1
Fair Work Act 2009
s.394—Unfair dismissal
Shaleen Charan
v
Lamson Concepts Pty Ltd
(U2024/6718)
DEPUTY PRESIDENT GRAYSON SYDNEY, 27 SEPTEMBER 2024
Application for an unfair dismissal remedy -jurisdictional objection - genuine redundancy -
application dismissed.
[1] Ms Charan was employed as a Senior Accountant by Lamson Concepts Pty Ltd
(Lamson) from 30 October 2023 until 24 May 2024. Lamson contends that Ms Charan’s
dismissal was a genuine redundancy within the meaning of s 389 of the Fair Work Act 2009
(Cth) (Act). Ms Charan contends that her dismissal was not a genuine redundancy and was
harsh, unjust and unreasonable.
[2] After taking into account the views of the Applicant and the Respondent and whether a
hearing would be the most effective and efficient way to resolve the matter, I considered it
appropriate to hold a hearing for the matter (per s.399 of the Act). I heard Ms Charan’s unfair
dismissal case against Lamson in the Fair Work Commission (Commission) at Sydney on 3
September 2024. Ms Charan gave evidence at the hearing and also relied upon a bundle of
documents. Lamson adduced evidence from Ms Kathryn MacMillan, a Human Resources
Advisor employed by Circle Recruitment and HR, who had been involved in the dismissal of
Ms Charan on behalf of Lamson and Ms Kate Kershaw, Managing Director of Lamson. Lamson
also relied upon a number of documents in support of its case.
Initial matters to be considered
[3] Section 396 of the Act sets out four matters which I am required to decide before I
consider the merits of the Application.
[4] There is no dispute between the parties, and I am satisfied on the evidence that:
(a) Ms Charan’s application was made within the period required in s 394(2) of the
Act;
(b) Ms Charan is a person protected from unfair dismissal; and
(c) Lamson was not a ‘small business employer’ as defined in s 23 of the Act and, as a
result, the Small Business Fair Dismissal Code does not apply to Ms Charan’s
dismissal.
[2024] FWC 2708
DECISION
AUSTRALIA FairWork Commission
[2024] FWC 2708
2
[5] In relation to the final initial matter which I am required to consider, Lamson contends
that Ms Charan’s dismissal was a genuine redundancy and Ms Charan disputes this.
Accordingly, I must decide this question before I consider the merits of the application.
Genuine Redundancy
[6] Section 389 of the Act defines genuine redundancy as follows:
389 Meaning of genuine redundancy
(1) A person’s dismissal was a case of genuine redundancy if:
(a) the person’s employer no longer required the person’s job to be performed by anyone
because of changes in the operational requirements of the employer’s enterprise; and
(b) the employer has complied with any obligation in a modern award or enterprise
agreement that applied to the employment to consult about the redundancy.
(2) A person’s dismissal was not a case of genuine redundancy if it would have been reasonable
in all the circumstances for the person to be redeployed within:
(a) the employer’s enterprise; or
(b) the enterprise of an associated entity of the employer.
[7] ‘Associated entity’ has the meaning given by s 50AAA of the Corporations Act 2001
(Cth).
The employer no longer required the employee’s job to be performed by anyone because
of changes in the operational requirements of the employer’s enterprise (s 389(1)(a))
[8] It is necessary to determine whether Lamson no longer required Ms Charan’s job to be
performed by anyone because of changes in the operational requirements of Lamson’s
enterprise.1
[9] A job involves ‘a collection of functions, duties and responsibilities entrusted, as part
of the scheme of the employer’s organisation, to a particular employee’.2 Where there has been
a reorganisation or redistribution of duties, the question is whether the employee has ‘duties left
to discharge’.3 For example, an employer may redistribute all the tasks done by a particular
person between several other employees, resulting in the person’s job no longer existing.
[10] An employee’s job may be genuinely made redundant when the employee’s duties, or
aspects of them, are still being performed by other employees.4 The test is whether the job
previously performed by the employee has survived the restructure or downsizing, not whether
the duties have survived in some form.5
[11] The reference to ‘changes in the operational requirements of the employer’s enterprise’
in s 389(1)(a) of the Act includes circumstances where an employer restructures its business to
reduce costs or improve efficiency, productivity, sales, revenue or some other aspect of
performance.6 The operational circumstances of a business which may result in a redundancy
are in the direct knowledge of the employer. The evidentiary onus is on the employer to provide
direct evidence about the nature of the employee’s job and why it is no longer required to be
performed as a result of changes in the operational requirements of the employer’s enterprise.7
[2024] FWC 2708
3
Relevant facts – job no longer required because of changes in operational requirements
[12] Lamson is a materials handling business, with their major product being pneumatic
tubing, which they also configure and install for clients. Those clients are in the retail,
healthcare, aged care, hospitality, commercial and government sectors.
