.  With the parties permission, providing the leader with greater detail about the agreements made in the Mediation Action Plan will assist the leader to support the parties in implementing their agreements and taking their ongoing responsibility in managing the relationship.Imparting any insights you have gained into the parties, their interaction and their conflict, will assist the leader in their development in managing workplace conflict -who knows, they might have been a contributing factor!
• Don't initiate mediation if a party is not ready.  By this I mean, when a party is too angry to focus on discussing the issue and being open to the other parties perceptions.  For a meaningful discussion to occur and a change to take affect, the parties need to be open to seeing the conflict through another's eyes and engaging with the other person in a constructive way.  A situation like this might require you to encourage the party to utilise the EAP first or you may commence with a shuttle mediation until the parties have clearly identified their interests and  needs and have moved to be forward focussed.
• Similarly, dont commence mediation if a party is too focussed on wanting to know they are right, that is, wanting vindication.  Mediation does not involve confirming that someone has done the right or wrong thing in a conflict.  It requires an open mind to appreciate or respect, not necessarily agree with, each others perceptions and move forward together with concessions.
• Dont embark on the mediation if a party does not have the nous to have an open and confronting discussion.  It sounds harsh but it takes a degree of communication skill to participate in mediation.  To sit infront of someone who you feel less than comfortable with and talk about how you perceive their interactions and what you intended with yours, is difficult and confronting.  You have a role in developing their communication skills to allow them to participate in the mediation.
• Stop the mediation process if a party disengages.  If a party has lost the willingness to arrive at a mediated outcome, dont continue as you will waste your time and everyone elses and you could risk further damage to the relationship between the parties.

The best and smartest practice is not to be in the spot where you need to mediate.  How can you do this ?

• Build communication skills of your employees.  When people communicate well, they can resolve their own disputes.
• Minimise conflict by reducing behaviours that are potentially damaging.  Train employees in expected standards of behaviour.  This might be part of your generic EEO, Corporate Values training program or a program focussed on behaviours.
• Use your existing resources to support employees in conflict.  Employee Assistance Programs can help employees identify issues at the early part of a conflict, establish expectations and assist employees in understanding their interactions.
• Use a conflict coach to provide more intensive support to an employee.  This may assist the employee to understand the issues in conflict and gain some insight into the conflict.
• Support your frontline leaders in identifying and managing conflict.  They are in the best spot to act early.  They can recognise when a conflict sparks, they know the people involved and will have the best feel for the next step.  Train your frontline leaders to in managing down conflict early and responding to grievances through Grievance Handling training.
• Give your frontline leaders the skills to be a coach to their team members.  Allow them the opportunity to foster a strong relationship with their team.
• Institute post incident/experience learning opportunities between frontline leaders as a measure to consolidate learnings between leaders and identify any systemic change required in the business.
• Dont allow your bullying policy to be a "how to" guide for bullying.  Ensure it emphasises desired conduct and outcomes, is underpinned with your organisational Values and establishes a framework that allows you some involvement in influencing the path for resolution of a conflict (eg an initial triage step).  Also ensure that mediation is an early step in the process not the one that is post complaint or just before an external avenue such as the ADB or FWA.

As the last week of most people’s working year comes upon us don’t be surprised to find some of your employees using social networking sites such as Facebook or Twitter to display their displeasure or air their grievances about their managers, co-workers or the organisation.

There have been a number of cases before Fair Work Australia (FWA) during 2011 that demonstrate that many of the inappropriate actions of employees in relation to social networking have not actually taken place ‘at work’.

In Mr Damian O’Keefe v Williams Muir’s Pty Limited T/A Troy Williams The Good Guys [2011], Mr O’Keefe’s employment was terminated following his highly abusive comments in relation to suffering delays in the payment of a bonus. FWA confirmed the manner in which Mr O’Keefe went about airing his frustrations warranted dismissal and his approach to making the comments via his home computer and out of work hours did not make a difference.

 Issues taken into consideration by FWA were:

• The public nature of the comments, even though he made them to his ‘Facebook friends’, many of them were work colleagues.
• The abusive and threatening language breached the company’s values of courtesy and respect.
• There were other avenues in which his grievance could have been aired within the company and these were known to him.
• The comments were detrimental to the employers business.

 It is important to know that in certain circumstances you have the capacity to terminate an employee’s employment or to manage their performance for out-of-hours conduct. To be on sure footing here, what must be established is a sufficient link between the conduct and the employment relationship. For example you must be able to establish that the conduct:

• is likely to cause serious damage to the relationship between the employee and employer.
• damages the employer’s interests, or
• is incompatible with the employee’s duties as employee.

