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Compensation Uplift for Code Breaches (s.207A TULRCA)

Where a claim under a jurisdiction listed in Schedule A2 TULRCA 1992 concerns a matter to which the ACAS Code of Practice on Disciplinary and Grievance Procedures applies, and the employer unreasonably failed to comply with it, the tribunal may, if just and equitable, “increase any award it makes to the employee by no more than 25%” (s.207A(2)). An unreasonable failure by the employee allows a reduction on the same terms (s.207A(3); Holmes v Qinetiq).

Approach. Slade v Biggs [77] sets four stages: is any uplift just and equitable; what percentage, up to 25%; does it overlap with other awards, and what adjustment avoids double counting; and a final check that the sum is not disproportionate in absolute terms. The maximum is for the most serious cases, which need not be exceptional. Where the underlying award is large, ignoring the absolute value of the uplift is an error (Acetrip Ltd v Dogra [102]-[104]).

Which heads. Slade upheld a 25% uplift on the compensatory award, injury to feelings and aggravated damages. Whether it reaches an award for psychiatric injury has not been decided on appeal: in Base Childrenswear Ltd v Otshudi the ET applied 25% across all its non-pecuniary awards, personal injury included, and the point was not appealed. The same failure should not be counted twice: where an unanswered grievance founded both aggravated damages and the uplift, the EAT reduced the aggravated damages (Otshudi).

Scope. Redundancy dismissals are an express carve-out from the Code (Lund v St Edmund's School Canterbury [12]), but an employer cannot escape it by dressing up a conduct or capability dismissal as redundancy, and a sham grievance process engages the Code in its own right (Rentplus UK Ltd v Coulson [30], [53]). A grievance and appeal submitted after dismissal and left unanswered supported a 25% uplift in Otshudi.

Key provision: Trade Union and Labour Relations (Consolidation) Act 1992, s.207A and Sch A2; ACAS Code of Practice on Disciplinary and Grievance Procedures (2015)

Authorities (4)

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