[13] Ms Charan worked in the Finance Department along with approximately three other
employees who reported to her. Whilst there was some contest about the extent that she had
been required to review and improve internal controls within the Finance Department and
control environment her role was largely as set out in her position description and consisted of
overseeing all of the aspects of the finance and accounting functions of Lamson including:
(a) Preparation and management of financial and management reporting (including
monthly and yearly general ledger reconciliations, month end processes involving bank
reconciliations, recurring journals, warranty provision calculations, revenue recognition
and cost allocations, fixed asset registers with depreciation calculations, monthly sales
invoicing reports, monthly management reports, weekly accounts reports, and other ad
hoc reports as required); and,
(b) Managing taxation and statutory reporting including PAYG withholding, BAS returns,
FBT returns and preparing and lodging payroll taxes and superannuation.
[14] At no time have any concerns been raised regarding Ms Charan’s performance in this
role.
[15] Lamson relied on a number of reports in support of its deteriorating financial situation.
There was no serious challenge to the difficult financial circumstances disclosed by these
reports. Lamson have observed a significant increase in salaries and wages expenses by more
than 25%, from $5.8 million in FY2022 to $7.3 million in FY2024. The sales order intake over
the same period has decreased by almost 28%, from $11.8 million to $8.45 million. Ms Kershaw
gave evidence for Lamson, which I accept, that sales revenue from retail markets was expected
to decline significantly by more than 36% from $3.1 million in FY2024 to $2 million in
FY2025. The anticipated decline in sales is partly attributable to a move away from using cash
and the consequent decrease in the need for pneumatic tubing for cash transactions. These
matters were anticipated to further negatively affect Lamson’s future cashflow. In addition,
there has been increased competition in the pneumatic tube market recently, placing Lamson
under significant pressure in sustaining its financial viability.
[16] Lamson has enacted various cost-cutting measures to address these commercial
pressures, including downsizing its head office and other premises, and reducing other costs
including telephone costs. Ms Kershaw gave evidence that Lamson had considered numerous
options to possibly mitigate the financial impacts identified above including reviewing its major
operating expenses to identify any opportunities for cost savings in rent, car running costs,
information technology and insurance premiums. It had also been searching for any alternative
products to replace the cash tube systems, however, it had been unsuccessful in finding any
suitable products that could offset the reduction in retail sales. Lamson have hired one
additional sales team member to seek to increase sales revenue by looking at any upselling
[2024] FWC 2708
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opportunities in the healthcare market. However, it had identified very little room for any
further cost savings or measures to address Lamson’s ongoing financial situation.
[17] As a result, Lamson made the decision to look further into increasing the sales team to
focus on other products, reducing the additional costs of contractors in the maintenance and
installation teams, and potentially outsourcing the Finance Department.
[18] In or around early May Lamson engaged Ms MacMillan to facilitate consultation with
the employees who were potentially affected including Ms Charan. On Friday 17 May 2024,
Ms Kershaw sent an email to Ms Charan and all other members of the Finance Department
titled ‘Potential Restructure’. That email included an invitation to a team meeting with Ms
Kershaw and Ms Macmillan scheduled to occur at 1:00 PM on Monday, 20 May 2024. Shortly
following the sending of that email, Ms Charan found that she was unable to access Lamson’s
bank logins. Ms Charan’s access to Lamson’s bank logins was reinstated in the morning of 20
May 2024.
[19] At a meeting on 20 May 2024, Ms Charan and her team were informed that, as a result
of a decline in sales orders, that Lamson would be restructuring the Finance Department and
that Ms Charan and her team were at risk of redundancy.
[20] On 20 May 2024, the Respondent wrote to Ms Charan as follows:
Lamson representatives, accompanied by our HR advisors from CIRCLE HR, will be meeting
on an individual basis with each employee whose position may be made redundant. During these
meetings, each employee will be provided with an opportunity to respond to the decision to
select them for possible redundancy, raise any measures they consider might be taken to avoid
their position being made redundant or mitigate its effect, and raise any possible alternatives to
their employment with Lamson being terminated as a consequence. Please feel free to bring a
support person to any meetings.