Warnings should be taken from the FWA Full Bench decision in Dianna Smith T/A Escape Hair Design v Sally-Anne Fitzgerald [2011].  That decision demonstrates the limitations in terminating an employee for conduct outside of work. The employee expressed her annoyance on Facebook at receiving a lesser bonus than she expected and receiving part of her holiday pay by cheque. She posted the comment: “Xmas ‘bonus’ along side a job warning, followed by no holiday pay!!!! Whoooooo! The Hairdressing Industry rocks man!!! AWESOME!!!” FWA held that whilst the comments were foolish, they were inaccurate and the employee had not named the salon. FWA held that the Facebook comments could not be considered to be detrimental to the employer's business and as such there was no valid reason for dismissal.

 In reflection of these cases it is imperative that organisations take steps to ensure that they have in place clear, transparent and enforceable social networking policies and strategies.

Advice for employers:

• Ensure you have a social networking policy that addresses:
  • Use during work hours
  • Use outside working hours
  • Use through employee’s own technology
  • How employees can use the sites
  • List specific inappropriate uses
  • Monitoring of employees’ access
  • The consequences for non-compliance
• Update other relevant policies such as recruitment, discrimination/bullying and IT policies to reflect the use of social media.
• Consider including in employment contracts specific clauses in relation to social media.
• Ensuring induction programs cover the use of social media and the related policies.
• Providing training and awareness sessions when policies are updated.
• Ensure grievance and investigation training is provided for line managers and HR staff to ensure procedural fairness is always applied.

Where there is a breach:

• Consider whether there is a sufficient link between the conduct and the employment relationship before taking any disciplinary action.
• Take into account the surrounding circumstances, including the employee’s length of service, previous performance or disciplinary issues, reasons given, and whether there was a clear policy in place at the time of the incident.
• Don’t make the decision to terminate before all relevant information has been gathered and considered - thoroughly investigate issues, and ensure procedural fairness is afforded when performance managing, or considering the termination of, an employee for the inappropriate use of social media.

For more information on how we can assist you with your organisational policies, employment contracts or staff training feel free to contact us or in the office on: 49 63 73 73

All Human Resource (HR) practitioners love those golden managers who effectively work with their people to illicit the necessary discretionary performance. While we can be fantastic at developing great HR policies and infrastructure it means nothing unless the business has good people leaders in place.

The best HR policies may encourage performance however it is the people leaders who will determine their effectiveness depending on the strategy they take. There is no one right strategy for all situations. People leaders must be equipped with an array of strategies that they can draw on to assist them in managing performance in the workplace, including skills related to:

• Giving feedback;
• Setting objectives;
• Counselling;
• Coaching;
• Conflict resolution; and
• Conducting disciplinary meetings

There will be times when despite the efforts of line managers, underperformance continues or misconduct issues arise and it is expected that line managers will play a role in formalised disciplinary procedures.

If an employee is terminated at the conclusion of a managing for performance process and they claim they have been unfairly dismissed, they must be able to establish to Fair Work Australia (FWA) that the dismissal was harsh, unjust or unreasonable. In considering this FWA will look at:

• Whether there was a valid reason for the dismissal, such as the employee’s performance or conduct;
• Whether the person was notified of that reason;
• If the dismissal related to unsatisfactory performance, whether the employee had been warned about that unsatisfactory performance before the dismissal; and
• Any other matters that FWA considers relevant.

The recent judgment of the Full Bench of FWA in Parmalat Food Products Pty Ltd v Kasian Wililo, has highlighted that the existence of a valid reason is pivotal to an employer's ability to succeed in defending unfair dismissal claims. The Full Bench of FWA said it is the primary consideration.

The Full Bench also highlighted the importance of complying with the procedural justice requirements, setting out that where such compliance is combined with a valid reason for dismissal "it would only be if significant mitigating factors are present that a conclusion of harshness is open".

As such, people leaders who play a critical role in this process should be afforded the opportunity to understand the legal considerations that apply when it gets to this stage on the performance management spectrum. A good practice is also to involve the people leader throughout the escalation process when a performance management issue becomes contested and to review cases with the people leaders generally when HR or an external consultant become involved.

Peel HR has developed a new “Managing for Performance” program that is aimed at building the confidence of line managers in applying various performance management techniques.  The scope of the program is to develop practical skills in performance management with a focus on addressing and realigning poor performance.

For more information on this program please feel free to contact us or by phoning: 02 4963 7373

Danielle Carney
Principal Consultant