We would like to meet with you on 21st May 2024 at 3:15 PM to consult with you further, and
hear your feedback on this situation. The meeting will be conducted via Teams.
[21] Following the meeting of 20 May 2024, a number of meetings were scheduled between
Ms Charan, Ms Kershaw and Ms MacMillan. Ms Charan did not attend these meetings for a
number of reasons including that she was unwell, had a medical certificate, that she didn’t have
access to the office, had made an appointment during her scheduled lunch break which
coincided with the time of the meeting, or needed rest. Ultimately, the Respondent asked Ms
Charan to send any feedback regarding the restructure and possible redundancy of her role in
writing.
[22] By emails sent on 23 May 2024 Ms Charan provided the Respondent with her feedback
following the meeting to discuss the restructure. Ms Charan’s email indicated that she sought
further details about the alternatives to redundancy that Lamson had evaluated prior to deciding
to restructure the Finance Department, and queried why Lamson did not conduct any
preliminary discussions with the Finance Department prior to 20 May 2024. Ms Charan also
questioned why the Finance Department had been selected for redundancy and no other Lamson
department. Ms Charan sought clarification about her current responsibilities, saying that it was
important to know who would be in charge of bank reconciliations, BAS lodgements, and end-
[2024] FWC 2708
5
of-month payroll journals in the event she was made redundant, and inquired as to whether (and
why) the outsourcing of those functions would result in cost savings.
[23] On 24 May 2024 Ms Charan met with Ms Kershaw and Ms MacMillan. At the meeting
the Applicant’s feedback of 20 May 2024 was discussed, the rationale for restructuring the
Finance Department was explained and Ms Charan was told that no suitable redeployment
opportunities had been identified. Ms Charan was advised that she was not being retrenched
due to any performance-based factors but due to a decision to outsource the entire Finance
Department. Ultimately, Ms Charan was advised that her position had been made redundant,
that she would be provided a career coach, and paid one week in lieu of notice and entitlements.
[24] On 24 May 2024 the Respondent wrote to Ms Charan formally terminating her
employment. During the week ending 24 May 2024 all employees of the Finance Department
were made redundant.
[25] Ms Kershaw gave evidence, which I accept, that all of the work, tasks and functions of
the Finance Department, including the duties and work previously performed by Ms Charan,
are now being performed by an Australian company with employees engaged in the Philippines.
She gave evidence, which I accept, that the tasks of Ms Charan’s role, including the statutory
compliance tasks, bank reconciliations and forecasts can and are being performed by the
outsourced provider, and that she is not performing the duties or role of Senior Accountant. Ms
Kershaw also deposed that the outsourcing decision has decreased the costs of the
Finance/Accounting function of Lamson by approximately 50%. Ms Kershaw was not cross-
examined on this evidence.
Summary of submissions – job no longer required because of changes to operational
requirements
[26] Ms Charan submits that her role must still be required to be performed due to the
fundamental statutory compliance aspect of her duties. She contends that her duties have not
disappeared and Ms Kershaw must be performing some of the duties.
[27] Ms Charan contends that the business factors relied on by Lamson to justify its decision
to outsource the Finance Department, including her role, are flawed as other measures could
have been identified to reduce costs or increase sales if she, or her team, had been consulted
earlier and in circumstances where Ms Charan claims that Lamson’s niche business remains
stable.
[28] Lamson contend that rising costs, the impact of a long and declining revenue cycle,
decreasing sales and a poor forecast due to a move to a cashless, digital society, resulted in a
decision being made to outsource the Finance Department as a cost reduction strategy. As a
result, Lamson no longer needed Ms Charan’s job to be performed by anyone.
Consideration – job no longer required because of changes to operational requirements
[29] In Schneider v Apollo Motorhome Holidays Pty Ltd [2015] FWCFB 1259, the Full
Bench succinctly said at [28]:
https://www.fwc.gov.au/documents/decisionssigned/html/2015fwcfb1259.htm
[2024] FWC 2708
6
In determining whether a dismissal is a ‘genuine redundancy’ the Commission is concerned
with whether the employer no longer required the person’s job to be performed by anyone
‘because of changes in the operational requirements of the employer’s enterprise’. A decision
by an employer to outsource all of an employee’s duties is clearly a redundancy.
[30] The reference to having the job no longer performed by ‘anyone’, must mean by anyone
employed by the business.8 I find that the duties undertaken by Ms Charan do not continue to
exist at Lamson. I am satisfied that some of these tasks were performed by Ms Kershaw for a
short period following Ms Charan’s dismissal while the outsourcing was operationalised.
However, these duties are now being undertaken by employees working for the outsourced
entity. In any event, the test is not whether the duties continue to be performed. The test is
whether the job that Ms Charan was working in is no longer required to be performed by
anyone.9 The evidence demonstrates to my satisfaction that Lamson no longer required the job
being performed by Ms Charan, Senior Accountant, to be performed by anyone after 24 May
2024.
[31] The second element of s 389(1)(a) is a question of causation: did changes in the
operational requirements of the employer’s enterprise cause the employer to no longer require
Ms Charan’s job to be performed by anyone? I consider, based on the evidence before me, that
they did.
[32] Ms Kershaw gave evidence that there had been a decline in the use of pneumatic tubing
for cash transportation due to the broader societal shift towards digital and cashless transactions.
This shift is indisputable. It was said that traditional methods of cash handling and
transportation were becoming increasingly obsolete. Pneumatic tubing for cash handling is a
core part of Lamson’s business. Ms Kershaw gave evidence, which I accept, that sales order
intake had been declining significantly since 2022 (by approximately 28%) and that this would
affect sales revenue over the coming years. In addition, salaries and related costs have increased
significantly. This downturn in business led Lamson to investigate or implement various cost
reduction measures, to investigate potential alternative products to market and to implement
other measures to increase sales revenue. One of the costs savings measures identified and
ultimately implemented was the outsourcing of the entire Finance Department. As I have
described, Ms Kershaw gave evidence that this had resulted in costs savings of approximately
50% to date.
[33] I do not accept Ms Charan’s contention that the business factors relied on by Lamson to
justify its decision to outsource the Finance Department, including her role, are flawed as
alternatives could have been suggested if the Finance Department had been consulted with
earlier and as Lamson’s niche business remains stable. Ms Charan did not lead any evidence to
support this contention. In any event, I accept the evidence of Ms Kershaw that the business
was not stable as sales had been declining and revenue would likely continue to decline. I also
consider, based on the evidence, that Lamson had considered and implemented a number of
options to improve its financial position prior to deciding to restructure its business. Ms Charan
did not lead any evidence as to what measures she could have identified to reduce costs or
increase sales that may have averted the need for a redundancy. Ms Charan asserted that had
Lamson consulted with her earlier, she may have been able to provide alternatives to the
redundancy, but when pressed, Ms Charan did not identify (nor did any of her evidence
disclose) what alternatives she would have proposed. I find that Lamson’s decision to make Ms
Charan’s position redundant as a result of economic and business factors is supported by reports
[2024] FWC 2708
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filed by Lamson and the evidence of Ms Kershaw. I also take judicial notice of the fact that
traditional methods of cash handling are in decline and likely to become even less prevalent, as
society moves to digital and cashless transactions.
[34] I am satisfied on the evidence that the decision to outsource the Finance Department and
make Ms Charan’s role redundant was based on the business and economic factors deposed to
by Ms Kershaw.
Conclusion – job no longer required because of changes to operational requirements
[35] Based on the evidence and for the reasons discussed above, I am satisfied, on the balance
of probabilities, that Lamson no longer required Ms Charan’s job to be performed by anyone
because of changes in the operational requirements of Lamson’s enterprise.
Compliance with any consultation obligation in a modern award or enterprise agreement
that applied to the employment (s 389(1)(b))
[36] Ms Charan contended that Lamson had not adequately consulted with her in relation to
her redundancy. Her main concern was that Lamson had failed to consult with her prior to
deciding to outsource the work of the Finance Department. However, she also raised concerns
that the consultation process was ‘rushed’ and that Lamson had decided to terminate her
employment prior to the completion of consultation in circumstances where it did not furnish
her with sufficient information to enable her to influence that decision.
[37] For there to be a genuine redundancy within the meaning of s 389 of the Act, Lamson
must have complied with any obligation in a modern award or enterprise agreement to consult
about the redundancy.
[38] Ultimately there was no dispute between the parties that Ms Charan was not covered by
any award or any enterprise agreement during the relevant period, and I am satisfied as to this
matter. Accordingly, Lamson was not required to consult with Ms Charan in relation to her
redundancy to meet the requirements of s 389(1)(b) of the Act.
[39] Ms Charan raised multiple, serious concerns regarding the consultation process
conducted by Lamson. If no consultation provisions apply from a modern award or enterprise
agreement, then this will not be a consideration in relation to whether a dismissal is found to be
a genuine redundancy within the meaning of the Act. Ultimately, broader issues of deficient
consultation are not relevant when determining Lamson’s jurisdictional objection, because they
go to the merits of the claim that the Applicant was dismissed harshly, unjustly or unreasonably.
Whether reasonable in all the circumstances for the person to be redeployed (s 389(2))
[40] For the purposes of section 389(2) of the Act, the Commission must consider whether
there was a job or a position or other work within the employer’s enterprise (or that of an
associated entity) to which it would have been reasonable in all the circumstances to redeploy
the dismissed employee. There must be an appropriate evidentiary basis for such a finding.10
The word ‘redeployed’ in section 389(2) of the Act should be given its ordinary and natural
meaning, which is to ‘transfer to another job, task or function’.11
[2024] FWC 2708
8
[41] If an employer wishes to rely on the ‘genuine redundancy’ exclusion in s 389 of the Act,
then it would ordinarily be expected to adduce evidence, on the question of redeployment, as
to whether there was a job or a position or other work within the employer’s enterprise (or that
of an associated entity) to which it would have been reasonable in all the circumstances to
redeploy the dismissed employee. Such evidence would usually include the steps taken by the
employer to identify other jobs, positions or work which could be performed by the dismissed
employee.12
[42] Whether it would have been reasonable in all the circumstances for the person to be
redeployed directs attention to the circumstances which pertained when the person was
dismissed.13
[43] In determining whether redeployment would have been reasonable a number of matters
may be relevant, including:
(a) Whether there exists a job or position or other work to which the employee can be
redeployed;14
(b) The nature of any available position;15
(c) Qualifications required to perform the job;16
(d) The employee’s skills, qualifications and experience. The employee should have
the skills and competence required to perform the role to the required standard
either immediately or within a reasonable period of retraining;17 and
(e) The location of the job in relation to the employee’s residence and the remuneration
which is offered.18
[44] It is important, however, to appreciate that, because there is a requirement to assess the
reasonableness of redeployment ‘in all the circumstances’, it is not possible to establish binding
or decision rules concerning the application of section 389(2) of the Act in all cases; the
circumstances of each particular case must be considered.19
Consideration – redeployment
[45] I am satisfied that it would not have been reasonable in all the circumstances for Ms
Sharan to be redeployed within Lamson’s enterprise, or an enterprise of an associated entity of
Lamson, for the following reasons:
(a) Lamson looked into all other areas for re-employment/redeployment within Lamson and
was not able to identify any other suitable roles for Ms Charan;
(b) Lamson invited employees to consider solutions and suggest possible alternative
outcomes to mitigate the possible redundancy of their positions, with a view to
discussing those ideas and possible re-employment/redeployment opportunities within
Lamson;
(c) Ms Charan elected not to express an interest in any opportunity for redeployment;
(d) Ms Charan is a Chartered Accountant and employed in the senior, specialised
professional role of Senior Accountant within the Finance Department of Lamson
reporting to the Managing Director, Ms Kershaw;
(e) The work of the whole of the Finance Department had been outsourced to a third party;
[2024] FWC 2708
9
(f) Ms Charan accepts, and I am satisfied, that there were no positions or other work to
which she could have been redeployed given her seniority, skills and qualifications;
(g) a role of Admin Assistant was advertised just prior to Ms Charan’s dismissal and this
role may have been vacant at the time of her dismissal. This role was paid approximately
$60,000 per annum plus superannuation, less than half of Ms Charan’s salary. Ms
Charan accepts, and I am satisfied, that she was overqualified for this position.
(h) I accept the evidence adduced on behalf of Lamson that there were no available
positions or roles suitable for Ms Charan, in light of her skills, experience and
qualifications.
Conclusion – redeployment
[46] For the reasons given above, I am satisfied that it would not have been reasonable in all
the circumstances for Ms Charan to have been redeployed within Lamson’s enterprise or an
enterprise of an associated entity of Lamson.
Conclusion – genuine redundancy
[47] I have found that Ms Charan’s job was no longer required to be performed by anyone
because of changes to the operational requirements of the business, that no consultation
obligations in an applicable modern award or enterprise agreement applied to the dismissal, and
that it would not have been reasonable to redeploy Ms Charan in all the circumstances.
Accordingly, I am satisfied that Ms Charan’s dismissal was a case of genuine redundancy
within the meaning of s 389 of the Act. It follows, by reason of s 385(d) of the Act, that Ms
Charan was not unfairly dismissed. Because Ms Charan’s redundancy was genuine within the
meaning of s 389 of the Act, I do not have the power to consider whether her dismissal was
unfair in the broader sense.
[48] For the reasons given, I dismiss Ms Charan’s application for relief from unfair dismissal.
An order will issue to this effect with this decision.20
[49] With this being said, I make the following observation with respect to the duration of
the consultation process. At most, the consultation process spread across one week - from the
late Friday afternoon communication that there was going to be a discussion about redundancies
the following Monday, to the time that Ms Charan was informed that she was dismissed due to
her role being made redundant. The timing of the initial communication was unfortunate and, I
accept, left Ms Charan feeling anxious. During the one-week period that followed, Ms Charan
was obviously deeply stressed about being made redundant on short notice. This is
understandable, especially given her personal circumstances and carer’s commitments. Whilst
ultimately, I cannot determine the merits of Ms Charan’s dismissal, I note that I consider that
Ms Charan would have benefitted from a longer consultation process where she was more
fulsomely engaged, felt less pressured, and given more time to process her potential
retrenchment.
[2024] FWC 2708
10
DEPUTY PRESIDENT
Appearances:
Ms S Charan on her own behalf.
Ms K MacMillan on behalf of the Respondent.
Hearing details:
2024.
Sydney.
3 September.
Printed by authority of the Commonwealth Government Printer
PR779750
1 Section 389(1)(a) of the Act.
2 Jones v Department of Energy and Minerals (1995) 60 IR 304 (Jones) at 308 per Ryan J; applied in Ulan Coal Mines
Limited v Howarth [2010] FWAFB 3488; (2010) 196 IR 32 (Ulan Coal 1) at [17].
3 Ibid.
4 Dibb v Commissioner of Taxation (2004) 136 FCR 388 at 404-5.
5 Kekeris v A. Hartrodt Australia Pty Ltd [2010] FWA 674 at [27] per Hamberger SDP.
6 Nettlefold v Kym Smoker Pty Ltd [1996] IRCA 496 at p. 373.
7 Kieselbach v Amity Group Pty Ltd PR973864 [34].
8 See the discussion by the Full Bench in Shop, Distributive and Allied Employees Association v Bunnings Building Supplies
Pty Ltd t/as Bunnings Warehouse AIRC PR949303, 15 July 2004 per Harrison SDP, Ives DP and Cribb C at [21].
9 Kekeris v A. Hartrodt Australia Pty Ltd [2010] FWA 674 at [27] per Hamberger SDP.
10 Technical and Further Education Commission T/A TAFE NSW v Pykett [2014] FWCFB 714; (2014) 240 IR 130 (TAFE) at
[36].
11 Ibid at [25].
12 Ibid at [36]-[37]; Teterin & Ors v Resource Pacific Pty Limited t/a Ravensworth Underground Mine [2014] FWCFB 4125;
(2014) 244 IR 252 (Teterin) at [28]-[29].
13 TAFE at [24] & [35]; Ulan Coal Mines Ltd v Honeysett [2010] FWAFB 7578; (2010) 199 IR 363 (Ulan Coal 2) at [28].
14 Ulan Coal 2 at [28].
15 Ibid at [28].
16 Ibid at [28].
17 Ibid at [28] & [34].
18 Ibid at [28].
19 Teterin at [35].
20 PR779751.
MISSION THE WORK CO THE FAIR WORK CON
https://www.fwc.gov.au/documents/decisionssigned/html/2010fwafb3488.htm
https://www.fwc.gov.au/documents/decisionssigned/html/2010fwa674.htm
https://www.fwc.gov.au/documents/decisionssigned/html/pr973864.htm
http://www.fwa.gov.au/alldocuments/PR949303.htm
https://www.fwc.gov.au/documents/decisionssigned/html/2010fwa674.htm
https://www.fwc.gov.au/documents/decisionssigned/html/2014fwcfb714.htm
https://www.fwc.gov.au/documents/decisionssigned/html/2014fwcfb4125.htm
https://www.fwc.gov.au/documents/decisionssigned/html/2010fwafb7578.htm
https://www.fwc.gov.au/documents/awardsandorders/pdf/pr779751.pdf
